2017-12-28
Added · Updated
The Hong Kong Monetary Authority and the Hong Kong Institute of Bankers launched the Enhanced Competency Framework on Retail Wealth Management to establish professional standards for retail wealth management practitioners in the banking industry. The framework defines two competency levels, Core and Professional, requiring practitioners to complete specific training modules, pass examinations, and fulfill annual continuing professional development obligations to obtain certification. Although non-statutory, the guide encourages authorized institutions to adopt these standards for talent development, recruitment, and assessing employee competence.
Guide to Enhanced Competency Framework on Retail Wealth Management Hong Kong Monetary Authority December 2017
2 - Contents 1 Introduction .............................................................................................................................. 3 2 Objectives .................................................................................................................................. 4 3 Scope of application ................................................................................................................. 5 4 Competency standards ............................................................................................................. 6 5 Qualification standards and certification ............................................................................... 7 6 Continuing professional development (“CPD”)..................................................................... 9 7 Training programmes and examinations ............................................................................. 11 8 Grandfathering ....................................................................................................................... 11 9 Maintenance of relevant records ........................................................................................... 12 10 Administration of the ECF-RWM ........................................................................................ 12 11 Accreditation .......................................................................................................................... 12 Annex 1 - ECF-RWM: Key roles and tasks for Relevant Practitioners .................................... 14 Annex 2 - ECF-RWM: Competency framework ......................................................................... 15 Annex 3 - ECF-RWM: Learning outcomes and topics ............................................................... 16 Annex 4 – Accreditation mechanism for ECF-RWM ................................................................. 22
3 - 1 Introduction 1.1 Hong Kong has a high potential demand in various investment or wealth management services at the retail level. As a proxy indicator, the population of retail investors was over 2.25 million people1 underlined by the Gross Domestic Product per capita for 2016 at above HK$339,0002 . On the other hand, the growing business opportunities are met with heightened customer expectations on the quality of financial advising or investment services. 1.2 In order to support sustainable development of the retail wealth management business, there is a need to further instill the talent pool with the required professional knowledge, job skills and ethical behaviour by introduction of a banking industry-wide competency framework. The goal is to enable talent development and facilitate the building of professional competencies and capabilities for those already working in the retail wealth management stream and those preparing to join. 1.3 Against this background, the HKMA, together with the Hong Kong Institute of Bankers (HKIB), will launch a module on Retail Wealth Management under the Enhanced Competency Framework (ECF) for banking practitioners 3 . It aims to facilitate the practitioners to develop their relevant skills and professional competencies more effectively and apply learning in their work as retail wealth management professionals. In addition, it can allow practitioners to gain recognition of their professional experience and knowledge and get a stronger foothold in the banking sector. Authorized institutions (AIs) will also be able to benefit from the improvement of skill match and availability of a more productive retail wealth management workforce.
1 According to the Retail Investor Survey 2014 conducted by Hong Kong Exchanges and Clearing Limited (HKEX), it showed that 36.4% of the Hong Kong adult population (or 2,265,000 individuals) were retail investors in stock (i.e. securities market products) and/or derivative (i.e. futures and options) traded on HKEX https://www.hkex.com.hk/eng/stat/research/Documents/RIS2014.pdf 2 Census and Statistics Department of HKSAR Government’s Hong Kong in Figures - Gross Domestic Product for 2016 http://www.statistics.gov.hk/hk_in_figures/nibp/nibp1e.xls
3 In addition to the ECF on retail wealth management, there are six other modules introduced or to be introduced, including (i) private wealth management, (ii) anti-money laundering and counter-financing of terrorism, (iii) cybersecurity, (iv) treasury management, (v) credit risk management, and (vi) risk management and compliance.
4 - 2 Objectives 2.1 The Enhanced Competency Framework on Retail Wealth Management (hereinafter referred to as “ECF-RWM”) is a non-statutory framework which sets out the common core competences required of retail wealth management practitioners in the Hong Kong banking industry. The objectives of the ECF-RWM are twofold: (a) to develop a sustainable talent pool of retail wealth management practitioners for the banking industry; and (b) to raise and maintain the professional competence of retail wealth management practitioners in the banking industry. 2.2 Although the ECF-RWM is not a mandatory licensing regime, AIs are encouraged to adopt it for the following purposes: (a) to serve as a benchmark to determine the level of competence required and assess the ongoing competence of individual employees; (b) to support relevant employees to attend training programmes and examinations that meet the ECF-RWM benchmark; (c) to support the continuing professional development of individual employees; and (d) to specify the ECF-RWM as an industry-recognised qualification including for recruitment purposes.
5 - 3 Scope of application 3.1 The ECF-RWM is aimed at ‘Relevant Practitioners’ (RPs), i.e. persons engaged by AIs performing the following job roles within the retail wealth management function: Role 1 – Frontline Customer Relationship and Retail Wealth Management Role 2 – Risk Management and Control (Staff who assume frontline retail wealth management roles and additional risk management duties as supervisors) Role descriptions (Please refer to the key tasks specified in Annex 1 for the detailed definition of each role) • Promote insurance and financial products to retail customers • Deliver investment, insurance or wealth management services to retail customers, taking into account customers’ circumstances • Oversee policies, procedures and controls for suitability assessments and selling practices • Supervise Know Your Customer (KYC)4 processes and review customer risk profiling 3.2 The definition of RPs recognizes differences in organization structure and job design among AIs in Hong Kong. To facilitate the determination of whether a staff member falls under the scope of RPs, the key tasks of different retail wealth management job roles are specified in Annex 1 as guidance. 3.3 The ECF-RWM applies to staff performing retail wealth management roles with key tasks specified in Annex 1. It is not intended to capture staff performing other job functions that are incidental to retail wealth management (e.g. staff responsible for sole promotion of deposit, MPF products or general insurance products5 (e.g. home or travel insurance) to retail customers without engaging in other retail wealth management functions). 3.4 In addition, the following categories of staff do not fall within the definition of RPs of ECF-RWM: (a) Staff in retail wealth management functions performing solely clerical and administrative duties.
4 Under the ECF-RWM, KYC processes refer to those aiming at understanding the risk profiles of customers and assessing the suitability of financial products rather than mitigating the risk of money laundering or financing of terrorism. 5 For the purpose of this Guide, general insurance products refer to products involving insurance contracts that belong to any class(es) of general business as defined in the Insurance Ordinance and do not carry substantial savings component.
6 - (b) Staff who handle general customer enquiries or manage customer relationships (unrelated to wealth management or financial products). (c) Staff responsible for back office functions without customer-facing or advisory roles (e.g. risk and control, risk profiling, product design and management, sales quality review, legal and compliance, financial reporting and internal audit). (d) Staff responsible for pure execution of transactions relating to financial products without delivering retail wealth management services. 3.5 For avoidance of doubt, a staff member is not required to work full time in retail wealth management or perform all of the roles specified in Annex 1 in order to be classified as a RP. A principle-based approach can be adopted by AIs in determining whether a staff member with multiple job roles falls within the definition of RPs for the ECF-RWM, based on the significance and permanence of the retail wealth management role performed by the staff member. AIs should be able to justify decisions made in this regard. 4 Competency standards 4.1 Competency standards are set at two levels: • Core level This level is applicable to entry-level staff responsible for carrying out frontline customer relationship and retail wealth management duties. • Professional level This level is applicable to staff who can discharge frontline customer relationship and retail wealth management duties on their own and/or assume additional risk management and control duties as supervisors. 4.2 The competency framework for the ECF-RWM with details on the key tasks, qualifications required and continuing professional development requirement for each job role of a RP is included in Annex 2.
7 - 5 Qualification standards and certification 5.1 Qualifications are set in accordance with the following two competency standards: (a) Core Level This level of qualification can be met by completing Module 1 to Module 4 of the Certified Financial Management Planner (CFMP) or the ECF on RWM training programme6 . The following arrangements are allowed for RPs to obtain exemption from completing individual modules of the training programme: RPs eligible for exemption CFMP or ECF on RWM Training Programme Module 1 Module 2 Module 4 (a) 1. RPs who are current Relevant Individuals (RIs) of specified regulated activities7 and have met the academic / industry qualification and regulatory knowledge requirements by passing relevant LE8 papers or obtaining exemption as set out in the Guidelines on Competence of the Securities and Futures Commission (SFC)
6 The HKIB is undergoing a process to develop a new ECF on RWM training programme. The training programme is expected to be launched in Q1 2018, subject to the accreditation by HKCAAVQ. Transition arrangement will be available for existing candidates studying towards the CFMP qualification after the launch of the new ECF on RWM training programme in 2018. 7 Type 1 – Dealing in securities and/or Type 4 – Advising on securities as defined in the Securities and Futures Ordinance. 8 LE refers to Licensing Examinations for Securities and Futures Intermediaries.
9 The three-year threshold can be met by (i) being a RI and/or licensed with the SFC in respect of specified regulated activities either currently or within the three years immediately before applying for exemption from individual module of the training programme; or (ii) passing the relevant LE paper(s) within the three years immediately before applying for exemption from individual module of the training programme.
10 Generally, the ECF Administrator will consider whether the nature of work experience is substantially the same as those described in the retail wealth management roles 1 and 2 in Annex 1.
10 - 6.2 Activities that qualify for CPD include: (a) Attending seminars or courses provided by AIs, professional bodies, academic and training institutions, and the HKIB; (b) Sitting professional examinations; (c) Self-study through e-learning (with assessment); (d) Delivering training and speeches; and (e) Writing on wealth management or related disciplines for publication. 6.3 Out of the 10 CPD hours, at least 3 CPD hours must be earned from activities related to topics of compliance, code of conduct, professional ethics or risk management. 6.4 CPD training topics should be related to banking and finance or the job function: (a) compliance, code of conduct, professional ethics or risk management (b) banking and financial knowledge (c) economics (d) accounting (e) legal principles (f) business and people management (g) language and information technology (h) subject areas covered in HKIB professional examinations 6.5 The annual CPD requirements are also applicable to RPs meeting the ECF-RWM benchmark through the grandfathering route. 6.6 The CPD requirements will be waived for the first calendar year (ending 31 December) of certification and grandfathering. 6.7 The lists of CPD activities and training topics are subject to HKIB’s review from time to time. For details, please refer to the HKIB’s website (https://www.hkib.org/).
11 - 7 Training programmes and examinations 7.1 RPs can meet the ECF-RWM benchmarks by undertaking: (a) CFMP or ECF on RWM training programme of HKIB or accredited training programmes; and (b) passing examinations accredited by HKIB. 8 Grandfathering 8.1 A RP may be grandfathered on a one-off basis based on the following grandfathering arrangements: (a) Core Level: • Passed the Certified Financial Planner (CFP) Certification Examination (Foundation Level) upon the cut-off time of the grandfathering application period; • Employed by an AI at the time of application; and • Possessing at least 1-year relevant work experience11 (b) Professional Level: • Possess valid CFP Certification upon the cut-off time of the grandfathering application period; • Employed by an AI at the time of application; and • Possessing at least 3-year relevant work experience12 8.2 Existing RPs meeting the above criteria can submit their grandfathering applications to HKIB, administrator of the ECF-RWM, during 2 January 2018 to 31 December 2018. A one-off grandfathering fee will apply. 8.3 For other individuals performing the job roles outlined in paragraph 3.1 but not working in an AI or those staff of an AI as specified in paragraph 3.4(a) to (d) during the grandfathering application period, they may submit their applications to the HKIB for grandfathering within three months from the date of joining the retail wealth management functions of an AI and becoming a RP. However, they should have met all the applicable grandfathering criteria on or before 31 December 2018 as prescribed
11 Please see footnote 10. 12 Please see footnote 10.
12 - above. 8.4 Applications for grandfathering are handled and assessed by the HKIB. The HKIB may request the applicant to provide employment records or additional information to substantiate the application for grandfathering. Late application will not be accepted. 8.5 Upon grandfathering, obtaining ARWP or CRWP certification with the HKIB is optional. 9 Maintenance of relevant records 9.1 AIs should keep proper training, examination, certification and CPD records of RPs for monitoring implementation of plan for developing staff competencies or for other talent management purpose. AIs are expected to support their staff to apply for grandfathering and certification. Regarding information related to a RP’s previous employment(s), the current employer is encouraged to provide the necessary assistance to RPs in the latter’s applications for grandfathering or ECF certification (e.g. confirming whether such information is consistent with the curriculum vitae provided by the RP at the time of job application). 10 Administration of the ECF-RWM 10.1 The HKIB is the administrator of the ECF-RWM and will be tasked with handling applications for certification and grandfathering under the ECF-RWM. The HKIB will also administer the CPD requirements as set out under the ECF-RWM. For details, please refer to the HKIB’s website (https://www.hkib.org/). 11 Accreditation 11.1 The ECF accreditation mechanism is established for interested AIs or education and training operators to have their learning programmes accredited as meeting the ECF standards (including but not limited to the Qualifications Framework (QF) Standards) of this ECF module. 11.2 The general criteria for ECF accreditation are as follows: (a) The learning programme meeting the required standards of individual ECF modules including programme objectives and learning outcomes, programme
13 - content and structure, and trainer qualifications and learning mode; (b) Accreditation of the learning programme at corresponding QF Levels; and (c) Endorsement by the ECF Steering Committee. 11.3 In order to satisfy criteria 11.2 (a) and (b) outlined above, (a) For self-accrediting institutions (e.g. institutions funded by the University Grants Committee, including their continuing education arms) / institutions with Hong Kong Council for Accreditation of Academic and Vocational Qualifications (HKCAAVQ) Programme Area Accreditation (PAA) status in related programme areas, they are required to: (i) complete internal quality assurance processes for meeting the relevant ECF standards and the corresponding QF Level and (ii) be assessed by HKCAAVQ as fulfilling the ECF training objectives (b) For other institutions, they are required to complete the accreditation by HKCAAVQ to confirm that their learning programmes can meet the ECF training objectives and the corresponding QF Level 11.4 HKCAAVQ will accept applications for ECF accreditation starting 2 January 2018. 11.5 Based on the relevant accreditation or assessment report submitted by the applicant, the ECF Steering Committee will confirm whether the training programme is or is not successful to qualify as an ECF accredited programme. The route for ECF accreditation mechanism is illustrated at Annex 4.
14 - Annex 1 - ECF-RWM: Key roles and tasks for Relevant Practitioners Role 1 – Frontline Customer Relationship and Retail Wealth Management Role 2 – Risk Management and Control (Staff who assume frontline retail wealth management roles and additional risk management and control duties as supervisors.) Core Level Examples of functional title Banking Services Officer / General Banking Officer / Personal Banking Officer / Sales and Services Officer -- Key tasks 1. Promote insurance and financial products to customers and explain product features to retail customers
13 Refer to paragraph 5.1(a) above for detailed information on exemption arrangements.
14 The Code of Conduct for Persons Licensed by or Registered with the SFC.
17 -
Treasury services
Investment banking services
Private banking services • Introduction to risk management, risk governance and risk culture in banking 2.2 Investment planning • Overview of the global and the Hong Kong financial markets • Securities investments in the global market and national markets • Hong Kong financial markets and instruments (equity, debt, foreign exchange, and derivatives) • Securities investment
Overview of the global and Hong Kong securities markets
The stock exchange of Hong Kong
Securities investment and participants in the Hong Kong securities markets • Securities analysis (fundamental and technical analysis) 2.3 Ethics and compliance • Regulatory framework of the financial services industry in Hong Kong
Legal principles of Hong Kong law
Legal and regulatory regime
Regulatory bodies and ordinances administered by them • Regulation of the banking industry
Fundamentals of Banking Ordinance
HKMA Supervisory Policy Manuals • Regulation of securities and markets and business operations / practices
Fundamentals of the Securities and Futures Ordinance (SFO)
Licensing regime
Regulated activities under SFO
Management and supervision
Market misconduct and improper trading practices
SFC authorised investment products and services
HKMA Guidelines on sale of investment products
18 - • Regulation of insurance and Mandatory Provident Fund (MPF) • Other relevant legislations
Prevention of money laundering
Protection of customer data • Code of banking practices and banking services
Product suitability assessment
Risk disclosure
Enhanced investor protection measures
Treat Customers Fairly Charter • Ethics and code of conduct of a banker • Code of conduct under SFC 2.4 Insurance and retirement planning • Insurance and risk management • Functions and benefits of insurance • Principles of insurance • Practice of insurance
Structure of an insurance company organisation and an insurance policy • Structure of the insurance market
Participants of the insurance market and their roles
Structure of the insurance market in Hong Kong and Mainland China • Types of insurance products
General insurance
Individual life insurance (term life insurance, life insurance with cash value, endowment plan, universal life plan, supplemental benefits, annuities, and application for life insurance)
Investment-linked long term insurance • Retirement plans and MPF
Needs for retirement planning
Features of the social safety net for retirement in Hong Kong
Combination of a MPF plan • Insurance as protection planning solutions and personal risk management
19 - II. Professional Level
Fixed income investments
Equity securities investments
20 -
Foreign exchange
Derivatives
Structured products
Investment funds and unit trusts • Alternative investment
Overview of alternative investment
Hedge funds
Commodities
Private equity • Real estate investment • Leverage, loans and liquidity management
Application of leverage in investment
Collateralised lending in wealth management • Portfolio management theory and practice
Portfolio theory
Capital asset pricing model
Portfolio management process • Asset allocation of investment funds portfolio
Client investment objectives and fund investment objectives
Asset allocation strategies 2.2 Tax planning and estate planning • Overview of the taxation system • Principles of tax planning • Principles of estate planning 2.3 Financial planning and wealth management • Overview of the wealth management industry and asset management industry
Wealth management business models and industry outlook
Clients and stakeholders
Investment management services for high net-worth individuals
Private wealth management services
21 - • Fundamentals of financial planning
Financial planning process
Financial management • Managing client relationship management • Upholding professional ethics and avoiding conflicts of interest • Case studies in financial planning
Investment planning
Life cycle financial planning
22 - Annex 4 – Accreditation mechanism for ECF-RWM Subject to re-accreditation/re-assessment by HKCAAVQ Endorsement by ECF Steering Committee Applicant to notify ECF Steering Committee the intention of obtaining accreditation with programme objectives & learning outcomes, programme syllabus, training materials, and trainers’ profile for record Obtain ECF and QF accreditation through HKCAAVQ Submit proof on ECF and QF accreditation Training programme accredited for ECF Register on the QR Submit proof on ECF assessment
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