Section 14 Transfer Explained: 7 Steps Every Benefits Broker Should Know

How a Section 14 transfer works under the Pension Funds Act: the 7 steps from trustee approval to FSCA sign-off and asset transfer, and where delays happen.
Section 14 Transfer Explained 7 Steps Every Benefits Broker Should Know

Reviewed by Jose Joseph CFP®, founder of EBlink and a practising employee benefits consultant.

A Section 14 transfer is how members and their retirement savings move from one retirement fund to another under the Pension Funds Act. For employee benefits brokers, Section 14 transfers come up whenever an employer changes funds, joins an umbrella fund, or two funds amalgamate.

Done well, a Section 14 transfer is invisible to members. Done badly, it can leave members waiting months for their savings to arrive in the new fund. This guide explains how a Section 14 transfer works, the seven main steps, and where delays usually happen.

Section 14 Transfer Explained 7 Steps Every Benefits Broker Should Know
Section 14 Transfer Explained 7 Steps Every Benefits Broker Should Know

Key Takeaways

  • A Section 14 transfer moves members and their retirement savings from one fund to another under the Pension Funds Act.
  • Some transfers need FSCA approval, while others fall under exemptions; the rules and forms were updated in 2025 for the two-pot system.
  • Both boards of trustees must approve the transfer, and it must be fair to members who move and those who stay.
  • Most delays come from poor member data, untraceable members and weak coordination between administrators.
  • Brokers add the most value by advising clearly, coordinating the parties and following up on every stage.

What Is a Section 14 Transfer?

Section 14 of the Pension Funds Act governs the transfer of business between retirement funds. It covers situations such as:

  • An employer moving its staff from a stand-alone fund to an umbrella fund
  • An employer changing from one umbrella fund to another
  • Two funds amalgamating
  • A fund transferring part of its membership to another fund

The aim is to protect members. A Section 14 transfer must be fair to the members who move and to the members who stay behind, and the regulator, the Financial Sector Conduct Authority (FSCA), oversees the process.

There are two broad routes. Some transfers need FSCA approval before they can be completed. Others fall under exemptions in the Act and FSCA conduct standards, which reduce the paperwork for certain types of transfer. The rules have changed in recent years, including new transfer forms published by the FSCA in 2025 to take account of the two-pot retirement system, so always confirm which route applies to your transfer.

Why Section 14 Transfers Matter to Benefits Brokers

As an employee benefits broker, you are often the person who recommends the move in the first place. Even though the funds and administrators handle the formal application, the employer will look to you to:

  • Explain why the move makes sense and what it will cost
  • Coordinate between the employer, both funds and the administrators
  • Keep members informed so they are not worried about their savings
  • Follow up when the transfer takes longer than expected

A Section 14 transfer that drags on reflects on the broker, even when the delay is outside your control. That is why tracking each transfer stage by stage is so important.

Section 14 Transfer: The 7 Main Steps

Every transfer is different, but most follow the same broad sequence.

1. The decision to transfer

The employer, usually on the broker’s advice, decides to move to a new fund. The reasons are recorded, including the expected benefits for members, such as lower costs, better investment options or improved governance. This is the start of your advice record.

2. Trustee approval

The boards of both the transferring and the receiving fund must approve the transfer. Trustees consider whether the transfer is fair and in the interests of members. Where a fund’s rules require it, members may also need to be consulted.

3. Preparing the transfer documents

The funds and their administrators prepare the prescribed Section 14 forms, the list of members and the basis on which assets will be transferred. Accurate member data is critical here. Gaps or errors at this stage are the most common cause of later delays.

4. Submission to the FSCA (where required)

Where the transfer is not exempt, the application is submitted to the FSCA. The regulator reviews it to confirm the transfer is reasonable and fair to all members, and may come back with questions.

5. FSCA approval or certification

Once satisfied, the FSCA approves the transfer. For exempt transfers, the funds instead confirm that the conditions of the exemption have been met. This approval date starts the clock on the next steps.

6. Tax directives and asset transfer

The transferring fund obtains the necessary tax directives from SARS and then moves the assets to the receiving fund. Fund practice guides commonly refer to a 60-day period after approval for transferring assets and member schedules. Check the current conduct standard for the exact deadlines that apply to your transfer.

7. Allocation to member accounts and confirmation

The receiving fund allocates the money to each member’s account and confirms the transfer is complete. Members should receive a statement showing their new balance. Only then is the Section 14 transfer truly finished.

Where Section 14 Transfers Get Delayed

Section 14 transfers have a reputation for taking a long time. The usual causes are:

  • Incomplete or inaccurate member data, which has to be fixed before the forms can be finalised
  • Unclaimed or untraceable members, especially in older funds
  • Back-and-forth with the regulator when the application is unclear
  • Tax directive delays
  • Poor coordination between the two administrators

The broker cannot control all of these, but you can make sure the employer’s data is clean, that each party knows what is outstanding, and that follow-ups happen on time.

How Brokers Can Keep Section 14 Transfers on Track

Treat each Section 14 transfer as a project with clear stages. For every transfer, record:

  1. The employer and both funds involved
  2. The effective date of the transfer
  3. The current stage, from trustee approval to member allocation
  4. Who is responsible for the next action
  5. The date of the last follow-up and the next one

This turns a vague “it’s with the administrators” into a clear status you can share with the employer. Our guide to broker insurer management covers how to keep provider correspondence organised so nothing falls through the cracks.

Section 14 Transfers and the Two-Pot System

The two-pot retirement system, which took effect on 1 September 2024, split retirement savings into components with different access rules. This affected Section 14 transfers because the forms originally allowed for a single transfer value.

The FSCA published revised Section 14 forms in 2025 to deal with the different components. If you are advising on a transfer, make sure the funds involved are using the current forms and that members’ component balances are carried across correctly.

What to Tell Employers and Members

Clear communication prevents most complaints. Before the transfer starts, explain to the employer:

  • Why the move is being recommended and what members gain
  • The main stages and a realistic timeframe
  • That members’ savings stay invested during the transfer
  • Who members should contact with questions

Then give members a short, plain-language summary. Our article on client communication has practical tips for keeping employers and members informed.

Recording Your Advice on a Section 14 Transfer

Recommending a fund change is financial advice, so your FAIS record-keeping obligations apply. Record the employer’s needs, the options you considered, the reasons for your recommendation and the costs and differences between the old and new funds.

If you are not sure what your records should cover, our employee benefits compliance guide is a good starting point.

Tracking Section 14 Transfers in a Broker CRM

When you manage several transfers at once, a spreadsheet quickly falls behind. A broker CRM built for South African practices can track each Section 14 transfer stage by stage, alongside the employer record and the rest of your compliance work.

In EBlink, Section 14 transfers sit in the same regulatory suite as FAIS, CDD/FICA, Section 37C and CPD tracking. Each transfer shows its current stage, and the most urgent items surface first, so a stalled transfer does not go unnoticed for months.

Section 14 Transfer Checklist

  • Reasons for the transfer recorded and advice documented
  • Trustee approval obtained from both funds
  • Member data checked and cleaned
  • Correct, current Section 14 forms used
  • FSCA submission made or exemption confirmed
  • Approval date recorded and asset transfer deadline diarised
  • Tax directives requested
  • Member allocations confirmed and statements issued
  • Employer and members informed at each stage

Section 14 Transfer FAQs

How long does a Section 14 transfer take?

It varies widely. A straightforward exempt transfer with clean data can move quickly, while a complex amalgamation can take many months. Good data and active follow-up are the biggest factors you can influence.

Do members lose investment returns during a transfer?

Members’ savings generally remain invested in the transferring fund until the assets move, and the receiving fund then invests them. Confirm the specific arrangements with the funds involved and explain them clearly to members.

Who is responsible for the Section 14 application?

The funds and their administrators prepare and submit the application. The broker’s role is to advise the employer, coordinate the parties and keep everyone informed.

Who Does What in a Section 14 Transfer?

Several parties are involved, and confusion about roles is a common cause of delay:

  • The employer decides to move and provides member and payroll data.
  • The broker advises on the move, coordinates the parties and keeps the employer informed.
  • The transferring fund’s trustees approve the transfer out and make sure remaining members are treated fairly.
  • The receiving fund’s trustees approve the transfer in.
  • The administrators of both funds prepare the documents, reconcile member data and move the money.
  • The FSCA reviews and approves the transfer where approval is required.
  • SARS issues the tax directives.

Agree on these roles at the start and write them down. When something stalls, you will know exactly who to follow up with.

Example: An Employer Moving to an Umbrella Fund

Consider a 150-member employer moving from a stand-alone fund to an umbrella fund. A realistic sequence might look like this:

  1. The broker presents a cost and governance comparison, and the employer agrees to move.
  2. Both boards approve the transfer and members are informed.
  3. The administrators reconcile member data and prepare the Section 14 documents.
  4. The application is submitted, or the exemption conditions are confirmed.
  5. Approval is received, tax directives are requested and the assets move.
  6. Members receive statements from the umbrella fund confirming their balances.

At each step, the broker records the date, the next action and the person responsible. If the administrators find data problems in step 3, the employer can be asked to resolve them straight away instead of weeks later.

Questions to Ask Before Recommending a Fund Change

Before you recommend a move that will trigger a Section 14 transfer, make sure you can answer these questions for the employer:

  • What will members gain, in costs, investment options or governance?
  • Are there any costs or penalties for leaving the current fund?
  • How will members’ two-pot components be carried across?
  • How long is the transfer likely to take, given the size and data quality of the fund?
  • Who will members contact with questions during the transfer?

Recording these answers strengthens your advice record and helps the employer explain the decision to staff.

More Questions Brokers Ask

Can members choose not to transfer?

In a Section 14 transfer that moves a group of members, the decision is usually made by the employer and the trustees rather than by each member. Members must be informed, and the transfer must be fair to them. Check the fund rules and current FSCA requirements for any member consultation that applies.

What happens to members who have already left the employer?

Former members who still have benefits in the fund, often called deferred or paid-up members, may be dealt with differently. The trustees decide how to handle them, so confirm the approach with the funds before advising the employer.

Final Thoughts

A Section 14 transfer is a regulated process with several moving parts, but it becomes manageable when you treat it as a project with clear stages and owners. Keep the data clean, follow up on time and keep the employer informed.

To see how EBlink tracks Section 14 transfers alongside your renewals and compliance deadlines, explore the features or start a free 30-day trial. Visit our employee benefits CRM home page for an overview of the platform.

JJ
Jose Joseph, CFP®

Founder of EBlink and a practising employee-benefits consultant with 15+ years in financial services. He builds EBlink for his own practice first.

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