CPD Policy

Our approach to continuing professional development (CPD)

MM Consultancy Pty Ltd, Australian Financial Services Licensee 483286 (We, Us) is committed to quality in everything we do, and this is embodied in our commitment to the ongoing professional development of our financial advisers who provide personal advice to retail clients (relevant providers).

All our financial advisers must undertake comprehensive and relevant continuing professional development of at least 40 hours every CPD year to ensure they keep up with developments relevant to their respective areas of practice.

We will ensure that our financial advisers have the appropriate resources and opportunities available to meet their CPD requirements.

Our CPD year is the calendar year – from January 1 to December 31.

Our process for approving CPD activities

How our financial advisers may undertake their CPD

Our advisers may undertake their CPD in the following ways:

• Formal relevant education (provided by an education provider) including degree equivalent study to meet legislative requirements (such as bridging courses and approved degrees) and any formal qualifications and designations relevant to the practice of the financial adviser; to a maximum of 25 CPD hours per year
• Non-formal education including for the purposes of achieving a relevant professional designation, for the purposes of meeting requirements in specific financial advice provision (aged care, self-managed superannuation etc.) and for the purposes of accreditation in specific form of financial products relevant to licensing arrangements e.g. credit
• In-house training sessions/workshops (internally developed and/or arranged)
• Attendance at professional developments days and workshops
• Product update sessions – internal and external
• Completing other professional development activities for example those provided by professional associations, product providers and other financial services industry participants
• Professional reading – four hours per annum maximum

At least 70 per cent of all professional development activities undertaken by our financial advisers must be approved by us as the responsible Australian Financial Services Licensee.

How we approve the CPD of our financial advisers and allocate hours to their CPD plans.

To be approved the CPD activity must meet all of the following requirements in accordance with Corporations (Relevant Providers Continuing Professional Development Standard) Determination 2018 (Exposure Draft), the final determination and amendments:

• The activity falls within one of the following CPD areas:
  • Technical competence
  • client care and practice
  • regulatory compliance
  • professionalism and ethics
  • general
• the activity has sufficient intellectual or practical content
• the activity primarily deals with matters relating to the provision of financial product advice
• the activity is lead or conducted by one or more persons who are appropriate, have sufficient standing, expertise, academic qualifications and practical experience *
• the activity is designed to enhance the financial adviser’s knowledge and skills in areas that are relevant to the provision of financial product advice

* Does not apply to an activity that consists of professional or technical reading.

If the CPD activity covers more than one CPD area, it will only be allocated to the CPD area to which it predominately relates.

If the financial adviser conducts or leads the CPD activity; the number of hours spent conducting or leading the activity can be allocated to their CPD plan.

Our process for ensuring CPD activities are provided by persons or entities that are appropriate

All CPD activities, required to reach the required minimum of 70 per cent approval within a CPD year, undertaken by our financial advisers, must be approved by us.

The determination of the appropriateness of the entity or person providing the CPD activity will include consideration of the following factors:

• sufficient standing
• expertise
• academic qualifications
• practical expertise

Our approach to evidencing outcomes of CPD

Any content that has been accredited by a professional association is also automatically approved as evidencing outcomes for CPD.

When approving the accreditation, we must consider the learning objectives/outcomes of the CPD content, as they relate to the role of the financial adviser, prior to approving the allocation of hours to the financial advisers CPD training plan. This is in addition to assessing the appropriateness of the person or entity providing the CPD as outlined previously.

Our requirements in relation to professional reading

We acknowledge that professional research and technical reading is an integral part of being a financial adviser. If a financial adviser undertakes professional reading as a part of their CPD, they must keep a record of the material read, provide a brief summary of the materials (may be bullet points) and calculate the CPD hours in accordance with the formula:

• (total number of words/225) = CPD minutes (rounded to the nearest 15 minutes)

Our approach to developing CPD plans for financial advisers

The training needs of each financial adviser will be assessed when developing the annual CPD training plan. Considerations will include:

• the financial services the representative is authorised to provide
• previous training completed by the representative before and after they joined us
• the financial adviser’s performance over the preceding year
• any recommendations made following an internal or external compliance audit
• any feedback received from their supervisor or manager
• any feedback or learnings from the dispute resolution process
• regulatory or business change which affects the financial advisers and/or the way they provide their financial services
• their knowledge and skill requirements with reference to Corporations (Relevant Providers Continuing Professional DevelopmentStandard) Determination 2018 (Exposure Draft) and the final determination, as updated

Our approach to monitoring the CPD activities of financial advisers

We will monitor the completion of CPD activities, and adherence to this CPD policy on a quarterly basis. Whilst we do not require our financial advisers to complete a proportionate number of CPD hours each quarter, we do encourage our team to complete their CPD activities regularly throughout the year. If we become concerned that a financial adviser is at risk of not completing the required CPD within the CPD year; we may direct the adviser to complete a certain number of CPD hours within a designated time frame.

At 11 months into the CPD year; weekly monitoring of CPD plan progress will be undertaken in relation to any financial adviser that has not yet completed their full 40 hour CPD training plan.

Any financial adviser that does not complete the requisite CPD training plan within the CPD year will be reported to ASIC in accordance with our reporting obligations. Any such adviser must complete the prior year’s training plan prior to commencing their new CPD year training plan, and may not be permitted to provide financial advice to retail clients until the prior year plan is completed in its entirety.

Our approach to career breaks

When a financial adviser has had a career break of a continuous period of two years or more, they are not able to resume practice as a financial adviser until we have approved a CPD plan for the first year that is designed to address any gaps in their competence, skills and knowledge that may have arisen in that period.

We may require the financial adviser to undertake specified CPD activities prior to providing personal advice to retail clients as a result of the career break.

We may also require others who have had breaks of shorter duration to undertake specific CPD activities prior to providing personal advice to retail clients, for instance after a period of parental, disability or medical leave.

Our approach to record keeping

Our financial advisers must keep records of their CPD for a period of 7 years from the end of any given CPD year. Evidence of CPD activities must be provided to us upon request.

If a financial adviser leaves, they must provide us with a copy of their complete CPD transcript as part of the standard off-boarding process. The record must include all CPD activities undertaken throughout their time as a financial adviser with us.

The records for each CPD activity must include documentation of the activities undertaken, evidence of completion and outcomes obtained.