ITO Sections 6A and 8A of FAIS- all FSPs who are sole proprietors, key individuals and representatives must meet the experience requirements and continue to meet those requirements. The purpose of the five year requirement is to ensure that a person’s practical experience remains appropriate, applicable and relevant for the category of FSP and subcategory of financial product relating to authorisation, approval or appointment.
The purpose of the Date of First Appointment (DOFA) date is to determine which qualification requirements apply to a person, by when the person must meet the qualification and regulatory examination requirements and to track the person’s experience. The five year experience therefore has no impact on a person’s DOFA date and the date will not and cannot be changed where the person has left the industry or has not rendered financial services for a period exceeding five years.
The five year requirement only impacts the determination of whether a person is compliant with the experience requirement and whether such experience is indeed still valid. It does not impact a person’s DOFA date and future requests to the Registrar to amend or ‘reset’ the DOFA date, owing to a person not rendering financial services for a period exceeding five years, will not be considered.
Please contact your Compliance Officer should you need clarity on whether you meet the five year experience requirement.
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