Secondary

Requirements for Compliance Officers

The changes to requirements for compliance officers (COs) caused quite a stir in the industry. We are not convinced that everybody understood how it affects them. Moonstone Compliance condensed the information below from Board Notice 127 of 2010. We trust this will clarify what is expected of you.

Internal COs, already approved by FSB on or before 9 September 2010, do not need to obtain a recognized qualification. The following requirements, however, have to be met before 31 December 2013

  • RE for COs (not yet available)
  • 1 Year experience with regard to FSP category/product categories

Internal COs approved between 10 September 2010 and 31 December 2011:

  • Must have a recognized qualification
  • Must have 3 years experience
  • Must have 1 year experience in FSP category/product category
  • Must pass the RE for COs (not yet available) before 31 December of the 2nd year after appointment

Internal COs approved after 31 December 2011:

  • Must have a recognized qualification
  • Must have 3 years of experience
  • Must have 1 year experience in FSP category/product category
  • Must pass RE for COs (not yet available) before 31 December of the 2nd year

Provision was made for a list of approved qualifications. An explanation notice was released shortly after the publication of Board Notice 127, with the following introduction:

“Please note that the list of qualifications has not yet been finalized and therefore has not yet been published as Annexure 2 of Board Notice 127 of 2010.”

Nothing has happened since September 2010.

We expect a decision to be made soon regarding the Regulatory Exams for COs. As far as we know, these exams are not yet available, as with the level 2 REs, and a cut-off date can only be determined once it is fully operational.

The same applies to Continuous Professional Development as mentioned in the Board Notice.

We advise you to concentrate and comply with those requirements that you can control.

As the saying goes: “Where there is a will, there is way” But if there is no way, how will you comply?

Wait for the next extension to be announced?

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