Are you really complying with ASIC's RG206 CPD obligations? It's more prescriptive than you may think...
At FEP we’re fortunate to speak with credit licensees on a regular basis.
One circumstance we come across surprisingly 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 the scope of credit CPD 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 final 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.
This has sparked 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.
ASIC recently wrapped up newsworthy public hearings in Sydney and Melbourne as part of its consultation on revisions to RG 209, with a view to publishing updated guidance in coming months. So, scrutiny of this area is likely to remain forensic for some time yet.
Getting the training mix right has even become a ministerial priority. PwC Skills for Australia’s Industry Skills Forecast and Proposed Schedule of Work for Financial Services dated May 2019 found:
“There is a lack of understanding of how technical skills relate to the context of mortgage broking, and a need for a greater focus on job readiness. Key areas for improvement include linking training to how these are used in the job, and an increased focus on conversational engagement skills as these become more important to establish the needs of the customer.”
As well as ASIC’s sharper focus on responsible lending, there are widespread calls for training around ethics and professional standards to be strengthened.
Additionally, while new technology improves the customer experience and boosts operational efficiency, it poses other issues that professionals will need learning in, such as data governance and cyber security.
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.
Credit licensee clients tell us that once this is in place each year, including structured learning and documented completion, it goes a long way to helping them sleep well at night.
It would also fill the need of customers for all their mortgage life.
You might like our Credit and Mortgage CPD
We also have a stand-alone course RG206.66 Responsible Lending