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Joint submission to the Quality Advice Review
We welcome the opportunity to provide feedback on the Quality of Advice Proposals Paper published on the Treasury website 29 August 2022. As an overall comment, our three companies are committed supporters of a well-functioning financial advice industry and see the proposal as a significant step forward in terms of encouraging autonomy and professionalism in our industry.
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.
Watch the knee-jerk when thinking about self-licensing
Make sure you understand all the risks and costs of self-licensing. A common view is that the cost to go self-licensed is minimal and there are players out there to help with the application and the outsourced services, particularly compliance. While this is true to a certain extent, my view is that it excludes some pretty important considerations.
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