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South Africa's 'Twin Peaks' financial regulatory model yet more of the same: ineffectual and inept

South Africa has a new financial regulatory model called "Twin Peaks" based on Australia's.  Financial services will be regulated by two regulators - the Prudential Authority responsible for prudential regulation and Financial Sector Control Authority for market conduct and consumer protection.

In the article Twin Peaks: the good, bad and ugly (Business Times) Roxanne Henderson writes:

“In the Twin Peaks model, financial services will be regulated by ... the Financial Sector Control Body (FSCA) to strengthen the country’s approach to consumer protection and market conduct.”  

She quotes University of Western Australia financial regulation expert Andy Schmulow who said “the implementation is going to be absolutely crucial”; UNISA law professor Michelle Kelly-Louw: “Australia’s model [on which South Africa’s is based] had encouraged deeper consumer participation in the financial services sector, which South Africa needed”, and Odette de Beer: “the renewed focus on consumer protection would give companies a competitive advantage over their peers”.

Greater consumer protection and participation?  Absolute poppycock!

The FSCA came into operation on April 1 and already has failed that first and vital test. And through no fault of theirs, Andy, Michelle and whoever else who advocated it in good faith because that’s their understanding of its mandate may be embarrassed and mistaken as a result.

On the advice of Schmulow whom I communicated with via his The Conversation article on the subject, I submitted a complaint to the FSCA online on May 1.  It concerned my credit card company Standard Bank that since January 1 unilaterally imposed a monthly fee for “value-added services” they never asked me/customers about that I don’t want or need. The Consumer Protection Act explicitly bans this practice which it calls “bundling” saying consumers are not obliged to buy them.  It’s similar to infamous Cash Paymaster Services levying social grant beneficiaries with “unauthorised, fraudulent deductions”.

I’m not upset by the small monthly fee (I pay R10, but it’s between R10 and R212 depending on the type of card), but that they’ve taken from me my right to exercise my economic and financial decision-making and imposed “services” I don’t want.  This scheme benefits them and their business partners and it remains to be seen if customers can get better deals on their own if they so desire.

In March after I complained, they briefly repeated the status quo and did not bother to explain the inconsistencies with the CPA.  

When there was no further response, on April 1 I wrote to the National Consumer Commission (NCC). On April 30 they replied they have no jurisdiction because the “Financial Services Laws General Amendment Act 45 of 2013 exempts the banking industry from the CPA”. They suggested the Banking Ombudsman. (I copied the complaint to Standard Bank.  Only then did they respond more fully, but still refused to delist me from the scheme saying there’s no “opt-out”.)

The Banking Ombudsman is a private, bank-funded organisation, not a regulator or statutory body. That’s like taking your criminal charge to the perpetrator to investigate. (I referred my complaints to the ombudsman and NCR. The former acknowledged it but the NCR didn’t although I believe they’re already investigating.)

That’s where it lay when Andy suggested the FSCA, which he described thus: “As of 1 April the Financial Sector Conduct Authority will have authority over ever regulated entity which is every entity that provides a product or service as defined by the Financial Sector Regulation Act, except in respect of credit, which is still the ambit of the National Credit Regulator”.

The FSCA automatically acknowledged my complaint, but on May 9 this is what their Itumeleng Kganane wrote:

“Kindly be advised that your complaint does not fall within our jurisdiction. The National Consumer Commission’s response was correct when stating that the best forum to deal with this matter is office of Banking Ombudman.”

The NCC has no jurisdiction because of a specific act but Kganane didn’t say what legislation or regulation prevents them from doing so.  (Her email didn’t identify her job title but a LinkedIn page identifies one “Itumeleng Kganane” as “senior analyst” at the FSB, FSCA’s forerunner.)  I replied stating that, otherwise they must investigate.  There was no further response.

In the absence of an explanation and based on what Schmulow and other experts say, my complaint does fall within FSCA’s jurisdiction. But it’s apparent they’re making up reasons not to investigate, a strange, illegal attitude by a regulator. I didn’t complain about a minor customer-bank dispute, but Standard Bank’s deliberate violation of the CPA and my economic rights and national credit act.  “Attorney Stephen Logan said the fee has nothing to do with the provision of credit, and a bank can't add additional services that aren't optional" (ibid). 

I don’t know how many credit card clients they have but if, say, a million don’t want the service and thus the bank incurs no related expense, and they’re forced to pay R20 a month each, Standard Bank’s earns over R200 million a year for doing absolutely nothing. 

But the regulator, allegedly the champion of consumer rights and protection, is fine with letting them get away with it!

To Schmulow’s follow-up article I related what the FSCA’s Kganane told me. He replied, “This is disappointing to hear”. That’s an understatement.  Unfortunately the FSCA’s conduct or confusion about their mandate undermines good-intentioned people and experts who believe the Twin Peaks model offers the kind of financial regulator the country needs and deserves.

This week I spoke to a senior consultant/financial planner of a major asset management company about another matter during which I mentioned my experience.  I asked what she knew of FSCA’s role. Regarding my complaint about its apparent lack of oversight of banks she opined, do “banks operate in their own bubble?”

That’s exactly what I told Schmulow: the ANC government, despite its promise of “better life for all” including some economic prosperity, gave banks the extraordinary privilege of “regulating themselves”, as former finance minister Pravin Gordhan cravenly allowed in 2009/2010 about excessive bank charges (at the time of his involvement, the Competitions Commission abandoned their investigation), a situation that saw fees immediately and significantly increase.

Ten years ago the same bank changed my savings account without informing me.  I lost some interest and incurred higher charges as a result.  According to the bank consultant I spoke to they probably contravened the Financial Intelligence Centre Act (FICA). After they promised to investigate but then became uncooperative, not knowing who had jurisdiction, I wrote to the South African Reserve Bank.  In an unsigned letter SARB told me they don't "mediate customer-bank" disputes.  The bank broke a law and that was what they thought it was - a minor dispute?

But if a client violates financial laws or regulations, as the Guptas found out to their cost, they face severe sanctions and penalties including having their accounts closed. But the government has given banks carte blanche.  

No other professional and commercial sector has this right. It’s in light of this – government letting banks to do what they want – that the big four banks’ non-interest revenue (charges and fees) is over R50bn a year, a 41% increase from 2010 to 2015 (also see here).  What is the ANC government getting in return?

It appears the FSCA is another in a long line of ineffectual, incompetent and compromised regulators and statutory bodies – NPA, public protector, etc – that’s failing the public. I’m not surprised.  

Schmulow offered to look into the matter for me (his The Conversation profile states, “He currently serves on an independent expert advisory panel convened by the South African National Treasury advising on the Conduct of Financial Institutions Bill”).  But I said I shall not hold him to it.  Already they’re going the way of sister organisations – inept, hopeless and waste of time.  Those invested or indirectly associated, e.g., advisors, etc, with it should not identify too closely out of reputational risk.

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