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Tangelo’s submission for CP 332 - Promoting access to affordable advice for consumers
Tangelo has made a submission to the CP 332 - Promoting access to affordable advice for consumers ASIC consultation. Working across the industry, on behalf of a variety of clients, we have strong views on what should be done to make high quality advice available to all Australians who need it.
Structural rethink needed for advice industry
One of the interesting insights to come out of the ‘How to Regulate Advice session at Professional Planner’s Best Practice Forum was ASIC’s assessment that licensees themselves were being too conservative around policy guidance. That is, it was observed that licensees were going far beyond ASIC’s guidance, which in some circumstances had been to the detriment of scaled advice.
Royal Commission recommendations are due for implementation in 2021 - have you prepared?
As part of the Royal Commission recommendations, there are a raft of changes coming our way, including independence declaration, the banning of advice fees inside MySuper products and the widening of reference checking processes industry wide. These changes will all require some level of action to accommodate, but there are two changes which we believe are most significant that licensees should start acting on now (if they haven’t already) which are the breach reporting and ongoing fee arrangement changes.
Mind the gap: Every Licensee has its compliance shortcomings
Over the past year, one of my clearest take outs from consulting to licensees and practices regarding compliance is that it’s almost never actually about “compliance”
Prepare for ASIC to focus on small end of town
Businesses need to plan for the fact that ASIC could come into their business. Explaining something away or saying “I haven’t done that sorry” no longer cuts it when you run a licensee. If they do come in, they are not going to worry about how you feel.
A fence at the top of the hill: changing how we think about “compliance”
Perspective is a powerful thing. Ask a financial adviser about “compliance” and you’re likely to get a grimace, a shrug or some kind of grunt. This is largely because compliance as we know it has been built and framed the wrong way.
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