SOA CPD Exposure Draft

[JMO]

Originally Posted by Michael Hawkins

JMO, I believe you received an incorrect answer to your question.

Only SOA members who must comply with AAA requirements are given the option of electing to comply with AAA requirements as an alternative to SOA requirements (same for CIA). See D. 3. in the draft.

Your question was: SOA member residing in US and not making any Statements of Actuarial Opinion, can you be a plain old FSA by complying with AAA requirements? Answer is NO, you must comply with SOA requirements or be "inactive".

What about FAQ AC3? This seems to conflict with your answer. . .

I’m subject to the US 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: Sally Member, FSA, who works in the United States, does not issue Statements of Actuarial Opinion (as defined in the U.S. Qualification Standard). Sally does not need to comply with the continuing education
requirements in the U.S. Qualification Standard. However, to fulfill the SOA CPD requirement using alternative compliance, she would have to fulfill the continuing education requirement of the U.S. Qualification Standard in its entirety (30 units of CPD per year, six units in organized activities and three
units of professionalism).