Revenue Laws Amendment Bill; Financial Services Board Amendment Bill

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Finance Standing Committee

01 November 1999
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Meeting Summary

A summary of this committee meeting is not yet available.

Meeting report

FINANCE PORTFOLIO COMMITTEE

FINANCE PORTFOLIO COMMITTEE
2 November 1999
REVENUE LAWS AMENDMENT BILL: CONSIDERATION & ADOPTION;
FINANCIAL SERVICES BOARD AMENDMENT BILL: BRIEFING

Documents handed out:
Draft Financial Services Board Amendment Bill [B -99] (email info@pmg.org.za for copy)
Memorandum on the Objects of the Draft Financial Services Board Amendment Bill, 1999
Revenue Laws Amendment Bill [B57-99] (only draft is currently available)

SUMMARY
The Committee was briefed on the draft Financial Services Amendment Bill.
The Committee adopted the Revenue Laws Amendment Bill which had several changes (outlined in the minutes) since the draft presented to the committee on 17 September 1999.

MINUTES
Draft Financial Services Board Amendment Bill
Background
Dr F H Van Zyl and Mr L Wessels of the Financial Services Board (FSB) briefed the committee on the Financial Services Board Amendment Bill. Mr Wessels indicated that the Board is functioning as an independant statutory body but, in spite of its independance, must still report to Parliament and is subject to audit by the Auditor-General. He noted that the four main officers of the Board are appointed by the Minister and that the executive officer of the FSB is similar to the Registrar of the corresponding financial institution of the old dispensation.

Proposed amendments
Clause 1 of the Bill
In the Principal Act it is stated that the FSB has a duty to supervise the exercise of control in terms of any law over the activities of financial institutions by the executive officer and goes on to say that such supervision happens on a daily basis. Accordingly, it must be determined what the relationship between the FSB and the executive officer is as the Act does not stipulate whether the executive officer is subject to actual control.

It was held in the Cape High Court that supervision does not mean actual control but that a form of control was intended. Accordingly, S1 of the amended Bill now has 3 tiers of supervision spelt out. The first relates to activities that the executive officer may not perform without the approval of the Board, the second, to the guidelines issued by the Board which the executive officer must follow and the third, to the functions which the executive officer may perform according to his/her discretion. The third relates to daily functions.

Questions and comments by members
Prof. Turok (ANC) commented that, in terms of supervision, there seemed to be a change from control to compliance with law. He indicated that previously the Board had a major oversight role over the industry, and now, with the new wording which was far more precise, the job description of the Board seemed to be narrower than before.
In response to this it was stated that the wording was more precise, but, previously, the Board supervised the executive officer while the executive offficer retained the exercise of control. The intent of the amendment was to make it clear that the Board was written into the Act as supervisor and controller.

Dr Luyt (FA) asked whether the notion of mere supervision was strong enough and questioned whether one can enforce a law when the function referred to is only supervisory.
The reply was that the executive officer is accountable. This means that he must report and account for what he does and further, that his functions are subject to the directions of the Board.

Clause 2
It was noted that what the Board does in terms of existing legislation is to supervise compliance with laws. In the Bill, however, a new portion, subsection (c) has been inserted. The effect of this is that the Board must promote programmes which will inform and educate users. This was described by Mr Wessels as a new mission for the Board.

Questions and comments by members
Dr Koornhof (UDM) asked how these programmes would be promoted and whether there would be any cost implications for the Board.
The response was that the intention was to stimulate the industry by promoting programmes and it was envisaged that these would be financed with the monies received from penalties imposed for contravention of the Act. These penalty monies would be kept in a separate reserve account. This however, was not a definite plan but only a possibility that they were exploring.

Clause 5 (of the Bill amending S6 of the Act): Termination of membership of board members
It was noted that at present the State President is responsible for this function but the FSB and the executive officer report to the Minister of Finance. Accordingly, Mr Wessels noted that it would be more prudent to relieve the State President of this function by conferring it onto the Minister, therefore allowing the Minister to appoint and terminate membership.

At this time the chairperson noted that the President had not been consulted on this bill and wondered whether the President's office was happy with this amendment.
The response was that Cabinet had approved the amendment, and the President being part of Cabinet means that there had been consultation.

Clause 7 (of the Bill amending S9 of the Act): Amendments dealing with the executive officer
The amendment allows for the appointment of more persons to the executive. It was indicated that the reasoning was that the Board deals with many issues daily and in view of this their base should be broadened. The intent was that there may be additional members in the executive.

Dr Koornhof asked how many people were envisioned as serving on the executive?
The response was that the FSB would have the power to decide this and that the executive, which consists of four people now could possibly be expanded to seven.

Clause 4(b) of the Bill
Mr A Feinstein (ANC) interrupted the briefing to ask a question relating to this clause. He indicated that a situation was being created where an individual might have a conflict of interest in that he was sitting on the Board and at the same time was also very active in the industry. Mr Wessels replied that the only amendment proposed to this section was to change the word 'State President' to 'Minister' and added that the desire was to keep a small channel of opportunity open.

Mr Feinstein communicated his concern that this 'channel of opportunity' would amount to a loophole, which allows for a situation whereby one can have an individual with a conflict of interest. Mr Du Plessis explained that there was a shortage of skills in South Africa, accordingly, they had to bring in people who were involved in the industry. He continued that where a conflict of interest did arise, that person would have to disconnect him/herself from the decision and know that they were there only in their capacity as an expert.

Mr Feinstein enquired as to who would ensure that household rules would be effected. The response was that the Chairperson would have to use her discretion. He added that another option would be for people to recuse themselves where there was a possible conflict of interest.

It was noted that the cause of Mr Feinstein's concern did not arise from the amendment but was part of the Principal Act. Accordingly, the chairperson indicated that the issue could not be dealt with now and Mr Feinstein conceded to flag the issue as this was not the appropriate forum.

Clause 12(b)
It was indicated that this clause in the Amendment Bill was erroneously inserted and that paragraph (c) of subsection 4, which deals with consultation, must remain as no amendment thereto is proposed.

Mr Leeuw (ANC) asked what would happen if there was a dispute during the consultation process. It was indicated that the decision could be taken on appeal and that this process was dealt with in S26.

Clause 13
This deals with that which the Minister may be consulted on.

Professor Turok was unhappy with the proposed wording in that the Board may consult the Minister on any matter and the Minister may only consult with the Board on matters in law which arise in terms of Acts of Parliament. Professor Turok was concerned that the Board had a greater consultation power than the Minister. This was not the intention.

The chairperson indicated that this was a minor issue and requested that the words be redrafted to reflect the true intention.

Clause 15: Confidentiality clause
Here the wording was expanded to enable the FSB to divulge information to national organisations and includes an expansion of items which may be disclosed in terms of international arrangements. In spite of this, the principle of confidentiality will still remain.

Questions and comments by the members
Dr Luyt indicated a concern that this might be nullified by the Open Democracy Bill (ODB).
Mr Wessels replied that they were aware of this and he had looked at the ODB to determine how it would affect them. He noted that it would not make a big impact as to how they would disclose or not disclose information, as they could be classified under certain of the exemptions. He added that he was watchful of the proceedings in the event of any changes.

Clause 16
This was designed to expand the limitation on liability for members of the Board.

Clause 17
This clause lifts the veil pertaining to the use of the FSB logo, upon application, by anyone in the industry. It was indicated that this was in line with international trends, and by analogy, was compared to the SABS mark.

Clause 18
This clause provides for an Appeal Board and appeal procedures. Three persons are appointed to the Appeal Board, these are, one lawyer, one accountant, and one member of the FSB. The member from the board, must be appointed on account of his or her knowledge of financial services and financial institutions.

Provision is also made for the Board of Appeal to call upon assessor to assist, where necessary, but such assessor may not take part in any decision of the Board of Appeal.

An important consideration in terms of the amendment is that the noting of an appeal will not have the effect of suspension of a decision. In terms of the latest legislation the executive officer has the right to stop persons from operating 'outside the net'. If such a decision is appealed against then the executive officer's decision will stand.

In terms of the amendment there will not be automatic suspension, although one can apply for suspension or urgent review to the Board of Appeal.

Further, the Board of Appeal has the right to refer the matter back for consideration or reconsideration. Also, it was indicated that the Board should have the power to order costs, which would have the effect of an order for costs in the High Court.

Questions and comments by the members
Regarding the phrasing 'with knowledge of the law' [s181(a)] Dr Luyt suggested that it should refer to an advocate or attorney with 15 years standing experience; which requirement should also apply to the appointed accountant. His rationale was that it took someone with experience to adjudicate.

Professor Turok disagreed with the time constraint and suggested that the insertion of the word 'senior' would be a better option, as the reference to time would exclude persons who were fit but had not practiced.

Mr Wessels noted that the Minister would in any event not appoint someone who was not qualified.

The chairperson indicated that the element of experience would be specified without reference to time. She noted that the two elements they were looking for were experience, and senior experience. The members finally decided that the wording 'adequate experience' was agreeable to all.

Mr Leeuw asked whether there were any precedents in law regarding the provision made for the awarding of costs.
The reply was that the Attorneys Act contains something to this effect in that costs may be awarded against an attorney.

This marked the end of the briefing by the FSB.

Revenue Laws Amendment Bill
The representatives from the South African Revenue Service (SARS) were Mr K Louw, Mr P Frank and Mr Cronje. Mr Louw informed the Committee that as a result of more consultation and objections several changes have been made to the initial draft of the Bill. Some of the changes that have been made since the last meeting with the Committee on 17 September 1999 are as follows:

Income tax issues
Clause 11
This clause makes provision for the Commissioner not to be excluded from disclosing to the Board administering the National Student Financial Aid Scheme any information relating to the name and address of the employer of any person, whom they have granted a loan or bursary.
Mr A Feinstein (ANC) questioned the constitutionality of this provision and whether the State law advisers had considered this. In response Mr Louw confirmed that the State law advisers had looked at the provision and no constitutional objections had been made.

Clause 20
This clause deals with the issue of intellectual property. This provision allows a person to write-off the acquisition price of intellectual property.
Mr Feinstein asked whether the Department of Trade and Industry and other stakeholders had been consulted, as was requested in the meeting held on 17 September 1999. Mr Louw said that the Registrar of Intellectual Property was contacted, the reply was that further time was needed to research and since then there have been no further communications. As for the law firm Spoor and Fischer, the intellectual property body to which they belong has been consulted. They are not happy with the proposal in the amendment and proposed the continuation of the deduction. This proposal could not be accepted by SARS, the only change that was made is that the only cost that will now be denied for deduction is the cost of acquisition.
Mr Louw went on to say that now provision is also made for writing off over 20 years, which is in line with the legislation regulating such property. Furthermore the discretion of the Commissioner, as far as the period over which the expenditure shall be allowed, has also been removed.

Clause 29 and 30
In these clauses provision is made for taxation of long-term insurers. Mr Louw said that SARS had met with insurance companies and three issues had been discussed:
The formula to be applied to cover administration expenses.
SARS was not prepared to make any changes in this regard, but made an undertaking to closely monitor the issue.
2. Transfer between funds
At the moment transfers are 100% deductible, but also 100% taxable. SARS have agreed that transfers will remain taxable, but the deduction in respect of the transfer in respective policyholder funds, from which the transfer is made, will be restricted. Double taxation is a concern that was raised and in principle SARS have accepted that there is double taxation. A decision was made to calculate the deductible portion of the transfer by applying the ratio to 50% of the transfer. This should cover the problem of double taxation.
Transitional Arrangements (from old to new)
Essentially two changes have been made.
Firstly, the initial proposal was to have two calculations. One on the first day of such year of assessment and the other at the end of such year. Now provision is made for both calculations to be made on the first day of such year of assessment.
Secondly, the type of deductions in respect of unutilised selling expenses has also been changed.

Customs Issues
Clause 49
With the intention to bring clarity, a minor change was made to this clause in that a definition for `beer' was included.

Clause 53
This is a new clause, which provides for the Commissioner to determine the amount of duty payable in a situation where an importer experiences problems with computers who are not Y2K compliant.

Clause 55 (sub-clause 9)
This sub-clause relates to procedures, which must be complied with if imported goods are claimed to qualify for any preferential rate of duty and the importer is unable to produce the certificate of origin or invoice declaration or other document confirming originating status at the time of entry of the goods.

Clause 67
This deals with the situation where certain goods which have been detained, seized or forfeited by the Commissioner, are to be released to the owner on certain conditions.

VAT issues
Mr Frank said that SARS was not given a proper opportunity to prepare for the submissions made by COSATU on frozen vegetables. As a result the frozen vegetables amendment has been left out, but research is being done into the possibility of removing the exemption.

Formal consideration of the Bill
Members were in favour of the motion of desirability and the adoption of the Bill. The Committee adopted the Bill.

The Chairperson thanked SARS for their assistance in the process of adopting the Bill.

The Chairperson informed the Committee that the South African Police Service, Department of Justice and Department of Transport have been invited and will appear before the Committee tomorrow.
Since there were no further matters to discuss the meeting was adjourned.

Appendix 1
Memorandum on the Objects of the Financial Services Board Amendment Bill, 1999

1. SCOPE OF BILL
The Bill proposes amendments to the Financial Services Board Act, 1990 (Act No.97
of 1990) (the Act), with consequential amendments to the Supervision of Financial
Institutions Rationalisation Act, 1996 (Act No. 32 of 1996), and the Inspection of
Financial Institutions Act, 1998 (Act No.80 of 1998).

2. AMENDMENTS
2.1 Amendment of section 1 of the Act
Current position
The Act uses the words "supervision" and "supervise" on a number of occasions to describe the relationship between the executive officer and the Financial Services Board (the board). These words have been given a particular meaning in the common law and can be construed to mean that the board "controls" the activities of the executive officer The executive officer is also the "registrar" in terms of several regulatory laws, which impose obligations on the executive officer as registrar directly, and decision made by the registrar are subject to appeal. Applying the aforesaid construction of the words "supervision" and "supervise", it would mean that the board has to approve all decisions made by the executive officer, including decisions delegated to clerical functions, such as noting changes of addresses.

New Approach
A new definition is introduced into section 1 of the Act whereby the words "supervision" and "supervise" are defined to refer to three tiers of decisions. These being a first level of significant decisions which the board has to approve, a second level of decisions where the executive officer must make decisions within guidelines set by the board and a third level of less significant decisions where the executive officer can make his or her own decisions.

Reason
The reason for this approach derives from litigation where it has been questioned whether decisions taken by the executive officer in the capacity of "registrar" were taken under "supervision" of the board. Since invalidity of decisions may result if this has not been done and since the board cannot confirm every minute decision, the separation of the decisions into various categories allows for significant decisions to be taken under close supervision, less significant decisions to be taken within guidelines and routine decisions to be taken freely. This maintains sufficient checks and balances and retains a streamlined and efficient decision-making process within the Financial Services Board.

2.2 Amendment of section 3 of the Act
Current position
Two functions are stated for the board in this section. The first function is that the board should exercise control in terms of any law over the activities of financial institutions and over financial services. This is not correct, as the board does not exercise such control.
The section does not state any function for the board in relation to investor education.

New approach
The function of the board in relation to financial institutions is rephrased to state clearly that the board is to supervise the compliance with financial regulatory laws by those parties to whom these laws apply
Furthermore a new function is formulated whereby the board has to promote programmes and initiatives by financial institutions and industry representative bodies to inform and educate the users and potential users of financial services.

Reason
The board does not really "exercise control" nor was it ever intended to do so as stated in the Act at present. The function is more clearly stated to be the
supervision of compliance with financial laws. It is accepted that regulatory
authorities should promote investor education. The proposed additional
responsibility of the board will enable that this dimension of the board be
developed.
The changes to the functions of the board must be read to savings and transitional provisions of clause 20 of the Bill, proposed changes to the long title of the Act in clause 22.

2.3 Amendment of section 4 of the Act
(a) Current Position
Uncertainty prevails as to whether the "board" is the body established by section 2 or whether it refers to its governing body, in a number of sec uncertain whether the board, if it "consists" of its members will continue to exist if the appointments of the members lapse.
Currently the members of the board are appointed by the President.

(b) New Approach
By referring to the board as the body established by section 2 and distinguishing it from the members of the board who govern its functioning, a clearer distinction is made and the continued existence of the board where terms of appointment expire is clarified.
Members of the board will be appointed by the Minister.

2.4 Amendment of sections 5 and 6 of the Act
These are consequential amendments arising from the amendment of section 4.

2.5 Amendment of section 7 of the Act
Current position
The Act prescribes that members of the board are appointed by the State President for a term of office not exceeding three years.

New approach
The new approach is to commence a process of rotation, retaining the three year limit, and to make provision for an extension of the term of members of the board if their reappointment or the appointment of other members cannot take place timeously. The extension is for a six month period only. The quorum for a meeting of the board continues to be a majority of its members (section 8(3)).

Reason
A rotation regime is considered superior to one where the expiry of the period of office is conterminous for all members. It is not always possible to secure the re-appointment of board members within the three year period, terms of office expiring before new members have been appointed, thereby creating administrative difficulties within the board if it has to function without having members appointed to its board.

2.6 Amendment of section 9 of the Act
Current Position
The executive as defined comprises only the executive officer, deputy executive officers and the chief actuary.

New Approach
As the executive deals with regulatory, operational and administrative matters, it will be possible to appoint other senior employees of the board, such as the general manager: finance administration, to the executive, because much of its agenda deals with financial and administrative matters.

Reason
Practical experience has shown that it is necessary that othersenior employees should serve on the executive by virtue of the nature of their Flexibility is needed if changes are made to the internal structures of the board to cope with changing supervisory requirements.

2.7 Amendment of section 10 of the Act
Current Position
The continued existence of committees of the board is uncertain when the terms of office of members of the board serving on such committee expire.

New Approach
The functioning of committees will be preserved where the terms of office of relevant members of the board expire.

Reason
The continued functioning of committees is essential and their should not be affected by the vacation of office of members of the board.

2.8 Amendment of sections 13 and 14 of the Act
These are technical amendments to repeal outdated provisions and to give effect to the proposed amendment of section 18 (clause 1 3).

2.9 Amendment of section 15 of the Act
Current position
This section preserves the pension rights of officers and employees transferred
from the public service to the Financial Services Board.

New approach
The preservation is repealed.

Reason
The original preservation was a temporary arrangement to cc establishment of the board during 1990. A decision was taken by the Department of Finance not to make any further payments in term section 15. It must be read together with the savings and transitional provision of clause 20 of the Bill and consequential amendment to the Supervision of Financial Institutions Rationalisation Act, 1996, referred to in the schedule to the Bill.

2.10 Amendment of section ISA of the Act
Current position
The board has the right to impose levies on financial institutions, but is not
required to follow a consultative role in that regard.

New approach
A compulsory consultative process prior to imposing levies is introduced by this amendment.

Reason
The amendment arises from a recommendation by the Committee of Inquiry into the role of the Financial Services Board (the Rabie Report, 10 September 1996) which recommended a consultative approach in this regard.

2.11 Amendment of section 18 of the Act
This is a consequential amendment arising from the amendment of section 9.

2.12 Amendment of section 21 of the Act
Current position
It is required that the Financial Services Board should file a report in both official
languages.

New approach
The reference to two languages is obsolete and should be deleted.

Reason
It is not considered necessary to specifically require an annual report in two languages, which involves unnecessary costs. Deleting this requirement will not impact on the actual report or its contents which remain obligatory. It will still be the responsibility of the board to act within the Constitution concerning the use of official languages if and when required to do so.

2.13 Amendment of section 22 of the Act
Current position
Section 22 of the Act places a strict onus of secrecy on the board and its employees. Subsection (2) allows disclosure of confidential information to foreign financial services supervisory authorities.

New approach
The new approach expands the ability of the executive officer to provide that information not only to the foreign authorities, but also to other supervisory authorities within the Republic. It furthermore expands the ability of the executive officer to assist such regulatory authorities and will improve the executive officer's ability to provide assistance under Memorandums of Understanding concluded with foreign regulators.

Reason
The need for closer co-operation between regulators internationally is required by the greater internationalisation of the financial services sector and evolving practice by international supervisory authorities. Placing a constraint on co-operation between local supervisory authorities, places an unacceptable impediment on them, especially in the supervision of conglomerate groups. The amendment must be read with the savings and transitional provisions of clause 20 of the Bill and the consequential amendments to the Inspection of Financial Institutions Act, 1998 referred to in the Schedule to the Bill.

2.14 Amendment of section 23 of the Act
Current position
This section establishes an indemnity for the board, its members, the members of the appeal board and the officers, the employees of the board, in case of a bona fide exercise of a discretion in the performance of their functions.

New approach
The new approach is to provide the indemnity in respect of the bona fide, but not grossly negligent, exercise of powers, carrying out of duties or performance of functions under the Act or any other law under the jurisdiction of the board

Reason
The need to expand the indemnity to include other laws, as well as the improvement in the wording, follow an improvement contained in the Stock Exchanges Control Amendment Act, .1995 (Act No. 54 of 1995), and the Financial Markets Control Amendment Act, 1995 (Act No. 55 of 1995). The improvement is required in view of the increase in delictual claims against regulators in the financial services industry. This will provide the necessary immunity in the case of delictual actions in respect of acts performed in good faith, with the exclusion of gross negligence. It does not preclude liability for willful acts or omissions as a result of which damage is caused.

2.15 Amendment of section 24 of the Act
Current position
Section 24 at present prohibits any person from using the name or logo of the
board under any circumstances.

New approach
The new approach is to allow usage of the name and logo of the board by other parties with the approval of the board and subject to conditions determined by the board.

Reason
It is foreseen that it may become necessary for the Financial Services Board, as regulator to confirm that various entities are registered to conduct certain types of regulated business lawfully. In order to do so, it will be necessary for the
board's logo to be applied in the process. The amendment will enable this to take place.

2.16 Amendment of section 26 of the Act
Current position
This section sets out the appeal procedure for any person affected by a decision of the registrar and establishes an appeal board for that purpose. It is currently required that one member of the appeal board must also be a member of the board and does not allow for the appointment of alternates.

New approach
The section is amended to reconstitute the appeal board by removing the requirement that one member should also be a member of board, and requiring that all three members of the board be independent. It also allows for the appointment of alternates. A number of technical improvements to this procedure are also introduced.

Reason
The reconstitution of the appeal board arises from the amendment to the requirement that the registrar be supervised by the board, implying control of the registrar and thereafter having one of the board's members sitting on an appeal board to adjudicate on an appeal by a person affected by a decision by the
registrar. This is considered to be administratively unjust. The proposed amendment will rectify this problem, and improve the appeal procedure in other respects as well. The amendment must be read with the savings and transitional provisions of clause 20 of the Bill.

2.17 Amendment of section 28 of the Act
This is a technical amendment to correct the references to banks and building societies as a result of intervening amendments to legislation.

3. CONSULTATION
The bodies consulted and their responses are summarised in Annexure A to this
Memorandum.

4. ORGANISATIONAL AND PERSONNEL. IMPLICATIONS
The Bill has not organisational or personnel implications for the State.

5. FINANCIAL IMPLICATIONS
The Bill does not have any financial implications for the State.

6. COMMUNICATION IMPLICATIONS
The Bill has no communication implications in addition to the commencement of the Bill as an Act of Parliament being published in the gazette.

7. PARLIAMENTARY PROCEDURE
The State Law Advisers and the Financial Services Board are of the opinion that this
Bill must be dealt with in accordance with the procedure established by section 75 of
the Constitution since it contains no provision to which the procedure set out in section 74 or 76 of the Constitution applies.

ANNEXURE A
SUMMARY OF CONSULTATlVE PROCESS
The following persons were consulted, and they responded as follows:
1.Parties who supported the Bill as circulated
M3 Capital
Swiss Re Southern Africa
Banking Council of SA
Sanlam

2. Parties who made no comment on the Bill
Department of Finance
Deputy Minister of Finance
Policy Board for Financial Services and regulation
Portfolio Committee on Finance (National Assembly)
Select Committee on Finance (National 'council of Provinces)
Members of the Board: Financial services Board
Prof J P van Niekerk
Prof R Vivian
Prof H A Lambrechts
Prof S R van Jaarsveld
Insurance Law Society of SA IiNISA
Bond Exchange of SA
SAFEX
Office for Public Enterprises
Office of the Auditor General
Select Committee on Public Accounts
Standing Committee on Public Accounts
SARS
Ombudsman for Banking
Ombudsman for Long-term Insurance
Ombudsman for Short-term Insurance
Pension Funds Adjudicator
Commission of Enquiry into the Affairs of the Masterbond Group
Actuarial Society of SA
Association for the Advancement of Black Accountants
Association of Banking Lawyers of SA - RAU
Association of Law Societies
Black Lawyers Association
Black Management Forum
Chartered Institute of Management Acccountants
Consulting Actuaries Society of Southern Africa
Corporate Lawyers Association of SA
General Council of the Bar of SA
Lawyers for Human Rights
National NGO Coalition
SA Institute of Chartered Secretaries and Administrators
Business Practices Committee
Registrar of Companies
Business South Africa
Consumer Institute of SA
National Consumers Affairs Office
Departments of Economic Affairs of most Provinces
Pension Lawyers Association
Public Accountants arid Auditors Board
SA Law Commission
Registrar of Medical Schemes
Securities Regulation Panel
National African Federated Chamber of Commerce and Industry
Free Market Foundation
National Consumer Forum
Registrar of Banks
Afrikaanse Handelsinstituut
South African Chamber of Business
National Black Consumer Union
Association of General Banks
Institute of Bankers in South Africa
Association of Property Unit Trust Management Companies
Association of Trust Companies in SA
Association of Unit Trusts
Public Property Syndication Association
SA Property Owner's Association
Association of Black Securities and investment Professionals
Association of Bond Issuers of SA
Association of Corporate Treasures of SA
Fund Managers Association of SA
Institute of Financial Markets
Shareholders' Association of SA
Trustee Board Limited
Financial Intermediaries Federation of Southern Africa
Insurance Brokers Council
South African Black Insurance Brokers Association
Life Underwriters Association of SA
SA Reinsurance Offices' Association
SA Society of Medical Underwriters
National Council of Trade Unions
Financial Markets Advisory Board
SA Insurance Brokers Association
Institute of Loss Adjusters of Southern Africa
SA Risk and Insurance Management Association
COSATU
NEHAWU
Pension Funds Advisory Committee
SA Reinsurance Brokers
Insurance Institute of SA
SA Insurance Association
SA Society of Claims Administrators
FEDSAL
Advisory Committees on Long- and Short-term Insurance
Unit Trusts Advisory Committee
Institute of Life and Pensions Advisors

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