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CPD Requirement: Record-Keeping, Audits and Exemptions

Frequently Asked Questions

What records must I keep to be able to prove compliance?

A log of activity must be kept, showing how you met the requirement. The log will be different based on whether you are meeting the basic requirement provisions of Section B or an alternative compliance provision of Section C.

For the basic requirement provision:

  • The log should include day, time spent (in minutes and/or units), description of the activity, whether the credit was self-study or structured. If structured credit, if the source was employer or non-employer, whether it was job-relevant, professionalism or business and management skills.
  • The description of the activity should be detailed enough to show why this was a CPD activity.
  • For example, a description of "attended internal webcast" is not sufficient.
  • The description "attended internal webcast on likely impact of PBA on internal audit procedures" is sufficient.
  • Similarly "read article in the Pension Section News" is not sufficient, but "read article titled 'Recent IRS Regulations' in June 2011 Pension Section News" is sufficient.

For the alternative compliance method:

  • The log should show how you met the terms of that requirement in its entirety.
  • For example, the U.S. Qualification Standard has specific requirements for organized activity and professionalism.
  • The log should show how those requirements were met, in addition to the U.S. Qualification Standard's general 30-hour requirement.

What additional proof do I need besides the log?

None. There is no requirement to keep meeting handouts, attendance records, notes or any other method of documentation.

If I am following an alternative compliance standard, and the record-keeping requirements of that organization, will that be sufficient for the SOA's purposes?

It depends:

  • If the other organization has no record-keeping requirement, that is not sufficient.
  • If that organization requires a log, or other similar recording of time spent, that should be sufficient, as long as that log or recording clearly details how you were able to meet the provisions of the alternative compliance standard.

How long do I need to keep records?

  • Keep records for one year from the date that you assert compliance.
  • The SOA audit will happen shortly after the close of the compliance notification period.
  • Remember that the SOA operates on a two-year cycle so you have to keep the log (or a duplicate) of the most recent year's records if you are counting that year in the next CPD cycle.

How will the SOA monitor compliance?

  • The SOA will not take an active role in enforcement or verification. We audit a small number of members, approximately one percent, or 200 members annually per CPD cycle, to verify that members' records confirm compliance.
  • To maintain the integrity of the self-reporting process, about 5 percent of audited members, or 10 members annually, will undergo a second review in which the SOA will gather proof of attendance at structured events.
  • Please note that you are not responsible for retaining proof of attendance at structured events should you be audited.
  • The SOA will work directly with the providers of structured education to verify your attendance.

What is the purpose of the audit?

  • An audit works to ensure good faith compliance on the part of all members, without requiring everyone to submit cumbersome paperwork.
  • For example, an audit process is used by the Joint Board for the Enrollment of Actuaries to ensure enrolled actuaries comply with its continuing education requirement without requiring each enrolled actuary to submit documentation with their enrollment renewal.
  • Early on, an audit also helps to ensure that everyone understands the requirement.
  • If we find that audited records show a misunderstanding of the provisions, then we know there is a point of confusion that we need to address.

What happens if I am audited? What happens if I fail an audit?

  • If you are audited, you must provide a copy of your log showing how you met the requirement.
  • You are not required to keep anything other than a log of your CPD activities.
  • You will not need proof of attendance for structured credit sessions, handouts or other forms of documentation.
  • If you "fail" an audit:
    • If you have made a good faith effort to follow the terms of the CPD requirement, SOA staff will work with you to develop a plan to earn your missing credits on a timely basis.
    • If you "fail" an audit and it is determined that you have not made a good faith effort to follow the terms of the CPD requirement and have falsely certified compliance, you could be subject to disciplinary action

Is anyone exempt from the CPD requirement?

  • No, all members must comply with the CPD requirement.
  • You comply by letting the SOA know as of each Dec. 31 whether you have met the provisions of the requirement.
  • If you do not fulfill the requirement by meeting the Basic Requirement Provisions of Section B, or one of the Alternative Compliance Provisions of Section C, then your CPD status in the membership directory will be shown as "Non-compliant" and you will be required to tell users of your services about your failure to fulfill the requirement.

Am I exempt if I do not practice in a traditional actuarial role?

  • No, all ASAs, FSAs and members who hold the CERA credential are subject to the CPD requirement.
  • Anyone who works in traditional roles and areas of practice is subject to the CPD requirement. Anyone who retains their designation but moved away from traditional actuarial work into emerging areas of practice is also subject to the CPD requirement.
  • The CPD requirement simply ensures that you obtain the "job-relevant" education best suited for your professional development.

Can I get an exemption or partial reduction in requirements if I work part-time?

No, all ASAs, FSAs and members who hold the CERA credential are subject to the CPD requirement.

Can I get an exemption if I am retired?

No, but if you qualify for dues waiver because of retirement, the membership directory will show your CPD status as "Retired".

What if I become unemployed during a cycle or take a leave of absence to raise children or care for a family member? How will that affect the CPD requirement?

  • You are always subject to the CPD requirement regardless of employment status.
  • You can use your credential, but if you have not fulfilled the CPD requirement then the membership directory will show your CPD requirement status as "Non-compliant."
  • If you are not employed, then you should have no users of your actuarial services who would need to be notified of your non-fulfillment of the requirement.

Am I exempt if I am on a dues waiver?

No. If you qualify for dues waiver because of retirement, the membership directory will show your CPD status as "Retired". You are always subject to the CPD requirement regardless of employment status.

Am I exempt if I earned my SOA credential through mutual recognition (rather than through the examination system)

No. See Section A on General Requirements.

I do not have to meet the U.S. Qualification Standard because I do not issue Statements of Actuarial Opinion in the United States. Does that make me exempt from the SOA Requirement?

No. See Section A on General Requirements.

I am exempt from the CIA Qualification Standard. Does that make me exempt from the SOA requirement?

No. See Section C on Alternative Compliance.