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🏡⚖️ CAPE TOWN PROPERTY PRACTITIONERS: THIS IS ONE TO ATTEND PREPARED.The PPRA has invited Western Cape stakeholders to a...
16/09/2026

🏡⚖️ CAPE TOWN PROPERTY PRACTITIONERS: THIS IS ONE TO ATTEND PREPARED.

The PPRA has invited Western Cape stakeholders to a Stakeholder Engagement and Awareness Event in Cape Town.

📅 Tuesday, 22 September 2026
🕣 08:30–13:30
📍 Premier Hotel Cape Town, 1 Marais Road, Sea Point

The agenda includes:

✅ the Property Practitioners Act and regulatory framework;
✅ registration and Fidelity Fund Certificates;
✅ CPD and PDE;
✅ compliance, inspections and enforcement; and
✅ consumer education and protection.

Importantly, a PPRA Help Desk will be available for practitioners to raise individual PPRA-related queries.

This is not simply a generic roadshow.

It is an opportunity to ask practical questions about live operational issues—including FFC applications and renewals, manual processes during the current registration-system maintenance period, CPD, PDE, education records, status upgrades, audits and public practitioner-search discrepancies.

There is also a particularly important question arising from Sakeliga v PPRA.

Pending the Constitutional Court process, paragraph 8 of the High Court order states that the PPRA may not refuse to issue an FFC solely by reason of section 50(a)(x) of the Property Practitioners Act—the B-BBEE-document requirement in issue in that case.

That does not mean the broader PPRA framework has fallen away. It does mean practitioners deserve a clear, practical answer from the regulator about how it is applying the order now.

To book a seat, RSVP to: [email protected]

⚠️ ⬇️⬇️⬇️⬇️⬇️⬇️⬇️⬇️⬇️ ⚠️

NMA ACADEMY | ASK THE PPRA: WESTERN CAPE INDUSTRY BRIEF™

We are compiling the questions property practitioners actually need answered.

Send us your unresolved PPRA question this week, particularly if it concerns:

1. FFC renewals and the correct manual process;
2. proof to retain where an application was submitted but the FFC has not issued;
3. candidate, qualification, EISA or PDE records not reflecting correctly;
4. the current position on B-BBEE documentation after the Sakeliga order; or
5. what to provide where a public practitioner search does not reflect the correct status.

Please send the question and a short timeline to : [email protected] —but do not post confidential personal information or reference numbers publicly here.

We will consolidate the common issues, seek clarity at the engagement where possible, and publish:

PPRA CAPE TOWN | 10 ANSWERS PROPERTY PRACTITIONERS ACTUALLY NEEDED™

Join our NMA Academy here: https://chat.whatsapp.com/HneIKT44PXQIQCyAUqaTd3

16/09/2026

🏡⚖️ A QUICK PROPERTY PRACTICE REMINDER FOR TODAY…

Sometimes the difference between a transaction that runs smoothly and one that becomes a rescue mission is simply knowing what to check before the problem lands on your desk.

That is exactly why I keep sharing these short practical tips for property practitioners — because better-informed agents create stronger transactions, better client experiences and fewer unpleasant surprises.

🎥 Today’s 40-second reminder.

Watch. Save. Share with your team.

Smart property practice is not about knowing everything.

It is about knowing what to check — and when to ask.

🌸 Natascha Miller & Associates
⚖️ Forensic Conveyancing™
📱 084 844 7948
📧 [email protected]

🚨 **R28 MILLION FOR COMPLIANCE GAPS.**Not for a proven money-laundering incident.Not for established fraud.Not for demon...
15/09/2026

🚨 **R28 MILLION FOR COMPLIANCE GAPS.**

Not for a proven money-laundering incident.

Not for established fraud.

Not for demonstrated financial loss.

**For failures in the compliance system itself.**

The Prudential Authority has imposed administrative sanctions and financial penalties totalling **R28 million** on Capitec Bank following a FIC Act inspection conducted in 2023.

The penalties were reportedly allocated as follows:

🔹 **R10 million** — inadequate customer due diligence
🔹 **R5 million** — inadequate enhanced due diligence
🔹 **R5 million** — inadequate ongoing due diligence
🔹 **R3 million** — inadequate ongoing employee training
🔹 **R5 million** — weaknesses in the Risk Management and Compliance Programme and related controls

Of the total penalty, **R5.5 million was conditionally suspended for 36 months**. Five cautions were also imposed.

Capitec has emphasised that the findings concerned administrative and control deficiencies—not identified instances of money laundering, fraud, illicit financial activity, or client loss—and that it has taken remedial steps.

That distinction is important.

But so is the regulatory message:

> **A regulator does not have to prove that money laundering occurred before it can sanction an accountable institution for inadequate FIC Act compliance.**

Among the specific shortcomings identified were:

❌ inadequate customer, enhanced and ongoing due diligence on sampled files;

❌ insufficient evidence of ongoing employee training;

❌ anti-money-laundering screening manuals implemented without prior management approval;

❌ an inability to produce evidence that end-to-end terrorist-property reporting processes had been documented and approved before the inspection; and

❌ inadequate policies, procedures, and controls dealing with terrorist-property reporting and financial sanctions.

🏡⚖️ **WHY SHOULD PROPERTY PRACTITIONERS AND LAW FIRMS CARE?**

Because estate agencies, property practitioners, and legal practitioners are also accountable institutions under the FIC Act.

The same fundamental principles apply:

✅ Your RMCP must be tailored to your actual business—not downloaded, renamed and forgotten.

✅ Client identification is only the beginning. You must understand identity, authority, beneficial ownership, the nature of the relationship, and the transaction risk.

✅ Higher-risk clients and transactions require enhanced measures consistent with your RMCP.

✅ Due diligence must continue after onboarding. Changes in ownership, payment arrangements, representatives, transaction structure, or risk profile may require reassessment.

✅ PEP/PIP and targeted-financial-sanctions screening must be performed, escalated, and evidenced.

✅ Policies and screening procedures must be properly approved before implementation.

✅ Employees must receive ongoing, relevant training—and the institution must retain proof of that training.

✅ Principals and senior management must be able to demonstrate actual oversight.

The critical compliance principle is brutally simple:

**IF IT IS NOT DOCUMENTED, APPROVED, IMPLEMENTED, AND EVIDENCED, IT MAY BE VERY DIFFICULT TO PROVE THAT IT WAS DONE.**

An RMCP sitting in a folder is not a functioning compliance program.

A tick on a checklist is not necessarily adequate due diligence.

A once-off training session is not necessarily ongoing training.

And “we know our client” is not a substitute for a defensible client file.

The FIC Act permits administrative financial penalties of up to **R10 million for a natural person and R50 million for a legal person**.

📂 **COMPLIANCE MUST SURVIVE FILE SAMPLING.**

Every agency and professional practice should now ask:

🔍 Can we produce our current, formally approved RMCP?

🔍 Does it reflect how our business actually operates?

🔍 Can we prove why a client or transaction received its risk rating?

🔍 Are enhanced and ongoing due-diligence decisions recorded?

🔍 Can we show screening results and how alerts were resolved?

🔍 Are our reporting and escalation processes documented?

🔍 Can we prove that every relevant employee has received appropriate ongoing training?

Compliance is not the paperwork surrounding the transaction.

**Compliance is part of the transaction.**

Natascha Miller & Associates
**Forensic Conveyancing™ — Done Right The First Time.**

📞 084 844 7948
📧 [email protected]

*General information only and not a substitute for advice on a particular institution’s obligations.*

🚨🏡⚖️ **URGENT FFC / B-BBEE UPDATE: PPRA AND REBOSA DISAGREE ON THE IMMEDIATE EFFECT OF THE SAKELIGA ORDER**Property prin...
15/09/2026

🚨🏡⚖️ **URGENT FFC / B-BBEE UPDATE: PPRA AND REBOSA DISAGREE ON THE IMMEDIATE EFFECT OF THE SAKELIGA ORDER**

Property principals and practitioners applying for their **2027 Fidelity Fund Certificates must take note**.

On **8 September 2026**, the Gauteng High Court declared **section 50(a)(x) of the Property Practitioners Act** unconstitutional and invalid.

This is the provision that prevents the PPRA from issuing an FFC to an applicant who is not in possession of a “valid BEE certificate”.

However, a declaration that legislation is constitutionally invalid must still be confirmed by the **Constitutional Court**.

The important new development is that the **PPRA and REBOSA are now publicly interpreting the immediate effect of the order differently**.

The PPRA’s position is that the declaration of invalidity and interim order do not take effect until confirmed by the Constitutional Court.

REBOSA disagrees and relies on **paragraph 8 of the High Court order**.

That paragraph expressly provides that, pending the Constitutional Court’s decision:

> **The PPRA may not refuse to issue a Fidelity Fund Certificate solely by reason of section 50(a)(x).**

The distinction is critical.

The declaration of constitutional invalidity still requires confirmation. However, paragraph 8 is framed as **temporary relief intended to govern the position while that confirmation is pending**.

# # # WHAT SHOULD PRINCIPALS AND PRACTITIONERS DO?

✅ Submit your 2027 FFC application on time.

✅ Ensure that every other part of the application is complete.

✅ Keep copies of the application, supporting documents and all correspondence with the PPRA.

✅ Do not allow your current FFC to lapse while waiting for clarity.

✅ If an FFC is refused, require the PPRA to provide its reasons in writing.

✅ If the only reason is non-compliance with section 50(a)(x), obtain legal advice regarding reliance on paragraph 8 of the Sakeliga order.

❌ Do not assume that every B-BBEE obligation has disappeared.

❌ Do not delay your renewal application while the legal position is being debated.

The legally accurate position is therefore **not simply that “BEE is no longer required for FFCs.”**

The more accurate formulation is:

**The High Court has declared the B-BBEE licensing condition unconstitutional, subject to Constitutional Court confirmation. Pending that decision, the Court has separately ordered that the PPRA may not refuse an FFC solely because of section 50(a)(x). The PPRA and REBOSA presently disagree about the immediate operation of that interim relief.**

The judgment also narrows aspects of the definition of a **“property practitioner”**, particularly in relation to:

• certain private owners dealing with their own property;

• persons dealing with property outside their ordinary course of business; and

• platforms whose involvement goes no further than carrying, hosting, publishing or disseminating advertisements placed by others.

Businesses should nevertheless **not deregister merely because of a headline**. Whether an entity falls within the narrowed definition requires a proper assessment of its complete activities, and the constitutional-confirmation process remains pending.

Finally, this judgment concerns the **FFC licensing mechanism contained in the Property Practitioners Act**.

It does not abolish South Africa’s broader B-BBEE framework, procurement requirements, applicable sector-code consequences or transformation responsibilities arising under other laws and commercial arrangements.

📌 **NMA POSITION**

Apply on time.
Keep the evidence.
Demand written reasons.
Do not permit an FFC to lapse.
Treat this matter as confirmation-pending and obtain advice before making compliance or deregistration decisions.

Natascha Miller & Associates will continue monitoring the Constitutional Court process and any formal PPRA directive or circular.

📞 084 844 7948
📧 [[email protected]](mailto:[email protected])

**Smart Law For A Complex World.**

🏡📉 AGENT DIARY | SARB INTEREST-RATE DECISION — 23 SEPTEMBERThe South African Reserve Bank’s Monetary Policy Committee an...
15/09/2026

🏡📉 AGENT DIARY | SARB INTEREST-RATE DECISION — 23 SEPTEMBER

The South African Reserve Bank’s Monetary Policy Committee announces its next interest-rate decision on:

Wednesday, 23 September 2026 at 15:00.

A useful client conversation this week:

«“There is another interest-rate decision next week, but we should structure your purchase around the rate that exists today — not around a rate cut that has not happened.”»

Agents, do not allow:

❌ seller pricing;
❌ purchaser affordability;
❌ bond commitments; or
❌ an OTP

to depend on social-media predictions about the MPC.

A lower rate may be welcome. But it is not yet part of the buyer’s affordability calculation, bank approval or contractual reality.

HOPE FOR THE CUT.
QUALIFY FOR THE LOAN THAT EXISTS.

📲 Save this for buyer conversations this week.

🏡📑 NEW NMA ACADEMY RESOURCEWhen does persuasive property marketing become a risky factual assurance?Our Disclosure and M...
14/09/2026

🏡📑 NEW NMA ACADEMY RESOURCE

When does persuasive property marketing become a risky factual assurance?

Our Disclosure and Marketing Language Guide uses Fitzpatrick v Latsky to help property practitioners:

✅ distinguish puffery from factual claims;
✅ manage mandatory disclosures correctly;
✅ verify statements before publishing them; and
✅ use safer, defensible marketing language.

Describe the feature. Attribute the source. Preserve the record.

Now available through the NMA Academy.

Join here: https://chat.whatsapp.com/HneIKT44PXQIQCyAUqaTd3

🏡 THREE TRUSTEES. TWO SIGNATURES. ONE EXCLUDED TRUSTEE.IS THE DECISION VALID?A trust resolution is not magic. The proces...
14/09/2026

🏡 THREE TRUSTEES. TWO SIGNATURES. ONE EXCLUDED TRUSTEE.

IS THE DECISION VALID?

A trust resolution is not magic. The process behind it still matters.

In Bellstedt v Trustees for the time being of the Bellstedt Family Trust and Others [2026] ZAWCHC 489, the Western Cape High Court dealt with a family trust that owned a Paarl farm. A sale agreement had been authorised by two trustees while a co-trustee alleged that she had been excluded from meaningful participation.

The dispute reached beyond the sale itself. It involved questions about trustee participation, the trust’s financial records and a claimed personal loan account. The Court found the alleged loan account unsupported and held that the resolution relied on to approve it had been adopted through a procedurally defective process. It was declared invalid.

The lesson for trust-owned property is clear:
➡️ A signed resolution is a starting point — not always the end of the authority enquiry.

Before a trust property is transferred, the right questions include:
✔️ Are all trustees properly appointed and authorised?
✔️ Were all entitled trustees given notice and a genuine opportunity to participate?
✔️ Does the trust deed permit a majority decision?
✔️ Is any trustee conflicted or personally benefiting?
✔️ Is there an unresolved internal dispute?
✔️ Has the resolution been validly adopted?
✔️ Are the sale proceeds being dealt with transparently and lawfully?

A property transaction can look perfectly orderly on paper while a serious authority dispute is developing underneath it.

At Natascha Miller & Associates, our Forensic Conveyancing™ approach looks beyond a document checklist. We examine the authority, the process and the risk before the matter becomes a lodgement-stage crisis.

Trust selling is not simply:
Letters of Authority + trust deed + resolution.

It is also:
Who decided? How was the decision made? And can it withstand scrutiny?

For assistance with a trust-owned property sale:
📧 [email protected]
📞 084 844 7948

Read the judgment: Bellstedt v Trustees for the time being of the Bellstedt Family Trust and Others [2026] ZAWCHC 489⁠

🏡 “LET’S NOT MENTION THAT.”Possibly the most expensive sentence in a property transaction.The roof leaked during a sever...
14/09/2026

🏡 “LET’S NOT MENTION THAT.”

Possibly the most expensive sentence in a property transaction.

The roof leaked during a severe storm.
The inverter sometimes trips.
The enclosed patio may not match the approved plans.

A seller may worry that disclosure will make the property impossible to sell.

It will not.

But concealing known information can turn a manageable issue into a failed deal, a dispute, a complaint—or far worse.

A professional property practitioner does not need to be an engineer, inspector or legal adviser. But they do need to know when to pause, ask better questions, document what the seller knows and recommend the appropriate next step.

A good agent does not say:

«“Don’t worry. Nobody will notice.”»

A trusted agent says:

«“Let’s record the facts properly, obtain advice where necessary and market this property with confidence—not concealment.”»

The Mandatory Disclosure Form is not designed to make a home look imperfect. It is there to ensure known information is handled responsibly and that buyers can make informed decisions.

The right approach is simple:

✅ Ask clear questions before the listing goes live.
✅ Record known information accurately.
✅ Do not minimise, diagnose or make promises you cannot prove.
✅ Encourage proper inspections or professional advice where appropriate.
✅ Make the transaction safer before it becomes urgent.

A property may have a history.
A transaction must have integrity.

At Natascha Miller & Associates, we help property practitioners build stronger, safer and more defensible transactions.

📧 [email protected]
📞 084 844 7948

🚨 NMA ACADEMY COMPLIANCE ALERTFIC DIRECTIVE 12 IS FINAL: RMCPs MUST NOW BE SUBMITTED EVERY YEARYour Risk Management and ...
14/09/2026

🚨 NMA ACADEMY COMPLIANCE ALERT

FIC DIRECTIVE 12 IS FINAL: RMCPs MUST NOW BE SUBMITTED EVERY YEAR

Your Risk Management and Compliance Programme is no longer merely a document that must be available if the Financial Intelligence Centre asks for it.

For affected accountable institutions, it must now be submitted to the FIC annually through goAML.

Directive 12 was finalised on 4 September 2026 and took effect on 7 September 2026.

📅 FIRST SUBMISSION DEADLINES

⚖️ Legal practitioners and law firms:
9 October 2026

🏡 Estate agencies/property practitioners:
31 October 2026

Importantly, these dates changed from those proposed in the draft Directive.

For estate agencies, 31 October now carries two separate compliance clocks:

1️⃣ The PPRA deadline for 2027 FFC/RC renewals; and
2️⃣ The FIC deadline for annual RMCP submission.

The PPRA registration system is currently still displaying “Registration system offline”, with registrations and renewals being handled manually. Do not allow the system difficulties to push either obligation into the final week of October.

WHAT ELSE DOES DIRECTIVE 12 REQUIRE?

🔹 A newly established affected institution must submit its RMCP within 90 days of commencing business.

🔹 If an RMCP is amended and approved after the annual submission period, the amended RMCP must be submitted within 10 days of approval.

🔹 Submission through goAML confirms delivery. It does not mean that the FIC has approved the RMCP or confirmed that it is legally adequate.

WHY THIS IS A MATERIAL COMPLIANCE ESCALATION

The FIC will now routinely receive the document in which an institution describes its anti-money-laundering, terrorist-financing and proliferation-financing controls.

That document may be compared with:

✅ the institution’s Risk and Compliance Return;
✅ its business and client-risk assessments;
✅ beneficial-ownership procedures;
✅ sanctions and PEP screening;
✅ source-of-funds and source-of-wealth controls;
✅ suspicious-transaction escalation procedures;
✅ technology-risk assessments;
✅ staff screening and training records; and
✅ what is actually happening in client and transaction files.

A beautifully drafted RMCP is not protection if it describes controls that the business does not actually apply.

In that situation, the RMCP may become evidence of the institution’s own compliance failures.

THE NMA ACADEMY TEST

Before submitting your RMCP, examine every stated control and ask:

“SHOW ME THE EVIDENCE THAT WE ACTUALLY DO THIS.”

If the RMCP says clients are risk-rated, produce the completed risk assessments.

If it says beneficial ownership is verified, produce the supporting records.

If it says sanctions and PEP screening take place, produce the screening evidence.

If it says staff receive F**A training, produce the attendance registers, training material and assessments.

If it says suspicious activity is escalated, show the internal reporting procedure.

If the evidence does not exist, the control may exist only on paper.

IMMEDIATE ACTION FOR LAW FIRMS AND ESTATE AGENCIES

Do not simply proofread your current RMCP.

Conduct a document-to-practice RMCP audit:

☑️ Confirm your correct Schedule 1 classification and deadline
☑️ Review the RMCP against section 42 of F**A and Guidance Note 7B
☑️ Ensure it reflects your present clients, services, systems and risks
☑️ Compare it with your latest Risk and Compliance Return
☑️ Test every written control against actual file evidence
☑️ Correct implementation gaps
☑️ Obtain the required approval from the appropriate governing authority
☑️ Confirm that your goAML access is active
☑️ Retain the submitted version and proof of submission
☑️ Create a procedure for submitting future amendments within 10 days

📌 YOUR RMCP IS NO LONGER JUST A FILE YOU KEEP.

THE FIC NOW EXPECTS YOU TO SEND IT IN.

🏡 ESTATE AGENCIES: 31 OCTOBER NOW HAS TWO COMPLIANCE CLOCKS — YOUR FFC AND YOUR RMCP.

Do not wait until the final week of October to discover that your RMCP is outdated, generic or inconsistent with the way your agency actually operates.

NMA Academy | Compliance that works in practice—not only on paper.

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