27 April 2020
We understand that, due to the coronavirus crisis, there may be times over the coming months where a certificate holder is unable to fulfil their duties. Therefore, the organisation may need to put emergency contingency plans in place for such an event.
The simplest solution would be, wherever possible, for the organisation to make use of another Practising Certificate (PC) holder within the same organisation or firm as the current PC holder.
We recognise however that this may not always be possible, and we would like to reassure our Members, particularly our PC holders, of the measures we have put in place to assist, should you find yourself in this type of situation:
- The Executive and Practising Certificates Committee (PCC) will fast track (where they are able) any applications that require a certificate to cover this type of situation. This will, of course, also rely on the applicant ensuring that they provide full and complete information at the time of application, as well as be on hand to answer any queries as quickly as possible.
- Where an applicant in these circumstances does not fully meet the technical experience criteria (i.e. meets some, but not all of the criteria), but can show, on balance, that they are, by way of their general experience, fit and proper to carry out the role, the PCC will have the ability to issue a restricted PC (e.g. restricted to the insurer(s) or pension fund(s) in question) that allows that member to act in a ‘substitute’ capacity for the period that the certificate holder is unable to carry out the role. In this situation, we would initially issue a certificate to cover a four month period, however this can be reviewed, with the possibility of extending, if required. Any certificates that are issued to cover a short term period will be charged on a pro rata basis. The full CPD requirement of 30 hours for a category 1 member will also be waived, due to the circumstances around which the certificate is required. This may need to be revisited, should a certificate be extended beyond a four month period.
The above will only cover applicants who need to apply for a certificate for contingency measures should the current role holder be unable to fulfil their duties due to coronavirus issues and should no alternative existing PC holder be available to act.
For the avoidance of doubt, it is noted that any actuary acting as a substitute under the above arrangements would be fully responsible for the advice they give, and that the current/incapacitated PC holder would not retain any such responsibility.
Should this apply to you, we would encourage you to get in touch to discuss this further.
Scheme Actuaries are also reminded of the specific requirement within APS P1 that they “must have appropriate arrangements to cover any period during which he/she is unable to fulfil his/her duties as a Scheme Actuary. The arrangements must take account of the length of the absence. Depending on the circumstances, it might be appropriate or necessary to resign the appointment.”
If you require any assistance with this, please get in touch.
We will keep these measures under review and implement further changes, as needed, depending on wider developments.