BOG Candidates: support for mandatory CPD requirements

[no]

Do you support it?

In another thread, I learned in a colorful language that current board members unanimously support it. I am curious how many of new candidates support it.

[bdschobel]

I don't recall seeing the word "unanimously," although maybe someone said that. A true statement would be that the leaders (presidents and presidents-elect) of the North American actuarial organizations unanimously signed a letter supporting mandatory CPD in September 2006. The Board includes many more people, of course. I don't recall any serious opposition in several discussions this year, but I'm not prepared to say that the Board unanimously supports mandatory CPD.

Bruce

[Jeremy Gold]

I support CPD and I admire the passion that Bruce brings in support of it.

I too would like to hear from the 21 people presently running for 10 Board seats.

[dhyamamoto]

I have somewhat mixed feelings about anything being mandatory but I'm in general support of mandatory CPD. Probably not what you'd expect from someone who has been responsible for continuing education in both the SOA and the CCA. There was an SOA Board motion a few years ago to require mandatory community service (volunteering with a non-profit like the SOA but helping in a soup kitchen would work) to complete Fellowship. Even though it's something that I would personally do, making it mandatory takes away much of the satisfaction. And, in fact, all of these organizations want volunteers who are there because they want to do it and not because it's required. Somewhat off topic but the tie-in is my frustration at attending Enrolled Actuaries' meetings and seeing attendees in the back of the room reading the newspaper, doing crossword puzzles, doing work, etc. They're "taking up space" just to satisfy their 36 hours of required CE for the 3-year cycle (and oftentimes crammed into the last year of that cycle).

Anyway, I'm off my soap box now. The short answer to the original question is, yes, I support mandatory CPD. All I have to do is to now focus on the majority of meeting attendees who are paying attention instead of the very small number who take up space.

[apanighetti]

My very first post! On any internet forum! Ever!

My name is Art Panighetti, and I'm running for the Board.

I have long wondered why our profession did NOT have mandatory continuing ed requirements. Most (nearly all?) highly regarded professions require continuing professional development. The accountants I work with have it, my doctor has it, my wife who is an audiologist has it, and my two kids in middle and high school have lots of it!

Most of us joined this profession because we love to challenge ourselves and continually learn. I suspect that most of us routinely obtain more than the minimum amounts of continuing education and professional development in the course of carrying out our daily job requirements.

That said, I do support mandatory CPD requirements. Why? To ensure that everyone in our profession has a minimum level of currency in their field, and that we as actuaries can demonstrate it to the rest of the world.

However, demonstrating compliance with the requirements needs to be reasonable and minimally burdensome. The Board needs to be open to feedback on the new system, and be open to making modifications down the road if necessary.

Great question, thanks for asking!

Art

[Tom Terry]

I strongly support this. As a profession engaged in real world matters, we need to keep up to speed. And it's a good thing to broadcast to the world that we're committed to this.

At the same time, I share Dale's concern. 30 hours is a pretty hollow requirement if the time is not well spent.

That said, let's get this requirement in place, then we can turn our attention to the QUALITY of those hours!

[Cecil Bykerk]

While the idea of saying things are mandatory may not have the best sound to our ears, it is critical that our members participate in CPD. We shouldn't call ourselves professionals if we are not willing to do CPD. If all I knew today about actuarial science was what I knew upon completing my FSA, I wouldn't deserve to call myself an actuary and I most certainly shouldn't be practicing as one. We all do CPD of one type or another. It isn't that difficult to demonstrate that we are. Without saying that we have mandatory CPD, others will look at the actuarial profession and wonder. However, I do believe that we need be sensitive to those actuaries who are FSAs but have moved on in their careers to positions that are, might I say, above the position of practicing actuarial science on a day to day basis. No one can tell me that I can't put BA and MS after my name. I graduated from two universities to get those two credentials. I don't want to take away the ability of an FSA to use those initials, but we need to somehow distinguish those who are practicing as actuaries and moved on. Perhaps we can call them 'FSA emeritus'.

[JMO]

An actuary who issues a Statement of Actuarial Opinion when providing Actuarial Services must satisfy the General Qualification Standard. When issuing certain types of Statements of Actuarial Opinion, an actuary must also satisfy Specific Qualification Standards (see Section 3). An actuary must have met the following requirements for basic education and experience and continuing education before issuing a Statement of Actuarial Opinion

Note that this clearly applies to actuaries when we issue a Statement of Actuarial Opinion. It still seems to me that if an actuary is not issuing such a statement, that the standards simply do not apply.

If I am correct, why is a special label required?

[Katie.]

Note that this clearly applies to actuaries when we issue a Statement of Actuarial Opinion. It still seems to me that if an actuary is not issuing such a statement, that the standards simply do not apply.

If I am correct, why is a special label required?

What she said. However, I think the answer is that those rules don't apply to actuaries outside the US. Also, many FSAs may be issuing (lower-case) statements of actuarial opinion and not be in compliance or even be Members of the Academy. I know a prior employer of mine balked at those dues. It is a bit frustrating that the SOA is creating separate and potentially different rules that we will also have to keep track of.

[bdschobel]

The SOA Board has already established an "alternate route" for members who meet an applicable qualification standard in Canada or the U.S. There will be absolutely no overlapping or redundant record-keeping.

Bruce

[Arlie_Proctor]

I am a member of the CAS, not the SOA, so please feel free to discount my opinions below. That said, I support increasing the CPD requirements as recommended by the AAA and endorsed by all of the North American Actuarial organizations. The move is long overdue.

Quite frankly, actuarial CPD requirements for hours and documentation are milk toast compared to most professional credentialing bodies in North America. That is not to say that actuaries are lax in their continuing education; most actuaries I know spend ample hours monthly researching new techniques for projects on which they are engaged or for volunteer committees on which they serve. However, we don't do a good job of advertising and documenting those personal efforts. We accredit individuals who demonstrate an incredible ability to learn new material. For most of us, our entire career consists of continued demonstration of that ability. The new requirements are simply asking our membership to demonstrate to the rest of the world that (collectively) we do not let our skills go stale. The new requirements are not a hammer applied to individuals, they represent an opportunity to blow our horn about the type of professionals we are.

[JMO]

I am a member of the CAS, not the SOA, so please feel free to discount my opinions below. That said, I support increasing the CPD requirements as recommended by the AAA and endorsed by all of the North American Actuarial organizations. The move is long overdue.

Quite frankly, actuarial CPD requirements for hours and documentation are milk toast compared to most professional credentialing bodies in North America. That is not to say that actuaries are lax in their continuing education; most actuaries I know spend ample hours monthly researching new techniques for projects on which they are engaged or for volunteer committees on which they serve. However, we don't do a good job of advertising and documenting those personal efforts. We accredit individuals who demonstrate an incredible ability to learn new material. For most of us, our entire career consists of continued demonstration of that ability. The new requirements are simply asking our membership to demonstrate to the rest of the world that (collectively) we do not let our skills go stale. The new requirements are not a hammer applied to individuals, they represent an opportunity to blow our horn about the type of professionals we are.

:iatp:

[rcr]

I am a member of the CAS, not the SOA, so please feel free to discount my opinions below. That said, I support increasing the CPD requirements as recommended by the AAA and endorsed by all of the North American Actuarial organizations. The move is long overdue.

Quite frankly, actuarial CPD requirements for hours and documentation are milk toast compared to most professional credentialing bodies in North America. That is not to say that actuaries are lax in their continuing education; most actuaries I know spend ample hours monthly researching new techniques for projects on which they are engaged or for volunteer committees on which they serve. However, we don't do a good job of advertising and documenting those personal efforts. We accredit individuals who demonstrate an incredible ability to learn new material. For most of us, our entire career consists of continued demonstration of that ability. The new requirements are simply asking our membership to demonstrate to the rest of the world that (collectively) we do not let our skills go stale. The new requirements are not a hammer applied to individuals, they represent an opportunity to blow our horn about the type of professionals we are.

This doesn't seem to show a lot of awareness of the relevant counterpoints that were often raised in the long debate on the SOA CPD proposal in the General Actuarial forum. Specifically, that discussed, at length, the differences between improving disclosure / advertisement of CPD (a goal for which I have found opponents only in others' imaginations) and unexpectedly mandating CPD (which has real-world opponents). Also, there seems to be an implicit reliance on a premise that other professions' actions are worth imitating; this was also a recurring theme in that thread.

I do not wish to waste our time retreading the details of those discussions here. On the contrary, I am suggesting that people who haven't already read that prior thread will find that many of these points have been already discussed, and that they can save time by first referring to those.

[Arlie_Proctor]

No, I have indeed read the discourse on mandatory CPD. I simply do not believe that most of the harsh opponents have really thought through the cost/benefit equation. For the vast majority of practicing actuaries, this is a record-keeping exercise and nothing more.

[bdschobel]

And focusing narrowly on the SOA's proposed CPD requirement, it's not even a record-keeping requirement for most of us, because of the "alternate route" that I have described many times. If you meet the applicable Canadian or U.S. quailification standard, then you're done as far as the SOA is concerned.

Bruce

[rcr]

No, I have indeed read the discourse on mandatory CPD. I simply do not believe that most of the harsh opponents have really thought through the cost/benefit equation. For the vast majority of practicing actuaries, this is a record-keeping exercise and nothing more.

Do you have any evidence for claiming that most of the "harsh" opponents of CPD haven't really thought it through, or are readers supposed to agree with your claim by means of faith or coincidence? Or are we supposed to be persuaded by your repetition of previously made (and previously addressed) arguments?

If mandating CPD is just a record-keeping requirement, then why wouldn't a record-keeping requirement and disclosure options (not a CPD mandate) serve pretty much as well if not better? Alternative CPD record-keeping / disclosure proposals were indeed made by multiple CPD opponents in that forum and got very little response from CPD proponents there. Would you like to comment on those?

For one who claims to have read the past forum discussion, you are displaying no evidence of familiarity with it. Whether you intend it or not, you are retreading old arguments, and, in my opinion, that is not the best use of readers' time.

[JMO]

:iatp:

[Lane Meyers]

Am I the only EA that keeps laughing at all the whining people are doing concerning CPD requirements?

[rcr]

Am I the only EA that keeps laughing at all the whining people are doing concerning CPD requirements?

Do you care to address the arguments, or do you consider laughing at people a good policy argument?

You would hardly be the first person to laugh at people for the simple reason that they have not chosen the same career and credential commitments as you. You're entitled to laugh at people who don't seem to have the various positive qualities you perceive in yourself, much as a drill instructor might be entitled to laugh at people who don't do 50 push-ups every day, or a police officer in a high-crime area might laugh at the idea of people getting nervous over desk work. But that wouldn't mean that FSAs should be required to carry pistols and batons into high-crime areas, right? So how is your laughter relevant to us deciding good policy?

How FSAs can avoid being the target of laughter of other people who chose other desginations, like yourself, is not what the CPD discussion was about. What matters is how the proposed policy would affect thousands of combined hours of FSAs' time, each year.

For some of us, one problem is that SOA leaders would approve policy changes on dubious rationales, the sort that can easily be used to quickly justify a whole range of bad policy initiatives in the future. It's better to contain the popularity of those dubious policy rationales here and now, before they could go on to cause serious harm to the actuarial profession. To some people like yourself, any lengthy discussion around this is just going to be seen as "whining."

[Lane Meyers]

I wasn't trying to belittle FSA's (a level I have not yet achieved) or any other actuary, regardless of practice area, and I certainly wasn't holding myself up as superior because I'm an EA and others aren't. If anything, numerous people on this forum have in the past tended to look down their noses at those in the pension field because they (incorrectly) think that the field of pensions is dead or dying. All I was trying to say was, that EA's have had continuing education requirements for years, which I believe is a good thing. Pension law has changed dramatically throughout the years. PPA '06 has totally re-written the pension laws as we once knew them. If I were a plan sponsor, I would want my actuary to stay current on the latest changes.

I don't know how the laws have changed for life/health/p&c/whatever actuaries throughout the years, because I don't practice in those areas. However, I would think changes are inevitable, and continuing education requirements can help actuaries stay aware of the latest developments in their fields.

Not all of the posts on this forum concerning CPD have discussed whether the SOA has the right to make changes or the manner in which they made the changes. I'm not addressing those issues, nor did I in my original post. My post was just poking a little stick at those that have complained about having to have any CPD requirements at all. As has been pointed out by Bruce and others, most professions with credentialed designations have continuing education requirements. I just don't see why so many actuaries think we as a profession should be above that.

In summary, lighten up Francis.

[AJ]

I have been following this thread and other discussions (on this forum) and elsewhere on CPD for some time now. I am bit distracted from regular work this Friday afternoon so I thought I would add by 2 cents worth.

In my mind, for the purposes of this discussion, I split actuaries into 3 groups:

A - actively practicing as an actuary (broadly defined) and participating in CPD activies at a level in excess of the proposed/contemplated mandatory requirements of AAA, CIA and SOA

As an aside, I am not sure where the CAS stands. I practice on the life side so you can view my comments with that background and this is the category that I would assign to myself.

B - actively practicing as an actuary but with little or no current CPD participating such that extra effort will be required to meet CPD requirements if they are adopted on a mandatory basis

C - not actively practicing as an actuary (very narrowly defined).

I believe that shoddy actuarial work is produced from time to time but that this is relatively rare. I would hope and have the impression that the relative proportion of shoddy work in group B is higher than in group A but that it is still quite rare on an absolute basis. This impression is based on my belief that the actuaries in group A, who take part in non-mandatory CPD, derive some benefit from this and that the reduction in the amount of shoddy work is one of the benefits.

When shoddy work is uncovered, I believe that our profession is best served, if our publics (broadly defined to include our employers and clients) come to conclude that the shoddy work uncovered was isolated and had confidence that the profession was capable of effectively dealing with instances of shoddy work.

I don’t believe that the amount of shoddy work will be much reduced if and when mandatory CPD is adopted, but there may be a small reduction as actuaries in group B benefit from the CPD that they would not have otherwise undertaken.

I believe that the adoption of mandatory CPD will increase the likelihood that our publics treat instances of shoddy work that are uncovered as aberrations and as isolated incidents. I believe that this will benefit the profession.

Undoubtedly, there are costs. The costs will fall disproportionately on group B (increased CPD costs) and group C (costs of complying with exemption process; disclosure of inactive status in some form). I believe that these costs can and should be mitigated to the extent possible.

On balance, based on the above, I support mandatory CPD requirements as currently contemplated by the CIA, AAA and SOA.

I would also encourage those of you who have advocated more detailed disclosure of the nature of CDP as an alternative to the hours based mandatory approach currently on offer to do so on a voluntary basis. I would love to see this and other efforts to increase transparency and raise the bar on CPD come into practice on a voluntary basis. If this is favourably received by our publics then elements of these enhanced voluntary disclosure practices should be given the fullest consideration for future adoption on a mandatory basis by the CIA, AAA and SOA.
.

[JMO]

:iatp:
Very nicely done.

[campbell]

Speaking of shoddy actuarial work, I read the following column this morning:
http://www.contingencies.org/septoct07/code.pdf

I think there may be trouble with regards to qualifications to practice as principles-based approaches spread in our work. I don't know if the CPD requirement at the very least will let people know they're unqualified to do certain work. The number of hours, frankly, are few for certain changes that are coming down the pike, but I wouldn't be surprised if some people are unaware what's brewing. Some kind of minimum CPD may get people to look up from their spreadsheets to find that many things have changed.

I always wondered how one deals with incompetence, as those who are incompetent or ignorant are the ones who are least likely to recognize that.

[rcr]

I wasn't trying to belittle FSA's (a level I have not yet achieved) or any other actuary, regardless of practice area, and I certainly wasn't holding myself up as superior because I'm an EA and others aren't. If anything, numerous people on this forum have in the past tended to look down their noses at those in the pension field because they (incorrectly) think that the field of pensions is dead or dying. All I was trying to say was, that EA's have had continuing education requirements for years, which I believe is a good thing.

What you actually posted didn't say any of that. Keep in mind that what you actually said was one sentence saying that you were "laughing" at "whining," which is derogatory.

Pension law has changed dramatically throughout the years. PPA '06 has totally re-written the pension laws as we once knew them. If I were a plan sponsor, I would want my actuary to stay current on the latest changes.

Do you need a profession-wide mandate to make your own employees keep up to date with new developments? Likewise, do you need a profession-wide actuarial dress code to prevent you from showing up to work in the nude?

I already discussed that point at length in the previous SOA CPD thread how proponents of mandatory CPD sometimes make arguments in a way that completely overlooks the existence of incentives coming from sources other than centralized professional organizations.

I don't know how the laws have changed for life/health/p&c/whatever actuaries throughout the years, because I don't practice in those areas. However, I would think changes are inevitable, and continuing education requirements can help actuaries stay aware of the latest developments in their fields.

This is basically the argument that "a rapidly changing industry means profession-wide CPD mandates are valuable." I addressed that argument in the previous thread.

Not all of the posts on this forum concerning CPD have discussed whether the SOA has the right to make changes or the manner in which they made the changes. I'm not addressing those issues, nor did I in my original post. My post was just poking a little stick at those that have complained about having to have any CPD requirements at all. As has been pointed out by Bruce and others, most professions with credentialed designations have continuing education requirements. I just don't see why so many actuaries think we as a profession should be above that.

I addressed the "All the other professions are doing it" type of argument, from Bruce and others, in the previous thread.

I haven't argued that actuaries are "above" mandatory CPD, but I have pointed out, among other things, that actuaries as a profession were already doing much better than many professions, even though we lack universal CPD requirements that some other professions attempt. That is, it is not at all self-evident that imitating other people's professions will make ours better off. Forgive me for not accepting that on faith; I want evidence for that. So far as I know, it is perhaps more likely that many of these other professions would be better off to imitate what we do.

In summary, lighten up Francis.

Personally, I find a lot of things much funnier than thinking of people who disagree with me as "whining." I think there are funnier things in life than when someone who is apparently unaware of the content of your arguments chooses to ridicule you as whining for having made them.

[JMO]

I haven't argued that actuaries are "above" mandatory CPD, but I have pointed out, among other things, that actuaries as a profession were already doing much better than many professions, even though we lack universal CPD requirements that some other professions attempt. That is, it is not at all self-evident that imitating other people's professions will make ours better off. Forgive me for not accepting that on faith; I want evidence for that. So far as I know, it is perhaps more likely that many of these other professions would be better off to imitate what we do.


One key risk of mandatory CPD is that it will become, to use a term that appeared in the Morris Report, an exercise in compliance. That is, CPD will encourage following the requirements in letter, rather than in spirit. That is not, of course, what the proponents of CPD think will happen.

[bdschobel]

And that's somehow worse than no requirement at all?

Bruce

[Chuck]

And that's somehow worse than no requirement at all?

Bruce

I think it could be worse:

Actuarial Organization A has no specific CPD requirements, but has a rich array of valuable PD offerings that a large majority of members voluntarily avail themselves of. Many of these offerings can result in non-trivial certifications of a level of up-to-date expertise in specific topics through specific demonstrations of competence (testing, papers, or other creative means). These offerings are a result of ongoing market research that identifies the wide variety of types of skills, knowledge and up-to-date topics that actuarial constituencies find valuable. This org tracks the member's PD activities in a database that is promoted/advertised and available to the publics that use actuaries. Need somebody with a specific expertise? Check with this database to find out who the experts are.

Actuarial Organization B has a 24 hour per year CPD requirement (sort of). Actuaries that do not meet the requirement are required to tell you so. You do not know what the actuary did or learned in those 24 hours (or if they did 240 hours instead of 24 hours). It could have been something really valuable or they could have been sitting in the back of the room at an SOA convention reading the newspaper. These "active" actuaries are still honor bound to only do work they are qualified to do, but the public has no way of determining whether they do.

I think A > B.

Both orgs could have members who run afoul of doing shoddy or unprofessional work. But Org B has a vague implicit and inaccurate label of qualification or non-qualification, that upon investigation (eg a Morris Report), could be shown to often be a meaningless exercise of compliance. On the other hand, Org A gives the users of actuaries a valuable tool to greatly increase the likelihood that the actuary is qualified and thereby encourages their members to seek additional PD.

Chuck

[bdschobel]

You're comparing A and B. I'm asking about B versus zero. Isn't B better than zero?

Bruce

[JMO]

Are you suggesting that what we have now is closer to zero than to A?

[MNSmith]

As an offshoot to JMO's question, why is Precept #2 not good enough?
http://www.soa.org/about/membership/about-code-of-professional-conduct.aspx

[bdschobel]

Are you suggesting that what we have now is closer to zero than to A?Yes.

Bruce

[Chuck]

You're comparing A and B. I'm asking about B versus zero. Isn't B better than zero?

Bruce

I guess Carol's question is the crux where reasonable people can disagree.

I agree that A > B > zero and that zero is bad.

But I do not agree that:

No hourly requirements = zero

...and I think B is close to zero.

That's because it has been said that the requirements will affect a very small portion of the membership and it is at best uncertain what portion of the membership affected will meaningfully increase their PD.

I think the argument is that B looks better because it is like other professions (as SNL Fernando Lamas used to say, "It is better to look good than to be good")

I thought that a response might be that A+B > A > B > zero.

That would be a more palatable argument for me. With enough A, maybe B becomes almost moot either way.

Chuck

[Gomer Fan]

...
Actuarial Organization A has no specific CPD requirements, but has (an) array of valuable PD offerings ...
Actuarial Organization B has a ... CPD requirement ... (no reference to educational offerings)

I think A > B.


A and B are talking about different perspectives on the SoA's role, but "B" is a non-starter since it ignores the SoA's role as an educational body. A vs. B vs. zero seems a very tangential discussion that does not take account of the actuarial practice role of other actuarial organizations.

The abbreviated version of "A" as described in the quote above (i.e. excluding the certification type enhancements that Chuck outlined), refers to the SoA's role as an educational body. Adding optional certification programs seems consistent with the SoA's role.

Actuarial practice requirements, as a component of "A'+B+C", are already provided by other actuarial organizations (AAA, CIA) where "C" refers to the accompanying development of the non-CPD actuarial standards of practice that would be added to A'.

Just because the SoA focuses on "A" and other organizations address "A'+B+C" does not mean that the other organizations are "better" than the SoA. e.g. "A" and "A' " have different content (e.g. SoA actuarial entrance exams are in A and not A').

[Take 2]

I'm still opposed to CPD for SOA. If it gets SOA closer to merging with AAA, that's laudable. But that's the tail wagging the dog.

[JMO]

I still don't see how SOA can merge with AAA. What then happens to Canadians?

[Take 2]

Canadians can join if they wish. There are a few CIA members who are MAAA but not in SOA or CAS. CRUSAP was right -- I see many more advantages than disadvantages to an AAA/SOA merger. JMO ;)

[JMO]

My point is that after CRUSAP, supposedly actuaries practicing in the US would belong to the single, combined SOA/AAA/CAS/Pension_alphabet.
Canadians would still have to belong to that organization PLUS the CIA. That just doesn't sound right to me. Or does CRUSAP actually envision combining CIA into the new all-things-to-all-NA-people-AAA?

[bdschobel]

I still don't see how SOA can merge with AAA. What then happens to Canadians?This is just one of many problems. Actual legal mergers are a practical impossibility. Not even worth trying.

Bruce