In a member vote in autumn 2022, more than 85% of votes cast were in favour of a revision of the IFoA’s Disciplinary Scheme.
Total participation in that vote was around 9% of the voting membership. That kind of participation rate isn’t bad when you consider that this concerned a Disciplinary Scheme that deals with an average of 17 allegations each year, involving only around 0.05% of the membership.
But it is important that the whole membership recognise the significance of the Disciplinary Scheme and understand the revisions that are coming into effect on 1 August 2023.
I am a part-time Crown Court Judge after a long career as a barrister in private practice. I have held many roles dealing directly with discipline and regulatory issues, including as a Commissioner at the (then) Independent Police Complaints Commission, Complaints Commissioner of the Cayman Islands, and was the first Service Complaints Ombudsman for the UK Armed Forces.
I became involved with IFoA regulation in April 2022. I did so because the actuarial profession safeguards a significant part of the global economy and so upholding actuarial standards really matters. The Disciplinary Scheme is the ultimate guarantor of those standards.
I joined the Disciplinary Committee just after the review of the Disciplinary and Capacity for Membership Schemes had been completed, but before the revised Disciplinary Scheme had gone forward to that member vote.
It has been an exciting time, because what we have achieved is a Disciplinary Scheme that is modern, proportionate, efficient and fair.
The duty to regulate the actuarial profession in the public interest stems from the IFoA’s Royal Charter and is central to its identity.
IFoA members are held to very high standards technically, professionally and ethically. But in a population of tens of thousands of professionals, things are sometimes going to go wrong.
The IFoA has to have an independent Disciplinary Scheme to act when standards are not met. This is the basis on which the public trust in the profession is founded and the basis of the high professional value actuaries enjoy.
The revisions coming into effect smooth the process for those few members who will face an allegation over the coming years (especially those against whom allegations have no substance), as well as for those making a complaint. And, in doing so, it means that the IFoA is better protecting the interests of the whole membership and better protecting the public interest.
The new scheme allows for greater flexibility in how conduct issues are addressed, without compromising the integrity of the process.
The Disciplinary Committee monitors the time taken to investigate allegations. Under the current process, a disproportionate amount of time can be spent on less serious cases. It is in the interest of all parties that such cases are dispatched more efficiently.
So, from August, complaints without substance can be dismissed quickly.
The revised Disciplinary Scheme also introduces Disciplinary Orders which are a quicker alternative for low-level, straightforward cases where misconduct is admitted at the outset.
These new processes should free up time and resource for the more serious cases that require fuller investigation and should lead to their timescales being reduced as well. This means that we’ll be delivering improved efficiency and better value for the membership.
The Disciplinary Committee will continue to monitor timescales to see whether the changes have had the desired effect.
A further key benefit of the revised Disciplinary Scheme is how much more user friendly it is. It has been drafted in plain English, rather than ‘legalese’. This will help both those making and those facing an allegation to understand the process.
Thank you for taking the time to read this and understand the importance of the changes coming into effect in August. If you wish to know more, you can find full details and documentation on our revised Disciplinary Scheme page.