Match & Mix Level Six – the Multi Body PTS Conundrum by Andrew Houghton

It’s a question that has been asked of us a few times over the last few months. Can you mix and match examining bodies to become a PTS. If you’ve done your CII diploma, can you do PETR with it? What about DipFa holders doing AF7? And where does PTPA fit into the equation. The answer, as confirmed by TC App 4.1 in the FCA handbook as of today (21 May 2019) is this.
The CII Certificate in Pension Transfers is recognised as an appropriate qualification to act as a pension transfer specialist. This requires completion of R01, R02, R04 and AF7. R01, R02 and R04 are, obviously, part of the Diploma in Regulated Financial Planning. Therefore, anyone who has that qualification can complete AF7 and act as a pension transfer specialist.

The other route that is open is to existing CII students who hold Diploma in Financial Planning, but may not necessarily hold an RDR compliant version. Those students can complete appropriate gap fill, together with AF7, and be accredited as a pension transfer specialist.

For those holding other organisations’ qualifications, the AF7 situation is less promising. Basically, the FCA qualification table makes no provision for students with another body’s level 4, RDR compliant or not, to sit AF7 and qualify as a PTS. You would therefore be reliant on the CII’s own recognition of prior learning program. Standard exemptions include R01 and R06 for those with the LIBF’s DipFA and R01 for those with the CISI investment Advice Diploma. However, this still appears to leave you needing to pass R02 and R04 in addition to AF7.

The LIBF unfortunately is no different. Its accreditation states: ‘Pension Transfers plus Diploma for Financial Advisers (DipFA®) post 2010 exam standards’. Therefore, if you have DipFA then PETR becomes an option.

Happily, the exception to all of this is the CISI’s PTPA examination. The accreditation for PTPA includes ‘Certificate in Pension Transfers and Planning Advice (when combined with an RDR compliant qualification for Activities 4 and 6)’. Therefore, any RDR compliant qualification is acceptable.

It remains to be seen whether this anomaly will be amended over the coming months/ years or whether the FCA/ examining bodies will stick to their guns. Perhaps an important point to note is that from October 2020, any practicing PTS will be required to have a level 4 investment advice qualification (at present, this is only required if they are also the party advising on the receiving investments). Therefore, those with ONLY R01, R02, R04 and AF7 will be required to complete the set of R0s OR complete other level 4 modules with appropriate gap fill.

Those with the old-style AF3 or G60 modules have less to worry about, as their qualifications are considered sufficient to act as a PTS on a stand-alone basis. However, they will still be subject to the requirement to complete an RDR compliant level 4 qualification by October 2020 if they wish to continue to act. There will be no grandfathering.

Confused? I don’t blame you!