Professionalism Counts is a column in Actuarial Update, the Academy's monthly newsletter.
I JUST BECAME AN ASSOCIATE. WHEN DO I HAVE TO START EARNING CE?
First, congratulations on your achievement! Your years of study and hard work have paid off and you are now a credentialed actuary.
Having just earned your newly minted credential, you may feel that you are up to date, but continuing education (CE) requirements apply as soon as you join one of the five U.S.-based actuarial organizations: the Academy, the American Society of Enrolled Actuaries, the Casualty Actuarial Society, the Conference of Consulting Actuaries, and the Society of Actuaries.
This is because each of these organizations has adopted the Code of Professional Conduct, which requires you to “observe applicable qualification standards … for the jurisdictions in which [you render] Actuarial Services.” For actuarial services rendered in the U.S., the applicable qualification standards are the Qualification Standards for Actuaries Issuing Statements of Actuarial Opinions in the United States (USQS), issued by the Academy.
The first thing to be aware of is that the USQS defines statements of actuarial opinion (SAOs) very broadly:
An opinion expressed by an actuary who is subject to the Code of Professional Conduct by virtue of membership in a U.S.-based actuarial organization, where such opinion is expressed in the course of performing Actuarial Services and intended by that actuary to be relied upon by the person or organization to which the opinion is addressed.
The Code defines Actuarial Services as “professional services provided to a Principal [client or employer] by an individual acting in the capacity of an actuary. Such services include the rendering of advice, recommendations, findings, or opinions based upon actuarial considerations.”
From these definitions we can see that, if you are working as an actuary in the U.S., you are likely issuing SAOs and therefore must meet the requirements of the USQS, including the CE requirements, before issuing an SAO. The good news is that the USQS permits you to count hours spent meeting the basic education requirement toward the CE requirements, as long as you earned them before issuing the SAO. The Committee on Qualifications (COQ) gives an example in FAQs on the USQS (FAQ #34):
An actuary becomes an Associate of the Society of Actuaries (ASA) in July 2022. The actuary meets the basic education and experience requirements to issue an SAO in October 2022 and wants to ensure compliance with the CE requirement as well.
When calculating CE hours, the actuary is allowed to count all the hours earned in 2021, and in 2022 up until the date of the October 2022 opinion, in determining the actuary’s qualification to issue that opinion. This time can be earned before or after qualification, but not before 2021. As per section 2.2.6, time spent studying … for relevant actuarial exams can also be included in this count as “other activities.” Time that this ASA spends in September 2022 studying for a Fellowship exam can also be counted, even if the studying did not result in a passing grade (section 2.2.6).
However, any 2022 CE time that the actuary uses to qualify to issue 2022 opinions cannot also be used for 2023 opinions. The actuary will need to earn another 30 hours of CE—normally during the remainder of 2022—to issue opinions in 2023.
FAQ #40 states that you may “count all of the actual time spent studying for actuarial exams toward … annual CE requirements … typically under the ‘other activities’ component.” Please note, however, that you may roll over excess CE hours for only one year and must earn at least 6 hours from “organized activities,” 3 hours on professionalism topics, and 1 hour on bias topics annually, for a total of 30 CE hours. For example, if you earned 100 CE hours from studying in 2021, you may count that toward the 24 hours of “other activities” CE for 2022 and roll over the excess toward the required 24 hours of “other activities” CE for 2023. (In both years, you still need 6 hours of “organized activity” CE.) You would not, however, be able to roll any of the hours earned in 2021 over into CE for 2024.
If you have questions not answered by the USQS or the FAQs, you may submit a question to the COQ.