The March edition of the ASISA publication “In the Loop” contains the following information on the time period within which newly appointed staff has to write the RE 5.
At the FSB FAIS conference on 25 July 2012, the FSB indicated that the time periods within which the regulatory exams must be completed will be amended to an exact time period from the date of appointment.
The current requirement in respect of services under supervision is that the regulatory exam must be completed by 31 December of the second year from the date of first appointment. It would be more practical to manage the process once a year, as opposed to on an on-going basis.
The practical difficulties were communicated to the FSB in a letter on 7 November 2012. The FSB indicated that the time period to pass exams will be aligned with the time periods in the Exemption for Services under Supervision. Draft amendments to the Fit and Proper Determination to this effect were expected to be published in December 2012.
The original time frame for writing the RE 5 for representatives under supervision was initially two years. This was subsequently changed to 31 December of the second year of appointment. This caused much confusion. Should these amendments be put in place, we cannot see it being backdated for people already employed. This means that there will be a period during which both arrangements will apply, depending on the date of first appointment.
