Supervision is triggered the moment a representative hasn't yet met all fit and proper requirements — typically before passing RE5 within the 24-month DOFA window. It's mandatory in that situation across all 7 of this task's QCs, not a discretionary choice for a new hire who seems experienced.
QC1 — Explain when representatives can act under supervision
QC2 — Confirm there are sufficient qualified individuals to act as supervisor
QC3 — Describe the requirements that must be in place when representatives act under supervision
QC4 — Ensure supervisors understand their role and have capacity for their supervisees
QC5 — Verify that supervision is in place to oversee representatives
QC6 — Perform the necessary supervision functions on representatives
QC7 — Explain the disclosure requirements for a representative under supervision
QC1 & QC3: Two Requirements That Must Exist Together
A proper supervision arrangement rests on two things happening at once: the supervisor must review and approve the representative's work before it reaches the client, and the representative must disclose their supervised status to every client before rendering any service (QC7).
QC2 & QC4: Capacity Has to Be Realistic
An FSP can't satisfy this task by appointing supervision in name only. It needs enough genuinely qualified people (QC2) to supervise the actual number of representatives who need it — one overloaded supervisor formally "responsible" for twenty unsupervised representatives isn't sufficient supervisory capacity for exam purposes, even if the paperwork names them as the supervisor. QC4 adds that supervisors must genuinely understand the role means active review, not passive availability "if questions come up" — a supervisor with a full personal client book and fifteen supervisees is unlikely to be genuinely reviewing each one's work before it reaches clients.
QC5–QC6: Rubber-Stamping Is Itself a Breach
QC5 is the KI's checking duty: confirming supervision arrangements actually exist and are documented, not assuming HR or a regional manager has it covered. QC6 is the hands-on skill — reviewing files and providing genuine feedback.
QC7: Disclosure, Every Time, Before Every Service
The disclosure must happen before any service is rendered, to every client, and cannot be satisfied by a general office notice — it must reach the specific client in that specific interaction. This sits on top of, not instead of, the General Code's own "before rendering a service" disclosures covered in Task 6.
Quick Recap
- Supervision is mandatory the moment a representative hasn't met all fit and proper requirements, not discretionary
- Supervisor approval and client disclosure must both happen — neither substitutes for the other
- Rubber-stamping approvals is a breach in itself, independent of whether harm actually resulted
- Supervisory capacity must be realistic for the actual caseload, and supervision ends when requirements are met, not on a fixed timeline
Approval Without Review Isn't Supervision
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