New legislation, familiar values—and a good reason to take a closer look at how we work.

I’m not sure about you, but when a topic has been buzzing around the insurance industry for years, it is easy to recognise the acronym without feeling entirely confident about what sits behind it.

COFI has been one of those topics for me. It keeps appearing in industry discussions, presentations and inboxes, usually somewhere between an urgent client request and a cup of coffee that never quite gets finished.

So, I decided it was time to get properly informed. What does COFI mean for me as a broker? What should my team understand? And, most importantly, what does it mean for the clients who trust us to look after their insurance needs?

This is where I truly appreciate the insurance organisations in South Africa and the work they do to help us make sense of change. The recent Insurance Institute of Gauteng (IIG) webinar on COFI, presented by Danny Joffe, helped me connect the dots.

To Danny and the IIG team: a big thank you. Making legislation understandable while keeping people interested is a skill in its own right!

Here is how I understand the main themes, and what they mean for our business.

1. A more joined-up approach

COFI stands for Conduct of Financial Institutions. The Bill aims to bring financial institutions’ conduct requirements into a more consistent, consolidated framework.

In everyday language, it is about how financial businesses behave, how they serve their clients and how they can be held accountable for that service. It brings together conduct requirements spread across different laws; it does not mean every financial law disappears into one enormous document. Source: Government’s explanatory summary.

For me, the purpose is easier to understand when I bring it back to the client: fair treatment should be a consistent experience.

2. Licensing belongs on my preparation list

The proposed framework also changes the approach to licensing, linking authorisations to the financial activities a business performs.

While this is often described as “re-licensing”, the published proposals envisage a transition involving the conversion of existing licences into the new framework. The final requirements, timing and regulatory guidance will matter, so I am treating this as something to prepare for as implementation arrangements become clear. Source: National Treasury’s COFI policy paper.

My practical takeaway? Understand what our business does, make sure our records reflect it, and keep informed about the transition. This deserves a place on the preparation list well before it becomes an urgent diary reminder.

3. Start with the client’s outcome and work backwards

The strongest message for me is COFI’s focus on outcomes.

Treating Customers Fairly, or TCF, already plays an important role in our industry. COFI’s proposed approach would embed fair customer outcomes more consistently across the financial sector. Source: FSCA Regulatory Strategy 2025–2028.

For our team, that means asking: What does the client actually experience as a result of what we do?

We may have sent the document, but was the explanation clear? We may have followed the process, but did we address the client’s needs? We may have disclosed an exclusion, but did we help the client understand why it matters?

An email marked “sent” is useful evidence. It cannot, on its own, tell us whether the person reading it understood their cover.

My approach is to start with the fair outcome we want the client to experience, then work backwards to review the advice, communication, procedures and support needed to achieve it.

4. Governance is the thread running through it all

Good intentions need a reliable way of becoming everyday practice.

That is how I think about governance: clear responsibilities, appropriate oversight, useful records and a way to identify and fix things when they go wrong.

Who checks that a process works? Who takes responsibility when it does not? What do complaints tell us? Are recurring problems leading to improvements?

For me, governance must run through the business. A beautifully filed policy needs to earn its keep outside the folder.

5. Culture sets the standard

Culture is how our values show up on a busy Tuesday afternoon.

It is the decision to explain something again when a client is unsure. It is a team member feeling comfortable raising a concern. It is taking a complaint seriously and being willing to change a process that causes unnecessary frustration.

The FSCA’s existing TCF framework already places fair treatment at the centre of business culture. It also covers clear information, suitable advice, expected service and avoiding unreasonable barriers when clients claim, complain or change providers. Source: FSCA’s TCF outcomes.

That gives us a useful lens for reviewing every point where a client encounters our business.

Looking through the client’s lens at TI Brokers

For my team and I, readiness begins with looking closely at our customer interface. This is a formal term for all the ways clients encounter and interact with us.

How do we promote and market our services? What do we disclose, and how clearly? How do we recommend and arrange cover? What advice do we give? What happens when a client needs help, has a claim or wants to complain?

The question running through each of these is:

Does this help us deliver a fair outcome for the client, and how do we know?

At TI Brokers, I want that question to become part of how we review every element of our business. Preparing early gives us time to involve the team, identify gaps and make thoughtful improvements as the requirements develop.

There will still be details to work through. But the part I can play now is clear: keep learning, prepare our business and make sure our processes support the people who rely on us.

And perhaps, somewhere along the way, finish that cup of coffee.