At an FSC “Get In Shape” conference dedicated to bringing the industry up to speed on the new disclosure regulations, David Greenslade of Strategi Group said that the new disclosure regulations will be “a big leap forward for some businesses”.
Greenslade added that some RFA advisers would not be used to talking about their own remuneration, but that the regulations were clear that it will be “on you to disclose the value that you add to a portfolio. This includes disclosing how much you are getting paid.”
Mark Banicevich from Partners Life, responding to a question from the audience clarified: “You don’t have to disclose your salary to clients, but you do have to disclose your commission. Also you must disclose your individual reliability history, whether you had any bankruptcy or warnings from the regulator.”
There are four stages of disclosure as part of the new regulations.
1. At all times on the company website, for which the FAP is responsible.
2. When the scope of financial advice is known, for which the adviser is responsible.
3. When financial advice is given, for which the adviser is responsible.
4. When there is a complaint, for which FAP and adviser are responsible.
It may seem that the multiple stages and murky separation of responsibility could have some advisers scratching their heads. But Banicevich said that while the industry was “saying what you had to disclose, it isn’t saying how you have to disclose it”.
Greenslade adds that there is “huge flexibility with how you facilitate disclosure. Whatever way you can think of communicating it you can do it.
“Disclosures shouldn’t be something hidden away at the bottom of the website. Wherever a client is likely to land on the website the disclosure should be there.
“It doesn’t have to be the current boring content. Advisers should be working to make these new disclosures engaging so that clients can read it and understand it at the point that they encounter it.”
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