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Investment Indicators - 23 April 2018
In This Week's Newsletter
Rates Review
Investment Rates
Money Market Funds
Top 3 Rates
 
From the Crow's Nest
Proposed amendments to Premium collection - Alan Holton clears up apparent confusion regarding intention of draft legislation
 
Your Practice Made Perfect
Don’t let good news headlines thwart your savings plans – Sound advice from Alan Gray to advisers and clients
Setback for home loan defaulters – High Court ruling on selling of dwelling without reserve price
 
Regulatory Examinations
Latest on study material
How can using the Preparation Guide help me prepare for the Regulatory exams?
Schedules for 2018 - next UK opportunity is on 1 October 2018
 
Careers Platform
Are you hiring? Moonstone offers biggest industry platform for employers
Featured Positions
 
In Lighter Wyn
Great thoughts
 
 
 
 

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"We know what we are, but know not what we may be”
- William Shakespeare
 
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Rates Review
Top 3 rates
 1. Secured Investment Rates
Please note that (G) indicates a Guaranteed and (L) a Linked product. In order to understand the difference between guaranteed and linked rates, kindly click here for an explanation.
 R 100 000
 
 
 
     
  Company This Week Last Week
1 1Life (L) 6.640% 6.630%
2 Clientéle Life (L) 6.620% 6.670%
3 Absa (L) 6.300% 6.265%
     
 R 1 000 000
     
     
  Company This Week Last Week
1 Clientéle Life (L) 6.720% 6.770%
2 1Life (L) 6.640% 6.630%
3 Discovery (G) 6.624% 6.658%
     
 2. Money Market Funds
  Company This Week Last Week
1 Cadiz 7.890% 7.900%
2 Allan Gray 7.800% 7.800%
3 Coronation 7.690% 7.800%
Please bear in mind that our figures, though based on the actual quotations that you also use, are for information purposes only, and can never replace the official quotation from the product house. In terms of the guarantees, you are requested to clarify the exact extent of such guarantees with the product house prior to advising clients.
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From the Crow's Nest
From the Crow's Nest
Proposed amendments to Premium collection
by Alan Holton
As I mentioned in my previous article, Draft Amendments on Premium Collection,  a number of significant amendments have been proposed to the Regulations to both the LIA and the STIA.

A recent industry article dealt to some extent with the proposed draft amendments to the STIA Regulations insofar as premium collection is concerned. The article suggests that an issue with the current method of premium collection is the perceived risk insurers have when the IGF guarantee is insufficient to cover the outstanding premiums. This risk, says the article, will be exacerbated when the IGF guarantees are no longer available.

The article then suggests that there is a problem with premium collection and proposes as a solution that premiums be collected and paid directly into the insurer’s bank account.

This may lead to some confusion in the industry.

Insurers have always been entitled to insist that premiums be paid directly into their own bank account. The implications inherent in the article, however, are that this is now a requirement directly as a result of the proposed repeal of the requirement that collecting intermediaries hold IGF cover – and that there is no alternative.

Treasury however, are of the view that the repeal of the security requirements could very well mean that an insurer will, nevertheless, still require some form of guarantee or fidelity insurance cover from an intermediary when allowing it to collect premiums on its behalf. Insurers will do so in the interest of good governance rather than as a consequence of a regulatory requirement.

Treasury released a “Statement explaining the amendments” (Annexure E) in which they state that the intention of the amendment to the LTIA Regulations is to provide more adequate protection to policyholders and to align the legislative framework governing premium collection across the LTIA and the STIA. Treasury says further that, in addition to aligning the requirements relating to premium collection in the LTIA and STIA, it is essential that the regulatory framework for premium collection remains relevant to current practices in the market.

There is no intention to interrupt current premium collection practices – rather the intention is to improve policyholder protection. There is no indication from Treasury that premiums must now be paid directly to insurers. The proposed amended Regulations are intended to improve the premium collection framework for the entire insurance market and to compel insurers to have appropriate oversight by independent intermediaries collecting premiums.

The following excerpt from the Treasury Statement is relevant to these considerations:

“Due to the fact that the IGF requirements will be repealed from Regulation 4 and because several significant risks regarding premium collection have been identified in respect of the manner in which insurance premiums are dealt with by independent intermediaries collecting premiums (see Proposal E and F, 2014 RDR), it was deemed necessary to improve the current legislative framework governing premium collection. The proposed amendments therefore propose to improve the premium collection legislative framework by, amongst other things, including:
  • a prohibition on an independent intermediary delegating the authority to collect premiums provided to it by a short-term insurer;

  • requiring that certain matters must be addressed in the written authorisation provided by the insurer to the independent intermediary;

  • requiring that the independent intermediary collecting premiums must maintain a separate bank account for the premiums collected;

  • prohibiting the independent intermediary from using the premiums collected for any business or commercial purposes; and

  • imposing governance and oversight requirements applicable to a short-term insurer when allowing an independent intermediary to collect premiums.

It is acknowledged that some of the existing premium collection arrangements between short-term insurers and independent intermediaries will not be consistent with these amendments and such arrangements will have to be restructured. Further, short-term insurers that currently do not have appropriate oversight over the functions performed by independent intermediaries in respect of its current premium collection arrangements will have to set up appropriate governance structures. Seeing that there is currently no requirement in the LTIA Regulations governing premium collection, National Treasury acknowledges that the new requirements with regards to premium collection have the potential of having a significant impact on the long-term and short-term insurance industry.

Consideration will be given to appropriate transitional arrangements necessary for some of the proposed amendments to mitigate the possible impact thereof. Specific comment is invited from both industries on what the cost and other potential implications of complying with these new premium collection requirements will be, and on transitional amendments necessary to facilitate the implementation of these requirements.” (Emphasis added)

Alan Holton is an independent compliance officer and regular consultant to Moonstone.
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DISCOVERY INVEST CELEBRATES DECADE OF TOP PERFORMANCE
 
The PlexusCrown survey for the fourth quarter of December 2017
saw Discovery Invest ranked as the fourth top CIS management company in the country. The asset manager’s overall score shot up from 12th spot to 4th spot between March and December last year.

The Discovery Balanced Funds have provided consistent bench-mark beating returns*. The Discovery Balanced Fund enjoyed top quartile performance over one, three, five, seven and ten years, with returns of 10.85%; 6.24%; 10.78%; and 9.98% respectively to the end of February 2018. Pretty impressive, and consistent, for a ten-year old.

Source: Profile Data, 28 February 2018

Disclaimer

This article is meant only as information and should not be taken as financial advice. For tailored financial advice, please contact your financial adviser.

Discovery Life Investment Services Pty (Ltd), branded as Discovery Invest, is an authorised financial services provider. Registration number 2007/005969/07.

Please click here to read our full disclaimer.
 

Your Practice Made Perfect
Your Practice
Don’t let good news headlines thwart your savings plans
Positive sentiment in the country is being fuelled by a change in political leadership, the stronger rand, a higher-than-expected GDP growth rate and a more optimistic consumer outlook. The latest decision by ratings agency Moody’s to keep South Africa's sovereign debt at above investment grade and revise its outlook from negative to stable, confirms this.

But, says Rob Formby, chief operating officer designate at Allan Gray, while the current mood is indeed good news for South Africans, investors should not let this distract them from continuing to tighten their belts.

“These good news headlines are a relief for many South Africans, but the reality is that a lot of work is required to fix the economy and the country. South African investors should not make changes to their long-term savings plans based on the recent euphoria alone,” says Formby.

Despite the recent interest rate cut, a Value Added Tax (VAT) hike – the first increase in the country since 1993 – coupled with the below-inflation increase in the bottom three personal income tax brackets and no inflation adjustment to the top four tax brackets, will see people out of pocket.

“Amidst this climate, we should still look at frugality as the new normal, adopt a savings mentality where possible, and look for ways to rein in spending,” he says, adding that going back to investing basics in 2018 will help investors stick to their plan.

“Investors should focus on spending less money than they earn, saving wherever their budget allows, and starting as early as possible.”

A recent report released by Lloyds Banking in the UK is calling for 2018 to become known as the year of savvy spending: It claims that, an astounding, 50% of people have changed their spending habits since the start of the year.

“South Africans would do well to follow this trend,” Formby notes.

Formby further reminds investors not to make sudden changes to their portfolios in response to the news headlines.

“Investors often lose out on performance when trying to adjust their investments based on day-to-day news and events. It makes far more sense to base investment decisions on what you need to reach your goals, and then stick with the plan,” he concludes.

Share the article with your clients – click here to download pdf version
.
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Setback for home loan defaulters
An article on the rights of home loan defaulters was recently published on the GroundUp website. Below is a summary from Legalbrief Today on the matter.

In a setback for home loan defaulters, the Gauteng High Court (Pretoria) recently dismissed a challenge against the constitutionality of certain rules of court which enable the home of a debtor to be sold without a reserve price. The primary issue the court had to determine was the constitutionality of rule 46(12) of the High Court rules which enable a creditor to attach and sell a debtor’s home without a reserve price being set. Under this rule, it is possible for the bank to sell a debtor’s home for any price and recover any amount they can for the outstanding debt, notes a GroundUp report examining the judgment.

In reaching its decision, the court dealt with four main issues –
  • will a reserve price result in a home being sold for a higher price;

  • does a sale without a reserve price constitute an arbitrary deprivation of property;

  • does the fact that the rules were subsequently amended mean that the previous rules were defective and

  • does the rule infringe upon the right to adequate housing?

Among other things it found that because there is judicial oversight over the process of determining whether a house is specifically executable before a warrant of execution is issued, the right to adequate housing is already protected. As such, there was no need for further protection in the form of a reserve price. It also decided the question of whether a reserve price should be set or not is in fact a policy decision which is best left to Parliament to determine.

The report notes that although the amended version of the rules, which came into effect in December 2017, enables a reserve price to be set in certain circumstances this is still not the default position. Debtors whose homes were attached prior to the amended rules will still be in a potentially precarious position. For this reason, Lawyers for Human Rights, intend to appeal.

Full GroundUp report

Judgment.
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Regulatory Examinations
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Latest on study material

We are still inundated with enquiries about “the new” INSETA study material.

There is no NEW study material. Only a small section is affected by the new Fit and Proper regulations, as outlined in the latest Preparation Guide.

It is therefore important that learners familiarise themselves with this document which contains the amended qualifying criteria and tasks.

According to the Inseta website, the amended Inseta training manual will be available from the middle of May onwards.

Click here to download the latest Preparation Guide.

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How can using the Preparation Guide help me prepare?
Candidates should not find it difficult to prepare for the exam because the Prep Guide outlines exactly what the examination will be testing and where to find the information. Studying the Prep Guide is in fact the very first step a candidate should take to ensure that he or she knows what they have to know, and where to find the required information.

For Example:
 
Task
no
Task QC Qualifying
Criteria
Knowledge
(K) or Skill
(S)
Legislation
Reference
Where in the legislation is this task and criteria covered that must be studied.
7 Dealing with complaints that have been submitted to the Ombud for FSPs 1 Explain the role and authority of the Ombud for FSPs K FAIS Act - Sec 1 Definition of Complaint
FAIS Act - Sec 20(3)
FAIS Act - Sec 20(4)
FAIS Act - Sec 27 & 27(3) & 27(4)
FAIS Act - Sec 28
FAIS Act - Sec 28(4)(a)
FAIS Act - Sec 31
BN 81 of 2003 - Sec 3
BN 81 of 2003 - Sec 4(c)

In the Preparation Guide the FSCA shares 6 steps that will work most effectively for examination preparation:

Step 1: Refer to the mapping document for the exam you are planning to write. (Appendix A in the Preparation Guide)

Step 2: Look at the number of criteria for each task (RE 1 has 16 tasks that will be tested RE 5 has 8 tasks that will be tested).

Step 3: To prepare for the exam, you must spend time each day and study the legislation and supporting training material. One should systematically select one criteria at a time. (allocate study hours per day to prepare)

Step 4: To start, read the task, and then the first criteria. Then refer to the legislation for these criteria, and read the legislation referred to.

Step 5: Now refer to the additional support or training material (for example the INSETA training material) and study the section in the training material dealing with those particular criteria.

Step 6: Then go back to the legislation itself, and read it again.

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2018 Schedules updated

Please note
: Registration cut-off is 11 working days before date of exam.
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In Lighter Wyn
In Lighter Wyn
Great thoughts

Great thoughts 1

 

Great thoughts 2

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