LEVEL 3 UPDATED COVID REGULATIONS FOR FSP'S
I recently counted the number of Covid regulations and they number at approximately 147 different documents on the Government Website. That is a ridiculous amount of new rules that I suspect many people transgress every day without even knowing it - and I do not blame them.
The FSCA, Reserve Bank and Prudential Authority issued a new set of Covid Measures for FSP's to comply with under level 3 lockdown. These rules also allow FSP's to actively deal with clients in a prescribed manner, which I suppose is a silver lining. Please see the full document here. We've tried to take the essence out of it as much as possible to show you what you need to comply with in this post.
Apart from what we detail in this post please remember that financial institutions must comply with the Occupational Health and Safety Directives issued by the Minister of Employment and Labour in terms of the Regulations regarding the precautionary measures in workplaces. You can find these regulations here.
The Summary
Where face to face meetings or physical interaction with customers are unavoidable, in order to protect both the employees of the financial institution as well as financial customers, these meetings should be held at premises where appropriate health measures and social distancing can be implemented, such as-
suitably equipped offices of the financial institution;
the place of work of the customer, or
other premises where appropriate health measures can be implemented and monitored.
A financial institution should not hold meetings at the homes of clients, or visit financial customers at home for purposes of providing financial services to them.
Where exceptional circumstances require that a meeting takes place at the home of a customer, the following protocols must be followed:
An employee of a financial institution should only visit a customer’s home after confirming an appointment with the customer, and should not arrive at a customer’s home without prior notice.
Both the customer and the employee are required to complete a risk questionnaire prior to the visit to establish if either of them is vulnerable, or whether the financial customer resides with a vulnerable person, or if either of them is at risk of infecting others. Only if both are not vulnerable or at risk of infecting others may the appointment at the customer’s home continue. If the appointment occurs more than one day after the telephonic questionnaire is completed, the financial institution should make a follow-up confirmation on the day of the appointment to ensure that the circumstances have not changed.
The employee should perform a non-contact temperature screen on him or herself in the presence of the customer as well as on the customer.
The employee should carry sanitiser, and a spare mask which should be offered to the customer on arrival if the customer does not have a mask. The consultation should not continue unless the customer has sanitised his or her hands and is wearing a face mask. The customer should be informed in advance of this requirement.
Social distancing should be practiced as far as possible whilst completing forms, limiting the time close to the customer as far as possible.
A record that the above measures were implemented must be kept in respect of each customer.
A financial institution must upon request by the Authorities submit the name of the COVID-19 compliance officer designated under Regulation 47 and its workplace plan as contemplated in Regulation 47(1)(b) of the Regulations to the Authorities.
