The system for registering insolvency practitioners
This chapter examines the adequacy of procedures for registering and
deregistering a liquidator. The key concern is whether the registration process
is sufficiently rigorous to test for the probity and capacity of applicants and
whether registered practitioners have adequate checks on their conduct and
In this broad context, the chapter raises several issues and options,
broadening the recruiting base of insolvency practitioners
implementing an interview process (paragraph 7.15–7.20);
- a written examination (paragraphs 7.21–7.23);
- monitoring and checking practitioners' professional indemnity
insurance (paragraph 7.24–7.37);
implementing a licensing regime with a requirement for regular renewal;
- stratifying registration to match practitioners' skills and
experience with the appropriate jobs (paragraphs 7.49–7.51);
- a single registration body for personal and corporate insolvency
practitioners (paragraphs 7.52–7.53); and
- promoting ongoing professional education (paragraphs 7.54–7.57).
The registration process
Recall from chapter 3 that the Australian Securities and Investments
Commission (ASIC) determines an applicant to be 'a fit and proper person' if it
is satisfied as to their honesty, integrity, good reputation and personal
solvency. ASIC's submission noted that in making this assessment, it relies on:
- a letter of membership from a professional accounting body;
the applicant's experience with corporate insolvency, focusing on
length of experience and seniority;
- two referees attesting to currency and depth of liquidation
experience, competency, integrity and reputation (whether applicant is 'fit and
- proof of relevant qualifications;
- historical searches on the status of the applicant (i.e. whether
subject of any previous adverse decisions);
- a statement by the applicant, declaring that they are not:
- an insolvent under administration;
- convicted of a criminal offence;
- subject of disciplinary action by their professional body or the Australian
Taxation Office (ATO); and
disqualified from managing corporations under Part 2D.6.
Mr Stefan Dopking of ASIC told the committee that in terms of this
the team which undertakes this work does it quite thoroughly,
not only by looking at the paper but by making inquiries of our own of people
who know the industry quite well in each state and talking to those referees.
However, ASIC has noted that one of its current projects is to review
the registration process (Regulatory Guide 186) to see if it can strengthen the
'fit and proper' test. The Chairman of ASIC, Mr Tony D'Aloisio, told the
committee that once a liquidator is registered 'it is not that easy for ASIC to
deregister'. Further, he observed that in contrast to licensing, the
requirements of registration 'are not a high hurdle'.
The Insolvency Practitioners Association of Australia (IPAA) observed in
its submission that to be registered as a liquidator in Australia:
A person requires tertiary qualifications and significant
experience...Apart from a degree which includes three years of accounting and two
years of legal study, persons applying to be registered must have worked under
the supervision of a registered liquidator for a period of 5 years out of the
preceding 10. Many of the profession's current senior practitioners have over
30 years' experience, and have been successfully involved in the restructure
and orderly administration of many insolvent companies, always acting in the
interests of creditors and employees.
The IPAA also told the committee that it has specific training in its
Code of Professional Practice. Further, the new accounting standard, APS 330, adopts
a great majority of what is in the code.
Broadening the practitioner base
The committee has received evidence that current entry requirements for registering
as an insolvency practitioner are too narrow, and should be broadened. Mr Geoffrey
Slater, a barrister who has represented liquidators, described the insolvency
profession as a 'little club' of accountants with a vested interest in keeping
this arrangement. He told the committee:
Section 1282 of the Corporations Act sets out all the
qualifications that people must have...It says that you have to be an accountant
and ASIC decides whether that qualification is adequate or not according to
their opinion. On what basis do they decide that? If you turn to regulation
9.2.02, it sets out a series of universities and so on. What it essentially
does, however, is create a monopoly for accountants. Australia is the only
country that does this. In the United Kingdom anybody can sit an exam, including
solicitors, and become a liquidator. The same thing applies in the United
States. In Europe, you must be a solicitor before you can act as a liquidator.
Why is this so? The answer is because...what liquidators are really doing is not accounting
and not looking at ledger. Their real skills are commercial.
Mr Slater told the committee that the type of skills required to be an
insolvency practitioner are quasi-judicial skills, which accountants do not
have. In this context, he added:
The first recommendation I would make to this committee is
that the door should be thrown open, to open the field to anybody who wants to
sit the exam. This should be removed from ASIC and Australia should be brought
into harmony with the United States and England so that anybody who is
qualified or who has a law degree or an accounting degree with sufficient law
should be able to sit the exam.
Mr Slater identified the significant consequence of this exclusive
arrangement as the charging of 'monopoly rents'. He contrasted the salaries of
partners at private law firms with the earning capacity of partners at
insolvency firms. The latter, he claimed, are earning well over $4 million a
Other submitters to this inquiry have claimed that the insolvency
profession operates as a self-interested clique. Mr Ian Fong of Carlovers
Carwash, for example, told the committee:
I think the industry is quite small and it is dominated by a
small number of practitioners, accountants and lawyers who all help each other
make money. For example, when we took legal action to complain about Mr Ariff's
conduct his lawyers somehow managed to convince the court that this matter was
just a commercial dispute rather than one that involved fraud and criminality.
The lawyers put up all sorts of hurdles to stymie a bit. They managed to convince
the court to appoint a mediator. The mediator is someone that works within the insolvency
industry. They rely on the insolvency industry for work. They then go and get
an independent expert report from another insolvency practitioner. Again, all
of them rely on work from each other. How can you have independence?
ASIC noted in its supplementary submission that it is open to the
concept of broadening the base for insolvency professionals provided that
strong standards of conduct, experience and continuing professional development
It noted that the eligibility criteria was broadened in the 2007 Amendments
with the repeal of section 1282(a)(1) relating to membership of an accounting
Mr Slater claimed that this reform was designed to prevent solicitors
from becoming liquidators. He noted that the Institute of Chartered Accountants
Australia (ICAA) allowed solicitors to join, and the ICAA was listed in the
Corporations regulations as being one of the qualifications for becoming a
liquidator. Mr Slater thereby reasoned that the repeal of section 1282(1)(a)
prevented solicitors from entering the insolvency profession.
The committee notes that there is, perhaps, some tension between demands
to increase competition in the market for insolvency professionals by
broadening eligibility criteria and improving standards. Some witnesses argued
that rather than broadening the qualifications criteria, it should be
tightened. One option in this regard would be to require all practitioners to
hold a Masters of Business Administration (MBA). As Mr Bill Doherty told the
These people are basically accountants with no specialist
skills. I suppose that they have worked for another group of insolvency
practitioners for a while and I suppose they have done a couple of corporate
law units in their degree, but how can somebody qualified to that degree then
take total control of such a variety of enterprises, in Ariff's case
nightclubs, earthmoving companies, metal finishing companies. They simply do
not have the expertise. But, yes, certainly tighten up the entry. They should
at least have an MBA. I would think it would probably be more appropriate if
they were legally qualified.
An interview process
ASIC identified an interview process as one of the issues it is
currently considering as part of its planned re-write of Regulatory Guide 186.
Mr D'Aloisio explained that an interview process would be supplementary to the
existing background checks:
An interview may assist. We will have a look at it, but
really at the end of the day it is the substantive qualifications that underpin
it. So an interview may give you a feeling as to whether a person is being
straight with you, but the checks you do in the background with the accounting
bodies—the experience, the referees and the declarations that are made to
you—are the substance of any application and we do look at that very
ASIC's supplementary submission noted that the Commission will consult
on how an interview process could be implemented. It considered the key
questions to be whether the interview is conducted by a panel of interviewers
and if so, who should be represented on the panel and how would the panel be
The IPAA supports an interview process for prospective practitioners. It
argued in its submission that an interview process may be important to
identifying those 'with an appropriate and informed approach to the practice of
The IPAA highlighted the Insolvency and Trustee Service Australia's
(ITSA) requirement for applicant Bankruptcy Trustee practitioners to attend an
interview conducted by a three person panel. The interview panel comprises a delegate
of the Inspector-General in Bankruptcy, an APS employee (usually from
Attorney-General's Department) and an experienced registered trustee nominated
by the IPA.
Mr Jeff Hanley of ITSA told the committee that the interview consists of 20
questions which are asked to each applicant.
The ICAA also supported an interview process to register insolvency practitioners.
As it observed in its submission:
We consider that including an interview as part of the
registration process for liquidators would strengthen it. An interview would require
the applicant to respond to a range of practical questions, so that they can demonstrate
they have the necessary understanding of the legislation deal with the varying
issues that may arise.
Dr Vivienne Brand of the University of Adelaide expressed some doubt
about the initial interview process but supported ITSA's model of frequent face
to face interviews of registered practitioners. As she explained to the
I do not know that I am convinced by the initial interview
idea. I think that people who do not have the level of competence they need
would probably be picked up by checking the paperwork. The people who had
genuinely fraudulent intentions would probably be quite impressive at
interview, so I am not sure that that is where you would pick it up. I like
that ITSA has a look at people every year, face-to-face. I think that they
would then have ongoing exposure to the person and that would probably be
helpful. I think there needs to be ongoing checking.
A written examination
This inquiry has received some evidence suggesting that, either in place
of or as a complement to an interview, there should be a written examination to
Associate Professor David Brown told the committee that ITSA currently
conducts both an interview and a written examination to screen applicants. He
explained that if applicants do not come up to scratch in the interview, they
have to sit an exam.
Mr Mark Robinson of the IPAA flagged the possibility of an exam as a secondary
screening process to register corporate insolvency practitioners:
Looking to improve the review of whether somebody is a fit
and proper person would also be by way of interview and, if somebody does not
present well at an interview, it might go further, even to a written exam, which
is the process through which ITSA considers the fitness of a person to be a
registered trustee in bankruptcy.
Mr Geoffrey Slater is a strong proponent of a written examination as
part of the insolvency registration process. Specifically, he argued that the
exam must be:
...a closed-book exam as distinct to an open-book exam, so that
people can prove that they have a fundamental grasp of equitable principles and
company law—not just parroting neat little answers that they have cribbed from
one of those nutshell books but actually demonstrating to an examiner that they
truly understand the underlying concepts.
Professional Indemnity Insurance
Since July 2008, a registered liquidator is required to maintain
adequate and appropriate professional indemnity (PI) insurance and fidelity
insurance to cover for claims that may be made against him or her. This
requirement was introduced under new section 1284 of the Corporations Act.
The policy purpose of the insurance requirements is to ensure that funds
are available to compensate creditors and other claimants for loss suffered as
a result of the inadequate or improper performance of duties by a registered
liquidator or their staff in connection with externally administered companies.
If a practitioner has not paid the insurance premium or the cover has lapsed or
been cancelled, creditors will not have recourse to that PI cover. This was the
case with Mr Ariff, whose policy lapsed prior to various insurance claims from
ASIC has identified its administration of section 1284 of the Corporations
Act 2001 as one of its key responsibilities in the insolvency area. It has
published a Regulatory Guide for stakeholders to explain how it will
administer the insurance requirements for registered liquidators under section 1284.
The Guide states:
We may undertake targeted or random surveillance to ensure
that registered liquidators or their firms comply with the insurance
requirements. Registered liquidators will also have to confirm each year on
Form 908 Annual statement by a liquidator that their insurance cover meets the
ASIC's Chairman, Mr Tony D'Aloisio, also told the committee that it is
conducting ongoing work to assess how the regime is operating and how to
improve lapses of PI insurance.
In its submission, ASIC noted that by December 2010, it will have:
...requested practitioners to provide confirmation of relevant insurance
policies to test compliance by practitioners with the new provisions and ASIC's
regulatory guide. In instances of non-compliance ASIC will proceed to cancel
registration under s1290A.
Criticism of ASIC's monitoring of professional
The committee has received strong views that the current system for
monitoring practitioners' PI insurance cover is inadequate and must be
strengthened. Mr Geoff Slater, a barrister, gave the following critique:
There is a section that says that they have to have
insurance. But guess what the problem is: nobody actually checks to see whether
they have insurance. And if they do not have insurance, guess what—the section
does not lay down a penalty. If I drive a car, and I do not have a green slip,
I get fined and I get into big trouble—but, more to the point, under the RTA in
New South Wales my registration and my insurance march in lock step. We have a
situation with ASIC where there is this enormous risk transfer. They can take
on big cases with no insurance and nobody is looking at it. If I wanted to say
to a liquidator, 'Have you got current insurance? Provide proof to me', and
they are an official liquidator appointed by the court, they do not have to do
that. There is no official public register to make sure they are currently
registered, in the same way that I can check whether a car is currently
registered. Why is that the case? It is the case because ASIC does not actually
interview any of these people when they get in; it is a registration
process—they stamp bits of paper.
Mr Bill Doherty inferred that ASIC needs to verify that insolvency
practitioners actually make insurance payments. He explained that in the past,
the practitioner has gone:
...to an insurance broker and they say, 'I want to renew my insurance.'
The insurance broker gives them a certificate of compliance and a deal where
they pay their insurance monthly. Having got their certificate of compliance,
then they simply do not pay the payments and the insurance is void. That is how
Mr Jeff Hanley of ITSA told the committee that ITSA checks that trustees
have PI insurance at the point of registration, three years later at the point
of license renewal and through its annual checks.
Professor Scott Holmes of the University of Newcastle argued that the
obvious solution to the regulatory gap with PI insurance is to require the
insurer to notify ASIC when a practitioner's policy lapses or is not renewed. ASIC
should be required to ensure they have current insurances through appropriate
Another submitter argued that there should be criminal sanctions if
registered practitioners do not hold a valid PI insurance policy.
Professional Indemnity insurance has a 'Claims Made Basis' policy: the
practitioner must have a policy in place at the time a claim is made against them,
rather than at the time the alleged act is committed. The PI policy that covers
a practitioner is the policy he or she has at the time the claim is made, not
the policy held at the time of the alleged act. Accordingly, insurance
companies may offer 'run off cover' on a policy where the practitioner will
continue to be covered by a policy despite it having lapsed.
The committee asked Mr D'Aloisio to comment on a proposal whereby
insurance companies would be required to notify ASIC if an insolvency
practitioner's PI insurance lapsed. Mr D'Aloisio replied that this system would
entail monitoring costs for both the insurance industry and ASIC. He added:
...it does not help either, because how do you reinstate it? If
the claims occur after, you may not have dealt with the issue that you are
concerned with. The issue you are concerned with I think might be better dealt
with if you have run-off cover for a period of time: after the policy is
cancelled there is cover for claims that occur within a certain period of time.
The committee understands that ASIC currently requires insolvency
practitioners to have 'run-off' cover as part of their PI insurance. ASIC's Regulatory
Guide states that registered liquidators should:
...use their best endeavours to obtain automatic run-off cover
for as long as reasonably practicable. In any event, their insurance policy
should contain run-off cover for at least one year after the expiry of the
policy period in the event of insolvency or external administration of the
registered liquidator or firm.
However, the committee received evidence from the IPAA that to their
understanding, the insurance industry have advised that they will not offer
run-off cover for insolvency practitioners.
The committee is also concerned that PI insurance does not cover fraud
and deliberate wrongdoing. In other words, creditors in the Ariff matters would
not have been covered. One submitter has suggested that all insolvency
practitioners should be members of the ICAA, the CPA or the National Institute
of Accountants. Each professional organisation should have a fidelity fund
which would cover fraud.
A licensing regime
The committee notes that the possibility of a licensing system for
insolvency practitioners was considered as part of the 2007 Amendments (see
chapter 1). This proposal included a requirement for regular renewal of
licenses to monitor compliance with practice capabilities and professional
education standards, the provision for the cancellation and conditional issuing
of licenses and more active monitoring of practitioners by ASIC. The government
rejected this proposal, preferring instead to target reform of the existing
registration process. This was seen as the more appropriate response as it
avoided the transitional costs and new compliance obligations of a licensing
Despite the 2007 reforms, the committee has concerns that the current
registration regime lacks the flexibility to enable the regulator to suspend a
practitioner's activities while an investigation takes place. As past
experience has shown, considerable damage can be done to creditors while a
practitioner is under investigation.
As detailed earlier (paragraph 7.5), ASIC's Chairman has himself
recognised that it is not easy to deregister a liquidator. In addition to the often
protracted processes of natural justice, the law requires ASIC to prove the
case against the practitioner before he or she is deregistered. Mr D'Aloisio
contrasted this approach with a police power to stop a motorist at the traffic
lights and issue an infringement notice.
Mr D'Aloisio was asked whether a licensing regime would give ASIC the
power to suspend immediately the practitioner's activities. He acknowledged
that a licensing system, such as the AFS (Australian Financial Services
licence) regime, is not without its problems. However, he noted that while a
licensing system for insolvency practitioners is ultimately a policy matter for
government, 'I think the current policy framework is in that direction'.
In its supplementary submission, ASIC compared insolvency practitioners'
registration obligations under section 1288 of the Corporations Act 2001
with the AFS licence obligations under section 912A. It noted that:
The general obligations of AFS licensees under s912A provide
a basis to address concerns about variable levels of experience of insolvency practitioners
through the ongoing requirement to ensure that the licensee and their
representatives are competent. These requirements also provide a mechanism
through which to address practitioner misconduct by allowing the suspension or
cancellation of a licence.
...the requirements of s912A and 912B for AFS licensees ensure that
the licensee not only has appropriate IDR [internal dispute resolution] processes
in place, but that they are also a member of an EDR [external dispute
ASIC emphasised that under the AFS licence regime, where it seeks to
cancel, suspend or vary a licence, it does need to afford the licensee the
right to appear before a hearing on the proposed action and the right to appeal
Mr Donald Magarey, the Chairman of the Companies Auditors and Liquidators
Disciplinary Board (CALDB), also raised this concern. He recognised that a proposal
to withdraw a practitioner's registration in lieu of a disciplinary process is
a policy matter for government. However, he urged caution:
...I have always taken the view that in this area the existing
system has been based on the proposition that, until people have an adequate
hearing and an opportunity to present their case and they have natural justice
and the rights to see the decision and all the reasons for the decision, taking
away their registration would somehow be in breach of the golden rule of
innocent until proven guilty. That is my own view; that is the way I have
always looked at it. I have never seen that written down but that is the way I
have always looked at it.
In addition to quickly stopping wrongdoing, a licensing system would
also have the advantage of improved monitoring of insolvency practitioners.
Unlike the current registration process, a licensing system would have a
requirement for regular renewal. This would involve the practitioner lodging
information every three years (for example) and an assessment by the regulator
of the practitioner's conduct and need for professional development. Pending
this assessment, the regulator has the options of renewing the license,
imposing conditions on it, suspending the license or revoking it.
The committee notes that regular, systematic surveillance of insolvency
practitioners is not a feature of the current system. ASIC only reviews
individual practitioner conduct if a complaint is made.
The contrast is with ITSA, which conducts annual reviews of their practitioners
and requires them to register every three years (see chapter 10).
ASIC does require insolvency practitioners to lodge an annual statement concerning
personal and practice details and the liquidations that they have conducted
Mr Jeffrey Fitzpatrick, Dr Vivienne Brand and Associate Professor Christopher
Symes describe this requirement as a 'de facto process of indirect periodic renewal
of registration'. They note that the annual statements are not open to public
inspection and copying due to the confidential nature of their content.
One submitter suggested that an avenue to improve the monitoring of the
profession is to put in place quarterly reporting requirements. He suggested
that this could be paid for through a registration fee payable to ASIC.
ASIC estimated in its supplementary submission that the cost of
implementing a license regime with a renewal process would be two start-up full
time equivalent (FTE) staff and seven ongoing FTE staff.
This costing assumed the current 662 insolvency practitioners would undergo
renewal of their license every three years.
Some submitters favoured a stratified system of registration (or
licensing) where practitioners are deemed qualified for particular types of
insolvency work. This idea was raised in a submission by Mr Fitzpatrick, Dr Brand
and Associate Professor Symes. They noted that currently, a registered
practitioner has the ability to accept an appointment of any company despite
its size, complexity or industry. It is left to the professionalism of the
individual liquidator to 'self-govern' whether he or she is 'fit and proper'.
The academics suggested that despite the higher costs involved,
stratifying registration could overcome this 'one size fits all' dilemma. Associate
Professor Symes told the committee:
...we were thinking something along the lines of restricted and
unrestricted registration, that we might need to review the idea of category A
and category B type registered liquidators...There is a distinct possibility of a
person having an unrestricted licence—registration as it is now—and that they
can embark upon any size liquidation, any size administration or any size
receivership. It is possible, I suppose, to look at a stratification where you
would have specialist insolvency practitioners looking at only operating in the
small and medium enterprise area. It is possible to restrict on the basis of
the size of the company which is going to be wound up or administered or the
size of the turnover. If we were to introduce categories, I think we would have
to look at differences between education, perhaps putting in hurdles for both
education and supervision.
The IPAA also supports the idea of stratifying registration, albeit through
a licensing regime. Mr Mark Robinson, President of the IPAA, told the
...what attracts the IPA to the concept of a licensing regime
is two things. On the initial licensing of a person who is reputedly of good standing
but whom we have not seen actually operate in the market let us put some terms
and conditions to see how they run for a period of time. Maybe we could put
some speeding restrictions, if you like, in terms of the number of matters they
take on. What also attracts our organisation to a licensing regime [is]...that,
if it is on a three-year to a five-year basis, you virtually have to go through
a re-application cycle, so your history and past conduct can be taken into
account in terms of whether the licence will be renewed.
A single registration body
Some submitters to this inquiry argued that there is no need for two
separate registration processes for personal bankruptcies and corporate
insolvencies. Associate Professor David Brown from the University of Adelaide
queried whether Australia needs two separate registration systems when both are
essentially the same people wearing different hats.
He suggested that in pursuing a single registration model, ITSA's approach
should be preferred to that of ASIC:
ITSA is now regulating debt agreement administrators on an
ongoing basis and requiring them to be interviewed and have an exam. If they do
not come up to scratch in the interview, they have to sit an exam. So it seems
that ITSA is pursuing that sort of ongoing monitoring and initial entry into
the door to a greater standard than ASIC is doing, at least on an ongoing
Dr Colin Anderson from the Queensland University of Technology and
Dr David Morrison from the University of Queensland have also argued in
their submission that given that most registered trustees are also registered
as liquidators, there should be one registration authority for insolvency
practitioners. They observed that the eligibility requirements for bankruptcy
and corporate insolvencies are essentially the same. Further, the merging of
personal and corporate insolvency regimes should be easier now than it has been
in the past given that all corporate law is regulated at Commonwealth level.
The academics suggested that:
...even if it is not feasible to integrate all of insolvency
regimes under the one supervisory authority, it is possible to place the registration
and supervision of the profession under one body.
Another issue raised during this inquiry concerned the educational requirements
for insolvency practitioners to become registered and to remain registered. Several
submitters noted that standard could be improved. Professor Scott Holmes,
for example, told the committee that current regulation of ongoing continuing
education is 'pretty slack'.
Mr Bill Doherty identified the need for an MBA and legal qualifications (see
Mr Geoffrey McDonald, on the other hand, argued that determining what
type of education is necessary to be registered and remain registered as an
insolvency practitioner is not easy. In his view:
The disciplines that you need for insolvency are very
widespread. In many respects, the accounting discipline is probably one of the
least disciplines you need. The ability to understand tax law is not necessary.
These companies do not pay tax; they do not make profits. Regarding the ability
to deal with consolidated accounts and the like, I just do not see that the
accounting skills are really the trick; it is commercial skills and probably
the law. Defining the skills and qualifications that are needed for a
liquidator to become registered is a challenge in its own right. The legal
profession, obviously, is very disciplined and has its statutory backing. You
cannot act as a legal practitioner without being qualified. That is a breach of
the legislation. You can be an insolvency practitioner—not to take on the
appointments, but be an insolvency practitioner without necessarily having
To be a full member of the IPAA, practitioners must have successfully
completed the Association's Insolvency Education Program (IEP). The IEP provides
a professional qualification for insolvency specialists and is a prerequisite
for full membership of the IPA. It is a combination of two units of post‐graduate university
level study, attendance and performance at workshops conducted by senior practitioners,
and written assessment on an ethics topic. The IEP takes a minimum of one year
to complete and covers each of the different types of insolvency administration,
in both personal and corporate, and includes topics of establishing insolvency,
workouts, and ethics.
The IPAA also requires their members to undertake 40 hours of professional
development per year. It conducts audits of their members to ensure they have
satisfied this requirement. Professional development activities may be offered
by the practitioner's firm, through educational institutions or through
industry associations. The IPAA, for example, offers the Introduction to
Insolvency Program (IIP), which is a two day face‐to‐face interactive
course providing new entrants to the profession with knowledge of insolvency
and restructuring. It also runs a 439A Report Training course. This course assists
practitioners with the theory of section 439A reports as well as the legal and professional
standards, tools for gathering information and presenting information to
This chapter has considered various options to improve the registration
process to become an insolvency practitioner. The committee recognises a
continuing need to make improvements to this process to ensure that the
regulators can have confidence that new practitioners are of high capability
and integrity. A more rigorous registration system also serves to bolster
public confidence in the profession.
Chapter 11 of this report provides the committee's view on the key
options of a licensing system, an interview process, a written examination, a
stratified registration system and a single registration body for practitioners.
The merit of each option should be considered in the context of the committee's
views on the need for broader reform of the regulatory framework.
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