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?

For those Relevant Practitioners who have at least 10 years of relevant customer-facing work experience described below, they 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.


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


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


Customer facing functions refers to those Relationship Manager or Investment Advisor type of roles making 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 financial services industry for the purpose of grandfathering application.


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

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

 

5.      How does one complete the Module 2 requirement?

Upon confirmation from the PWMA that a one-off exemption has been granted, the Relevant Practitioner may either complete accredited training programme on Module 2 or pass accredited examination on Module 2 by 30 June 2016.  Provider for the initial programme and examination for Module 2 will be The Hong Kong Institute of Bankers.


6.      When will the courses and examinations be available for the “grandfathered” Relevant Practitioners?

The Hong Kong Institute of Bankers (HKIB) provides the initial Module 2 programmes and examinations and has started its first run of training programmes in November 2014.  Please go to the HKIB website (http://www.hkib.org/indexen.asp) for details of the training and examination schedule.


7.      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.


8.      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.


9.      Is there any application fee?

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


10.  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 the PWMA member institutions provided that the eligibility for grandfathering has been met. They need to complete the Module 2, either by passing the examination or taking the course, within 12 months after a one-off exemption has been granted.


11.  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 by the Accreditation & Exemption Committee on case by case basis.


12.  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. 

 

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


The purpose of self-declaration form is for indicating the key responsibilities of your previous work experience.


Self-declaration forms are considered as supporting documents about the key roles and responsibilities of previous employment history of applicants. You are advised to enclose them together when submitting the applications.


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


You should contact the corresponding personnel or co-ordinator of your firm designated for grandfathering applications to obtain a copy of the self-declaration form. We would consider posting the form later in the website.


15.  How to fill in the details of 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 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:

a)      tick “Self-Declared” under “Roles Verified By”; and

b)      indicate “please refer to the self-declaration form enclosed”, or a remark with similar wordings, under “Key Responsibilities”.