Don’t take a DOFA report at face value in the recruitment process: Two recent representative appointments have highlighted the importance of taking all the facts into account when appointing a representative. This includes the CV and supporting documentation such as evidence of qualifications.
In the first case, the CV noted the representative to have a degree. The DOFA report confirmed their prior appointment as a representative at a number of FSPs. When joining the latest FSP all seemed well but the standard is that full supporting documentation has to be supplied before being added to the KI/Rep register.
That’s when the problem came to light. The mentioned degree turned out not to be a full degree but only one part of the degree – the full degree had not been obtained. The result should have been that they should never have remained on a licence past the original qualification deadline.
Currently this person sits employed but unable to conduct the job they were employed for, and this situation will remain in place until they complete a qualification or apply for an exemption/ date extension from the FSCA.
The second case is “worse” in that the CV of the prospective representative disclosed that they did not have credits or a qualification, yet they had been a representative since 2005.
Between then and now, this person moved jobs 3 times, the latest being up until December 2023, where they had been added but with no credits/qualifications, although they had been placed under supervision at one stage suggesting that one of the employers realised there was a problem.
There was also employment with one FSP where the representative worked for 12 months which is not recorded on the DOFA report, but the full extent of their role, based on their CV, is unknown.
We suspect the problem was, at least at the last employer, reliance on the DOFA and requests for supporting documentation not being followed through.
And to complicate the picture, the DOFA dates and CV dates don’t line up and should have been questioned.
Now the person sits in limbo not being able to be appointed as a representative, as a qualification or exemption is needed. Interestingly enough, the person has RE1 & RE5.
The purpose of relaying these issues to you is to raise the awareness of the importance of a comprehensive recruitment process which seeks to verify supplied information and not rely on DOFAs and CVs alone. We have also fallen into this trap where the lack of all the paperwork gets lost in time.
We do appreciate that employment opportunities can present themselves at short notice, preventing a thorough check. In these situations, any offer of employment should ideally be made subject to the verification process.