Key points to note regarding the qualifications and experience requirements under the Fit and Proper statement:

• NQF Level 7 Qualification: The outdated and the revised versions of this standard frequently mention a "Namibia Qualifications Authority (NQA) accredited NQF level 7 qualification". This generally indicates a bachelor's degree level qualification.
• Grade 12/NSSCO: The outdated and the revised versions also use Grade 12 (or an equivalent) or a "Namibia Senior Secondary Certificate Ordinary (NSSCO) or equivalent". This generally means a high school certificate.
• "Related Experience": The outdated and the revised versions use "related experience". This can be interpreted in multiple ways, so it would be important to understand NAMFISA's specific guidelines on what counts as "related".
• Market Entry Exam: This term is used in the revised version, and if present, it also means that it is one of the qualifications requirements.
• "None": In the outdated and the revised versions, the word "None" indicates that there are no qualification requirements. If experience is also present in that cell, only experience is needed.

Many current fund officials’ and service providers' qualifications were obtained before the NQA and NSSC frameworks were established. It is not clear how NAMFISA envisages managing the transition. Will NAMFISA require each person to have their qualifications assessed under the NQA framework? If so, the process will likely experience delays, potentially disqualifying the person from serving in any role subject to the fit and proper requirements for an extended time. This time delay could leave management bodies in a precarious situation where they cannot function due to the absence of a quorum. Financial institutions may be unable to continue a business relationship with a person obliged to register under the FIMA but whose qualification has not yet been assessed. Alternatively, NAMFISA will be the arbiter with extensive discretion on accepting or rejecting a person required to register. Both routes are undesirable but, unfortunately, unavoidable where regulation goes into as much detail.

Here is a detailed breakdown by institution and role under Schedule 1, Part A of the standard relevant to the retirement funds industry:

1.    Insurance Agent or Corporate Insurance Agent:

Role

The revised version - Qualification

The revised version - Experience

Insurance broker and members of the board of a corporate insurance broker

NSSCO or equivalent with commercial subjects

OR

3 years related management, insurance, or the financial services and markets sector.

OR

Market entry exam.

5 years experience as an insurance intermediary or related experience in the financial services and markets sector.

Principal Officer

NSSCO or equivalent with commercial subjects

OR

3 years related management, insurance, or the financial services and markets sector.

OR

Market entry exam.

5 years related management, insurance, or the financial services and markets sector.

Other Key Person

NSSCO or equivalent with commercial subjects

OR

3 years related management, insurance, finance, marketing, sales or the financial services and markets sector

OR

Market entry exam.

5 years related management, insurance, finance, marketing, sales or the financial services and markets sector.

Summary of Changes:

1. Market Entry Exam: the "Market Entry Exam" now replaces "None" as a form of qualification in the revised version.

Clarification of Experience: The revised version has "the financial services or markets sector" in the first cell of experience, adding “or” instead of “and”.

2.    Chapter 5 and Fund Administrators

Role

The revised version of the Qualification

The revised version Experience

Beneficiary Fund or Retirement Fund - Member of Board

NSSCO or equivalent with commercial subjects and Completion of Trustee Toolkit.

Minimum of three years’ experience in the financial services, markets or beneficiary funds or retirement funds sector.

Beneficiary Fund or Retirement Fund - Principal Officer

Relevant NQA NQF level 7 (Finance, Commerce, Accounting, Law, Economics or related)

OR

3 years related business management or financial services and markets sector.

OR

NSSCO or equivalent with commercial subjects

OR

5 years experience in fund administration, legal, financial consulting, compliance management, risk management, corporate governance, auditing, financial sector regulation, or other related experience

OR

None

10 years related management, insurance, or financial services sector.

Beneficiary Fund or Retirement Fund - Valuator

Designated Actuary or Member of a category of occupations specified in the standards.

Minimum of three years’ experience in the corporate or financial services and markets sectors.

Fund Administrator - Member of Board

NSSCO or equivalent with commercial or business-related subjects.

Minimum of three years’ experience in the financial services or markets sector or any other relevant sector.

Fund Administrator - Principal Officer

Relevant NQA NQF level 7 (Finance, Commerce, Accounting, Law, Economics or related)

OR

3 years related experience in the financial services and markets sector or any other relevant sector

OR

NSSCO or equivalent with commercial or business-related subjects.

5 years experience in fund administration, legal, financial consulting, compliance management, risk management, corporate governance, auditing, financial sector regulation, or other related experience

Fund Administrator - Other Key Person

NSSCO or equivalent with Commercial or Business related subjects

OR

3 years’ experience in the financial services or markets sector, or other relevant sector;

OR

None

Minimum of five years’ experience in pension fund administration, legal, financial consulting, compliance management, risk management, corporate governance, auditing, financial sector regulation, or other related experience.

Summary of Changes:

• Clarification of Experience: The revised version has many additions to clarify the required experience in various parts of this section. The general trend is adding “or markets sector” to many cells instead of “and markets sector”.

·       Qualifications for Other Key Person: The revised version replaces Grade 12 with an NSSCO.