INFORMATION ADVISORY NOTE CACS CPD for Covered Persons under PB Code of Conduct

Transcription

1 1. Introduction INFORMATION ADVISORY NOTE CACS CPD for Covered Persons under PB Code of Conduct 1.1 Under the Private Banking Code of Conduct ( PB Code ), Covered Persons are expected to achieve a minimum of 15 hours of Continuing Professional Development ( CPD ) in each calendar year after passing the Client Advisor Competency Standards ( CACS ). The CACS CPD requirements ensure that Covered Entities and their Covered Persons providing financial advisory services to High Net Worth Individuals ( HNWIs ) conduct their business activities with integrity and professionalism and ensure that they possess a requisite level of competence and knowledge. 2. Commencement of CACS CPD Obligation 2.1 To ensure that knowledge and skills are kept current with industry and regulatory developments, CACS CPD is considered to be a critical component of the ongoing competency of Covered Persons. All Covered Persons are expected to achieve a minimum of 15 hours of CACS CPD in each calendar year. 2.2 The CACS CPD requirement will take effect from 1 March 2013 onwards. To oversee the smooth implementation of the CACS CPD, the Private Banking Industry Group ( PBIG ) has formed a CACS CPD Advisory Group ( CPDAG ). The Institute of Banking and Finance ( IBF ) has also been appointed as the CACS Administrator and will serve as secretariat to the CPDAG. Please see Annex 1A for the governance structure. 2.3 For a Covered Person who passes the CACS prior to 1 March 2013, his CACS CPD obligation under the PB Code for Year 2013 will be 12 hours of CACS CPD. His CACS CPD obligation from Year 2014 onwards is 15 hours of CACS CPD hours per year. If a Covered Person passes the CACS on or after 1 March 2013, his CACS CPD obligation will be pro-rated as set out in paragraph under the Competency Section of the PB code and as shown below: Table 1: Pro-ration of CACS CPD hours No. of working months in calendar year CACS CPD obligation under the PB Code Less than 3 months 5 CACS CPD hours Between 3 months to 6 months 8 CACS CPD hours Between 6 months to 12 months 12 CACS CPD hours Version 2.0 Updated Dec

2 3. CACS CPD Activities 3.1 CACS CPD activities should generally fulfill the following criteria: Table 2: Criteria for CACS CPD Activities Relevant Required to carry out current role effectively and/or expand current skill set within Wealth Management Private Banking Certifiable Courses must be conducted by trained individuals or professionals knowledgeable of subject matter Measurable Must meet stipulated learning outcomes and specified number of hours Verifiable Timely Must have system in place to track course attendance and provide attendance certification upon completion of activity Must be completed within the relevant calendar year 3.2 The annual CACS CPD activities in which the relevant hours are accumulated are expected to comprise an appropriate combination of the following, taking into account knowledge dominant competencies within the FICS framework, where relevant: (a) relevant market conduct requirements; (b) relevant product knowledge; (c) relevant skills / competencies; and/or (d) relevant compliance-related matters. 3.3 The appropriate combination of the 15 hours of CACS CPD to be achieved by the Covered Persons is expected to be determined by the Covered Entity for whom the Covered Person acts on behalf of, subject to paragraph To help facilitate the varied CACS CPD needs of Covered Persons of different seniority and industry experience, a wide variety of CACS CPD activities will be recognized under the broad categories of (i) Training & Education, (ii) Instruction, (iii) Leadership and (iv) Research & Publication, as documented in Table 3: CACS CPD Guidelines. Version 2.0 Updated Dec

3 Version 2.0 Updated Dec

4 3.5 The table below illustrates some programmes that have surfaced to IBF for clarification. Please note that this list is not exhaustive. CACS CPD Activities Industry-related Event Table 4: Eligibility of Activities for CACS CPD Recognition Examples of activities NOT eligible for CACS CPD recognition Χ Networking events, trade fairs and investor presentations Examples of activities eligible for CACS CPD recognition Conventions, conferences and seminars with financial sector related content E-learning External Courses Χ E-learning programme that is less than 30 mins Χ E-learning with no assessment component Χ Preparatory programmes leading to regulatory- required examinations (eg. CMFAS preparatory course or online examination tips) Χ Product/ systems-specific programmes (eg. vendor A s systems training or fund house s briefing on a new fund) Χ Generic language programmes (eg. Introduction to Mandarin ) Χ Generic soft skills/ personal development programmes (e.g. presentation skills) Any form of e-learning with verifiable assessment and meets the minimum duration of 30 mins. This includes PC-based online interactive learning as well as mobile learning apps Preparatory courses leading to professional qualification / certification examinations (eg. CFA preparatory course conducted in a structured setting with the issue of supporting documents ) Finance related undergraduate / MBA programs (upon passing) Product / technical training with no marketing content (eg. Introduction to structured warrants and the risks involved ) Language programmes targeted for financial-sector professionals and is relevant to the Covered Person s role (e.g. Business Finance in Mandarin ). The same language programme can only be recognised once for CACS CPD Structured Leadership Programmes Internal Courses Χ Regular in-house market briefings on investment outlook/ economic updates or analyst briefing on house views Annual/ bi-annual conference covering market or industry analysis Version 2.0 Updated Dec

5 Χ Training on bank-specific product, in-house systems/ processes (eg. training on the use of Bank A s new system) Χ Orientation/ induction programmes Χ Generic soft skills/ personal development programmes (e.g. presentation skills) Programmes providing generic product or systems training with finance-related technical component Clearly demarcated segment of the orientation programme that covers technical content on laws & regulations/ product knowledge/ functional competencies. The knowledge/ skills acquired have to be transferable within the industry. Only hours that cover these transferrable knowledge can be counted towards CPD Structured Leadership Programmes Professional Examinations Χ Self-study time leading to professional qualification Duration of examinations leading to a professional qualification / certification (excluding regulatory/ industry examinations) with a pass grade can be counted in the year of passing Lecturing/ Teaching Assignments Presentation, Panel Discussion or Speaking at Events Financial Sector Committee / Working Group Structured mentoring programme Research & Publication Χ On-the-job sales coaching Χ Speaking to students to promote the bank or to drive recruitment Χ Company meetings Χ On-the-job coaching Χ Internal research reports (e.g. reports/ research prepared for internal briefings or for dissemination to clients/ investors) Χ Contributions of individual viewpoints or quotes to the media (e.g. newspaper, TV or radio interviews) Supervisors involved as assessors or trainers in a structured training programme, where hours are independently verifiable Speaking to students to share an overview of the Private Banking industry Financial sector related industry committee of professional bodies, industry associations, IBF or MAS Structured mentoring programme either offered by professional associations or as part of in-house leadership programme Articles/ reports published or disseminated to the public Contributions of researched material to the media Version 2.0 Updated Dec

6 4. Recognition and Endorsement of CACS CPD Activities 4.1 All FICS-accredited/ Financial Training Scheme (FTS) listed programs will qualify towards the fulfilment of CACS CPD requirement (subject to the relevant cap). With effect from 1 Jan 2014, Training Providers can seek CACS CPD programme recognition by applying for either FICS- Accreditation or FTS Programme Eligibility. FICS-accreditation caters to programmes with content aligned to the FICS Standards while FTS Programme Eligibility caters to financial sector-specific programmes aimed at raising the competency of the financial sector. To find out more about FICS Accreditation and FTS Programme Eligibility and how you can put in an application, please visit For other programmes that do not meet the FICS/ FTS criteria, the Designated Representatives of the Covered Entity will have to make his own discretion based on the CACS CPD guidelines. CPDAG IBF may float new activity areas up to CPDAG for advice IBF Designated Representative to approach IBF if he is unsure about eligibility of any activity Covered Entity s Designated Representative Covered Entity s Designated Representative(s) should determine if the activity fulfils CACS CPD eligibility and advise the appropriate number of CPD hours accordingly. Covered Persons to approach Designated Representative for all matters pertaining to CACS CPD requirements Covered Person 5. Submission of Covered Person s CACS CPD Hours 5.1 All Covered Persons are expected to maintain their own records of how the expected CACS CPD hours are met. This should include: (a) Name of the course attended; (b) Date of the course; (c) Whether it is held internally or externally; and (d) Number of hours attended. Version 2.0 Updated Dec

7 5.2 Covered Entities are expected to maintain appropriate records for each Covered Person to allow for an audit to be conducted on the hours of CACS CPD achieved by each Covered Person, and the relevance of the CACS CPD activities undertaken. 5.3 The Covered Entity s Designated Representatives are expected to submit CACS CPD reporting of their Covered Persons annually for the calendar year, using the form - Annual Fulfillment of CACS CPD Obligations (Annex 2A) and CACS CPD Activities (Annex 2B), by 31st January of the following year. For the purpose of closer monitoring of CACS CPD fulfilment in the initial phase, IBF will require all Covered Entities to submit a mid-year interim report for the period 1 March 2013 to 30 June 2013 by 15 July IBF reserves the right to perform audits on the Covered Persons to ensure fulfillment of CACS CPD requirements in the previous year. Covered Persons are required to submit supporting documents for activities undertaken in the event of an audit. 6. Penalty for Non-Compliance of CACS CPD Requirements 6.1 If a Covered Person is unable to fulfil the CACS CPD requirement by 31 Dec of any given calendar year, he will be required to make up the remaining CACS CPD hours in the following calendar year, plus a 3 CACS CPD hours penalty. This implies that, in addition to the usual 15 CACS CPD hours, he will be required to make up the remaining CACS CPD Hours of the previous year plus a 3 CACS CPD hours penalty. Illustration of Penalty for Non-Compliance of CACS CPD requirement 6.2 If a Covered Person is unable to complete the CACS CPD requirement for 2 consecutive years, he will be required to re-take and pass the CACS Assessment. According to the PB Code, the Covered Person will not be able to practice during the lapse period. 6.3 If a Covered Entity hires a Covered Person with penalty hours brought over from the previous year, it the responsibility of the Covered Entity to ensure that the Covered Person fulfills his uncompleted and penalty hours brought over from the previous year(s) in addition to his CACS CPD obligation for the year. Version 2.0 Updated Dec

8 7. Reporting of CACS CPD Data 7.1 As the CACS Administrator, IBF will be compiling statistics and making regular reports to the regulatory authorities (e.g. Monetary Authority of Singapore and Private Banking Industry Group Executive Committee). This would include the CACS CPD status of Covered Persons and that Covered Entities have ensured that their Covered Persons have fulfilled the required CACS CPD obligations. Personal data relating to individuals will not be disclosed without the Covered Person s prior consent. 8. Frequently Asked Questions (FAQs) 8.1 We have also attached a list of FAQs in Annex 1B to address common queries relating to CACS CPD for Covered Persons. Should you still need any further assistance, please us at cacs@ibf.org.sg. Alternatively, you may contact Ms Tan Yan Wei at or Mr Kyo Tan at Version 2.0 Updated Dec

9 ANNEX 1A CACS CPD Governance Structure & Terms of Reference for CACS CPD Advisory Group ( CPDAG ) 1. Governance Structure for CACS CPD in the Private Banking Industry 1.1 The proposed governance structure would comprise the Private Banking Industry Group ( PBIG ), CACS CPD Advisory Group ( CPDAG ), Institute of Banking and Finance ( CACS Administrator ) and Covered Entity s Designated Representative(s) as shown graphically in Figure 1. Figure 1 Governance Structure for CACS CPD in the Private Banking Industry PBIG CPDAG CACS Administrator Covered Entity s Designated Representative(s) 2. PBIG 2.1 The PBIG is mandated with the task to shape the development and foster the sustainable growth of the Singapore Private Banking Industry. 2.2 Role of PBIG The specific objectives of PBIG include the following: To serve as the custodian of the Private Banking Industry Code of Conduct ( PB Code ) To enhance the stature, reputation and growth of the Singapore Private Banking Industry To serve as a channel of communication amongst industry players and with the Monetary Authority of Singapore ( MAS ) 3. CACS CPDAG 3.1 The CACS CPDAG will consist of a committee of 10 representatives from Singapore s Private Banking industry holding the position of Head Relationship Manager (RM), Head of Product Specialist, Head of Compliance and Head of Human Resource (HR) or Learning & Development (L&D). Version 2.0 Updated Dec

10 3.2 The proposed composition of the CACS CPDAG is as follow: Work Function No. of seats Head Relationship Manager (RM) 4 Head of Product Specialist 2 Head of Compliance 2 Head of HR or L&D For the first year of implementation, meetings would be convened quarterly to provide guidance and oversight on the implementation of the CACS CPD. 3.4 Terms of Reference for CACS CPDAG The Terms of Reference for the CACS CPDAG include the following: To provide guidance on the implementation of CACS CPD policies for Covered Persons under the PB Code; To provide guidance on the topics and coverage deemed suitable to raise the competency of the Private Banking industry through CACS CPD; To review and approve issues raised by the CACS Administrator such as: (i) criteria for eligibility of CACS CPD activities; (ii) exemption from fulfilment of CACS CPD; (iii) follow-up actions to be recommended, if any; (iv) recommendation on changes to CACS CPD policies/guidelines 1 4. Covered Entity s Designated Representative(s) 4.1 The Covered Entity s Designated Representative(s) shall be appointed by the Covered Entity s Board or senior management. The Designated Representatives shall have managerial oversight in areas such as Human Resource (HR), Learning & Development (L&D), Compliance or in managing Covered Persons. 4.2 Role of Designated Representative(s) The role of the Covered Entity s Designated Representative(s) is to assess and certify in-house CPD training programs to ensure compliance with the CACS CPD guidelines as well as oversee the reporting of Covered Entities CACS CPD status to the CACS Administrator. 5. CACS Administrator 5.1 The CACS Administrator will be the first point of contact in administering the established CACS CPD criteria and standards and handling all CACS CPD queries. 5.2 Role of CACS Administrator The role of CACS Administrator includes the following: Alignment of CACS CPD to FICS where relevant; 1 On the recommendation of the CACS CPDAG, issues on policy matters and follow-up actions should additionally be cleared with the PBIG Exco. Version 2.0 Updated Dec

11 Supports CACS CPDAG for all CACS CPD matters and queries; Serves as a channel of communication amongst Covered Entities and with the CACS CPDAG; Provides CACS CPD status update to the CACS CPDAG and PBIG; Facilitates the tracking of CACS CPD hours of Covered Persons; Monitors the fulfilment of annual CACS CPD requirements by Covered Persons; Conducts annual CACS CPD audits; Accreditation for CACS CPD programs; Update and document revisions of CACS CPD policies; Determine appropriate fees for CACS CPD administration if necessary. Version 2.0 Updated Dec

12 ANNEX 1B CACS Continuing Professional Development ( CPD ) For Covered Persons under the Private Banking Code of Conduct ( PB Code ) Frequently Asked Questions (FAQs) Version 2.0 Updated Dec

13 SECTION (A) GENERAL Q1. What is the role of the Private Banking Industry Group ( PBIG )? A1. The PBIG is mandated with the task to shape the development and foster the sustainable growth of the Singapore Private Banking Industry. Q2. What is the role of the CACS CPD Advisory Group ( CPDAG )? A2. The CPDAG provides guidance on CACS CPD eligibility topics and recognized CACS CPD learning activities. It will not aim to endorse specific courses. Q3. Who are the members of the CPDAG? A3. The CPDAG consists of a committee of 10 representatives from Singapore s Private Banking industry holding the positions of Head Relationship Manager (RM), Head of Product Specialist, Head of Compliance and Head of Human Resource (HR) or Learning & Development (L&D). Q4. What is the role of the CACS Administrator (IBF)? A4. The CACS Administrator will be the first point of contact in administering the established CACS CPD criteria and standards and handling all CACS CPD queries. Q5. What is the role of the Covered Entity s Designated Representative(s)? A5. The role of the Covered Entity s Designated Representative(s) is to assess and certify CACS CPD training programs taken by their Covered Persons to ensure compliance with the CACS CPD guidelines as well as oversee the reporting of their Covered Persons CACS CPD status to IBF. Q6. Who is eligible to be appointed as the Covered Entity s Designated Representative(s)? A6. The Covered Entity s Designated Representative(s) shall be appointed by the Covered Entity s Board or senior management. The Designated Representatives shall have managerial oversight in areas such as Human Resource (HR), Learning & Development (L&D), Compliance or in managing Covered Persons. Version 2.0 Updated Dec

14 SECTION (B) CACS CPD OBLIGATION Q7. With the launch of the PB Code, when will a Covered Person be required to commence his CACS CPD obligation? A7. With the launch of the PB Code, a Covered Person will be required to fulfill his CACS CPD obligation with effect from 1 March The CACS CPD calendar year commences on 1 January and ends on 31 December every year. If a Covered Person passed his CACS prior to 1 March 2013, his CACS CPD obligation under the PB Code for Year 2013 is 12 hours of CACS CPD. His CACS CPD obligation from Year 2014 onwards is 15 hours of CACS CPD per year. If a Covered Person passes his CACS Assessment on or after 1 March 2013, his CACS CPD obligation in the year which he passes his CACS Assessment, will be pro-rated as set out in paragraph under the Competency Section of the PB Code as follows: (a) Less than 3 months 5 CACS CPD hours (b) Between 3 months to 6 months 8 CACS CPD hours (c) Between 6 months to 12 months 12 CACS CPD hours From the following year onwards, his CACS CPD obligation is 15 CACS CPD hours per year. Q8. Can the CACS CPD activities that a Covered Person undertakes between 1 Jan 2013 and 1 Mar 2013 qualify for the CACS CPD obligation under the PB Code? A8. CACS CPD activities undertaken between 1 Jan 2013 and 1 Mar 2013 can be counted towards fulfilling 2013 s CACS CPD obligation provided the activities were undertaken after the Covered Person passed his CACS Assessment. Q9. Can the CACS CPD activities undertaken before the Covered Person passes his CACS Assessment qualify for the CACS CPD obligation under the PB Code? A9. No, CACS CPD activities undertaken prior to passing CACS will not count towards meeting his CACS CPD obligation. Q10. Can a Covered Person carry 'surplus' CACS CPD hours from one year to the next? A10. No. Surplus CACS CPD hours cannot be carried to the next year. Q11. Will an overseas private banker who is temporarily transferred to Singapore s branch be subjected to the CACS CPD requirement? A11. If the temporarily transferred overseas private banker is required to take the CACS Assessment, he is obligated to fulfill his CACS CPD requirement as well during the period for which he is working in Singapore. Version 2.0 Updated Dec

15 Q12. If a Covered Person has been exempted from taking the CACS Assessment (either having undergone NEC or FICS certification), does he still need to fulfill CACS CPD obligation? A12. Yes, all Covered Persons are required to fulfill their CACS CPD obligation under the PB Code, which will take effect from 1 March Q13. Are Non-Covered Persons who took the CACS Assessment required to fulfill CACS CPD? A13. Non-Covered Persons who passed the CACS assessment are not required to fulfill CPD obligations. In the event that he becomes a Covered Person within 3 years, he will be required to fulfill pro-rated CPD hours for the year. However, if he becomes a Covered Person after 3 years, he will have to re-take and pass the CACS assessment even if he had been voluntarily fulfilling CPD in the last 3 years. SECTION (C) RECOGNISED CACS CPD ACTIVITIES Q14. How can a Covered Person find out if an activity or program is recognised for CACS CPD? A14. All FICS-accredited / Financial Training Scheme (FTS) eligible programmes can be recognised for CACS CPD. A list of these programmes is available on IBF s website. For other programmes, the Covered Person should approach his Covered Entity s Designated Representative(s) who would advise him based on the CACS CPD guidelines. Q15. Why is there a cap on the maximum number of hours that can be attained from a CACS CPD activity? A15. The maximum cap of 10 CACS CPD hours for each category of activity is intended to ensure that the Covered Person benefits from a more comprehensive range of learning platforms to enhance his professional development. Q16. Is there a minimum criterion for trainers of internal or external courses recognised for CACS CPD? A16. Trainers should minimally possess the relevant qualification or experience in the subject matter. Q17. A Covered Person spends hours each day reading newspapers, journals, research papers etc. What CACS CPD hours does he get? A17. Reading of newspapers, journals and research papers will not qualify for CACS CPD hours. Version 2.0 Updated Dec

16 Q18. Can time spent on preparing for an instruction activity be recognised for CACS CPD hours? A18. As a guiding principle, activities should be measurable and verifiable to be considered eligible CACS CPD activities. If the time spent on preparing for the instruction activity can be measured and verified with supporting documents, it can be recognised as CACS CPD hours. Q19. Having passed the CACS Assessment, a Covered Person goes on to complete a FICSaccredited program in Wealth Management - Relationship Management (High Net Worth) at Job Role IV and above and attains FICS Certification. How will this count towards the fulfillment of CACS CPD requirement? A19. As long as the Covered Person completes the FICS-accredited programme in Wealth Management - Relationship Management (High Net Worth) at job role IV and above after passing the CACS assessment, and attains FICS certification, he will be deemed to have fulfilled CACS CPD requirements for 2 years the year in which he completed the program and the year in which he attained FICS certification (Note: this may include the year after certification if program completion and attainment of certification took place in the same year). In the case where the Covered Person completed the FICS-accredited programme in Wealth Management - Relationship Management (High Net Worth) programme at Job Role IV and above and attained FICS certification between 1 st Sep 2011 (CACS commencement) and 1 st Mar 2013, he would be deemed to have fulfilled CACS CPD requirement for the years 2013 and Q20. If a Covered Person had completed the FICS-accredited programme in Wealth Management - Relationship Management (High Net Worth) programme at Job Role IV and above and attained FICS certification prior to 1 st Sep 2011 (CACS commencement), would he be deemed to have fulfilled CACS CPD requirement? A20. No, he may not use the completion of the above programme and certification attained before 1 st Sep (CACS commencement) to fulfill CACS CPD requirements. Version 2.0 Updated Dec

17 SECTION (D) MONITORING CACS CPD HOURS Q21. Whose responsibility is it to monitor the Covered Person s CACS CPD requirements? A21. Both Covered Entities and Covered Persons will have to maintain records of how the expected CACS CPD hours are met. Covered Entities are required to monitor and ensure that all Covered Persons who act on their behalf will meet the expected CACS CPD hours by the end of each calendar year. (See paragraphs of the PB Code) In the event that the Covered Person leaves Covered Entity X to join Covered Entity Y, X will have a responsibility to issue a confirmation of the Covered Person s CACS CPD records before he leaves. It is Y s responsibility to ensure that the Covered Person fulfills his outstanding CPD obligation for the year. Q22. Is there a specific format for the bank to adhere to when issuing the confirmation letter of the Covered Person s CACS CPD records? A22. A sample template (Annex 2C) is available on the IBF website. However, if a bank already has a CPD system with tracking capability, the bank may provide the confirmation letter using its own format. Q23. What are the supporting documents required for an activity under the Training & Education Category to be considered verifiable? A23. Supporting documents may include the employer s acknowledgement or sign-off, certificate of attendance or completion, or where there has been an assessment, a copy of the result slip. Q24. How does a Covered Person show evidence of participation in leadership activity? A24. Covered Person who is a member of an industry committee is to produce a certificate of attendance from the Secretariat of the committee to reflect the appropriate hours of his involvement. Q25. How long does a Covered Person need to retain the supporting documents for CACS CPD activities? A25. All CACS CPD supporting documents should be retained for a minimum period of 3 years for audit purposes. Version 2.0 Updated Dec

18 SECTION (E) ABSENCE FROM SINGAPORE PRIVATE BANKING INDUSTRY Q26. Can an overseas course count towards fulfilling CACS CPD requirement? A26. Yes. Courses which fall within the CACS CPD requirements whether taken locally or overseas will count towards CACS CPD hours. Please ensure you have a copy of all the relevant documents. Q27. If a Covered Person left the private banking industry but is planning to rejoin the industry, what is his CACS CPD obligation? A27. As long as the Covered Person is in a client-facing advisory role in a Singapore-based Covered Entity, he is required to fulfill CACS CPD obligation. Whenever he exits the industry, the obligation does not follow. When he rejoins the industry, he will have to resume his CACS CPD obligation. In addition, if he is away for more than 3 years, his CACS assessment will be nullified and he will need to re-take the CACS assessment. His CACS CPD obligation will then resume after he passes his CACS assessment. However, we make exceptions for Covered Person who continue to be in a client-facing advisory role working overseas. For such instances, Covered Person will not need to re-take his CACS assessment, even if he is away for more than 3 years. SECTION (F) REPORTING & SUBMISSION Q28. Does a Covered Person or the Covered Entity report the status of their CACS CPD hours to the CACS Administrator ( IBF )? How frequently should this report be submitted? A28. The Covered Entity s Designated Representatives are expected to submit CACS CPD reporting of their Covered Persons annually for the calendar year, using the form - Annual Fulfillment of CACS CPD Obligation (Annex 2A) and CACS CPD Activities (Annex 2B), by 31st January of the following year. Q29. What will happen after the Covered Entity submits their Covered Persons declared CACS CPD hours to IBF? A29. As the CACS Administrator, IBF will be compiling statistics and making regular reports on the CACS CPD status of the Covered Entities and their Covered Persons as well as the progress of CACS to the regulatory authority (i.e. Monetary Authority of Singapore and the Private Banking Industry Group Executive Committee). Version 2.0 Updated Dec