Description

Client Advisory Policy Pack for FAIS FSPs

The Client Advisory Policy Pack is an editable downloadable template designed for authorised Financial Services Providers that need a practical framework for advice, intermediary services, client reviews, investment monitoring, execution-only sales and automated advice controls.

This Client Advisory Policy helps an FSP document how client engagements must be handled from first contact to post-sale servicing. It supports clear disclosures, suitable advice, complete records of advice, fair treatment of clients, replacement advice controls, quality assurance and ongoing monitoring.

For related compliance templates, you may also view our Complaints Management Framework Template, Conflict of Interest Management Policy and Representative Appointment Compliance Pack.

For official regulatory information, you can also visit the FSCA FAIS regulated entities page.

What Is Included In This Client Advisory Policy?

This template is designed to help FSPs standardise their advisory process and create evidence that clients were treated fairly, advice was properly considered, disclosures were made and records were retained.

The policy includes sections for:

• Policy review and version control
• Training and implementation record
• Introduction, purpose and objectives
• Scope and applicability
• Regulatory framework
• Definitions, including advice, intermediary service, execution of sales, automated advice, client review and record of advice
• Governance, accountability and responsibilities
• Client advisory principles
• End-to-end client advisory procedure
• Record of Advice and advice evidence requirements
• Client reviews and annual section 7(4) statements
• Client investment monitoring procedure
• Execution of sales procedure
• Automated advice procedure
• Replacement advice controls
• Vulnerable clients and fair treatment controls
• Complaints, errors and remediation
• Monitoring, quality assurance and management information
• Training, competence and supervision
• Recordkeeping and POPIA controls
• Breaches and non-compliance
• Review, approval and ownership

Client Advisory Policy Annexures Included

The Client Advisory Policy Pack includes practical annexures that help the FSP implement and evidence the advisory process in real client files, reviews, monitoring activities and sales quality assurance.

The annexures include:

• Annexure A: Client Advisory File Checklist
• Annexure B: Client Needs Analysis Summary
• Annexure C: Record of Advice Template
• Annexure D: Comparative Quote / Product Comparison Template
• Annexure E: Replacement Advice Checklist
• Annexure F: Annual Client Review Template
• Annexure G: Client Review Tracker
• Annexure H: Investment Monitoring Register
• Annexure I: Execution of Sales Script Approval Register
• Annexure J: Execution of Sales Call QA Checklist
• Annexure K: Automated Advice Approval and Testing Log
• Annexure L: Automated Advice Exception Register
• Annexure M: Advice File Quality Assurance Checklist
• Annexure N: Staff Acknowledgement and Declaration

Why FSPs Need a Client Advisory Policy

Advice and intermediary services are high-risk areas for FSPs because they directly affect client decisions, product suitability, disclosure quality, complaints, Ombud outcomes and regulatory scrutiny.

A written Client Advisory Policy helps the FSP show how representatives must define the client relationship, collect client information, analyse needs, compare options, present recommendations, obtain client authority, implement products and provide post-sale service.

This template helps address common weaknesses such as:

• No documented advice process
• No standard client advisory file checklist
• No structured needs analysis summary
• No Record of Advice template
• No comparative quote or product comparison template
• No replacement advice checklist
• No annual client review template
• No client review tracker
• No investment monitoring register
• No execution-only sales QA checklist
• No automated advice approval and testing log
• No advice file quality assurance checklist

Record of Advice and Advice File Controls

The pack includes a Record of Advice template and client advisory file checklist to help the FSP keep evidence of what was recommended, why it was recommended, what information was considered, what alternatives were discussed, what disclosures were made and what the client decided.

This supports better advice file quality and helps the FSP prepare for internal monitoring, external compliance reviews, product supplier queries, Ombud matters or FSCA requests.

Client Reviews and Investment Monitoring

The Client Advisory Policy includes client review procedures and templates for annual review records, client review tracking and investment monitoring. These tools help the FSP record whether the client’s circumstances have changed, whether the product remains suitable and whether any further action is required.

The investment monitoring register is useful where the FSP provides ongoing monitoring within its licence category and agreed client mandate.

Execution of Sales and Automated Advice Controls

The pack includes execution-only sales controls for FSPs that use approved scripts, call recordings and quality assurance reviews. It helps the FSP distinguish between factual execution-only sales and regulated advice.

It also includes automated advice controls, including an approval and testing log and exception register. These tools help the FSP document system testing, client data controls, suitability safeguards, human oversight, audit trails and remediation where automated outputs create risks.

Replacement Advice and Vulnerable Client Controls

The replacement advice checklist helps the FSP record why an existing product is being replaced, what costs and consequences were explained, whether benefits may be lost, whether waiting periods or exclusions may apply and whether the client gave proper authority.

The policy also includes guidance on vulnerable clients, including additional care where a client may be affected by age, language, literacy, disability, financial distress, trauma, health or limited financial knowledge.

Who Should Use This Client Advisory Policy?

• Authorised Financial Services Providers
• Key Individuals responsible for advice oversight
• FSPs with representatives or supervised representatives
• FSPs providing advice or intermediary services
• FSPs performing client reviews or investment monitoring
• FSPs using execution-only sales scripts
• FSPs using automated advice or decision-support tools
• Compliance officers assisting FSPs with advice process controls

Editable and Customisable FAIS Advice Template

This Client Advisory Policy Pack is editable and must be customised before use. The FSP must insert its name, FSP number, policy owner, authorised product categories, advice process, service model, review cycle, script approval process, automated advice controls, monitoring frequency and evidence storage location.

The template includes practical annexures that should be completed and aligned to the FSP’s actual business model before the policy is approved and implemented.

Important Compliance Note

This Client Advisory Policy Pack is a compliance support document. It does not replace legal advice, regulatory advice, a full advice process review, product suitability assessment, automated advice model validation or external compliance officer monitoring. Each FSP remains responsible for ensuring that the final policy is accurate, practical, implemented and aligned with its licence categories, advice model, representatives, systems and current FAIS obligations.