During the March professionalism webinar, “A Guided Tour of the U.S. Qualification Standards,” one of the panelists explained the difference between the continuing education (CE) requirements of the Qualification Standards for Actuaries Issuing Statements of Actuarial Opinion in the United States (USQS) and the continuing professional development (CPD) requirements of other actuarial organizations. It is important for actuaries to understand the difference between the two.
CE is a basic component of the qualifications an actuary must have in order to issue a statement of actuarial opinion (SAO) in the United States under the USQS. The USQS applies to every member of any of the five U.S. actuarial organizations that has adopted the Code of Professional Conduct. This is because under Precept 2, Annotation 2-1, of the Code, an actuary must “observe applicable qualification standards that have been promulgated by a Recognized Actuarial Organization for the jurisdictions in which the Actuary renders Actuarial Services.”
When an actuary issues an SAO in the United States, the actuary must have already completed and documented 30 hours of “relevant” CE (as “relevant” is defined in the USQS). CPD requirements are completely different, and meeting them is not part of the qualification requirements to issue an SAO. The CPD requirements of other actuarial organizations are not established in or mandated by the USQS. CPD requirements apply as determined by the actuarial organization that establishes them. They may apply to actuaries outside the United States and may apply whether or not the member issues an SAO in the United States. In addition, CPD requirements may be structured quite differently than the CE requirements in the USQS (for example, mandated over two years instead of one). Importantly, meeting CPD requirements does not indicate that an actuary is qualified to issue an SAO.
Another source of confusion in this area has arisen from the notations some other actuarial organizations make publicly available in member directories showing whether their members are in “compliance” with that organization’s CPD membership requirements. It is important to know that this “compliance status” indicates only whether the actuary has met that organization’s CPD requirements, not whether the actuary is qualified to issue an SAO under the USQS requirements.
If this sounds confusing, here’s a good rule of thumb: Several actuarial organizations with CPD requirements state that their CPD requirements can be met by fulfilling the CE requirements of the USQS. But the reverse is not true: An actuary will not, by virtue of having completed CPD requirements of an actuarial organization, automatically be deemed qualified to issue an SAO in the United States under the USQS. A separate analysis has to be done to make sure that the actuary has completed 30 hours of relevant CE under the USQS.
So what does the USQS require by way of documenting CE? USQS Section 6 requires an actuary “to keep appropriate timely records as evidence that their continuing education requirements have been met” and further states that “whenever an actuary issues a Statement of Actuarial Opinion, an actuary should be prepared to provide evidence of compliance with the Qualification Standards, including certificates of attendance (if any), meeting outlines or handouts, and notes related to ‘other activities,’ when requested by the appropriate counseling and disciplinary body of the profession.”
The Academy has created useful tools to help actuaries document their compliance with the USQS. Being compliant with the CE requirements of the USQS is one of the three elements necessary to be qualified to issue SAOs. The Academy’s voluntary attestation form provides a comprehensive way for an actuary to document how their basic education, experience, and CE meet the requirements of the General and/or Specific Qualification Standards of the USQS. TRACE is another online tool that the Academy provides to help its members track the CE component.
The Academy also provides several tools that are geared to help members find answers to their questions on CE required under the USQS. For example, the FAQs on the U.S. Qualification Standards include 26 questions and carefully considered answers about a wide range of topics related to CE, and “Which CE Requirements Apply to Me?“ is an infographic that can serve as a quick primer on CE requirements under the USQS.
So, if you are confused about the difference between CE and CPD, just remember—the requirements of the USQS are what you need to meet to be qualified to issue SAOs in the United States. If, after perusing the USQS and the above-mentioned resources, you still have CE questions, you may submit a question to the Committee on Qualifications through the Academy’s website.
(Featured in the April 2018 Actuarial Update.)