GISC issued a guidance note a few weeks ago referring to the proliferation of organisations selling services under the guise of "compliance support". (For the actual wording go to

GISC issued a guidance note a few weeks ago referring to the proliferation of organisations selling services under the guise of "compliance support". (For the actual wording go to )

This can be something of a nightmare for compliance officers, training officers and of course the directors or partners of regulated firms who, ultimately, are responsible for allocating sometimes scarce resources.

Many firms offering such services are genuine, expert and reasonably priced but, at the other end of the scale, there are some who are not so genuine.

Logging on
The proliferation of "learning systems" that are being offered to broker firms is a matter of concern. Insurance companies, computer companies, human resource specialists and even psychological research centres are all getting in on the act. There is little doubt that as the next two years unfold, all practitioners will find themselves logging on for training and competence assessments.

Frankly, I have some reservations. I always become suspicious when insurers start doing things for brokers, particularly at a time when they cannot quote a decent rate for half the insurance business offered to them. Looking back over the past 40 years, how often those now offering to sell us these wares, have appeared so close to turning their backs on brokers for direct sales.

It will take a lot to convince me that they and the others suddenly appearing in the market are other than opportunists seeking to grab the lucre that regulation offers. Will they all be willing to give the time and money that is required to fuel these systems with material well into the future and also keep them up to date and current?

An assessment and learning system is not just for Christmas and prospective buyers might do well to consider the following list:

  • Shareholders and dividends
  • Directors' bonuses
  • Changes in management
  • Changes in distribution preference
  • Takeovers
  • Liquidations (did not brokers rely on Independent for some training support?)

    My opinion is that, while such systems are going to be vital for ease of use and access to assessment and learning material, the only real way to make sure the broker gets the right deal is for the following criteria to be satisfied

    It must help you to be GISC and FSA compliant, so perhaps you shouldn't really commit to anything too expensive, until we know a little more about FSA thinking.

    Is the material really broker friendly?

    Is it relevant to the jobs in your firm?

    Is the material up to date?

    On the last point I would be suspicious of any system that did not have any material about the employers' liability crisis and hard markets if it is being sold to a broker.

    Is it too cheap? The writing of good material costs money. If it is too cheap the chances are that the material is not well thought out or is stale and not updated.

    How often is the material updated (monthly is excellent, three-monthly the minimum)?

    Does it cover the subjects in your job specification?

    Does it record information in a manner that is comfortable to you and your staff and assists your compliance plan?

    Learning point 1
    If you have the responsibility of choosing or evaluating a learning and assessment system, you need to construct a list of what you require from the system or product and not just rely upon what you are told you need.

    If you need help then use a specialist consultant or talk to your trade association. It may feel as though the suppliers love you and are knights in shining armour, but do not forget that they have to meet targets as well.

    Learning point 2
    This arises out of an exercise to do with job specifications. You need one before you can start a training plan and you need one for each job in your organisation. The task is not about job specifications themselves but about an element of the specification.

    Make a list of all the competencies that are required to do your job well. For the following example we have used an account executive specialising in farms and agricultural risks.

    A competency is knowing about a subject, understanding it and being able to apply the knowledge and understanding in doing your job. It effectively means an activity undertaken by the individual, to an accepted standard, which has real meaning in the work place.

    Now split it into four sections:
    Agricultural motor

    Regulatory (GISC)
    The commercial code
    The law of agency (basic)
    Money laundering (basic)

    Soft skills
    Telephone skills
    Meeting skills
    Time management
    Looking good in a waxed jacket and wellies

    Firm specific
    The firm's rules
    The firm's compliance rules

    There are two uses for this exercise: it will allow you to check what areas you (or your employer) need to consider for the next stage of competence assessment. This is a training needs analysis (see Insurance Times Broker Toolkit); and if you are responsible for choosing and evaluating one of these systems, one that cannot provide learning material on all of the first three lists might be considered suspect with regard to your needs.

    And there are two final points that relate to the feel of the material if you are evaluating systems of external training:

    Does it relate to your job and do the examples of situations seem real to your normal working life? Many blocks of material are prepared from textbooks rather than real life experience.

    Does the system provide learning material about things that can go wrong?

    Good luck with the exercise and record everything on your training and CPD file.

    Recommended reading
    Designing Competence Based Training and Competence Based Assessment Techniques, both by Shirley Fletcher and published by Kogan Page.

    Also David Jackman from the FSA is talking at the CII Training and Development Forum on 5 December.

  • Waltham Pitglow is an insurance investigator specialising in compliance.

  • This page is edited by RW Associates, specialists in training, competence and compliance. Email to:

    Using this CPD page
    For the vast majority of practitioners and indeed support and supervisory staff in our industry, CPD is about regular learning and study that is planned, recorded, timed and evaluated.

    If you are a member of a professional body with a CPD requirement then there will be certain rules regarding the quality and nature of study material, and the way in which it is recorded.

    For staff of GISC members this means recording on your individual training file what the learning was, who provided it and when.

    It might be structured, such as a course, a learning programme or exam study. But it can be unstructured. This form of study encompasses reading the trade press, technical material or taking part in activities to support your professional body.

    Some CPD requirements are points related (a little antiquated) and others require a time value to be allocated.

    For example, it might take one hour to read Insurance Times each week. Most of that could be put as a time value but, in reality, perhaps only an half hour was devoted to learning something. The rule is to be honest with yourself and record the time that is relevant.

    Always take time to make a note of what you felt you gained from the activity. This is useful information for anyone else considering the same activity.

    In response to the popularity of our CPD programme each week's CPD page can now be downloaded from our website. We will be preparing a binder for you to keep these in alongside the results of your exercises and a record of your CPD hours.

    To download a PDF of this article as it appears in the magazine click here .

    To view this article you will need Adobe Acrobat