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Scheme Review Working Party

The Disciplinary Board undertook to commence a review of the Disciplinary and Capacity for Membership Schemes (‘the Scheme’). The Scheme Review Working Party was established to recommend changes to the Disciplinary Board.


The composition of the Scheme Review Working Party is as follows: -

  • Ian Farr, FFA (Chair) (Former Convener of the Disciplinary Tribunal Panels of the IFoA)
  • Theresa Thorpe (lay member, Head of Regulatory Policy and Tribunals, RICS)
  • Alison Marron (lay member, Risk Compliance Manager, Morton Fraser)
  • Stephen Redmond (lay member, Chair of Disciplinary Board)
  • Kevin Doerr, FIA (actuary member, Disciplinary Board)
  • Simon O’Regan, FIA (actuary member, Disciplinary Board)

View the terms of the reference for the Scheme Review Working Party.


The Scheme Review Working Party agreed five core principles which the IFoA’s disciplinary process should reflect.  The principles are:-

  1. Public interest and independence of disciplinary enforcement - The public interest obligations of the Royal Charter of the IFoA, and the independence of the disciplinary enforcement arrangements for the IFoA are central to its identity and shall continue be upheld in every aspect of disciplinary process and procedure. 
  2. Consistency with the principles of better regulation - Generally the Scheme should follow the principles of better regulation which underpin the IFoA’s Refreshed Regulatory Policy.  They are:  transparent; accountable; proportionate; consistent and targeted.
  3. Clarity of communication - The Scheme should be drafted in clearer terms which is understandable for our members and all users, bearing in mind the IFoA's international membership. 
  4. Scope for flexibility in the governance of process and procedures - The Scheme provides, at Rule 2.41 (h) that the Disciplinary Board can make regulations as it considers necessary for the implementation of the Scheme.  It is recommended that the more detailed procedures about how mechanisms such as the Capacity for Membership process, Disciplinary Tribunal Panels etc. are contained within regulations, rather than the Scheme itself.  This affords the Disciplinary Board the flexibility to change procedures, as may be required.
  5. Simplicity, and allowing for streamlined processes where appropriate - Under the current Scheme a disproportionate amount of time can be spent on cases where the process could be more efficient.  Where appropriate, measures should be introduced to speed up cases, or remove them from investigation under the Scheme altogether.


The following progress has been made by the Scheme Review Working Party:

  • A comparative exercise with other regulators was completed in early 2019.   User and key stakeholder feedback (including from the 400 club) was analysed and it supported retention of the “misconduct” regime.
  • The Working Party recommended, which was endorsed by the Disciplinary Board, that the current misconduct regime remained the best fit for the IFoA and its global membership.   
  • Following on from the Working Party’s review of all the processes within the current Scheme, 22 high level recommendations were made to the Disciplinary Board which were agreed.
  • The Working Party has been developing detailed proposals on these high level recommendations, which are being considered by the Disciplinary Board.

If you have any thoughts on the Scheme Review or how to shape the disciplinary regime for the IFoA, please contact the Project Manager,

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Events calendar

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