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  #11  
Old 07-15-2007, 09:42 PM
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Originally Posted by bdschobel View Post
Absolutely not. But actuaries who do not maintain their knowledge, as indicated by not meeting the new CPD requirements, will be designated "inactive" (or some such word not yet determined). Note that this is essentially a self-designation, because the SOA does not intend to actively police this.

Bruce
If "SOA does not intend to actively police this", how will they be able to determine who fails to meet CPD requirements and will be designated "inactive"? I'm baffled.
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  #12  
Old 07-15-2007, 09:50 PM
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At the risk of seeming defensive, I need to tell you guys the context in which the SOA is doing this.

You probably know that the CIA in Canada imposed a stringent hour-based qualification and membership standard a year or two ago. CIA representatives described this requirement and the reasons for it at the North American Actuarial Council meeting in September 2006. All of the U.S.-based attendees later signed a letter pledging to impose reasonably consistent mandatory CPD requirements on actuaries across the U.S. The actual letter that we signed was reproduced on page 6 of the March 2007 issue of the Actuarial Update:

http://www.actuary.org/update/pdf/0307.pdf

Note that the CAS representatives signed the letter, too, so the usual mindless chanting about how the SOA is stupid and the CAS is smart apparently doesn't apply to this subject. CPD requirements are not new in the U.S., anyway. The JBEA imposed them ages ago. The AAA's Committee on Qualifications followed in 2001, as I recall. The CCA imposed mandatory CPD as a membership requirement in 2005. Now it's coming to the SOA.

Frankly, I can't believe that anybody -- actuary or non-actuary -- would oppose this, but the world is full of surprises, I guess.

Bruce

Last edited by bdschobel; 07-15-2007 at 09:56 PM..
  #13  
Old 07-15-2007, 09:51 PM
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If "SOA does not intend to actively police this", how will they be able to determine who fails to meet CPD requirements and will be designated "inactive"? I'm baffled.
People will certify on their dues statement that they met the requirements. Lying is a violation of the Code of Professional Conduct. While we won't actively police, violations may come to light in other ways (like litigation).

Bruce
  #14  
Old 07-15-2007, 11:08 PM
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Replying to Bruce Schobel's initial 4:06PM comment that suggested there were "egregious errors":

1. Bylaw provisions**. I'm not sure I would call this an error, but I agree that I was not aware that the wording being introduced into the bylaws was already contained in the SOA constitution. In any case, it is not clear that the purpose and intent of that wording was to allow for a unilateral expansion of the SOA role to impose the sort of CPD requirement that is proposed. (Bruce, regarding your 8:56PM comment about the CIA's advocacy of the CIA approach, your note does not mention that the CIA's proposed bylaw changes to authorize the proposed role of the CPD requirements was defeated by the CIA membership on June 28 2007.)

2. Hours-based. Not an error item. The arbitrary nature of a single hours-based requirement is more problematical when there are diverse and non-unique job functions (even to the extent that the law does not recognize "actuary" as a profession) and where application of the requirement is inappropriately broad (e.g. the AAA does not apply just a requirement to all AAA members).

3. Scope and cost*. Not an error item. Simply noting there is a conflict of interest and the need to identify and address the proposed scope of the CPD requirements and their arbitrary nature in the context of that scope.


* For expanded response > link to July 18 7:27AM posting:
http://www.actuarialoutpost.com/actu...35#post2204635

** Reference: item #3 in original posting at start of this thread: link#1 .

.

Last edited by Dan Anderson; 08-04-2007 at 06:41 AM.. Reason: adding ** reference; July 18 8:58AM - adding * comment at bottom; July 17 10:18PM - clarifying words were in consititution and not prior bylaw
  #15  
Old 07-16-2007, 12:07 AM
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Dan raised a number of points in his opening post, and Bruce has responded to several of them, which I hope has provided some insight. Let me add my comments on some of the other issues Dan has raised.

I am a Board member and a member of the KMSAT. In particular, I’m the KMSAT member Dan quoted in his item 5 e).

The whole point of the CPD proposal is to maintain the value of the SOA’s credentials. If someone says he is a practicing FSA or ASA, the public should be able to assume that it means the person is qualified. This is the issue the Board is trying to address.

Dan’s item 4 referred to the development of the CPD requirements as coming from the 8-member KMSAT. It is true that the KMSAT has done the legwork on this proposal, but only based on direction from the Board. The Board has had in-depth discussion of CPD over at least four Board meetings, and the KMSAT has prepared papers in response to requests from the Board for specific background information. The CPD proposal is being made by the Board after very thoughtful and considered discussion. It is not something that was dreamed up by the KMSAT.

Dan’s items 5 a) and c) refer to the arbitrary nature of an “hours” requirement, as opposed to a knowledge-based requirement. As Bruce noted, “hours” is the standard method for measuring whether appropriate CPD has been completed, both within our profession and among many other similar professions. From a practical standpoint, it gives an actuary a benchmark for the minimum amount she should be doing and makes it feasible to measure whether the requirement has been completed. The Board did consider whether there should be required knowledge-based topics, but felt that the knowledge requirements vary based on an actuary’s specific position and level of expertise. We do intend, with the help of the sections, to provide suggested topics of study for actuaries in various areas of practice.

Dan’s item 5 e) quotes one sentence from me, "The increase in demand for CPD that will flow from this requirement may well enable us to provide continuing education programs on a more cost-effective basis". That sentence was part of a statement in which I noted that the SOA is very cognizant of the expense issue some actuaries will face in meeting CPD requirements, and that one of our goals will be to make more economical structured education options available, such as web casts. As Bruce has already stated, the motivation behind CPD has nothing to do with trying to obtain more revenue from CE.

We are not intending to insult anyone with the term “inactive”, or whatever it ends up being. If an actuary is still practicing as an actuary, he should be maintaining his educational qualifications. If he is not, that should mean that he is not in practice as an actuary and therefore, should not mind being considered “inactive”. As I understand it, CPAs use a similar approach.

It may well be possible for retired actuaries to use a different term, such as “retired” or “emeritus”, if that is more acceptable. None of these details have been decided yet.
  #16  
Old 07-16-2007, 06:44 AM
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Quote:
Originally Posted by Dan Anderson View Post
Replying to Bruce Schobel's initial 4:06PM comment that suggested there were "egregious errors":

1. Bylaw provisions. I'm not sure I would call this an error, but I agree that I was not aware that the wording being introduced into the bylaws was already contained in the SOA constitution. In any case, it is not clear that the purpose and intent of that wording was to allow for a unilateral expansion of the SOA role to impose the sort of CPD requirement that is proposed. (Bruce, regarding your 8:56PM comment about the CIA's advocacy of the CIA approach, your note does not mention that the CIA's proposed bylaw changes to authorize the proposed role of the CPD requirements was defeated by the CIA membership on June 28 2007.)

2. Hours-based. Not an error item. The arbitrary nature of a single hours-based requirement is more problematical when there are diverse and non-unique job functions (even to the extent that the law does not recognize "actuary" as a profession) and where application of the requirement is inappropriately broad (e.g. the AAA does not apply just a requirement to all AAA members).

3. Scope and cost. Not an error item. Simply noting there is a conflict of interest and the need to identify and address the proposed scope of the CPD requirements and their arbitrary nature in the context of that scope.
1. I didn't know about that June 28 vote (and still don't, really -- I'll take your word for it). But that doesn't persuade me that the SOA is making a mistake. Anyway, even if the SOA did nothing in this area, the new qualification standard passed by the AAA Board on May 23 will apply to most actuaries in the U.S., and those requirements are functionally equivalent. Are you complaining to the AAA, too?

2. Tell the lawyers and accountants that their hour-based CPD requirements are ineffective. And the standard passed by the AAA applies to all actuaries in the U.S. who issue "statements of actuarial opinion," defined to include all work expected to be relied upon by others. That's just about all of us, wouldn't you think?

3. This goes beyond mere error. Your original statement -- from which you have partially backed off -- was an accusation -- and one that offends me personally. And, truth be told, makes me very angry. The notion that the SOA would impose mandatory CPD in order to force people to attend its CE offerings is simply outrageous, and you should hang your head in shame (or never show your face again -- your choice). Would you stand up at an SOA Board meeting and accuse us of this motivation face-to-face? I'll give you the opportunity.

Bruce
  #17  
Old 07-16-2007, 08:54 AM
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Kathy and Bruce have done a good job in carrying on the discussion of the CPD issue, but let me add a few thoughts:

The SOA leadership debated CPD for many years before the current proposal. In fact, a CPD requirement is not new, because it was always a part of the Code of Conduct. Thus, the change that the BOG made was not to require CPD, but to make the program formal.

Why now? In recent years, particularly with the Morris Review in the UK and the CRUSAP in the US, it has increasingly been recognized that a formal CPD requirement was a critical part of increasing the confidence of the users of actuarial services of the credibility of the ASA and FSA credentials.

The KMSAT and the BOG spend a great deal of time and effort into identifying the requirements for the program. While it is true that simply requiring hours does not translate to education, it is a reasonable proxy and a necessary part of a formal CPD program.

Research done on FutureRisk as a part of the CPD research indicated that most actuaries were in favor of a CPD requirement and already participated in some types of CPD. However, as this thread indicates, there are a some of members who oppose a formal CPD requirement.

As to the self-interest of the SOA in promoting CPD, only about 25% of SOA members participate in SOA CPD, but more than 90% of the members who responded to the FutureRisk survey reported participating in some CPD. If it were just about more revenue for the SOA, it never would have been adopted.
  #18  
Old 07-16-2007, 09:15 AM
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Quote:
Originally Posted by bdschobel View Post
At the risk of seeming defensive, I need to tell you guys the context in which the SOA is doing this.

You probably know that the CIA in Canada imposed a stringent hour-based qualification and membership standard a year or two ago. CIA representatives described this requirement and the reasons for it at the North American Actuarial Council meeting in September 2006. All of the U.S.-based attendees later signed a letter pledging to impose reasonably consistent mandatory CPD requirements on actuaries across the U.S. The actual letter that we signed was reproduced on page 6 of the March 2007 issue of the Actuarial Update:

http://www.actuary.org/update/pdf/0307.pdf

Note that the CAS representatives signed the letter, too, so the usual mindless chanting about how the SOA is stupid and the CAS is smart apparently doesn't apply to this subject. CPD requirements are not new in the U.S., anyway. The JBEA imposed them ages ago. The AAA's Committee on Qualifications followed in 2001, as I recall. The CCA imposed mandatory CPD as a membership requirement in 2005. Now it's coming to the SOA.

Frankly, I can't believe that anybody -- actuary or non-actuary -- would oppose this, but the world is full of surprises, I guess.

Bruce
"I don't mean to insult anyone", but then half the post is filled with attacks about the 'mindless CAS defenders' and 'if the shoe fits comment'.


This is a professional part of the forum, Bruce. If you can't keep your tone respectful, please go to the reef or something.
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  #19  
Old 07-16-2007, 09:30 AM
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Half the post? I see an actuary desperately in need of CPD!

Bruce
  #20  
Old 07-16-2007, 09:35 AM
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Default Hours-based approach applied arbitrarily.

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Originally Posted by Dan Anderson View Post
2. Hours-based. ... The arbitrary nature of a single hours-based requirement is more problematical when there are diverse and non-unique job functions (even to the extent that the law does not recognize "actuary" as a profession) and where application of the requirement is inappropriately broad (e.g. the AAA does not apply just a requirement to all AAA members).
Quote:
Originally Posted by KathyWong View Post
Dan’s items 5 a) and c) refer to the arbitrary nature of an “hours” requirement, as opposed to a knowledge-based requirement.
Kathy, this is not a binary issue of hours-based vs. knowledge-based. The primary concern with the arbitrary nature of an hours-based approach is whether its application and the scope of its application are reasonably appropriate, or arbitrary. Thus far the SOA's intention appears to be to apply the requirement arbitrarily regardless of the nature of the individuals' work.
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