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What you think about recent regulatory attentions

23 November 2011 | | Gareth Stokes

On 15 November 2011 I distributed a newsletter titled Welcome respite for intermediaries as regulators shift focus. I suggested that the pending Treating Customers Fairly (TCF) regulation, although not bypassing financial intermediaries, would demand more from product providers. The reader response to the newsletter was overwhelming so I’ve dedicated today’s column to sharing some of your views. An open dialogue remains the best way to raise issues and areas of concern within the financial services industry.

The overriding sentiment from FAnews readers is that they’re up to their proverbial necks in regulation and that any shift in regulatory focus is long overdue. Yet the majority of comments pick up on the burden placed on the intermediary by existing regulation rather than the promise of a softer stance in the future. One reader – incensed with the impact of regulatory exams on the financial services sales force opines: “They [the Financial Services Board] are systematically wiping out the very reason for their existence – the men and women who rely on the industry to support their families!” He warns that many among South Africa’s ageing intermediary workforce are approaching retirement age – with younger intermediaries seeking alternative employment as compliance functions escalate.

A dying breed

His view was supported by many of our readers. An intermediary with 27 years in the short-term industry observes: “I have become very disillusioned with my career as an independent broker as constant changes result in ever-increasing costs. I fear for the future of this industry and will take the first opportunity to get out.”

Another reader, who went by the nom de plume Old Broker (OB), reckons the FSB has always acted to the advantage of the insurance companies. He offered up the recent decisions around investment commission and conflict of interest as examples. He also questioned whether the regulator’s attention was directed in the right area. An issue that immediately springs to mind is that of churning, which is almost exclusively identified by the regulators as an intermediary-induced ill… The reality is that much of the “churn” in today’s marketplace is a direct result of large insurers and investment houses buying up independent books of business.

They say that absolute power corrupts absolutely – and we have plenty of examples of this truism. Think for example of the Gauteng freeway tolling proposal… The minister of transport tells us that a “user pays” system is the fairest solution before announcing that half of the users (those in taxis and buses) will be exempt from any charge. An example from the financial services space is the decision to cap the annual license fee paid by insurance companies. “These companies should pay a license fee for each adviser on their books,” reckons OB. “As things stand the independent adviser is subsidising the insurance companies!” OB was on a roll, asking why the sales forces of the direct insurers, among the biggest culprits where miss-selling of insurance product is concerned, were not fully “covered” by the FAIS Act.

Feeling the costs of compliance

Costs are another hot issue. In recent weeks I’ve received a number of complaints about the increased cost of conducting business as an independent financial intermediary. FSB license fees top the list. One reader opines: “A year or two before the FAIS Act was promulgated the FSB said that the cost of registering and complying with FAIS would be nominal.” This is clearly not the case today… Andre Otto chipped in with the question top of every IFA’s mind: “What does the FSB do for the small independent brokers to justify the nearly R5, 000 per annum they charge?”

Reader Allan writes: “Our fees do not stop at the annual levies. Every time we need to make a change, register, de-register, or change a name or even an address, there is another fee to pay. Some fees – such as adding a category to your licence – are excessive.” Over and above the license fees practices are spending thousands of rand to comply with various regulatory interventions – not least the cost of regulatory examinations. “No brokerage will be able to absorb all these extra costs,” reckons John. “For starters you will require extra office space, extra staff, new computer programmes, the increased burden of carrying accounts, increased phone and stationary accounts, staff benefits and salaries, bad debts and legal fees to name a few.” Another frequent complaint centres on the soaring cost of professional indemnity cover, which has gone through the roof due to the increasing complexities in the financial advice space.

What does the future hold for the financial intermediary? “Eventually the FSB will kill the goose that lays the golden egg,” reckons Allan, before asking whether the local regulators will learn from the various mistakes made by the Financial Services Authority in the UK. If you buy into conspiracy theories then you might wonder whether the demise of the IFA is perhaps on the FSB’s agenda. “The sooner the FSB can reduce the independents to a tiny minority the less their administrative burden, the bigger their profits and the more they can concentrate on big payouts and hiking their fees,” opines John.

The big fish always get away

He asks where the regulator was when Fidentia and Sharemax set about fleecing investors. In doing so he raises a point very close to my heart: “[After each product provider collapse] the liquidators – appointed by the FSB – and all the other [private sector] scavengers walk away with purses bulging while the investors and the brokers involved are left to fight for survival. The investors stand to lose their hard-earned cash and the brokers stand to lose their licences and future incomes while the corpulent predators scuttle away with their new found loot!”

The independent advisers need someone in their camp. “What gets to me is that the small independent broker is the only category of service provider that truly renders an unbiased service to the consumer out there – yet the FSB stands back while the Outsurances of this world publicly tell the consumer to avoid brokers,” notes Deon. He asks why the FSB cannot stand up to protect its licensed practitioners.

It is difficult to forecast the impact of today’s legislation on the IFA landscape a decade from now. Perhaps John sums it up best: “The FSB is effectively forcing brokers out of the industry or into the hands of the banks and insurance companies, thereby denying clients the freedom to experience unbiased advice from truly independent advisers.”

Editor’s thoughts: There is no doubt that regulation adds costs to doing business. While private companies continue to lobby for prohibitive red tape to be removed, the financial services industry is snowed under by new, proposed and pending legislative interventions. Are you concerned that the current regulatory load will result in small IFAs being closed out of South Africa’s financial advice space? Please add your comment below, or send it to gareth@fanews.co.za

Comments

Added by Knox, 25 Nov 2011
We seem to copy everything that the UK's Financial Services Authority (FSA produces. Perhaps then it would be useful to stay in touch with the responses in the UK to their FSA. - ARTICLE: -- "Avalanche of new FSA rules to cost business £1.4bn a year". (The Telegraph, 20 November 2011) - "The Square Mile has been hit with an avalanche of new financial rules and regulations over the past year which will cost up to £1.4bn annually to comply with." - " An analysis of laws imposed by the industry watchdog since last October reveals no fewer than 18 separate consultations on law changes, each resulting in costly measures, which small City firms warn will damage competitiveness and limit growth." - "The study, compiled by pensions consultancy Hargreaves Lansdown, shows one-off implementation costs ranging from between £253m and £323m, and further £1.1bn to £1.4bn annual compliance costs, based on the Financial Services Authority's (FSA) own impact assessments. " - "The figures come as Vince Cable, the Business Secretary, prepares to outline plans for cutting business red tape at an employers' event on Wednesday, and feed into growing concern from companies about "regulation overload". " - "Among the numerous measures and levies imposed on the financial services sector are rules on capital requirements, data collection, consumer complaints and financial crime. " - "Daniel Pinto, chairman of London-based investment firm Stanhope Capital and director at the New City Initiative, which represents independent firms, said the "excessive" regulation would stifle small and medium enterprises which were paying the price for the failure of big banks. " -
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Added by Quinten Knox, 24 Nov 2011
"Every revolution evaporates and leaves behind only the slime of a new bureaucracy." (Franz Kafka July 3, 1883) "Bureaucracy is the death of all sound work” (Albert Einstein, March 14, 1879) “Any change is resisted because bureaucrats have a vested interest in the chaos in which they exist.” (Richard Nixon, January 9, 1913) “The best way to deal with bureaucrats is with stealth and sudden violence.” (Butros Butros-Ghali, November 14, 1922)
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Added by jo, 23 Nov 2011
The average age of independent Brokers in the industry is 52. There are many on the corporate side and insurance companies who are younger, but they don’t plan to become independent Brokers. They are comfortable earning a salary, getting bonuses and not having to struggle building a client base. The average Broker is tired of being exploited by the Insurers who blame them for everything, a bad press image and ridiculous legislation that places no responsibility on the client. They see themselves as having another decade at most, in an increasingly legislated industry, to build his practise, sell and retire. The one's who has sons/daughters willing to get qualified and take over the practise, also see themselves in a similar scenario whereby they will be selling in the next decade and changing careers. So where will the financial services be in a decade? Decimated by arrogant myopic industry and legislators!
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Added by The Court Jester, 23 Nov 2011
Two years ago the FSB hiked the annual fees with 200% above Rate of Inflation...due to them not being able to budget properly....that says a lot... When they licensed the Sharemaxes, Blue Zones, CIty Capitals, Fidentias of our world - were they NOT the ones who were supposed to do the due diligence and approve the products? Now the expect that the Advisers would have done a due diligence on institutions they gave the approval for...That does not make sense at all..
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Added by Kevin, 23 Nov 2011
The following quote sums it up for me (I do not know of the source): "When you see that trading is done, not by consent, but by compulsion — when you see that in order to produce, you need to obtain permission from men who produce nothing — when you see that money is flowing to those who deal, not in goods, but in favours — when you see that men get richer by graft and by pull than by work, and your laws don't protect you against them, but protect them against you — when you see corruption being rewarded and honesty becoming a self-sacrifice — you may know that your society is doomed." While we have those lauding it over us that do nothing much more than plunder, then our industry is doomed. Except, of course, for the corporates who probably are driving the show anyway!
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Added by Bill, 23 Nov 2011
I am also an old broker (69 years old) and I have been in the life insurance / employee benefits business since leaving school in 1961. The fixation that the FSB has with intermediaries completely ignores the exhorbitant fees which are charged for investment managment. As I am about to retire the matter of fees has become very pertinent. For every R1million of my retirement capital invested I pay 1.5% to 1.75% per annum for investment services. The theory is that one should not draw more than 5% per annum as a pension income, ie R50 000 per annum/ R1mil. The investment management costs amount at the lower end amount to R15 000 per annum per R1mil, or 30% of my pension. The fee works out to R1250 per month per R1mil invested, SURELY the FSB is aware of this and if they really wanted to apply TCF principles then they should immediately legislate to limit investment management fees. Regards Bill Els
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Added by Humphrey, 23 Nov 2011
I used to always actively recommend the short term industry to youngsters as a great career choice. Whilst I do not run the industry down as a career choice, I rather abstain from recommending it. It is totally over-regulated to the extent of future destruction and all of this comes at huge financial cost to the end consumer in additional costs. R.O.I. calculations (of all this legislation and the expanding FSB) across the short term industry I bet would not justify their existance to this extent - but such measurements will never be made. The industry is no longer a fun place and if I wanted to read legal documents all day I would have become an attorney. Finally it is about time legislators start producing legislation in plain language.
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Added by Elna, 23 Nov 2011
I am sure that all of my Broker Colleagues have kissed the Blarney Stone, such eloquence in stating their believes in your summary! Just a comment about a recent experience, I quote clients on referral basis only. The client asked us twice to obtain quotes for him, currently insured with Outsurance, the first time we could save him on premium and offered better excesses, he responded that he wants to wait for his Outbonus and would then contact us again. And so he did. Yet again we could save him on premium and excesses with a comprehensive product without all the exclusions on his own policy. He accepted and we activated the new product, then he phoned back to inform us that when he phoned to cancell Outsurance they offered to pay the R1,500 for the immobilizer he just installed that was a requirement on our policy and that the client already paid, if he stayed with them - Conflict of Interest? Obviously he stayed - retention of business is fair but this insident left me with a bad taste in my mouth - who is regulating Direct Insurers????
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Added by rosy, 23 Nov 2011
The big issue at the moment appears to be the "churning" of policies by advisers and brokers who are unfortunately constantly being denigrated by the media leading to the possibility of the imposition of patently unjust restrictions on commission paid in respect of risk business. A mechanism exists which is meant to monitor this, namely the " Policy Replacement Advice Record. " Perhaps I.'m wrong but my understanding is that the "new" company is obliged to to advise the previous compamy of the replacement and one would expect that the client then be contacted by the original company. I doubt whether this is being done to any extent, There are of course many instances ( hopefully most" ) where the client unquestionably benefits by making a change, and the adviser is fully entitled to be remunerated for the service he has rendered.To help control the few bad eggs I would suggest that in all instances where a company sees a policy being lapsed or surrendered,and they have had no notification from another compnay thereof, it should follow up with a personal telephone call to the client to confirm that they are happy with their decision and that they have signed a Policy Advice Record
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Added by Craig A, 23 Nov 2011
Churning for commission should be stopped, but restructuring a client's portfolio so that he gets the best benefits for a better premium is what we are supposed to do. Imagine the car salesman that cant do a trade- in because he is 'churning'? The life assurers dont seem too interested in stopping the practice of churning, because they are benefitting from it. In fact, some of them encourage it.
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What you think about recent regulatory attentions
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