What does ROA stand for?

Record of Advice. It is the record of what you recommended to a client and why it suits their needs, required by section 9 of the FAIS General Code of Conduct — and section 9(2) requires the client to be given a copy in writing.

What is a rekord van advies?

It is the Afrikaans for Record of Advice — the same section 9 document. A client asking for their rekord van advies is asking for the record the Code already requires you to give them.

What is the difference between FAIS and the FSCA?

FAIS is the Act; the FSCA is the regulator that administers and enforces it. FSPs are licensed by the FSCA under FAIS. The FSCA replaced the Financial Services Board, which ceased to exist on 31 March 2018.

What is the difference between an endorsement and a new policy?

An endorsement changes an existing policy — adds an item, alters a condition, adjusts a sum insured — and is recorded on the schedule. It still changes what is covered, so it is advice and belongs in the advice record. A replacement of the product itself brings in section 8(1)(d), which requires the comparison of costs and consequences.

How long does a client have to complain to the FAIS Ombud?

They must complain to you first, and you have six weeks to resolve it. From your final response — or from the end of that six weeks — they have six months to take it to the Ombud. The Ombud’s monetary limit is R3 500 000 under the 2024 Ombud Council Rules.

Do these requirements apply to short-term insurance brokers?

Yes. Short-term (personal and commercial lines) advisers are FSPs or representatives under FAIS and must keep records of advice and needs analyses like any other adviser.

/ REFREFERENCE

FAIS compliance glossary for insurance brokers

Every term a South African broker meets in a compliance file or on a policy schedule, in plain language — grouped by the question you are actually asking, with the statutory reference where there is one and a link to the guide that covers it properly. The Act, the Code, the documents, the policy words that decide a claim, how a complaint runs, and the Afrikaans you will see on a schedule.

Reviewed 8 September 2026 · Broker AI team

The Act, the Code and the regulator

Four of these get used interchangeably and should not be. The Act licenses you; the Code is what you are measured against; the FSCA enforces both.

FAIS

Financial Advisory and Intermediary Services Act

Act 37 of 2002. Regulates anyone giving financial advice or intermediary services in South Africa, and sets the code of conduct advisers must follow.

FSP

Financial Services Provider

A business licensed under FAIS to give advice or render intermediary services. Its representatives act under its licence.

FSCA

Financial Sector Conduct Authority

The market-conduct regulator that licenses and supervises FSPs and enforces FAIS.

GCOC

General Code of Conduct

The conduct rules for authorised FSPs and representatives — including the duty to record the advice given and its basis.

ROA

Record of Advice

The record of what you recommended and why it meets the client’s needs. Required by the GCOC.

FNA

Financial Needs Analysis

The analysis of the client’s circumstances, objectives and risk profile that the recommendation is built on.

POPIA

Protection of Personal Information Act

South Africa’s data-protection law. Governs how client personal information in advice files must be handled and secured.

REP

Representative

A person who renders a financial service for or on behalf of an FSP. Section 13 of the Act makes the PROVIDER responsible for their competence and supervision, and section 14 makes the provider debar one who no longer meets the requirements.

F&P

Fit and proper

The honesty, competence, qualification and operational-ability requirements an FSP and its representatives must meet — at application under section 8, and continuously thereafter. Section 18(c) requires records of that continued compliance.

TCF

Treating Customers Fairly

The FSCA’s market-conduct approach, expressed as six outcomes for customers. It is not a separate statute: section 57 of the Financial Sector Regulation Act 9 of 2017 gives the FSCA the objective of promoting the fair treatment of financial customers, and TCF is how that objective is supervised in practice.

The documents in an advice file

What each one is for, and the provision that requires it. These are the documents an Ombud asks for first.

ROA

Record of Advice — s9

The record of what you recommended and why it suits the client. Section 9(1) of the General Code sets out what it must contain; section 9(2) requires the client to get a copy in writing. It is not the same document as the needs analysis.

FNA

Financial Needs Analysis — s8

The analysis the recommendation is built on: the client’s needs, objectives, financial situation, risk profile and product knowledge. Section 8(1)(a) of the Code. In short-term practice this is often called the risk analysis.

RAR

Risk Analysis Report

The short-term equivalent of the needs analysis — what the client owns, what could go wrong, what is and is not covered. Same statutory home as the FNA, different vocabulary.

REPL

Replacement record

Where a product replaces another, section 8(1)(d) requires the actual and potential financial implications, costs and consequences of the replacement to be recorded — a comparison, not a statement that a replacement occurred.

FILE

Advice file

Everything above plus the quotes, correspondence and schedules. Section 3(2) of the Code requires the records to be kept for five years after the product ends or the service was rendered — a different duty from section 18 of the Act.

Policy words that decide a claim

These are the terms a client discovers at claim stage, which is the worst moment to learn them. Each is a live source of complaints.

AVG

Average

The condition that cuts every claim proportionally when the sum insured is less than the value at risk. Underinsure by a third and you lose a third of a claim — including small ones. Applied item by item, not across the schedule.

Sum insured

The amount the item is insured for. Average measures it against the value at the moment of the loss, not at inception or renewal — so a figure that was right in March can be wrong in September.

EXC

Excess

The first amount of every claim the client carries themselves. Section 7(1)(c)(vii) of the Code lists excesses among the things that must be disclosed in concise detail — told, not merely printed on a schedule.

END

Endorsement

A change to the policy recorded on the schedule — added cover, a new item, an altered condition, a warranty. An endorsement can change what is covered, so it is advice, and it belongs in the advice record like any other recommendation.

REPU

Repudiation

The insurer rejecting a claim — for an exclusion, a breach of condition, non-disclosure or misrepresentation. A repudiation is where the quality of your disclosure at inception gets tested, which is why section 7 disclosure and the advice record matter before there is ever a claim.

SASRIA

Sasria

The state-owned insurer that covers special risks — riot, strike, civil commotion, labour disturbances, public disorder and terrorism — which ordinary policies exclude. It attaches as a coupon to an underlying policy, so it follows that policy’s sums insured and conditions.

Indemnity period

On business interruption, the period over which loss of gross profit is measured after damage — chosen up front, and the single most consequential number on a commercial schedule.

How a complaint actually runs

The FAIS Ombud’s current jurisdiction, taken from Rule 4 of the Ombud Council Rules made in 2024 under section 201 of the Financial Sector Regulation Act. Check the figures against that source rather than against an older summary — they have moved.

01The client must complain to YOU first. The Ombud requires that the complainant has tried to resolve it with the provider, and that the provider has failed to resolve it within SIX WEEKS of receiving it.
02They then have SIX MONTHS to bring it to the Ombud — from your final response, or from the expiry of that six-week period.
03The monetary limit is R3 500 000, unless the provider agrees in writing to exceed it or the complainant abandons the excess.
04A determination under section 28 of the Act can dismiss the complaint, or uphold it and award fair compensation, direct you to take steps, and make any other order a court may make.

The Afrikaans you will see on a schedule

South African policy documents and client instructions are often in Afrikaans, and searching the English term finds nothing in them. The ones that matter:

rekord

Rekord van advies

Record of Advice. The same section 9 document under its Afrikaans name — a client asking for their “rekord van advies” is asking for the record the Code requires you to give them.

polis

Polis · versekerde bedrag · premie

Policy · sum insured · premium. “Versekerde bedrag” is the figure average is measured against.

eie

Eie risiko · uitsluitings · dekking

Excess · exclusions · cover. These three are what a repudiation letter turns on.

wan

Wanvoorstelling · nie-openbaarmaking

Misrepresentation · non-disclosure. The two grounds an insurer most often gives for declining a claim, and the reason section 7(1)(d) requires you to tell the client that accuracy is their responsibility.

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Frequently asked questions

What does ROA stand for?: Record of Advice. It is the record of what you recommended to a client and why it suits their needs, required by section 9 of the FAIS General Code of Conduct — and section 9(2) requires the client to be given a copy in writing.
What is a rekord van advies?: It is the Afrikaans for Record of Advice — the same section 9 document. A client asking for their rekord van advies is asking for the record the Code already requires you to give them.
What is the difference between FAIS and the FSCA?: FAIS is the Act; the FSCA is the regulator that administers and enforces it. FSPs are licensed by the FSCA under FAIS. The FSCA replaced the Financial Services Board, which ceased to exist on 31 March 2018.
What is TCF?: Treating Customers Fairly — the FSCA’s market-conduct approach, expressed as six outcomes for customers. It is not a separate Act: section 57 of the Financial Sector Regulation Act 9 of 2017 gives the FSCA the objective of promoting the fair treatment of financial customers, and TCF is how that is supervised.
What is the difference between an endorsement and a new policy?: An endorsement changes an existing policy — adds an item, alters a condition, adjusts a sum insured — and is recorded on the schedule. It still changes what is covered, so it is advice and belongs in the advice record. A replacement of the product itself brings in section 8(1)(d), which requires the comparison of costs and consequences.
How long does a client have to complain to the FAIS Ombud?: They must complain to you first, and you have six weeks to resolve it. From your final response — or from the end of that six weeks — they have six months to take it to the Ombud. The Ombud’s monetary limit is R3 500 000 under the 2024 Ombud Council Rules.
Do these requirements apply to short-term insurance brokers?: Yes. Short-term (personal and commercial lines) advisers are FSPs or representatives under FAIS and must keep records of advice and needs analyses like any other adviser.

This page is general information about FAIS, not legal or compliance advice. Statutory references are to the Financial Advisory and Intermediary Services Act 37 of 2002 and the General Code of Conduct as amended to Board Notice 706 of 26 June 2020; the Ombud figures are from the 2024 Ombud Council Rules. Check the current text before relying on any of it.