Scope
This policy applies to Macquarie Equities Limited (‘MEL’) and the Private Bank (a division of Macquarie Bank Limited (‘MBL’)), in compliance with the Corporations (Relevant Providers Continuing Professional Development Standard) Determination 2018. Specifically, this policy applies to all employees who are:
- authorised by MBL to provide personal advice to retail clients under the MBL AFSL 237502;
- authorised by MEL to provide personal advice to retail clients under the MEL AFSL 237504.
Hereafter referred to as ‘relevant providers’. Where the term 'Licensee’ is used in this document, it refers to either or both MBL and MEL, as appropriate.
Purpose
Continuing Professional Development (‘CPD’) is an essential requirement for maintaining accreditation and embraces a culture of lifelong learning. In particular, CPD:
- maintains currency of technical knowledge
- enhances and extends knowledge and skills
- involves critical reflection and development
- is relevant and flexible
- is integral to ethical and professional practice.
This policy embeds a CPD framework to ensure compliance with:
- the Corporations Act 2001; and
- the Corporations (Relevant Providers Continuing Professional Development Standard) Determination 2018 (‘CPD Determination’)
CPD Year
For the purpose of this policy, a ‘CPD Year’ is the 12 month period from 1 July to 30 June (inclusive) each year.
Overall approach
Each relevant provider will be allocated an approved CPD plan at the commencement of a new CPD Year or when their CPD requirements commence. CPD plans and any other specific requirements that the relevant provider is required to achieve must be recorded in the Kaplan Professional Ontrack platform.
Each relevant provider, unless otherwise excepted, must ensure they undertake a minimum of 40 hours of approved CPD activities in total per CPD Year, consisting of at least:
- 5 hours for technical competence;
- 5 hours for client care and practice;
- 5 hours for regulatory compliance and consumer protection; and
- 9 hours for professionalism and ethics.
PLUS
- 5 hours of tax specific training for relevant providers who are authorised to provide tax financial advice.
The attribution of the remaining hours will be based on a relevant provider’s individual development needs.
Part time employees
In special circumstances where employees work part-time for the whole of the CPD year, their minimum hours may be reduced to 36 hours, with prior written consent of the Licensee. This is considered on a case-by-case basis.
Career breaks
Where relevant providers take a career break for a continuous period of 2 year or more, a CPD plan for the CPD year must be established and approved by the Licensee prior to resuming practice as a representative. Appropriate CPD activities must be undertaken to ensure the relevant provider is upskilled with the latest regulatory and licensee requirements
Transferring relevant providers
Relevant providers that transfer from another licensee during a CPD year must meet the CPD requirements for the full CPD Year.
For activities undertaken outside Kaplan, details must be loaded into the Kaplan Professional Ontrack platform, with evidence submitted for assessment.
The Licensee will also request evidence that CPD requirements have been met in the previous 2 years. If this is not possible or available, additional appropriate CPD may be added to the CPD plan, to ensure relevant providers are up to date with the latest regulatory and licensee requirements.
Extenuating circumstances
Those impacted by illness, medical conditions, disability or parental leave must liaise with the Licensee, who will determine a remedial CPD plan on a case-by-case basis.
Where an individual’s leave of absence is 3 months or more during a CPD Year, generally their authorisation will be suspended, and a new CPD plan will be commenced on their return to work, as if they have taken a career break (outlined above).
Professional Year candidates
Provisional relevant providers who are completing their Professional Year are not required to meet CPD requirements outlined in this policy.
However, CPD requirements will apply once the Professional Year is completed. Given the extent of training undertaken during the Professional Year, CPD hours for the period between a relevant provider’s completion of the Professional Year and the end of the CPD Year may be pro-rated, and will be considered on a case-by-case basis.
CPD Plan assessment and approval
CPD plans will include the minimum CPD hours and the minimum areas of competency. It will also consider the relevant provider’s individual training needs and identify areas for improvement in, and development and extension of, their competence, knowledge and skills.
CPD Plan implementation monitoring
CPD plans will be loaded into the Kaplan Professional Ontrack system for implementation and monitoring.
The Licensee will use the Kaplan Professional Ontrack system to monitor CPD plans on a quarterly basis, and to verify that each relevant provider has fulfilled their CPD requirements.
Assessment and approval of CPD activities
Relevant providers can use a variety of channels to satisfy CPD requirements, provided the course is relevant to the providers accreditations and/or activities as a representative. These include:
- online learning, including courses offered by external providers (e.g. Kaplan) and those developed internally;
- workshops and seminars;
- self-directed study; and
- internal or external PD Days / conferences
- At least 70% of the qualifying activities must be approved by the Licensee.
Activities completed through Kaplan are Licensee approved CPD activities and do not require additional assessment or approval.
For activities undertaken outside Kaplan, relevant providers are responsible for uploading details into the Ontrack platform and submitting evidence for assessment. The Licensee will assess the proposed activity to determine whether it is a qualifying CPD activity as defined in Section 7 of the CPD Determination. After assessment, the Licensee will notify the adviser if the proposed activity is approved, and if so, the relevant CPD area and hours. The Licensee may allocate a different number of CPD hours to external events, despite the CPD hours dictated by the external provider.
If a CPD activity meets the requirements of more than 1 CPD area, it must only count towards the CPD area to which it predominately relates, to ensure there is no double counting.
The approved CPD activities must not include any more than 30 hours of ‘formal relevant education’ provided by an education provider, which may include;
- a degree, equivalent qualification or course approved under the Corporations (Advisers Degrees, Qualifications and Courses Standard) Determination 2018;
- education or training provided or approved by a professional association;
- formal education or training study towards qualifications or designations relevant to practice as an adviser.
The approved CPD activities must not include any more than 4 hours of professional reading.
Compliance with CPD Policy and CPD Determination
Relevant providers must comply with the CPD obligations specified in this Policy. Failure to meet the specified requirements will result in mandatory reporting to ASIC of non-compliance with the CPD standard as outlined in the Corporations Act.
Record keeping
All CPD activities must be recorded through the Kaplan Professional Ontrack platform. This will capture:
- total number of training hours completed, and;
- details of training completed, and;
- category or classification of training, and;
- date training completed, and;
- number of training sessions and hours per session, and;
- all reflections completed.
Completion of approved CPD activities outside of Kaplan must be manually loaded into Kaplan by the relevant provider, including evidence of completion and will be assessed by the Licensee for approval.
CPD records must be maintained for at least 7 years.
