2020 Fit and Proper deadlines – Only 50 days left to comply

Through various communications this year, the Financial Sector Conduct Authority (FSCA) acknowledged the impact of COVID-19 on the financial services industry and the challenges that FSPs, key individuals and representatives might face in complying with various regulatory requirements. As a result, the FSCA granted exemptions and/or extensions in respect of the submission of statutory returns and Fit and Proper related deadlines (FSCA General Notice 2 of 2020 and FSCA FAIS Notice 22 of 2020).

It has now found it necessary to once again remind the industry of these deadlines, and to indicate that further extensions should not be expected.

It is thus a good time for you to take stock of these requirements to ensure you comply in time.

Regulatory exams

In March 2020, the FSCA communicated that all Regulatory Examinations with a deadline in 2020 will be extended to 15 December 2020.

It is therefore important to register urgently to write the Regulatory Exam to allow time in case you do not succeed at the first attempt.

For example: Registration for the exam of 10 November 2020 closes today and for the exam on 15 December 2020, on 30 November 2020. Should a candidate who writes on 10 November fail, it leaves precious little time to re-register before the final exam, which experience has shown to be fully booked long in advance.

Conversely, those who left it to the last date may find themselves up the creek without a paddle should they fail.

Moonstone’s RE registration call centre is available weekdays during business hours (08h00 – 16h00). Contact 021 883 8000 / 888 9796, e-mail or book online.

Class of Business and Qualifications

COB and Qualification deadlines applicable to supervised reps which fall between 27 March 2020 and 30 November 2020 have been extended to 15 December 2020. FSPs and supervised reps that are affected should therefore urgently consider what steps need to be taken to ensure compliance by 15 December 2020.

On 1 February 2019 the new Exemption of Services under Supervision (FSCA FAIS Notice 86 of 2018) came into effect. In terms of this Notice the transitional arrangements regarding representatives were as follows:

Representatives that were working under supervision at 1 April 2018, including Representatives that commenced with Supervision between 1 April 2018 and 1 February 2019 31 January 2020 FSCA Notice 86 – section 4(3)
read in conjunction with Board Notice 194 of 2017 – section 52(12)
Representatives working under supervision from 1 February 2019 onward 12 months from the date of first appointment FSCA Notice 86 – Condition 2(3)

It is important to note that Moonstone Business School of Excellence (MBSE) is a duly accredited institution and provides training in all nine COB modules stipulated in the Act. Visit the MBSE website if you are interested to enrol for any qualification, COB or CPD training course or send an email to

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