Are you really complying with ASIC's RG206 CPD obligations? It's more prescriptive than you may think...
At FEP we consider ourselves fortunate to speak with credit licensees on a regular basis.
One circumstance we come across often is how many of them believe that mere training on internal systems and policies, and products and services they offer, constitutes continuing professional development for credit representatives and responsible managers.
ASIC is quite clear – in fact prescriptive – in identifying and mandating what CPD should cover in RG 206 Credit licensing - Competence and training:
“Your ACL CPD should include both product and industry developments related to credit, and also compliance training, including in relation to new regulatory requirements of the credit regime. For example, compliance training would need to encompass the responsible lending obligations.” ASIC (RG 206.66)
While this regulatory guidance is not new, the recent interim report of the Financial Services Royal Commission has likely sent some credit organisations scurrying to re-read RG 206 and RG 209 Credit licensing: Responsible lending conduct.
With that has come demand for refresher training on responsible lending for reps and RMs that will withstand the scrutiny of ASIC, should it feel compelled to delve into licensee’s CPD records.
Given ASIC has unequivocally detailed a review of RG 209 in its Strategic Agenda (due to be released in June 2019), it is clear that credit licensees and responsible lending in Australia will bear increased scrutiny.
Ideally RG 206 CPD should encompass regulatory updates, responsible lending, systems and processes, fostering innovation and transformation, and conduct management (professionalism and ethics). It should also properly assess transfer of learning to ensure that it:
- Is understood and applied
- Genuinely motivates best practice
- Complies with licence obligations; and
- Improves organisational capability.
Once this is in place each year, including structured learning and documented completion, it will go a long way to helping credit licensees sleep well at night.
It would also deliver the worthwhile outcomes for customers we could all get a kick out of contributing to.
We offer Responsible Lending refresher training. Please call us on (02) 9233 2000 for more information or download the course outline.