Advisely Partner
Advisely PartnerThanks Ataia. The ability to address the FSG obligations through the disclosure of information on an adviser’s website was an important part of DBFO Tranche 1. It ran into problems, when it was discovered that it only covered financial advice and did not cover dealing, which is an essential activity for any financial adviser helping their clients to implement the advice. Fortunately, ASIC stepped in to provide regulatory relief on this issue, however it has caused a hold up.
I might not be the closest to where this is at in the marketplace, however I understand that it is a bit mixed. Some licensees are taking advantage of it, whilst others are holding off to wait for a permanent solution to the ‘dealing’ problem. At this stage, it might be around half and half.
Thanks Phil - can you clarify if we need to replace FSG with Website Disclosure and as a result refer to it as such?
Advisely PartnerHi Ataia. I might start by saying that you do not need to move to website disclosure information. You can stay in the old world where you provide paper or electronic FSGs to clients. You can also go hybrid and use FSGs for some clients and website disclosure for other clients.
I hope that I have understood your question. If not then please respond.
Thanks Phil - I mean if we do move to website disclosure information (which is our intention for all clients) - my understanding is we can upload our current FSG as is, but rename it as website disclosure information (or am I mistaken?). If we do have to rename it, would we then have to update all our correspondence that currently references FSG and change to website disclosure? Hopefully that clarifies my question.
Advisely PartnerHi Ataia. That is a good question, and not one that I have a definitive answer to. The term Website Disclosure Information is being added to the existing term 'Financial Services Guide'. I assume that website disclosure information can still be called a Financial Services Guide and the FSG can be left on the website, however it would be worth checking with your compliance consultant.
