The role of the organization
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The role of the organization. “ QUO VADIS TUSSENGANGER? ” / “ QUO VADIS INTERMEDIARY? ”. Presented by: Brian van Flymen. The three strategic pillars. RECENT SUCCESSES. Pre-merger industry feedback - Negative. RECENT SUCCESSES. Pre-merger industry feedback - Negative 2008 FIA Dream.

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The role of the organization

“QUO VADIS TUSSENGANGER?” / “QUO VADIS INTERMEDIARY?”

Presented by: Brian van Flymen


The three strategic pillars


RECENT SUCCESSES

  • Pre-merger industry feedback - Negative


RECENT SUCCESSES

  • Pre-merger industry feedback - Negative

  • 2008 FIA Dream


RECENT SUCCESSES

  • Pre-merger industry feedback - Negative

  • 2008 FIA Dream

  • Insurance Laws Amendment Act – Parliament 2008


RECENT SUCCESSES

  • Pre-merger industry feedback - Negative

  • 2008 FIA Dream

  • Insurance Laws Amendment Act – Parliament 2008

  • Binder agreements / Secure income streams for brokers


RECENT SUCCESSES

  • Pre-merger industry feedback - Negative

  • 2008 FIA Dream

  • Insurance Laws Amendment Act – Parliament 2008

  • Binder agreements / Secure income streams for brokers

  • RE Level 1 exams / Member support / Pass mark / Afrikaans / Format


RECENT SUCCESSES

  • Pre-merger industry feedback - Negative

  • 2008 FIA Dream

  • Insurance Laws Amendment Act – Parliament 2008

  • Binder agreements / Secure income streams for brokers

  • RE Level 1 exams / Member support / Pass mark / Afrikaans / Format

  • RE Level 2 exams / In limbo until after house is in order


RECENT SUCCESSES

  • Pre-merger industry feedback - Negative

  • 2008 FIA Dream

  • Insurance Laws Amendment Act – Parliament 2008

  • Binder agreements / Secure income streams for brokers

  • RE Level 1 exams / Member support / Pass mark / Afrikaans / Format

  • RE Level 2 exams / In limbo until after house is in order

  • Health Care fees / FIA Approach Minister of Health Office


RECENT SUCCESSES

  • Pre-merger industry feedback - Negative

  • 2008 FIA Dream

  • Insurance Laws Amendment Act – Parliament 2008

  • Binder agreements / Secure income streams for brokers

  • RE Level 1 exams / Member support / Pass mark / Afrikaans / Format

  • RE Level 2 exams / In limbo until after house is in order

  • Health Care fees / FIA Approach Minister of Health Office

  • Sasria Commission


RECENT SUCCESSES

  • Pre-merger industry feedback - Negative

  • 2008 FIA Dream

  • Insurance Laws Amendment Act – Parliament 2008

  • Binder agreements / Secure income streams for brokers

  • RE Level 1 exams / Member support / Pass mark / Afrikaans / Format

  • RE Level 2 exams / In limbo until after house is in order

  • Health Care fees / FIA Approach Minister of Health Office

  • Sasria Commission

  • Section 156 Interest on premium


RECENT SUCCESSES

  • Pre-merger industry feedback - Negative

  • 2008 FIA Dream

  • Insurance Laws Amendment Act – Parliament 2008

  • Binder agreements / Secure income streams for brokers

  • RE Level 1 exams / Member support / Pass mark / Afrikaans / Format

  • RE Level 2 exams / In limbo until after house is in order

  • Health Care fees / FIA Approach Minister of Health Office

  • Sasria Commission

  • Section 156 Interest on premium

  • Human Capital Project / FIA, SAIA, IISA, FSB / Industry Roadmap


RECENT SUCCESSES

  • Pre-merger industry feedback - Negative

  • 2008 FIA Dream

  • Insurance Laws Amendment Act – Parliament 2008

  • Binder agreements / Secure income streams for brokers

  • RE Level 1 exams / Member support / Pass mark / Afrikaans / Format

  • RE Level 2 exams / In limbo until after house is in order

  • Health Care fees / FIA Approach Minister of Health Office

  • Sasria Commission

  • Section 156 Interest on premium

  • Human Capital Project / FIA, SAIA, IISA, FSB / Industry Roadmap

  • Code of Conduct / Perceptional change


RECENT SUCCESSES

  • Pre-merger industry feedback - Negative

  • 2008 FIA Dream

  • Insurance Laws Amendment Act – Parliament 2008

  • Binder agreements / Secure income streams for brokers

  • RE Level 1 exams / Member support / Pass mark / Afrikaans / Format

  • RE Level 2 exams / In limbo until after house is in order

  • Health Care fees / FIA Approach Minister of Health Office

  • Sasria Commission

  • Section 156 Interest on premium

  • Human Capital Project / FIA, SAIA, IISA, FSB / Industry Roadmap

  • Code of Conduct / Perceptional change

  • FSB realize that FIA Members are more informed


RECENT SUCCESSES

  • Pre-merger industry feedback - Negative

  • 2008 FIA Dream

  • Insurance Laws Amendment Act – Parliament 2008

  • Binder agreements / Secure income streams for brokers

  • RE Level 1 exams / Member support / Pass mark / Afrikaans / Format

  • RE Level 2 exams / In limbo until after house is in order

  • Health Care fees / FIA Approach Minister of Health Office

  • Sasria Commission

  • Section 156 Interest on premium

  • Human Capital Project / FIA, SAIA, IISA, FSB / Industry Roadmap

  • Code of Conduct / Perceptional change

  • FSB realize that FIA Members are more informed

  • Broker mandates / direct writers as well as no agreements


RECENT SUCCESSES

  • Pre-merger industry feedback - Negative

  • 2008 FIA Dream

  • Insurance Laws Amendment Act – Parliament 2008

  • Binder agreements / Secure income streams for brokers

  • RE Level 1 exams / Member support / Pass mark / Afrikaans / Format

  • RE Level 2 exams / In limbo until after house is in order

  • Health Care fees / FIA Approach Minister of Health Office

  • Sasria Commission

  • Section 156 Interest on premium

  • Human Capital Project / FIA, SAIA, IISA, FSB / Industry Roadmap

  • Code of Conduct / Perceptional change

  • FSB realize that FIA Members are more informed

  • Broker mandates / direct writers as well as no agreements

  • FSGLAB / Institutional failure


RECENT SUCCESSES

  • Pre-merger industry feedback - Negative

  • 2008 FIA Dream

  • Insurance Laws Amendment Act – Parliament 2008

  • Binder agreements / Secure income streams for brokers

  • RE Level 1 exams / Member support / Pass mark / Afrikaans / Format

  • RE Level 2 exams / In limbo until after house is in order

  • Health Care fees / FIA Approach Minister of Health Office

  • Sasria Commission

  • Section 156 Interest on premium

  • Human Capital Project / FIA, SAIA, IISA, FSB / Industry Roadmap

  • Code of Conduct / Perceptional change

  • FSB realize that FIA Members are more informed

  • Broker mandates / direct writers as well as no agreements

  • FSGLAB / Institutional failure

  • Value of the intermediary (FIA) / Level playing fields


RECENT SUCCESSES

  • Pre-merger industry feedback - Negative

  • 2008 FIA Dream

  • Insurance Laws Amendment Act – Parliament 2008

  • Binder agreements / Secure income streams for brokers

  • RE Level 1 exams / Member support / Pass mark / Afrikaans / Format

  • RE Level 2 exams / In limbo until after house is in order

  • Health Care fees / FIA Approach Minister of Health Office

  • Sasria Commission

  • Section 156 Interest on premium

  • Human Capital Project / FIA, SAIA, IISA, FSB / Industry Roadmap

  • Code of Conduct / Perceptional change

  • FSB realize that FIA Members are more informed

  • Broker mandates / direct writers as well as no agreements

  • FSGLAB / Institutional failure

  • Value of the intermediary (FIA) / Level playing fields

  • Exco member of WFii – IAIS Access


RECENT SUCCESSES

  • Pre-merger industry feedback - Negative

  • 2008 FIA Dream

  • Insurance Laws Amendment Act – Parliament 2008

  • Binder agreements / Secure income streams for brokers

  • RE Level 1 exams / Member support / Pass mark / Afrikaans / Format

  • RE Level 2 exams / In limbo until after house is in order

  • Health Care fees / FIA Approach Minister of Health Office

  • Sasria Commission

  • Section 156 Interest on premium

  • Human Capital Project / FIA, SAIA, IISA, FSB / Industry Roadmap

  • Code of Conduct / Perceptional change

  • FSB realize that FIA Members are more informed

  • Broker mandates / direct writers as well as no agreements

  • FSGLAB / Institutional failure

  • Value of the intermediary (FIA) / Level playing fields

  • Exco member of WFii – IAIS Access

  • President of WFii


RECENT SUCCESSES

  • Pre-merger industry feedback - Negative

  • 2008 FIA Dream

  • Insurance Laws Amendment Act – Parliament 2008

  • Binder agreements / Secure income streams for brokers

  • RE Level 1 exams / Member support / Pass mark / Afrikaans / Format

  • RE Level 2 exams / In limbo until after house is in order

  • Health Care fees / FIA Approach Minister of Health Office

  • Sasria Commission

  • Section 156 Interest on premium

  • Human Capital Project / FIA, SAIA, IISA, FSB / Industry Roadmap

  • Code of Conduct / Perceptional change

  • FSB realize that FIA Members are more informed

  • Broker mandates / direct writers as well as no agreements

  • FSGLAB / Institutional failure

  • Value of the intermediary (FIA) / Level playing fields

  • Exco member of WFii – IAIS Access

  • President of WFii

  • FIA Awards / Industry benchmark


BURNING ISSUES

  • Remuneration


BURNING ISSUES

  • Remuneration

  • RE2


BURNING ISSUES

  • Remuneration

  • RE2

  • CPD


BURNING ISSUES

  • Remuneration

  • RE2

  • CPD

  • Pro-intermediary Campaign


BURNING ISSUES

  • Remuneration

  • RE2

  • CPD

  • Pro-intermediary Campaign

  • Demarcation Health Products


REALITIES

  • Regulation

  • Commoditisation – Consumerism

  • Value of the intermediary (lack – perception)

  • Image and Reputation

  • Wfii

  • IAIS

    • Core principles 18/24


COMMUNICATION (HOW)

  • Technology

  • New Connect

    • Daily

    • Weekly – Indaba

    • Monthly – Inform

  • Selective – What is relevant for me

  • One consistent message through structures

  • Regional Coordinators

  • Branches

  • Regional Conferences


REPRESENTATION (WHAT)

Threats (Reality or Perception)

  • October 2004 (FAIS)

  • 14700 FSPs

  • July 2012

  • 10750 FSPs

  • 3206 Cancelled

  • Consolidation

  • Retire/ Leave the industry

  • Fraud (minority)


REPRESENTATION (WHAT)

  • New entrants (Human Capital Initiative

  • Level playing fields

  • Direct

  • Aggregators

  • Economy (Section 8)

  • Banks (One fits all)

  • FAIS Ombud determinations (Due diligence)

  • COSTS……………

  • Image and Reputation

  • Remuneration

  • Education – (In general)

  • Transformation


REPRESENTATION (WHAT)

  • New entrants (Human Capital Initiative

  • Level playing fields

  • Direct

  • Aggregators

  • Economy (Section 8)

  • Banks (One fits all)

  • FAIS Ombud determinations (Due diligence)

  • COSTS……………

  • Image and Reputation

  • Remuneration

  • Education – (In general)

  • Transformation


TWIN PEAKS

  • National Treasury - Prudential

  • FSB – Conduct

  • CMS

  • Inseta

  • SAM

  • TCF

  • FSGLAB

  • Binder Regulations


CHALLENGES

  • Capacity to represent all disciplines in the industry

  • Our own worst enemy

  • Trust the leaders you elect and believe in them


Member priorities


PRODUCT LIFE STAGES APPROACH TO TREATING CUSTOMERS FAIRLY (TCF)


FSA (UK)

The FSA began studying the TFC programme in 2000,

published its first paper in 2001, and the programme

was officially launched in 2005.

Realties in the UK:

A change of mindset of the industry

Clarity of regulatory expectations

Education to encourage consumer responsibility

A supervisory approach that is pre-emptive and intensive

Enforcement and compliance


Product life cycle

Cultural Framework


Desired Outcomes

Developing products for specific target markets, based on a clear understanding of the likely needs and financial capability of each group of customers


Desired Outcomes

Marketing products for specific target markets, based on a clear understanding of the likely needs and financial capability of each group of customers

Communicating clearly and fairly the nature of the product before the consumer is “locked in”.


Desired Outcomes

Balancing the commercial objective of increasing sales with the objectives of Treating customers fairly.

With assessment, offering suitable alternatives to consumers.


Desired Outcomes

Providing clear and appropriate information, making charges transparent.

Being clear to customers about what the firm, its products and services offer.


Desired Outcomes

Monitoring and responding appropriately to changes in the wider environment that may affect products and impact on particular classes of new or existing customers.


Desired Outcomes

Honouring representations, assurances and promises that lead to legitimate customer expectations.

Identifying common underlying causes of complaints and taking action to eliminate the root cause.


Culture Change: Six Key Drivers

  • Leadership

  • Strategy

  • Decision making

  • Controls

  • Recruitment, training and competence

  • Reward


FSB’s TCF initiative

  • FSB published a TCF discussion paper at the end of April 2010 which introduces TCF concept and contextualises it by dealing with specific examples

  • Stakeholder workshops to debate TCF

  • Cross-sectoral task team

  • External consultant

  • FSA Stakeholder Workshop

  • Considering comments received


Key elements

  • Culture Change

  • Fair treatment at the heart of company’s business

  • NOT a compliance function

  • Ownership of TCF should rest at Board and Senior Management level

  • Board/Senior Management must embed culture of TCF at all levels of organisation

  • Further guidance on TCF culture framework and a self-assessment tool will be published


Key elements

  • Revisiting the regulatory framework

  • Challenges of rules based approach vs outcomes based approach to regulation

  • Combination of rules/principles in regulation so that the ‘spirit’ of what the regulator wants to achieve is made clear

  • Gap analysis of legislation of FSB to determine if all elements of TCF are adequately covered and to ensure alignment across sectors.

  • Guidance notes on TCF best practice will be published


Key elements

  • Revisiting the supervisory approach to market conduct

  • Reactive approach vs proactive approach

  • Increased focus on thematic on-site visits / testing of outcomes on the ground (for instance by way of mystery shopping)

  • Creating the right incentives

  • Relying on financial institution to do the right thing : TCF not likely to succeed

  • Visible enforcement of TCF principles, increased probability of detection, higher cost of non-compliance (steep penalties)

  • Enforcement Committee

  • Other forms of redress


Key elements

  • Consumer Education and Co-ordination with Ombuds

  • Consumers also have a responsibility to understand rights/obligations

  • TCF and Consumer Education must go hand in hand –

    - Asymmetry of information

    - Generally complex nature of financial products

    - Consumer Education Department


Next Steps

  • Roadmap document

    • Evaluation of comments and setting out what FSB will do next and how

    • Published by year-end

  • Self-assessment pack

    • Briefing document

    • Self-assessment tool

    • Initial focus on product providers

    • Piloted process, published for industry to use

  • Benchmark study

    • Survey of firms based on self-assessment tool

    • Interviews with firms

    • Publication of assessment and report

  • Supervisory Gap Sub Committee

  • Regulatory Gap Sub Committee


Conclusion

  • TCF aims to elevate fair treatment of consumers on agendas of financial institutions.

  • Behavioural change will be a multiyear project

  • After consideration of comments on discussion paper-

  • Issuance of more detailed guidance on what the FSB expects of firms in applying TCF.

  • Obligation will be on Board/Senior Management to undertake a TCF self-assessment


Thank you


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