Prepared by Catherine Evans
ASIC is currently seeking information on the issues and impediments that exist around advisers delivering affordable personal advice. Submissions are due by 18 January 2021. You can submit your views online via the link on page 4 of the Consultation Paper here: https://download.asic.gov.au/media/5853864/cp332-published-17-november-2020.pdf.
Some of the items we will be raising are:
- confusion over Code of Ethics requirements in giving scaled advice;
- ambiguity in ASIC guidance, in particular in papers such as REP 413 (requirements for cash flow modelling and bringing into scope contributions advice for risk only advice) and how this can be delivered in a simple and cost effective way;
- ROAs vs SOAs in general;
- requirements for foundation SOAs;
- not getting clear answers from ASIC when we ask specific questions;
- confusion about how much of a client’s information to include in SOA documents and what can be incorporated by reference (including from previous SOAs provided under a different AFSL).