Update:
The FSAs original question in the consultation paper was "Do you agree with our proposals to introduce an overall time limit of thirty months, within which individuals must be qualified?".
This was an interesting question for the FSA to pose and I found it difficult to give a "yes/no" answer when writing a response for Resolve Compliance Ltd.
Firms should, as a matter of course within their own T&C framework, consider setting an overall expected timescale for an individual’s route to competency, including but not limited to the passing of appropriate exams, taking into account any risk associated with an individual continuing under supervision. That said, I also believe there needs to be an element of flexibility to cater for individual circumstances.
For those interested, I attach a copy of the full response to CP 10/12 submitted by Resolve Compliance Ltd.