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Investment Indicators - 22 January 2018
In This Week's Newsletter
Rates Review
Investment Rates
Money Market Funds
Top 3 Rates
 
From the Crow's Nest
Draft Determination on Equivalence of Reward – Tied agents “unfair advantage” addressed
 
Your Practice Made Perfect
National Credit Regulator Fee Guideline – Fee guideline and schedules published for comment
Professional Principal Executive Officer Qualification – Registration now open for February 2018
 
Regulatory Examinations
Updated 2018 schedules
Important Regulatory Exam Information – Substantial changes to Qualifying Criteria impacts on question bank and study material
 
Careers Platform
Are you hiring? Advertise your position on Moonstone’s Career Platform
Featured Positions
 
In Lighter Wyn
Why I still read newspapers...
Paul Kruger 2016-10-31
Paul Kruger Author/Editor
 
 
 
 

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Wisdom is knowing what path to take next…Integrity is taking it. – M H McKee
 
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Rates Review
Top 3 rates
 1. Secured Investment Rates
Please note that (G) indicates a Guaranteed and (L) a Linked product. In order to understand the difference between guaranteed and linked rates, kindly click here for an explanation.
 R 100 000
 
 
 
     
  Company This Week Last Week
1 Clientéle Life (L) 6.760% 6.900%
2 1Life (L) 6.710% 6.880%
3 Absa (L) 6.576% 6.753%
     
 R 1 000 000
     
     
  Company This Week Last Week
1 Clientéle Life (L) 6.860% 7.000%
2 1Life (L) 6.710% 6.880%
3 Assupol (G) 6.680% 6.860%
     
 2. Money Market Funds
  Company This Week Last Week
1 Allan Gray 7.900% 7.880%
2 Cadiz 7.870% 7.860%
3 Coronation 7.810% 7.810%
Please bear in mind that our figures, though based on the actual quotations that you also use, are for information purposes only, and can never replace the official quotation from the product house. In terms of the guarantees, you are requested to clarify the exact extent of such guarantees with the product house prior to advising clients.
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From the Crow's Nest
From the Crow's Nest
Draft Determination on Equivalence of Reward
The sustainability of independent financial advice was always a key aspect in the Registrar’s approach to the Retail Distribution Review.

Board Notice 181 of 2017, published on 10 November last year, aims to level the playing field as far as tied agents and independent advisers are concerned.

The publication of this draft Determination follows RDR Proposal RR, which proposed that specific standards be set to clarify and strengthen the principle of "equivalence of reward" as the basis on which long-term insurers may remunerate their tied advisers.

In response to industry comments received in respect of the above proposal, the FSB subsequently confirmed that full implementation of RDR Proposal "RR" will be deferred until broader RDR proposals dealing with the future remuneration model for long-term insurance are closer to finality. The FSB did however highlight that, despite this deferral, it remained concerned that a number of current practices in relation to tied adviser remuneration give rise to inappropriate distortions in the advice market, posing risk of unintended levels of migration from independent to tied models. Accordingly, the FSB advised that, as an interim measure, pending full implementation of Proposal RR, it intends to clarify certain practices that the Registrar regards as inconsistent with the principle of equivalence of reward.

Key provisions of the draft determination

The determination identifies two specific forms of remuneration or considerations that would enable an insurer to provide its representatives with potentially significant financial advantages that it is not able to provide to independent intermediaries.
  • The provision to a representative of various forms of credit or access to credit on terms that are more favourable than those available on an arms' length basis; and

  • Arrangements whereby an insurer in effect "buys the representative's book of business" from that representative when the representative's intermediary agreement with the insurer comes to an end. The policyholders contained in the "book" are already customers of the insurer concerned by virtue of its agency relationship with the representative, and the insurer is already obliged to ensure appropriate ongoing service to such policyholders, regardless of whether or not the intermediary agreement with the representative remains in place. Accordingly, the rationale for the insurer remunerating the representative for, in effect, retaining access to its own customers is unclear.

In addition to addressing the above specific remuneration arrangements, the determination includes a more general limitation providing, in effect, that remuneration arrangements where more than 15% of a representative's overall remuneration comprises benefits that are not generally provided to all of the insurer's representatives (or all representatives of a particular type), do not comply with the principle of equivalence of reward.

This provision is intended to address other remuneration arrangements (over and above those specifically identified above) through which insurers could provide benefits to selected representatives that it would not be permitted to offer to independent intermediaries. The provision also seeks to ensure a reasonable degree of equivalence with the requirement in Part 3A that an independent intermediary may only be remunerated through "commission in monetary form", while recognising that Part 3A contemplates that a representative may be remunerated "in cash or in kind".

The provision seeks to clarify that, in order for remuneration "in kind" to be consistent with the principle of equivalence of reward, it should largely comprise benefits typically available to the insurer's representatives generally in the normal course of their employment/tied agency relationship with the insurer, rather than including a significant proportion of non-standard benefits that are available only to select representatives'.

The determination contains additional provisions confirming that non-compliance with the principle of equivalence of reward extends, in summary, to arrangements that —
  • are substantially similar in effect to those identified in the determination; or

  • entail an undertaking to provide the identified forms of remuneration or consideration in the future.

These provisions no doubt stem from practices like “sign-on bonuses”, and are aimed at preventing the industry from using clever terminology to bypass regulations.

Implications of Equivalence of Reward

Cynics may view this as a case of robbing Peter and not paying Paul. Many fiercely independent financial advisers managed to avert the temptation of monetary reward, access to cheap bonds and car instalments, subsidized pension funding, free medical aid and other benefits. Taking such benefits away from tied agents will do nothing for independent advisers, except maybe making it easier to say no.

The real threat, in my view, will come from the onerous compliance obligations currently being layered on the industry. Product providers will not be allowed to offer assistance to top producers in conflict with regulations aimed at curbing conflict of interest.

This may very well lead to independents throwing in the towel and joining the tied agency ranks, where support in terms of compliance is provided, amongst other obligations which the non-tied agent is responsible for. This will put paid to the intended good intentions of sustaining independent financial advice.

At the same time, clients who rely on independent advice will be the biggest losers, which is exactly contrary to why we are seeing the introduction of all the new legislation in the first place.
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Receive 10% additional income with Discovery Invest

To celebrate Discovery Invest’s 10th anniversary, the company is offering clients 10% additional income for three years on the Discovery Fixed Retirement Income Plan. This is in addition to your quoted annuity income amount before tax, and will be applied for the first three years of the policy. For single-life annuities, the 10% additional income stops after three years or when the client dies. For joint-life annuities, the 10% additional income is only applied to the current amount in payment and stops after three years or when both annuitants have died.

Disclaimer
Nothing contained herein should be construed as financial advice and is meant for information purposes only.

Discovery Life Investment Services (Pty) Ltd branded as Discovery Invest is an authorised financial services provider. Registration number 2007/005969/07.

Product Rules and Terms and Conditions Apply.

 

 
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Your Practice Made Perfect
Your Practice
National Credit Regulator Fee Guideline
We published an article on 16 November 2017 titled Insurer Obligations re Credit Reports which dealt with the National Credit Regulator’s (NCR) guideline for the submission of credit information and indicated that a fee structure would be published in December 2017.

NCR have now published its fee guideline and schedules relating to the above for comment.

The Fee Guideline is of specific significance to Category 1 to 5 Credit Providers (where the total principal debt is equal to or greater than R5 million) as these credit providers are required to be onboarded at the South African Credit and Risk Reporting Association (SACRRA) by 30 November 2018. All other categories of credit providers (where the total principal debt is less than R5 million), will only commence with the SACRRA onboarding process in 2019.

Please note that all interested parties have 30 days from 12 January 2018 to provide the NCR with their comments on the guideline, by emailing it to compliance@ncr.org.za.

The proposed onboarding fees are as follows:
 
Credit provider category Proposed fee
1 R37 000
2 R35 000
3 R33 000
4 R33 000
5 R10 000

The NCR advised that the annual maintenance fees will be published during December 2018.

Please click here to download a copy of the Fee Guideline.

Moonstone employed an NCA Specialist to render NCA compliance services to its clients and prospective clients. As part of these services, we are able to assist you with your data access and submission practices in compliance with the NCA. Should you have any queries, please contact Gerrit Viviers on 021 883 8000 or by email to gviviers@moonstonecompliance.co.za.

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Professional Principal Executive Officer Qualification
Registration is now open for candidates who want to enrol for the first intake on 26 February 2018.

The Professional Principal Executive Officer Qualification is a much-needed stimulus for the professionalisation of the role of the Principal Officer which has historically been unstructured and undefined. It will also support the very important transformation imperative as it enables learners to obtain a qualification which may have been inaccessible to working individuals, as well as those unable to satisfy traditional Higher Education access criteria.

Moonstone Business School of Excellence (MBSE) is the first duly accredited training provider to offer this qualification.

Given the very important role played by Principal Executive Officers within the governance structure of a retirement fund, it is surprising that, up to now, very little was available in the form of a duly recognised NQF level 7 qualification for those performing this function, or those aspiring towards it.

This occupational qualification will form the apex of the retirement functionary learning path and will be linked to the Principal Officer Association (POA) professional designations.

Who should register?
  • Current Principal Officers, trustees and retirement fund functionaries.

  • People working in a claims or employee benefits and compensation environment who have access to a retirement fund.

Successful learners will be linked to the professional designations offered by Batseta, the professional body for the profession. The learning pathway will include the Retirement Fund Trustee qualification.

Registration

You are welcome to speak to Frans Petrus Zeelie at 087 702 6429 who will gladly assist.

To register, click here, then on Enrol today and finally on the Professional Principal Executive Officer button.

For more information, please click here. You can also email us on at learning@mbse.ac.za.
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Regulatory Examinations
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2018 Schedules updated

Please note
: Registration cut-off is 11 working days before date of exam.
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Important Regulatory Exam Information
In terms of our mandate from the FSB, we are not allowed to promote or endorse any training service provider, hence I am unable to disclose details of the author of the very important information below.

We have now received revised and updated Fit and Proper Requirements from the Registrar of the FSB with the publication of Board Notice 194 of 2017 on 15 December 2017, with variable implementation dates.

This draws to an end a period of nearly three years of public and corporate-wide consultation which our Regulator engaged in. Included in this review and consultative process was a careful and thorough review of the Qualifying Criteria (content requirements) upon which our Regulatory Exams for key Individuals (RE1) and Representatives (RE5) are based.

The review process has now provided us with a more in-depth but less repetitive set of Qualifying Criteria. There are still 16 Tasks or sections for the RE1 exam and 8 for the RE5 exam, but there are a significant number of new Qualifying Criteria and of course the updated FICA legislation is now incorporated, where applicable.

This has led to important changes to the Regulatory Exam requirements and therefore, of course the Regulatory Exams, the study material and bank of MCQ questions.

Common sense suggests that taking the exams before 1 April 2018 will be wise and I do recommend and encourage those who need to complete these exams to do so sooner rather than later i.e. before 1 April 2018.

With the benefit of hindsight we can also suggest that you leave yourself sufficient time to rewrite in the event that you not pass at the first attempt. Seats are filling up very fast, so please make sure you register in time.

Frequently Asked RE Questions – Answers to questions on REs and preparation material

DOFA - Do's and Don'ts

Email enquiries should be addressed to faisexam@moonstoneinfo.co.za. You can phone us on 021 883 8000 - select option 2 to speak to one of our consultants.

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Careers Platform
Are you hiring? Advertise your position on Moonstone’s Career Platform
Careers Platform Packages

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Featured Positions
  • Insurance Field Sales Reps: Quantum Invest, Nationwide - We are looking for field Reps nationwide. RE5 qualification is recommended. We offer a competitive commission structure. Read More

  • Financial Advisor: Kaizen Solutions, Gauteng - We are currently recruiting an unlimited number of individuals aged 25 to 35 who are sales driven, motivated, ethical and dedicated. Read More

  • Senior Credit Controller: CIA Building Insurance, Bedfordview, is currently looking for an experienced credit controller to join our finance team. Read More

  • Short Term Insurance Underwriter: JFA Shortterm Brokers CC, Milnerton, Cape Town - If you have a minimum of 3 years experience and, live in the vicinity of the brokerage, then Read More

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In Lighter Wyn
In Lighter Wyn
Why I still read newspapers
Thanks, Roche Cowley

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