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Disclosure regulations - points for discussion

The disclosure regulations consultation is not too large to quickly get your thinking around at little more than a dozen pages of real content. The issues for more detailed discussion are, perhaps, the disclosure of scope, commission, and conflicts of interest. 

Scope because thinking hard about what your standard service is, and the most common variations, is always an important feature of any business. Considerations include: whether you want to craft each scope statement uniquely, or have a standard, or other approaches like a short menu of different scope statements. Dimensions of scope including areas of service, companies, and products, but also methods and approach - so the client knows what the limits of your efforts shall be as well as your view. 

Commission because complete disclosure of commission may be new to some. Of course disclosure of the fact of commission, relative levels in some form early on. My preference is for dollar disclosure along the lines required for fees, but current wording in the consultation document appears to allow discretion to state a calculation method, although there can be concerns about how clear that will be to many clients. 

Conflicts of interest and how they are managed. It is the last piece which is of most interest. Clearly receipt of commission is a conflict that requires disclosure, but even a fee requires disclosure. Management strategies include disclosure, review of alternatives, commitments to review the wider marketplace, the use of external research, equalising the remuneration for the financial adviser, and so on. 

I encourage everyone to read the consultation document (scroll down for the link below) and to consider making a submission. 

 

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