INTRODUCTION

  • Title

  • REVIEWS COMPLETED:

  • NAME OF FSP:

  • FSP no.

  • Conducted on:

  • This report was prepared by

  • Location
  • PRESENT:

PROCEDURE

COMPLIANCE AND RISK MANAGEMENT IN RESPECT OF YOUR FSP

  • TO: THE KEY INDIVIDUALS AND GOVERNING AUTHORITY

    The content of this report is based on our findings of work performed during the period under review, and includes assessment of documentation, sampling and onsite verification. The report should be read in the context of any contemporaneous notes, as well as email correspondence relating to the specific themes.

  • The areas covered during the period under review include your adherence to compliance obligations imposed by the FAIS Act, as well as anti money laundering legislation.

    Every quarter, you are provided with a workflow in respect of compliance obligations for such period, to be completed monthly. It is expected that you follow this workflow and record all requirements in your compliance file, so that when we conduct our monitoring, evidence and sampling is easily accessible and in one place.

    Where you supply us with the completed monthly tasks and verification in advance, this allows us to spend more time on value add and assistance with your risk register discussions when we conduct our onsite verification.

  • When we conduct our compliance monitoring, we will be assessing:
    1. The compliance risk
    2. Whether policies and procedures have been adopted to address this risk
    3. The effectiveness of these policies and procedures as a control

    In other words, unless there is sufficient evidence of the adequate implementation and monitoring of the area in question by you, as the FSP, we are required to note the area as deficient.

    Our purpose is to assist you to a degree whereby we believe you have adequate measures in place to address compliance risk whilst still ensuring productive business function and efficiency. Compliance is intended to add to your efficiency and bottom line, not detract from this.

  • Included in our process is a focussed, risk based guidance session, during which we will be assisting you in the identification of risk areas in your business, rating these risks, and adopting strategies to deal with these risks which are practical, real and applied immediately within the business.

    You will be provided with an aspect of risk management, which is discussed, debated, SWOT analysed, and tools and templates provided to help address such risks. Your risk management records should be kept in a safe place, as they now become a living document for use within your business.

    At each engagement, we will build on this, ensuring that you are provided with a valuable tool, as well as the support and guidance which may be required, in respect of risk mitigation in general.

P1701

  • P1701

  • DATE:

COMPLIANCE REVIEW FOR THE FIRST QUARTER OF 2017 - SEPTEMBER 2016 - NOVEMBER 2016

  • 2017 compliance monitoring will be focussing to a large extent on assisting you to adopt, implement and apply the policies, processes and controls required from a financial services provider, as well as provide guidance on your risk identification, recording and management.

    Risk management does not entail the mere adoption of policy, without the alignment of this with your business strategy, your risk management plan, and incorporating these into your standard operating procedures with the appropriate controls. As such, at every engagement, we will be focussing on reviewing your risk plan and effectively assist you in identifying both risk and risk controls which may be required in your business.

  • Our process is as follows:
    We provide you with your workflow quarterly in advance, and will be reviewing these requirements in the quarter following. Our meetings focus on assessing the extent of your compliance in these predetermined areas, addressing any concerns and assisting you where required. it is incumbent on you to address any non-compliance and ensure we are notified of amendments, and measures taken to rectify these risks.

    We cannot implement and address the workflow for you. This remains your responsibility and the responsibility of your Governing Authority. Failure to address compliance risk places your business at risk of Legislative, Financial and Reputational penalties, which are unnecessary and unproductive. We strongly urge you to complete your workflow and send this to us on a monthly basis so that we can review these prior to our onsite monitoring and assessment, in order for you to reap the most benefit from these reviews.

    Should you need assistance in any of the tasks, please contact our offices and we will assist where possible.

COMPLIANCE CONCERNS WHICH REQUIRE YOUR ATTENTION

  • ANY UNRESOLVED MATTERS FROM PREVIOUS REPORTS, ANNUAL OR OTHER

  • DETAILS:
  • NON-compliance:

  • RESPONSIBLE PARTY:

  • :-

  • ACTION:

  • DUE DATE:

  • FEEDBACK/ VERIFICATION REQUIRED:

  • REVIEWED:

  • STATUS

  • Compliance matters which remain unresolved place your firm at risk. Please ensure any area which remains a compliance concern is addressed or the matter may have to be reported to the Regulator.

    Any material non-compliance is required to be reported, regardless of whether it is in the process of being addressed or not, and may lead to penalties or regulatory action. Please contact our offices should you require assistance or have any questions as to what is expected.

FSP INFORMATION AND VERIFICATION

  • You are requested to compile a comprehensive record of business and management information to be added to your compliance file. This was discussed with you.

    1. Your information register for the purposes of identifying any profile changes which may require action
    2. Your information register for the purpose of identifying key roles within your FSP and the responsible persons
    3. Information relating to the background, history and nature of the FSP as well as general business function
    4. Source information in respect of any required registrations and renewals of these, or reporting required, for the purpose of compiling your compliance calendar
    5. General information relevant to the compliance monitoring function

PROFILE CHANGES

  • Have all changes to any business information (bank account/auditor/representatives/directors/shareholders etc.) been identified and forwarded for updating at the FSB within the required 15 day period

  • Please ensure that all profile changes are addressed within 15 days of such change occurring. A copy of the requirements for various changes is available from the compliance practice offices on request

  • Updates or Information in respect of any profile changes:

  • Details:

DOCUMENT / FILE AUDITS

  • Emphasis will be placed on conducting file/ document audits and ensuring these are correct and in order. The results of this will be appended to the report. Where we note non-compliance areas which are a concern, we may conduct further reviews and require additional samples.

    You are requested to ensure that any areas which may be identified as risk areas are attended to and that our offices are informed once this has been finalised.

  • GENERAL NOTES:

NOTES:

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  • P1701 - COMPLIANCE OFFICER

P1702

  • P1702

  • DATE:

COMPLIANCE REVIEW FOR THE SECOND QUARTER OF THE 2017 COMPLIANCE YEAR - DECEMBER 2016 THROUGH FEBRUARY 2017

  • This content of this report focusses on assessing compliance with the workflow provided in respect of the first quarter of the 2016 compliance year. Additionally, we will be addressing the next section of the RISK REGISTER and review the requirements of last quarter

ADVERTISING AND MARKETING

  • The FSP advertises its financial services (including websites)

  • The FSP has a documented advertising policy which has been approved by the Governing Authority, and is implemented within the FSP

  • EVIDENCE ATTACHED:

  • Advertising must comply with Section 14 of the General Code of Conduct, as well as the Regulations to the FAIS Act.
    Where an FSP conducts advertising, a drafted policy as well as approval process is required to ensure that this area is being risk managed and monitored for compliance with these requirements.

    Please ensure that you update your non-compliance register, update your risk register and ensure the matter is rectified.
    Once the policy and process has been approved, and implemented within your FSP, please forward a copy to our offices as verification of the task being addressed.

  • A responsible person has been identified to assume responsibility for advertising approval and the register of roles updated

  • Email signatures, websites, business cards and/or other advertising has been reviewed and approved

  • All advertising must be approved in terms of the internal advertising policy of the FSP. This needs to be evident and recorded.
    Please ensure your non-compliance register is updated.
    Please ensure your risk register is updated.
    Please forward the compliance practise evidence of this matter being rectified once it has been addressed.

  • Attach:

ANTI MONEY LAUNDERING

  • It is important that there is a clear and demonstrable process for confirming compliance in this area. Anti- money laundering legislation in terms of reporting applies to all businesses, regardless of industry, however, our review will be focussing on the compliance requirements of accountable and reporting industries only.

  • The FSP is an accountable and/or reporting institution

  • All AML (FICA) registrations are correct

  • FICA REG. NUMBERS:

  • S43 MLCO NAME AND ID:

  • Ensure that all registrations are correct and complete on the FIC website - www.fic.gov.za. Obtain your registration number and details, and ensure these are kept in your compliance manual

  • Section 43 MLCO appointment form is complete, signed and on record, together with a copy of ID

  • EVIDENCE:

  • The MLCO has reviewed his duties and responsibilities and updated the training register accordingly, or otherwise confirmed this review.

  • EVIDENCE:

  • The responsibilities of the MLCO (S43 Money Laundering Compliance Officer) must be assumed and executed with diligence and authority, and with the respect due its significance.

    Non-compliance in respect of money laundering activities carry severe penalties, inclusive of large fines and imprisonment.
    Please update your non-compliance register.
    Please update your risk register.
    Please ensure this is addressed as a matter of priority and that confirmation is forwarded to our offices.

  • EVIDENCE

  • The FSP has adopted, implemented and trained all staff on its Anti Money Laundering Policy and Process, and updated its registers with details on what was trained, how it was trained, and how understanding was established.

  • EVIDENCE:

  • The FSP's AML policy and rules must be adequately documented, adopted by the Governing authority, and implemented.

    The Financial Intelligence Centre Act (FICA) requires accountable institutions to have applicable FICA Rules, and processes in place to ensure that customers are identified (KYC), that appropriate reporting procedures are in place, that records are retained for a period of at least 5 years, and that all staff are properly trained on this. Please ensure that you address this matter as non-compliance carries severe penalties (up to R10 Million and/or 5 year imprisonment for not training).

    Please update your non-compliance register.
    Please update your risk register - this is a MATERIAL risk!
    Please ensure this matter is addressed and our offices provided evidence of this as a matter of priority.
    Failure to address this within a reasonable period will result in our offices having to notify the Regulator.

  • AML - Identification and verification procedures are being followed, with documents being dated and signed by the verifier, and clients risk rated in terms of potential money laundering activities (client acceptance procedures)

  • EVIDENCE:

  • All FICA reporting has been done as required and records of this securely and confidentially retained. Where no reporting is required, this has been noted.

  • EVIDENCE:

BUSINESS INFORMATION

  • The business information register is being completed and provided to our offices. A copy is on file and is being used to monitor any possible profile changes

CLAIMS - TCF PILLAR 6

  • The FSP provides clear information which is easy to understand, including the process to institute a claim

  • EVIDENCE:

  • It is important to ensure this matter is addressed and that clients do not face any post sale barriers to claim. Please provide confirmation of compliance to our offices once you have rectified this.

COMPLAINTS

  • TCF Pillar 6 requires that every FSP adopt a clear, unambiguous and accessible complaints policy and process, to ensure that customer complaints are managed fairly and effectively. Root cause analysis provides valuable management information which allows the FSP to implement procedures to avoid similar complaints, and this needs to be completed regularly, with full evidence of any remedial action taken to prevent any re-occurrence.

  • The FSP has an updated, approved complaints policy, aligned to TCF, supplemented by an appropriate complaints process. This includes the ability to draw management information in respect of type of complaint, against whom, root cause analysis etc. to identify complaint trends and areas for improvement, and take action where necessary. <br><br>The register of roles has been updated with the appropriate complaints officer details.<br>

  • The FSP is to ensure that this is addressed and that it drafts, adopts, implements and trains all staff on its complaints policy and process.

  • EVIDENCE:

  • All staff have been trained on the complaints policy and are aware of where to access the policy, to whom complaints should be forwarded, and the process which is followed should there be any complaint.

  • EVIDENCE:

  • All staff need to be aware of the FSP's complaints policy and process, how to identify a complaint and where to find the business policy. The process of routing a complaint to the right person should also be firmly entrenched.
    Please update your non-compliance register
    Please update your risk register
    Please ensure this is addressed and confirmation of compliance forwarded to our offices.

  • Where complaints have been received, the RFC (recommendation following complaint) has been completed, as well as all information in respect of the complaint, in the correct format.

  • EVIDENCE:

  • Where a complaint is received, it is important that this be addressed in compliance with the FSP's internal complaints policy, and the Outcomes of TCF 6. Information should be assessed to determine the root cause of the complaint as well as identify any areas which may require attention, such as training, process adjustment etc. and the necessary actions taken. Full records must be retained of the process followed, any causes identified, and actions taken to avoid a repeat of the problem.

CONFLICT OF INTEREST

  • THE FSP has a current, up to date, correct and approved conflict of interest policy which is being applied in the business, and upon which all staff have received training. This policy should be reviewed annually and updated in respect of:<br>1. Any interests, shareholding, directorships etc in any other FSP or product supplier<br>2. More than 30% of income from a single provider<br>3. Referral fee agreements <br>And any other actual or perceived conflict of interest situations. All staff should be trained on their responsibilities and adequate monitoring implemented to ensure the R1 000 annual limit is not exceeded.

  • Attach Policy /Training register/ Gifts Register

  • The FSP is to ensure that this is addressed and that it updates and implements the correct conflict of interest policy and process and that all staff are trained on this. All gifts are to be logged in the "Gifts Register" which must be monitored on a monthly basis to ensure compliance.

CONTRACTS WITH 3RD PARTIES

  • The FSP has records of all contracts with 3rd parties, including product suppliers, securely stored and accessible if required. A register has been compiled with the contracts held and applicable management information noted.

  • EVIDENCE:

  • The FSP is to ensure it retains signed copies of all contracts with 3rd parties, and stores these for when they may be required. Contracts should be regularly reviewed and assessed in terms of TCF.

DIRECT MARKETER

  • The FSP is a direct marketer

  • The FSP is registered as a Direct Marketer with the Regulator

  • A profile change request must be sent through requesting that the information held by the Regulator be updated

  • EVIDENCE:

  • Direct Marketing Records: - Confirm there is:<br><br>1. Proper voicelogging in place<br>2. Records are adequate stored and easily retrievable<br>3. Records are regularly backed up<br>4. There is an SLA with the system provider

  • EVIDENCE:

  • This needs to be addressed as a matter of priority as it constitutes a material transgression. Voicelogging, record retention and the retrieval of records is critical for any direct marketer.

    Please ensure:
    1. Your non-compliance register is updated
    2. Your risk register is updated
    3. The areas requiring attention are addressed and confirmation of this forwarded to our offices

  • Telephone marketing is done

  • Confirm telemarketing has:<br><br>1. Scripts approved before implementation<br>2. Calls monitored to ensure script compliance<br>3. Recordings quality assured and the process recorded<br>4. Non-compliance addressed

  • EVIDENCE:

  • Ensure that this matter is addressed as a matter of priority, and compliance confirmed within 2 weeks.

DISCLOSURES

  • The FSP has verified that all disclosures and disclosure documents are correct. There is a process to ensure that disclosures are made as required by the general Code of Conduct and this has been recorded.

  • All FSP's must ensure that their disclosures comply with the requirements of applicable codes of conduct. Please ensure that this matter is addressed and confirmation provided to the compliance practise. Please also ensure that:

    1. Your non-compliance register is updated
    2. Your risk register is updated
    3. A process is implemented to ensure that this will not be a risk area going forward.

  • EVIDENCE:

FINANCIAL

  • Financial records are being completed and brought up to date monthly, as required by Section 19 of the FAIS Act. These confirm:<br><br>1. Financial soundness requirements are understood<br>2. The FSP's assets exceed its liabilities<br>3. The business current assets exceed current liabilities<br>4. Liquidity requirements are compliant

  • EVIDENCE:

  • The FSP is to ensure that all financial records are compiled and brought up to date monthly, and that confirmation of this is provided to the compliance practice within 15 days.
    Any non-compliance areas must be addressed.
    Risk register to be updated.
    Non-compliance register to be updated.

FIT AND PROPER

  • Fit and Proper confirmations are on record, confirmed in the last quarter, for all:<br><br>1. Directors, members, Trustee, Partner<br>2. Key Individuals<br>3. Representatives

  • The FSP is responsible for ensuring that all applicable persons are, and remain Fit and Proper. A process is required whereby this is verified on a regular basis and evidence placed on record of this verification. Please ensure this is addressed and proof provided to the compliance practise. Please also ensure that:

    1. Your non-compliance register is updated
    2. Your risk register is updated
    3. processes are implemented to avoid further non-compliance going forward

  • EVIDENCE:

KI ROLES AND RESPONSIBILITIES

  • The FSP has at least one KI appointed for every product category. This is recorded in the FSP business information as well as the register for KI's and Representatives

  • This is a material non-compliance are which requires immediate attention.
    Risk register to be updated
    Non-compliance register to be updated

  • The FSP has more than one KI:

  • The FSP has appointed each KI in terms of clearly defined areas of accountability, authority and responsibility, whether this be general, geographical, product category etc. This is clearly recorded and each KI is aware of their role.

  • EVIDENCE:

  • Please ensure this is addressed and that evidence of the matter being rectified is forwarded to our offices.
    Please update your risk register

LICENCE DISPLAY

  • The FSP has a certified copy of its licence, or the original, displayed prominently and durably at every premises. The licence must be immediately visible.

  • EVIDENCE:

MONITORING

  • THE FSP has a recorded monitoring process, which is being applied, and which monitors financial services. This includes:<br><br>1) what will be monitored<br>2) how monitoring occurs and is recorded<br>3) frequency of monitoring<br>4)non-compliance action<br><br>All applicable staff are aware of this and are implementing

  • The FSP must ensure that it addresses the requirement of a monitoring process, to ensure that financial services are provided efficiently, fairly and compliantly. Such a process allows the FSP to identify any risks which may impact on itself, its customers or any other stakeholder, and address these

  • Detail:

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RECORDS

  • The FSP has a documented back-up policy and procedure for electronic records which is implemented.<br>Backups are regularly done and the back-up register updated<br>Backups are periodically tested and the results of this testing noted

  • Where electronic records are held (including financials, emails etc.) there is a requirement that these be adequately secured and backed up. Please ensure this is addressed and evidence provided to the practise. Please also:

    1. Update your non-compliance register
    2. Update your risk register
    3. Ensure processes are implemented to address this risk going forward

  • EVIDENCE:

  • The FSP has an approved, implemented policy and procedure for the storage and security of records, as well as confidentiality.<br>All staff have been trained on the requirements, and spot checks have been done to assess compliance.

  • The retention of records needs to be controlled, and executed in accordance with prevailing legislation. Please ensure this matter is addressed and that evidence of this is forwarded to the compliance practise. Please also ensure that you:

    1. Update your non-compliance register
    2. Update your risk register
    3. Ensure processes are implemented to address this risk going forward

  • EVIDENCE:

REPRESENTATIVE APPOINTMENT AND DOFA

  • The FSP has a documented process to ensure that any representative appointed, is done so in accordance with an appropriate procedure which includes a due diligence, DOFA monitoring, a drafted agreement, and adequate verification. Supporting documentation of this should be on record.

  • Any FSP who appoints a representative must do so in accordance with Section 13 of the FAIS Act. it is ultimately the responsibility of the FSP to conduct an adequate due diligence to confirm the Fit and Proper status of a representative, both at appointment, as well as after. Sufficient records are required to provide evidence of this.

RISK

  • The FSP has identified its Regulatory Universe. The Regulatory Universe is applicable legislation which impacts the business, and which should be risk rated, for inclusion in the FSP's risk plan.

  • As a risk based approach to compliance is adopted, the first step to the compilation of an appropriate risk plan is the identification of the FSP's Risk Universe. Please ensure this is addressed and documented, with critical legislation being identified. Please provide the compliance practise with evidence of this being addressed and ensure that you:

    1. Update your non-compliance register
    2. Update your risk register

  • EVIDENCE:

  • The FSP has an approved, applicable risk plan and register, with motivation on how risks are identified, rated, addressed and actioned

  • An appropriately drafted practical risk plan is a requirement in terms of the operational ability requirements for every FSP. Please ensure this is addressed as a priority and that proof is provided to the compliance practise. Please also ensure that you:

    1. Update your non-compliance register
    2. Update your risk register
    3. Ensure processes are implemented to address this risk going forward

    Your risk register should be regularly updated with identified and treated risks

  • EVIDENCE:

SERVICES UNDER SUPERVISION

  • The FSP has persons who are rendering services under supervision

  • Supervision records are complete and on file, and adequately completed. Each representative under supervision has a supervision file, with the following content:<br><br>- Signed supervision agreement<br>- Details of supervisor/s, experience, position in FSP, details of working relationship with supervisee<br>- Details of supervisee, experience, qualifications, starting date<br>- Training plan and records, including DOFA dates and monitoring<br><br>Records of: <br><br>(1) Monitoring activities<br>(2) The criteria applied in assessing competence; and <br>(3) How and when the “competence decision” was arrived<br>(4) Performance appraisals (the supervisor must conduct performance appraisals/ progress assessments of the representative, to help the representative learn the necessary skills to function independently.)

  • This area requires attention. Supervision processes must be followed, and full supervision records kept to prove this. Please ensure these are brought up to date.

    Failure to maintain proper records can be seen as a failure to supervise - this places the business at risk and requires addressing as a matter of priority.
    Where there is a break in the supervision period, or where there is a gap in recordkeeping / supervision, this period will have to be added to the end of the term, which means that this will then be extended.

  • EVIDENCE:

TCF

  • TCF Pillar 1 - CULTURE:
    The Key Individual must ensure compliance with Outcome 1 of TCF:
    □ Is TCF written into your organisation’s stated values/aims/ policy?
    □ Is the TCF message affirmed/communicated to staff by senior management?
    □ Has your staff received information and/or training in the principle of TCF?
    □ Can you measure staff’s understanding of TCF?
    □ How have your training and competency requirements developed to implement TCF?
    □ How have you included the Treating Customers Fairly Self Assessment Tool (TCF) into the way you run your business and your firm’s values?
    □ Could you provide records to confirm the above?
    □ Is any element of staff remuneration in your organisation related to treating customers fairly?
    □ Do you have a TCF staff awards programme?
    □ Do you have service standards that encourage TCF?

  • TCF PILLAR 1 has been assessed and there are records of this. TCF Pillar 1 has been effectively implemented in the FSP and a culture of treating customers fairly is evident, with sufficient management information on record to prove this

  • AS TCF is an inherent part of how any FSP should be conducting business, it is important to ensure that every Pillar is addressed. The FSP should review its TCF implementation and ensure compliance, and the implementation of the correct ethic. It is essential that there be sufficient evidence and management information which can successfully confirm compliance.

  • EVIDENCE:

  • TCF training: All staff have been trained on TCF, and their understanding confirmed.

  • TCF PILLAR 2:

    □ How do you ensure you and your representatives properly understand the product you are offering to your customers
    □ How do you assess if financial promotions are clear, fair and not misleading
    □ How do you assess whether product information is appropriate for your customer
    □ How often is product material and information reviewed and if so, by whom?
    □ What steps are taken to ensure material is understandable by the target audience?
    □ What process do you have for approving a financial promotion?
    □ How are customer queries and complaints used to improve or stop financial promotions?
    □ Do you have secure retrievable records of all product information provided to customers?

  • THE FSP has reviewed the requirements and has adequate records to confirm compliance

  • TCF Outcome 2 needs to be assessed for applicability within the FSP, and addressed. There needs to be sufficient management information on record to confirm this. Please ensure this is attended to ad confirmation forwarded to the compliance practise.

  • EVIDENCE:

PROFILE CHANGES

  • Have all changes to any business information (bank account/auditor/representatives/directors/shareholders etc.) been identified and forwarded for updating at the FSB within the required 15 day period

  • Please ensure that all profile changes are addressed within 15 days of such change occurring. A copy of the requirements for various changes is available from the compliance practice offices on request

  • Updates or Information in respect of any profile changes:

  • Details:

  • General Notes:

GENERAL NOTES AND COMMENTS:

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  • P1702 COMPLIANCE OFFICER SIGNATURE:

P1703

  • P1703

  • DATE:

COMPLIANCE REVIEW FOR THE THIRD QUARTER OF THE 2017 COMPLIANCE YEAR - MARCH 2017 THROUGH MAY 2017

  • This content of this report focusses on assessing compliance with the workflow provided in respect of the second quarter of the 2017 compliance year. Additionally, we will be addressing the next section of the RISK REGISTER and review the requirements of last quarter

ANTI MONEY LAUNDERING

  • All AML processes are implemented as required and all FICA reporting has been done as required. Records of this securely and confidentially retained.<br><br>This includes:<br>1) Threshold transactions - 2 days<br>2) Terrorist financing and property - 5 days<br>3) Suspicious and Unusual transactions - 15 days. <br><br>MLCO to check financial statements for cash/ suspicious transactions<br>MLCO reporting register to be maintained by MLCO (confidential)

  • EVIDENCE:

  • Reporting in terms of AML is essential, and any non-compliance poses a material risk to the FSP. This must be addressed as a priority, and all reports brought up to date. Please also ensure:

    1. Your non-compliance register is updated
    2. Your risk register is updated
    3. processes are implemented within the business to ensure that there is no further contravention

    Sufficient evidence of this must be provided to the compliance practise.

COMPLAINTS

  • The complaints register is up to date with all complaints against the FSP or staff and there is sufficient evidence of the risk being mitigated. There is sufficient evidence that this is being monitored (even if there are no complaints) and that management information is assessed to note root cause analysis and to track complaint trends, and take action where necessary.

  • EVIDENCE:

  • This needs to be addressed, to ensure compliance with Outcome 6 of TCF. Sufficient records need to be maintained to confirm compliance. Please ensure that you rectify this matter and provide evidence to the compliance practise.

    1. Non-compliance register to be updated
    2. Risk register to be updated
    3. Processes to be implemented to ensure that this risk is mitigated

COMPLIANCE

  • Compliance is integrated into the risk management of the FSP. Reports are provided to the governing authority and actioned as and when required

  • Attach:

  • The compliance programme is integral to the FSP's risk management. The Governing Authority remains ultimately accountable, together with the Key Individual, for ensuring and directing the FSP in respect of compliance obligations. TCF Outcome 1 requires a culture of compliance and this is required to be evident, and equally important, is for the Governing Authority to be aware of all risks to the business. Please ensure this is addressed and evidence of this provided to the compliance practise.

CONFLICT OF INTEREST

  • Any COI situations (including gifts) are: <br><br>1. Noted in client engagement documents<br>2. Gifts and COI register current and complete <br>3. Any required reports are being forwarded to the Governing Authority

  • EVIDENCE:

  • Section 3A of the General Code of Conduct governs conflicts of interest. Please ensure that you address this as a priority and that you provide the compliance practise with evidence of the matter being finalised. Please also ensure that you:

    1. Update your non-compliance register
    2. Update your risk register
    3. Implement processes and controls to mitigate and address this risk going forward

DEBARMENT

  • The FSP has an approve debarment policy and procedure, aligned to its internal HR Procedures.<br>Ensure that the FSP Disciplinary Code includes debarment-related offences and failure to comply with material requirements of the FAIS Act and reasons for this. Further confirm that the internal performance management is actively implemented, that all employees are aware of this.

  • This area requires attention. Please ensure that non-compliance is rectified and evidence provided to the compliance practise. Ensure that:

    1. Your non-compliance register is updated
    2. Your risk register is updated
    3. processes are implemented to avoid a repeat of this risk area

  • EVIDENCE:

DIRECT MARKETING

  • The FSP is a direct marketer

  • Confirm any new telemarketing has had scripts signed off before implementation.<br>Ensure that recordings are quality assessed, the QA process recorded, and any non-compliance addressed.

  • EVIDENCE:

  • Where direct marketing happens, written confirmation of requirements/ disclosures are forwarded to customers within 30 days of the transaction

  • EVIDENCE:

DOFA MONITORING AND REMEDIAL ACTION

  • The FSP has representatives

  • The FSP has an effective process for monitoring representative Fit and Proper requirements, aligned to the dates of first appointment of such representatives. (DOFA)<br>

  • EVIDENCE:

  • This is an area which should be addressed as a priority, and the FSP is at risk. Please ensure that the identified non compliance is addressed and that evidence of this is provided to the compliance practise. Please also ensure that:

    1. Your non-compliance register is updated
    2. Your risk register is updated
    3. processes are implemented to avoid a repeat of this risk area

  • Confirm that any KI's or REPS who should be/ have been debarred/ removed in the preceding or following month(s) have been debarred/ removed, as result of any of the following and that the Register of Representatives and Key individuals is correct and up to date.<br><br>(1) Qualification not achieved by due date - DEBARMENT<br>(2) RE exams not passed by due date - DEBARMENT <br>(3) Honesty and Integrity issues - DEBARMENT<br>(4) Resignation - REMOVAL

  • EVIDENCE

  • This is an area which should be addressed as a priority, and the FSP is at risk. Please ensure that the identified non compliance is rectified as a priority and that evidence of this is provided to the compliance practise. Please also ensure that:

    1. Your non-compliance register is updated
    2. Your risk register is updated
    3. processes are implemented to avoid a repeat of this risk area

FINANCIAL

  • The FSP has processes implemented to ensure it checks its financial soundness and remains financially sound

  • NON-COMPLIANCE! This is a critical area requiring compliance and is an area where a report to the Regulator is required unless immediately addressed. Please note that urgent and immediate attention is required. Please ensure that:

    1. Your non-compliance register is updated
    2. Your risk register is updated
    3. Processes and controls are implemented to ensure there is no future non-compliance in this area

    Evidence of this is to be forwarded to the compliance practise.

  • EVIDENCE:

  • The FSP collects or holds premium:

  • Premium/ client funds are collected/ held in respect of investment or long term

  • SHORT TERM INSURANCE PREMIUMS are held in accordance with Section 45 of the Short Term Insurance Act as well as the requirements of the FAIS Act:<br><br>1. There is written authorisation from the product supplier to collect premium<br>2. IGF or a guarantee is held<br>3. PI of a minimum of R1 000 000<br>4. Fidelity insurance of a minimum of R1 000 000<br>5. Auditor appointed<br>6. 4/52 weeks liquid assets in place<br>7. Any cash received - receipted<br>8. FSB notes FSP as receiving premium

  • EVIDENCE: AUTHORISATION FROM SUPPLIER TO COLLECT PREMIUM REGISTRATION AS PREMIUM COLLECTION AT FSB AUDITOR APPOINTMENT AT FSB/ CIPC

  • EVIDENCE: PI AND FIDELITY INSURANCE IGF/ GUARANTEE (please also send these certificates to the compliance practise per mail)

  • EVIDENCE: LIQUID AND SOLVENT 4/52 WEEKS LIQUIDITY IN PLACE

  • LONG TERM PREMIUMS are held in accordance with the requirements of the FAIS Act:<br><br>1. PI of a minimum of R1 000 000<br>2. Fidelity insurance of a minimum of R1 000 000<br>3. Auditor appointed<br>4. 4/52 weeks liquid assets in place<br>5. Any cash received - receipted<br>6. FSB notes FSP as receiving premium<br>7. Separate bank account

  • EVIDENCE: REGISTRATION AS PREMIUM COLLECTION AT FSB AUDITOR APPOINTMENT AT FSB/ CIPC

  • EVIDENCE: PI AND FIDELITY INSURANCE SEPARATE BANK ACCOUNT (please also send these certificates to the compliance practise per mail)

  • EVIDENCE: LIQUID AND SOLVENT 4/52 WEEKS LIQUIDITY IN PLACE

  • MATERIAL NON-COMPLIANCE! This is a critical area requiring compliance and is an area where a report to the Regulator is required. Please note that urgent and immediate attention is required.

  • Financial Information integrity is preserved through access control, password protection and verification <br>Full back ups of financial records are kept regularly<br>

  • Integrity of financial records must be preserved and it is therefore important for an FSP to implement appropriate measures to ensure this. Please ensure this matter is addressed as a priority and ensure that:

    1. Your non-compliance register is updated
    2. Your risk register is updated
    3. processes are implemented to avoid a repeat of this risk area

    Evidence of this to be provided to the compliance practise.

  • EVIDENCE:

KEY INDIVIDUAL

  • The Key Individual is adequately monitoring the financial services of the FSP, in accordance with an adequate process and with sufficient recording to evidence this. NOTE DETAILS OF THIS

  • EVIDENCE: MONITORING POLICY PROCESS MONITORING RECORDS

PROFESSIONAL INDEMNITY

  • The FSP has reviewed its PI and noted the reasons for establishing the amount in the business information report

RECORDS

  • Records are being stored securely and confidentially. Controls are in place to ensure that no information may be left lying on desks, and no open screens are exposed where information security is compromised, and there should be no access to records for unauthorised persons. <br><br>This includes ensuring that when information is removed from the premises, that sufficient safeguards are in place to ensure confidentliality and security

  • ATTACH

REGISTERS

  • Section 18 of the FAIS Act requires:
    Records are kept for five years of the following, and all required records are being brought up to date regularly, and are available for inspection:

    □ Register of known premature cancellations
    □ Register of complaints as well as how these were dealt with/ resolved
    □ Register of representatives and key individuals
    □ Register of non- compliance and reasons for this, as well as actions taken to rectify non - compliant areas
    □ Non - cash incentive/ conflict of interest/ gifts register
    □ Training register reflecting all training in the organisation - FORMAL AND INFORMAL

    REGISTERS OF BACKUPS BEING DONE AND TESTED
    Records of monitoring and ensuring the ongoing compliance of representatives

    a) Premature cancellation Register: known premature cancellations of transactions or financial products by clients of the provider;
    b) Complaints Register: complaints received, details, whether or not any such complaint has been resolved;
    c) The continued compliance with the requirements referred to in section 8;
    d). Non-compliance Register: cases of non-compliance with this Act, and the reasons for such non -compliance; and
    e) The continued compliance by representatives with the requirements referred to in section 13(1) and (2).

  • REGISTERS - REPLACEMENT/ EARLY TERMINATION<br><br>□ Register of known premature cancellations/ replacement - If a customer has requested to cancel their relationship with you, or where a replacement is done, you have records of:<br><br>1) Reasons in the early termination register so that you can fix any potential problems going forward<br>2) Complied with their request<br>3) Verify that the customer has been notified in writing and understands all the implications of the

  • EVIDENCE ATTACHED:

  • REGISTERS - NON COMPLIANCE<br><br>□ Register of known non-compliance, as well as how this was addressed

  • EVIDENCE ATTACHED:

  • RECORDS - FIT AND PROPER<br><br>□ Records of continued fit and proper (DOFA monitoring/ Fit and Proper confirmation)

  • EVIDENCE ATTACHED:

  • REGISTERS - NON CASH INCENTIVES AND GIFTS<br><br>□ Non - cash incentive/ conflict of interest/ gifts register

  • EVIDENCE ATTACHED:

  • REGISTERS - TRAINIING<br><br>□ Training register reflecting all training in the organisation are updated. This includes both formal and informal training (such as systems or product training)

  • EVIDENCE ATTACHED:

  • REGISTERS/ OTHER CONTROL - DOCUMENT VERSION CONTROL<br><br>□ Register of standard documents or other control used in ensuring compliance - information asset register. This will help with version control as well as a requirement for POPI

  • EVIDENCE ATTACHED:

REPLACEMENT

  • The FSP effects replacements

  • All applicable staff are trained in terms of their responsibilities with regards the Code on Replacement and this has been recorded.<br>

  • Ensure that all applicable staff are trained in terms of their responsibilities with regards the Code on Replacement and this has been recorded. Provide evidence to the compliance practise. Ensure that:

    1. Your non-compliance register is updated
    2. Your risk register is updated
    3. Processes and controls are implemented to ensure there is no future non-compliance in this area

    Evidence of this is to be forwarded to the compliance practise.

  • EVIDENCE:

  • The FSP has assessed the replacement advice record to ensure it remains compliant, and ensures that replacement records are being properly completed, stored and forwarded to the client, as part of the record of advice, as well as relevant compliance departments of replaced product providers where the replacement is a long term insurance product.

  • EVIDENCE:

REPRESENTATIVES

  • All representatives are appointed in terms of a written agreement

  • EVIDENCE:

SUCCESSION

  • The FSP has an appropriate, documented succession plan in respect of:<br><br>1. Key Individual replacement<br>2. Owner succession

  • EVIDENCE: TCF OUTCOME 1 IMPLEMENTATION TRAINING RECORDS

TCF

  • TCF OUTCOME 1:<br>Persons have been trained on TCF outcomes band how this impacts on them

  • EVIDENCE: TCF OUTCOME 1 IMPLEMENTATION TRAINING RECORDS

  • The FSP has considered the following and implemented controls and appropriate processes:<br><br>1. How compliance Is communicated to staff and the effective of this, or is additional training required. <br>2. How The FSP can confirm that customers have a good understanding of the services and products provided to them. <br>

  • EVIDENCE: TCF OUTCOME 1 IMPLEMENTATION TRAINING RECORDS

  • The FSP's performance is measured in terms of service level agreements with providers and actual feedback from the customers which must be obtained regarding services and products. The FSP regularly collects, combines, analyses and uses management information to ensure its processes deliver fair outcome for its customers<br><br> <br>

  • ATTACH:

  • TCF OUTCOME 3: The FSP has assessed the applicability of this outcome and implemented controls and records to ensure compliance. Full records of each of the following being assessed and mitigated, with appropriate controls, are on record and are being implemented.<br><br>The Key Individual must ensure compliance with Outcome 3 of TCF: <br>□ How do you ensure you understand the product you are offering to your customers?<br>□ How do you assess if financial promotions are clear, fair and not misleading?<br>□ How do you assess whether product information is appropriate for your customer?<br>□ How often is product material and information reviewed?<br>□ What steps are taken to ensure material is understandable by the target audience?<br>□ What process do you have for approving a financial promotion?<br>□ How are customer queries and complaints used to improve or stop financial promotions?<br>□ Do you have secure retrievable records of all product information provided to customers?

  • EVIDENCE:

  • Product information/ marketing material used is correct, easy to understand and appropriate for customers. Confirm this is presented in an informative and balanced manner and provide evidence of this being assessed and confirmed compliant<br> <br>

  • It is important for the FSP to have sufficient management information to be able to evidence compliance with the requirements of TCF. Review the requirements of the 6 Pillars and ensure these are complied with, integrated into the standard operating procedures of the FSP, and adopted into the culture of the Firm. Every Pillar requires demonstration, therefore it is important to ensure there are sufficient records for this.

  • EVIDENCE:

  • TCF OUTCOME 4:<br>The FSP has assessed the applicability of this outcome and implemented controls and records to ensure compliance. Full records of each of the following being assessed for applicability, and mitigated, with appropriate controls, are on record and are being implemented.<br><br>□ How do you assess whether or not the appropriate skills and business processes are in place to provide advice and service that will be suitable for the target market and product concerned<br>□ Have due diligence assessments been conducted on all product supplier (to satisfy ourselves that their products and service levels are likely to meet customers' reasonable expectations)<br>□ Do you insist that product suppliers provide representatives with adequate product training at least annually<br>□ How do you prevent representatives from providing advice on products where they do not have adequate product training<br>□ How do you ensure that you have access to product promotional material and technical information<br>□ Do you have a process for monitoring TCF standards amongst appointed representatives off-site<br>□ What criteria are used to determine sales person performance, bonus and promotion opportunities?<br>□ How has TCF been communicated to advisors and how is it measured in sales areas?<br>□ How clear are customer agreements, and what steps are taken to ensure the customer understands the services being offered?<br>□ What steps are taken to assess the suitability of services and how do these relate to the personal circumstances of the customer?<br>□ How do advisors ensure customers understand the risk and limitations of a product as well as its benefits?<br>□ What processes and checks are in place to ensure adequate records are kept of discussion and communication with customers?<br>□ What is the process where representatives have provided inappropriate advice or misleading information to customers<br>□ How are TCF indicators such as insurance claims experience, product retention / early termination data, investment portfolio switching, type and frequency of product changes etc. monitored to identify and mitigate risks of inappropriate advice or poor customer outcomes<br>□ What is the frequency and process of communication with product suppliers and other third parties in the customer value chain in respect of their products or services<br>□ What controls are in place to identify and address any conflicts of interest<br>□ How are poor sales practices and sales people identified?<br>□ What happens to advisers who fail to meet sales targets?

  • EVIDENCE:

SUPERVISION

  • The FSP has representatives under Supervision

  • There is an implemented, recorded supervision process which ensures that:<br><br>1. Appropriate supervisors have been identified<br>2. The supervision process is being followed properly - <br>3. Supervision contract on file <br>4. Weekly and Monthly records are being kept and are sufficiently comprehensive<br>5. The FSB website and all disclosure documents state that the person is under supervision<br>6. Monitoring of supervisor duties occurs, to confirm that the supervisor is complying<br>7. Skills are being transferred<br>8. The supervisor must conduct performance appraisals/ progress assessments of the representative, to help the representative learn the necessary skills to function independently.

  • EVIDENCE: Supervision agreement Supervision records Performance appraisal

  • DETAILS OF HOW SUPERVISOR IS MONITORED:

WAIVER OF RIGHTS

  • All persons have been trained on the requirement that clients may not be induced to waive any right or benefit and ensure documentation by clients confirm that clients are aware of their rights and confirm compliance.<br>

  • EVIDENCE: Waiver of rights policy or other documentation

  • TRAINING REGISTER:

  • The FSP is to ensure that all staff are properly trained on the requirement that clients may not be asked, or induced or in any way deprived of their rights. The training register is to be completed and forwarded to the compliance practice as confirmation of this.

PROFILE CHANGES

  • Have all changes to any business information (bank account/auditor/representatives/directors/shareholders etc.) been identified and forwarded for updating at the FSB within the required 15 day period

  • Please ensure that all profile changes are addressed within 15 days of such change occurring. A copy of the requirements for various changes is available from the compliance practice offices on request

  • Updates or Information in respect of any profile changes:

  • Details:

  • General Notes:

GENERAL NOTES AND COMMENTS:

  • Add media

  • P1703 - COMPLIANCE OFFICER

P1704

  • P1704

  • DATE:

COMPLIANCE REVIEW FOR THE LAST QUARTER OF THE 2017 COMPLIANCE YEAR - JUNE 2017 THROUGH AUGUST 2017

  • This content of this report focusses on assessing compliance with the workflow provided in respect of the THIRD quarter of the 2017 compliance year.

    We will be addressing the Annual Compliance Report and review the requirements of last quarter. This workflow will be assessed only as an overview as the main focus for this quarter is the completion of the Annual Compliance Report

CONTINUITY

  • The FSP has an updated disaster recovery plan (DRP) which has been:<br><br>1. Approved<br>2. Tested<br>3. test results logged<br><br> <br>

TCF

  • TCF OUTCOME 5: PRODUCT PERFORM AS THE CLIENT EXPECTS:

    □ How and when are customers informed of the types of changes they may make to their products
    □ At what point are customers informed of any important limitations on their ability to access funds or make changes
    □ Can you provide evidence of how would you become aware of a change in a customer’s situation or circumstance (including affordability difficulties) and do you review premium payments?
    □ What is the process to assist customers at this stage and inform them of changes they may consider making to their products to meet their changed requirements
    □ Does your service level agreement have clear service standards in place for processing product changes
    □ Does the product supplier’s service level agreement have clear service standards in place for processing product changes
    □ Are these communicated to customers?
    □ Where a request for a product change is declined by any party in the value chain, how is the customer notified of the reasons?
    □ When a request to change a product is received, is the customer notified of any potential risks associated with the change in time for them to act on the information

  • Outcome 5 has been assessed and implemented within the FSP, with sufficient records to show this

  • General Notes:

GENERAL NOTES AND COMMENTS:

  • Add media

  • P1704 - COMPLIANCE OFFICER

CAT II

CATEGORY II FSP:

  • PERIOD UNDER REVIEW:

  • DATE OF REVIEW:

  • MANDATE COMPLIANCE
    Review the CAT II mandate for content and ensure that it is correct. A mandate may not be substantially changed without the approval of the Financial Services Board

  • The FSP mandate has not been amended in any way, in a substantial manner, without the prior approval of the Regulator

Notes and Actions

ACTION ITEMS - FSP (Action items should indicate what, by whom, and by when)

  • FSP REQUIRED ACTIONS:

  • DETAILS:
  • PERIOD UNDER REVIEW:

  • DATE:

  • RESPONSIBLE PARTY:

  • :-

  • ACTION:

  • DUE DATE:

  • FEEDBACK/ VERIFICATION REQUIRED:

  • REVIEWED:

  • STATUS

ACTION ITEMS - Compliance Practise (Action items should indicate what, by whom, and by when)

  • COMPLIANCE PRACTISE REQUIRED ACTIONS:

  • DETAILS:
  • PERIOD UNDER REVIEW:

  • DATE:

  • RESPONSIBLE PARTY:

  • ACTION:

  • DUE DATE:

  • FEEDBACK/ VERIFICATION REQUIRED:

  • REVIEWED:

  • STATUS:

COLLECTIONS/ DELIVERIES

  • Please ensure that all documents either collected/ delivered are fully completed and checked before receipted.

    PROFILE CHANGES - Incomplete documents cannot be collected/ delivered so please ensure that all the requirements are submitted as one, and that you retain copies of these for your records. All documents must be complete and signed where required. (A copy of these requirements (profile changes) and forms is available from the FSB's website (www.fsb.co.za) , as well as the compliance office on request.

  • DELIVERY OR COLLECTION
  • PERIOD UNDER REVIEW:

  • DATE:

  • DETAILS: Include to whom the delivery occurs plus details of what is delivered:

  • DELIVERY FROM COMPLIANCE

  • DELIVERY TO COMPLIANCE

  • RECIPIENT SIGNATURE

File Reviews and Audits

TYPE OF FSP

  • CLIENT CORRESPONDENCE AND FILES AUDITED: PERIOD:

  • This FSP is licenced as a:

  • Only intermediary services, and no advice is provided

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

  • 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

  • Notes:

  • Files Audited:
  • Name of Client

  • Disclosures correct

  • Services provided within the agreed SLA

  • Correspondence clear, correct and complete

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

  • NOTES:

  • PHOTO EVIDENCE

  • Add media

  • FILE AUDITS

  • FILE AUDITS

MOTOR DEALERSHIP

  • Name of Representative:

  • Transaction Date:

  • Name of client/file

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

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

  • Offer to Purchase - on file and correct and complete

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

  • Full Product and Fees disclosures - evident

  • Contract - Page 1 on file

  • Record of advice - correct updated version

  • Record of advice - complete, initialled every page

  • Cash deal / Cash deposit

  • FICA verification done

  • 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

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

  • 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

  • Drivers licence - correct, up to date, valid

  • Correspondence on file/ File Notes/

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

  • Documents are correctly and comprehensively completed

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

  • Evidence of KI checking - monitoring

  • Notes/ Comments:

  • Files Audited for compliance

  • Files Audited

File Audits CAT I - SHORT TERM

  • Name of Representative:

  • Date of Transaction:

  • Name of client/file

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

  • Disclosure document - is this the correct, updated document

  • Consent to obtain information/ Schedule provided<br>

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

  • Broker Appointment - on document/ application form or other

  • Full product and fees disclosures

  • Mandate/ Evidence of Instruction being provided by client

  • Information gathering in order for intermediary to perform analysis

  • Evidence of analysis

  • Quote signed and on record

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

  • Claims History - (short term)

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

  • RPAR - correct, complete, copy to client

  • Correspondence/ File notes/ Records of engagement

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

  • Evidence of KI checking/ assessing content, plus appropriateness

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

  • Notes/ Comments

  • Files Audited for compliance

  • Files Audited

File Audits CAT I

  • Name of Representative:

  • Date of Transaction:

  • Name of client/file

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

  • Consent to obtain information<br>

  • Disclosure document

  • Broker Appointment - on document/ application form or other

  • Mandate/ Evidence of Instruction being provided by client

  • Information gathering in order for intermediary to perform analysis

  • Evidence of analysis and risk assessment

  • Quote signed and on record

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

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

  • 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:

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

  • Full product features, risks and fees disclosures confirmed

  • RPAR - correct, complete, copy to client

  • Correspondence/ File notes/ Records of engagement

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

  • Evidence of KI checking/ assessing content, plus appropriateness

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

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

  • Notes/ Comments

File Audits - CAT II

  • Files Audited for compliance

  • Files Audited
  • Date of transaction:

  • Name of client/file

  • Disclosure document is correct and includes Section 13 certification?

  • Consent to obtain information<br>

  • Intermediary appointment on file

  • CAT II mandate on file, complete and signed

  • CAT II mandate is confirmed as the approved version

  • Was advice provided?

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

  • Information gathering in order for intermediary to perform analysis

  • Evidence of analysis and risk assessment

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

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

  • 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:

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

  • Correspondence/ File notes/ Records of engagement

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

  • Product due diligence complete

  • 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?

  • Notes/ Comments

SIGNATURE:

  • Compliance officer signature- P1701

  • Compliance officer signature- P1702

  • Compliance officer signature- P1703

  • Compliance officer signature- P1704

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