FCA has previously said that is expects firm to be able to show that individuals are competent to carry out their work during the pandemic. It notes that effective and consistent CPD is a part of this, but that it is, in these exceptional circumstances, allowing firms to defer individuals’ CPD to the next year.
FCA notes, though, that most individuals should be able to continue completing CPD when working at home and even while on furlough. It expects firms to support employees on furlough by providing them with appropriate materials.
That said, it does recognise the potential difficulties particularly for retail investment advisers who need to complete 35 hours of CPD which is independently verified, and relevant employees within insurance distribution firms who must complete at least 15 hours in any 12 month period. As a result, it is allowing individuals, in exceptional circumstances, to carry over any uncompleted CPD hours to the next year, where the CPD year ends before 21 April 2021. The missing hours must be completed in the next year, on top of the hours required for that year.
FCA also gives guidance on what it considers to be exceptional circumstances, which will include when employees need to carry out significant extra work-related duties, have caring responsibilities or have difficulties accessing CPD material, and where in those circumstances it is not realistic to expect the individual to fulfil the requirements.
Where firms have made this decision, they should record the reasons for it, but do not have to tell FCA. Independent accredited bodies may also verift complaice with TC 2.1.15R.