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Following publication of the FSA’s policy statement PS11/01, there is one aspect that is causing some consternation and debate. To quote the FSA: “Gap-fill should be structured, rather than unstructured, CPD. However, if structured CPD is not available to fill the gap identified, then an adviser may complete the gap by reading suitable material. We expect that such cases would be for a minority of gaps, if any.”
Before jumping to the conclusion that this message means that “reading” is automatically unstructured, we need to be clear about the difference between structured and unstructured CPD. The Chartered Institute of Personnel & Development has broadly defined structured CPD as following a three-step process:
Point two is particularly important as this indicates that provided the three steps are followed, reading learning material that has been created to meet a clearly-defined learning outcome can meet the structured CPD definition. An individual would need to complete the third step by considering carefully whether they have fully understood the material and verifying that the activity has met the learning outcome. This is a very different proposition from reading topical articles or even technical material that may be very useful, but not designed to meet specific learning needs.
Qualification gap-fill for retail investment advisers (FSA)