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Regulation needs to be a movement, not a hindrance

FSB Executive Officer Dube Tshidi

Jonathan Faurie, FAnews Journalist

Rosemary Hunter, Deputy Executive Officer (DEO) of Pensions

Over the many years that I have spent covering many different industries, I have come to notice one prevailing aspect which is applicable to all sectors of society. While regulation is needed in order to establish order, over-regulation negatively affects

This is the fear of the financial services industry which is going through a lot of changes, many of which are being enforced on the industry by the implementation of regulation. The industry is fast approaching ‘Twin Peaks’ and the prospect of implementing reforms such as treating customers fairly, solvency assessment and management as well and retail distribution review is daunting with many industry players vociferously voicing their concerns.

However, meaningful reform which would benefit the sector will be welcome by all and the Financial Services Board feels it is on the right track to achieve this.

Don’t focus on the regulation…focus on its implementation

Yesterday, the FSB unveiled the high profile appointments of Rosemary Hunter, who will be the Deputy Executive Officer (DEO) of Pensions, and Caroline da Silva who will be the DEO of Financial Advisory and Intermediaries Services (FAIS) from September 2nd. Addressing the media at the announcement, FSB Executive Officer Dube Tshidi encouraged the industry to focus on the implementation of regulation rather than the fact that it is facing changes.

“Regulation is a very complex task. It is a task where it will be hard to find anyone who praise companies that implement it. It is also an area where you will attract a lot of criticism which will be either justified or not. But even if this criticism is unjustified, you still need to stand up and go ahead with its implementation,” says Tshidi.

He added that the majority of the criticism comes of a base of uncertainty regarding the regulation which is being driven by limited information regarding the cost implications of its implementation.

“We need to move towards a situation where regulation is not forced upon a company. It must be a proactive process. If companies make treating customers fairly a culture within their business it will eliminate the majority of the cost of its implementation and the majority of the uncertainty surrounding it. If you cannot look at your product and feel comfortable to sell it to a relative who is on pension, that product is not ready for distribution.”

Over regulation? No…we have learned lessons

Regardless of Tshidi’s desire that focus should be paid on the implementation of regulation as opposed to its future challenges or possible restrictiveness, the fact of the matter is that the industry is staring down the barrel of three new pieces of legislation. This has given fuel to the fire that the industry is over regulated.

But Da Silva feels that regulation is necessary as the industry has learned a lot from the 2009 global financial crisis.

“The amount of regulation in the sector is inversely proportionate to the amount of trust the customer has in the sector. After the 2009 global financial crisis, we need to rebuild that trust. The more we rebuild the trust in the sector, the more we can balance regulation. We need to get this right, not just for the protection of the policyholder, but for the sustainability of the industry as a whole. And the best way to achieve this is through regulation,” says Da Silva.

Because of her reputation and industry experience, Da Silva will be instrumental in the implementation of FAIS. And it seems as if the broker’s concerns will be taken into consideration as they play an important role in the industry.

“The broker is one of the distribution channels whereby the public can access financial services. As the FSB, we need to make sure that brokers are sufficiently qualified to provide the right advice and are there to act in the best interest of the customer. So we will give them all the support they need to achieve this,” she says.

However, it seems as if there is one debate which will not die down and may prove to have a significant impact on the industry.

Although Da Silva hasn’t officially joined the FSB, she gave her personal views point on the fees vs commissions debate, which she has encountered many times during her years in the industry. “South Africa must be one of the last countries in the world which still has a commission regulation. This makes it complicated to formulate regulation which will advance the industry. Because commission is capped, stakeholders look for other avenues in which to gain revenue. We need to balance that with customer protection to make sure that there is no conflict in interest between how the product is being distributed and how the broker/adviser is being rewarded,” she says.

Editor’s Thoughts:
It is clear that the FSB is taking consumer protection seriously, and by encouraging it to become a movement rather than pieces of legislation which may serve as a hindrance, it is making a bold move to reform the industry.

The FSB is ‘talking the talk’, but can they now ‘walk the walk’? It is all very well that you draft legislation, it is another thing entirely to put the correct people in place to ensure that this is effectively implemented. Da Silva will make her presence felt and may prove to be the catalyst for change that the industry needs. She spent eight years as a broker and many years looking at legislation advising the FSB on the best way in which to implement it. So she will look at reforming the industry with the experience of being on both sides of the fence.

By all accounts, TCF will play a major role in the FSB’s reform strategy. But in order for this to be a success, there needs to be significant industry buy in. If there isn’t, the FSB’s TCF ambitions may suffer the same fate as its British counterparts where Tshidi openly admits that TCF failed miserably. Do you feel that the appointment of Da Silva will facilitate the change that the industry needs? Please comment below, interact with us on Twitter at @fanews_online or email me your thoughts[email protected].

Comments

Added by Also Miffed, 29 Aug 2013
Well done MIFFED! You expressed my feelings most eloquently and to add anything would only detract from the gravity of the article you have written. I have always thought that a Conflict of Interests exists between the Large Corporates and the FSB which neither will reveal for fear the Independants would complain.
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Added by Thomas, 20 Aug 2013
I just wish to make one comment on TCF. Before the FSB implement TCF they should first turn to our GOVERNMENT and implement a regulation called TCF but that mean:"TREAT CITIZENS FAIRLY". Our industry are being regulated daily but the whole big sour pot running the country is corrupt.We do not steal and waste billions--GOVERNMENT DO. Who regulate them?.
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Added by Des, 20 Aug 2013
If anyone can get it right it will be Caroline da Silva. She is an astute and knowledgeable industry player with hugely useful experience in the sector as well as considerable exposure to the workings of the Regulator. To my mind her appointment is a breath of fresh air for the sector and is much to be applauded. Des
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Added by Ari, 20 Aug 2013
" industry has learned a lot from the 2009 global financial crisis." The financial crisis was the result of the activities of US and European banksters - "too big to jail" who still walk among us. It was not in any manner caused or supported by ordinary financial services providers. But these people are the ones who are taking the strain - and will in a short while disappear as a profession. Over regulation? Sure. Only in recent years have people become aware of the menace of bureaucracy, and they consider bureaucracy not an instrument of democratic government but, on the contrary, the worst enemy of freedom and democracy. (Ludwig Von Mises, Bureaucracy. New Haven: Yale University Press, 1944 p. 44) Rules of Bureaucracy Rule #1: Maintain the problem at all costs! The problem is the basis of power, perks, privileges, and security Rule #2: Use crisis andpercei.ved crisis to increase your power and control. Rule #3: If there are not enough crises, manufacture them, evenfrom nature, where none exist. Rule #4: Control the flow and release of information while feigning openness. Rule #5: Maximize public-relations exposure by creating a cover story that appeals to the universal need to help people. Rule #6: Create vested support groups by distributing concentrated benefits and/or entitlements to these special interests, while distributing the costs broadly to one's political opponents. Rule #7: Demonize the truth tellers who have the temeri:ty to say, 'The emperor has no clothes." (Harry E. Teasley Jr - https://www.mises.org
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Added by Paul C, 20 Aug 2013
What exactly does Da Silva mean when she says: "We need to balance that with customer protection to make sure that there is no conflict in interest between how the product is being distributed and how the broker/adviser is being rewarded"? How is this to be achieved - by dereguating Commision rates? Would this not lead to a free-for-all?
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Added by Barry, 20 Aug 2013
It's all about weeding out the "bad apples" what ends up happening is that the "good guys" end up being regulated and have the growth of their businesses stifled. I don't think we need to change anything. Brokers all get the same commission for placing business with insurers. It is the price insurers pay for buying business. With the amount of commission being legislated, there can be no conflict of interests. Likewise outsourcing fees are paid to the brokers who add value to insurers. Section 8(5) fees are between the client and the broker. the only criteria here, should be that the fees are disclosed to and agreed by the client. Brokers provide clients with different levels of service and service clients in different socio economic groups. These different groupings attract different expenses and the broker should be able to determine the amount of money he wants to charge his client. Likewise the client has the opportunity of accepting or declining the service. The free market system will determine the brokers success or otherwise. You cannot have a situation where you force someone to sell a Mercedes for the same price as a Volkswagen. I bet there are many people out there who buy different makes of cars for many different reasons, the least being an understanding of the technical differences between the various models. The FSB should not be able to apply subjective regulation to a mature market, and their role should be as much about educating the industry as it is on "punishing" it, which seems to be their idea of "regulation". Why does the FSB have such an unsavory reputation with so many members of the industry? I'm not referring to the CEO's of Insurers who deal on a higher level than the ordinary insurance practitioner, but the everyday insurance worker. By far the majority of the people I speak to have had unpleasant/inefficient/unsatisfactory reactions with the FSB. Why? It can't all be the fault of the insurance workers, surely. I really hope the FSB will apply it's own rules to itself, particularly treating customers fairly.
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Added by Miffed, 20 Aug 2013
It's somewhat grimly ironic that SA is a world leader when it comes to financial regulation yet has concurrent shockingly high levels of crime, fraud and corruption embedded in both corporate and government structures. Being the global leading light in terms of regulation obviously spurs our gallant regulators on to set yet more onerous new world class benchmarks – so we see TCF etc entering stage left with scarce a pause whilst exiting at right are 1000's of honest financial advisers, many of whom have grown intolerant to the gross rigidity being visited upon them by the advances of the FSB into the sphere of what was private enterprise. I for one resent what I see as growing totalitarianism in the way the FSB (and Treasury) views and treats its fee paying constituency. There is no respect. The FSB claim to engage but the pseudo mouth pieces who ‘act’ on my behalf must have slipped up somewhere or perhaps they have their own agendas as they have failed miserably thus far to portray my interest and needs. So Board Notices are churned out dime a dozen unchallenged, replete with 100's if not 1000’s of sections, sub sections and sub, sub sections that in turn require further explanatory memorandum due to the fact that they are so ill thought, badly worded, overly complicated and unworkable but all given business fatal penalties and sanction for non- compliance for often trivial and inconsequential transgressions. This, with respect is crap. I understand and support initiatives to rid the industry of those who are crooks and shysters but the current manner in which this is being done only boosts the coffers of the existing large operations allowing them to retake territory lost from the independents over the past 2 decades. Ever wonder why the FSB goes unchallenged by the financial super powers in this country? How they must chuckle as the remaining independents struggle to survive against this tsunami of bureaucratic interventions that will in time swamp and drown even the hardiest of souls, how they must laugh as the remainder fight for the spoils to eventually cannibalise and ultimately subsume each other. Just business? Other sectors of industry have ministries that are supportive of their members and actively promote and uplift them. Ours conversely seek to denigrate and punish. Treats us like children. Makes frequent public statements that damage and tarnish. That hurt financially and embarrass me to admit that I practice in this profession. They have scant regard for what is practicable and fair, for what is doable given the precarious and fickle nature of the business we are in. We help build the economy, we provide the mechanisms to ensure that people and business through all spectrums of society remain successful, do not become destitute and make informed financial choices. For me the relationship is very often cradle and especially to the grave. It’s implicit in what I do. It’s a service but it’s also a relationship that the FSB thinks can be parcelled out, compartmentalised, legislated and enforced. In our business nothing is guaranteed. The risk you take on is immense. Besides the FSB pawing through your files looking for some technical oversight you now have a slew of ombud rulings that indicate we underwrite the entire investment even though our reimbursement is usually less than a few basis points and notwithstanding that the ‘loss’ is occasioned by 3rd parties or even the client himself . Can anyone explain that logic?
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