FAIS CLIENT FILE AUDITS

• CLIENT FILE REVIEWS

• PERIOD

  Select P1801 P1802 P1803 P1804

  • P1801
  • P1802
  • P1803
  • P1804

• NAME OF FSP:

• FSP no. (PREFIX WITH "FSP")

• Conducted on:

  Date

• This report was prepared by

• Select Simply Comply (Pty) Ltd Gerard Schiel Bianca Engelbrecht / D Julyan Gaylene Crous

  • Simply Comply (Pty) Ltd
  • Gerard Schiel
  • Bianca Engelbrecht / D Julyan
  • Gaylene Crous
• Location
  Address

• PRESENT:

TYPE OF FSP

• CLIENT CORRESPONDENCE AND FILES AUDITED: PERIOD:

  Select P1801 P1802 P1803 P1804

  • P1801
  • P1802
  • P1803
  • P1804

• This FSP is licenced as a:

  Select Motor Dealership Brokerage - ST Brokerage - Investment Brokerage - Risk UMA Cell captive Call Centre - outbound Call Centre - Inbound Pro- Banker CAT II

  • Motor Dealership
  • Brokerage - ST
  • Brokerage - Investment
  • Brokerage - Risk
  • UMA
  • Cell captive
  • Call Centre - outbound
  • Call Centre - Inbound
  • Pro- Banker
  • CAT II

• Only intermediary services, and no advice is provided

  Yes

  No

  Requires attention

• A documented, correct service level agreement is in place between:<br>1. Product supplier and FSP<br>2. Brokerage and FSP (where applicable)

  Yes

  No

  Requires attention

• It is incumbent on the FSP to ensure that there are adequate drafted service level agreements - as these are the basis on which service can be measured from a TCF perspective. Please ensure this is attended to a.s.a.p.

• Administrative procedures are in place, to ensure proper process, checks and balances and controls. Deviations are noted and addressed

  Yes

  No

  Requires attention

• Notes:

Files Audited:

• DATE OF AUDIT

  Date

• Name of Client

• Disclosures correct

  Compliant

  Not compliant

• Services provided within the agreed SLA

  Yes

  No

  Not Applicable

• Correspondence clear, correct and complete

  Compliant

  Not compliant

• The product performs as it has been led to perform (TCF Pillar 5)

  Yes

  No

  Not Applicable

• NOTES:

• PHOTO EVIDENCE

• Add media

  Media

• FILE AUDITS
FILE AUDITS

• DATE OF AUDIT

  Date

MOTOR DEALERSHIP

• Name of Representative:

• Transaction Date:

• Name of client/file

• A due diligence has been completed on products and product providers recommended

  Yes

  No

  Needs attention

• Date the representative last received product training on the recommended product

• Offer to Purchase - on file and correct and complete

  Yes

  No

  Requires attention

• Invoice - figures on invoice are the same as the OTP

  Yes

  No

  Requires attention

• Full Product and Fees disclosures - evident

  Yes

  No

  N/A

• Contract - Page 1 on file

  Yes

  No

  Requires attention

• Record of advice - correct updated version

  Yes

  No

  Requires attention

• Record of advice - complete, initialled every page

  Yes

  No

  Requires attention

• Cash deal / Cash deposit

  Yes, it is

  No, it is not

• FICA verification done

  Select ID - dated and verified ID - not dated or verified No proof of ID Proof of address - dated and verified Proof of address - not dated or verified No Proof of address FICA risk rate document Complete No FICA risk rate document Juristic Entity - Resolution/ Proxy Juristic entity - No resolution/ Proxy Not all documents on file Source of Funds Proof on file No proof of source of funds Source of income (proof) No source of income (proof)

  • ID - dated and verified
  • ID - not dated or verified
  • No proof of ID
  • Proof of address - dated and verified
  • Proof of address - not dated or verified
  • No Proof of address
  • FICA risk rate document Complete
  • No FICA risk rate document
  • Juristic Entity - Resolution/ Proxy
  • Juristic entity - No resolution/ Proxy
  • Not all documents on file
  • Source of Funds Proof on file
  • No proof of source of funds
  • Source of income (proof)
  • No source of income (proof)

• It is critical that the correct FICA verification and documents are on file. Please ensure that staff are retrained on this, and that the matter is attended to as priority.

• Reportable transaction

  Select No Yes - threshold Yes - suspicious/ unusual Yes - terrorist related Reporting done Reporting not done - risk

  • No
  • Yes - threshold
  • Yes - suspicious/ unusual
  • Yes - terrorist related
  • Reporting done
  • Reporting not done - risk

• All FICA reporting done within the required timeframes: 1) Threshold transaction - 2 days 2) Suspicious/ Unusual - 5 days 3) Terrorist financing - 15 days

  Select No Yes - threshold Yes - suspicious/ unusual Yes - terrorist related Reporting done Reporting not done - risk

  • No
  • Yes - threshold
  • Yes - suspicious/ unusual
  • Yes - terrorist related
  • Reporting done
  • Reporting not done - risk

• Non-reporting of FICA reportable matters within the required timeframes, places the dealership at risk. Please ensure this matter is addressed as a priority as this is a material non-compliance which carries severe penalties.

• Insurances on file

  Yes

  No

  Not applicable

• Drivers licence - correct, up to date, valid

  Yes

  No

  Not applicable

• Correspondence on file/ File Notes/

  Select Complete and comprehensive Complete but requires more detail Not compliant and requires addressing and monitoring Not applicable - no analysis was required Evident from the record of advice/ engagement Existing client - ongoing analysis

  • Complete and comprehensive
  • Complete but requires more detail
  • Not compliant and requires addressing and monitoring
  • Not applicable - no analysis was required
  • Evident from the record of advice/ engagement
  • Existing client - ongoing analysis

• Deal File compliant - all documents are complete, correct (including dates and signatures) - all transaction values match

  Yes

  No

  Requires attention

• Documents are correctly and comprehensively completed

• Has a system been implemented which ensures regular product training. Describe.

  Yes

  No

  Needs attention

• Evidence of KI checking - monitoring

  Yes

  No

  Requires attention

• Notes/ Comments:

• Files Audited for compliance
  

Files Audited

File Audits CAT I - SHORT TERM

• DATE OF AUDIT

  Date

• Name of Representative:

• Date of Transaction:

• Name of client/file

• A due diligence has been completed on products and product providers recommended

  Yes

  No

  Needs attention

• Disclosure document - is this the correct, updated document

  Yes

  No

  Not Applicable

• Consent to obtain information/ Schedule provided<br>

  Yes

  No

  Not applicable - not appointed

  Not applicable - existing client

  Working off schedule

• Is the transaction a comparison off an existing schedule only, a new quote completely, or a combination of schedule and advice/ assessing risk

  Schedule only

  New cover

  Schedule and assessment

• Broker Appointment - on document/ application form or other

  Yes

  No

  Not applicable - not appointed

  Not applicable - existing client

  Working off schedule

• Full product and fees disclosures

  Yes

  No

  Needs attention

• Mandate/ Evidence of Instruction being provided by client

  Yes

  No

  Needs attention

• Information gathering in order for intermediary to perform analysis

  Select Complete and comprehensive Complete but requires more detail Not compliant and requires addressing and monitoring Not applicable - no analysis was required Evident from the record of advice/ engagement Existing client - ongoing analysis

  • Complete and comprehensive
  • Complete but requires more detail
  • Not compliant and requires addressing and monitoring
  • Not applicable - no analysis was required
  • Evident from the record of advice/ engagement
  • Existing client - ongoing analysis

• Evidence of analysis

  Select Complete and comprehensive Complete but requires more detail Not compliant and requires addressing and monitoring Not applicable - no analysis was required Evident from the record of advice/ engagement Existing client - ongoing analysis

  • Complete and comprehensive
  • Complete but requires more detail
  • Not compliant and requires addressing and monitoring
  • Not applicable - no analysis was required
  • Evident from the record of advice/ engagement
  • Existing client - ongoing analysis

• Quote signed and on record

  On file and complete

  Not required as this is an existing client

  Not found on file. This is a requirement

  Not required

• Application form complete, with no blank areas (customer did not sign an incomplete form)

  Yes

  No

  Needs attention

• Claims History - (short term)

  Yes

  No

  Not Applicable

• Record of advice - complete and copy provided to client.

  Select Complete and comprehensive Complete but requires more detail Not compliant and requires addressing and monitoring Not applicable - no analysis was required Evident from the record of advice/ engagement Existing client - ongoing analysis

  • Complete and comprehensive
  • Complete but requires more detail
  • Not compliant and requires addressing and monitoring
  • Not applicable - no analysis was required
  • Evident from the record of advice/ engagement
  • Existing client - ongoing analysis

• RPAR - correct, complete, copy to client

  Yes

  No

  Needs attention

• Correspondence/ File notes/ Records of engagement

  Yes

  No

  Requires attention

• Documents are correctly and comprehensively completed 1-not at all 10- Perfect!

• Evidence of KI checking/ assessing content, plus appropriateness

  Yes

  No

  Needs attention

• Has a system been implemented which ensures regular product training. Describe.

  Yes

  No

  Needs attention

• Notes/ Comments

• Files Audited for compliance
  

Files Audited

File Audits CAT I

• DATE OF AUDIT

  Date

• Name of Representative:

• Date of Transaction:

• Name of client/file

• A due has diligence been completed on products and product providers recommended

  Yes

  No

  Needs attention

• Consent to obtain information<br>

  Yes

  No

  Not applicable - not appointed

  Not applicable - existing client

  Working off schedule

• Disclosure document

  Yes

  No

  Not Applicable

• Broker Appointment - on document/ application form or other

  Yes

  No

  Not applicable - not appointed

  Not applicable - existing client

  Working off schedule

• Mandate/ Evidence of Instruction being provided by client

  Yes

  No

  Needs attention

• Information gathering in order for intermediary to perform analysis

  Select Complete and comprehensive Complete but requires more detail Not compliant and requires addressing and monitoring Not applicable - no analysis was required Evident from the record of advice/ engagement Existing client - ongoing analysis

  • Complete and comprehensive
  • Complete but requires more detail
  • Not compliant and requires addressing and monitoring
  • Not applicable - no analysis was required
  • Evident from the record of advice/ engagement
  • Existing client - ongoing analysis

• Evidence of analysis and risk assessment

  Select Complete and comprehensive Complete but requires more detail Not compliant and requires addressing and monitoring Not applicable - no analysis was required Evident from the record of advice/ engagement Existing client - ongoing analysis

  • Complete and comprehensive
  • Complete but requires more detail
  • Not compliant and requires addressing and monitoring
  • Not applicable - no analysis was required
  • Evident from the record of advice/ engagement
  • Existing client - ongoing analysis

• Quote signed and on record

  On file and complete

  Not required as this is an existing client

  Not found on file. This is a requirement

  Not required

• Application form complete, with no blank areas (customer did not sign an incomplete form)

  Yes

  No

  Needs attention

• FICA verification (verified ID/Proof of address/Source of funds) DATED?

  Select Not applicable ID - verified and dated ID - not verified/ dated Proof of address - verified Proof of address - not verified/dated FICA risk rate document - complete FICA risk rate document - not complete 2 year re-verification done 2 year re-verification not on file Additional risk requirements Additional risk requirements - not on file

  • Not applicable
  • ID - verified and dated
  • ID - not verified/ dated
  • Proof of address - verified
  • Proof of address - not verified/dated
  • FICA risk rate document - complete
  • FICA risk rate document - not complete
  • 2 year re-verification done
  • 2 year re-verification not on file
  • Additional risk requirements
  • Additional risk requirements - not on file

• FICA verification is signed and dated, and less than 2 years, with a process in place to re-verify at least once every 2 years:

  Yes

  No

  Not Applicable

• Record of advice - complete and copy provided to client.

  Select Complete and comprehensive Complete but requires more detail Not compliant and requires addressing and monitoring Not applicable - no analysis was required Evident from the record of advice/ engagement Existing client - ongoing analysis

  • Complete and comprehensive
  • Complete but requires more detail
  • Not compliant and requires addressing and monitoring
  • Not applicable - no analysis was required
  • Evident from the record of advice/ engagement
  • Existing client - ongoing analysis

• Full product features, risks and fees disclosures confirmed

  Yes

  No

  Needs attention

• RPAR - correct, complete, copy to client

  Yes

  No

  Not Applicable

• Correspondence/ File notes/ Records of engagement

  Yes

  No

  Requires attention

• Documents are correctly and comprehensively completed 1-not at all 10- Perfect!

• Evidence of KI checking/ assessing content, plus appropriateness

  Yes

  No

  Needs attention

• Has a system been implemented which ensures regular product training. Describe.

  Yes

  No

  Needs attention

• Has a system of feedback from customers been implemented to identify any problematic areas?

  Yes

  No

  Needs attention

• Notes/ Comments

File Audits - CAT II

• Files Audited for compliance
  

Files Audited

• DATE OF AUDIT

  Date

• Date of transaction:

• Name of client/file

• Disclosure document is correct and includes Section 13 certification?

  Yes

  No

  Needs attention

• Consent to obtain information<br>

  Yes

  No

  Not Applicable

• Intermediary appointment on file

  Yes

  No

  Not applicable - not appointed

  Not applicable - existing client

  Working off schedule

• CAT II mandate on file, complete and signed

  Yes

  No

  Requires attention

• CAT II mandate is confirmed as the approved version

  Yes

  No

• Was advice provided?

  Yes

  No

• Is there a record of advice on file, in compliance with the requirements of a CAT I provider?

  Yes

  No

  Needs attention

• Information gathering in order for intermediary to perform analysis

  Select Complete and comprehensive Complete but requires more detail Not compliant and requires addressing and monitoring Not applicable - no analysis was required Evident from the record of advice/ engagement Existing client - ongoing analysis

  • Complete and comprehensive
  • Complete but requires more detail
  • Not compliant and requires addressing and monitoring
  • Not applicable - no analysis was required
  • Evident from the record of advice/ engagement
  • Existing client - ongoing analysis

• Evidence of analysis and risk assessment

  Select Complete and comprehensive Complete but requires more detail Not compliant and requires addressing and monitoring Not applicable - no analysis was required Evident from the record of advice/ engagement Existing client - ongoing analysis

  • Complete and comprehensive
  • Complete but requires more detail
  • Not compliant and requires addressing and monitoring
  • Not applicable - no analysis was required
  • Evident from the record of advice/ engagement
  • Existing client - ongoing analysis

• Is there evidence of assessing the customer's risk profile or motivating why a certain risk approach is undertaken

  Yes

  No

  Needs attention

• FICA verification (verified ID/Proof of address/Source of funds)

  Select Not applicable ID - verified and dated ID - not verified/ dated Proof of address - verified Proof of address - not verified/dated FICA risk rate document - complete FICA risk rate document - not complete 2 year re-verification done 2 year re-verification not on file Additional risk requirements Additional risk requirements - not on file

  • Not applicable
  • ID - verified and dated
  • ID - not verified/ dated
  • Proof of address - verified
  • Proof of address - not verified/dated
  • FICA risk rate document - complete
  • FICA risk rate document - not complete
  • 2 year re-verification done
  • 2 year re-verification not on file
  • Additional risk requirements
  • Additional risk requirements - not on file

• FICA verification is signed and dated, and less than 2 years, with a process in place to re-verify at least once every 2 years:

  Yes

  No

  Needs attention

• Reporting is done at least quarterly, in accordance with the Mandate

  Yes

  No

  Not Applicable

• Correspondence/ File notes/ Records of engagement

  Select Complete and comprehensive Complete but requires more detail Not compliant and requires addressing and monitoring Not applicable - no analysis was required Evident from the record of advice/ engagement Existing client - ongoing analysis

  • Complete and comprehensive
  • Complete but requires more detail
  • Not compliant and requires addressing and monitoring
  • Not applicable - no analysis was required
  • Evident from the record of advice/ engagement
  • Existing client - ongoing analysis

• Documents are correctly and comprehensively completed 1-not at all 10- Perfect!

• Product due diligence complete

  Yes

  No

  Needs attention

• Describe the process of ensuring that the Mandate is complied with. If there are any breaches, provide details on what these were as well as how they were addressed

• Has a system of feedback from customers been implemented to identify any problematic areas?

  Yes

  No

  Needs attention

• Notes/ Comments

SIGNATURE:

• COMPLIANCE

  Sign