Changes to the CII’s Pension Transfer Advice Qualification
This article is relevant to those studying for, or who have previously achieved, the CII’s Certificate in Pension Transfer Advice.
Well, that certainly came around rather quickly.
Concerns about pension transfer advice
It doesn’t seem like five minutes ago that the Financial Conduct Authority first raised potential concerns about pension transfer advice being given by advisers who are not also investment specialists. Yet in actual fact, it was back in 2017 that CP17/16 commenced exploratory work. It was also March 2018 when CP18/6 made the first concrete proposal to require pension transfer specialists to hold an RDR level 4 compliant investment advice qualification.
You might think it would be a no-brainer that an adviser recommending the transfer of secured benefits should also be qualified to recommend where they should go to. Yet multi-adviser models have been used more frequently than one might expect, either within the same firm or via specialist pension transfer bureaus. The main concern with this is that it risks a scenario where each adviser working on the case is not able to truly see the case ‘in the round’.
Deadline for achieving level 4
Having decided in PS18/20 to press ahead with the proposal, the regulator has already handed out one reprieve. The initial deadline of October 2020 for pension transfer specialists to achieve level 4 was pushed back by a year due to the impact of COVID. But by 1st October 2021, all advisers in the field will need to hold it or cease giving advice.
A new qualification for Pension Transfer Advice
What does this mean for CII students? Well, the Certificate in Pension Transfer Advice, which comprised R01, R02, R04 and AF7, is no more as of 31 August. Instead, it will be replaced by a new level 6 Award in Regulated Pension Transfer Advice. To be eligible for this, current students will need to pass their AF7, combined with an RDR compliant level 4 qualification.
The most logical route for new entrants is likely to be the full suite of R0 papers, but recognition of prior learning may be applied for in the usual manner by those holding, for example, the LIBF’s DipFA qualification. The CII’s own Diploma in Financial Planning would also be acceptable, subject to appropriate gap-fill being completed.
For the old-fashioned among us, the new qualification may also be awarded to those who hold the historic AF3 or G60 units together with an appropriate level 4 qualification. The obvious caveat to this is that holding the qualification is one thing, but competent adviser status still needs to be assessed and maintained.
Whilst this is a matter for each individual firm’s training and competence scheme, merely holding G60, which was discontinued in 2006, is unlikely to be considered appropriate for someone who has not advised in this market recently. Pension professionals of a certain vintage will be aware of the numerous significant changes that have occurred over this time period, including A-day, the 2015 freedoms and several significant annual and lifetime allowance changes.
Plenty to chew over there, as always in the pensions market.
Grab the resources you need!
For any aspiring pension transfer specialists working towards either the Diploma in Regulated Financial Advice or the AF7 qualification, Brand Financial Training’s extensive range of resources can help. Click the link to download the AF7 mock paper taster now.
Information in this article is correct as at 7 August 2021
