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| Issued November 2025 | |||||||||||||||||||||||||||||||||||||
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| In this newsletter... | |||||||||||||||||||||||||||||||||||||
| Benchtest 10.2025 – FIMA restarted, pensions and housing, digital signatures and more... | |||||||||||||||||||||||||||||||||||||
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| IMPORTANT NOTES AND REMINDERS | |||||||||||||||||||||||||||||||||||||
NAMFISA levies
The interest rate on direct housing loans remained unchanged at 9% in November. The minimum repayment amounts will also remain unchanged for December 2025. |
Registered service providers Certain pension fund service providers must register with NAMFISA and submit regular reports to the authority. Download a list of service providers registered as of August 2025, here... Retirement calculator Use our web-based retirement and risk shortfall calculator for your 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 the 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 October 2025 |
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| In October 2025, the average prudential balanced portfolio returned 2.4% (September 2025: 2.7%). The top performer is the Stanlib Namibia Managed Fund 3.1%. The Allan Gray Namibia Balanced Fund, with 1.8%, takes the bottom spot. Ninety One Namibia Managed Fund takes the top spot for the three months, outperforming the ‘average’ by roughly 0.8%. The Lebela Balanced Fund underperformed the ‘average’ by 0.9% 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 October 2025 reviews portfolio performances and provides insightful portfolio analyses. Download it here... |
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| Where Local Investors Find Value | |||||||||||||||||||||||||||||||||||||
Investors continue to navigate a highly polarised global equity environment where valuations vary dramatically across regions. An updated analysis of trailing price-to-earnings (P/E) ratios as at October 2025 (or nearest available) reveals significant disparities between major markets — the S&P 500 (USA), JSE (South Africa), DAX (Germany), and Nikkei 225 (Japan).
Read paragraph 6 of the Monthly Review of Portfolio Performance to 31 October 2025 for an interesting perspective on global equity sectors. 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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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 an effective date. In the last several newsletters and the next few issues, we have presented and will continue to provide a brief overview of the latest status on standards and regulations.
This summarises the main provisions of draft standards and regulations under the FIM Act and implications for retirement funds. Standards Chapter 10: General GEN.S.10.4 General notification for appointment and termination of valuators This Standard applies to ‒
Summary:
What to do:
GEN.S.10.5 General notification for appointment and termination of principal officers
This Standard applies to financial institutions and financial intermediaries. Summary:
What to do:
GEN.S.10.8 Independence
This Standard applies to any person who is required under the Act to be independent, including, without limitation, directors, members of a board, principal officers, trustees, custodians, auditors and valuators. Summary:
What to do:
Housing Finance Through Pensions
by Vincent Shimutwikeni, B. Juris, LLB (honours), CGRC-BP™, Manager: Legal Support This article explores the growing role of pension-backed housing finance in Namibia, following the Minister of Finance’s decision to reduce the minimum interest rate on housing loans from pension funds, from repo + 4% to repo + 2.5%, effective 1 July 2025. This policy change has revived national debate and renewed government and industry interest in making home ownership more accessible through retirement savings.
Readers will find a clear and practical explanation of the two main ways pension funds can assist members with housing:
The article breaks down the legal framework under Sections 19(5) and 37D of the Pension Funds Act, explains eligibility limits (usually one-third of a member’s benefit), and discusses how repayments, defaults, and safeguards work in practice.
It also provides perspectives for all stakeholders:
In short, the article offers a comprehensive yet practical guide to understanding how pension savings can be responsibly leveraged for housing — a topic of growing importance for both public and private sector funds.
Bringing Clarity to Pension Fund Reporting Requirements
Why Regulation 6 — not outdated statutory references — should guide financial statement disclosure.
As practitioners in the pension fund industry, we often encounter uncertainty about which financial statements stakeholders are entitled to access. Sections 15 and 22 of the Pension Funds Act, 1956, are frequently cited as the source of these obligations — yet their context has shifted over time. Section 15 requires every registered fund to submit audited financial statements within six months of the year-end, while section 22, read with section 35, grants the right to inspect or obtain copies of certain documents. However, section 35 reflects a reporting model conceived nearly seventy years ago. Its references to “documents” have since been overtaken by Regulation 6, which modernised and consolidated all reporting and disclosure requirements. Regulation 6 provides that: “Every registered fund shall, within six months of the end of its financial year, submit to the Registrar such annual financial statements, statistical returns, and reports as the Registrar may require.” This regulation gives NAMFISA the authority to prescribe the scope and format of financial information in line with contemporary accounting standards. The statements referred to in section 35, which may be inspected or copies obtained, no longer exist by the name given by section 35. Occasional reliance on the older provisions when stakeholders request access to financial statements has caused avoidable uncertainty. The audited, IFRS-compliant statements submitted annually under Regulation 6 are the definitive financial reports of each fund — and the documents stakeholders may legitimately expect to obtain. Recognising this alignment avoids unnecessary administrative friction and ensures consistency between funds and the regulator. We believe that applying Regulation 6 as the operative rule promotes transparency, efficiency, and confidence in Namibia’s retirement-fund system. NAMFISA’s ongoing reforms already reflect a commitment to modern, principles-based supervision. Clear acknowledgement that Regulation 6 governs fund reporting would reinforce that commitment — ensuring the regulatory framework functions as intended: to support sound governance, informed stakeholders, and trust in the integrity of the system. |
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| COMPLIMENT | |||||||||||||||||||||||||||||||||||||
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Compliment from a retiree Dated August 2025 |
“Dear Dennis, I hope this message finds you well. I've been adjusting to the new adventure known as retirement—contrary to popular belief, free time seems to be in short supply! But I didn’t write to share tales from the retired life. I wanted to extend my heartfelt thanks for your assistance with my pension. Your support has been truly appreciated, and it’s been a pleasure working with you. Once again, thank you. NN !Gaoseb.” |
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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 issued no new circular after:
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| NEWS FROM RFS | |||||||||||||||||||||||||||||||||||||
| Long Service Awards | |||||||||||||||||||||||||||||||||||||
| RFS places a high value on its employees and recognises the importance of their contributions to the company’s success. In addition to recognising employees’ contributions, long service awards can be a powerful retention tool, demonstrating that the company values and appreciates its employees’ dedication and hard work. These awards foster a positive and motivating work environment, where employees feel supported and encouraged to grow and develop within the company. In November, RFS recognises the following anniversary:
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| RFS Year-End Function in Pictures | |||||||||||||||||||||||||||||||||||||
| FS’s 2025 social committee laid on an utterly enjoyable year-end function at the Kubata restaurant on 1 November. Here are a few pictures capturing the spirit of the night. |
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Staff Walk for Good Making strides in the fight against cancer! Team RFS proudly participated in the Walk for Good in support of the Cancer Association of Namibia. We stand with all those affected by cancer and remain committed to supporting organisations that provide vital care, research, and hope to our community.
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| Staff improving their competencies |
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RFS prioritises the ongoing education and professional development of its staff. As Nelson Mandela once said, “education is the greatest equaliser,” and by investing in the education and training of its employees, RFS is helping to create a more skilled and knowledgeable workforce.
By supporting its staff in their pursuit of further education, RFS is also investing in the long-term success of its business. As staff members become more skilled and knowledgeable, they are better equipped to provide high-quality service to clients and to help the company stay competitive in a rapidly changing market. We heartily congratulate Annemarie Nel on passing the Financial Planning Institute of Southern Africa board exam with distinction to earn the designation of Certified Financial Planner®! We wish her continued success. Let this be another milestone on the road to greater heights! 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 their benefits and investment values online from anywhere 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
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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.
The latest issue covers the following insightful articles:
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| Important circulars issued by RFS | |||||||||||||||||||||||||||||||||||||
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RFS issued the following new circular:
Clients are welcome to contact us if they require a copy of any circular.
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| NEWS FROM NAMFISA | |||||||||||||||||||||||||||||||||||||
| CONSUMER CREDIT BILL STATUS UPDATE
NAMFISA recently provided an update on the status of the Consumer Credit Bill.
It conducted public consultation on the Bill during 2023. The feedback on comments received during the public consultation can be found here. RFS proposed that direct housing loans provided by retirement funds be excluded from the Consumer Credit Bill. NAMFISA’s response to our proposal can be found on page 46 of the Summary of comments document. NAMFISA incorporated our proposal by excluding direct housing loans between a retirement fund and a member of that fund from the scope of “credit agreements” as per section 4(6)(d) of the Bill. Here is the latest version of the Consumer Credit Bill, and incorporates some of the comments received from the public in the consultation process. NAMFISA Notifies the Implementation of the FIMA
In a public notice of 13 November 2025, NAMFISA gives notice that –
This notice comes as a surprise (and disappointment) to the pensions industry, which was busy preparing for a meeting with the Minister of Finance, scheduled for Monday, 17 November 2025, to share its remaining concerns regarding the FIMA, as directed by the President.
Cybersecurity Risk Governance
Following NAMFISA’s engagement with Trustees, Principal Officers, pension fund officers, and service providers of registered pension fund organisations on Cybersecurity Risk Governance aimed at highlighting the critical role that trustees play in managing cybersecurity risks, in line with their fiduciary duties under the Pension Funds Act, 1956 (Act No. 24 of 1956), as well as sound corporate governance and effective risk management practices, it circulated the presentations given at this occasion.
Find the presentations here. |
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| LEGAL SNIPPETS | |||||||||||||||||||||||||||||||||||||
| The Legal Position on E-signatures in Namibia Contributed by Vincent Shimutwikeni, B. Juris, LLB (honours), CGRC-BP™, Manager: Legal Support |
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Namibia’s Electronic Transactions Act, 2019 (Act No. 4 of 2019) provides a comprehensive legal framework for the use of electronic signatures. Under this Act, e-signatures are legally recognised and have the same legal effect as handwritten signatures, subject to certain conditions. This means that, from a legal standpoint, parties may rely on electronic signatures for the execution of documents, including beneficiary nomination forms.
It is important to note that, although the Act is largely in force, Sections 20 and Chapters 4 and 5, which relate to consumer protection, electronic authentication, accreditation of service providers, and certification services, have not yet commenced. This is confirmed in Government Notice No. 364 of 29 November 2019, which brought the remainder of the Act into operation on that date, with the stated exclusions. These remaining provisions are expected to be brought into effect as part of the planned national rollout of accredited electronic signature infrastructure in February 2026, which will be overseen by the Communications Regulatory Authority of Namibia (CRAN). Until that time, Namibia does not yet have an official system of accredited e-signature service providers. Nevertheless, the current law does not prohibit the use of electronic signatures, and they remain legally valid and enforceable, provided the method used -
Based on the current legal framework and the provisions of the Electronic Transactions Act, and subject to complying with the above three bullets, there is no legal impediment to accepting electronic signatures for beneficiary nomination forms and any other forms relating to pension fund administration that require a member, the fund, or an employer to sign.
Section 37A Award and Late Payment Interest
1. Section 37A background The PFA section 37A(1) provides that: “No benefit provided for in the rules of a registered fund… shall… be capable of being reduced, transferred, ceded, pledged, hypothecated, or be liable to be attached or subjected to any form of execution under a judgment or order of a court of law…” However, Section 37D allows limited exceptions — such as deductions for housing loans, maintenance orders, or damages to the employer. When a court judgment is validly obtained and recognised under 37D, the fund may pay over the amount to satisfy that judgment from the member’s benefit. 2. Example
The question is whether that judgment automatically extends to or includes the R100,000 late payment interest.
3. Key legal distinction:
The answer hinges on whether the late payment interest forms part of the member’s “benefit” under the fund’s rules or is a discretionary ex gratia payment. (a) If the late payment interest is provided for under the rules If the fund’s rules require that interest be paid when a benefit is delayed (i.e., it is a contractual component of the benefit), then the R100,000 becomes part of the member’s “benefit” in terms of Section 37A.
If the interest is not provided for in the rules but instead is a discretionary compensation for delayed payment (an act of good faith by the trustees), it’s not part of the “benefit” as defined in Section 1 and Section 37A.
4. Timing and scope of the court order
A court order or writ of execution applies to the benefit as at the time it accrues to the member (i.e., when payable under the rules). Suppose interest accrues after the judgment and by virtue of the fund’s own action, not the court’s. In that case, it’s not a given that the judgment extends to that incremental amount unless the order explicitly includes “any subsequent amounts or interest accrued on the benefit.” Thus:
5. Summary Table
6. Practical implications for funds Funds should:
In short
It is not a given that a court’s judgment against a member’s benefit automatically includes late payment interest.
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| SNIPPETS FOR THE PENSION FUND INDUSTRY | |||||||||||||||||||||||||||||||||||||
| The Hidden Challenge of Retirement: A Psychological Shift Few Anticipate |
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Retirement is often celebrated as a time of freedom, but for many, it ushers in an unexpected challenge: the loss of identity and purpose. While financial readiness dominates most retirement planning discussions, the psychological transformation that follows the end of one’s career is often overlooked — and it can quietly undermine even the best-funded retirement plan.
From Role to Reinvention For decades, careers have defined who we are — doctor, manager, teacher, or entrepreneur. When the title disappears, so does much of the validation that came with it. Many retirees ask, “Who am I now?” Without actively redefining purpose, even financially secure individuals can feel unfulfilled or invisible. From Structure to Uncertainty Freedom from schedules and meetings may sound appealing, but a lack of structure can breed restlessness. Purposeful retirees create new routines, pursue growth, and engage meaningfully — not to fill time, but to restore direction. From Earning to Spending Switching from accumulating savings to drawing them down is another major adjustment. Even the wealthy experience the anxiety of “What if I run out?” A sound retirement strategy must therefore deliver both financial security and emotional peace of mind. From Responsibility to Legacy Work gives structure; retirement offers legacy. The most fulfilled retirees focus on values, mentorship, and impact — creating meaning beyond money and leaving a purposeful footprint for the next generation. Preparing for the Emotional Transition Acknowledge that retirement involves loss and change. Beyond financial projections, plan how you’ll spend your days, build support networks, and pursue purpose. True retirement readiness integrates emotional well-being with financial sustainability. Retirement is not the end of work — it’s the beginning of renewal. Read the full article by Hardi Swart in Moneyweb of 5 September 2025 here. |
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| Retirement Funds vs Property | |||||||||||||||||||||||||||||||||||||
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For decades, South Africans viewed property ownership as the ultimate mark of success. Yet, in today’s volatile economy of fluctuating interest rates and unpredictable markets, the old wisdom of “bricks over bonds” is being re-examined. The modern investor’s question is no longer either/or — it’s how to use both property and retirement funds to build sustainable long-term wealth.
The power of retirement funds Retirement funds remain one of the most tax-efficient and reliable tools for retirement planning. Contributions are tax-deductible (up to 27.5% of taxable income or R350 000 per year), while investment growth within the fund is free from income, dividend, and capital gains tax. Additional benefits include:
Property remains attractive for investors seeking tangible assets and potential rental income. Properly managed properties can appreciate and provide lasting wealth. Key advantages include:
Comparative insights
Bottom line There’s no single “winner.” Both retirement funds and property can play important roles in a balanced financial plan. Retirement funds offer structure, discipline, and tax efficiency, while property provides tangible value and potential income diversification. The most successful retirees share a common formula: start early, stay consistent, and seek professional advice. The era of relying on one asset class is over — long-term financial security is built through diversification, patience, and sound planning. Read the full article by Zander Loots in Moneyweb of 21 October 2025 here. |
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| SNIPPETS OF GENERAL INTEREST | |||||||||||||||||||||||||||||||||||||
| How to Turn Employee Surveys Into Engines of Organisational Growth |
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In this insightful piece, Chaze Nalisa-Jagger explores how employee surveys can evolve from simple diagnostic tools into catalysts for genuine organisational transformation. While some argue that surveys are outdated in an age of real-time feedback, the author contends that their true value lies in how organisations use the insights they generate. The problem is not the survey itself, but the failure to turn feedback into visible, lasting action.
The article outlines a practical framework for three critical stages of the survey cycle:
Ultimately, the article’s message is clear: never diagnose without the will to act. When feedback is met with transparency, humility, and consistent follow-through, trust deepens, engagement rises, and surveys evolve from periodic exercises into continuous instruments of progress. If your organisation values feedback-driven improvement, this article offers practical guidance on transforming employee voice into sustained organisational impact. Read ‘Beyond Diagnosis – Turning Insight into Lasting Progress’ by Chaze Nalisa-Jagger in The Brief of 27 October here. |
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| A List of Financial Things to Do in Your 40s | |||||||||||||||||||||||||||||||||||||
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Your 40s mark a turning point, typically your peak earning years and the most crucial decade for shaping long-term financial freedom. The choices you make now will determine how comfortably you live in your 50s and beyond.
1. Tackle debt strategically Shift focus from building debt to eliminating it. Distinguish between good debt (like a low-interest mortgage) and bad debt (credit cards, personal loans). Use the debt avalanche method to pay off high-interest accounts first, and consider making one extra mortgage payment each year to save on interest and shorten your loan term. 2. Supercharge retirement savings This is your last major window to build retirement wealth. Increase your contributions to at least 15–20% of pre-tax income and review your investment mix to balance growth with risk protection. Those approaching 50 should plan for catch-up contributions. 3. Balance education and retirement goals If you’re funding children’s studies, use tax-efficient education savings vehicles, but remember: you can borrow for college, not for retirement. Discuss realistic expectations with your family about costs and contributions. 4. Update your estate plan If you don’t yet have a will, draft one now and name guardians for minor children. Review beneficiary nominations on policies and pensions, and set up powers of attorney for financial and medical decisions to ensure your wishes are respected. 5. Protect what you’ve built Revisit insurance policies to confirm they cover mortgage, living costs, and dependants’ needs. Maintain adequate income protection and critical illness cover, and ensure home and vehicle insurance keep pace with inflation. Your 40s are your decade of decision, a time to consolidate, plan, and protect. Sound advice from a qualified financial planner can help align today’s choices with tomorrow’s security. Read the full article by Hendri de Klerk in Moneyweb of 14 October 2015 here. |
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| AND FINALLY... | |||||||||||||||||||||||||||||||||||||
| Wise words from wise men | |||||||||||||||||||||||||||||||||||||
| "Talent hits a target no one else can hit; genius hits a target no one else can see.” Arthur Schopenhauer (1788 - 1860) | |||||||||||||||||||||||||||||||||||||
| 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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