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Version 2.0 – Updated Dec 2013 1 INFORMATION ADVISORY NOTE CACS CPD for Covered Persons under PB Code of Conduct 1. Introduction 1.1 Under the Private Banking Code of Conduct (“PB Code”), Covered Persons are expected to achieve a minimum of 15 hours of Continuing Professional Development (“CPD”) in each calendar year after passing the Client Advisor Competency Standards (“CACS”). The CACS CPD requirements ensure that Covered Entities and their Covered Persons providing financial advisory services to High Net Worth Individuals (“HNWIs”) conduct their business activities with integrity and professionalism and ensure that they possess a requisite level of competence and knowledge. 2. Commencement of CACS CPD Obligation 2.1 To ensure that knowledge and skills are kept current with industry and regulatory developments, CACS CPD is considered to be a critical component of the ongoing competency of Covered Persons. All Covered Persons are expected to achieve a minimum of 15 hours of CACS CPD in each calendar year. 2.2 The CACS CPD requirement will take effect from 1 March 2013 onwards. To oversee the smooth implementation of the CACS CPD, the Private Banking Industry Group (“PBIG”) has formed a CACS CPD Advisory Group (“CPDAG”). The Institute of Banking and Finance (“IBF”) has also been appointed as the CACS Administrator and will serve as secretariat to the CPDAG. Please see Annex 1A for the governance structure. 2.3 For a Covered Person who passes the CACS prior to 1 March 2013 , his CACS CPD obligation under the PB Code for Year 2013 will be 12 hours of CACS CPD. His CACS CPD obligation from Year 2014 onwards is 15 hours of CACS CPD hours per year. If a Covered Person passes the CACS on or after 1 March 2013 , his CACS CPD obligation will be pro-rated as set out in paragraph 3.1.3 under the Competency Section of the PB code and as shown below: Table 1: Pro-ration of CACS CPD hours No. of working months in calendar year CACS CPD obligation under the PB Code Less than 3 months 5 CACS CPD hours Between 3 months to 6 months 8 CACS CPD hours Between 6 months to 12 months 12 CACS CPD hours

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Page 1: INFORMATION ADVISORY NOTE CACS CPD for Covered Persons ... CPD Info Advisory Note_v2.0.pdf · Version 2.0 – Updated Dec 2013 1 INFORMATION ADVISORY NOTE CACS CPD for Covered Persons

Version 2.0 – Updated Dec 2013 1

INFORMATION ADVISORY NOTE

CACS CPD for Covered Persons under PB Code of Conduct

1. Introduction

1.1 Under the Private Banking Code of Conduct (“PB Code”), Covered Persons are expected to achieve a

minimum of 15 hours of Continuing Professional Development (“CPD”) in each calendar year after

passing the Client Advisor Competency Standards (“CACS”). The CACS CPD requirements ensure that

Covered Entities and their Covered Persons providing financial advisory services to High Net Worth

Individuals (“HNWIs”) conduct their business activities with integrity and professionalism and ensure

that they possess a requisite level of competence and knowledge.

2. Commencement of CACS CPD Obligation

2.1 To ensure that knowledge and skills are kept current with industry and regulatory developments,

CACS CPD is considered to be a critical component of the ongoing competency of Covered Persons.

All Covered Persons are expected to achieve a minimum of 15 hours of CACS CPD in each

calendar year.

2.2 The CACS CPD requirement will take effect from 1 March 2013 onwards. To oversee the smooth

implementation of the CACS CPD, the Private Banking Industry Group (“PBIG”) has formed a CACS

CPD Advisory Group (“CPDAG”). The Institute of Banking and Finance (“IBF”) has also been

appointed as the CACS Administrator and will serve as secretariat to the CPDAG. Please see Annex

1A for the governance structure.

2.3 For a Covered Person who passes the CACS prior to 1 March 2013, his CACS CPD obligation under the

PB Code for Year 2013 will be 12 hours of CACS CPD. His CACS CPD obligation from Year 2014

onwards is 15 hours of CACS CPD hours per year. If a Covered Person passes the CACS on or after 1

March 2013, his CACS CPD obligation will be pro-rated as set out in paragraph 3.1.3 under the

Competency Section of the PB code and as shown below:

Table 1: Pro-ration of CACS CPD hours

No. of working months in calendar year CACS CPD obligation under the PB Code

Less than 3 months 5 CACS CPD hours

Between 3 months to 6 months 8 CACS CPD hours

Between 6 months to 12 months 12 CACS CPD hours

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3. CACS CPD Activities

3.1 CACS CPD activities should generally fulfill the following criteria:

Table 2: Criteria for CACS CPD Activities

Relevant

Required to carry out current role effectively and/or expand current skill set within

Wealth Management Private Banking

Certifiable

Courses must be conducted by trained individuals or professionals knowledgeable of

subject matter

Measurable

Must meet stipulated learning outcomes and specified number of hours

Verifiable

Must have system in place to track course attendance and provide attendance

certification upon completion of activity

Timely

Must be completed within the relevant calendar year

3.2 The annual CACS CPD activities in which the relevant hours are accumulated are expected to

comprise an appropriate combination of the following, taking into account knowledge dominant

competencies within the FICS framework, where relevant:

(a) relevant market conduct requirements;

(b) relevant product knowledge;

(c) relevant skills / competencies; and/or

(d) relevant compliance-related matters.

3.3 The appropriate combination of the 15 hours of CACS CPD to be achieved by the Covered Persons is

expected to be determined by the Covered Entity for whom the Covered Person acts on behalf of,

subject to paragraph 3.1.

3.4 To help facilitate the varied CACS CPD needs of Covered Persons of different seniority and industry

experience, a wide variety of CACS CPD activities will be recognized under the broad categories of (i)

Training & Education, (ii) Instruction, (iii) Leadership and (iv) Research & Publication, as documented

in Table 3: CACS CPD Guidelines.

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3.5 The table below illustrates some programmes that have surfaced to IBF for clarification. Please note that this list is not exhaustive.

Table 4: Eligibility of Activities for CACS CPD Recognition

CACS CPD

Activities ���� Examples of activities NOT eligible for

CACS CPD recognition

���� Examples of activities eligible for

CACS CPD recognition

Industry-related

Event

Χ Networking events, trade fairs and investor presentations ���� Conventions, conferences and seminars with

financial sector related content

E-learning Χ E-learning programme that is less than 30 mins

Χ E-learning with no assessment component

���� Any form of e-learning with verifiable assessment and meets the

minimum duration of 30 mins. This includes PC-based online

interactive learning as well as mobile learning apps

External Courses

Χ Preparatory programmes leading to regulatory- required

examinations (eg. CMFAS preparatory course or online

examination tips)

���� Preparatory courses leading to professional qualification /

certification examinations (eg. CFA preparatory course conducted in

a structured setting with the issue of supporting documents )

���� Finance related undergraduate / MBA programs (upon

passing)

Χ Product/ systems-specific programmes (eg. vendor A’s

systems training or fund house’s briefing on a new fund)

���� Product / technical training with no marketing content (eg.

“Introduction to structured warrants and the risks involved”)

Χ Generic language programmes (eg. “Introduction to

Mandarin”)

���� Language programmes targeted for financial-sector professionals

and is relevant to the Covered Person’s role (e.g. “Business Finance

in Mandarin”). The same language programme can only be

recognised once for CACS CPD

Χ Generic soft skills/ personal development programmes (e.g.

presentation skills)

���� Structured Leadership Programmes

Internal Courses

Χ Regular in-house market briefings on investment outlook/

economic updates or analyst briefing on “house views”

���� Annual/ bi-annual conference covering market or industry analysis

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Χ Training on bank-specific product, in-house systems/

processes (eg. training on the use of Bank A’s new system)

���� Programmes providing generic product or systems training with

finance-related technical component

Χ Orientation/ induction programmes

���� Clearly demarcated segment of the orientation programme that

covers technical content on laws & regulations/ product

knowledge/ functional competencies. The knowledge/ skills

acquired have to be transferable within the industry. Only hours

that cover these transferrable knowledge can be counted towards

CPD

Χ Generic soft skills/ personal development programmes (e.g.

presentation skills)

���� Structured Leadership Programmes

Professional

Examinations

Χ Self-study time leading to professional qualification ���� Duration of examinations leading to a professional qualification /

certification (excluding regulatory/ industry examinations) with a

pass grade can be counted in the year of passing

Lecturing/

Teaching

Assignments

Χ On-the-job sales coaching ���� Supervisors involved as assessors or trainers in a structured training

programme, where hours are independently verifiable

Presentation,

Panel Discussion or

Speaking at Events

Χ Speaking to students to promote the bank or to drive

recruitment

���� Speaking to students to share an overview of the Private Banking

industry

Financial Sector

Committee /

Working Group

Χ Company meetings ���� Financial sector related industry committee of professional

bodies, industry associations, IBF or MAS

Structured

mentoring

programme

Χ On-the-job coaching ���� Structured mentoring programme either offered by professional

associations or as part of in-house leadership programme

Research &

Publication

Χ Internal research reports (e.g. reports/ research prepared

for internal briefings or for dissemination to clients/

investors)

���� Articles/ reports published or disseminated to the public

Χ Contributions of individual viewpoints or quotes to the

media (e.g. newspaper, TV or radio interviews)

���� Contributions of researched material to the media

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4. Recognition and Endorsement of CACS CPD Activities

4.1 All FICS-accredited/ Financial Training Scheme (FTS) listed programs will qualify towards the

fulfilment of CACS CPD requirement (subject to the relevant cap). With effect from 1 Jan 2014,

Training Providers can seek CACS CPD programme recognition by applying for either FICS-

Accreditation or FTS Programme Eligibility. FICS-accreditation caters to programmes with content

aligned to the FICS Standards while FTS Programme Eligibility caters to financial sector-specific

programmes aimed at raising the competency of the financial sector. To find out more about FICS

Accreditation and FTS Programme Eligibility and how you can put in an application, please visit

www.ibf.org.sg.

4.2 For other programmes that do not meet the FICS/ FTS criteria, the Designated Representatives of

the Covered Entity will have to make his own discretion based on the CACS CPD guidelines.

5. Submission of Covered Person’s CACS CPD Hours

5.1 All Covered Persons are expected to maintain their own records of how the expected CACS CPD

hours are met. This should include:

(a) Name of the course attended;

(b) Date of the course;

(c) Whether it is held internally or externally; and

(d) Number of hours attended.

Covered Person

Covered Entity’s Designated Representative

Covered Entity’s Designated Representative(s) should determine

if the activity fulfils CACS CPD eligibility and advise the

appropriate number of CPD hours accordingly.

IBF

CPDAG

Designated Representative to

approach IBF if he is unsure about

eligibility of any activity

Covered Persons to approach Designated

Representative for all matters pertaining

to CACS CPD requirements

IBF may float new activity areas up to

CPDAG for advice

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5.2 Covered Entities are expected to maintain appropriate records for each Covered Person to allow for

an audit to be conducted on the hours of CACS CPD achieved by each Covered Person, and the

relevance of the CACS CPD activities undertaken.

5.3 The Covered Entity’s Designated Representatives are expected to submit CACS CPD reporting of

their Covered Persons annually for the calendar year, using the form - “Annual Fulfillment of CACS

CPD Obligations (Annex 2A)” and “CACS CPD Activities (Annex 2B)”, by 31st January of the

following year. For the purpose of closer monitoring of CACS CPD fulfilment in the initial phase, IBF

will require all Covered Entities to submit a mid-year interim report for the period 1 March 2013 to

30 June 2013 by 15 July 2013.

5.4 IBF reserves the right to perform audits on the Covered Persons to ensure fulfillment of CACS CPD

requirements in the previous year. Covered Persons are required to submit supporting documents

for activities undertaken in the event of an audit.

6. Penalty for Non-Compliance of CACS CPD Requirements

6.1 If a Covered Person is unable to fulfil the CACS CPD requirement by 31 Dec of any given calendar

year, he will be required to make up the remaining CACS CPD hours in the following calendar year,

plus a 3 CACS CPD hours penalty. This implies that, in addition to the usual 15 CACS CPD hours, he

will be required to make up the remaining CACS CPD Hours of the previous year plus a 3 CACS CPD

hours penalty.

Illustration of Penalty for Non-Compliance of CACS CPD requirement

6.2 If a Covered Person is unable to complete the CACS CPD requirement for 2 consecutive years, he will

be required to re-take and pass the CACS Assessment. According to the PB Code, the Covered Person

will not be able to practice during the lapse period.

6.3 If a Covered Entity hires a Covered Person with penalty hours brought over from the previous

year, it the responsibility of the Covered Entity to ensure that the Covered Person fulfills his

uncompleted and penalty hours brought over from the previous year(s) in addition to his CACS CPD

obligation for the year.

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7. Reporting of CACS CPD Data

7.1 As the CACS Administrator, IBF will be compiling statistics and making regular reports to the

regulatory authorities (e.g. Monetary Authority of Singapore and Private Banking Industry

Group Executive Committee). This would include the CACS CPD status of Covered Persons and that

Covered Entities have ensured that their Covered Persons have fulfilled the required CACS CPD

obligations. Personal data relating to individuals will not be disclosed without the Covered Person’s

prior consent.

8. Frequently Asked Questions (FAQs)

8.1 We have also attached a list of FAQs in Annex 1B to address common queries relating to CACS CPD

for Covered Persons. Should you still need any further assistance, please email us at

[email protected]. Alternatively, you may contact Ms Tan Yan Wei at +65 63055689 or Mr Kyo Tan at

+65 6305 5675.

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ANNEX 1A

CACS CPD Governance Structure &

Terms of Reference for CACS CPD Advisory Group (“CPDAG”)

1. Governance Structure for CACS CPD in the Private Banking Industry

1.1 The proposed governance structure would comprise the Private Banking Industry Group (“PBIG”),

CACS CPD Advisory Group (“CPDAG”), Institute of Banking and Finance (“CACS Administrator”) and

Covered Entity’s Designated Representative(s) as shown graphically in Figure 1.

Figure 1 – Governance Structure for CACS CPD in the Private Banking Industry

2. PBIG

2.1 The PBIG is mandated with the task to shape the development and foster the sustainable growth of

the Singapore Private Banking Industry.

2.2 Role of PBIG

The specific objectives of PBIG include the following:

• To serve as the custodian of the Private Banking Industry Code of Conduct (“PB Code”)

• To enhance the stature, reputation and growth of the Singapore Private Banking Industry

• To serve as a channel of communication amongst industry players and with the Monetary Authority

of Singapore (“MAS”)

3. CACS CPDAG

3.1 The CACS CPDAG will consist of a committee of 10 representatives from Singapore’s Private Banking

industry holding the position of Head Relationship Manager (RM), Head of Product Specialist, Head

of Compliance and Head of Human Resource (HR) or Learning & Development (L&D).

CPDAG

CACS Administrator

Covered Entity’s Designated

Representative(s)

PBIG

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3.2 The proposed composition of the CACS CPDAG is as follow:

Work Function No. of seats

Head Relationship Manager (RM) 4

Head of Product Specialist 2

Head of Compliance 2

Head of HR or L&D 2

3.3 For the first year of implementation, meetings would be convened quarterly to provide guidance and

oversight on the implementation of the CACS CPD.

3.4 Terms of Reference for CACS CPDAG

The Terms of Reference for the CACS CPDAG include the following:

• To provide guidance on the implementation of CACS CPD policies for Covered Persons under the

PB Code;

• To provide guidance on the topics and coverage deemed suitable to raise the competency of the

Private Banking industry through CACS CPD;

• To review and approve issues raised by the CACS Administrator such as:

(i) criteria for eligibility of CACS CPD activities;

(ii) exemption from fulfilment of CACS CPD;

(iii) follow-up actions to be recommended, if any;

(iv) recommendation on changes to CACS CPD policies/guidelines1

4. Covered Entity’s Designated Representative(s)

4.1 The Covered Entity’s Designated Representative(s) shall be appointed by the Covered Entity’s Board

or senior management. The Designated Representatives shall have managerial oversight in areas

such as Human Resource (HR), Learning & Development (L&D), Compliance or in managing Covered

Persons.

4.2 Role of Designated Representative(s)

The role of the Covered Entity’s Designated Representative(s) is to assess and certify in-house CPD

training programs to ensure compliance with the CACS CPD guidelines as well as oversee the

reporting of Covered Entities’ CACS CPD status to the CACS Administrator.

5. CACS Administrator

5.1 The CACS Administrator will be the first point of contact in administering the established CACS CPD

criteria and standards and handling all CACS CPD queries.

5.2 Role of CACS Administrator

The role of CACS Administrator includes the following:

• Alignment of CACS CPD to FICS where relevant;

1 On the recommendation of the CACS CPDAG, issues on policy matters and follow-up actions should additionally be cleared with

the PBIG Exco.

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• Supports CACS CPDAG for all CACS CPD matters and queries;

• Serves as a channel of communication amongst Covered Entities and with the CACS CPDAG;

• Provides CACS CPD status update to the CACS CPDAG and PBIG;

• Facilitates the tracking of CACS CPD hours of Covered Persons;

• Monitors the fulfilment of annual CACS CPD requirements by Covered Persons;

• Conducts annual CACS CPD audits;

• Accreditation for CACS CPD programs;

• Update and document revisions of CACS CPD policies;

• Determine appropriate fees for CACS CPD administration if necessary.

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ANNEX 1B

CACS Continuing Professional Development

(“CPD”) For

Covered Persons under the

Private Banking Code of Conduct (“PB Code”)

Frequently Asked Questions (FAQs)

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SECTION (A) – GENERAL

Q1. What is the role of the Private Banking Industry Group (“PBIG”)?

A1. The PBIG is mandated with the task to shape the development and foster the sustainable

growth of the Singapore Private Banking Industry.

Q2. What is the role of the CACS CPD Advisory Group (“CPDAG”)?

A2. The CPDAG provides guidance on CACS CPD eligibility topics and recognized CACS CPD

learning activities. It will not aim to endorse specific courses.

Q3. Who are the members of the CPDAG?

A3. The CPDAG consists of a committee of 10 representatives from Singapore’s Private Banking

industry holding the positions of Head Relationship Manager (RM), Head of Product

Specialist, Head of Compliance and Head of Human Resource (HR) or Learning &

Development (L&D).

Q4. What is the role of the CACS Administrator (IBF)?

A4. The CACS Administrator will be the first point of contact in administering the established

CACS CPD criteria and standards and handling all CACS CPD queries.

Q5. What is the role of the Covered Entity’s Designated Representative(s)?

A5. The role of the Covered Entity’s Designated Representative(s) is to assess and certify CACS

CPD training programs taken by their Covered Persons to ensure compliance with the CACS

CPD guidelines as well as oversee the reporting of their Covered Persons’ CACS CPD status to

IBF.

Q6. Who is eligible to be appointed as the Covered Entity’s Designated Representative(s)?

A6. The Covered Entity’s Designated Representative(s) shall be appointed by the Covered

Entity’s Board or senior management. The Designated Representatives shall have

managerial oversight in areas such as Human Resource (HR), Learning & Development

(L&D), Compliance or in managing Covered Persons.

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SECTION (B) – CACS CPD OBLIGATION

Q7. With the launch of the PB Code, when will a Covered Person be required to commence his

CACS CPD obligation?

A7. With the launch of the PB Code, a Covered Person will be required to fulfill his CACS CPD

obligation with effect from 1 March 2013. The CACS CPD calendar year commences on 1

January and ends on 31 December every year.

If a Covered Person passed his CACS prior to 1 March 2013, his CACS CPD obligation under

the PB Code for Year 2013 is 12 hours of CACS CPD. His CACS CPD obligation from Year 2014

onwards is 15 hours of CACS CPD per year.

If a Covered Person passes his CACS Assessment on or after 1 March 2013, his CACS CPD

obligation in the year which he passes his CACS Assessment, will be pro-rated as set out in

paragraph 3.1.3 under the Competency Section of the PB Code as follows:

(a) Less than 3 months – 5 CACS CPD hours

(b) Between 3 months to 6 months – 8 CACS CPD hours

(c) Between 6 months to 12 months – 12 CACS CPD hours

From the following year onwards, his CACS CPD obligation is 15 CACS CPD hours per year.

Q8. Can the CACS CPD activities that a Covered Person undertakes between 1 Jan 2013 and 1

Mar 2013 qualify for the CACS CPD obligation under the PB Code?

A8. CACS CPD activities undertaken between 1 Jan 2013 and 1 Mar 2013 can be counted

towards fulfilling 2013’s CACS CPD obligation provided the activities were undertaken after

the Covered Person passed his CACS Assessment.

Q9. Can the CACS CPD activities undertaken before the Covered Person passes his CACS

Assessment qualify for the CACS CPD obligation under the PB Code?

A9. No, CACS CPD activities undertaken prior to passing CACS will not count towards meeting his

CACS CPD obligation.

Q10. Can a Covered Person carry 'surplus' CACS CPD hours from one year to the next?

A10. No. ‘Surplus’ CACS CPD hours cannot be carried to the next year.

Q11. Will an overseas private banker who is temporarily transferred to Singapore’s branch be

subjected to the CACS CPD requirement?

A11. If the temporarily transferred overseas private banker is required to take the CACS

Assessment, he is obligated to fulfill his CACS CPD requirement as well during the period for

which he is working in Singapore.

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Q12. If a Covered Person has been exempted from taking the CACS Assessment (either having

undergone NEC or FICS certification), does he still need to fulfill CACS CPD obligation?

A12. Yes, all Covered Persons are required to fulfill their CACS CPD obligation under the PB Code,

which will take effect from 1 March 2013.

Q13. Are Non-Covered Persons who took the CACS Assessment required to fulfill CACS CPD?

A13. Non-Covered Persons who passed the CACS assessment are not required to fulfill CPD

obligations. In the event that he becomes a Covered Person within 3 years, he will be

required to fulfill pro-rated CPD hours for the year. However, if he becomes a Covered

Person after 3 years, he will have to re-take and pass the CACS assessment even if he had

been voluntarily fulfilling CPD in the last 3 years.

SECTION (C) – RECOGNISED CACS CPD ACTIVITIES

Q14. How can a Covered Person find out if an activity or program is recognised for CACS CPD?

A14. All FICS-accredited / Financial Training Scheme (FTS) eligible programmes can be recognised

for CACS CPD. A list of these programmes is available on IBF’s website. For other

programmes, the Covered Person should approach his Covered Entity’s Designated

Representative(s) who would advise him based on the CACS CPD guidelines.

Q15. Why is there a cap on the maximum number of hours that can be attained from a CACS

CPD activity?

A15. The maximum cap of 10 CACS CPD hours for each category of activity is intended to ensure

that the Covered Person benefits from a more comprehensive range of learning platforms to

enhance his professional development.

Q16. Is there a minimum criterion for trainers of internal or external courses recognised for

CACS CPD?

A16. Trainers should minimally possess the relevant qualification or experience in the subject

matter.

Q17. A Covered Person spends hours each day reading newspapers, journals, research papers

etc. What CACS CPD hours does he get?

A17. Reading of newspapers, journals and research papers will not qualify for CACS CPD hours.

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Q18. Can time spent on preparing for an instruction activity be recognised for CACS CPD hours?

A18. As a guiding principle, activities should be measurable and verifiable to be considered

eligible CACS CPD activities. If the time spent on preparing for the instruction activity can

be measured and verified with supporting documents, it can be recognised as CACS CPD

hours.

Q19. Having passed the CACS Assessment, a Covered Person goes on to complete a FICS-

accredited program in Wealth Management - Relationship Management (High Net Worth)

at Job Role IV and above and attains FICS Certification. How will this count towards the

fulfillment of CACS CPD requirement?

A19. As long as the Covered Person completes the FICS-accredited programme in Wealth

Management - Relationship Management (High Net Worth) at job role IV and above after

passing the CACS assessment, and attains FICS certification, he will be deemed to have

fulfilled CACS CPD requirements for 2 years – the year in which he completed the program

and the year in which he attained FICS certification (Note: this may include the year after

certification if program completion and attainment of certification took place in the same

year).

In the case where the Covered Person completed the FICS-accredited programme in Wealth

Management - Relationship Management (High Net Worth) programme at Job Role IV and

above and attained FICS certification between 1st

Sep 2011 (CACS commencement) and 1st

Mar 2013, he would be deemed to have fulfilled CACS CPD requirement for the years 2013

and 2014.

Q20. If a Covered Person had completed the FICS-accredited programme in Wealth

Management - Relationship Management (High Net Worth) programme at Job Role IV and

above and attained FICS certification prior to 1st

Sep 2011 (CACS commencement),

would he be deemed to have fulfilled CACS CPD requirement?

A20. No, he may not use the completion of the above programme and certification attained

before 1st

Sep (CACS commencement) to fulfill CACS CPD requirements.

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SECTION (D) – MONITORING CACS CPD HOURS

Q21. Whose responsibility is it to monitor the Covered Person’s CACS CPD requirements?

A21. Both Covered Entities and Covered Persons will have to maintain records of how the

expected CACS CPD hours are met. Covered Entities are required to monitor and ensure that

all Covered Persons who act on their behalf will meet the expected CACS CPD hours by the

end of each calendar year. (See paragraphs 3.1.7 - 3.1.9 of the PB Code)

In the event that the Covered Person leaves Covered Entity X to join Covered Entity Y, X will

have a responsibility to issue a confirmation of the Covered Person’s CACS CPD records

before he leaves. It is Y’s responsibility to ensure that the Covered Person fulfills his

outstanding CPD obligation for the year.

Q22. Is there a specific format for the bank to adhere to when issuing the confirmation letter of

the Covered Person’s CACS CPD records?

A22. A sample template (Annex 2C) is available on the IBF website. However, if a bank already

has a CPD system with tracking capability, the bank may provide the confirmation letter

using its own format.

Q23. What are the supporting documents required for an activity under the Training &

Education Category to be considered verifiable?

A23. Supporting documents may include the employer’s acknowledgement or sign-off, certificate

of attendance or completion, or where there has been an assessment, a copy of the result

slip.

Q24. How does a Covered Person show evidence of participation in leadership activity?

A24. Covered Person who is a member of an industry committee is to produce a certificate of

attendance from the Secretariat of the committee to reflect the appropriate hours of his

involvement.

Q25. How long does a Covered Person need to retain the supporting documents for CACS CPD

activities?

A25. All CACS CPD supporting documents should be retained for a minimum period of 3 years for

audit purposes.

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SECTION (E) – ABSENCE FROM SINGAPORE PRIVATE BANKING INDUSTRY

Q26. Can an overseas course count towards fulfilling CACS CPD requirement?

A26. Yes. Courses which fall within the CACS CPD requirements whether taken locally or overseas

will count towards CACS CPD hours. Please ensure you have a copy of all the relevant

documents.

Q27. If a Covered Person left the private banking industry but is planning to rejoin the industry,

what is his CACS CPD obligation?

A27. As long as the Covered Person is in a client-facing advisory role in a Singapore-based

Covered Entity, he is required to fulfill CACS CPD obligation. Whenever he exits the

industry, the obligation does not follow. When he rejoins the industry, he will have to

resume his CACS CPD obligation.

In addition, if he is away for more than 3 years, his CACS assessment will be nullified and he

will need to re-take the CACS assessment. His CACS CPD obligation will then resume after

he passes his CACS assessment.

However, we make exceptions for Covered Person who continue to be in a client-facing

advisory role working overseas. For such instances, Covered Person will not need to re-take

his CACS assessment, even if he is away for more than 3 years.

SECTION (F) – REPORTING & SUBMISSION

Q28. Does a Covered Person or the Covered Entity report the status of their CACS CPD hours to

the CACS Administrator (“IBF”)? How frequently should this report be submitted?

A28. The Covered Entity’s Designated Representatives are expected to submit CACS CPD

reporting of their Covered Persons annually for the calendar year, using the form - “Annual

Fulfillment of CACS CPD Obligation (Annex 2A)” and “CACS CPD Activities (Annex 2B)”, by

31st January of the following year.

Q29. What will happen after the Covered Entity submits their Covered Persons’ declared CACS

CPD hours to IBF?

A29. As the CACS Administrator, IBF will be compiling statistics and making regular reports on the

CACS CPD status of the Covered Entities and their Covered Persons as well as the progress of

CACS to the regulatory authority (i.e. Monetary Authority of Singapore and the Private

Banking Industry Group Executive Committee).