The FSB published a Guidance Note on the Interpretation and Application of Section 13(1)(c) on 24 June 2015.
This document has specific bearing on “…authorised financial services providers who wish to conduct financial services business with the assistance of an agent, or a network of agents engaged as their employees or mandatories…” and requires them “…to accept vicarious responsibility for the activities of their agents performed within the scope of, or in the course of implementing, the agent’s mandate or service contract.”
Further to the Guidance Note, the FSB now issued Circular 4 of 2015 which highlights certain practical considerations when applying section 13(1)(c).
Affected Moonstone Compliance clients will be advised by their compliance officers who were fully briefed on the Guidance Note at a recent conference.
