The correct identification details of FSPs, key individuals and representatives are critical especially the correct ID numbers and/or passport numbers.
The FSB has distributed several communications and requests to FSPs to update their records, and more specifically the ID numbers of all their key individuals and representatives, to ensure that the FSB records are up to date and correct. FSPs are also requested to check the records regularly to ensure that they remain up to date.
All examination records are linked to the ID number of the person writing the examination, and since the roll-out of the examinations, problems were experienced in relation to ID numbers specifically. Below are a few examples of the most common problems encountered:
a. A person would have a particular ID number recorded on the FSB system (this number may be “old” or outdated) and then the person would write the examination with his/her new ID number. When the examination record is uploaded to the FSB then the two different ID numbers for the same person do not link up;
b. A person is a South African citizen and has an ID number recorded on the FSB system. When the person writes the examination, he/she writes the examination using his/her passport number. When the examination record is uploaded to the FSB, the two different numbers do not link up and two separate records are created;
c. A persons’ ID number has become outdated and the person is required to obtain a new ID book from the Department of Home Affairs. The ID number on the FSB system is the “old” ID number, because at the time that this ID was recorded on the FSB system, the number was in fact valid, and became outdated after it was captured on the system.
Now that the person uses this same ID to write the examination, and the examination is uploaded to the FSB, the system validates the ID number, and it rejects the number because it has become outdated. Therefore, the examination body cannot upload the exam result until the person has supplied them with an updated ID number, and the FSB has updated its records with the new ID number as well.
The updating of these records is the responsibility of the FSP, and if these records are not accurate, then the accuracy of the communication issued by the Registrar may also be affected. It is therefore of utmost importance for all FSPs to check and confirm that all their records are accurate.
Regulatory action has nevertheless commenced by means of letters of intention to suspend being issued to sole proprietors that, according to the FSB records, are in breach of the level 1 regulatory examination requirements. This process will continue in January 2013.