the role of the organization

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The role of the organization Presented by: Justus van Pletzen QUO VADIS TUSSENGANGER?” / “QUO VADIS INTERMEDIARY?”

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The role of the organization. “ QUO VADIS TUSSENGANGER? ” / “ QUO VADIS INTERMEDIARY? ”. Presented by: Justus van Pletzen. REALITIES. Regulation Commoditisation – Consumerism Value of the intermediary (lack – perception) Image and Reputation Wfii IAIS Core principles 18/24. - PowerPoint PPT Presentation

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Page 1: The role of the organization

The role of the organization

Presented by: Justus van Pletzen

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

Page 2: The role of the organization

REALITIES

Regulation Commoditisation – Consumerism Value of the intermediary (lack – perception) Image and Reputation

o Wfiio IAIS

- Core principles 18/24

Page 3: The role of the organization

The three strategic pillars

Page 4: The role of the organization

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

Page 5: The role of the organization

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)

Page 6: The role of the organization

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

Page 7: The role of the organization

TWIN PEAKS

National Treasury - Prudential FSB – Conduct CMS Inseta SAM TCF FSGLAB Binder Regulations

Page 8: The role of the organization

RECENT SUCCESSES Binder agreements RE Level 1 exams RE Level 2 exams Health Care fees Human Capital Project Code of Conduct FIA Members are informed Broker mandates – direct FSGLAB Value of the intermediary (FIA) President of Wfii Exco member of Wfii FIA Awards Pro-intermediary Campaign

Page 9: The role of the organization

CHALLENGES

Capacity to represent all disciplines in the industry

Our own worst enemy

Trust the leaders you elect and believe in them

Page 10: The role of the organization

Member priorities

Page 11: The role of the organization

PRODUCT LIFE STAGES APPROACH TO TREATING CUSTOMERS FAIRLY (TCF)

Page 12: The role of the organization

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 industry2. Clarity of regulatory expectations 3. Education to encourage consumer responsibility4. A supervisory approach that is pre-emptive and

intensive5. Enforcement and compliance

Page 13: The role of the organization

Product life cycle

Cultural Framework

Page 14: The role of the organization

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

Page 15: The role of the organization

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”.

Page 16: The role of the organization

Desired Outcomes

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

With assessment, offering suitable alternatives to consumers.

Page 17: The role of the organization

Desired Outcomes

Providing clear and appropriate information, making charges transparent.

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

Page 18: The role of the organization

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.

Page 19: The role of the organization

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.

Page 20: The role of the organization

Culture Change: Six Key Drivers

Leadership Strategy Decision making Controls Recruitment, training and competence Reward

Page 21: The role of the organization

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

Page 22: The role of the organization

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

Page 23: The role of the organization

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

Page 24: The role of the organization

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

Page 25: The role of the organization

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

Page 26: The role of the organization

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

Page 27: The role of the organization

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

Page 28: The role of the organization

Thank you