In 2008, the FSB realised that the fit and proper requirements could prove to be a major obstacle for new people entering the industry. This was particularly true of the minimum experience requirements. How can someone gain experience, if experience is a prerequisite for appointment? Other areas concerned the required qualifications, the level 1 and 2 regulatory exams and continuous professional development.
Board Notice 104 of 2008 provides for the appointment of representatives under supervision, and sets out the conditions for such appointments. Space does not allow us to cover the content of the BN in full. For exact details, kindly access the official document by clicking on this link.
A very common query these days come from FSPs where representatives working under supervision have now complied with all the conditions, bar one: the level 2 regulatory exams.
Conforming to the conditions applicable while working under supervision can be both restrictive and costly. Those that have now gained the required experience and qualifications, and passed the level 1 RE 5 have yet to continue working under supervision as they are unable to write the level 2 exams.
We believe that the Regulator is aware of the situation, and will announce steps to address this, soon.
The need for more information on the level 2 regulatory exams is also important for training service providers who made substantial outlays to align their training with the qualifying criteria. This is to ensure that there is 100% correlation between the criteria and their content. In order for them to be included on the list of approved qualifications, it needs to be approved by the FSB, which is another expensive operation.
Moonstone’s training division developed such courses, but we are holding back from applying for approval until such time as the roll-out of the level 2 exams, as anticipated, is announced.