CPD is only part of the journey to compliant conduct and behaviours. It is, in fact, just one input to the process. Simply completing the requisite number of CPD hours does not ensure improvement in or adherence to the higher standards (the outputs) that the FCA now expects (and has clearly signalled will be their focus in future).
CPD should form part of the process of T&C management and conduct assessment. The progress of CPD and training for the individual needs to be tracked, with the learning outcomes and consequent improvements in delivery assessed. This process needs to be managed by all those responsible for the oversight of that individual.
If HR and Compliance can view all of this activity through one tracking, assessment and monitoring tool (with records being kept and updates being made in one place) that is accessible by all concerned, then the pathway to compliant conduct becomes far less cluttered.