It was refreshing to participate in a members’ only 2023 FIA National Roadshow. The decision to stack the programme with feedback from Advisory Council and the FIA Secretariat encouraged meaningful, open and transparent engagement between members, free from external influence. This was a roadshow with a difference, designed to illustrate the lobbying and representation by the FIA on both domestic and international fronts, and to share some of the gains being made by members on behalf of members. This brief overview is based on presentations made to the Northern Region event, held in Centurion, 15 March.
PART I, THE INTERMEDIARY ASSOCIATION LANDSCAPE
First up was FIA President, Butši Tladi, who deserves commendation for raising the profile of the FIA after recently being elected as the Vice-President of the World Federation of Insurance Intermediaries (WFII). Butši opened proceedings on a philosophical note, praising FIA members for their resilience and service during the pandemic and reminding attendees that they could choose how they responded to challenges.
The key observation following the FIA’s participation in recent WFII proceedings was that the FIA, with its 15-year history, punches far above its weight. “The FIA’s voice, and how we position ourselves on the global stage, has a profound impact in terms of the outcomes that we see,” she said, before commenting on how similar the intermediary threat landscape is in an increasingly interconnected world; intermediaries worldwide worry about commission; compliance; fees; overregulation etc.
And financial sector regulators are consistent in their focus on the fair treatment of customers and customer outcomes, regardless of which country they operate in. “The beauty of this global village [is that intermediaries] can share ideas; we do not have to solve every problem from scratch,” Butši said. Wasting little time, the FIA President shared six factors that global intermediary associations will have to respond to over the next 12-months. These include changing consumer behaviour; cyber security; increased competition; regulatory change; talent retention; and the economy.
The impact of technology on both competitor and consumer behaviour – and the pace of change in the regulatory environment – were singled out as important focus areas, as was the need to encourage young talent to enter the advice profession. It is not possible to go into detail in this short overview, except to say that the FIA is keeping each of these factors ‘top of mind’ in its interactions with members, product providers and, of course, regulators.
Consumer protection; environment, social and governance (ESG) factors, sustainability and transformation; protection gaps; and regulation stood out as four main themes for financial services stakeholders globally, while the emerging risk protection gap in the non-life insurance industry (exacerbated by systemic risks such as natural catastrophe and pandemic) received special mention.
“There is a level of risk that insurers are not prepared to take on; we need to understand what that means for intermediaries and our clients,” Butši said, before singling out the energy crisis; rule of law; political reform and implementation; and economic stability as key challenges that local intermediaries need to overcome to ensure their success. These issues were dominating intermediary association discussions at the start of 2023.
The FIA President left the stage to applause, having affirmed the association’s commitment to intermediary matters and its capability to represent members’ interests at the very highest level.
PART II, THE REGULATORY ENVIRONMENT
We doubt any of the FIA members in attendance would have traded places with Samantha Williams, FIA Head of Legal and Regulatory Affairs, who was second to step up to the podium. Her task, to give an update on the fast-paced regulatory environment as it pertains to intermediaries. Sam’s presentation kicked off with some comment on the global nature of financial services regulation. “Whether you are in England, Ireland, the United States, Germany, France or Spain, everyone is grappling with the same issues,” she said.
Sam then drew attention to the roles played by the Organisation for Economic Cooperation and Development (OECD) and the International Association of Insurance Supervisors (IAIS) in steering global financial services regulation, before focusing on SA-specific regulatory interventions. It turns out that protection gaps are among the OECD’s key focus areas presently. “Every market has varying exposures: for some, flood is more of an issue; for others, climate change, cyber security or grid failures,” she said. Fortunately, international regulators realise a ‘one size fits all’ approach cannot work. Some useful points made in the early part of the presentation include:
- On affordability and risk management: “Consumer education is key to help clients understand what their risks are and how better to mitigate them; the better the mitigation of risk, the lower premiums can be,” Sam said. Also, the fact that government steps in as an ‘insurer of last resort’ removes the incentive for populations to buy insurance.
- On cyber security: Sam pointed out that both consumers and intermediaries needed to know more about the cyber risks they face because this was not just a business threat, but a national security threat. FIA members were warned that South Africa was considered ‘high risk’ for cyberattack, and encouraged to respond accordingly.
- On the intermediary: “There needs to be a proactive dialogue with intermediaries; the OECD is seeing too much engagement with insurers [when] it is the intermediary that is close to clients,” said Sam. The FIA and other intermediary associations were challenged to bring proactive solutions to global talk shops.
- On the IAIS focus areas: The IAIS believes that increased focus on diversity, equity and inclusion (DEI) will result in better prudential and customer outcomes. DEI was mentioned alongside climate change, cyber risk, digital innovation, natural catastrophe and protection gaps as areas that concerned global insurance supervisors.
Of course, FIA members are more concerned with regulatory changes that will impact their businesses and clients. And they were not disappointed by the whirlwind update on the Conduct of Financial Institutions Bill (COFI) and the dreaded Omni Conduct of Business Return (Omni CBR). To begin, Sam suggested the timings of COFI remained unclear. “We were anticipating it to be tabled in Parliament this year, but the FATF’s grey listing has shifted Treasury’s focus,” she said. It is anticipated (but not certain) that the Bill will be tabled in the second half of 2023.
Once COFI is approved by Parliament, FIA members can expect it to take anything from six to eight years for all the resulting changes to bed down. Members were reassured that COFI was a long-term project that would involve the issuing of countless conduct standards, each followed by rounds of public consultation. They were also told that unresolved RDR matters, including adviser categorisation and premium collection, would be handled via COFI.
“The Omni CBR is going to have a fundamental impact on every single regulated business in South Africa … it is intended to facilitate cross sectoral statutory reporting to the regulator,” Sam said. “It is not a replacement for your annal FAIS return and, as currently proposed, will have to be completed and filed each quarter”. The FIA has gone through the Omni CBR requirements with a fine-tooth comb and has made comprehensive submissions to the Financial Sector Conduct Authority (FSCA) but encouraged all members to participate in the public comment / feedback processes. From an SA regulatory environment, the following noteworthy points were made:
- Cybersecurity and cyber resilience: “The FSCA are extending the reach and scope of its cybersecurity requirements to include Cat I FSPs (that provide investment fund administration services) and administrative FSPs; if you have not paid attention before, and you fall within any of these categories, please do have a look,” Sam said. Binder holders must also pay close attention because insurers will expect them to comply.
- Transformation: The FIA Transformation Executive Committee has initiated a transformation guideline project to develop a practical roadmap for FIA members to transform their businesses, or rather to incorporate DEI in members’ businesses. Work on this project is ongoing, and has been supported by extensive member feedback across business size and type. Members were reminded that COFI would make transformation planning part of the licensing requirement.
- National Health Insurance (NHI): The FIA is working with BUSA’s Health Policy Unit to inform its NHI response. Business remains “in favour of universal health care” but is not in agreement with all aspects of the NHI’s current draft. The centralisation of funding and abolition of private medical schemes are among the contested proposals.
Sam conceded that there were plenty of regulatory challenges in the pipeline, and that it was impossible to cover everything during a 30-minute update. She concluded that her talk covered the main issues affecting intermediaries; and the resounding applause suggested that her coverage was spot on.
PART III: YOUR ASSOCIATION – FIA UPDATE
FIA CEO, Lizelle van der Merwe was full of praise for FIA members for their ability to navigate the evolving compliance landscape in addition to running profitable intermediary practices. “We should all reflect on the challenges that FIA members face in their businesses each day; the FIA secretariat has a full-time team of 22 people to fulfil the lobbying, regulation and representation functions that members have to tackle in addition to worrying about the commercials,” she said.
Lizelle explained that the 2023 FIA National Roadshow was about face-to-face member engagement, and reaffirmed that the association “remains as committed to members’ interests as ever”. One of the interesting observations, made early on during the presentation, was that the active volunteers within the FIA did not reflect the association’s demographics. Around 56% of the KIs and Representatives within the FIA membership are age 40 or younger, while just over half are woman. The CEO updated FIA members on four key areas, bulleted below:
FIA brand sentiment analysis: This survey was undertaken to gain an understanding of how FIA members experience the association, measuring its performance in areas such as communication, education, reliability and trust. FIA members were asked whether the association was executing on its mandate. ‘Being a trustworthy organisation’ and ‘providing relevant information’ turned out to be the factors that members placed the greatest emphasis on. A 6% weighting was assigned to ‘lobbying and regulatory matters’.
FIA intermediary experience survey: Lizelle commended members for the number of contracts rated by the survey, up an impressive 67.3% from 2019 to 2022. This survey is seen as critical to the association’s future, and there are concerns that it shows a slight downward trend in the intermediary service levels from product providers in certain categories. Product supplier interactions with intermediaries are seen as essential to both business sustainability and customer outcomes. As such, FIA members must encourage product suppliers to interact with the FIA on the annual survey results: “The more insurers that engage in these results, the better the outcome is for intermediaries and the association”.
Game plan and strategy: Defining a strategy for a diverse membership is difficult; it eventually took about eight months of planning and engagement to set out three strategic pillars for the FIA to focus on over the coming three years. These include professional and organisational development; advocacy and representation; and financial sector and market information.
Lots was discussed under the strategy heading, so we thought to share a quotable quote under each pillar. Pillar one: “We know how to give value to our clients, and therefore we will turn to experts in our field, to those who understand our challenges, to give us the training and education we need”. Pillar two: “Regulators and policymakers need to understand that FIA members have a complex job, sitting as we do between the client and the product provider”. And pillar three: “Our industry needs better data; we need a clear understanding of our businesses and what we do, whether engaging with the regulators or discussing matters among the membership”.
Focus 2023-25: A strong value proposition is non-negotiable, and the FIA has set a steep membership target of 3 000 FSPs by 2025. This target will be achieved thanks to various initiatives set in motion by the FIA over the past 18-months, to be discussed further in the Advisory Council feedback session.
“Overarching challenges such as COFI, ESG, NHI and Omni CBR can only be tackled one day at a time; if you consider the wins secured by the FIA for intermediaries going back 15-years, you will understand why we are not backing down on the critical issues,” Lizelle concluded. “The FIA will fight alongside its members; but we need your support”.
BY MEMBERS, FOR MEMBERS
Chair of the FIA Advisory Council, Roy MacLahlan, stepped to the podium to update members on the ‘by members, for members’ efforts of the association. “Members are at the heart of all that we do in this organisation; the victories that the FIA has recorded over the last 15-years are entirely due to members agitating for specific causes,” he said. Roy spent some time explaining the valuable contributions made by volunteers within the association, commending them for serving as “custodians of members’ voices”.
He then updated members on various discussions and projects that were born out of member interactions at branch and regional events, and championed at the annual Advisory Council meeting. Shortcomings in the FIA’s data and information capabilities were flagged at repeated member meetings, resulting in an FIA CRM project. “A deeper understanding of members’ licensing and training needs is seen as an important win for the association, and therefore an important focus of the association’s strategic projects division,” he said.
Other important projects rooted in member interactions include the FIA’s succession planning guidance notes; the FIA App that seeks to address communication challenges and more; and the FIA brand and website refresh. “The brand and website refresh are stunning, both speak to the new energy and vibrancy of the organisation,” said Roy, before urging FIA members to associate with the brand via their own email signatures and digital branding, wherever possible. The CPD platform also cracked a mention for offering loads of training material and allowing intermediaries to complete some of their CPD hours online, and without hassle.
Items raised for additional attention at the most recent FIA Advisory Council meeting include classification of membership; compliance guidance; consumer education; legal assistance for members; PI cover; and regulatory overburden. Each of these matters is receiving attention at various levels within the association.
“The regulatory wins achieved by the FIA on behalf of members are well-referenced; those regulatory wins and the many activities within the FIA that advance your cause cannot take place without your input and support,” concluded Roy. He singled out the association as an excellent home for discussion and engagement to shape members’ futures and encouraged all stakeholders in the intermediated financial advice industry to show their support for their association, in both action and word.