FAQ - One-off Exemption (Grandfathering)

One-off Exemption (Grandfathering)

1.      What is this one-off exemption?

The ECF provides for a one-off exemption to those Relevant Practitioners who have at least 10 years of relevant work experience.  Please refer to “Guidelines for Grandfathering” for full details.   The 10 years of work experience must be met on or before December 31, 2014.


Relevant Practitioners who have been granted this one-off exemption will be exempted from the Module 1 (Technical, Industry and Product Knowledge) requirements, but still need to fulfil the Module 2 (Ethics and Compliance) requirements.


2.      What relevant experience would be counted in the 10 years?

Those Relevant Practitioners who have at least 10 years of relevant customer-facing work experience described below, may be eligible for grandfathering. 


Recent PWM customer-facing functions

(i.e. x = at least 5 years)

 

 

 

 

 

AND

 

Other customer-facing functions in the financial services industry

(i.e. y = (10 years minus x), and multiplied by 2

[if x is not greater than 10 years])

5 years

10 years

6 years

8 years

7 years

6 years

8 years

4 years

9 years

2 years

>= 10 years

0 year


The counting of years of relevant experience is calculated up to the nearest month, with days less than one month rounded up to the nearest month and cut-off as at December 2014.


For example, an applicant employed in a PWM institution with customer-facing functions from 20 January 2006 to 2 October 2013, would have 7 years and 10 months relevant working experience and would need to have an additional 4 years and 4 months relevant working experience in other customer-facing functions in the financial services industry in order to meet the 10 years relevant working experience requirement.


3.      What is the coverage of other customer-facing functions in the financial service industry?


Customer-facing functions refers to those roles such as Relationship Manager or Investment Advisor  which make customized solicitations or recommendations to clients in the provision of securities dealing and advisory services and/or portfolio management services. Please refer to the definition of Relevant Practitioners for the detail of the key roles.


Financial services industry refers to investment banking, corporate banking, retail banking, asset management companies, brokerage firms, hedge funds, private equity funds etc.


Credit card companies, credit unions, insurance companies, consumer finance companies, and firms providing audit, consulting, financial advisory, tax or related services to financial institutions will not be considered as within the financial services industry for the purpose of grandfathering applications.


PWM Assistants, including but not limited to those with a functional title such as Assistant to Relationship Manager, would be recognized in the same way as other customer-facing functions in the financial services industry for Grandfathering purposes if the individual performs substantially all of the prescribed key roles, including the provision of investment ideas or recommendations to customers directly. 



4.     Is a Corporate Finance or Research function considered a PWM customer-facing function for the purpose of ECF?


No, corporate finance or research are not considered PWM customer-facing functions for the purpose of ECF.


5.      How does the Relevant Practitioner know if he / she is eligible for exemption?

The application for Grandfathering requires Human Resources or other relevant departments of the concerned PWM institution(s) to endorse an application's employment history based upon respective verification and / or self-declaration. The endorsement by your current employer indicates that the Relevant Practitioner has met the eligibility criteria for relevant experience before the application is passed to PWMA for processing.

 

6.      How does one complete the Module 2 requirement?

Upon confirmation letter issued from the PWMA that a one-off exemption has been granted, the Relevant Practitioner may either complete the accredited training programme from Module 2 or pass the accredited examination for Module 2 within 12 months from the confirmation letter issuance date.  The provider for the initial programme and examination for Module 2 will be The Hong Kong Institute of Bankers. 


Please go to the HKIB website (https://www.hkib.org/en/index ) for details of the training and examination schedule.


7.      How will I be informed of the assessment results? Do I get a chance to appeal if the result is a rejection? 

Results will be given in writing usually within 60 days upon receipt of a completed application form and the required supporting documents. More time may be required if further clarification is needed.


Applicants may appeal by providing additional information with supporting document(s) for substantiation within 3 months from the date of notification of result. Reassessed results are final and no further appeal will be accepted.


8.      Is leave counted for grandfathering if the employee continues to work in the institution?

The ECF provides for a one-off exemption to those Relevant Practitioners who have at least 10 years of relevant experience.  The 10 years of relevant experience must be met on or before December 31, 2014.  Leave of any type is counted for grandfathering while the employee remains working in the institution.


9.      If an applicant has 10 years relevant experience but had left the industry, is he/she eligible for grandfathering?

Currently, the grandfathering is only applicable for Relevant Practitioners who are currently employed at a PWMA member institution.


10.      Is there any application fee?

There is a non-refundable HKD1,000 application fee for application of grandfathering and CPWP certification. 


11.      Is there a cut-off date for applying for the grandfathering eligibility?

The 10 years of relevant experience must be met on or before December 31, 2014. 


For those Relevant Practitioners who are currently employed by PWMA member institutions, the deadline to apply for the grandfathering exemption will be on or before 30 January 2015. They need to have the Module 2 completed, either by passing the examination or taking the course, on or before 30 June 2016.


Those Relevant Practitioners who are currently employed by Non-PWMA member institutions may apply for grandfathering within 3 months of becoming Relevant Practitioners of PWMA member institutions provided that the eligibility for grandfathering has been met. They need to complete Module 2, either by passing the examination or taking the course, within 12 months after a one-off exemption has been granted.


12.     Would overseas work experience be recognized for grandfathering application?


In general, relevant overseas work experience in established financial centres / wealth management centres is recognized for the purpose of grandfathering application. These countries include France, Germany, Japan, Singapore, Switzerland, United Arab Emirates (Dubai), United Kingdom and United States. Work experience in other countries will be considered on a case-by-case basic by the Accreditation & Exemption Committee, following guidance from the PWMA Executive Committee when needed.


13.     Does PWMA accept batch submission of the application forms from its members?


A member institution may deliver the application forms of its relevant practitioners in batch together with one single payment for the application fee. Please provide the details of a representative as key contact person regarding the applications in a cover letter. 

 

14.     What is the use of the self-declaration form for a grandfathering application?


The purpose of the self-declaration form is to serve as a supporting document indicating key roles and responsibilities in relation to the applicant’s previous work experience.


You are advised to complete and enclose this form when submitting your application.


15.     Where can we obtain the self-declaration form?


Please contact the relevant personnel for your firm in charge of coordinating CPWP applications to obtain a copy of the self-declaration form. We would consider posting the form later in the website.



16.     How do I fill in the details of my employment history on the application form for Grandfathering if self-declaration forms are used?


You should list all your relevant work experience in the Employment History section on the application form for Grandfathering, no matter whether you use self-declaration forms or not.


Nonetheless, when filling in the Employment History section for the previous work experience with self-declarations, you should tick “Self-Declared” under “Roles Verified By”; and indicate “please refer to the self-declaration form enclosed”, or a remark with similar wordings, under “Key Responsibilities”.