With slightly more than 200 days to go to the 1 March 2019 legislative implementation deadline for the default regulations, we are to briefly updating our clients on progress within Sanlam Employee Benefits (“SEB”) towards implementing the requirements.
Although there remains as yet unresolved interpretative difficulties with the legislation (some of which is being taken up with the regulator e.g. via the Institute of Retirement Funds Africa), we believe we have no practical option but to move forward with implementation.
We are aware that further regulatory notices relating to the default regulations might yet be issued prior to 1 March 2019, and we are monitoring developments in this regard as closely as possible with the aim of trying our best to avoid any last minute surprises.
Clients will already be aware that the default regulations significantly impact day to day operational procedures such as withdrawal and retirement pay-out processes. For both processes, there is introduced a legal requirement for boards of trustees to ensure members have access to retirement benefits counselling before completing any pay-outs. Furthermore in the case of withdrawal pay-outs, the fund must obtain member written instruction before any pay-outs (other than default in fund preservation) can be processed. As can be imagined, these new requirements have significant operational and IT implications, and our experts are hard at work to ensure we comply from an administrative perspective before 1 March 2019.
This topic will be covered in detail during the upcoming Sanlam Umbrella fund Symposium.