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Moonstone Monitor -  26 April 2018
In This Week's Newsletter
 
From the Crow's Nest
Is health insurance disappearing for South Africans? – Free Market Foundation concerned about demarcation regulations
 
Your Practice Made Perfect
FSCA confirms service delivery delays – Affects rule amendments, fund registration and benefit administrator licensing
NCR proposes new income guidelines – aims to address problems stemming from income validation quandary
Compliance Workshops - Get CPD points while upskilling on “must know” information
Another CPD option from Moonstone – Possibly earn CPD hours by reading this newsletter
 
Technologically Speaking
Discover the jobs in SA most at risk of total digital automation - Stellenbosch University seminar reveals a potential of 5.7 million job losses
 
Regulatory Examinations
DOFA deadline looming – Time is running out to pass the RE 5 Regulatory Exams
Moonstone website updated with latest regulatory examination terms and conditions
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
ANZAC Day – Possibly not quite so light. Take it with a dash of music
 
 
 
 

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From the Crow's Nest
From the Crow's Nest
Health insurance disappears for South Africans
This media release from the Free Market Foundation leaves little doubt of its views on government interference in the marketplace.

The FMF is concerned that too few people are aware of and / or understand the implications of the demarcation regulations in the healthcare insurance market that came into effect from 1 April 2017 and which have a dramatic effect on how consumers pay for healthcare and the type of care we receive. The demarcation regulations force insurance companies to behave as medical aid schemes in terms of products and benefits offered. This is forcing up the cost to consumers and reducing the range and choice of benefits available.

A further concern is that the price we pay for healthcare is inflated because government actions and interference by regulation have artificially raised the price of medical scheme cover for questionable motives.

Insurance is a simple business or should be: you pay a monthly fee, which provides financial protection against unforeseen, sometimes catastrophic events. Everything can be insured: cars, homes, your life and even pets. Yet health insurance is becoming more complicated and expensive and depriving citizens of protecting themselves from health risks.

Medical aid schemes are not health insurance but in reality are pre-paid healthcare plans that cover routine check-ups, less serious illnesses and, depending on the benefit option, recurring expenses like prescription and chronic medications in addition to protecting you from a health disaster.

However, government interference has systematically raised the cost of medical aid schemes. The Medical Schemes Act made it mandatory for healthy people to cross-subsidise unhealthy people. Medical aid schemes are forced to charge person with a much lower risk of getting sick, the same amount as a person with a much higher risk.

Government also compels every medical scheme option to provide a minimum package of benefits, known as PMBs to cover all members even if they do not need such cover. Because medical schemes are now obligated to pay healthcare providers in full for PMBs, there is no incentive for service providers to control the costs, which are then passed onto the consumer in higher medical scheme contributions.

Regulatory add-ons have made healthcare much more expensive and complex than any other form of insurance irrespective of whether you get your medical scheme cover through your employer, through the government or if you pay your own premiums.

In laying the foundations for the National Health Insurance scheme the government has progressively and increasingly made it more expensive for individuals to take care of their own healthcare needs and in the process is swelling the numbers on an already overstretched public healthcare system.

Government intends to further limit medical scheme options by restricting them to providing complementary cover to the as yet undefined NHI package of benefits and to providing only one benefit option despite different people having very different healthcare needs and abilities to pay. This will destroy the private medical scheme market in South Africa and deny people access to quality healthcare. These two measures have caused the price of insurance to rise dramatically.

FMF health policy unit director Jasson Urbach said, “The solution is to allow health insurance to be exactly that: insurance. We should encourage a real health insurance market to develop by allowing insurance companies to innovate and respond to consumer needs as they do in any other market. Then, stop forcing people to buy plans that include things they won’t use and don’t want. Doing these two things would introduce genuine affordable health insurance for many more people”.

He continued, “For those who have pre-existing conditions yet cannot afford any insurance plan, we do what every compassionate society does and make sure that they get the medical care that they need, without disrupting the whole concept of insurance and making healthcare more expensive for all. Increasingly citizens face no choice as government squeezes and will ultimately destroy the private healthcare market”.
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Your Practice Made Perfect
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FSCA confirms service delivery delays
The FSCA released a communique to retirement funds and benefit administrators to confirm a delay in the finalisation of applications for rule amendments, registration of retirement funds and licensing of benefit administrators. This is due to the transitional arrangements from the Financial Services Board to the Financial Sector Conduct Authority (“the Authority”). It is anticipated that the delays will be resolved within the next five (5) weeks at the latest, by which time it is hoped that most if not all of the backlog would have been addressed. Click here to download the FSCA communication.
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NCR proposes new Guidelines to ‘fix’ Income Validation Quandary
Following our article published on 29 March 2018, dealing with the High Court case between Truworths & others v The Minister of Trade and Industry & others, including the National Credit Regulator (NCR), the NCR published its proposed guidelines to ascertain the gross income and calculate the discretionary income of a consumer as part of its affordability assessment procedures. The court case dealt with Regulation 23A(4) of the National Credit Act 34 of 2005 (NCA) which specified the required steps to be taken by credit providers to validate the gross income of prospective consumers, which was subsequently set aside on 16 March 2018.

Please note that all interested parties have until 31 May 2018 to provide the NCR with their comments on the guideline, by emailing it to compliance@ncr.org.za.

In essence, this guideline follows the provisions of Regulation 23A(4) for formally employed consumers in that their payslips and bank account statements should be used to validate their gross income. It also provides for three payslips or bank statements to be used in order to establish the consistency of the consumer’s income.

The guidelines go further to say that where a consumer was employed for less than 3 months, the credit provider may require the consumer’s latest payslip, his or her bank statements showing the latest salary deposit or a letter from the consumer’s employer as confirmation of the consumer’s gross income and the frequency thereof.

For self-employed, informally employed or consumers receiving additional income, which is not evidenced by payslips or bank statements, credit providers may choose their own verification methods, provided that the validation of the income is sufficient to meet the consumer’s debt instalments under the proposed credit agreement. What is interesting here is that the NCR requires credit providers to provide them with its affordability assessment models, procedures and mechanisms in respect of this category of consumers. It is unclear if the NCR will review these models and ‘approve’ it or if this is just to demonstrate to the NCR that the credit provider follows some kind of procedure to validate the gross income. The guidelines further provide that credit providers should first ascertain from the consumer whether he or she has a bank account. Again it is unclear what exactly is meant with this provision and it can only be speculated that, should a consumer have a bank account, credit providers should rather obtain those to verify the gross income and only use their alternative models, mechanisms and procedures where a consumer does not have a bank account.

In summary, according to Ann Crotty’s Business Day article titled Affordability regulation: the state will not contest ruling on credit dated 20 April 2018, Mr Lionel October, the Department of Trade and Industry’s director general, informed Business Day that instead of appealing the Truworths judgment, they will ‘fix the clause’ that prompted the legal challenge. These guidelines appears to be the first step taken by the department and the NCR to address the shortcomings of Regulation 23A(4) that dealt with the validation of a consumer’s gross income.

Please click here to download a copy of the Proposed Guideline.

Gerrit Viviers is an NCA compliance specialist at Moonstone Compliance and Risk Management Services. Please contact Gerrit on 021 883 8000 or by email to gviviers@moonstonecompliance.co.za if you require assistance with NCA related queries.
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Compliance Workshops – save the dates
The financial services industry finds itself in a position where not only the rules of the game changed – the game itself and even the referee has changed.

Changes in the regulator’s mandate, sweeping changes to the fit and proper regime, new requirements for insurers and proposed changes to the general code of conduct are but a few of the issues that industry has to come to grips with.

Moonstone Compliance is pleased to announce that it will hosting another round of highly informative regulatory update workshops during June 2018.

As regular attendees have come to expect, we will once again share what you need to know in a practical and understandable manner to allow you to make informed decisions on how the changes and proposed changes will impact you and your business.

This year our workshops will be accredited by a recognized body and will qualify as a CPD activity towards the accumulation of CPD hours as required by the FSCA.

The workshops will again be facilitated by Billy Seyffert and Alan Holton and will cover:
 
A concise overview of:
  The Insurance Regulations, the impact and what’s next?
  The most important Policyholder Protection Rules considerations
  Debarments – What has changed?
  Financial Sector Regulation Act – What is important to me?
The proposed changes to the General Code of Conduct and the impact on FSPs
An in-depth unpacking of the 12 elements of the New Fit and Proper Requirements and what it will take to comply.

The workshops will run from 09h00 until 13h00 and take place on the following dates and venues:

VENUE DATE
East London - EL Golf Club 5 June 2018
Port Elizabeth - PE Golf Club 6 June 2018
Cape Town - The River Club 18 June 2018
Johannesburg - Houghton Golf Club 19 June 2018
Pretoria - Diep in die Berg 20 June 2018
Durban - Coastlands Hotel Umhlanga 21 June 2018
Bloemfontein - Emoya Estate 26 June 2018

 Please save the date - we will confirm as soon as registration opens.

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Another CPD option from Moonstone
Advisers will be obliged to perform CPD activities during a “CPD cycle”. This is a period of 12 months commencing on 1 June of every year and ending 31 May of the following year, starting on 1 June 2018.

A “CPD activity” is a verifiable activity that is accredited by a professional body who also allocates an hour value or a part thereof to the activity. Activities performed towards a qualification and “product specific training” does not qualify for CPD points, but “class of business” training does.

Minimum CPD hours

This is determined by the make-up of your business. Where you render:
  • a single subclass of business within a single class of business, you must complete a minimum of 6 hours of CPD activities per CPD cycle;

  • more than one subclass of business within a single class of business, you must complete a minimum of 12 hours of CPD activities per CPD cycle; and

  • more than one class of business you must complete a minimum of 18 hours of CPD activities per CPD cycle.

We strongly advise you to study the actual details on CPD contained in the Determination, which we have extracted for your ease of reference.

Moonstone is in the process of developing a variety of CPD offerings, including regulatory update workshops and Class of Business training interventions which will count towards CPD hours.

Reading Moonstone Monitor as possible CPD activity – are be interested?

Moonstone Monitor has always provided its readers with reliable industry information. In a survey, conducted by an international company in May 2016, independent financial advisers ranked it as their number 1 source of information.

From a CPD point of view the Moonstone Monitor aligns with the CPD requirements of
  • maintaining knowledge and skills that are appropriate for an advisers’ activities and responsibilities;

  • updates advisers’ knowledge and skills; and

  • develops new knowledge and skills to assist with advisers’ current functions and responsibilities or functions contemplated in the future.

As a result the Moonstone team is looking at registering the reading of the Moonstone Monitor as a CPD activity and offering you, our reader, CPD hours for reading our content.

To ensure that its verifiable hours, each edition will have an assessment. Should you be interested, please register and access our trial.

Click here to register.
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Technologically Speaking
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Jobs at risk as a result of digital automation
A recent seminar at the University of Stellenbosch revealed that in South Africa about 5.7 million jobs will be at risk as a result of digital automation. Dr Roze Phillips, who holds a postgraduate diploma in futures studies, is an alumnus of the University of Stellenbosch Business School (USB) and the managing director for Accenture Consulting in Africa. She spoke at the USB’s Leader’s Angle event.

She shares what leaders need to do today to prepare themselves for tomorrow as leaders have the opportunity to reshape their organisations and society at large for the better if they accelerate reskilling people. She emphasized that it needs to happen at an accelerated speed.

“Digital technology will usher in a new economic era, exposing new sources of value and growth, increasing efficiency and driving competitiveness. For South Africa to rise to the challenge, the country needs to recalibrate its economy and its workforce for digital, creating entirely new products, services and markets. And the time to do that is now,” Phillips said.

Click here to read the USB’s news release about the event.
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Regulatory Examinations
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DOFA deadline looming – Time is running out to register and pass the RE 5 Regulatory Exams
Board Notice 194 of 2017, Part 4 describes the regulatory examination requirements as follows: “An FSP, a key individual and a representative must successfully pass the applicable regulatory examinations before that person's authorisation, approval or appointment.” There is of course an exemption which allows representatives some leeway in fulfilling this obligation, based on their Date of First Appointment (DOFA).

30 June 2018 is the DOFA date for candidates who are obliged to write and pass the Regulatory Examinations (REs) within the prescribed period. If your DOFA therefore falls between 1 July 2015 and 30 June 2016 you have to PASS the regulatory examination by 30 June 2018. Please note the emphasis on PASS. If you write and fail, you will be considered to not be fit and proper

What happens if you miss the Fit and Proper deadline?

Representatives who do not meet the requirements by their respective cut-off dates will be removed from the rep register and can be debarred by their FSP, until such time as they fulfil the requirements.

This is in line with the FAIS Act and may have a significant impact on your livelihood and career. If you are not Fit and Proper, no FSP will be able to employ you. And your employer may terminate your contract if you lose your status.

Steps to take
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2018 RE Schedules updated

Please note
: Registration cut-off is 11 working days before date of exam.
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Careers Platform
Are you hiring? Advertise your position on Moonstone’s Career Platform
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•   The Moonstone website - www.moonstone.co.za - enjoys an average of 20 000 visits and approximately 39 000 page views per month.
Moonstone boasts an exclusive newsletter mailing list of over 51000 dedicated financial decision makers who receive 2 newsletters per week.
Our audience is relevant and industry specific: individual and corporate advisors and brokers in the following financial sectors: Investment, Risk, Healthcare, Banking, Retirement, and Insurance.


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Featured Positions
  • Broker Consultant: CIA - Commercial & Industrial Acceptances, KZN Umhlanga - We are looking for a candidate with at least 5-10 years working experience in the insurance industry, short term insurance qualifications and RE1. Read More

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In Lighter Wyn
In Lighter Wyn
ANZAC Day
Yesterday was ANZAC Day in Australia and New Zealand.

Dear Australian media and the general public, it's time for an ANZAC Day education. Below is a list of things that current, and former members, of the Australian and New Zealand Defence Force would like to point out prior to ANZAC Day:
  1. ANZAC Day marks the anniversary of the Gallipoli Campaign of WWI. ANZAC is an acronym for Australia and New Zealand Army Corps. It’s written as ANZAC, not Anzac.

  2. Each year on the 25th of April we reflect on all Defence Force personnel, past and present, and the sacrifices they’ve made. It is a solemn day, treat it as such.

  3. ANZAC Day is one of Australia’s most important national occasions. It marks the anniversary of the first major military action fought by Australian and New Zealand forces during WWI.

  4. Traditionally, Rosemary is worn on ANZAC Day. Rosemary is found growing wild on the Gallipoli peninsula. That’s why it’s significant.

  5. The RED Poppy symbolises peace, death and sleep of the fallen servicemen/woman while the PURPLE Poppy represents remembrance of the animal victims of war. The ORANGE Poppy represents the acknowledgement of the Service families, and also acknowledges the families’ loss due to veteran suicide. The WHITE Poppy worn between 1918 - 1939 symbolises the wearers’ commitment to peace.

  6. We commemorate ANZAC Day, not celebrate it. It's not a bloody party.

  7. At dawn on the 25th of April 1915, soldiers rowed ashore in boats called ‘lighters’ during the Gallipoli landings, under fire and without outboards motors.

  8. It's a bugle, not a trumpet. The Last Post is sounded, not played. It's not a bloody dance tune.

  9. Not every serviceman/woman were 'soldiers'. Some were Sailors and Airmen. Please take the time to ascertain what Service they served in, and use the correct terminology.

  10. They’re medals, not badges. They’re citations, not pins. Learn the bloody difference.

  11. Medal recipients wear their medals on the left side of their chest covering their heart; family members/descendants wear the medals on the right side of their chest.

  12. No, I am not wearing my father’s medals, they are mine. I earned them during my Service while you were at home enjoying all the comforts I was dreaming of.

  13. Medals, ribbons and Unit Citations are EARNED, not WON. It's not a bloody chook raffle. They are awarded to the recipient, not given to them.

  14. Yes, I am allowed to wear my 'Return From Active Service' badge on any bloody day of the year that I choose to wear it. Get over it. And no, it’s not a bloody Medal.

  15. Australian and New Zealand soldiers did not retreat from Gallipoli, they withdrew.

  16. It really doesn't matter which side you wear your Poppy on, as long as it's worn with pride. Traditionally, men wear it on the left breast and women on the right breast.

  17. Please, don't try to draw comparisons between sports players and war veterans. I've never seen a sports player perform acts of heroism whilst under fire, to protect their fellow Service personnel, flag and Country.

  18. ANZAC Day isn’t a day to go and watch, or play sport. Show some respect to the brave men and women in uniform, past and present, who fought for the blanket of freedom that you currently sleep under.

  19. Having a few drinks and playing ‘2 up’ is an ANZAC Day tradition. Getting drunk, picking fights and acting like a bloody yobbo isn’t.

  20. 'Lest We Forget' isn't a throwaway line, it actually has meaning: it's an expression of remembrance, par excellence. It has dignified origins, a rich history. Don’t misuse or disrespect it.

  21. The 'Ode' comes from the poem "For the Fallen", written by Laurence Binyon. The verse, which is commonly known as 'The Ode Of Remembrance', is as follows:

"They shall grow not old, as we that are left grow old;

Age shall not weary them, nor the years condemn.

At the going down of the sun and in the morning

We will remember them."

Lest We Forget.

Here endeth the lesson.

Some do not share all the above sentiment. Listen to the Pogues sing And the band played waltzing Matilda and watch the graphic pictures, then decide for yourself.

And now every April I sit on my porch
And I watch the parade pass before me
my old comrades, how proudly they march
Reliving dreams of past glory
The forgotten heroes a forgotten war
And the young people ask, "What are they marching for? "
And I ask myself the same question.
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