FCA Policy Statement PS18/20 introduced a new requirement that all Pension Transfer Specialists (PTS) must hold the Level 4 qualification for providing advice on investments as defined in the Retail Distribution Review (RDR), before they can advise on or check pension transfer advice.
The rationale behind this was that, while a PTS may not always be giving the investment advice, they do need to be able to identify whether, in the context of overall suitable pension transfer advice, a proposed scheme and investment is consistent with a client’s needs and objectives for a proposed transfer. It was intended that PTSs should acquire the additional qualification by October 2020. . In April 2020, the deadline for passing this qualification was extended to 1 October 2021 due to Covid-19.
That deadline has now passed and individuals cannot continue to operate as a PTS unless they have attained the required qualification.
Each PTS must also be maintaining the additional CPD requirements that have applied to PTSs since 1 October 2020. These are summarised below.
PTSs must undertake a minimum of 15 hours CPD each year, focused specifically on pension transfer advice. This is in addition to any other existing CPD requirements that an adviser may need to meet for other types of advice.
The rules require that 9 of the 15 hours will need to be structured learning, while the remaining 6 hours may be unstructured.
Examples of structured continuing professional development activities include …
- participating in courses
- web-based seminars or e-learning
… which require a contribution of thirty minutes or more.
Examples of unstructured continuing professional development activities include:
- conducting research relevant to the individual’s role
- reading industry or other relevant material
- participating in professional development coaching or mentoring sessions
At least 5 of the 15 hours must be provided by an independent provider external to any firm that employs or contracts services from the PTS. Firms must ensure that external CPD is delivered by organisations or individuals who are not associated with or influenced by the firm’s own view.