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The CIS Industry


                 Tied Brokers, IFAs and RDR
                 Independent Financial advisers (IFAs) are brokers who are licensed to place investments
                 with more than one product supplier. A tied broker, on the other hand, is a financial adviser
                 who sells products for a single supplier. But IFAs, although nominally independent, are
          often incentivised by product suppliers in various ways, and these incentives can introduce bias. The
          FSCA has made changes to the General Code of Conduct under the FAIS Act that oblige advisers to
          declare any conflicts, to declare if they earn more than 30% of their remuneration from a single source
          and to ban the acceptance of any establishment fees and incentives from product providers.
             The Conduct of Financial Institutions Bill is likely to also include new labels for financial advisers
          that will oblige them to disclose to investors the level of their independence from product providers.
          The proposals so far suggest PSA (Product Supplier Agent) for tied broker and RFA (Registered
          Financial adviser) in place of IFA.


         also resulted in growth in the number of retirement fund
         members who are offered a choice of underlying unit trust
         investments for their retirement savings.
            The introduction from September 2024 of the two-pot
         retirement system is expected to result over time in greater
         preservation of retirement savings as two-thirds of all
         contributions made by members of most funds after this
         date will have to be preserved until retirement. Currently,
         members are allowed and typically do, withdraw all their
         savings when they resign.
            The new system has resulted in 2.5 million members
         withdrawing more than R43 billion in the first four months
         after implementation, but it is likely to result in an increase
         in retirement savings invested in collective investments
         over time.
         Financial Advisers (Brokers)

            Brokers, or financial intermediaries, have always played an important part in the collective
         investment schemes industry. Before 1998, initial costs, which included 3% commission payable
         to brokers, were regulated by the industry. Since fee structures were deregulated, however,
         financial advisers may be remunerated in a variety of ways, including trailer fees in the form of
         ongoing advice fees.
            The Financial advisery and Intermediary Services (FAIS) Act and its General Code of Conduct
         emphasise the need for financial advisers to determine the suitability of financial products in the
         context of an investor’s needs. Financial advisers need to be able demonstrate that they
         recommended appropriate solutions; it is no longer feasible to fall back on legacy justifications like
         brand reputation or historical performance data that ignores risk factors.
            The RDR proposals seek to make the distinction between tied brokers and independent
         brokers more clear-cut, especially as understood by consumers.
            It appears that most South Africans need the services of brokers to help them with their
         financial planning and investment decisions. As a retail investor, the differences between funds,
         platforms, multi-managers and DFMs are bewildering – and that’s before facing passive vs active,
         retirement wrappers, tax free saving accounts (TFSAs), and other options.
            Many management companies – either directly or via platforms – work through both “tied” and
         “untied” (independent) financial advisers, where the former exclusively offer the products of a
         single channel and the latter (in theory at least) offer a broader choice.
            According to the FSCA’s RDR Discussion Document on Adviser Categorisation and Related
         Matters, published in December 2019, financial services customers should be in a position to
         clearly understand what services intermediaries provide and in what capacity they act. The latter


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