FAIS PRODUCT SPECIFIC AND CLASS OF BUSINESS TRAINING
With the advent of the new FAIS Fit and Proper amendments the Financial Services environment has been shaken up a bit. Due to the complex nature of the requirements and short deadlines many have been left in the dark as to what exactly they should do and how. As usual we aim to quickly tease out some of the basic elements of what is in store. If you need more in depth details please contact us for advice.
Product Specific Training
Product Specific training is intended to address the specific characteristics that differ from the general characteristics of products in the market. Product Specific training is usually provided by the FSP’s product supplier and must be done by KI’s and reps before rendering or overseeing financial services, as applicable.
Class of Business Training
Class of Business Training, on the other hand, is intended to address training in the subclasses of each product, as identified by the FSCA and must be done by KI’s and reps before rendering or overseeing financial services, as applicable. Only accredited provider or education institution can provide this type of training. At this stage there are only limited providers that offer this training.
“There are certain FSP’s that some of the training does not apply to. Contact us to find out more.”
Transitional Provisions
For Product Specific training:
Appointed before 1 April 2018 (excl. supervision):
Deemed to have completed product specific training for the financial products for which they were authorised or appointed.
The above does not apply to amendments to financial products where those amendments occurred after 1 April 2018.
Reps under supervision @ 1 April 2018:
Has 3 months to comply from 1 May 2018.
Hence, they have until 1 August 2018 to complete product specific training.
Appointed after 1 April 2018 but before 1 May 2018:
Has 3 months to comply from 1 May 2018.
Hence, they have until 1 August 2018 to comply.
We advise all FSPs to contact the product providers with whom they do business to enquire about product specific training.
For Class of Business training:
Reps & KI’s of Cat II, IIA, III, IV and Reps of Cat I: Appointed before 1 April 2018 (excl. supervision):
Deemed to have completed COB training in respect of that COB.
KI’s of Cat I: Appointed before 1 April 2018 (excl. supervision):
Key Individual is deemed to have completed COB training in respect of that COB
This KI must inform the registrar within 6 months (@ 1 October 2018) of those classes of business it currently manages and oversees in respect of all FSPs for which he/she is approved
This information must be submitted as required by the registrar
Reps under supervision @ 1 April 2018:
Has 12 months to comply from 1 August 2018.
Hence, they have until 1 August 2019 to complete COB training.
Appointed after 1 April 2018 but before 1 August 2018:
Has 12 months to comply from 1 August 2018.
Hence, they have until 1 August 2019 to comply.
Constant change
It remains to be seen how many FSP's will be compliant in time with the above-mentioned due dates, however we expect some teething problems. Never a dull moment in the state of constant change in the financial services industry.
