The monthly compliance report for FSPs
The monthly compliance pack is where the Compliance Officer actually does their job. This is a plain-English guide to what belongs in it, who reads it, and how the monthly cycle rolls up into the Annual Compliance Report.
What is a monthly compliance report?
A monthly compliance report is the pack a Compliance Officer produces each month to evidence that the FSP is meeting its FAIS, FICA and POPIA obligations on an ongoing basis. It captures monitoring reviews, findings and remediation, the state of the statutory registers (complaints, gifts and conflicts, CPD, breaches), Section 17 material irregularities, and the compliance calendar status.
What does a monthly compliance pack contain?
A typical monthly compliance pack contains: an executive summary; the compliance monitoring plan with tests completed in the period; findings and corrective actions; complaints register movements; gifts and conflicts register entries; CPD register status per KI and Rep; Section 17 irregularity register updates; risk-and-compliance dashboard vs the annual plan; and outstanding obligations. The pack is dated, versioned and signed by the CO.
Who reviews the monthly compliance report?
The monthly report is delivered to the FSP’s Key Individual and, where applicable, the board or accountable executive. The KI reviews and signs the acknowledgement. The pack sits in the FSP’s compliance file and is one of the first things an FSCA inspector asks for at a routine visit.
What triggers a Section 17 irregularity report?
Section 17 of the FAIS Act requires the Compliance Officer to report to the FSCA any material irregularity: a breach of the FAIS Act, its Board Notices, or the General Code of Conduct that has resulted or is likely to result in material prejudice to clients, or that indicates a material weakness in the FSP’s operational ability or financial soundness. The CO must report the irregularity to the FSCA as soon as possible; the monthly pack is where these are logged and tracked.
How does the monthly pack feed the annual compliance report?
The Annual Compliance Report to the FSCA (due 15 September for the reporting period ending 31 May) is a summary of the year’s monthly cycles. Monthly findings, remediation, register movements and Section 17 activity are collated into the FSCA’s annual return format (Omni-CBR). Running the monthly cycle properly is what makes the annual report a compilation exercise instead of an emergency scramble.
Do all FSPs need a monthly compliance report?
Where an external Compliance Officer is appointed the monthly report is standard practice. Even where a small FSP operates without a separate CO and the KI carries the compliance function directly, a monthly cadence of monitoring, register updates and evidence collection is what makes the Annual Compliance Report defensible and the FSP inspection-ready.