Define the Role of the Representative in Terms of the FAIS Act

RE5 candidates study this from the inside — what it means to be a representative. RE1 tests it from the KI's side: recognising when someone has crossed into needing representative status, and keeping an accurate register of everyone who has.

QC1: Substance, Not Job Title

A representative renders financial services — advice or an intermediary service — under an FSP's licence. They're authorised, not separately licensed, and they carry their own conduct duties under the General Code even though the FSP bears overall legal responsibility.

QC2: When Does Someone Actually Become a Representative?

The moment a person renders advice or an intermediary service in relation to an included financial product, to an identifiable client — regardless of what their job title says.

QC3–QC4: The Register of Representatives

The register is the FSP's authoritative record of who may legally render financial services on its behalf at any given moment — not a piece of administrative box-ticking that can lag behind reality. A register still listing someone who resigned months ago is a live compliance failure, not a paperwork delay.

QC4 is the KI's own checking duty: confirming the register's accuracy directly, not assuming HR maintains it correctly without independent verification. Anyone relying on the register to confirm a person's authority must be given accurate information — a client calling to confirm they're genuinely dealing with an authorised representative deserves a register that reflects reality, not one four months out of date.

Quick Recap

• Representative status is triggered by what someone actually does, not their job title
• The FSP's overall responsibility doesn't remove a representative's own personal conduct duties
• A register that lags behind reality is a live compliance failure, not a minor lapse
• Verifying the register's accuracy is the KI's own checking duty, not something to delegate blindly