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  #31  
Old 01-13-2010, 02:36 PM
actuary21c actuary21c is offline
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Default Official response = no answers will be provided

I received the following response today (13 Jan 2010) to my letter of 24 Dec 2009 (see this post) from the Secretary to the Joint Councils

Quote:
Dear Patrick

With regard to your email of 24 December, of which I formally acknowledge receipt, I am writing to advise you that the Presidents will not be entering into further correspondence on this.

Regards

[name of Secretary to Joint Councils]
This raises the following questions:
  1. Are the Presidents unable to answer the questions put to them, or unwilling?
  2. What about Council members? Do they feel the same way or do they feel gagged by some secret rule (there seems to be nothing in the Institute or Faculty Charters, Rules or Byelaws about this)? Shouldn't Council be acting more like a Parliament (with different Council members representing different members' views) than a Cabinet? If there is a gagging rule, shouldn't it be disclosed to members to give them a right to approve or reject it?
If there are good answers to the questions I posed in my letter of 24 December, wouldn't the simplest thing have been for the Presidents to provide them?

They can still do so in this forum, and I urge them (or other Council members) to do so.
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  #32  
Old 01-13-2010, 04:07 PM
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Well, at least they told you they weren't going to respond.

So I guess that's the positive side.
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  #33  
Old 01-13-2010, 06:53 PM
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The arrogance of our "leaders" knows no bounds, apparently. Disgraceful.

Bruce
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  #34  
Old 01-13-2010, 10:18 PM
ishamael ishamael is offline
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Jeezz.... if one day, the ABCD were to haul me up for any potential disciplinary action (touch wood!), can I write the following reply:

Dear ABCD
With regard to your letter of [insert date], of which I formally acknowledge receipt, I am writing to advise you that the I will not be entering into further correspondence on this.

Regards

[yours truly]

and consider the case closed?
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  #35  
Old 02-14-2010, 01:15 PM
actuary21c actuary21c is offline
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Question Does the official communications policy comply with The Actuaries' Code?

My previous posts in this thread will indicate that I retain serious misgivings about whether the sort of policy that Institute and Faculty Council have recently admitted to now be following (and may have been following before - remember the Presidents refused to answer my question as to when the policy was first adopted) is ethical enough for a profession like ours.

Perhaps my doubts could have been dispelled by answers to the further questions that I posed, but as members can see, the current leadership have point-blank refused to answer what I believe to be not only perfectly reasonable questions, but also important ones from a professional point of view.

I don't know what the requirements for US actuaries are, but my understanding is that UK actuaries have a duty under our professionalism requirements to question any actions by fellow actuaries (or our clients or our employers) that appear to be unlawful, unethical or improper.
Now I very much doubt whether the Institute/Faculty communications policy is unlawful, but I do have serious doubts as to whether it is ethical or proper. In particular, communications from actuaries have to be clear, accurate and not misleading, and to contain sufficient information to enable its subject matter to be put into the proper context. Actuaries also have to be sure that the communication and method of communication is appropriate to the intended audience (here both fellow actuaries and the wider public) and has regard to the significance of the communication to its intended audience.

Under the dual balanced/promote policy, how can communications from Councils be clear without an explicit health warning as to which mode the communication is made in? Such a health warning seems essential to put the communication into its proper context. (Otherwise, it is a bit like not knowing, when an investment professional advises you to buy a particular stock, whether he or she owns that stock [and hence has an interest in selling it to you if he/she thinks it might be overvalued], or not. That makes quite a difference!).

Further, when a communication is made in "promote" mode (is this not a euphemism for "one-sided"?), how can this be clear, accurate and not misleading? Doesn't the very one-sidedness by definition imply that the information being supplied is incomplete, and therefore fails to provide sufficient information to enable recipients to put the communication into its proper context?

I'm thinking aloud here, and will return to this subject when my other commitments allow, but if anyone can reassure me that my concerns about professionalism are misplaced, please do so! (In particular, I urge the UK leadership once more to respond to the legitimate, important questions I have asked).

Here is a copy of the current Actuaries' Code, which all Institute and Faculty members have been subject to since 1 Oct 2009: (http://www.actuaries.org.uk/the_prof...actuaries_code - I have highlighted what I consider to be the most relevant parts in bold)

Quote:
1. Integrity:
Members will act honestly and with the highest standards of integrity.
1.1 Members will show respect for others in the way they conduct themselves in their professional lives.
1.2 Members will respect confidentiality unless disclosure is permitted by law and justified in the public interest.
1.3 Members will be honest, open and truthful in promoting their business services.


2. Competence and care:
Members will perform their professional duties competently and with care.

2.1 Members will consider who their advice and/or services are being provided to (their clients). In many cases this may be their employer.
2.2 Members will not act unless:
(a) they have an appropriate level of relevant knowledge and skill; or
(b) they are acting on the advice of an individual who has the appropriate level of relevant knowledge and skill and all interested parties are aware that this is the case; or
(c) they are acting under the direct supervision of another member who is taking professional responsibility for that work.
2.3 Members will consider whether advice from other professions and other specialists is necessary to assure the relevance and quality of their work.
2.4 Members will take care that the advice or services they deliver are appropriate to the instructions and needs of the client, including the legal and other rules which may govern the matter, having due regard to others, such as policyholders of an insurer, members of a pension scheme, or any analogous persons whose interests are affected by the work of the member.
2.5 Members will agree with the client the scope and nature of any appointment or instruction.
2.6 Members will agree with the client the basis for their remuneration before commencing an appointment or instruction and before any material change in the scope of an existing appointment or instruction.
2.7 Members will keep their competence up to date.


3. Impartiality:
Members will not allow bias, conflict of interest, or the undue influence of others to override their professional judgement.
3.1 Members will ensure that their ability to provide objective advice to their clients is not, and cannot reasonably be seen to be, compromised.
3.2 A conflict of interests arises if a memberís duty to act in the best interests of any client conflicts with:
(a) the memberís own interests, or
(b) the interests of the member's firm, or
(c) the interests of other clients.
3.3 Members will take reasonable steps to ensure that they are aware of any relevant interest, including income, of their firm.
3.4 Members will disqualify themselves from acting where there is a conflict of interest that cannot be reconciled.
3.5 Members will document the steps they have taken to reconcile a conflict and will agree those steps with their clients if they would be ineffective without agreement.
3.6 Before accepting any assignment, members will consider carefully whether they should consult with any member who previously held such a position with the client, to establish whether there might be any professional reason why the assignment should be declined.


4. Compliance:
Members will comply with all relevant legal, regulatory and professional requirements, take reasonable steps to ensure they are not placed in a position where they are unable to comply, and will challenge non-compliance by others.
4.1 Members will speak up to their clients or to their employers, or both, if they believe, or reasonably ought to believe, that a course of action is unlawful, unethical or improper.
4.2 Members will fulfil any obligations to report information to relevant regulatory authorities.
4.3 Where there is legal protection available, members will report behaviour that they have reasonable cause to believe is unlawful, unethical or improper, to regulators or other relevant authorities. In the UK these protections include: the Public Interest Disclosure Act 1998, sections 342 and 343 of the Financial Services and Markets Act 2000 and section 70 of the Pensions Act 2004.
4.4 Members will promptly report any matter which appears to constitute misconduct or a material breach of any relevant legal, regulatory or professional requirements including Actuarial Profession Standards and Technical Actuarial Standards issued by the Board for Actuarial Standards, for consideration under the relevant disciplinary schemes. To the extent that the consent of a third party is required for this purpose in order to disclose information, members must take all reasonable steps to obtain such consent.


5. Open Communication:
Members will communicate effectively and meet all applicable reporting standards.
5.1 Members will ensure that their communication, whether written or oral, is clear (indicating how any further explanation can be obtained) and timely, and that their method of communication is appropriate, having regard to:
(a) the intended audience;
(b) the purpose of communication;
(c) the significance of the communication to its intended audience; and
(d) the capacity in which the member is acting.
5.2 Members will take such steps as are sufficient and available to them to ensure that any communication with which they are associated is accurate and not misleading, and contains sufficient information to enable its subject matter to be put in proper context.
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  #36  
Old 02-15-2010, 12:37 PM
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The U.K. code, like the U.S. code, seems to be written from the perspective of services provided to employers and clients. I'm not sure that volunteer service to the profession is ordinarily "actuarial practice" at all. It's a good question.

Bruce
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  #37  
Old 02-15-2010, 04:06 PM
actuary21c actuary21c is offline
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Default The same high standards must surely apply when actuaries communicate with one another

(Caveat: once again, I am not a lawyer, but it seems to me that documents as important as codes of professional conduct should be written in such a manner that the most natural interpretation applies to any wordings therein - if not, they should be re-written as soon as possible!).

Quote:
Originally Posted by bdschobel View Post
The U.K. code, like the U.S. code, seems to be written from the perspective of services provided to employers and clients. I'm not sure that volunteer service to the profession is ordinarily "actuarial practice" at all. It's a good question.

Bruce
Actually, the (UK, more precisely Institute and Faculty since we have many members outside the UK) Actuaries' Code currently makes no distinction between communications provided to employers and clients and any other communications, so I think it is much harder to argue that it doesn't apply. With regard to the US code (which does distinguish, and apparently restricts itself to communications to employers and clients), I agree with what Tom B. has written here (about the US Code):

Quote:
Originally Posted by tbakos View Post
It seems incredible to me that any actuary would argue that the Code does not (or should not) apply when dealing with each other on professional matters.
Whilst of course it might be going too far to argue that the Institute/Faculty Code's wide framing means that Institute/Faculty members have to be mindful of the code even when making communications in their personal life, as individuals (e.g. in letters to their grandma or tennis coach etc.), in my opinion it must apply to any communications they make to fellow actuaries, as one actuary to another and relating to matters pertaining to the profession, including the running of their professional body.

Note that the Scope of the Actuaries' Code is stated as:

Quote:
The Code applies at all times to membersí conduct in their work as actuaries, but will also be taken into consideration where their conduct in other contexts could reasonably be considered to reflect on the profession.
so the scope does imply that even personal communications will result in a violation of the Code if they are likely to reflect badly on the profession. [Aside: of course if a whistleblower draws attention to poor behaviour by other actuaries, then that would be another matter: it would be the poor behaviour of the actuaries which reflected badly on the profession, not the exposure by the whistleblower. If the whistleblower had remained silent, this would probably not only in itself constitute a violation of the code, but would probably reflect even worse on the profession when the poor behaviour eventually came to light].

Returning to what Tom Bakos said above, I agree because if for example a US actuary did argue that the Code of Conduct didn't apply to him/her with regard to communications he/she sent to other actuaries about the operation of the professional body, then although at the moment such a statement might be strictly true according to the wording of the Code of Conduct, its use as an argument would look very much (to this member of the public [since I am not a US actuary], and hence probably to other members of the public, and I suspect to other US actuaries) like an admission that the said actuary had not followed the high standards that would have been required under the Code.

It would also do the reputation of actuaries no good if the public became aware that actuarial leaders thought it right for actuaries to relax their high standards of honesty, integrity and clarity of communications when communicating with one another!
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  #38  
Old 02-16-2010, 07:03 PM
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I want to pursue the very important issue of whether the "neutral/promote" dual communications policy is in keeping with the Actuaries' Code or not, so I didn't want this thread to get diverted with regard to a puzzle (given this policy) with regard to statements made by UK leaders during the failed 2009 merger campaign. Instead, please see this new thread for that puzzle.
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a21c is one of the better posters on the AO. That's not saying he's good.

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  #39  
Old 12-27-2018, 01:32 AM
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Quote:
Originally Posted by GargoyleWaiting View Post
...going by this forum, only one person's talking, and no-one's listening...
This summarises GargoyleWaiting's attitude towards anyone who comes onto this forum with criticisms or uncomfortable truths about IFoA. Please declare what is already know elsewhere of why you are conducting yourself in this toeing the party line manner? The OP should be congratulated not mocked.
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  #40  
Old 12-27-2018, 06:36 AM
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Quote:
Originally Posted by bdschobel View Post
The arrogance of our "leaders" knows no bounds, apparently. Disgraceful.

Bruce
Indeed but remember they are advised usually by lawyers on what to say. This does not excuse the conduct but it's about time actuaries realised the people running our professional bodies don't solely consist of well-meaning actuaries who care about anything a member has to say. The sadness is that members pay to keep all these lawyers, managers etc. in jobs. In many ways I think actuaries have lost control over their own professional bodies. Many of the complaints being put to the professional bodies I think most actuaries would agree with but the door is slammed in people's face at a very early stage. There are even dubious individuals appearing on forums who appear tasked to spread misinformation and stop complaints germinating and becoming movements for change; in real life members don't find people who act in that way as they have genuine sympathy with other members and the standards actuaries are expected to show, hence don't find low standards from the qual body acceptable. I've increasingly seen more actuaires complain publicly on forums and social media having become really fed up of being fobbed off time after time after raising genuine complaints that should be properly addressed. Instead they find their intelligence being insulted by a professional body in denial then a declaration of matter closed.

Last edited by almost_there; 12-27-2018 at 06:42 AM..
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