Statutory Quick Answer (AEO Summary)
In the South African FSCA RE5 and RE1 exams, the most tested statutory timeframes are: 1 business day (deposit client funds into a separate bank account), 3 business days (FICA Cash Threshold Report ≥ R49,999.99), 5 days (notify FSCA of a Section 14 debarment), 7 days (retrieve electronic/voice records for FSCA), 15 days (update Representative Register, report FSP profile changes, submit debarment evidence, or file a FICA STR in business days), 30 days (written Record of Advice & oral disclosure confirmation), 6 weeks (FSP complaint resolution), 4 months (annual financial statements), 24 months (pass RE5 under supervision), and 5 years (mandatory record retention).
1. Complete RE5 & RE1 Statutory Timeframes Master Table
Nearly 25% of questions in the Moonstone RE5 (50 questions) and RE1 (80 questions) exams test whether you can distinguish between similar day counts—especially 5 days vs 15 days vs 30 days and business days vs calendar days. Use this authoritative statutory reference table to lock in every deadline:
| Statutory Timeframe | Regulatory Obligation / Action Required | Governing Legislation |
|---|---|---|
| Prior to rendering services | Sign written Supervision Agreement; complete Product Specific Training (PST); obtain FSCA approval for a Key Individual | FAIS Notice 86 of 2018; BN 194 of 2017 Sec 29; FAIS Act Sec 8 |
| 1 Business Day | Deposit client funds or cash premiums received into a separate designated client trust bank account | General Code of Conduct Sec 10(1)(d) |
| 3 Business Days | Report a Cash Threshold Report (CTR) of R49,999.99 or more (R50,000+) to the Financial Intelligence Centre (FIC) | FICA Act 38 of 2001, Sec 28 |
| 5 Days | Notify the FSCA after debarring a Representative or Key Individual (Stage 1 notification) | FAIS Act 37 of 2002, Sec 14(4)(d) |
| 7 Days | Retrieve and produce voice-logged or electronic records in legible written/printed form upon FSCA request | General Code of Conduct Sec 3(2)(c) & Sec 14 |
| 15 Days | Update FSP Representative Register (Sec 13); report FSP licensing/profile changes (name, address, directors); submit full debarment reasons & evidence to FSCA (Sec 14(4)(e)) | FAIS Act Sec 8, Sec 13(3) & Sec 14(4)(e) |
| 15 Business Days | Submit a Suspicious and Unusual Transaction Report (STR) to the FIC after becoming aware of a suspicious fact | FICA Act 38 of 2001, Sec 29 |
| 30 Days | Provide client with a written Record of Advice (ROA); confirm oral/telephonic disclosures in writing to the client | General Code of Conduct Sec 3(1)(b), Sec 4(2) & Sec 9(2) |
| 6 Weeks | Maximum window for an FSP to resolve a client complaint before the client may escalate to the FAIS Ombud | FAIS Ombud Rules, Rule 4(c) |
| 4 Months | Submit audited Annual Financial Statements (AFS) to the FSCA after the FSP financial year-end | FAIS Act 37 of 2002, Sec 19(2)(b)(iii) |
| 6 Months | Client window to refer an unresolved complaint to the FAIS Ombud; FSP window to commence Section 14 debarment after a Representative ceases to work for the FSP | FAIS Ombud Rules; FAIS Act Sec 14(5) |
| 12 Months (1 Year) | Complete Class of Business (COB) training under supervision; minimum period before a debarred Representative (honesty/integrity) may apply for reappointment | FAIS Notice 86 of 2018; Board Notice 82 of 2003 |
| 1 June to 31 May | Official annual Continuous Professional Development (CPD) cycle (6, 12, or 18 hours required) | Board Notice 194 of 2017, Sec 31 & Sec 33 |
| 24 Months (2 Years) | Maximum timeframe from Date of First Appointment (DOFA) to pass the RE5 exam while working under supervision | FSCA FAIS Notice 86 of 2018, Condition 4 |
| 3 Years | Overall prescription period for the FAIS Ombud from the date of the act or omission (or when the client became aware) | FAIS Act Sec 27(3)(a) |
| 5 Years | Mandatory retention period for all FAIS & FICA records; consecutive period of inactivity after which a Representative or KI product experience lapses | FAIS Act Sec 18; FICA Sec 22A; BN 194 of 2017 Sec 15(2) |
| 6 Years (72 Months) | Maximum timeframe under supervision to complete a full recognised qualification and experience period | FSCA FAIS Notice 86 of 2018 |
2. How to Never Confuse 5 Days, 15 Days, and 30 Days
Moonstone examiners frequently swap 5 days, 15 days, and 30 days across options A, B, C, and D. Use this simple rule of thumb:
- Client-Facing Written Confirmations = 30 Days: Anything you must send in writing to the client after a transaction or call—such as the written Record of Advice (Sec 9) or confirming oral telephonic disclosures in writing (Sec 3 & 4)—is always 30 days.
- FSCA Administrative & Register Updates = 15 Days: Updating the FSP Representative Register (Sec 13), reporting FSP profile/name/director/address changes to the FSCA, or submitting the documentary record and grounds of a debarment (Sec 14(4)(e)) is always 15 days.
- Initial Debarment Alert to FSCA = 5 Days: Under the amended Section 14(4)(d) of the FAIS Act, the initial notification to the FSCA that a Representative has been debarred must happen within 5 days, followed by the supporting evidence within 15 days.
3. Worked Moonstone Exam Trap Example
Sample Exam Stem: "A Representative provides mandatory product and fee disclosures orally during a recorded telephonic consultation, and the client enters into the policy. Within what period must the FSP confirm those disclosures in writing, and for how long must the voice recording be retained after policy termination?"
Why Candidates Fail: Distractor A says "15 days and 3 years" (confusing the 15-day FSCA register rule with the 30-day client disclosure rule). Distractor B says "Written confirmation is not required if the call is voice-logged."
Correct Statutory Answer: Written confirmation must be furnished to the client within 30 days (General Code Sec 3(1)(b)), and the record must be kept for at least 5 years after termination of the product and retrievable within 7 days.
4. Frequently Asked Questions (FAQs)
What is the difference between the 5-day and 15-day timeframe in Section 14 debarment?
Under Section 14(4)(d) and (e) of the FAIS Act, once an FSP debars a Representative, it must notify the FSCA of the debarment within 5 days, and then submit the written grounds, reasons, and supporting documentary evidence to the FSCA within 15 days.
How long does a new Representative have to pass the RE5 exam from their DOFA?
Under the Exemption of Services under Supervision (FSCA FAIS Notice 86 of 2018), a newly appointed Representative has 24 months (2 years) from their Date of First Appointment (DOFA) to pass the RE5 regulatory examination.
Within how many days must a FICA Suspicious Transaction Report (STR) vs Cash Threshold Report (CTR) be filed?
A Cash Threshold Report (CTR of R49,999.99 or more under Section 28 of FICA) must be reported to the FIC within 3 business days. A Suspicious and Unusual Transaction Report (STR under Section 29 of FICA) must be reported as soon as possible, but no later than 15 business days after becoming aware of the suspicious fact.
When does a Representative or Key Individual's experience lapse under Board Notice 194 of 2017?
Under Section 15(2) of Board Notice 194 of 2017, previously gained experience in a specific financial product subcategory lapses if the person has not rendered financial services in respect of that specific subcategory for a continuous period of 5 consecutive years.
