The Spanish Banking Association firmly supports the promotion of financial training in the firm conviction that it is a fundamental pillar of an efficient financial system.
Employee training has always been a primary concern for the Association’s member banks, whose training departments have been responsible for implementing continuous training programs in all areas where services are provided to clients, and employees have been obligated to comply with them.
In the area of financial product distribution, this traditional concern and commitment of institutions acquired a more rigid format when the CNMV developed the training obligation contained in the MiFID II directive, that is, the second European directive on markets in financial instruments.
Thus, MiFID II establishes the obligation to ensure and demonstrate to the supervisor that persons providing financial information or advice to clients possess the knowledge and competencies necessary to perform such function.
In implementation of this obligation, the CNMV published Technical Guide 4/2017 for the evaluation of the knowledge and competencies of personnel who inform and advise, whose content was favorably received by the sector given the flexibility it demonstrated. However, it is fair to note that the price of this flexibility was an excessive burden on regulatory compliance units, which had to assume functions more typical of training departments.
The most significant innovation of the Guide, the fact that each employee had to have “accredited” training, required organizing the examination of thousands of employees in record time, which resulted in a considerable organizational effort for institutions, as well as for employees who had to face the requirement of an examination after many years of experience.
The most positive consequence of this effort by institutions and employees is that, while training was already in the DNA of institutions, these regulated processes provide the banking sector’s training with undeniable transparency and improved effectiveness by harmonizing its content through the supervisor.
Having successfully completed the first wave that involved “certifying” the knowledge of thousands of employees, institutions maintain their continuous training programs that reach both new professionals and those with greater experience. This continuous training remains necessary, not only because the CNMV requires it, but also due to the need to respond to changes that continuously occur in products and markets.
Spanish banking institutions will continue to invest in the training of their employees in their firm commitment to provide increasingly better service to their clients and to achieve, in the area of investment product distribution, the highest possible levels of investor protection.
Patricia Rodríguez, Financial Markets Advisor at AEB
