Debarment removes someone from the industry who no longer meets fit and proper requirements or has materially breached the Act. It's a protective mechanism for clients and industry integrity — not a disciplinary tool for ordinary employment disputes, and the FSP itself carries it out, since it holds the direct relationship and knowledge needed to act.
QC1 — Define the purpose of debarment
QC2 — Describe when debarment should be considered
QC3 — Check that representative agreements include scope of activities and possible debarment grounds
QC4 — Explain the debarment process to be followed for a possible FAIS Act contravention
QC5 — Confirm all role players are informed of debarment reasons, process, and recourse available
QC6 — Verify internal processes and procedures for debarment of representatives are in place
QC7 — Explain the timeframe and process to notify the FSCA of a debarment
QC1–QC2: Two Triggers, Filtered by "Material"
Debarment applies in exactly two situations: the person no longer meets fit and proper requirements, or they've materially contravened a FAIS Act provision. The word "material" is the operative filter — a minor, one-off administrative slip isn't automatically a trigger, while dishonesty or a serious or repeated breach typically is.
QC3–QC4: Even Serious Breaches Need a Fair Process
QC3 requires this to be documented before any debarment question arises — representative agreements should already specify scope of activities and possible debarment grounds, not be improvised once misconduct is discovered.
QC5–QC6: Consistency Across the FSP
QC5 is broader than just informing the representative in question — other role players (supervisors, the KI, relevant staff) need clarity too, so the process is applied consistently rather than depending on whoever happens to be handling that specific case. QC6 requires a documented, consistently-applied internal process — treating debarment as an HR matter rather than a regulatory one is a common way this goes wrong in practice.
QC7: Two Separate Notifications, Two Separate Deadlines
This is a common way the exam collapses two distinct requirements into a trap.
- Part I notification: within 5 days of the debarment decision
- Part II notification: within 15 days of the debarment date, with complete details
Quick Recap
- Debarment triggers on two grounds only: no longer meeting fit and proper, or a material FAIS Act contravention
- Procedural fairness — reasons, process, recourse, considered representations — applies even to serious, clear-cut breaches
- Part I notification is due within 5 days of the decision; Part II within 15 days of the debarment date
- These are two separate deadlines, not one combined requirement
Serious Misconduct Doesn't Excuse a Skipped Process
RE Mastery Hub's Task Quizzes test the Part I / Part II deadline split directly — a genuinely common way marks get lost on this task.
Try RE Mastery Hub Free