The Financial Sector Conduct Authority (FSCA) recently published FSCA Communication 19 of 2021 (FAIS) – submission of representative register, which provides information to Financial Services Providers (FSPs) and key individuals, on the new process for the submission of the representative register to the FSCA. It is a legal requirement that FSPs notify the FSCA of any changes to their representative register within 15 days of any changes to the data included in that register. Such information must be furnished to the FSCA, where it will be recorded in the FSCA’s central records.
The current process for submission
Currently, the FSP can inform the FSCA of changes through the following channels:
- A manual process of submitting Form FSP 5 to the Licensing and Business Centre of the FSCA to perform a profile change
- Logging on to the FSCA e-portal using the log-in credentials provided by the FSCA; or
- Update the representative register electronically by sending a text-based document or a Microsoft Excel spreadsheet, which is then approved by the FSCA before being entered into the FSCA’s central record. The FSCA has now changed this method for submitting updates to the representative register by introducing an electronic channel (FSCA web service).
The new process for submission
The FSP will be able to upload its representative register in XML (plain text) format using system to system integration using the FSCA web service. System integration is when subsystems function together as one system. FSPs will now be able to connect their systems to the FSCA web service using the SOAP API (simple object access protocol application programming interface) provided by the FSCA. As a result, the SOAP API will be used to make changes to the representatives register.
In the new process, the FSCA has also prioritized information security. To decrease security risks, all SOAP API transactions will use a secure protocol (HTTPS). All FSPs will be assigned a username and password, which must be submitted along with any changes to the representative register. The FSP’s login and password for accessing he FSCA web services will be provided to the FSP via the FSCA e-portal. It is the FSP’s obligation to always maintain these credentials safely and securely. If an attempt is made to contact the FSCA SOAP API without authorisation, the FSP will get an error message stating that the credentials are invalid or that the FSP does not have access to the requested method.
Testing of the FSCA web services
The FSCA has created a testing environment to allow development and testing to be completed on the systems of the FSP in order to facilitate system integration and the use of the web service. It is important to note that before an FSP submits representative changes via the FSCA web service, the FSP must first be granted access to the testing environment. To acquire access to the testing environment, an FSP must send an email to firstname.lastname@example.org requesting a username and password, which will only be used for testing purposes. After, successful integration testing, the FSP will be provided with a new username and password that will allow the FSP to submit modifications to the representative register via the FSCA web service. Therefore, FSPs must first test the FSCA web service before making the required changes to allow for system integration.
It is important for FSPs to understand the new process because the method of submitting representative register updates in Microsoft Excel format will no longer be permitted after 31 March 2022. The FSCA web service has become available since 1 November 2021, and FSPs will be able to obtain credentials for the testing environment. FSPs are urged to become familiar with this process as the maintenance of a representative register is a legal requirement in terms of FAIS.
In addition to this new process, FSP will still be able to submit representative register updates through by making use of the manual (Form FSP 5) process or by logging on to the FSCA e-portal.