FAIS Record-Keeping for South African Brokers: What You Must Keep, and For How Long

Every South African financial services provider knows the feeling. The compliance officer asks for the advice record on a client from three years ago, and the search begins: an email inbox, a shared drive, a WhatsApp thread, and someone''s memory.

FAIS does not fail brokers on intent. It fails them on retrieval.

What the FAIS Act expects you to keep

Under the Financial Advisory and Intermediary Services Act and the General Code of Conduct, an FSP must maintain records of:

• Client needs analysis and the advice given, including the reasons for the recommendation
• Disclosures made to the client (fees, commission, conflicts of interest, product supplier)
• Any replacement of a financial product and the comparison that justified it
• Premium collection and payment records
• Client instructions, including cancellations and amendments
• Complaints received and how each was resolved

The general expectation is a five-year retention period from the date the relationship or transaction ends, and records must be retrievable in a reasonable time. Electronic records are acceptable, provided they are safe from unauthorised change.

Why brokers still fail audits

The records usually exist. They are simply scattered:

• The advice conversation happened on a call that was never logged
• The disclosure was emailed from a personal mailbox
• The renewal instruction came in on WhatsApp
• The complaint was resolved verbally and never written down

When compliance is a filing exercise done after the fact, it will always be incomplete. The fix is not more discipline. It is a system where the record is created as a by-product of doing the work.

What "automatic" record-keeping looks like

In practice, a compliant broker operation needs four things wired together:

1. One client record. Every policy, contact, document, invoice and conversation attached to the same client, not to an individual staff member''s inbox.
2. Logged interactions. Calls, emails and messages captured against the client automatically, with the date, the adviser and the outcome.
3. Document trail with versions. Needs analyses, quotes, disclosure letters and signed mandates stored against the client, with the version history intact.
4. A complaints register. Every complaint logged as a ticket with an owner, a due date and a resolution note, so the FAIS complaints report writes itself.

A five-minute self-audit

Pick any three clients at random and answer these questions without asking a colleague:

• Can you produce the advice record and the disclosures in under two minutes?
• Can you show every interaction with that client for the past 24 months?
• If the adviser who handled them left tomorrow, would the file still stand up?

If any answer is no, the exposure is not theoretical. It is the exact gap a compliance review or an ombud referral will find.

How Recenvy handles it

Recenvy is used by brokerages that need the audit trail without hiring a full-time administrator to maintain it. Client records, policies, quotes, invoices, contracts with digital signatures, call logs and complaint tickets all live in one place, with role-based access so staff only see what they should. Every change is written to an audit log, and documents are retained with version history, so the five-year requirement is met by default rather than by effort.

Compliance stops being a project when the system records the work as it happens.