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Do you know your products?







According to the Fit and Proper Requirements timeline schedule a representative under supervision as at 1 April 2018 or appointed during April 2018 must have completed Product Specific Training by 31 July 2018.

To better understand this requirement let’s recap the three types of training under the competence requirements first. A closer look at the definitions will distinguish more clearly what impacts on them, and what not:

  1. “class of business training” means training in respect of a class of business and which training is provided and assessed by an accredited provider or an education institution;
  2. “product specific training” refers to training in respect of a particular financial product (which forms part of a specific class of business) and which training is assessed, including any amendments to that particular financial product. Product specific training need not be conducted by an accredited provider. Should the specific product provider not have material available for this purpose, the onus rests on the FSP’s key individual to develop such training material.
  3. “CPD” means continuous professional development. A “CPD activity” means an activity that is accredited by a Professional Body, allocated an hour value or a part thereof by that Professional Body and is verifiable. CPD excludes an activity performed towards a qualification and product specific training, but class of business training is not, provided that the provider is duly accredited.

The following are important definitions relating to the above classification:

  1. “assessed” in relation to competence requirements, means the structured process of gathering reliable evidence to determine the level of a person’s competence in relation to a pre-determined standard. We queried this with the FSCA who advised that this standard is determined by the training provider.
  2. “accredited provider” means a person that is recognised and certified or accredited by a Quality Council as having the capacity or provisional capacity to offer a qualification or part-qualification registered on the NQF at the required standard, or a foreign person that is so recognised and certified or, accredited by a foreign authority that is equivalent to a Quality Council.
  3. “professional body” means a body recognised by the SAQA as a professional body for purposes of the NQF Act.

So, what does product specific training entail?

According to the Fit and Proper Requirements an FSP must ensure that it, its key individuals and representatives are proficient in respect of, understand, and have completed adequate and appropriate class of business training and product specific training relevant to the particular products in respect of which they render financial services or manages or overseas the rendering of financial services. A KI is not obliged to complete it, except if he or she also acts as a representative.

The Fit and Proper Determination outlines very specific requirements for Product Specific Training. We recommend that you download the
three-page document outlining these specifications, particularly where no training material can be obtained from the product provider. Ultimately, the FSP will have to be able to show that it has conformed to these specifications.

Product specific training should, by rights, be treated as a form of product accreditation, specifically in the light of the proposed accountability on product providers for both tied agents (“product supplier agents - PSAs) and independent brokers (registered financial advisers – RFSs). Where product specific training material is not yet available, providers should consider developing such as a matter of urgency.


The updated RDR proposals state:


Product suppliers clearly bear full legal accountability for advice provided by their tied advisers in accordance with ordinary agency principles.


Rule 12.2.1 of the LTIA and STIA PPRs which came into operation on 15 December 2017 for new intermediary agreements and will come into operation on 15 December 2018 for existing intermediary agreements, which require insurers to ensure that intermediaries with whom they contract comply with FAIS product knowledge requirements.

It is also important to note that, should you have contracts with three different product providers, you will need accreditation from all three as far as product specific criteria are concerned.

By way of example: If you do short-term personal lines, and are contracted with three insurers, you will have to attend one approved Class of Business training session and a total of at least three Product Specific courses. If the provider offers more than one product, you have to do Product Specific training for each and every one. Quality control and assuring objectivity of the assessment of learners will be one of the major challenges facing FSPs.

The onus to monitor and track the competence of its Key Individuals and Representative therefore rests squarely on the shoulders of the FSP to ensure that they receive appropriate and relevant training. 

Source: Moonstone Compliance (Pty) Ltd
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