A completed Record of Advice, section by section

Before you copy anything from this page

A completed example is useful for seeing the SHAPE of a defensible record. It is not a form to transcribe, and a well-structured record of bad advice is still bad advice.

1. 01The reasoning has to be yours. The value of section C below is not its phrasing — it is that a reader who was not in the room can follow why this cover, for this client.
2. 02The facts here are invented. "Thandeka Mokoena" does not exist, ABC Panelbeaters does not exist, and the premiums are illustrative.
3. 03This is not advice about how to advise. Broker AI is not a licensed FSP; it drafts documents, and the adviser advises and signs.

A. Client and adviser details

The identifying block. Dull, and the first thing an Ombud reads, because it establishes who owed the duty and when.

B. What the client told me

The analysis required before a recommendation can be made. This section is the reason the recommendation later makes sense; without it, section C is an assertion.

1. 01Three vehicles used in the business: a 2019 Isuzu NPR 400 truck (financed, R480,000 outstanding), a 2021 Toyota Hilux, and a 2016 VW Polo used by an employee for deliveries.
2. 02Annual turnover approximately R4.2m. Goods carried are third-party retail stock, average load value R180,000, occasionally to R400,000.
3. 03Current cover: vehicles insured individually on a personal-lines basis by a previous broker. No goods-in-transit cover. No liability cover.
4. 04Stated priority, in the client’s words: "if the truck goes I cannot trade". Second priority was cost.
5. 05The client declined to discuss business-interruption cover at this meeting and asked to revisit it at renewal.

B — why this version holds up

Four things this section does that a weak one does not.

C. What I considered, and what I recommended

The section most often reduced to a single product name. A record of advice is a record of the reasoning, so what was set aside belongs here as much as what was chosen.

1. 01CONSIDERED: keeping the three vehicles on separate personal-lines policies. Set aside — the Isuzu is used commercially and the Polo is driven by an employee, so a personal-lines policy would likely be voidable on both. Cheaper, and it would not have paid.
2. 02CONSIDERED: a commercial motor fleet policy with third-party-only cover on the Polo. Set aside — the saving was approximately R310 per month and left the client exposed on a vehicle in daily business use.
3. 03RECOMMENDED: a commercial motor fleet policy covering all three vehicles comprehensively, plus goods-in-transit cover to R400,000 per load, plus R5m public liability.
4. 04REASONING: the truck is financed and its loss stops the business, so comprehensive is required on the client’s own stated priority as well as by the finance agreement. Fleet rating brought the combined premium below the three separate policies. Goods-in-transit was added because the client carries third-party stock and had no cover for it — an uninsured loss at the stated average load value would exceed a month’s turnover.
5. 05NOT RECOMMENDED AT THIS TIME: business interruption. Raised, and the client asked to revisit at renewal. Flagged for the annual review.

D. Replacement — the section 9(1)(d) comparison

Where a product replaces another, the Code requires the comparison to be recorded. This is the provision most likely to be raised later and most likely to be missing, because replacement usually happens quietly inside a review.

E. Disclosures made

What was disclosed, when, and in what form. The Code requires certain disclosures before or at the time of the transaction, and some to be confirmed in writing afterwards.

1. 01FSP name, licence number and authorised categories — given verbally at the meeting and in the written record.
2. 02The nature of the commission earned on this business, and that it is paid by the insurer.
3. 03That the adviser is not a representative of any single insurer and the basis on which insurers were approached.
4. 04The client’s duty of disclosure and the effect of non-disclosure or misrepresentation on a claim.
5. 05Cooling-off rights and how to exercise them.
6. 06Complaints procedure, including the FAIS Ombud’s contact details.

F. What the client decided

Advice is a recommendation, not an instruction. The record has to show what the client actually chose, including where they went against the recommendation.

1. 01Accepted the fleet policy and goods-in-transit cover as recommended.
2. 02Accepted liability cover at R5m rather than the R10m initially discussed, on cost grounds. Adviser recorded that R10m was recommended and R5m was chosen.
3. 03Deferred business interruption to the annual review, at the client’s request.

F — the line most files leave out

The R5m-instead-of-R10m entry is the most valuable sentence on this page.

1. 01A file recording only what the client bought cannot show that something more was recommended. If a R7m liability claim later exhausts the cover, the difference between "we sold R5m" and "we recommended R10m, the client chose R5m on cost, and it is written down" is the whole defence.
2. 02It costs one sentence at the time and is unrecoverable afterwards.
3. 03The same applies to any recommendation declined: the record of the declining is the record of the advice.

G. Declarations and signature

The closing block. Signed by both, dated, and kept for the statutory retention period.

1. 01Client declaration: the information recorded above is accurate and complete, the recommendation and its basis were explained, and the client understands the cover being taken.
2. 02Adviser declaration: the recommendation was based on the information recorded in section B and the analysis in section C.
3. 03Signed by client and adviser, dated 14 March 2026.
4. 04Retained for five years from termination of the product or the rendering of the service, per the Act’s record-keeping requirement.

Frequently asked questions

Is this a real Record of Advice?

No. The client, the broker, the FSP number and every figure are invented. The section structure and the provisions they discharge are real, and the reasoning shown is the kind a defensible file contains.

Can I copy this for my own client?

Copy the structure, not the content. The facts and the reasoning have to be your client’s and yours — a well-structured record of advice that does not match what you actually advised is worse than a rough one that does.

What is the difference between this and the template?

The template is a blank Word file with the headings. This is a filled-in one, so you can see what each section looks like when it is done properly. Most people want both: the example to understand the shape, the template to work in.

Why does the example record advice the client DECLINED?

Because an adviser who never raised something and an adviser who raised it and was declined look identical in a file that omits it — and only one of them has a defence. It is one sentence at the time and unrecoverable afterwards.

How long must a Record of Advice be kept?

Five years, under the Act’s record-keeping requirement. The record-keeping guide sets out what that covers and in what form records may be kept.

Every name, number and figure in this example is invented; any resemblance to a real client, broker or FSP is coincidental. Broker AI (Pty) Ltd is not a licensed financial services provider and this page is not legal or compliance advice — it drafts documents, and the adviser advises and signs. The regulatory page sets that out in full.

Sources

1. 01General Code of Conduct for Authorised Financial Services Providers and Representatives, Board Notice 80 of 2003 as amended to Board Notice 706 of 26 June 2020 — sections 3(2), 7, 8 and 9 (consolidated text hosted by Masthead)
2. 02Financial Advisory and Intermediary Services Act 37 of 2002 — section 18, Maintenance of records