5th January 2011

IFA letter of the week- Gap Fill fog cut through

I wrote the email below to our staff as after weeks and months of trying to get some clarification and sense on the Gap fill process we had all lost the will to live. Until a very helpful person at the CII told us what we should be doing. Refunds and apologies are being issued but it doesn’t give us our valuable time back. 

I have the CII Gap fill answers below – 4 months on and several �£’s down.

Please read this email very carefully to save yourself a huge amount of time and unnecessary expense. I know having spent �£400 and 5 days on courses, revising etc that this is not funny when it transpires that I didn’t need to do it at all!

All of us have been trying to get to grips with what we are / not required to do RDR / CII / Gap fill wise. We have all spoken to various people at various organizations and still we have been as clear as mud as to what we are supposed to do next.

I am going to refuse this opportunity to send a 55-page email rant about the CII (and FSA) after the most demoralizing week of my whole career. I will just say in terms of implementing the RDR philosophy (which in principle is excellent, in implementation so far is a disaster) within this industry, the CII know stands for the Cancer of the Insurance Industry, in terms of our development. It is not raising standards in the R0 exams as the Q&A, study materials etc are a disgrace! It is merely raising funds for its own self-serving agenda. Rant over.

The answers we have all been looking for are:

• If you are DipFS qualified or in Ted’s case higher you DO Not need to sit any R01 – R06 papers. Please do not do what Elliot and I have done and go on R01 courses with Friends Provident, pay for Adviserexam revision aids and the exam itself. You DO NOT need to do this for Gap fill.
• If you are DipFS qualified please DO NOT go to training courses or PFS afternoons. You DO NOT need to do this for Gap fill.

I have spoken to Lucy Courtenay, the Director of Education at the IFP and her equivalent Fay Goddard of the PFS at length about the subject of Gap fill and that we are all being told different things.  I got some sense that all was not right from them – apart from the stupid questions and answers in the R01 exam – but we still needed to put the final pieces of the anarchy and chaos into place.

They had both said to me don’t do the Level 4 / RO exams just Gap fill. I said that I was concerned Gap fill would take up afternoons and days each year of my time and that it would be easier to just do the exams. I believed that GAP fill would be for each subject area where the relevant RO exam hadn’t been passed and that this would be an annual updating event / training day required.

This never really eased my concerns but maybe I misunderstood the GAP fill? Still baffled by all of the uncertainty I vowed to take the front foot and plough on through the exams to get R01 – R06 completed by mid February so I could get back on the Chartered and then Certified exam trail.

Yesterday afternoon the clouds lifted and the sunshine came for us all. I went to book R04 the pension paper and Justin Clark (my hero) answered and point blank refused to take any more money of me for any R0 papers. He was very unhappy that the CII had taken money of me for exams and that no one had explained the GAP fill process properly.

I initially insisted that I wanted to continue to with the exam route and just get it done. Justin again refused to take my money and went through all of my previous qualifications to explain why I didn’t need to take RO papers. Simply all I needed to do was go to

http://www.gapfill.cii.co.uk/Home

log in

using R01 as an example

click on financial services and regulations (right hand side, bottom of the page)

go to the first section with an X (some are already ticked so are complete)

click on Details box

then go to Find Gap Fill activities

blue activity box comes up

Click on this, then press add and close

Click on details box (again)

In blue is the activity now already downloaded?

Click on this and it will download on screen for you.

Print this so you can read it to complete the GAP fill

Click on Add GAP fill evidence

Name: write in the subject title

Complete: date started and finished

Click OK to finish

You have now GAP filled that section and this means you DO NOT need to sit an exam, go on training course nor go to PFS gap fill afternoons.

I asked Justin how this was being monitored and he said that there is no requirement from the CII to put pages of notes / commentary in the boxes on the GAP fill process above.

My suggestion is that for those who just need to GAP fill to complete RDR compliant IFA status by the end of 2012 that:

• You print of each GAP fill activity as per above.
• Read it – please do and do take this seriously. You will be disqualified if caught out by the FSA and we will be fined if the FSA find any abuse of the system.
• Make any relevant notes on the document.
• Then give it to Angela, or Ted in a 1-1 meeting, to sign off to say that you have read said GAP fill activity.
• If we time and date the paperwork, with an IFA signature, plus a compliance person one, then this will belts and braces the whole process.
• The document can then be stored on your CPD file.

If you have also been working through CII past papers, CII Revision mate chapters and mock exams, Adviser exam papers etc, etc please place these in your CPD file as evidence too. The work I have done so far does actually count for something thank god!

Justin Clark has taken our bad news personally and wants to help. He has had 3 months of dealing with worried / confused IFA’s trying to get some clarity on this and he has said notably the people calling and signing up for exams are those who are already well qualified.

The GAP fill / introduction of the RO papers has rained chaos over the last 3 months in the CII as well as us and he has said that a lot of the confusion is coming from the insurance companies. I understand this from his point of view because he has been telling people the right answers – it is just a lot of his team that haven’t and I know quite a few of us have lost out time wise and financially.

Justin is wanting to help us and has asked that you call him with any queries and just mention my name and Panacea.com. If you feel aggrieved that you have wasted time and money like me please DO Not take it out on Justin. We need to keep him onside to help us going forward. Air your grievances internally and we will resolve them with you.

I hope this brings the much-needed clarity we are all seeking and an end to a very sad chapter in the way the CII and FSA are failing to develop this wonderful industry. I lost my breath twice this week I was so angry / disappointed / frustrated with the CII that I was initially not going to take any more CII exams ever again. I just hope this now means that this won’t happen to you!

Alex

Alex S Morris B.A. (Hons), Dip PFS

Financial Relationships LLP

http://www.financialrelationships.co.uk/

Adviser Letter of the Week