Licence application

Assessment

On initial engagement we assess the likelihood of the success of an application based on educational qualifications and skills/experience of the proposed Responsible Manager(s).  There is a fee payable for this assessment.

Online application

We ask you numerous questions to obtain information about your proposed operation to assist us in drafting the online application for the applicant and guide you where we believe that it is necessary .

We also develop for you, based on the information that you provide to us, the relevant policies to support your application in the preferred ASIC format.  We work closely with you in the development of these policies as they must be relevant on how you will run the operation.  You must sign off the online application and the policies before submission.

Our involvement does not stop when​​ the submit button is pressed.  We also assist you to address any requisitions you may receive from ASIC.

Outsourced Compliance​

Policies and procedures
The policies developed during the licence application may be sufficient for a small operation with all advisers in a central office.  However where there are numerous advisers and/or they are geographically spread it would be prudent to have a set of policies and procedures specifically designed for them so that they comply with the necessary requirements in providing financial services on your behalf.   These policies have to be maintained to reflect changes in legislation as well as improvements in efficiencies.

We can provide the manual containing these policies and procedures in a format that can be adapted to any medium.  The Policies cover expectations for:
  • ​Training.
  • Research.
  • Analysis of the client.
  • Data collection and recording.
  • Written advice.
  • Record keeping.
  • Cooperation with the Licensee or its appointed representative for monitoring and supervision activities.
  • Complaint handling.
  • Termination.
Compliance Activity Management (CAM)
Compliance activity management is effectively having a part time resource to assist the Licensee with the compliance function on an agreed regular basis.  The frequency depends on how much time the employees of the Licensee have available to dedicate to compliance and if those employees can do so without conflict.  It is structured with agenda and report however flexibility is available to address any issues that arise for the Licensee.

Licensee Assessment

Licensees must comply with the Licence conditions and the Regulatory requirements set out in the Corporations Act and its associated Regulations.  The method of compliance is not specified.  Therefore during our standard review we:
  • Review the written policies.
  • Interview relevant senior staff.
  • Review the application in the day to day operation of the Licensee's activities.
  • Provide feedback to the nominated person.
  • Compose and deliver a report of the findings as well as recommendations to address them.
​In addition to the standard review we can assist with the implementation of agreed recommendations then reassessed the effectiveness of those changes once the Licensee has had time to implemented them.

Adviser Reviews​​

Advisers must also comply with the Licence Conditions and the legislative requirements that apply to its licence.  Part of this is to comply with the policies and procedures set down by the Licensee in providing those financial services to retail clients.  As you would be aware the Licensee is responsible for ensuring the compliance of its advisers.  Consequently it must assess the performance of those advisers and take remedial activity where necessary.

The main focus in the Adviser​ Review is assessment of the adviser's client records to establish if there is sufficient evidence to support the personal advice that was provided to the client.  We all agree that a quality service is the primary aim so that all involve win in the end.

The assessment can involve:
  • An interview with the adviser.​
  • A questionnaire to be completed by the adviser to see if there have been any changes in circumstances since they were originally authorised.
  • The quality of:
    • Data collection.
    • Analysis of the client information.
    • Research conducted. 
    • The record of the advice provided.
    • How the advice addresses the client's objectives.
  • Feedback is provided at the conclusion of the review.
  • A written report is provided to the Licensee on the results of the review and actions recommended.​

Due Diligence

When taking on a new adviser or purchasing a client base a Licensee must do its due diligence.  This involves a financial investigation, profiling the client base and a compliance assessment of the adviser's activities.  Most Licensees tend to do the first and possibly the second but do not always give adequate attention to the compliance.  Our service is on the compliant nature of files as well as the activities or focus of the adviser with the aim to uncover any potential hidden problems/complaints that may arise at a later point in time.

Similarly when an adviser is to depart your Licence you should conduct due diligence especially if there has not been a file review for some time.  You also need to maintain access to the files in order to continue to comply with your licence conditions.​
Additional bespoke services include assessment of complaint handling, assessment of a complaint file for ability to defend the complaint (which may be covered in the CAM days if taken), Guidance Notes  and presentations at PD days on compliance topics.
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