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| Issued April 2025 | ||||
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| In this newsletter... | ||||
| Benchtest 03.2025 – FIMA restarted; RBS for Namibia; heads-up on overregulation, and more... | ||||
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| IMPORTANT NOTES AND REMINDERS | ||||
NAMFISA levies
The repo rate remained unchanged at 6.75% during April. The interest rate of 10.75% on funds’ direct loans and repayments will remain unchanged for May 2025. Budget proposals
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Registered service providers Certain pension fund service providers must register with NAMFISA and report to NAMFISA. Download a list of service providers registered as of June 2024, here... Retirement calculator Use our web-based retirement and risk shortfall calculator for your personal retirement planning. Find it here... If you need help with your financial planning, get in touch with
RFS provides comprehensive support for trustees. Find a list of download documents to assist with governance and management of private funds, registered as of June 2024, here... |
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| IN THIS NEWSLETTER... | ||||
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In this newsletter, we address the following topics:
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In 'Tilman Friedrich's industry forum' we present...
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In 'Legal snippets', read about...
As always, your comment is welcome, so open a new mail and drop us a note! Regards Tilman Friedrich |
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| TILMAN FRIEDRICH'S INDUSTRY FORUM | ||||
| Monthly Review of Portfolio Performance to 31 March 2025 |
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| In March 2025, the average prudential balanced portfolio returned 0.1% (February 2025: -0.2%). The top performer is the Allan Gray Balanced Fund, with 1.8%, while the NAM Coronation Balanced Plus Fund, with minus 1.4%, takes the bottom spot. Allan Gray Balanced Fund took the top spot for the three months, outperforming the ‘average’ by roughly 2.6%. The Stanlib Managed Fund underperformed the ‘average’ by 2.1% on the other end of the scale. Note that these returns are before (gross of) asset management fees. The Monthly Review of Portfolio Performance to 31 March 2025 reviews portfolio performances and provides insightful analyses. Download it here... |
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| ‘Hurricane Trump’ and the bigger picture | ||||
| The US is much more than President Trump and will sail the seas long after his demise. So the bigger picture remains its global supremacy and singularity even after Hurricane Trump’. If it was left to Europe, the world would still live in peace for another three years. But will the East afford it the time, and must the investor now adopt a short-term strategy? Market volatility is normal and should not derail a well-planned long-term investment strategy. Investors can navigate the ups and downs by staying the course, focusing on long-term growth, and taking advantage of market dips. Investors must know their needs and adapt their investment strategy to short-term needs. Investing during times of uncertainty requires a balanced approach that combines defensive strategies with opportunistic investments. While the potential for global conflict and economic downturns poses significant risks, it also presents opportunities for those who can navigate the complexities of the market. By focusing on value, diversifying geographically, and being flexible in your asset allocation, you can position yourself to protect and grow your discretionary assets in future years. These strategies should be tailored to your financial situation, risk tolerance, long-term goals and investment horizon. Read paragraph 6 of the Monthly Review of Portfolio Performance to 31 March 2025 for our views on investment markets and global political developments. It also reviews portfolio performances and provides insightful analyses. Download it here... |
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| The FIM Act – a new start Contributed by Carmen Diehl, C.A.(Namibia), Senior Manager: Risk Management and Compliance |
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This is a summary of main provisions of draft standards and regulations under the FIM Act and implication for retirement funds.
The FIMA (Act 2 of 2021) was promulgated in Government Gazette no. 7645 on 1 October 2021. The Minister of Finance has not yet set a date for it to become effective. It has hibernated ever since, but following last year’s elections, we will see action on it again in 2025, once the new Minister of Finance has found her feet. NAMFISA, however, has not been idle, spending a lot of time revising and issuing FIMA standards and regulations. In the next few issues of this newsletter, we will present the latest status on the standards and regulations and provide a brief overview. This summarises the main provisions of draft standards and regulations under the FIM Act and implications for retirement funds. Standards Chapter 5: Retirement Funds
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| A Model for Risk-based Supervision for Namibia | ||||
| NAMFISA recently engaged stakeholders regarding the introduction of a Risk-Based Supervisory model. The model envisages nine steps and emphasises the trustees’ responsibility for mitigating the risks. However, given Namibia’s unique environment, is this model appropriate? This question will be explored further on. 1. The nine steps of NAMFISA’s proposed risk-based supervision (RBS) NAMFISA will follow a structured process to assess the risks faced by pension funds:
NAMFISA’s transition from compliance-based supervision to Risk-Based Supervision (RBS) is a commendable step towards proactive and efficient regulatory oversight; however, given the unique structure of the Namibian pensions industry, where only the Government Institutions Pension Fund (GIPF) operates with full internal administration, while other funds outsource key functions to third-party service providers, such as administrators, consultants, and asset managers. Recognising the unique operational environment of the industry, NAMFISA should adapt the RBS approach to ensure effective and efficient supervision. 3. Key Observations Industry Structure and Systemic Risks
NAMFISA’s nine-step RBS model assesses risk at the individual fund level. While these nine steps align with global best practices, the focus on third-party-managed small and medium-sized funds creates regulatory blind spots in operational risk and cybersecurity, diverting resources unnecessarily to small and medium-sized funds whose boards effectively do not manage their operational risks. 4. Recommendations for an Enhanced RBS Model
NAMFISA’s transition to Risk-Based Supervision is a positive move towards safeguarding the Namibian pensions industry. However, NAMFISA must adjust its focus towards third-party service providers, given their critical role in fund operations, to ensure its effectiveness. By implementing service provider risk scoring, cybersecurity audits, and optimising regulatory resources, NAMFISA can better protect pension fund members and provide financial system stability. |
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| BON Governor warns against over-regulation | ||||
| The Brief reported in its 4 April issue that ‘the Bank of Namibia (BoN) Governor Johannes !Gawaxab has cautioned against excessive regulation, warning that stringent policies could hinder economic growth and drive businesses into the informal sector. He stressed the need for a regulatory framework that fosters business efficiency and investment while ensuring consumer protection. “Namibia is a developing country, yet our regulations often mirror those of more advanced economies. We must acknowledge that our unique socio-economic challenges require a regulatory approach that is both flexible and progressive,” !Gawaxab said. The Governor highlighted the risks of excessive regulation, citing its potential to stifle innovation, discourage investment, and push businesses into the informal economy. He also emphasised the importance of fostering a regulatory environment that enables businesses to operate efficiently while maintaining necessary safeguards for consumer protection.” The topic of overregulation is close to our hearts, and we have on numerous occasions lamented our regulators slavishly following the advice of experts from developed countries. Regarding the impact of the FIMA on the pensions industry, we have repeatedly expressed our concern about the high governance and compliance costs associated with this new law, which fund members and pensioners will ultimately bear. This law contains around 600 compliance requirements for retirement funds and their administrators. Considering the wide discretion the law affords the regulator in interpreting governance and compliance requirements and regulating these, it will be impossible for any service provider and fund to avoid severe penalties for failure to meet the law’s requirements, in the regulator’s opinion. Considering our new President’s resolve to reduce costs through a leaner government structure. Should our regulators not also follow her example? I suggest that now is the time to pause and reevaluate the appropriateness of the FIMA to avoid overregulation and its consequences, as the BON Governor cautioned. |
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| COMPLIMENT | ||||
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Compliment from a principal officer
Dated 1 April 2025 |
“Hi Jolene Thank you for your prompt response. I truly appreciate it. The new benefits statement looks fantastic! The design and overall presentation are impressive, making it visually appealing and user-friendly. Kudos to the development team for their excellent work creating such a well-structured and professional statement. Looking forward to its implementation. Kind regards.” |
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Read more comments from our clients, here...
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| BENCHMARK: A NOTE FROM GÜNTER PFEIFER | ||||
| Circulars issued by the Fund | ||||
The Benchmark Retirement Fund did not issue any new circular or announcement after -
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| NEWS FROM RFS | ||||
| RFS celebrates 35 years of Namibian independence | ||||
| On the occasion of Namibia's 35th-anniversary celebrations, staff dressed beautifully in their traditional attire. | ||||
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| RFS shares views on financial services sector with Forbes Africa | ||||
| RFS MD Marthinuz Fabianus had an exclusive interview with Forbes Africa. He discussed RFS’ strategic vision for Namibia's financial services sector, pension fund opportunities, and its commitment to driving economic growth as Namibia celebrates 35 years of independence. RFS Fund Administrators were grateful for the opportunity to share insights highlighting the critical role of financial services in Namibia’s development. | ||||
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| RFS sponsors the SKW soccer tournament | ||||
| RFS has been a main sponsor of the SKW youth soccer tournament since 2000, continuing its 15-year tradition of supporting Namibian youth football with a generous sponsorship for the tournament from 25-27 April 2025 on the SKW sports fields. This sponsorship demonstrates RFS’ long-standing commitment to developing young football talent in Namibia. With 65+ teams across U7-U15 categories, RFS is proud to help tomorrow’s stars showcase their skills! (photo attached) In the photo, director Kai Friedrich hands over the sponsorship to Leander Schatz of SKW to celebrate this enduring partnership. |
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| RFS sponsors Windhoek Karneval | ||||
| RFS has been a faithful sponsor of the Windhoek Karneval since 2004. This year, RFS sponsored KIKAWI, an event for our youth and school-going kids in the name of the Benchmark Retirement Fund. | ||||
 RFS director Kai Friedrich, leisurely dressed for this social event, collected the sponsor certificate and medal
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 The medal and certificate
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| RFS sponsors t-shirts for Holy Cross Convent | ||||
| Rauha Hangalo, senior manager of client services at RFS and parent of a Holy Cross Convent Pre-Primary School learner, arranged for RFS to sponsor T-shirts for Teachers and their Assistants at the Holy Cross Convent Pre-Primary School. “Thank you to RFS Fund Administrators for sponsoring our beautiful teacher and assistant’s t-shirts – we love it”, said Sanja Kritzinger, the pre-primary school’s HOD, in recognising RFS’ sponsorship. |
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 FLTR Maria Simunja (3rd), Rauha Hangalo (fifth), Sanja Kritzinger (HCC – sixth), Salomé Sloa (7th)
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| Holy Cross Convent pre-primary school teacher’s assistants | ||||
| RFS encourages complaints and fraud reporting | ||||
| NAMFISA assists the public in resolving complaints regarding non-banking financial institutions such as RFS, the Benchmark Retirement Fund or RFS Financial Advisers. However, it expects any complainant to have first unsuccessfully approached the relevant financial institutions regarding the complaint before it would assist. The RFS website was expanded recently to allow the public to lodge complaints. The RFS website also allows the public to confidentially alert an independent professional adviser about any suspected or committed fraud a person may become aware of regarding RFS, the Benchmark Retirement Fund or RFS Financial Advisers. The adviser will inform RFS management of the report without disclosing the reporting person's identity. |
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| Elevate your fund experience with EPIC | ||||
| Members of funds administered by RFS can now access EPIC, its member communication platform, if the trustees agree to make the platform available to members. Members can access benefits and investment values online from any place at any time. Members of the Benchmark Retirement Fund take note that they have similar functionality through Benefit Counsellor. We encourage our fund members to make the best use of these facilities. |
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| The RETIREMENT COMPASS | ||||
| RFS Fund Administrators sponsor this newsletter as part of their social responsibility and initiatives to support the retirement fund industry. It aims to provide members of funds managed by RFS Fund Administrators and other parties in their network with retirement funding and planning-related news and insights, presented understandably. This issue covers the following insightful articles:
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| Important circulars issued by RFS | ||||
RFS issued no new circular after the circular
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| NEWS FROM NAMFISA | ||||
| Notes of the Industry meeting of 27 March | ||||
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NAMFISA’s quarterly industry meeting took place at NIPAM on 27 March. For an early insight into the discussions, our Mrs Carmen Diehl provided the following notes of the meeting:
Download the NAMFISA presentation slides here...
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| LEGAL SNIPPETS | ||||
| Admissibility of affidavits as evidence in death benefit claims | ||||
| Under SA [and Namibian] law, an affidavit is a statement made under oath by an individual to a Commissioner of Oaths. While the person making the statement does so knowing that if it contains false information, they could face a jail sentence, this doesn’t necessarily mean that the affidavit is proof of the claims it contains. This means that trustees should be wary of simply accepting affidavits as substantial evidence to back a benefit claim. Section 37 requires the trustees to
Download the full article by Wahida Parker in Pensions World of June 2015 here… |
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| Death benefit payment: L Dickson v Netcare Pension Fund and another | ||||
| Introduction: The deceased nominated the complainant to receive 100% of the benefit. The deceased passed away on 21 June 2019, and the nomination form was completed in 2004. The fund allocated 100% of the benefit to the deceased’s mother. The complainant submitted that her grandparents raised the deceased from the age of four months, and for most of her life, she had an estranged relationship with her mother. The mother lived in the UK until her retirement and then relocated to South Africa, where she lives off her pension and rental income from her 5-bedroom house. The mother is 73 years old, resides on her own, and only has herself to fend for. From 1999 to 2008, the complainant and the deceased were in a romantic relationship and engaged. Despite the break-up, they maintained a close friendship and agreed to keep their nominations unchanged, as she did with her PPS policy. Further, this was the deceased’s wish. The complainant submitted that the board’s decision be revised to reflect a more equitable split between her and the deceased’s mother. According to the complainant, a fair and equitable award would be 50% each. The fund submitted that the board had to consider the deceased’s Nomination of Beneficiary Form completed in 2004, in which the complainant was nominated to receive 100% of the death benefit against the deceased’s addendum to her will in which she had nominated her mother to receive 100% of her death benefit in 2017. Further, since the deceased had not updated the said form, the board elected rather to allocate 100% of the death benefit to the deceased’s mother in line with the will and the submitted proof of financial dependency on the deceased. The Adjudicator held that:
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| SNIPPETS FOR THE PENSION FUND INDUSTRY | ||||
| Diversify or di-worse-ify: The fine balance between smart strategy and risky overload | ||||
| This article takes a sharp look at one of investing’s golden rules — diversification — and flips it on its head. While spreading your investments is key to managing risk, going overboard can backfire, leading to a bloated, underperforming portfolio that’s harder to manage and less effective. Charize Beukes of Brenthurst Wealth Management unpacks how trying to “own everything” can reduce returns and shares practical tips on finding the sweet spot between smart diversification and risky overload. The article also shares clear, actionable strategies to help you refine your portfolio and avoid common traps:
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| Diversifying your portfolio beyond forex | ||||
| This article raises the following key poiThis article highlights the risks of overtrading and over-diversifying in forex trading and emphasises the importance of strategic diversification. Roger Eskinazi, Managing Partner at Tickmill, shares insights on how diversifying a portfolio across asset classes, including stock indices, commodities, and bonds, can help mitigate risks and unlock new profit opportunities. By balancing different assets, traders can offset volatility, hedge against inflation, and preserve capital during economic downturns. The article also examines how instruments such as stock indices, commodities, and bonds can complement forex trading, providing stability and potential returns. If you're looking to refine your trading strategy and manage risk effectively, this article in Money Marketing of 3 April 2025 is a must-read... |
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| SNIPPETS OF GENERAL INTEREST | ||||
| Vishing: The Voice Scam You Need to Know About | ||||
| Vishing (voice phishing) is a fast-growing scam where cybercriminals call victims pretending to be from a trusted institution, like a bank, and pressure them into sharing sensitive information such as passwords or PINS. This tactic is increasingly sophisticated due to spoofing technology and the emotional urgency created over a call. Reports show a 442% increase in vishing attacks in late 2024 and a 1,265% rise in voice-based scams since the launch of AI tools like Chatgpt. Steps to Avoid Being Vished
Read the full article in Cover of 7 April 2025, here... |
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| Investing offshore: A brief guide. | ||||
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With South Africa’s economic challenges and low GDP growth, more investors are looking beyond local borders for better returns. But how exactly can they do this? Investing offshore is simpler than many think, especially when aiming for hard currencies like the US dollar, euro, or pound.
One of the key hurdles is transferring money abroad, but South African citizens can easily take out up to R1 million per year (R2 million for couples) using their Single Discretionary Allowance. A tax clearance certificate is required for larger amounts, though this process has become more complicated. Despite these hurdles, the reward is worth it — investing offshore provides access to global markets and assets, potentially protecting against local economic risks. Offshore investments come in various forms, from flexible discretionary investments to endowments offering tax benefits and estate planning advantages. These investments allow exposure to diverse global sectors like healthcare and technology. Fixed investments provide a safer option with some capital assurance, while asset swaps and feeder funds allow offshore exposure through local funds. Opening an offshore bank account might also be beneficial for those serious about maximising their offshore investments. Given the complexities, seeking advice from a qualified professional is always recommended to ensure the best strategy is in place. Read the article by Magnus Haystek in Moneyweb of 26 March here... |
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| Essentials of a power of attorney | ||||
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Granting someone the authority to manage your financial affairs is a significant decision that requires careful consideration. A Power of Attorney (POA) allows an agent to act on your behalf, whether due to illness, travel, or other circumstances. But with this responsibility comes risks, so understanding the rights, responsibilities, and potential pitfalls is crucial.
Broadly speaking, a power of attorney is a written declaration by one person (the principal) to bestow powers on another person (the agent) to perform juristic acts (i.e. actions that are intended and capable of having a legal effect) on their behalf. A power of attorney is not a contract but, rather, is made possible in terms of the South African [and Namibian] law of agency – the basis of which is that an agent is not permitted to perform any juristic act that the principal is incapable of performing. A POA can be general, giving the agent broad authority, or special, with more limited powers for specific tasks like managing tax affairs. However, in South Africa, the process isn’t straightforward. There’s no standard form; certain situations, like property purchases or banking, have specific requirements. For those with elderly parents or individuals losing mental capacity, managing finances becomes even more challenging. While a POA can provide assistance, it automatically terminates if the principal becomes mentally incapacitated or passes away, potentially complicating matters. The document must be carefully drafted to ensure it’s legally valid, and professional guidance is recommended to protect all parties involved. Whether managing a loved one’s affairs or considering a POA for your own reasons, it’s essential to know the risks and ensure all legal steps are followed. Read the article by Eric Jordaan of Crue Investments in Moneyweb of 26 March here... |
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| AND FINALLY... | ||||
| Wise words from wise men | ||||
| "The Budget should be balanced, the Treasury should be refilled, public debt should be reduced, the arrogance of officialdom should be tempered and controlled, and the assistance to foreign lands should be curtailed, lest Rome becomes bankrupt. People must again learn to work instead of living on public assistance." ~ Cicero (106-43 B.C.) |
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| Unsubscribe If you do not want to receive these newsletters {unsubscribe}click here...{/unsubscribe} Disclaimer Whilst we have taken all reasonable measures to ensure that the results reflected herein are correct, Benchmark Retirement Fund and RFS Fund Administrators (Pty) Ltd do not accept any liability for the accuracy of the information and no decision should be taken on the basis of the information contained herein before confirming the detail with the relevant portfolio manager. |
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