New regulatory requirements such as the introduction of counselling services to members, obtaining members’ personal contact details and making direct contact with members, are pushing retirement funds to change the way it interacts and service the various stakeholder groups.  While most of the new regulatory measures seek to expand the duties and responsibilities of a fund, the Protection of Personal Information Act tends to limit the scope of these expansions and make attempts to contact members directly complicated and challenging.

In response to the new legislation and irrespective of these challenges, the Sanlam Umbrella Fund revised its communication strategy to make provision for servicing members directly in an effective manner.

Review of current roles and responsibilities

As part of the new strategy, the Fund is also reviewing the current roles and responsibilities as defined for each stakeholder group.  The most important consideration is to ensure that the role of the retirement counsellor complies with legislation, but that any additional services do not impact negatively on the role and function of the Contracting Benefit Consultant (CBC) or the Contracted Financial Adviser (CFA).

The Board of Trustees are in the process of finalising these arrangements and is doing so in consultation with stakeholders. Once finalised, the revised roles and responsibilities will be incorporated in the Fund rules and documented in the next version of The Fund in Detail (prior to 1 March 2019).

Proposed revised roles and responsibilities for CBC’s and CFA’s

The current roles and responsibilities of CBC’s and CFA’s is to remain substantially the same, but with the suggestion that it specify more detail. The following proposals are being considered:

  • The role of the CFA: Members who request independent financial advice will be referred to the CFA on record. From a POPI Act perspective however, the Fund may only provide the CFA with member information once the member submits such a request in writing.
  • The role of the CBC: Specify more detail on the duties and responsibilities towards servicing and supporting the participating employer – at implementation stage as well as ensuring compliance with all participating requirements on an ongoing basis.

New role and responsibilities of the Retirement Benefit Counsellor

  • Provide members with counselling before receiving a withdrawal or retirement benefit from the Fund.
  • Counsellors are not allowed to provide members with individual financial advice, and will refer members to the CFA on record, in cases where such advice is required.
  • If the participating employer selected this option, counsellors will make pro-active contact with members on certain events as determined by the employer, such as:
    • New members joining the fund
    • Members leaving employment
    • Members approaching retirement
    • Members with low replacement ratios
    • Members invested inappropriately.

Revised Participating Employer and Member duties and responsibilities

To ensure a holistic approach, we are amending the Fund rules and will phase in revised participation requirements in terms of which:

  • Participating employers may be required to provide HR support to assist members to gather and maintain “Fund information”, view the Day One Fund induction video, run a projected retirement ratio calculation and retain a copy for future reference.
  • Members will be required to maintain their “Fund information” with the Administrator and submit a schedule of dependants as well as a beneficiary nomination form.

Electronic Fund membership services

A new element in the Fund’s communication strategy is that of direct contact with members – “Electronic Fund membership services”.  This new strategy provides for the Fund to make contact with members directly, using their personal contact details on record with the Administrator.  Where appropriate and possible, the CBC or CFA will be copied in such communication.

Such communication may include:

  1. Alerting members to the fact that their employer failed to make contribution payments.
  1. Providing members/dependants with relevant Fund information on the options available to them and the implications thereof, on withdrawal or retirement.
  1. Providing member counselling services at certain predefined events or on request.
  1. Tracking and advising on the progress of any benefit payment due.
  1. Advising members who are invested in the lifestage investment strategy when key phasing strategies will commence.
  1. Inviting member representatives to participate and vote in the trustee election and attending the Fund’s annual symposium event (AGM).

Confidentiality and “Anti-spam” communication commitment

The Fund is aware of the fears and negative perceptions of members, participating employers and intermediaries relating to the sharing of members’ personal contact details.  The Sanlam Umbrella Fund therefore makes the following commitments:

Protection of personal information commitment

We respect members’ personal information and have taken special measures to ensure compliance with the provisions of the Protection of Personal Information Act. In particular, we will not pass members’ personal contact details on to anyone outside the agreed Fund infrastructure, other than as may be required in terms of the Fund rules or legislation.

“Anti-spam” and electronic communication commitment:

We respect members’ privacy and will limit the number of communications accordingly. We will only communicate information that the Fund is legally required to convey and information in relation to fund membership.


The following elements will be put in place and rolled out in various stages over a period of time.

  • The Fund has and will continue to request participating employers to gather and maintain the personal contact details of their members as envisaged by the FSCA in Information Circular 2 of 2016.
  • The Fund has and will continue to connect with members electronically to encourage them to register for access to the Administrators online member portal (and App). Once members are registered, they have direct access to the all their person Fund information, a number of member tools and useful information.
  • The Fund will communicate any changes in the duties and responsibilities of stakeholders and any adjustments to the Fund offering once the changes to the Fund rules has been developed and finalised.
  • Special measures will be taken to facilitate and roll out the changes and the new requirements with minimum disruption.