A number of significant changes were introduced to the financial services industry in 2020, with amendments made to the General Code of Conduct (GCOC) and Fit and Proper requirements. Furthermore, all entities, including Financial Services Providers (FSPs), will also have to comply with the provisions of The Protection of Personal Information (POPI) Act by 30 June 2021.
Keeping track of what must be done to remain compliant is key to remaining in business as an FSP. It is therefore important for FSPs to know what changes, especially those which have already been announced, they need to comply with.
Here are some key dates to help FSPs plan for 2021:
Hereunder are some other important reminders. We suggest that you set these, and the ones above, in your year planner.
- Ensure all information on the FSP’s profile on the FSCA’s website is always up-to-date, especially as at 31 August of each year as the FSCA will use the information on their records to prepare the Levy Statement which will be due and payable by the FSP by 31 October 2021. Simply put, you don’t want to pay levies unnecessarily.
- Inform the FSCA of any changes to the business within 15 days of the change, e.g. shareholders, directors, representatives, address, bank account, accountant, etc.
- Update the Competence Register with Product Specific Training within 15 days after training has occurred.
- FSPs must submit their Annual Financial Statements to the FSCA within 4 months of their financial year-end and, if required, attach Annexure A of FAIS Notice 82 of 2015.
- Apply for Professional Indemnity (PI) renewal at least 1 month before the renewal date.
- Apply to the Medical Schemes Council for renewal of Broker Accreditation 4 months before the expiry date using the CMS online portal. Note that this accreditation lasts for 2 years and on renewal the Council may request proof of qualifications.
- Monitor deadline dates for Representatives under Supervision to comply with the competence requirements.
- Conduct monitoring of Representatives at least quarterly.
- Conduct monitoring of Representatives under supervision at the required intervals.
- Monitor deadline dates for Representatives under Supervision to comply with the competence requirements.
- Prepare and review monthly management accounts.
- Schedule a date for staff to complete FICA and RMCP Training and keep records of same.
- Diarise a date for a review of critical policies and procedures including:
– Conflict of Interest Management Policy
– Complaints Management Framework
– Competence Policy
– Remuneration policy
– Debarment and Disciplinary Procedure
– Disaster Recovery and Business Continuity Plan
– FICA Risk Management and Compliance Programme
– FAIS Risk Management Policy and Plan
Should you require assistance with any of the policies or implementation, please get in touch with us or contact your Masthead Compliance Officer.