The draft Financial Advisers Act has just been released on the MBIE website. An overview is here, the documents can be found at this link. Some of the key changes are outlined in this article on goodreturns. Feedback closes on the 31st of March.
Draft changes appear to leave a number of issues without adequate resolution, or perhaps a more generous interpretation might be that, resolution is entirely in the hands of the regulator.
We are worried that there may still be many people that can be "Financial Advice Representatives" that give no "Financial Advice". We are worried that there is not enough distinction between a "Financial Advice Representative" and a "Financial Adviser". We think that an ordinary person would assume that both give financial advice.
We are worried that given the absence of any differentiation the numbers of "Financial Advisers" will fall.
We are also concerned that there appears to be no mechanism to stop people who have been poor reps in one FAF moving to another to be poor reps.
More detailed review to be conducted during the week. Any clients wishing to discuss their submission should contact us.