The Legal & General Network Performance Management System (Adviser)

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1 The Legal & General Network Performance Management System (Adviser) Page 1 of 28

2 Contents 1) Introduction 2) Recruitment 3) Training and assessment 4) Commencing the role 5) Continuing the role 6) Requirements of L&G network enforced increased individual supervision 7) Enhanced Supervision 8) Supervisors moving to adviser status (or vice versa) 9) Supervision of close relatives 10) Adviser Long term sickness and maternity leave 11) Key knowledge and skills grid 12) Observations 13) Formal 1:1 meetings 14) Key performance indicators and Management information standards Page 2 of 28

3 1. Introduction The Legal & General Network (hereafter called The Network ) Performance Management System (PMS) has been designed to provide a framework to ensure a consistent approach to the supervision of every adviser. A comprehensive training and coaching programme is essential to ensure that the knowledge and skills of the adviser are appropriate, are developed throughout their careers, identifies development needs and sets the foundation for the continuing professional development of the adviser. By working closely with the adviser and following these guidelines, we believe that it will benefit the relationships between the adviser, the firm, the Network and the customer, as well as satisfying regulatory requirements. Supervisors must ensure they are comfortable with their ability to carry out all the requirements of this scheme with all advisers within their span of control (SPOC). We would suggest a maximum of 15 advisers per supervisor. Where the SPOC is in excess of 15, the Supervisor or the firms PoCC must document via a fully completed CSmart event (SPOCDEC) the current position and how they will continue to manage the increased SPOC. An adviser is required to show and maintain competence in 4 key areas: Knowledge to have appropriate qualifications, and a continually tested understanding of generic industry and firm specific products, and of the processes required to fulfil the role Skills to have the ability to display a range of technical and interpersonal skills in order to perform the role to the desired standards Ethics personal commitment to demonstrate ethical behaviours which improves the customer perception of the industry as a whole and ultimately achieve better customer outcomes Expertise the ability to apply their knowledge and skills to achieve positive and fair outcomes for the customer, and meet the performance standards required of the role of adviser The PMS is aimed at providing the steps to allow you to monitor and assess all of the key areas above. To achieve and maintain competent status all the relevant steps in each section of this document must be completed, checked/evidenced and documented in a timely and accurate manner. The CSmart system is used to document adviser career progress. The CSmart system for advisers normally covers 3 areas known as tracks which are now known as:- Training and assessment Commencing the role Continuing the role The PMS will be regularly reviewed to ensure it remains appropriate and may be updated from time to time. Where no specific ruling or guidance exists within these procedures, we expect that an individual or firm will take an intelligent view in the interest of the customer, or seek guidance from us, rather than seek to exploit any apparent omissions. Any queries relating to this scheme must be directed to the Business Standards Team. Any requests for concessions must be submitted to Any concessions granted will be logged on the Adviser s CSmart track under an event named (BSTCON) and will be granted an end date that must be adhered to. Page 3 of 28

4 2. Recruitment Introduction It s important to have a comprehensive recruitment process to ensure the right calibre of individual is appointed to the role of Adviser. This will contribute to the successful completion of all stages in the Performance Management system and improve customer satisfaction. Recruitment Process The recruitment process needs to assess knowledge, skills, behaviour and expertise, and therefore could include but is not limited to : Interviews (including general industry and product knowledge) Role plays Review of Financial standing Review of Disciplinary issues Consideration of the past experiences and successes of the candidate Psychometric testing Interrogation of detail within applicants C.V. Personal effectiveness It s also considered good practice to try to attain some detail of Advisers current performance including: Business mix Production track record Proof of earnings Conversion ratios Other relevant KPI data (for example review of complaints history, CFO s etc) Other steps to be completed during or prior to this stage: Step 1: Remuneration Structure Firms should ensure that they have a documented remuneration structure in place that encourages the correct adviser behaviours. Rewards under the structure must not encourage spikes in activity or written business. The correct metrics should be used to assess whether any poor behaviour exists, and appropriate sanctions should be included to ensure that this behaviour is not rewarded. Detailed guidance is available in Section 3 of the Operating Procedures. Step 2: Job description and Principal Accountabilities The recruiting firm must ensure that a job description is available, up to date and reflects the principal accountabilities of the role. This must be held centrally and be available for inspection if required. Step 3: Appropriate examination level The candidate must be appropriately qualified for the role. The qualifications required are : Mortgage and Protection Adviser CF1 and CF6 (or CeMap) Mortgage and Protection Adviser wishing to also advise on Lifetime Mortgages CF1, CF6 and ER1 General Insurance Only Advisers CF1 only Protection Only Adviser CF1 only Supervisors must advise the potential recruit that they will need to provide original certificates of any exams achieved which are appropriate to the role. Copies of original certificates can be provided but need to be validated by an employee of Legal & General, the firms APER, Supervisor or Point of Compliance Contact. Validated copies must be sent to Legal & General Network Training Department along with the Training Registration Form, or with the application pack (see step 5). Dispensation can be given for previous equivalent exams. If unsure about whether dispensation may apply, please refer to the Business Standards Team. Page 4 of 28

5 Step 4: Discuss and agree market areas The firm and the potential recruit must discuss and agree the market areas in which the adviser will act in (this may of course be limited by the firms scope of service or the qualifications of the adviser). The normal market areas covered by Legal & General Network are: Standard Mortgages Lifetime Mortgages Mortgage Protection Family Protection General Insurance Step 5: Application pack requested The firm must ensure the application pack (including Training Registration form) has been acquired and must be fully completed. All relevant documents must be enclosed. Any missing information or documents could cause delays in getting the Adviser authorised. It s important to point out that all information must be disclosed or they risk having their application declined. The fully completed application pack must then be sent to Firms and Individual Approvals Team (FIA) to assess and reference as necessary. The Training Registration Form must be sent to Training Department to gain access to The Learning Network (TLN). All potential recruits must be advised to chase any outstanding references to aid the speed of the processing of the application. FIA will also require all potential recruits to complete a Criminal Record Bureau (CRB) check. A link will be sent via in order that the applicant can complete the CRB check online. Step 6: Approval and Offer Letter issued Once approval has been received from FIA, the PoCC, Supervisor or Firm s HR department must ensure that : The relevant offer letter is issued to the successful applicant A copy of the offer letter is retained on the Adviser appointment file A written copy of acceptance of offer from the successful applicant/s is submitted to the FIA and the original retained on the appointment file Start date agreed with Adviser Contracts are signed by new Adviser Copy of signed contracts are sent to FIA A letter is issued to new Adviser confirming contract commencement date and details of Supervisor or designated point of contact. Adviser is issued with a copy of the contract Page 5 of 28

6 3. Training and assessment Steps Step Action Required By Whom Event Name 1 Check adviser can access training Supervisor/Adviser N/A and can launch material and tests 2 Set up CSmart access for adviser Supervisor MNIT and coach effective use 3 Maintain regular contact to track Supervisor MNCONTLOG training progress and coach as required 4 Supervisor to brief adviser on L&G Supervisor MNSUPSO Network procedures, standards and requirements 5 Adviser programme adds Supervisor/Course ADVSPA development and coaching as necessary Trainers 6 Ensure adviser is aware of SYSC Supervisor MNSUPSO requirements of L&G and AR firm 7 Supervisor finalises all tracks and confirms adviser is ready to act as an adviser for the Network Supervisor MNSUPSO 8 L&G receive sign off notification, assess CSmart and Training tracks. CSmart track closed, new one loaded Legal and General Network MNHOSO & MNCOMM Introduction The purpose of this section is to highlight the Training and Assessment programme that needs to be completed by a new adviser. All activities highlighted in this section must be completed before the new adviser can move in to the next stage of development. Customer contact Supervisors must ensure new Advisers do not contact customers in connection with any activity (including Mortgages) during this stage of the development programme. If an Adviser is currently licensed under wealth, please call Business Standards Team to discuss a concession. General The Adviser programme is anticipated to last for around 4 weeks, culminating in a residential course. If an adviser has not successfully completed the programme after 3 months then the key personnel within the firm must fully review the progress made to date and make a business decision whether the individual is likely to achieve the desired key knowledge and skills to be able to perform the role of Adviser. Steps to be completed by Supervisors during this stage: Preparation for training Step 1: Training Registration Form & Training track Once we have received the Training Registration Form, the Adviser will be set up on our Learning and Development system. This will allow the Adviser to access various learning materials and tests designed to build their knowledge and skills in preparation for their role, and for the forthcoming adviser programme. Dependent upon the detail provided on the Training Registration Form, the appropriate learning will be loaded onto their personal learning plan for them to fully complete. This learning will include: Core Standards via computer based training as listed in the Training track Industry awareness online learning and testing Product workbooks Page 6 of 28

7 Licence assessments All other requirements under the Advisers Training track Additionally, Lifetime Mortgage Advisers will be required to complete: The Lifetime Mortgage Marketplace/Industry awareness The Lifetime Advice Standards, including an assessment of knowledge The submission process How to use Fintal (separate course provided by Ferret) Fintal case study, including assessment All training must be debriefed, and any areas identified as weaknesses must be included in a development plan and re-tested prior to supervisor signing off as ready to progress to commencing the role. Supervisors must then ensure Advisers have access to the necessary equipment, backup support and literature to enable them to study efficiently. Step 2: Adviser is registered on and introduced to CSmart Supervisors must ensure that Advisers can access and use the CSmart system. Supervisors must then introduce and coach Advisers on how to use it effectively. Advisers must then be assigned the Recruitment and Initial Training track. (Assign MNIT - Manual) Step 3: Adviser contact Supervisors are expected to maintain regular contact (at least weekly) with new advisers to ensure they are on course to finish all the required elements of their training track prior to attendance on the residential selling event. There will also be additional learning requirements following the residential course which will also need to be completed prior to you requesting licences.contact records must be maintained to detail any training and development undertaken by you to assist new Advisers and this must be updated in CSmart. (MNCONTLOG - AUTO) Step 4: Briefing on the Legal & General Network, Operating procedures and Performance Management System Supervisors must brief Advisers on the L&G Networks Operating Procedures, its contents and requirements, and must include the following areas: Relevant sections of the operating procedures and expected sales process as documented in the What good looks like guidance (appendix 8.0 of the Operating Procedures) The Key Performance Indicators that have to be met to show and maintain competence (and licences) The use of the Personal Activity Log and how this must be completed to display continuing professional development The expectations of how the individual will be managed including their 1:1 s, use of development plans and regular observations The standards of integrity and ethics expected by the Network and the FCA Supervisors must ensure Advisers are fully briefed on the content and requirements of : Advice Standards (Mortgage Advice Standards and Protection and General Insurance Advice Standards) The expectations about the quality of records kept and standards of advice given Supervisors must also ensure Advisers are trained on the content of and quality expected within the documents issued to customers including: PSL letters MRoS letters (MNSUPSO) Page 7 of 28

8 Step 5: L&G Network Adviser Programme It s compulsory that all new advisers fully complete the Adviser Programme which will culminate in the requirement to attend the Legal & General residential selling event. The adviser programme focuses on the skills and knowledge required to perform the role of Adviser. The induction course will introduce the advisers to the Point of Sale system, allow them to understand and test their knowledge of our Sales Quality requirements, and tests the application of skills and knowledge learnt during the training track and induction course, culminating in a role play assessment of a full interview. Feedback will be provided to the firm following the adviser s attendance on the induction course, to define any areas of weakness, concern or specific development required. Should the Adviser fail their assessment, the Supervisor will be required to complete further development, and a subsequent role play assessment (logged onto CSmart) prior to requesting Legal & General approval for granting the relevant licences. Please contact who will provide role play case studies. Course activity will be detailed in an event named ADVSPA. Full details of the requirements of the programme are detailed here AP Guide For an overview of the scheme, click here. Step 6: Business processes and procedures Supervisors must brief Advisers and ensure they understand all the relevant processes and procedures that occur within their business. The following is a guide to the areas that could be covered but is not exhaustive : Systems & Controls Internal structures including Reporting lines Roles and Responsibilities Processes and Practices Business orientation Complaints and breach procedures Step 7: CSmart track completion Supervisors must ensure that all relevant events in CSmart are accurate and fully completed and then signed off. Once complete, the Supervisor will need to certify that they believe the Adviser is ready to commence in their role. This will then trigger a request to grant licences, enabling us to review both TLN and CSmart to ensure that we are satisfied with the development to date. No activity must take place until formal confirmation has been received that we have granted licences. (MNSUPSO - AUTO) Step 8: Moving to Commencing the Role Once the Supervisor has received formal notification that licences have been granted, they must close the Initial Training Track, and assign the Commencing the Role track. Any outstanding development needs should be transferred on to Advisers Development Plan event in the newly assigned Commencing the Role track. Page 8 of 28

9 AP OVERVIEW. WEEK 1 Overview of programme via Supervisor, including system access Sales video review System and local processes training F2F sales process Support systems webinar and link essentials Self study for CBT Sit CBT (TLN) Self study for CBT Sit CBT (TLN) Sales video review F2F sales process Induction programme conference call 1 Study/Sit CBT WEEK 2 I/O webinar 2 I/O case study (client review) I/O webinar 3 I/O case study I/O case study Product presentations Study/Sit CBT Trust toolkit Lifestyle toolkit/podcast Induction programme conference call 2 Product presentations WEEK 3 Product presentations Study/Sit CBT Quality of advice and record keeping Study/Sit CBT Quality of advice and record keeping F2F sales process Mortgage advice and record keeping Protection advice and record keeping Mortgage advice and record keeping Protection advice and record keeping Induction programme conference call 3 Mortgage advice and record keeping Protection advice and record keeping WEEK 4 Attend Residential selling event day 1 Attend Residential selling event day 2 Attend Residential selling event day 3 Attend Residential selling event day 4 Attend Residential selling event day 5 WEEK 5 Protection application Webinar Page 9 of 28

10 4. Commencing the Role Steps Step Action Required By Whom Event Name 1 Monthly 1:1s following the Supervisor MNA121COM1 expectations as detailed in Section 13 2 Observation to be carried out within 3 Supervisor MNOBSFORMNEW months, prior to 1 year, and upon leaving the Commencing track 3 Record of activity undertaken by Adviser/Supervisor UCMLOGAH adviser, discussed with the supervisor to check if any development areas exist 4 All MRoS letters checked until 3 Supervisor MNMROSCHK/MNROSLTF consecutive deemed as correct 5 All PSL letters checked until 3 Supervisor MNPSLCHK consecutive deemed as correct 6 Minimum of 7 file checks per annum Supervisor FILECHKMP 7 Knowledge and skills must be tested Advisor/Supervisor MNPAL regularly 8 Ensure relevant learning and tests are Supervisor MNACONTACT undertaken when requiring to add a licence. Checks on business written following granting of licence 9 Supervisor requests competence Supervisor/PoCC MNCAS status review by PoCC/APER 10 Close Commencing Track and open Continuing Track Supervisor MNCONT Introduction The purpose of this section is to highlight the live field activity that must be completed so Advisers can progress towards, and be assessed as Competent in their role. All activities in this section must be completed before Advisers can move into the Continuing the Role track. Commencing the Role process Advisers must spend a period of at least 3 months in this stage of the training programme under appropriate supervision. This will enable Supervisors to ensure Advisers consistently demonstrate the knowledge, skills, ethics and expertise necessary to act in the role of Adviser. The period is designed to allow a build up of Key Performance Indicators (KPI s) and the collation of other evidence to support the confirmation of competence (when granted). The maximum period that Advisers can remain in this track is 18 months. If Advisers have not demonstrated sufficient knowledge, skills, ethics and expertise necessary by this time, then there must be serious consideration given to terminating their contract. If there are any extenuating circumstances in relation to this that may require consideration for concession, please contact the Business Standards Team. Appropriate Supervision During this track it s the Supervisors responsibility to ensure that their Adviser develops their skills and knowledge, uses the appropriate sales processes effectively, follows the L&G Network advice standards, and ensures the advice given is appropriate to the customer s needs. Any issues raised in respect of sales activity in this period will be documented against both the Adviser and their Supervisor. Sales Quality Reviews Sales Quality Review Team (SQRT) randomly check Advisers submitted business even whilst they are in Commencing the Role. Although Supervisors will be responsible for ensuring that business conducted by Page 10 of 28

11 the Adviser is compliant, SQRT are required to randomly sample all business in order to maintain standards of quality and mitigate the risk of future complaints. Steps to be completed by Supervisors during this stage: Step 1: Monthly 1:1 s Supervisors must complete formal 1:1 s on a monthly basis during this phase of development. They can be conducted either face to face or using remote meeting software. Within any three month period it s expected that at least one face to face meeting is completed. Supervisors must pay particular attention to unaccompanied activity and the progression towards competence, as these are specific to this stage of an Advisers progress. All 1:1 s must be documented fully and recorded on the appropriate event on CSmart. Please see section 11 for further information on Formal 1:1 meetings. Step 2: Observations To ensure that Advisers are progressing towards competency, Supervisors must observe Advisers completing a live competent observation of the full sales process within 3 months of entering this stage. In addition, a further observation must take place prior to deciding whether Advisers are ready to move into the Continuing the Role stage. An annual observation must also take place, should they remain in the track for more than 12 months. At least one live observation of the full Lifetime Mortgage sales process (if applicable) must be observed every 12 months. For clarity, if an adviser is in commencing the role for 16 months, they will require 3 observations. Please see Section 10 for further information on Observations. (MNOBSFMNEW AUTO for recurring obs, Manual for all others) Step 3: Unaccompanied activity debrief Advisers must record all unaccompanied activity on a contact note for discussion with Supervisors at regular 1:1 s. Supervisors must discuss and log all activity undertaken in order to debrief unaccompanied activity including: Completing unaccompanied activity logs and the debrief document on Advisers CSmart record Ensuring that Records of Suitability are completed according to the standards and that advice given is suitable (if applicable) Ensuring that PSL s are completed according to the standards and that advice given is suitable (if applicable) Checking for trends in cancelling and/or replacing existing policies Investigating where problems have been encountered, and arranging coaching as necessary, and logging on Advisers development plan Discussing what went well or not so well to assess journey to competence, or establish development needs What additional activity is required (e.g. mentoring, file checks or further observations) (UCMLOGAH - AUTO) Step 4: Mortgage Record of Suitability letter checks Supervisors must check all Mortgage Record of Suitability letters in conjunction with the POS record (e.g. file check), prior to issue to the customer, until there have been 3 consecutive satisfactory completions. All checks that take place must be logged on CSmart on the MRoS checklist event. Such checks must be undertaken as well as the file check requirements detailed in step 6. Where Advisers are also licensed in Lifetime Mortgages all POS sales records for these sales must be checked until 3 consecutive satisfactory completions of Records of Suitability. Page 11 of 28

12 Supervisors must: Review, along with Advisers, any Records of Suitability you have rejected and highlight any areas where the requirements (as described in the suitability checklist) are not met or the customer outcome is not appropriate Agree action that needs to be taken by new Advisers before it s re-submitted to the Supervisor Agree development activity that needs to be taken to prevent the same issues arising in the future and log in Advisers development plans. (MNMROSCHK Standard Mortgages- Auto) and (MNROSLFT Lifetime Mortgages Auto) Step 5: Protection Suitability letter checks. Supervisors must check all Protection Suitability letters, in conjunction with the POS record (e.g. file check), prior to issue to the customer, until there have been 3 consecutive satisfactory completions. All checks that take place must be logged on Advisers CSmart track on the PSL checklist event. Such checks must be undertaken as well as the file check requirements detailed in step 6. Supervisors must: Review, along with Advisers, any Protection Suitability Letters you have rejected and highlight any areas where the requirements as described in the suitability checklist are not met or where the customer outcome is not considered appropriate Agree action that needs to be taken by Advisers before re-submission to the Supervisor Agree development activity that needs to be taken to prevent the same issues arising in the future and log in Advisers development plans (MNPSLCHK - Auto) Step 6: File checks Supervisors must check a minimum of 7 cases per annum. These must be conducted as follows: 1 case per quarter (4 per annum) Plus, at any point in the year, a further 3 consecutive cases must be checked to determine whether any poor practices or selling trends are noticeable. However, if the production of the Adviser exceeds 150 cases over a rolling 12 month period, you must check an additional 3 trend analysis checks (e.g. total cases checked = 10) Where the Quality of Advice rate of the Adviser is published at less than 50%, additional file checks will be expected to be completed by the Supervisor in order to establish the root causes of the issue. File checks must be: Full case reviews (i.e. full assessment of the record and the sale, and with mortgages and protection for the same customer(s) classed as one sale) Across the full range of products and licences used by the Adviser An assessment of the quality of record keeping and the advice given Comprehensive case checklists are available from the AR Centre here These checklists must be scanned and attached to the summary of results in the event FILECHKMP in CSmart. Outcomes must be discussed at 1:1 meetings and any actions arising must be fully documented in both the 1:1 document and development plans as necessary. (FILECHKMP - Manual) Step 7: Maintenance of Knowledge and Skills Supervisors must ensure that Advisers complete the Personal Activity Log with all relevant learning and activities including product and compliance updates prior to each 1:1. Continuing Professional Development should be measurable as well as relevant, and consider learning outcomes. Page 12 of 28

13 As part of the monthly 1:1 process Supervisors need to: Debrief all entries and test Advisers knowledge of these updates Highlight and log any development areas Ensure there s a balance of knowledge and skills Validate the activity documented on the Personal Activity Log is accurate Where learning activity documented is minimal, Supervisors must remind Advisers of their duty under CPD and log in 1:1 as necessary Team events on PALs may be of a templated nature, provided that individual content is added to this, but the content of all entries must be tested and validated by Supervisors. (MNPAL Auto) Step 8: Additional Licences Should any additional licences be required, Advisers must complete all of the relevant stages from Initial Training and Commencing the Role for that licence, eg. Relevant study and product tests, Role play and/or observation of the recommendation and presentation part of the sales process, check written business for content, accuracy and outcome, and check MRoS/PSL s (depending on the licence added) before issue to the client until 3 consecutive checks are correct. Step 9: Competence Status sign-off Once all requirements in this stage have been successfully completed, and Supervisors are satisfied Advisers are displaying the desired behaviours associated with competency, and maintaining their level of performance in all areas, they will need to ensure that CSmart records are fully completed and up to date. If the CSmart record successfully demonstrates that the requirements detailed within this section have been successfully completed and that the monitoring and assessment to date doesn t indicate that any further development is required, the relevant section of the Competence Status request event must be completed and signed off by the Supervisor. Notification should be then sent to the firms PoCC who needs to review the CSmart record and must countersign the Competence request only if all criteria has been satisfied and they are satisfied that competence has been consistently demonstrated. Where the Supervisor and PoCC are the same person, the Approved Person in the firms should validate the competence request. In the event the Supervisor and PoCC is also the Approved Person you should refer to the Business Standards Team for approval. (MNCAS Auto) Step 10: CSmart track completion Supervisors must ensure that all relevant events in CSmart are completed and signed off. Once competence has been confirmed by the PoCC, Supervisors must ensure they fully complete and close the Commencing the Role track prior to assigning the Continuing the Role track in CSmart. (Close MNCOMM and assign MNCONT Manual) Page 13 of 28

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