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RE1 Blueprint Series · Task 8 of 16

Comply with Regulated Record Keeping Requirements

A smaller task by weighting, but the questions tend to be precise about exact retention periods and start dates — exactly the kind of detail that's easy to get half right.

The 5 QCs, in full:
QC1 — Explain the record keeping obligations prescribed by the FAIS and FIC Acts
QC2 — Verify record keeping and retrieval is carried out per FAIS and FIC Act obligations
QC3 — Describe the requirements imposed when record keeping is outsourced to a third party
QC4 — Confirm third-party outsourcing agreements are executed correctly
QC5 — Explain the security requirements for record keeping, including POPIA

QC1: Two Obligations, Two Different Start Dates

FAIS and FICA record-keeping aren't the same rule wearing two names — they run on genuinely different clocks. FAIS records (like records of advice, under General Code Section 9) run 5 years from when the advice was given. FICA/CDD records run 5 years from termination of the relationship, not from the last transaction.

Exam trap: A 12-year client relationship doesn't mean the FICA retention clock has been running for 12 years — it only starts ticking once the relationship actually ends.

QC2: Retrieval Is the Real Test, Not Just Retention

Knowing the retention rule in theory is not the same as being able to produce the record in practice.

Real scenario: A KI can correctly recite the five-year FAIS retention period but cannot locate an actual client file when the Ombud requests it. This is a failure in substance, regardless of how well the retention theory was understood — the obligation is retrieval within a reasonable time, not just storage somewhere.

QC3–QC4: Outsourcing Records Doesn't Outsource the Accountability

Handing record-keeping to a third-party administrator doesn't transfer the FSP's regulatory responsibility for those records. QC4 requires an actual signed, reviewed agreement covering retention periods, security, and retrieval obligations — not an informal arrangement with a service provider assumed to "handle it properly."

QC5: Where Record-Keeping Meets POPIA

Client files often contain ID numbers, income details, and sometimes health information — this is where FAIS record-keeping meets POPIA's security safeguard requirements directly. Confidentiality and controlled access are part of the record-keeping obligation itself, not a separate add-on consideration.

Quick Recap

Two Clocks, Not One

RE Mastery Hub's Task Quizzes test the FAIS-versus-FICA retention distinction directly — a detail that's easy to blur under time pressure.

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