SOA CPD Requirement–Frequently Asked Questions (FAQs)
Recordkeeping & Audit
R1. 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 an 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.
R2. 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.
R3. If I'm following an alternative compliance standard, and I'm following the recordkeeping requirements of that organization, will that be sufficient for the SOA's purposes?
That depends. If the other organization has no recordkeeping requirement, then clearly 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.
R4. How long do I need to keep records?
One year from the date as of which you assert compliance. The SOA audit will happen shortly after the close of the compliance notification period. Remember, though, 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're counting that year in the next CPD cycle.
R5. How will the SOA monitor compliance?
The SOA won't take an active role in enforcement or verification but will audit a small number of members–approximately 1 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're 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.
R6. 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's a point of confusion that we need to address.
R7. What happens if I'm 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, and if you've 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.
R8. I know that SOA will be auditing a limited number of member's CPD records as part of its attestation process. What if the SOA disputes that some credits are not allowable, which would bring you below the number of credits needed to meet the requirement?
First, a primary intent of the audit, particularly in the first few years of compliance, is to ensure that everyone understands the requirement and is fulfilling it to the best of their abilities. Second, the primary check being performed in the audit is that sufficient credit was earned and in the proper categories (based on the compliance method chosen by the member).
Most of the compliance methods (Section B of the SOA CPD Requirement, the US Qualification Standard, the CIA Standard, the UKAP CPD Scheme and the IAAust CPD Standard) place a heavy reliance on the member to determine what courses are relevant to their own professional development. We don't anticipate that the SOA would disallow credits unless inclusion of those activities as CPD credits was an egregious error (e.g. including "Attendance at the Parent-Teacher Association Meeting" as job-relevant or relevant CPD).
To the extent a member has made a good faith effort at compliance, and the error is minor, the SOA may, at its discretion, counsel a member that such credit ought not to be used again in the future (the member's SOA CPD compliance status would not change). If the error is more significant, the normal course would be for those credits to be disallowed, and the SOA member's CPD compliance status to be set at "Non-compliant" until such time as a member has earned sufficient credits to change the status back to "Compliant." "Compliant" status can be reinstated as soon as the member can attest to having earned the additional credits. For example, the member could allocate credits already earned in the audit year back to the prior cycle, and comply immediately.
In extreme cases, including but not limited to instances where a member has repeatedly attested compliance with the standard by counting as CPD activities that clearly did not meet the standard, the member can be brought to the ABCD for violation of the Code of Professional Concept (most likely under Precept 12).