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FSCA Leadership Profile – Deputy Commissioner: Farzana Badat
 

The FSCA’s Executive Committee comprises of the Commissioner and three Deputy Commissioners. It is responsible for general oversight of the management and administration of the organisation to ensure that it is efficient and effective throughout strategic and operational matters. Over the next few issues, we will be profiling the FSCA leadership as individuals and pick their brains on different regulatory matters.

 
 
 
 
Outside the FSCA, and your professional life, how would you describe yourself?
 


By Boitumelo Manganyi – Communication and Language Services Department

 

Gosh, for me this is probably the most difficult question to be asked. As an extreme introvert and painfully private person, a question as seemingly harmless as “tell us about yourself” immediately invokes anxiety and my mind goes uncomfortably (and unusually) blank. And maybe that’s the first thing to know about me, I can sometimes be a bit too honest, even if it appears to be against my own interests😊. 

 

So, I am going to draw on some outside help to try and get the ball rolling with this answer: I am a fan of late-night comedians, but only a select few with razor-sharp wit and astute social and political commentary, cloaked in ridiculous humour. I find they help soften the relentless intensity and seriousness of the daily news cycle, ever so slightly. One such gifted entertainer that I turn to for help in answering this question is Stephen Colbert, host of The Late Show with Stephen Colbert. He often jokes that his team has come up with a scientifically researched set of questions that covers the full spectrum of the human experience, guaranteed to make the person answering those questions “fully known” to an audience. So  here it goes …

 

 What is the best sandwich? 

Toasted tuna and mayo with cheese and freshly chopped green chilies, made in a griddle pan! 

 

What is the one thing you own that you really should throw out? 

Endless stacks of empty shopping bags. No idea why I hold on to them. I have a cupboard full.

 

What is the scariest animal? 

Snakes (eeek!!) Shudder … 

 

Apples or oranges? 

Apples. How else do you keep the doctor away? 

 

Have you ever asked someone for their autograph?

 Yes. A bunch of football and cricket players in the 90’s and early 2000’s. I may have been a bit of a groupie! Also, Nelson Mandela and Bono (on the same day!). 

 

What do you think happens when we die?

 I believe in life after death. We return to the Creator to begin our eternal lives. 

 

Favourite action movie?

 Can I choose two? Each groundbreaking in its own way … Die Hard & Terminator 2: Judgment Day. They definitely don’t make them like they used to. 

 

Favourite smell? 

The unmistakable scent of a favourite person. 

 

Least favourite smell? 

Bad breath and stinky feet. 

 

Exercise: worth it? 

Definitely. But easier said than done. 

 

Window or aisle? 

Before Covid – I would have chosen window always. Post-Covid – aisle please! 

 

Cats or dogs? Both! 

Cats are more relatable to me in personality 😊 But, dogs are just pure bundles of joy and warmth, especially puppies. 

 

Still or sparkling? 

Sparkling for sure. It is a running joke in my family that I can’t leave the house without a bottle of sparkling water in hand, like a security blanket. 

 

Most used app on your phone? 

Prayer app. 

 

You get one song to listen to for the rest of your life: what is it? 

November Rain (by Guns ‘n Roses) Describe the rest of your life in 5 words? No idea. But … that’s ok!

 
 
What inspired you to pursue a career in financial regulation?
 

I think I was unexpectedly guided towards this career rather than inspired by it. And I continue to be grateful for the incredible faith of those who played important roles in helping me learn and grow and providing the opportunities that have led me to this path. 

 

 If you had asked me as a 20-year-old law student if this is where I would find myself over two decades later, the answer would have been no. During law school I discovered an affinity for human rights law, social justice and teaching. So that was how my career began: I spent a few years as a law lecturer; had the most amazing opportunity to work at the Constitutional Court; and I was blessed with a scholarship to study comparative human rights and international law abroad. I even wrote a passionate letter to the United Nations International Criminal Court convincing them why they should hire me, explaining that my future aspirations lay in “dismantling oppressive global regimes and bringing brutal dictators to justice”. 

 

I never sent the letter. In fact, I still have it. Despite my youthful idealism and fervent convictions, the unpredictability of life and increasing responsibilities led me to a more pragmatic and stable professional path. Joining a multi-national, diverse corporation like KPMG turned out to be such a formative learning experience. It helped me gain a more balanced world view of the practical realities of business, economic and social drivers beyond the theoretical abstracts of policy making, legal drafting and academia. During my time there I was exposed to multiple industries including financial services, telecommunications, health, mining, technology and the public sector. KPMG also invested generously in strategic leadership and development programmes, which contributed greatly to my accelerated professional growth in the years to come. While at KPMG I was involved in many audit and secondment projects at the major banks, several insurers and investment companies. The financial sector was growing and innovating at a rapid pace, while simultaneously experiencing an onslaught of regulatory reform in the aftermath of the Global Financial Crisis. 

 

This called for different and harmonized skill sets and innovative ideas to help financial institutions realise their enormous growth potential and expand services to the broader South African public in a responsible and inclusive manner while carefully navigating the regulatory landscape. It was also around this time that the Treating Customers Fairly (TCF) principles were introduced globally and locally, a perfect opportunity (and challenge) for me to join a major insurance company that was looking to establish a Regulatory Risk and Compliance Function from scratch. That is how I ended up at Old Mutual and had my first direct interaction with the regulator as a supervised entity. It was quite an eye-opening experience. On my first day at the insurer, I arrived ready to ease myself into the new environment, only to discover that the Financial Services Board’s (FSB) supervisory team was also going to be there that week for a full on-site visit. 

 

That is what you call trial by fire for a newly appointed Head of Regulatory Risk! Thankfully, that experience crystalized the foundation of what has now become a deeply meaningful, rewarding and ever fascinating career in financial sector regulation. Fast forward to 2014 when I was offered the opportunity to move over from the “dark side” to join the FSB in a role that would help reimagine and reframe conduct supervision and financial consumer protection in the country. It was another unexpected opportunity, but the most transformational professional and personal decision I have ever made. The rest, as they say, is recent history …

 

 
Amongst the FSCA values, which one resonates with you the most, and how does that value help you in your role as a Deputy Commissioner?
 

Integrity and Accountability. A key component of integrity is ensuring authenticity in all we say and do. This means our actions should be consistent with our words, we should follow through consistently on our commitments and be open and transparent in our decisions. 

 

Accountability is inextricably linked to this. It requires us to take responsibility for the consequences of what we say and do – to give credit where it’s due, have the courage to own up when we falter, not blame others for our missteps, and constantly reflect on how we can do things better in the future. 

 

These values are important because as leaders we lend our credibility to the organizations we lead. If we are not seen as credible, reliable, honest or fair, we will face an impossible task when executing our mandate due to a lack of trust from those we seek to influence. As a member of the EXCO, if I fail to demonstrate credibility both with external stakeholders as well as internally, then I am failing the organisation as a whole.

 
 
How would you describe your management style and how do you think this elevates the divisions that you are responsible for?
 

I will talk about leadership rather than management, as there are important distinctions in the outcomes expected of managers versus leaders. Leadership, which focuses on harmonizing a future vision is what I believe the organisation needs, and what our people should collectively aspire to for the FSCA to truly evolve into the world-class regulator we have the potential to be. Every single person in the organisation has a role to play in helping unlock this potential. So, for me, a crucial component of effective leadership is to guide teams and individuals on a path to understand and execute this vision. 

 

Leadership is not an entitlement. It is not about having the loudest voice. And it is not an indicator that one is infallible or always in possession of the right answers. Rather, it is a responsibility that is entrusted to someone to bring different people and perspectives together in service of a common goal. In my experience, the most effective leaders are those who lead quietly and reflectively, who guide, shape and influence, rather than dominate, direct and impose, while giving those around them the room and opportunity to learn, grow and thrive. They elevate their teams by empowering those who do have the skills, talent and experience to provide the right answers, especially those who sometimes lack the confidence or are reluctant to speak up for themselves. 

 

My leadership style is probably more adaptive or situational in that I try to adapt my approach and expectations to the uniqueness of a particular situation, the needs of the specific team and the level of urgency required to act at a given point in time. I try to gather as much information as I can, evaluate the circumstances and individuals affected, and then work with them to create an action plan appropriate for the situation. I am also always scenario-planning in my head to ensure that if Plan A or Plan B don’t work, we are able to nimbly pivot in how we respond to changing circumstances. It sounds exhausting, but I believe strongly that having a good sense of the big picture and potential challenges upfront goes a long way in helping overcome operational obstacles along the way. 

 

During this time of transition when Divisions are still in the early stages of bedding down what the FSCA’s overall strategy means for them individually, it is important for me to be flexible in my approach so that the respective teams feel safe, protected and heard as they navigate this change. My key priority right now is to help ensure that the teams are aligned both internally within their divisions and across other FSCA divisions on how to collectively execute on the organisational strategy. Teams can only be elevated if they feel that they are truly part of the organisation’s strategic vision and have a clear understanding of their roles. 

 

One of my favourite quotes on leadership, which resonated with me very early in my career is from Chinese philosopher Lao Tzu: A leader is best when people barely know s/he exists, when his/her work is done, his/her aim fulfilled, the people will say: we did it ourselves.

 
 
What are your thoughts on the general conduct of financial institutions and how do you plan to contribute to ensuring the institutions abide by the sector laws?
 

I think it is difficult to paint the entire financial sector with a single brush or “general” view in respect of their I think it is difficult to paint the entire financial sector with a single brush or “general” view in respect of their conduct or treatment of financial customers. The sector is vibrant and diverse and has a range of institutions and industries that are at varying stages of maturity when it comes to understanding and harmonizing what “good conduct” means. 

 

There are certainly parts of the sector with whom we have travelled a long journey from the early days of TCF as the former FSB, who have demonstrated that they are truly customer centric. These are the institutions whose Boards and senior management set the cultural tone from the top by integrating issues around conduct and customer fairness in their ongoing strategic decisions. They are open and transparent in their engagements with us and approach us proactively to understand our expectations. Sadly, this is not consistent across the sector. Too many institutions still approach conduct as a compliance or checklist exercise or view the regulator as an adversary or barrier to business rather than as an enabler for improved market outcomes which would be beneficial for institutions and customers alike. 

 

 There are a number of things that I intend focusing on to help financial institutions be more consistent in embedding good conduct and treating customers fairly. Firstly, I would like to spend more time engaging with the key decision makers and senior leadership of financial institutions to clarify our expectations, demonstrate that we understand their businesses, and be firm in holding them accountable for how their customers are treated on the ground. Secondly, I want to work more closely with the licensing and supervision teams to help entrench a more harmonized, intelligence-led risk based supervisory approach that focuses on the key drivers of decision making and behaviours within financial institutions so that we can flag potential conduct risks early on and intervene proactively before customers suffer any harm.

 

I think the incredible work that is currently being done on developing a licensing risk model and the cross-sectoral conduct of business statutory return for all financial institutions will go a long way towards achieving this. Thirdly, I believe that as the supervisor it is important for us to recognise that smaller and emerging institutions have specific challenges and limitations when navigating the complex and evolving regulatory framework. As part of our shift towards an outcomes-based approach to regulation and supervision, we have an important responsibility and opportunity to provide guidance and support to these smaller entities. I would therefore also like to see a deeper implementation support capability being built into our supervisory teams over time. This will hopefully contribute to elevating the general conduct and levels of compliance across the financial sector.

 
 
What is the motto that you live by?
 
If given be thankful; if tested be patient; if errant admit your mistake and seek forgiveness. Above all choose kindness over anger, ego or pride. An act of kindness, no matter how small, beautifies any situation. The absence of kindness, on the other hand, serves only to tarnish it.

 
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