Mindset, strategy, and preparation – these are the three pillars financial services providers need to focus on if they want to be ready when the Conduct of Financial Institutions (COFI) Bill comes into effect.
Think of it like training for the Rugby World Cup: those who start early and plan smart will be the ones lifting the trophy when the final whistle blows.
This was the message from practice management and compliance expert Anton Swanepoel, who spoke at a COFI update session hosted by the Financial Planning Institute of Southern Africa (FPI) last week.
COFI aims to create a unified regulatory framework for all financial institutions. The latest draft has been approved by state law advisers and is expected to reach Parliament by early 2026, with full implementation likely in 2028.
Swanepoel described COFI as a watershed moment: “It’s probably going to be the piece of market product legislation that will lay the foundation for market conduct and conduct standards for the next 50 years. That’s how serious it is.”
He emphasised COFI is not an entirely new regime: “It’s not an additional piece of legislation. It is a holistic piece of legislation, of which 95% of all the principles are already incorporated in it for you, so you only have to spend five to 10% strategically positioning yourself for the COFI Bill.”
Drawing on Springbok coach Rassie Erasmus’s disciplined approach before the 2019 Rugby World Cup, Swanepoel urged FSPs to start early and with focus: “Like Rassie, when he thought about the World Cup, he started to strategize. He started, firstly, to get the mindset of the guys ready.”
Erasmus began planning 18 months before the tournament – roughly the same timeline FSPs face now.
“Do not become a victim of voluminous legislation. Become a strategic business planner to make sure that you are ready for implementation.”
Swanepoel added: “We are now in the beginning, middle of 2025, we are like the World Cup champions, starting to put their business plans, their game plans, etc, in motion. They’re getting rid of negative vibes. They got the bomb squad. They’ve got strategies. They have got technology that they use to get battle stats.”
He emphasised leadership’s role: “You can’t afford to be a key individual with a negative energy. You will have to be positive for the sake of the rest of your team. So, get your mindset ready first, and then start strategizing very much along the lines than the Springbok team.”
Perspective is key
Swanepoel acknowledged that COFI may feel overwhelming, particularly for sole proprietors, but suggested it could prompt some to rethink their business model or join FSPs with better systems.
“If you are standing behind legislation, that’s going to be your perspective. But if you look legislation in the eye for what it is… You were informed. You will see that COFI is going to be a pivotal moment in the future structure of your FSP.”
Quoting Jeff Bezos, he said: “Everybody asked me, what’s going to change, and it’s important, but the more significant question is what’s not going to change.
“Rather look at what’s not going to change in the next 10, 20, 30, 40 years, and you pull the strategy around that. This is how you do it.”
He described market conduct rules and business planning as “two sides of the same puzzle”, using a jigsaw analogy: the colourful side reveals the full picture, while the grey backs resemble complex laws such as COFI, the Protection of Personal Information Act, and the Financial Intelligence Centre Act.
“Do not separate the two. It’s part of the same puzzle.”
Strategy: planning with intent
Swanepoel urged FSPs to adopt a deliberate approach to strategic planning, similar to Erasmus’s alignment sessions.
“You know about the Rassie alignment groups on YouTube. You have seen how they entered into the room, and Rassie discussed all the strategies and the fundamentals, and he took ego out of those alignment sessions.”
He encouraged governing body members to invest in focused planning: “One of the best things you can do is to invest in a proper two-day strategic planning session, strategically position yourself for the future.”
Mindset is the starting point, followed by structured, purposeful strategy.
“Rassie was deliberate. He created the bomb squad. He was absolutely relentless in playing with the guys’ psyche. He masterfully just shifted the guys’ perspective.”
He noted FAIS as a dress rehearsal for COFI and advised particularly small and medium-sized FSPs to focus only on the relevant sections of the legislation.
“We need to take the volumes of COFI and reduce it [to] only those sections in the legislation that apply to you – small, small to medium, medium-sized FSPs. You will see that FAIS is there, and we can strip out all the other pieces of legislation that applies to the banks, insurance and the fund managers and the DFAs.”
Technology: a critical tool for COFI readiness
Swanepoel identified technology as the key enabler for meeting COFI obligations.
“Technology is going to be the number-one leveller of the playing field, because we cannot even begin to make sure that we meet all our obligations without technology.”
He advised firms to review their internal processes and adjust what to stop, continue, or start for better client service.
“There’s always room for improvement. Do not become complacent.”
The compliance foundation under FAIS is in place, and “if you master those and you integrate that into technology with workflows, automation, pre-population, you are going to be surprised of how quickly you’re going to transition from FAIS to COFI, from a systems point of view.”
Many FSPs have yet to fully automate advice processes. “If you’re going to wait for COFI, I’m afraid you’re going to lose a hitch in the marketplace.”
He stressed integrating key tools: “Then the integration of Astute, the EasyFICA or Beeswax, or DocFox, the integration of FICA into your process, the integration of financial planning software, cash flows, CRM, Outlook, with your Teams, Transcribe, QuicklySign – we can go on and on, and on.”
Management information systems (MIS) can automate compliance reporting. “Your MIS – that starts capturing the information of your clients, so that you can be prepared to submit a compliance report that will automate many of those statistics, or then your FSP profile.”
CRM integration is a priority: “If there’s one thing you can start doing, it is to make sure you need to integrate software CRM.”
Automation also reduces compliance paperwork and duplication, smoothing the client and advisor experience.
“It is the automation and integration and pre-population into your systems to make it a smoother client and advisor experience.”
Many systems already embed Artificial Intelligence capabilities. “Many of these system providers have already incorporated AI into their software, so you can benefit from those, and you may save the time and energy of implementing your own AI whilst bearing the risk of AI, because it doesn’t come without risks.”
His warning to firms without systems was blunt: “If you don’t have a system, you simply can’t afford inconsistent results. You have got to create 10 extra people in your business through technology to have a fighting chance of growing your profits over the years.”
Client engagement: from compliance to ‘blowing clients’ socks off’
Swanepoel said client engagement must go beyond compliance to build trust, culture, and long-term value. He urged FSPs to review every step of their engagement process to exceed regulatory requirements.
He outlined the 10 steps of professional client engagement: prospecting, setting appointments, professional introduction, sharing and gathering client information, agreeing on services, analysis and report preparation, presenting proposals and recommendations, agreeing on financial plans or products, implementation, and ongoing service.
He advised: “You should stress test in your strategic planning session, every one of those compliance documents you need to stress test in the 10-step process of client engagement.”
Culture, he said, is central. COFI demands a values-based culture, including “first, an ethical culture, second, a Treating Customers Fairly culture, but ultimately those two cultures, what you want is an outcome of high trust.”
Although fair treatment of customers is essential, Swanepoel urged FSPs to aim higher. He again referenced Bezos.
Swanepoel explained: “I’m paraphrasing now, but it comes down to this. They start with a customer and everything else follows. He’s quoted by saying, we want to blow their socks off. Now if we settle for treating customers fairly… treating customers fairly pales in comparison to treating customers to blowing their clients’ socks off.”
“That’s my inspiration to you today,” he concluded. “If you read through the COFI draft, if you read through the conduct standards, do not ask yourself, what is this rule about? Ask yourself, how does this principle help me to blow my customers’ socks off.”
