Monitoring programme
An annual, risk-based monitoring plan agreed with the Key Individuals, covering licence conditions, the General Code of Conduct, fit and proper, advice files, FICA controls and complaints.
FAIS s.17 · FSCA-approved compliance officer
Outsourced Compliance Officer for FSPs
An FSCA-approved compliance officer appointed to your licence, running your monitoring programme and filing your compliance report, without adding a salaried role.
The appointment the FAIS Act requires, delivered as a service.
Section 17 of the FAIS Act requires an FSP with more than one Key Individual, or with one or more representatives, to appoint a compliance officer approved by the FSCA. The officer must be independent enough to report findings without fear or favour and competent enough to be approved: Board Notice 127 of 2010 sets the qualifications, experience and the Phase I and Phase II approval process. Most independent FSPs do not have, and cannot justify, a salaried person who meets that standard.
RCC's outsourced compliance officer service places one of our FSCA-approved compliance officers on your licence. The appointment is lodged with the FSCA, the monitoring programme is agreed with your Key Individuals, and the officer carries the statutory duties for as long as the appointment stands. It sits inside our compliance monitoring practice, so the officer's findings are backed by the same file reviews, registers and reporting cycle we run for every monitored client.
What the officer does
The duties that come with the appointment
Compliance reports
The annual compliance report to the FSCA in the officer's name, with the findings, the remediation and the Key Individual's sign-off, filed within the prescribed period after your financial year-end.
Reporting irregularities
Where the Act requires it, non-compliance that is not remedied is reported to the FSCA. The officer tells you first, in writing, with the time you have to fix it.
Advice to management
Written guidance to the Key Individuals and the board on regulatory change, new products, representative appointments and the handling of complaints and conflicts.
FSCA liaison
Queries, information requests and conduct reviews are handled by the officer, who speaks the Authority's language and knows what it is actually asking.
Registers and records
The register of representatives, the competence register, the complaints register and the conflict of interest register are reconciled and kept inspection-ready.
Who it is for
FSPs that need the role, not the salary
The service fits Category I FSPs with between two and fifty representatives, Category II discretionary managers who need an officer with investment experience, funeral administrators under Category IV, and newly licensed FSPs whose licence application named RCC as the compliance officer. It also suits FSPs whose in-house officer has resigned and who need an approved replacement before the next compliance report falls due.
Accountable institutions have a second, separate requirement: the person responsible for FIC Act compliance under section 42A. Where the same officer can hold both roles we structure the appointment that way, and our FICA implementation team supports the RMCP side.
How it runs
From appointment to the first report
01 · Scoping
We review the licence, the categories, the register and the last compliance report, and agree the monitoring scope and the reporting calendar with the Key Individuals.
02 · Appointment
The officer's Phase II approval for your FSP is lodged with the FSCA and the profile is updated. Any outgoing officer's removal is handled in the same submission.
03 · Monitoring
The programme runs on its calendar: file sampling, register reconciliation, FICA testing and complaints review, with findings reported quarterly.
04 · Reporting
The annual compliance report is prepared from the year's findings, reviewed with the Key Individuals and filed with the FSCA in the officer's name.
Common questions
Questions we are asked
Does every FSP need a compliance officer?+
An FSP with more than one Key Individual, or with one or more representatives, must appoint a compliance officer approved by the FSCA under section 17 of the FAIS Act. A sole proprietor with no representatives is the exception and carries the compliance duties personally.
Can the compliance officer be external?+
Yes. The Act allows the officer to be an employee or an external compliance practitioner, provided the person is approved by the FSCA for your FSP. Most independent FSPs use an external officer.
What does the service cost?+
A monthly retainer fixed for the year, based on your licence categories, the number of representatives and the monitoring scope agreed at the outset. It is quoted after a short scoping review and includes the annual compliance report.
How quickly can the appointment be made?+
Where RCC's officer already holds Phase I approval, the Phase II approval for your FSP is a profile submission to the FSCA. We prepare it within days of the engagement letter; the FSCA's processing time runs from there.
What happens to findings?+
Findings are reported to the Key Individuals in writing with a remediation date. They appear in the annual compliance report with their status. Non-compliance that the FSP does not remedy must be reported to the FSCA, which the officer will tell you before doing.
Related services
Services that go with this one
- Compliance monitoringOngoing FAIS, FICA and NCA monitoring, plus outsourced compliance officer services.Explore compliance monitoring
- FICA implementationRMCP drafting, AML and CFT measures, inspection readiness.Explore fica implementation
- Governance frameworksInternal controls and regulatory readiness that survive scrutiny.Explore governance frameworks
- Key individual servicesKey Individual placement, capacitation and training.Explore key individual services
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