By Kea Koffman – Communications and Language Services
One of the key panellists at the recent FSCA Retirement Funds Conference titled The Future of Retirement Funds in South Africa was Zareena Camroodien, Head of the Retirement Funds Supervision: Fund Governance and Trustees Department. We sat down with her for a chat about her role and the role of the department she heads up. This is what she had to say.
Please tell us a little bit about who Zareena is?
I am an advocate and mother of four, who was born in District 6 of Cape Town. I am passionate about making positive changes in my own small ways and strive to live a life of impact. Treating people with integrity, dignity and respect are values which are incredibly important to me.
You are currently the Head of the Retirement Funds Supervision Division: Fund Governance and Trustee Conduct Department. What is the department responsible for and what do some of your duties entail in heading it up?
Our department ensures that pension fund boards have good governance and monitors the behaviour and conduct of trustees. Should there be concerns about inadequate or poor governance or pension fund governance and/or unruly trustees, the FSCA’s relevant departments and divisions, will take the necessary action there on.
We provide Trustee Training to better equip trustees in the exercise of their fiduciary duties, contribute to the drafting of certain regulatory instruments and provide both formal and informal guidance to the industry on various matters of concern.
We also provide technical legal support to all the departments in the Retirement Funds Supervision Division, and process Default Regulation exemptions and extensions. In the near future we will also assess the operation and impact of the default regulations on retirement funds and member outcomes.
The Department is required to have oversight on the conduct of trustees in relation to their obligations in applying Treating Customers Fairly (TCF) outcomes. This includes but is not limited to regular communications with members and compliance with the default regulations. Please tell us a bit about what this entails?
We work jointly with our Retirement Funds Conduct of Business Department, which has the primary function of overseeing TCF as the cornerstone of conduct. Our contribution to this aspect of supervision is to educate trustees in respect of the 6 TCF principles, through the Trustee Toolkit, as many trustees do not see all 6 TCF principles having application to retirement funds.
You are also responsible for the implementation and management of the FSCA’s Trustee Toolkit and related matters. With the revamping of the Trustee Toolkit currently underway, what does the revamp entail and what does it hope to address or achieve which it did not before? How will this in the long run benefit trustees?
The current Trustee Training Toolkit (TTK) was a wonderful introduction for trustees on the governance of retirement funds. There is, however, a significant revamp of the TTK; it is more comprehensive to assist in better equipping trustees in the exercise of their fiduciary duties which translates into better governance by boards and outcomes for members. Equally important, the Toolkit will now be updated to incorporate a topic on ESG.
With any change in life comes some uncertainties. What is your promise to trustees regarding this revamp and are there any myths that you would like to address at this point?
The revamp of the TTK is neither designed to make trustees’ lives more difficult nor is there any desire for it to be exclusionary. It has been designed to enhance trustees’ knowledge and to help them so that they may effectively exercise their fiduciary duties.
In general, what are some of the noteworthy milestones achieved since assuming leadership of the department?
The first milestone has been capacitating the department with highly competent staff. The department was new (only a month old) when I joined. We were responsive from the start of the Covid -19 pandemic by issuing Communique (FSCA Communication 11 of 2020) to the retirement fund industry on 26 March 2020 to inform them that they may apply for the suspension of contributions as long as they had registered rules in place or applied to register them on an urgent basis, whilst at the same time encouraging funds to continue paying risk benefits so that members were covered should any of the risks eventuate, which during the pandemic became critically important.
There was a backlog of default regulation exemption applications and extensions when I joined, and we have cleared that backlog within a relatively short space of time. I have not had any complaints regarding the legal advice that we have dispensed so I believe that we consistently provide well thought-out advice, given the generally complex pension issues we regularly deal with.
We have also provided extensive input in respect of COFI and the consequential amendments, amendments to Regulation 28 on, inter alia, infrastructure, the Two-Pot System, Auto Enrolment, and governance of commercial retirement funds to National Treasury. We have recently hosted the second Retirement Funds Conference and ran Webinars in respect of the first 11 Modules of the TTK, which is to be rolled out in September 2023. I must point out that it is took a collective effort to achieve our milestones and not merely by virtue of leadership.
After all is said and done, what do you want your legacy to be in the financial regulation environment?
So essentially, I will end where I started. I hope to make a positive difference in the lives of members by trying to ensure good governance of retirement funds and that trustees conduct themselves in a fit and proper manner to ensure favourable outcomes for members and society at large, as retirement funds are one of the largest institutional investors in the country. And I hope that I am remembered as someone who strove for excellence, acted with integrity, and treated every person with dignity and respect whilst doing my job, that I absolutely love and indulge in with humility and humour. | 
