the role of the organization presented by: brian van flymen “ quo vadis tussenganger? ” / “...
TRANSCRIPT
The role of the organization
Presented by: Brian van Flymen
“QUO VADIS TUSSENGANGER?” / “QUO VADIS INTERMEDIARY?”
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
o Wfiio IAIS
- Core principles 18/24
COMMUNICATION (HOW)
Technology New Connect
o Dailyo Weekly – Indabao 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
o Consolidationo Retire/ Leave the industryo 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:
1. A change of mindset of the industry
2. Clarity of regulatory expectations
3. Education to encourage consumer responsibility
4. A supervisory approach that is pre-emptive and intensive
5. Enforcement and compliance
Product life cycle
Cultural FrameworkCultural 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