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Post-Sale Treatment, Claims Support and Service Standards Under COFI

Post-sale claims support guidance by Nkwali Compliance Consultants
COFI Readiness Series | Week 4

Post-Sale Treatment, Claims Support and Service Standards Under COFI

What happens after the sale matters just as much as what happens at the point of sale.

COFI is not only about how the sale happens. It also focuses on what happens after the sale, including service, claims support, complaints, policy changes, cancellations, and whether clients face unreasonable barriers when they need help.
Post-sale claims support for financial services providers

Post-sale claims support starts after the sale

Post-sale claims support is central to this Week 4 discussion. In the earlier weeks, we looked at customer outcomes, practical compliance evidence, and how COFI may affect licensing, activities, and remuneration. This week, we focus on a highly practical question: what happens after the sale?

Many FSPs focus heavily on getting advice, disclosures, and records right at the start of the relationship. That is important. However, fair treatment must continue after the point of contracting and even in relation to how the contract is terminated and what happens after termination.

For many intermediary businesses, conduct risk becomes very real after the sale, because that is where the client needs help, follow-up, updates, and fair support in practice.

Why post-sale claims support matters

Your business may not design products, but it may still shape the client’s post-sale experience through client servicing, policy changes and amendments, underwriting follow-ups, claims submissions, complaints handling, cancellations, replacements, switches, and post-sale queries.

These day-to-day interactions shape how clients experience your business and whether they are treated fairly in practice. Therefore, post-sale service should not be treated as an informal extra. It should be treated as a controlled part of the customer journey.

Post-sale barriers under COFI

The Bill says a financial institution may not impose post-sale barriers that may unreasonably prevent clients from changing products, moving to another institution, submitting a claim, or making a complaint. That means businesses should think carefully about whether clients face unnecessary friction once they need help.

Post-sale barrier What it may look like in practice
Claims support difficulty The client struggles to get help, does not know where to send documents, or receives slow follow-up.
Repeated information requests The client keeps submitting the same information or documents more than once without a clear reason.
Servicing delays Policy changes, amendments, or post-sale queries take too long and nobody explains the delay properly.
Poor communication The client does not know what documents are needed, what stage the matter is at, or what happens next.
Cancellation or switching friction The business makes cancellation, replacement, or switching more difficult than necessary.
Weak complaints handling Complaints are ignored, delayed, or handled informally without proper follow-up or records.

Post-sale claims support in practice

The Bill expects clients to continue receiving relevant information on an ongoing basis, to have access to efficient and effective complaints management, and to be supported by claims processes that are fair, transparent, and expeditious.

In addition, clients should be able to access dispute resolution mechanisms, terminate contracts without unreasonable barriers, and avoid unreasonable fees, charges, or penalties on termination. For many FSPs, that means post-sale claims support should be structured, controlled, and reviewed.

Claims support under a conduct lens

For your business, the useful question is not only whether the insurer or product supplier ultimately decides the claim or processes the amendment. The real question is how your business supports the client through that process.

Claims communication: Do clients know where to send claim documents and what is required?
Follow-up discipline: Are follow-ups done promptly and are delays explained properly?
Client updates: Are updates given to the client at sensible points in the process?
Tracking: Are servicing requests and claims-related matters tracked until completion?
Escalation: If a matter is urgent or stalled, does someone escalate it?

Even where the final outcome sits with a supplier, the way your business supports the client can still create either a fair or poor conduct outcome.

Service standards after sale

The Bill requires acceptable levels of service support after the initial sale, including responses to enquiries and later transactions or engagements with the client. It also expects service to be fair, reliable, transparent, and consistent with the reasonable expectations created earlier.

This means clients should not experience one standard of service during sales and then a very different standard once they need help. A practical COFI question for any FSP is this: would a client say that getting help after the sale is clear, fair, and reasonably efficient?

Review post-sale claims support this week

Choose one post-sale area in your business and review it properly. Good examples include claims submission support, policy servicing and amendments, complaint handling, cancellations, and client queries after sale. Then ask practical questions about what the client experiences and what evidence your business keeps.

Post-sale areas to test

  • Claims submission support
  • Policy servicing and amendments
  • Complaint handling
  • Cancellations
  • Client queries after sale

Post-sale questions to ask

  • What happens when the client needs help after the sale?
  • What are the exact steps followed by the business?
  • What communication does the client receive?
  • How are delays, handovers, or outstanding matters tracked?
  • Is there evidence that the matter was handled fairly and within a reasonable time?
  • Are there any points where the client may face unnecessary difficulty or frustration?

Why post-sale claims support matters now

The message is clear: fair treatment does not end at the point of sale. Financial institutions are expected to continue promoting fair treatment after the contract has been entered into, including in relation to claims, complaints, switching, termination, and ongoing service support.

If you need broader support, you can also explore our compliance consulting, licensing and registration services, and compliance training. You can also monitor conduct-related developments through the FSCA and broader policy material published by National Treasury.

This Week’s Practical Focus

Use this week to test whether your business treats post-sale service as a controlled part of the customer journey.

First, choose one post-sale area. Next, map the actual steps the business follows. Then, review whether the client receives clear communication, reasonable support, proper follow-up, and fair treatment throughout.

Week 4 focus areas

Claims support Client servicing Complaints Cancellations Service standards

This gives your business a practical way to identify post-sale conduct risk early.

Post-sale warning signs

  • Clients do not know what to do after the sale.
  • Claims support depends on ad hoc follow-up.
  • Servicing requests are not tracked properly.
  • Complaints are handled informally.
  • Cancellations or switches create unnecessary friction.

How Nkwali helps

At Nkwali Compliance Consultants, we help FSPs assess whether their post-sale treatment, claims support, complaint handling, and service standards reflect fair conduct in practice.

We help businesses map real client journeys, identify unreasonable barriers, improve oversight, and strengthen the evidence that shows fair treatment continues after the sale.

Need help reviewing post-sale service under COFI?

We can help you review claims support, complaints handling, post-sale servicing, and other client-facing processes that may create conduct risk after the sale.

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