Discretionary Asset Management

This Standard Compliance Officer Service is for Category 2 (Discretionary) Financial Service Providers (FSPs) that wish to outsource the compliance officer appointment specified in the Financial Advisory & Intermediary Services Act 2002 (FAIS) to a professional services provider.

Compli-Serve will supply an independent and qualified compliance officer as required under Section 17 (1) (a) of the FAIS Act.

The Service consists of several components as described below;

Initial Assessment

This is an essential first step of the compliance risk management process where a detailed assessment of the investment manager’s practice is undertaken by Compli-Serve to assess current readiness levels for the regulatory requirements of FAIS. It is designed to identify areas of prime concern at an early stage. The assessment is conducted on an interview basis with the key persons in the practice and any other persons as deemed necessary. Feedback and recommendations are presented to the client at a follow up consultation.

FSP FAIS License Review

Compli-Serve will review the current FAIS license to ensure submission integrity and to ensure that the appropriate license categories have been obtained.

Process Implementation

Once readiness levels have been assessed and conclusions reached Compli-Serve will advise upon the following:

· What stills needs implementation to ensure FAIS readiness; and

· What, that is already in place, needs amending to ensure compliance with regulations.

Compli-Serve endeavours to amend rather than replace existing processes.

Monitoring

Compli-Serve utilises various monitoring techniques for its ongoing client monitoring process and this monitoring process, with the client, takes place at regular intervals during the year..

Initial follow up

This is generally undertaken approximately 30 days after the process implementation consultation to assess the level of client compliance with mutually agreed recommendations.

Regular checks

Regular on-site visits/Teams meetings, to assess the progress of implementation, are carried out. A feedback report is prepared for the client summarising any action that may be required. Areas that remain outstanding from a previous visit are normally given a higher priority.

Bi-Annual Compliance Report

Compli-Serve to assist in the completion of any compliance reports that need submission to the Financial Sector Conduct Authority (FSCA).

Client Support Services

Ongoing support is an important component of the Outsource Service and is delivered to our client via our Standard, Premium Support and Legal Services that are described in more detail below.

1. Standard Support

This level of support is delivered via our in-house support facilities detailed below and is included in the monthly subscription fee;

· Telephonic support – Make a call to the support centre on 0878976970. Service available during business hours Monday – Thursday 08:30 to 16:30 and Fridays 08:30 to 16:00.

· E-mail support – Send a mail to the support centre via support@compliserve.co.za

· Web Site Support Clients – are allocated a username and password to gain access to the protected areas of our website and gain access to the online support facilities.

2. Premium Support

Premium Support will relate to services that would not be required by the client on a regular basis and are therefore excluded from the monthly fee. Premium Support will be quoted on a case by case basis and priced at the ruling Compli-Serve rate which is available upon request.

· On Site interventions – Mutually agreed onsite interventions that fall outside the schedule of visits detailed under the Monitoring section.

· Complaint Handling (Initial Review & Response) – In the event of a client complaint Compli-Serve will review the complaint and advise the key individuals as to the merits of the complaint in terms of the FAIS Act. A case file will be opened, and a timeline inserted to ensure compliance with the rules of the FAIS Ombud. A response will be prepared to the client detailing the proposed course of action.

· Complaint Handling (Ombud Liaison and Legal Representation) – In the event of a client complaint CS can get involved in proceedings at a number of levels working in conjunction with compliance officers and external counsel. CS will liaise with the offices of the FAIS Ombud or the Financial Sector Conduct Authority as may be required on behalf of the respondent FSP.

PLEASE NOTE

The Service is rendered on an annual contract basis and is subject to the Terms and Conditions of Service. Prices will vary depending on the number of authorised individuals operating under the license entity and the levels of client discretion.

Please note that some premium services are dependent of availability of specialist resources at the time of request.