FAQ | CACS CPD

For Individuals

What are the CACS CPD requirements?

Under the Private Banking Code of Conduct (“PB Code”), Covered Persons are expected to fulfil annual Continuing Professional Development (“CPD”) requirements after passing the Client Advisor Competency Standards (“CACS”) Assessment. The CACS CPD requirements are designed to ensure that Covered Entities[1] and their Covered Persons[2] providing financial/wealth advisory services to accredited investors (“AIs”) conduct their business activities with integrity and professionalism and that Covered Persons possess a requisite level of knowledge and skills.

As part of the annual CACS CPD requirement, Covered Persons are expected to achieve a minimum of 15 CACS CPD hours, of which a minimum of 8 hours should be in training that is accredited under the IBF Standards Training Scheme[3] (“IBF-STS”) in Private Banking and Wealth Management segment, Future-Enabled Skills or Critical Core Skills (previously known as Generic Skills and Competencies) and a minimum of 4 hours should be in training related to Rules & Regulations, Compliance or Ethics.

Covered Persons who are newly appointed as Relationship Managers[4] or who have less than 3 years of experience as Relationship Managers as at 31 Dec 2018 are required to complete a minimum of 15 hours of their annual CACS CPD in training that is accredited under the IBF-STS (Private Banking and Wealth Management) and be IBF Certified in Private Banking within 3 years[5].

New Covered Persons or individuals who have worked for 6 or less working months in any calendar year may qualify for a prorated CACS CPD obligation for that year based on the table below. Any unfulfilled CPD hours for that year may be carried forward and completed in the next calendar year.

No. of working months in calendar year	CACS CPD Obligation under the PB Code
	Total CPD (Core CPD)	Requirement for IBF-STS Training
		RMs with <3 years’ experience	CPs with >= 3 years’ experience (includes all reported ARMs)

12 months	15 hours (4 hours)	15 hours	8 hours
11 months
10 months
9 months
8 months
7 months
6 months	8 hours (4 hours)	8 hours	Not required
5 months
4 months
3 months
2 months
1 month

[1] A “Covered Entity” refers to any financial institution or a division thereof which is regulated by the Monetary Authority of Singapore (MAS), where the financial institution or division provides services to accredited investors.

[2] A “Covered Person” refers to an individual who is (i) in a client-facing role and (ii) provides financial/ wealth advisory service(s) to accredited investors on behalf of a Covered Entity.

[3] With effect from 1 January 2019.

[4] This includes individuals who transit from other roles (e.g. Assistant RMs, Investment/ Product Specialist or Priority Banking RM) to a Relationship Manager role.

[5] For the avoidance of doubt, a Relationship Manager that is newly appointed in 2019 would need to be IBF Certified in Private Banking before 31 Dec 2022. An existing Relationship Manager with less than 3 years of experience as at 31 Dec 2018 would need to IBF Certified in Private Banking before 31 Dec 2021.

What is IBF’s role as a CACS Administrator?

The IBF has been appointed as the CACS Administrator and serves as secretariat to the IBF PBWG. The CACS Administrator will be the first point of contact in administering the established CACS CPD criteria and handling all CACS CPD queries.

The responsibilities of the CACS Administrator includes:
• To align CACS CPD requirements to Skills Framework for Financial Services- Private Banking where relevant;
• To support IBF PBWG on all CACS CPD matters and queries;
• To provide CACS CPD updates to the IBF PBWG and PBIG;
• To monitor the fulfilment of annual CACS CPD requirements by Covered Persons;
• To conducts annual CACS CPD audits; and
• To update and document revisions to CACS CPD policies

How are the CACS CPD hours tracked?

Both Covered Entities and Covered Persons are expected to maintain appropriate records (e.g. certificate of attendance/ completion, appointment letter or copy of published article etc.) of how the expected CACS CPD hours are met. This should include:
• Name of the course attended;
• Date of the course;
• Type of Activity; and
• Number of hours attended.

The Covered Entity’s Designated Representatives are expected to collate and report the CACS CPD fulfilment of their Covered Persons for the calendar year by 31 January in the following year. In the event that a Covered Person leaves the Covered Entity during the year, the Covered Entity is required to issue a confirmation letter detailing the Covered Person’s CPD records (including any extra hours brought forward from the previous year). IBF reserves the right to perform audits on Covered Entities and Covered Persons to ensure that CACS CPD requirements are met.

As the CACS Administrator, IBF may submit reports to the authorities or industry committees (e.g. Monetary Authority of Singapore and Private Banking Industry Group Executive Committee) from time to time. Personal data relating to individuals that is submitted to IBF for the purposes of CACS CPD reporting will not be disclosed to other parties without the Covered Person’s prior consent.

What is the Private Banking Industry Group (PBIG) and IBF Private Banking and Family Office Workgroup (IBF PBFO WG)?

IBF PBIG

The Private Banking Industry Group (PBIG) is an industry body that reviews and undertakes initiatives to develop and foster the sustainable growth of the Singapore Private Banking Industry.

The terms of reference of the PBIG include:
• To serve as the custodian of the Private Banking Industry Code of Conduct (“PB Code”);
• To enhance the stature, reputation and growth of the Singapore Private Banking Industry; and
• To serve as a channel of communication amongst industry players and with the Monetary Authority of Singapore (“MAS”).

IBF PBFO WG

The IBF Private Banking and Family Office Workgroup ("IBF PBFO WG") oversees the implementation of CACS CPD and advises IBF on initiatives to develop competencies for the private banking and family office segments.

The terms of reference of the IBF PBFO WG include:

Skills Framework for Financial Services - Private Banking & Wealth Management. To provide guidance on competencies required for Private Banking and Family Office segments
CACS Assessment. To provide guidance on the content and coverage of the CACS assessment so that it remains relevant
CACS Continuous Professional Development (CPD) Framework. To provide guidance on the implementation of CACS CPD policies for Covered Persons under the PB Code To provide guidance on training focus areas and coverage for CACS CPD

How long should I retain the supporting documents for CACS CPD activities?

All CACS CPD supporting documents should be retained for a minimum period of 3 years for audit purposes.

How frequently should I report the status of my CACS CPD hours to IBF?

The Covered Entity’s Designated Representatives are expected to submit CACS CPD reporting of their Covered Persons annually for the calendar year by 31 Jan in the following year.

What is the scope of audit for CACS CPD and when will the Covered Entity be informed of any audit findings?

The scope of audit will typically cover processes and procedures in place to endorse CPD activities (i.e. evidence that activities meet the CPD guidelines e.g. endorsement by Designated Representative) and monitor CACS CPD fulfilment (i.e. supporting documents for activities e.g. Certificate of Completion/ Attendance/ Result slips). IBF will follow up on the audit findings with individual Covered Entities upon completion of the audit process.

Is there a specific format for the bank to adhere to when issuing the confirmation letter of the Covered Person’s CACS CPD records?

A sample template is available on the IBF website. However, the bank may provide the confirmation letter using its own format as long as all fields in the sample template (e.g. Indication of penalty hours, Initial of the personnel declared, contact details and company stamp) are clearly indicated.

Whose responsibility is it to monitor the Covered Person’s CACS CPD requirements?

Both Covered Entities and Covered Persons will have to maintain records of how the expected CACS CPD hours are met. Covered Entities are required to monitor and ensure that all Covered Persons who act on their behalf meet the expected CACS CPD hours.

In the event that the Covered Person leaves Covered Entity A to join Covered Entity B, Covered Entity A is required issue a confirmation of the Covered Person’s CACS CPD records before he leaves. It is Covered Entity B’s responsibility to ensure that the Covered Person fulfils his outstanding CPD obligation for the year.

Can an overseas course count towards fulfilling CACS CPD requirement?

Yes. Courses which meet the criteria set out in the CACS CPD guidelines whether taken locally or overseas will count towards CACS CPD hours.

Is there a minimum criterion for trainers of internal or external courses recognised for CACS CPD?

Trainers should minimally possess the relevant qualification or experience in the subject matter.

What are the supporting documents required for an activity under the Training & Education Category to be considered verifiable?

Supporting documents may include the employer’s acknowledgement or sign-off, certificate of attendance or completion, or where there has been an assessment, a copy of the result slip.

When a Covered Person leaves Covered Entity A to join Covered Entity B, and takes a break in between, will his CPD requirement be prorated accordingly?

Where a Covered Person leaves Covered Entity A to join Covered Entity B, he continues to remain in the role, and his CPD requirement would be calculated by adding his total working months in both Covered Entities A and B, and the duration of the break. In the event that the duration of the break exceeds 3 years, the Covered Person will have to pass the CACS Assessment again.

Examples of Covered Persons who are considered to remain in the role include (i) those who join Covered Entity B after serving garden leave with Covered Entity A, and (ii) those who secure employment with Covered Entity B while still under the employment of Covered Entity A, even if they do not start work immediately after leaving Covered Entity A.

These examples are not exhaustive, and Covered Entity B should assess whether a Covered Person can be considered to have exited the industry, taking into consideration factors such as the period of time that has lapsed since the person has left Covered Entity A, reasons for leaving Covered Entity A, nature of employment/activities undertaken since the person has left Covered Entity A, among others. If a Covered Person is assessed to have remained in the role, the break between Covered Entity A and Covered Entity B should be included in the calculation of CPD hours.

Will an overseas private banker who is temporarily transferred to Singapore’s branch be subjected to the CACS CPD requirement?

If the private banker is required to take the CACS Assessment, then he will be subject to the CACS CPD requirement as well during the period for which he is working in Singapore.

Who should be appointed as the covered entity’s Designated Representative?

The Designated Representative(s) of a Covered Entity should be a member of the management team with functional oversight over Human Resources (HR), Learning & Development (L&D), Compliance or in the managing of Covered Persons.

The responsibilities of the Designated Representative(s) include:
• To assess and endorse CPD activities which have not been recognised under the IBF Standards Training Scheme ("IBF-STS") or Financial Training Scheme ("FTS") to ensure compliance with the CACS CPD guidelines; and
• To oversee and ensure the accurate reporting of CACS CPD fulfilment of Covered Persons of the Covered Entity.

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