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| Issued March 2026 | ||||||
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| In this newsletter... | ||||||
| Benchtest 02.2026 – investing during global turmoil, FIMA restarted, members’ right to information and more... | ||||||
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| IMPORTANT NOTES AND REMINDERS | ||||||
NAMFISA levies
The Bank of Namibia did not change the repo rate in March, and it remains at 6.5%. The interest rate on funds’ direct loans will remain at 9% in April 2026. Housing loan repayment will remain unchanged. |
Registered service providers Certain pension fund service providers must register with NAMFISA and submit regular reports to the authority. Download a list of service providers registered as of August 2025, here... Retirement calculator Use our web-based retirement and risk shortfall calculator for your retirement planning. Find it here... If you need help with your financial planning, get in touch with
RFS provides comprehensive support for trustees. Find a list of download documents to assist with the governance and management of private funds, here... |
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| IN THIS NEWSLETTER... | ||||||
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In this newsletter, we address the following topics:
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In ‘A Note from the Managing Director’, read “- Are pension funds moving from paternalistic to personal choice?”
In 'Tilman Friedrich's industry forum' we present...
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In news from NAMFISA, read about...
As always, your comment is welcome, so open a new mail and drop us a note! Regards Tilman Friedrich |
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| A NOTE FROM THE MANAGING DIRECTOR | ||||||
| Are Pension Funds Moving from “Paternalistic” to “Personal Choice”? |
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| There was a time when pension funds were simple. Employers and trustees made most of the decisions, and members largely went along with them. The thinking behind this approach was straightforward: to do what is best for the whole group. In earlier years after Namibia’s independence, pension funds typically worked with only one or two investment managers. Each manager would usually offer just a single portfolio, generally a prudential balanced portfolio (the investment manager’s best investment view) designed to perform well in most market conditions. All members’ money was pooled together and invested in the same way. At the end of each year, the fund would declare an interest rate based on the performance of its investments. But importantly, these returns were “smoothed.” In good years, the fund would hold back some of the gains. In bad years, it would use those reserves to top up returns. The goal was to avoid big ups and downs and give members a more stable experience over time. This system reflected the nature of pension funds. They are part of an employee’s overall pay package and are intended to serve groups rather than individuals acting on their own. Trustees who represent both employers and employees focused on what would work best for the majority and be most economical. But things have since changed as financial markets have developed and pension funds have grown, with more investment options introduced. Instead of just one or two portfolios, funds began offering several, each aiming to beat different benchmarks. At the same time, people became more financially aware and wanted greater control over their retirement savings. Today, many pension funds are moving toward giving members more choice. This includes various investment options, more detailed online platforms, and even structures that resemble retail investment products. On the surface, this sounds like progress, and in many ways, it is. People are different. They have different goals, risk appetites, and personal circumstances. It makes sense that a younger member might want to invest differently from someone close to retirement. However, there is an important trade-off that is often overlooked: “cost”. Group pension funds are powerful because they pool resources. By combining many members into one arrangement, they can keep costs low. Investment fees, administration expenses, and insurance premiums are all reduced through scale. When funds start offering highly individualised options, those cost advantages will begin to fade. For example, retail-style investment platforms now increasingly being introduced into group funds, are more expensive. While they offer flexibility, they are likely to deliver poorer outcomes for the average member when costs are taken into account. The same applies to customised benefit structures or overly complex digital platforms. While it is useful for members to access their information online, replicating the full experience of individual investment platforms within a group fund will be unnecessarily costly. It is important to remember why group pension funds exist in the first place. They are designed to provide cost-effective, reliable retirement savings for a group of employees. Standardisation is not a weakness; it is what makes the group system work. This does not mean that all members should be treated the same. There is room for flexibility. For example, life-stage investment strategies allow members to reduce risk as they get older. This approach provides some level of personalisation without adding high cost. Similarly, giving members access to clear, useful information about their savings is essential. In today’s digital world, people expect to see their balances, track performance, and understand their options. That kind of transparency is a positive development. The problem arises when the push for individual choice goes too far. If members are given too many options, it can lead to confusion and worse decisions. Not everyone has the time or knowledge to manage complex investment choices. In fact, many people are better off sticking with well-designed default options. There is also a risk that a small group of members could drive changes that increase costs for everyone. Pension fund trustees must be careful not to lose sight of the bigger picture. Pension fund features that benefit a few individuals should not come at the expense of the entire group. Trustees and employers, therefore, still have a critical role to play. While they may no longer make every decision on behalf of members, they are responsible for ensuring that the fund remains fair, efficient, and sustainable. The shift from a fully paternalistic approach to one that includes more member choice is understandable. Times have changed, and pension funds must adapt. But the core principle should remain the same: to use the strength of the group to benefit the individual. In the end, it is about balance. Too little choice can feel restrictive, but too much can be costly and confusing. The best approach lies somewhere in the middle, where members are supported, informed, and given reasonable options, without undermining the advantages of being part of a group. As pension funds continue to evolve, maintaining this balance will be key to ensuring they deliver real value to the people who depend on them. |
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| TILMAN FRIEDRICH'S INDUSTRY FORUM | ||||||
| Monthly Review of Portfolio Performance to 28 February 2026 |
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| In February 2026, the average prudential balanced portfolio returned 2.5% (January 2026: 1.6%). The top performer is the Allan Gray Namibia Balanced Fund, with 3.8%. The NAM Coronation Balanced Plus Fund, with 0.2%, takes the bottom spot. Momentum Namibia Growth Fund takes the top spot for the three months, outperforming the ‘average’ by roughly 2.7%. The NAM Coronation Balanced Plus Fund underperformed the ‘average’ by 3.4% on the other end of the scale. Note that these returns are before (gross of) asset management fees. The Monthly Review of Portfolio Performance to 28 February 2026 reviews portfolio performances and provides insightful analyses. Download it here... |
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| How local investors should navigate the investment landscape | ||||||
| Before making any investment decisions, it is crucial to gain a thorough understanding of the current global economic and political environment. The ongoing conflicts in the Middle East and Ukraine, coupled with the rising tensions in the Indo-Pacific region, have introduced significant uncertainties into the global market. These geopolitical tensions have the potential to disrupt supply chains, impact energy prices, and exacerbate inflation concerns. Many countries are now de-risking their supply chains. Manufacturing is brought back home or close to home so that the political risk becomes more predictable and manageable. We have dwelled on the consequences of this global trend in previous commentaries in paragraph 6 of the Benchtest Performance Review newsletters. It clearly offers exciting new investment opportunities. Conversely, much manufacturing capacity will fall into disuse, resulting in large-scale investment write-downs. Amidst these global challenges, investors should seek to identify investment opportunities that offer diversification and resilience in the face of potential market volatility. Read paragraph 6 of the Monthly Review of Portfolio Performance to 28 February 2026 for our views on investment markets and global political developments. It also reviews portfolio performances and provides insightful analyses. Download ithere... |
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Industry stakeholders mobilise for evidence-based input on National Pension Fund proposals Discussions around the proposed National Pension Fund (NPF) have entered a more structured phase following an employers’ consultation convened by the International Labour Organisation (ILO) under the UN Global Accelerator programme, which aims to support Developing Countries in strengthening social protection systems. The consultation forms part of an ILO-driven process that appears to run parallel to the separate reform initiatives currently being considered by the Government and the Social Security Commission (SSC). Objective of the Proposed Reform The ILO outlined a proposal to introduce a social insurance pension pillar alongside Namibia’s Old Age Grant and existing occupational (private) pension arrangements. The aim is to expand pension coverage, particularly among workers currently outside formal retirement savings systems, including lower-income and informal-sector workers, while increasing overall national retirement savings. Industry Working Committee In response, the Namibia Employers’ Federation (NEF) and the Namibia Savings and Investment Association (NaSIA) have coordinated a joint industry working committee, bringing together representatives from the retirement fund industry, actuarial profession and other stakeholders. The committee has been tasked with conducting independent research on the potential implications of the proposed NPF model and developing informed industry input into the policy process. Key Issues Raised During the consultation, employers and industry representatives highlighted several key issues requiring careful consideration:
Independent Research
The industry working group plans to commission a study examining:
The ILO indicated that this research will be relevant to the broader consultation process and will be reflected in its reporting.
Alignment with ILO Standards The ILO also emphasised that any proposed framework should align with international social security standards, particularly those contained in relevant ILO conventions. In this regard, the organisation indicated a preference for a defined-benefit social insurance structure consistent with minimum social security principles. Next Steps The working group will shortly meet to consider appointing a consultant, agreeing on cost-sharing arrangements, and finalising the research scope. The study is expected to be completed within approximately six months. As the policy discussion evolves, the industry’s research initiative is intended to ensure that any reform of Namibia’s retirement system is informed by independent analysis and practical implementation considerations. Clarifying governance roles under the FIMA
One of the most persistent governance challenges in the retirement fund sector is the misunderstanding of the respective roles of trustees and administrators. Because fund administrators perform most operational activities, trustees sometimes assume that responsibility for those activities has also been transferred. Under the Financial Institutions and Markets Act, however, this is not the case. Trustees retain fiduciary responsibilities even where administration functions are outsourced. In this and the next newsletters, we will present the ten responsibilities most frequently misunderstood in practice, and many other differences between the PFA and the FIMA. 1. Trustees remain responsible even when administration is outsourced. Many trustees believe that appointing an administrator transfers responsibility for operational functions. In reality, outsourcing transfers execution, not accountability. Trustees must therefore continue to supervise the administrator and ensure that the fund is administered correctly. 2. Administrators do not make governance decisions Administrators provide operational support, but governance decisions must always be made by trustees. Examples of trustee decisions include:
Administrators may advise trustees, but they do not have decision-making authority.
3. Trustees are responsible for the fund rules. Fund rules are the legal constitution of the retirement fund. Trustees must ensure that the rules are:
Administrators typically prepare rule amendment documentation for submission to NAMFISA, but trustees must approve the amendments.
4. Administrators execute benefit calculations, but trustees remain accountable. Benefit calculations are usually performed by administrators. However, trustees remain responsible for ensuring that:
Operational accuracy, therefore, requires both administrative controls and trustee oversight.
5. Trustees are responsible for financial soundness Administrators provide data to valuators, but trustees must ensure that the fund remains financially sound. This includes monitoring:
Financial soundness ultimately falls within the trustees’ fiduciary responsibilities.
The key governance principle The relationship between trustees and administrators can be summarised by a simple rule: Trustees govern. Administrators execute. Trustees retain fiduciary responsibility for the retirement fund, while administrators provide the operational infrastructure required to implement trustee decisions. Understanding this distinction is essential for maintaining strong governance and protecting the interests of retirement fund members. Clear governance structures:
For trustees, understanding the distinction between governance and administration is one of the most important elements of effective pension fund governance.
The FIM Act – a new start Contributed by Carmen Diehl, C.A.(Namibia), Senior Manager: Risk Management and Compliance |
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The FIMA (Act 2 of 2021) was promulgated in Government Gazette no. 7645 on 1 October 2021. The Minister of Finance has not yet set an effective date. In recent newsletters, we have provided brief overviews of the latest status of standards and regulations.
Standards Chapter 10: General Chapter 10 now comprises the following standards:
The following draft standards under the FIM Act applicable to retirement funds were issued by NAMFISA to the Industry for comment:
Standards Chapter 10: General
In this newsletter, we continue the series on the FIMA. It summarises the main provisions of draft standards and regulations under the FIMA and implications for retirement funds.
GEN.S.10.19 The form and content of any application for approval of a change of name, use of another name or use of a shortened form or derivative form of a name made to NAMFISA The Standard does not disclose to whom it applies. It will apply to all regulated entities under the FIM Act. Summary:
What to do:
This is only applicable upon a name change or use of an alternate name.
GEN.S.10.20 Definition of related party transactions and identifying those that are prohibited under the Act and the Standards This Standard applies to all financial institutions and financial intermediaries registered under the Act. Summary:
What to do:
Update the financial institution's or financial intermediary's code of conduct to include this standard's requirements. GEN.S.10.21 Fair treatment of customers and principles relating to market conduct and their administration by NAMFISA The standard applies to all financial institutions and intermediaries registered under the Act, including their boards, senior management, and principal officers, who are accountable for enforcing fair treatment policies for customers. Summary:
What to do:
Financial institutions and financial intermediaries should draft a written policy on treating customers fairly that addresses the seven key outcomes in the standard. |
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| COMPLIMENT | ||||||
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Compliment
from a fund member Dated December 2025 |
“I herewith wish to extend my sincere appreciation for fast-tracking my application for a pension-backed home loan and for going the extra mile to make the payment still in this year. May you have a blessed festive season and my best wishes for the new year ahead.”
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Read more comments from our clients, here...
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| BENCHMARK: A NOTE FROM GÜNTER PFEIFER | ||||||
| Client visits Benchmark Ms Zealand, a Benchmark pensioner and long-serving former member of one of our long-standing clients, travelled from Cape Town to Windhoek and surprised her RFS contact person at our offices. She specifically hoped to meet her contact person during her visit. Over the past six years, Ms Zealand and her RFS contract person have only interacted by phone and email, so finally meeting Ms Zealand in person was quite special.
This interaction showed how much our clients trust and value the consistency of our work. Moments like these quietly affirm the importance of relationship-building and quality service in our space, and we are humbled to realise how RFS, with its client-focused service philosophy, positively impacts our members' lives, sometimes in ways we only fully realise later.
Fund Announcements
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The Benchmark Retirement Fund issued no new circular after the following circular:
Clients are welcome to contact us if they require a copy of any circular.
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| NEWS FROM RFS | ||||||
| Staff improving their competencies | ||||||
| RFS prioritises the ongoing education and professional development of its staff. As Nelson Mandela once said, “education is the greatest equaliser,” and by investing in employee education and training, RFS is helping build a more skilled and knowledgeable workforce. By supporting its staff in pursuing further education, through bursaries, study leave, and study loans, RFS is also investing in the long-term success of its business. As staff members become more skilled and knowledgeable, they are better equipped to provide high-quality service to clients and to help the company stay competitive in a rapidly changing market. We heartily congratulate Rauha Hangalo on obtaining the Post Graduate Diploma in Financial Planning from the University of Stellenbosch (USB). May this be another milestone on the road to greater heights! |
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RFS manager legal services makes ‘Legal 500 GC Powerlist’ |
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We are proud to congratulate Vincent Shimutwikeni CGRCS™, Manager: Legal Services at RFS, on being included in the Legal 500 GC Powerlist: Namibia 2026!
 The GC Powerlist recognises legal leaders who demonstrate exceptional leadership, professional achievement and impact within their organisations and the broader business community. Vincent’s inclusion reflects his commitment to strong governance, legal excellence and the important role he plays in supporting RFS Fund Administrators as a trusted partner in retirement fund administration. The official Legal 500 GC Powerlist Namibia 2026 event took place at the Weinber Hotel on 5 March, where this well-deserved recognition was celebrated. We are incredibly proud to see Vincent recognised on this respected international platform! RFS celebrates Namibia’s 36th anniversary
This year, Independence Day fell on a Saturday, so RFS staff celebrated the occasion in their traditional attire the day before. As the picture below shows, our staff really made an effort to display their traditional dressing.  Congratulations to the new arrival, Victory Petrus, who earned himself the accolade as best-dressed for the day.  Elevate your fund experience with EPIC
Members of funds administered by RFS can now access our EPIC communication platform, provided the trustees agree to make it available to members.
Members can access their benefits and investment values online from anywhere at any time. Members of the Benchmark Retirement Fund take note that they have similar functionality through Benefit Counsellor. We encourage our fund members to make the best use of these facilities. |
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The RETIREMENT COMPASS
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RFS Fund Administrators sponsor this newsletter as part of their social responsibility and initiatives to support the retirement fund industry. It aims to provide members of funds managed by RFS Fund Administrators and other parties in their network with retirement funding and planning-related news and insights, presented understandably.
The latest issue covers the following insightful articles:
Don’t miss out on the latest Retirement Compass (vol 3, no 1) here...
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| Important circulars issued by RFS | ||||||
| RFS issued the following circular in February:
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| NEWS FROM NAMFISA | ||||||
| NAMFISA meets the industry on its FIMA concerns
Following RFIN’s letter in response to the Minister of Finance’s invitation to share any concerns about the FIMA, RFIN submitted a 16-page document listing its key concerns. The Minister forwarded the list to NAMFISA, which prepared responses to the concerns and set a meeting with the industry for Monday, 23 March. Here is some initial feedback from the meeting:
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| NEWS FROM RFIN | ||||||
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RFIN urges industry to prepare for FIMA
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In a member circular of 10 March, 2026, RFIN advised that the FIMA is progressing towards commencement. It urges its members that FIMA readiness must be a priority and that organisational, governance and operational alignment with the new regulatory framework will be essential. While formal commencement dates remain subject to confirmation, it encourages funds to conduct an internal FIMA readiness or gap assessment to identify priority areas requiring immediate attention. Members must plan for implementation within expected regulatory timeframes, strengthen compliance structures and address any internal gaps to ensure readiness activities are not delayed. RFIN will continue to engage NAMFISA and other stakeholders to ensure that implementation considerations, industry capacity and operational realities are taken into account. In the circular, RFIN offers training and capacity-building support in the following areas:
You can read the circular here.
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| LEGAL SNIPPETS | ||||||
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Member’s Right to Information on Pension Benefits
By Vincent Shimutwikeni, Manager, Legal Support Services |
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The Pension Funds Adjudicator considered a complaint by a pension fund member alleging that his fund had failed to provide adequate and meaningful information regarding the calculation of his pension benefits. The case highlights the importance of transparency and communication between pension funds and their members.
Facts The City of Ekurhuleni has employed Mr EM Thaba since October 2005 and became a member of the Municipal Employees Pension Fund as a result of his employment. Over time, Mr Thaba became concerned that the fund's benefit statements did not clearly explain how his benefits were calculated, particularly regarding his contributions, withdrawal benefits, retirement projections, ill-health benefits, and death benefits. After raising these concerns directly with the fund without receiving a satisfactory response, he lodged a complaint with the Pension Funds Adjudicator. The Complaint The complainant argued that the fund's benefit statements did not adequately explain how his benefits were calculated or provide a detailed breakdown of the figures presented. He requested, among other things:
The complainant also requested the option to transfer from the fund's defined-benefit section to its defined-contribution section, arguing that the fund's rules did not explicitly prohibit such a transfer.
The Law The Adjudicator reaffirmed the established principle that the rules of a pension fund constitute its governing constitution, and that the fund may act only within the powers granted by those rules. The Adjudicator further referred to section 7D of the Pension Funds Act, which places a duty on pension fund boards to ensure that adequate and appropriate information is communicated to members regarding their rights and benefits. This duty is essential to enable members to understand their retirement benefits and make informed financial decisions. Ruling of the Adjudicator The Adjudicator found that the fund had provided general explanations and formulas for calculating benefits but had failed to provide the complainant with specific information regarding his individual benefits. In particular, the fund had not provided a detailed breakdown of:
The Adjudicator therefore held that the fund failed to adequately inform the member of how his benefits were calculated.
However, the Adjudicator rejected the complainant’s request to transfer from the defined benefit category to the defined contribution category, finding that the fund rules did not allow such transfers and that the fund cannot act outside its rules. Order The fund was ordered to provide the complainant with detailed information regarding the value and calculation of his benefits, including:
Relevance for Namibian Pension Funds
This determination underscores an important principle that is equally relevant to Namibian pension funds: members have a legitimate expectation of receiving clear, accurate, and understandable information regarding their benefits. Trustees and administrators must ensure that member communication goes beyond simply providing formulas or generic explanations. Members should be able to understand how their individual benefits are calculated and which factors influence them. The case also reaffirms the importance of strict adherence to fund rules, particularly when dealing with requests that may fall outside the powers granted by those rules. For trustees of Namibian pension funds, the case serves as a reminder that transparency and proper member communication are essential components of good pension fund governance. Withholding Tax on service payments to non-residents
In practice, Namibians, including Namibian pension funds, mostly deal with South Africans, and, in general, the services provided by South African service providers would be subject to Namibia's double taxation agreement with South Africa. This agreement prohibits the taxation by Namibia of any of the following income –
The income of a South African taxpayer that may specifically be taxed in Namibia is the following:
Income is not dealt with in any of the above bullets if it arose in Namibia.
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| SNIPPETS FOR THE PENSION FUND INDUSTRY | ||||||
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Retirement Income Check-Up: Are You Still on Track?
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Jonathan Brummer (Rexsolom Invest) presents a practical framework for retirees to assess, at any stage of retirement, whether their current withdrawal rate remains sustainable. Unlike most retirement income research, which focuses only on the starting withdrawal rate (e.g., the well-known “4% rule”), this analysis provides a dynamic, ongoing checkup tool.
Core Concept: A Two-Dimensional Sustainability Chart Brummer introduces a single chart combining:
The model uses:
This simple rule meaningfully improves sustainability, raising safe withdrawal rates by roughly 0.5% compared with rigid annual CPI adjustments.
Why This Matters A retiree’s withdrawal rate naturally drifts over time due to inflation adjustments and market performance. Benchmarking this evolving withdrawal rate against the appropriate remaining time horizon offers a more accurate picture of sustainability than relying on the original starting rate. What the Chart Shows
Practical Examples
Brummer illustrates three scenarios:
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 Bottom Line Retirement income sustainability is not a once-off calculation. It requires periodic reassessment as:
Brummer’s framework offers a simple, data-driven way for retirees (or their advisors) to evaluate whether current income is sustainable, whether to increase spending, or whether minor adjustments may be needed.
Read the full article here. Investment fundamentals that outlast the headlines This article revisits a well-established but often neglected truth: long-term investment outcomes are driven less by market timing and product selection, and more by disciplined adherence to core principles. Core Messages
Trustee Takeaway
The article reinforces a central principle: Successful investing is process-driven, not prediction-driven. For pension funds, this translates into:
Bottom Line
For experienced readers, the article confirms existing knowledge rather than extending it. Its value lies in its clarity: Investment success is achieved not by doing more, but by consistently doing the right things. Read the full article by Erin White in Moneyweb of 11 March, 2026 here. |
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| SNIPPETS OF GENERAL INTEREST | ||||||
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The most effective financial plans are often the simplest
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For many financially literate persons, complexity often mimics sophistication. However, this article argues that the most resilient financial plans are those that intentionally favour clarity over complication.
Core Principles for the Financially Literate The article breaks down why a "lean" financial architecture outperforms a fragmented one:
Why This Matters
For those overseeing significant assets or fiduciary responsibilities, the takeaway is a shift in perspective:
Conclusion
A simple plan is easier to trust, and a trusted plan is easier to follow. In the long run, consistency, not complexity, is the primary driver of investment success. Read the full article by Devon Card in Moneyweb of 25 February 2026 here. |
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| Romance vs reality: Financial mistakes to avoid | ||||||
| “Relationship risk" is often an overlooked variable in long-term wealth preservation. This article highlights how emotional optimism frequently leads to structural financial fragility. Critical risks for couples The authors identify several "romance-driven" traps that compromise capital:
To maintain long-term sustainability, the article suggests specific structural interventions:
Love is emotional, but money is mathematical. The most significant "investment loss" often stems from emotional decisions made during relationship transitions rather than market performance. Read the full article by Bianca and Annika Strydom in Cover of 23 February, here. |
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| AND FINALLY... | ||||||
| Wise words from wise men and women | ||||||
| "When you’ve got something to prove, there’s nothing greater than a challenge.” ~ Terry Bradshaw, American football quarterback, born 2 September 1948. | ||||||
| Unsubscribe If you do not want to receive these newsletters {unsubscribe}click here...{/unsubscribe} Disclaimer Whilst we have taken all reasonable measures to ensure that the results reflected herein are correct, Benchmark Retirement Fund and RFS Fund Administrators (Pty) Ltd do not accept any liability for the accuracy of the information and no decision should be taken on the basis of the information contained herein before confirming the detail with the relevant portfolio manager. |
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