|
Alternative Compliance Provisions (Section C)
AC1. To be able to use the alternative compliance standard, I have to be "subject to" that standard? What does that mean?
We don't want to burden members with having to comply with multiple standards; that's why we included alternative compliance provisions to allow members to consolidate the number of requirements they need to understand. However, this does not mean that SOA members get to choose which alternative compliance standard they like the best. To be able to use an alternative compliance standard, you have to be subject to or have a reasonable expectation that you could be subject to that standard.
Example: Debra Member is a member of the SOA and the CIA. She does not provide "services of an actuarial nature" (as defined in the CIA Qualification Standard) and is therefore eligible for an exemption from the CIA Qualification Standard. She is subject to that standard, even though she qualifies for an exemption. She can elect to meet the provisions of the CIA Qualification Standard to meet her SOA CPD Requirement as a means of alternative compliance.
Example: Rachel Member works in Germany. She is an SOA member but hasn't practiced in the United States and does not currently issue Statements of Actuarial Opinion in the United States. She will transfer to the United States, effective Jan. 1, 2013. Since she will now be practicing in the United States, she needs to be able to issue Statements of Actuarial Opinion. She meets the U.S. Qualification Standard requirements in 2012, to be able to issue Statements of Actuarial Opinion in 2013. She can use the U.S. Qualification Standard to meet her CPD Requirement since she had a reasonable expectation of having to meet the U.S. Qualification Standard.
Example: Jessica Member, based in the United States, is currently not employed. She wants to be able to re-enter the workforce at any time, and she knows to be employable she needs to be able to issue Statements of Actuarial Opinion. She meets the provisions of the U.S. Qualification Standard each year to keep her resume up to date. Jessica would be able to use the U.S. Qualification Standard as a means of alternative compliance, because she has a reasonable expectation of having to meet that standard, should she reenter the workforce.
Example: Eric Member is based in the United States but does not issue Statements of Actuarial Opinion. He does not meet the U.S. Qualification Standard. He decides to meet the provisions of the IAAust CPD Standard because he's always wanted to work in Australia. However, he has no reasonable expectation of working in Australia in the near future. Eric could not elect to meet the IAAust CPD Standard as a means of alternative compliance, because he's not subject to that standard (he's not an FIAA and does not practice in Australia) and he does not have a reasonable expectation of having to meet that standard.
AC2. I'm already subject to the U.S. Qualification Standard. Why do I have to do both?
You don't have to do both–you can elect to meet the U.S. Qualification Standard as a means of alternative compliance with the SOA CPD Requirement, and use that standard to fulfill both requirements. When you certify compliance with the SOA CPD Requirement, you will certify that you met the SOA Requirement by meeting the U.S. Qualification Standard. This way, you have to focus on meeting only one standard–the U.S. Qualification Standard. You will not have to separately comply with both standards. If your compliance is audited, you will show how over the two-year period, you met the U.S. Qualification Standard in each year.
AC3. I'm subject to the CIA Qualification Standard? Can I elect to comply with that instead?
Yes. If you're subject to the CIA Qualification Standard you may choose the alternative compliance path and meet your SOA CPD Requirement by meeting the CIA Standard. You will certify compliance with the SOA Requirement by certifying that you complied with the CIA Standard, and you will focus on meeting one standard–the CIA Standard. You will not have to separately comply with both standards. If your compliance is audited, you will show how over the two-year period, you met the CIA Qualification Standard.
AC4. Do I need to do something else if I elect to use alternative compliance to meet the SOA CPD Requirement?
Alternative compliance is considered to be compliance in full. Whether you meet the Basic Requirement Provisions of Section B or the Alternative Compliance Provisions of Section C, you must follow the Certification of Compliance procedures outlined in Section D. Document how you're meeting your chosen alternative compliance standard, and be sure to notify the SOA how you've met the standard starting with the cycle ending Dec. 31, 2010 (See FAQs C1, C10, R1 and R3).
AC5. I'm subject to the U.S. Qualification Standard, but I don't need to meet it because I don't issue Statements of Actuarial Opinion. Does this mean that I can meet my SOA CPD requirement using alternative compliance and earning no CPD credit?
No. You must completely fulfill the requirements of the alternative standard (the U.S. Qualification Standard or the CIA Qualification Standard) to be eligible for alternative compliance.
Example: Jacob Member, FSA, who works in the United States, does not issue Statements of Actuarial Opinion (as defined in the U.S. Qualification Standard). Jacob does not need to comply with the continuing education requirements in the U.S. Qualification Standard. Jacob is still potentially subject to the U.S. Qualification Standard, so he can use it as a means of alternative compliance. To fulfill the SOA CPD requirement using the U.S. Qualification Standard as a means of alternative compliance, Jacob would have to fulfill the continuing education requirement of the U.S. Qualification Standard in its entirety (i.e. 30 units of CPD per year, six units in organized activities and three units of professionalism, etc.).
AC6. I'm exempt from the CIA Qualification Standard. Does this mean I can meet my SOA CPD requirement using alternative compliance and earning no CPD credits?
No. As noted in FAQ AC5, you must completely fulfill the requirements of the alternative standard (in this case, the CIA Qualification Standard) to be eligible for alternative compliance.
AC7. I'm subject to the CPD Scheme of the Faculty & Institute of Actuaries (U.K. CPD Scheme). I can meet the U.K. CPD Scheme through Category 3. Does this meet the alternative compliance provisions of the SOA CPD Requirement?
No. Category 3 and 4 of the U.K. CPD Scheme are specifically excluded as means of alternative compliance with the SOA CPD Requirement. Category 3 allows members to determine their own minimum number of CPD hours, and Category 4 does not require any CPD hours. The SOA Board felt that the lack of a specific minimum requirement did not meet the rigor of the other alternative compliance standards. You can elect to complete Category 1 or 2 of the U.K. CPD Scheme as a means of completing the SOA CPD Requirement, or you can meet the provisions of Section B of the SOA CPD Requirement.
AC8. Is completing the Joint Board for the Enrollment of Actuaries' continuing education requirement a form of alternative compliance with the SOA CPD Requirement?
No. However, under very limited circumstances it might be sufficient for the CPD cycle ending on Dec. 31, 2010. It depends on whether you qualify for the limited exemption for Enrolled Actuaries in Paragraph 2.2.8 of the U.S. Qualification Standard.
If you are an enrolled actuary, and you only issue Statements of Actuarial Opinion related to ERISA retirement plans and because of that you meet the Enrolled Actuaries exemption in paragraph 2.2.8 of the U.S. Qualification Standard, you meet the terms of the U.S. Qualification Standard. By meeting the terms of the U.S. Qualification Standard, you meet the SOA CPD Requirement, through alternative compliance. Meeting the Joint Board requirement meets the requirements of the U.S. Qualification Standard, and meeting the requirements of the U.S. Qualification Standard, in turn, meets the SOA CPD Requirement.
|