aligned dealer group {adg) authorised representative
TRANSCRIPT
ANZ.800.390.0004
Internal use only
Aligned Dealer Group {ADG) Authorised Representative Recruitment & Authorisation Procedures Version 5.0 December2017
Description:
Key Principles:
Tools and
References:
Further
assistance:
Version control
Version Released
1.0 1 Sept 2013
1.1 1 October 2013
2.0 1 April 2014
3.0 1 April 2015
Procedure
This document describes the procedures and processes that must be undertaken to meet the
obligations required under the ADG Authorised Representative Recruitment & Authorisation
Standard.
This document is divided into 4 sections:
• Recruitment
• Appointment o Pre-approval tasks o Authorisation
• Set-up & Induction
• Termination
Recruitment- initial due diligence and fact finding steps must be taken to determine whether
the prospect has strong potential and should move to the Appointment stage.
Appointment- minimum requirements and competencies in line with ANZ standards must be
reviewed and checked for each Adviser/Practice before the authority can be issued.
Set-up & induction- processes must be followed to ensure new Advisers/Practices are set-up,
enabled and inducted consistently and in a timely manner.
Termination- processes relate to whether or not the Licensee retains responsibility for the
provision of advice to clients or if another Licensee with assume responsibility, as well as the
termination of authority and cessation of all Licensee services and system access.
ADG Authorised Representative Recruitment & Authorisation Standards
Recruitment Fact Find
Appointment checklist
Termination checklist
Contact: Adviser Appointments team
E: CONFIDENTIAL
Owner Approved by Summary of changes Next review
Adviser Head of Operations & Projects, Aligned New internal procedures September 2014 Appointments Licensees
Adviser Head of Operations & Projects, Aligned Update September 2014 Appointments Licensees
Advice Process GM, Advice & Open Market Channels Update April 2015 & Systems
Advice Process GM, Advice & Open Market Channels April 2016 & Systems
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4.0 April 2017 Advice Process & Systems
GM, Advice & Open Market Channels April 2018
5.0 December 2017 Advice Operations & Initiatives
GM, Advice & Open Market Channels November 2018
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Table of Contents
Overview .......................................................................................................................... 6
1. Recruitment .............................................................................................................. 6
1.1 Initial Due Diligence ...................................................................................................................... 6
1.1.1. Generating recruitment leads ............................................................................................... 6
1.1.2. Contacting lead to assess recruitment potential .................................................................. 7
1.1.2.a) Recruitment Fact Find for practices and advisers ....................................................................... 7
1.1.3. Adviser proposal developed ................................................................................................. 8
1.1.4. Adviser proposal presented .................................................................................................. 8
1.1.5. Adviser accepts proposal and a formal letter of offer/terms & conditions sent to Practice 8
1.2. Offer Letter / Terms & Conditions (new Practices only) .............................................................. 8
1.3. Sending the Application Kit to the Applicant ............................................................................... 8
2. Australian Banking Association – Reference Checking & Information Sharing Protocol 10
3.1. Pre-approval steps ..................................................................................................................... 11
3.1.1. Application for Authority .................................................................................................... 12
3.1.1.a) Receipt of Application Documents ............................................................................................ 12
3.1.1.b) Contacting SDM / RPM / PDM .................................................................................................. 12
3.1.1.c) Contacting Applicant ................................................................................................................. 12
3.1.1.d) Setting up a new Adviser File .................................................................................................... 13
3.1.1.e) Adding the Applicant’s details to internal registers .................................................................. 14
3.1.2. Minimum standards and competencies ............................................................................. 14
3.1.2.a) Assessing the Applicant’s Educational Qualifications for RG146 compliance ........................... 17
3.1.2.b) Review of Recommended Products by CIO (if transferring with a book of clients) ................... 18
3.1.2.c) Advice Assurance Review ........................................................................................................... 18
3.1.2.d) Background checks .................................................................................................................... 20
3.1.2.e) Reference Checks ....................................................................................................................... 27
3.1.3. Additional Licensee specific procedures ............................................................................. 28
Technical Competency test (RI Advice only) ........................................................................................... 28
3.1.4. Additional checks for new Practices only ........................................................................... 28
3.1.4.a) Review of financials ................................................................................................................... 28
3.1.4.b) Practice background checks ...................................................................................................... 28
1.1.2.b) Risk Adviser Review ................................................................................................................... 29
3.1.4.c) Marketing Materials & Website ................................................................................................ 30
3.1.5. Waivers or variations to standard appointment process ................................................... 30
3.1.6. Subsidiary / Non-controlled entity arrangements .............................................................. 31
3.1.7. Due diligence sign off .......................................................................................................... 31
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3.1.8. Final approval ...................................................................................................................... 31
3.1.9. Delegated authority ............................................................................................................ 33
3.2 Authorisation steps ..................................................................................................................... 33
3.2.1. Legal Agreements ................................................................................................................ 34
3.2.1.b) Authorising a Trustee ................................................................................................................ 35
3.2.2. ASIC Notification ................................................................................................................. 35
2.2.3. Authorisation Notification ............................................................................................ 36
Inform Applicant of successful Application ............................................................................................. 36
Authority Notice ..................................................................................................................................... 37
3.2.4. Transfer Agreement - transition of brokerage (if applicable) ............................................. 37
3.2.5. Updating Internal Registers ................................................................................................ 37
3.2.6. Notify Licensee Support Staff.............................................................................................. 37
3.2.8. Maternity Leave (if applicable) ........................................................................................... 38
3.3 Confirmation / Follow-ups .......................................................................................................... 38
4. Set-up & Induction ................................................................................................... 39
4.1. Welcome email to the Applicant ............................................................................................... 39
4.2. Licensee Support Staff enable access to systems and services ................................................. 40
4.2.1. Adviser Website Access ...................................................................................................... 41
4.2.2. Brokerage system set up and access .................................................................................. 41
4.2.3. Brokerage transition – client transfers and Adviser codes ................................................. 41
4.2.4. Financial Services Guide and Adviser Profile ...................................................................... 42
4.2.5. Induction ............................................................................................................................. 43
4.2.7. Ongoing Training system..................................................................................................... 43
4.2.8. Professional Indemnity Insurance ....................................................................................... 43
4.2.9. Research Tools .................................................................................................................... 44
Mercer and Chant West access .............................................................................................................. 44
4.2.10. Stationery Ordering .......................................................................................................... 44
4.2.11. Technology, data conversion & access to advice templates ............................................ 45
Process for RI & FSP ................................................................................................................................ 45
Process for M3 ........................................................................................................................................ 45
4.2.12. Vetting Standards .............................................................................................................. 45
4.2.13. Website - Licensee public website listing ......................................................................... 46
4.3. Quick Reference Guide: Set-Up & Induction ............................................................................. 46
5. Termination Procedures .......................................................................................... 47
5.1.1. Terms of Agreement – preparing for termination .................................................................. 48
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5.1.1.a) Receipt of resignation ...................................................................................................... 48
5.1.1.b) Adviser File and Termination/Cancellation checklist ...................................................... 48
5.1.1.c) Notifying the Adviser of their obligations and the next steps in the termination process
...................................................................................................................................................... 48
5.1.1.d) Payment of outstanding debts ........................................................................................ 49
5.1.1.e) Review of Tripartite arrangement (if applicable) ............................................................ 49
5.1.1.f) Review of outstanding complaints, incidents & remediation .......................................... 49
5.1.1.g) Licensee sign off on any outstanding matters ................................................................. 49
5.1.2. ASIC Notification - Revocation of Authority ............................................................................ 49
5.1.3. Client Communication ............................................................................................................ 50
5.1.4. Transfer Deed .......................................................................................................................... 50
5.1.5. Client Release Letter ............................................................................................................... 50
5.1.6. Transferring Client Register to another internal Adviser (if applicable) ................................. 51
5.1.7. Authorising an Xplan Data Conversion (if applicable) ............................................................ 51
5.1.8. Exit Survey ............................................................................................................................... 51
5.1.9. Notification of termination to all Licensee Support Staff ....................................................... 51
5.1.10. Removal of services & system access ................................................................................... 51
5.1.10.a) Notifying Brokerage ....................................................................................................... 52
5.1.10.b) Cancelling software ....................................................................................................... 52
5.1.10.c) Updating internal registers ............................................................................................ 52
5.1.10.d) Cancelling Website Access / Stationery ID .................................................................... 52
5.1.10.e) Cancelling Adviser Website access ................................................................................ 52
5.1.10.f) Cancelling Training System Access ................................................................................. 52
5.1.10.g) Cancelling Research Tools .............................................................................................. 53
5.1.10.h) Cancellation of PI Insurance Cover ................................................................................ 53
5.1.11. Retention of Client Data ....................................................................................................... 53
5.1.12. Destruction of Adviser’s personal information after termination ........................................ 54
6. Australian Banking Association – Responding to a Request ...................................... 54
Email Template to Make Request to Other Licensee........................................................ 55
ABA Consent Form Protocol ............................................................................................................. 56
ABA Industry Reference Checking Form .......................................................................... 64
Xplan data conversion process ........................................................................................ 68
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OVERVIEW There are four stages in the Aligned Dealer Groups (ADGs) Recruitment & Authorisation procedures.
This document outlines the sequence of actions that must be undertaken in each stage in order to
achieve compliance with the ADG Authorised Representative Recruitment & Authorisation Standards
and to manage the associated risks.
1. RECRUITMENT The recruitment of a new Adviser / Practice requires initial fact finding and due diligence to
determine whether the prospect will be an appropriate cultural fit within the group and to ensure
minimal risk to the Licensee if the prospect is appointed. This is the responsibility of the Licensee
Practice Development team (RPM/SDM/PDMs).
Recruitment activities are the responsibility of the Licensee Practice Development teams and the
primary purpose is to gather information to assess the Applicant’s suitability and compatibility to
join an ANZ Licensee.
The key steps in the process are as follows:
Generating recruitment leads
Contacting leads to assess recruitment potential
Holistic Adviser proposal developed
Holistic Adviser proposal presented
Adviser accepts proposal and letter of offer / terms & conditions (containing commercial
terms) sent to Practice
1.1 Initial Due Diligence 1.1.1. Generating recruitment leads Currently, recruitment leads are generated/sourced by:
Licensee Practice Development Managers (RPM/RMs)/ Sales Development Managers (SDMs)
OnePath Business Development Managers – leads passed to central team for execution
These leads typically come from:
Existing aligned Advisers
Newly recruited Advisers
Cold calling targeted group – e.g. AFS
1.
Recruitment
2.
Appointment
(Pre-approval +
Authorisation)
3. Set-up & Induction
4.
Termination
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1.1.2. Contacting lead to assess recruitment potential 1.1.2.a) Recruitment Fact Find for practices and advisers
Once the lead has been received, the Licensee RPM/SDM/RM contacts the Adviser to assess their recruitment potential. If the lead is considered strong potential, the RPM/SDM/RM must complete a Recruitment Fact Find to ascertain key information about the Practice.
The high-level due diligence questions in the Recruitment Fact Find are for internal use only and cover:
How complex is the business structure of the Practice
Financial profile of the business
Types of exposure to known areas of business concern eg exposure to agribusiness, sub-prime mortgages, illiquid investments, high gearing etc
Details of previous Licensee – any concerns re poor reputation etc
Where the adviser will act as an Authorised Representative or Director of another AFSL where one or more of its license conditions are the same as the ADG’s. The ADG must decline the application unless it receives specific approval that the conflict and its potential impact is understood and accepted by stakeholders based on advice from in-house legal (s917C Corporations Act)
Where the adviser will act as an Authorised Representative or Director of another AFSL where none of its license conditions are the same as the ADG being joined, the ADG must determine if it will cross endorse the Authorised representative or decline the application whilst the adviser remains an Authorised representative of another AFSL
Details of compliance history
Complaints and litigation history (if any)
Any other concerns eg physical office security, staff turnover, recent acquisitions or divestments etc
Initial due diligence and fact finding should be undertaken by the licensee before an application is
completed by the applicant/s.
The Licensee Practice Development team (RPM/SDM/RMs) is responsible for any additional
information or fact finding required by the individual Licensees for the purposes of assessing the
Applicant’s cultural fit with the Licensee or for the purposes of segmentation.
Information gathered during this recruitment phase should be provided to the Adviser
Appointments team so a copy can be saved on the Applicant’s file and considered as part of the
overall assessment of the Application.
! It’s important to note that where applicable the Adviser / Practice should not resign from their current authority until new agreements are approved and new agreements are issued.
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1.1.3. Adviser proposal developed Following initial contact with Adviser, the Licensee RPM/SDM/RM negotiates/consults with the Adviser to develop a proposal.
1.1.4. Adviser proposal presented After negotiations have concluded, and provided all parties agree they wish to move forward, the Licensee RPM/SDM/RM provides the proposal to the Adviser, and acts as the ‘go to’ for any additional queries/requests.
This step may also involve a ‘Meet the Manager’ day for Practices with high brokerage/FUM or a group of Practices from the same licensee. This would typically involve key Licensee staff (e.g. General Manager, Practice Development Manager) and key OnePath service stakeholders (e.g. Research, Technical Services, Compliance).
1.1.5. Adviser accepts proposal and a formal letter of offer/terms & conditions sent to Practice Upon Adviser acceptance of the proposal, the Licensee prepares a formal letter of offer and or terms & conditions for the Practice (if applicable). The letter of offer is sent to the Practice and a copy is provided to the Adviser Appointments team. The terms & conditions are included in the CAR agreement which is executed once the application is approved.
1.2. Offer Letter / Terms & Conditions (new Practices only) As outlined in Section 1.1.5. above, upon completion of the initial due diligence and providing there
are no major issues which may pose a risk to the Licensee’s AFSL, the Licensee will issue an Offer
Letter and or Terms & Conditions to the new Practice which outlines any key terms in writing, such
as incentives and next steps involved in the transition. The Letter of Offer and or Terms & conditions
is conditional on the Practice and Adviser/s meeting all of the required standards as outlined in Stage
2: Appointment and is therefore revocable.
1.3. Sending the Application Kit to the Applicant Once a Letter of Offer (Practices only) has been sent and/or approval has been given for the
application process to proceed, the Application Kit must be sent to the Authorised Representative.
This is the responsibility of the RPM/SDM/PDM.
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The Application Kit is sent by the following teams and contains the following documents:
Application Kit FSP RI M3
Responsibility to send to Applicant SDM RPM SDM
Individual and or Corporate Authorised
Representative Application form/s
Research due diligence spreadsheet / New
Adviser Fund Manager Information Spreadsheet
Adviser Systems Registration Process
Questionnaire
N/A
Statutory Declaration (only to be completed if
audit reports cannot be provided by applicant)
The application documents can be located using the following file path:
FSP: Advice Delivery\04. Advice Process and Systems\03. Operations and Payments
\Adviser Appointments & Resignations\Document Control\Applications Forms
RI: Advice Delivery\04. Advice Process and Systems\03. Operations and Payments \Adviser Appointments & Resignations\Document Control\Applications Forms
o Licensee can access via - R:\Practice Development\RPM\RPM Toolkit\RECRUITMENT\New Practice & Adviser Transition Document Requirements
M3: Advice Delivery\04. Advice Process and Systems\03. Operations and Payments
\Adviser Appointments & Resignations\Document Control\Applications Forms
The prospect now moves to Stage 2: Appointment for further assessment.
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2.AUSTRALIAN BANKING ASSOCIATION- REFERENCE CHECKING & INFORMATION SHARING PROTOCOL
This purpose of the ABA Protocol is to promote improved reference checking during the recruitment
process for all new financial advisers.
It is designed to share the performance history of the Financial Advisers focusing on the previous 5
years of their compliance, risk management and advice quality records. Below are the steps for ABA
Protocol process when seeking information from the current subscribing licensee:
1. ABA Protocol Consent Form to be signed by the adviser and returned to the
SDM/PM/RM
2. The signed ABA Protocol Consent Form will be forwarded to the Adviser Appointment
Team with applications and supporting documents.
3. Adviser Appointment Team will forward a copy of the signed ABA Protocol Consent Form
with a request to perform an ABA Reference check to the email inbox CONFIDENTIAL and upload a copy to Adviser Hub.
4. The Risk Liaison Officer will access the email inbox and create a file for the adviser and
enter details in to the ABA Protocols Requests Log. They will then send a request with a
pdf of the signed ABA Protocol Consent Form to the key contact person of the other
Subscribing Licensee.
5. Refer to Appendix for the ABA Protocol Subscribers Key Contact List and email template
for ABA Protocol request
6. The information collected will date back to the previous 5 years of employment with any
of ABA Subscribing Licensees.
7. The ABA Protocol Reference Check Form request is to be completed in writing and
returned by the current licensee within 10 business days of receiving the request.
8. Once the Risk Liaison Officer receives the completed ABA Protocol Reference Check
Form, they will review the completed form . Once reviewed the completed form will be
forwarded in an email to the Adviser Appointments Team with any concerns highlighted
in the email. The Adviser Appointment Team will upload the completed ABA Protocol
Reference Check Form to Adviser Hub under the Onboarding case for the Applicant.
9. Adviser Appointment Team will provide the completed ABA Protocol Reference Check
together with all due diligence documentation to Head of Advice Quality and Assurance
and the Licensee Head for review and final sign off.
PLEASE NOTE: The ABA Protocol Reference Check process applies to advisers employed by a
Subscribing Licensee.
I OJ For more information please refer to Australian Bankers Association website
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Record keeping
The ABA Protocol Reference Checks and ABA Protocol Consent Forms are uploaded to Adviser Hub
by the Adviser Appointment team for record keeping purposes. The Risk Liaison Officer will maintain
records for each adviser request on the Advice Risk Shared Drive
Appointment
Stage 2 is the Appointment stage where due diligence and checks are conducted on all individual
prospects wishing to join an ANZ Aligned Licensee.
This stage comprises both pre-approval steps and authorisation steps, and is the primary
responsibility of the Adviser Appointments & Resignations Officer (referred to as ‘Adviser
Appointments team’ throughout the document), unless otherwise specified.
3.1. Pre-approval steps The pre-approval steps involved in assessing the application of a potential Authorised
Representative with an ANZ Aligned Licensee (the Licensee) consist of the following processes:
Receipt of Application documents: o Checking that all relevant forms have been returned and completed correctly o Checking all supporting documents have been supplied (Identification, Education,
Training & Accreditation documents, last two Compliance Reports, product information)
Confirming receipt of Application Form with RPM/SDM/PDM
Setting up a new Adviser File (both in Outlook and windows explorer)
Adding Applicant’s details to the internal registers (planner movements spreadsheet)
Completing minimum due diligence checks, namely: o RG146 Compliance: Adviser Development team assesses the Applicant's educational
qualifications for RG146 compliance o Recommended Product Review: Research Team assesses the Applicant's product
listing against the current APL (if applicable) o Advice Assurance Review: Advice Assurance reviews two previous audit reports
(excluding green advisers) o Conducting background checks: Adviser Appointments team conducts Police, Credit,
Bankruptcy, ASIC, Financial Adviser Register (FAR), APRA, Sanctions, internet, social media, and where applicable, Work Entitlement Checks
o ABA Protocol Reference Check Risk Liaison Officer will perform the ABA Protocol process. For additional information please refer to ABA Subscribing Licensees are located on ABA Website.
o Reference checks: A minimum of 2 professional references, including previous licensee (if applicable) must be completed by the RPM/SDM/PDM.
Completing any other Licensee specific processes (if applicable)
Additional background checks are completed on the Practice by the Adviser Appointments team, including a Company credit check (VEDA), ABR review (to check the ABN, if the business is registered to receive GST and if there is a trading name) and an APRA disqualification check. Information on the Trustees of a Trust (if applicable) must also be
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collected. Checking that all minimum due diligence checks have been completed and appropriate sign-offs obtained
Forwarding the file to the Licensee General Manager (or delegate) and Head of Advice Quality and Assurance (or delegate) for final approval (this can be done either in soft copy email, or providing the hard copy file for review)
3.1.1. Application for Authority
3.1.1.a) Receipt of Application Documents
Each application must be reviewed for completeness by the RPM/SDM/PDM prior to submission to
the Adviser Appointments Team
! Note: if minimum information is not provided, and the Applicant has not been granted a waiver or exemption regarding this information then the Application process cannot continue.
! The exception is if an existing Authorised Representative is applying to join an existing practice within the same Licensee. In these circumstances no additional checks are required (assuming all minimum standards and competencies have been met and are up-to-date), however, sign off by the Licensee General Manager (or delegate) must be granted prior to the new agreements being issued.
3.1.1.b) Contacting SDM / RPM / PDM
Contact the SDM/RPM/PDM via an email containing the following information:
1. Confirm receipt of the Applicant’s application documents 2. List any information or documents that are missing and may cause delays in the
Appointment process 3. Inform them to ask the Applicant to forward any outstanding documents (if applicable) to
you as soon as possible so the Appointment process is not delayed further 4. Inform the SDM/RPM/PDM that you will keep them informed of the progress of the
Applicant’s application and will confirm any outstanding documents being received (if necessary) It is the responsibility of the RPM/SDM/PDM to keep the Applicant informed of the progress of their application
5. Ask them to confirm the next steps and manage the Adviser’s expectations in regards to the process as outlined in Section 2.1.1.c).
3.1.1.c) Contacting Applicant
To give the Applicant a better understanding of the Appointment process the RPM/SDM/PDM team
should inform the Applicant of the following key points, including:
Confirming receipt of the Application documents
If the Applicant has not completed the documents as required or has not submitted all
supporting Education, Training & Accreditation documents or Compliance Reports, request
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that they attend to this immediately and forward to you as soon as possible so as not to hold
up the Appointment process.
The estimated timeframe from the date of receipt of the complete set of application
documents to a final approval is generally at least three to six weeks.
They will be kept informed of the progress of their Application and you will confirm any
outstanding documents being received (if necessary).
The Licensee needs to ensure that appropriate due diligence has been conducted and final
sign-off is received from the appropriate stakeholders prior to a potential new Adviser
resigning from their previous licensee.
The background checks that will be performed (Police, Credit & Bankruptcy, ASIC, FAR, APRA, Sanctions screening, internet & social media, References)
o It’s important for them to submit their details for the police check as early as possible
as authorisation cannot be made until a clean police check has been returned by the
Federal Police, which can take 1 to 3 weeks (approximately).
Adviser Development Team to review Qualifications for RG146 compliance, and specialist Licensee accreditation (if applicable)
Research Team to assess the Applicant's product listing against the current APL (if transferring book)
Advice Assurance Team to review previous two compliance audits (unless green adviser)
Enhanced Due Diligence may require an onsite or desk review of client files.
Licensee General Manager (or delegate) and Head of Advice Quality and Assurance (or delegate) will review file for approval
Explain that set-up of software, stationery and other services etc will occur in Stage 3 Set-up & Induction if and when they are approved, however, encourage them to submit the following as soon as possible so that preparation steps can commence: o Adviser Systems Registration process questionnaire – to assist with Xplan set-up and
data conversion process o Research due diligence spreadsheet / New Adviser Fund Manager Information
spreadsheet - this includes product listing and Adviser Codes so that Client/brokerage transition preparation steps can be completed.
3.1.1.d) Setting up a new Adviser File
Set up a new softcopy Adviser folder go to:
Advice delivery\04. Advice Process and Systems\03. Operations and Payments\Appointments &
Resignations\ Due Diligence\Adviser Due Diligence
Copy and paste the template file structure re-naming it with the relevant name under the licensee
group. The file should contain the following sub headings:
Adviser Application
Brokerage
Compliance
Correspondence
Qualifications
References
Research Review
Social Media Checks
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Print out the Authorised Representative Appointment Checklist and place with the Adviser
Application. Checklist Location: Advice Delivery\04. Advice Process and Systems\03. Operations and
Payments\Appointments & Resignations\Authorisation\Authorisation Administration\Appointment
Tools\ADG. File documents received from Applicant in relevant sections of Adviser File
If applicable set up a soft copy file for Practices. Go to:
Advice Delivery\04. Advice Process and Systems\03. Operations and Payments\Appointments &
Resignations\ Due Diligence\Practice Due Diligence
Copy and paste the template file structure re-naming it with the relevant name under the licensee
group. The file should contain the following sub headings:
Brokerage
Compliance
Correspondence
Financials
Marketing
Practice Application
Product Review
Ensure copies of all information, documents and sign-offs in relation to an CAR Application are saved
in this directory.
3.1.1.e) Adding the Applicant’s details to internal registers
Add the Applicant’s details to the following internal registers:
Advice Delivery\04. Advice Process and Systems\03. Operations and Payments \Adviser
Appointments & Resignations\Reporting\Planner Movements
Find the “Listing and Stats” spreadsheet for the relevant year and month.
3.1.2. Minimum standards and competencies
A number of due diligence and background checks are performed by teams within Advice Delivery.
In the event the minimum standard cannot be obtained from the potential Applicant (Adviser),
prescribed escalation steps need to be followed.
A summary of these escalation steps are as follows –
Due Diligence/Background
Check
Exception noted in due diligence/background
check
Escalation required
Adviser qualifications Must confirm in writing Applicant’s qualifications
have been reviewed. Outcome of the review –
Satisfactory – requirements met
Adviser Development
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Further information required / review required – documents/evidence are incomplete
Declined/Approved subject to approval – recommendations to remediate gap or application may be declined
Licensee specialist
accreditation
Must confirm in writing Applicant’s specialist
accreditation qualifications have been reviewed.
Outcome of the review –
Satisfactory – requirements met
Further information required / review required – documents/evidence are incomplete
Declined/Approved subject to approval – recommendations to remediate gap or application may be declined
Adviser Development
Advice Assurance Review Must confirm in writing Applicant’s previous
compliance audit reports have been reviewed.
Outcome of the review –
Satisfactory – no apparent compliance issues
Enhanced due diligence required – compliance issues identified and further investigation is required
Advice Assurance
team
Advice Assurance Review –
previous compliance audit
reports unable to be provided
Applicant must complete a Statutory Declaration
Waiver must be obtained from Licensee General Manager and Head of Advice Quality and Assurance
Licensee General
Manager and Head of
Advice Quality and
Assurance
In the event the
parties don’t agree,
escalate to General
Manager, Aligned
Licensee and Advice
Standards.
Police Check In the event of a disclosable outcome the matter must be referred to Head of Advice Risk and Compliance and Group Investigations
Head of Advice Risk
and Compliance and
Group Investigations
Credit and Bankruptcy Check In the event credit rating is below 500 or there are adverse results, notify Licensee General Manager and Head of Advice Quality and Assurance
Licensee General
Manager and Head of
Advice Quality and
Assurance
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ASIC Check Where the applicant will act as an Authorised Representative or a Director of more than one AFSL, provide search results to Licensee General Manager and Head of Advice Quality and Assurance
Licensee General
Manager and Head of
Advice Quality and
Assurance
Banned and Disqualified
Register
Any exceptions identified must be notified
to Licensee General Manager and Head of
Advice Quality and Assurance
N/A – Potential
candidate is unable to
be onboarded
Tax Practitioners Board (TPB) Applicant is not registered with the TPB
(note that the applicant can still be on
boarded only if the Practice agrees to the
Corporate Advice Model and supervisory
obligations. The Licence needs to confirm
these arrangements via completion of the
Corporate Advice Model Supervisory
Checklist)
Licensee
Supervisor/Licensee
General Manager
ASIC Enforceable
Undertakings Register
Any exceptions identified must be notified
to Licensee General Manager, Head of
Advice Quality and Assurance and Head of
Risk Wealth Advice and Distribution
N/A – Potential
candidate is unable to
be onboarded
Financial Advisers Register
(FAR) Any exceptions identified must be notified
to Licensee General Manager and Head of
Advice Quality and Assurance
Licensee General
Manager and Head of
Advice Quality and
Assurance
APRA check – Enforceable
Undertaking and
Disqualification Check
Any exceptions identified must be notified
to Licensee General Manager and Head of
Advice Quality and Assurance
Licensee General
Manager and Head of
Advice Quality and
Assurance
Sanctions Check Any exceptions must be notified to the
Wealth MLRO, Licensee General Manager and Head of Advice Quality and Assurance
Wealth MLRO, Licensee General Manager and Head of Advice Quality and Assurance
Internet and social media
check Any discrepancies identified must be notified to Licensee General Manager and Head of Advice Quality and Assurance
Licensee General
Manager and Head of
Advice Quality and
Assurance
ANZ.800.390.0019
ANZ.800.390.0020
Internal use only
•
•
•
•
Applicant is not entitled to work in
Australia
Applicant unable to provide certified true
copies of 100pt identification
Any concerns identified must notified to
Licensee General Manager and Head of
Advice Quality and Assurance
If an Applicant fails the test, a decision is required by the Licensee General Manager if on boarding the applicant should continue
• Alternatively, the Licensee may provide a waiver or authorisation conditional on completion within a certain timeframe. The waiver must be signed by the Licensee General Manager and Head of Advice Quality and Assurance
Licensee General
Manager and Head of
Advice Quality and
Assurance
Licensee General
Manager and Head of
Advice Quality and
Assurance
Licensee General
Manager and Head of
Advice Quality and
Assurance
Licensee General
Manager
3.1.2.a) Assessing the Applicant's Educational Qualifications for RG146 compliance
Send the Applicant's qualifications, educational details, and CPO history for the last 3 years to the
Adviser Development team to review to assess for RG146
compliance. CPO history should include TASA hours for advisers who are already TPB registered .
The Adviser Development team must confirm in writing that they have reviewed the Applicant's
qualifications, including the outcome of their review and whether the outcome is:
Procedure
• Satisfactory- all requirements met- where evidence of qualifications for all RG146
knowledge areas and skills is provided and currency of knowledge has been demonstrated;
OR
• Further information I review required- where documents/evidence provided are
incomplete; OR
• Declined/Approved subject to recommendation- where gaps are identified in
qualifications or CPO history, recommendations will be made to either remediate that gap
OR the application may be declined.
Page 17 of 68 Version 5.0 December 2017
I
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A copy of this written confirmation must be kept in the Applicant’s file under ‘Qualifications’.
Licensee Specialist Accreditation
Review the Application and supporting documents to determine whether the Applicant wishes to be
accredited in any specialist advice areas. If so, forward details to Adviser Development team for
specialist accreditation assessment.
The Adviser Development team must confirm in writing that they have reviewed the Applicant’s
specialist accreditation qualifications, including the outcome of their review and whether the
outcome is:
Satisfactory – all requirements met – where evidence of accreditation is provided and
currency of knowledge has been demonstrated; OR
Further information / review required – where documents/evidence provided are
incomplete; OR
Declined/Approved subject to recommendation – where gaps are identified in
accreditations or CPD history, recommendations will be made to either remediate that gap
OR the application may be declined
A copy of this written confirmation must be kept in the Applicant’s file under ‘Qualifications’.
3.1.2.b) Review of Recommended Products by CIO (if transferring with a book of clients)
When an Adviser and/or Practice is transitioning a book of business the CIO team is responsible for
the review of the products against the Licensee’s Approved Product List to establish if there are any
products transitioning to the Licensee’s AFSL, which may be considered higher risk.
This review must be undertaken prior to the new Adviser/Practice joining the group. The CIO team
must attest to having completed this review by confirming in writing to the RPM/SDM/PDMs and the
Adviser Appointments team. In this review the CIO team will advise if they have any major concerns
with the transitioning book.
All reports are forwarded to the Risk Adviser together with the Recruitment Fact Find and Advice
Assurance review for assessment of the due diligence level required. (i.e. standard or enhanced).
3.1.2.c) Advice Assurance Review
Review of prior Compliance Audit Report
The Advice Assurance team is responsible for the review of the Applicant’s previous two compliance
audit reports to ensure there are no issues or concerns which may lead to a client complaint in the
Applicant’s previous compliance history. This team is also responsible for conducting the enhanced
due diligence steps (when required).
The Advice Assurance team must complete their review and provide a written recommendation as
to whether Enhanced Due Diligence should occur (via a 5 files review per Adviser) or otherwise. This
should be communicated in writing to the RPM/SDM/PDMs, the Risk Adviser and the Adviser
Appointments team.
ANZ.800.390.0021
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This review must be undertaken prior to the new Adviser/Practice joining the group and the Advice
Assurance team must attest to having completed this review by confirming in writing to the Adviser
Appointments team (informing the Risk Advice) and advising whether the outcome is:
Satisfactory – no apparent compliance issues based on compliance reports provided; OR
Enhanced due diligence required – compliance issues identified and further
investigation via client file review or licensee intervention required – Advice Assurance
team to provide details.
If the Applicant is unable to provide copies of two previous compliance audits then the following
applies:
the Applicant must provide a reason why they cannot provide audit reports and complete a
Statutory Declaration, which states the following:
“I declare that during my employment as an Authorised Representative of
…….…………………………………(Licensee), I had reviews conducted and have complied with the provisions
of the financial services law, industry codes and internal organisational standards. There have been
no formal complaints made against me registered in my internal complaints register, nor have any
breaches been reported to ASIC under s912D. Where I have breached the above stated standards and
legislation, I have disclosed these in writing to <Licensee>.”; and
Enhanced due diligence must be undertaken via a review and assessment by the Advice
Assurance team of a minimum of 5 client files (per adviser) ahead of the appointment. The
Licensee General Manager (or delegate) and Head of Advice Quality and Assurance must be
notified of this prior to commencement of the Enhanced due diligence.
In the event that the Applicant has only been in the industry for a limited time and has not had two
(2) compliance audit reports completed and / or has no client files that can be reviewed then a the
Applicant must complete a Statutory Declaration (as above) and a waiver must be obtained from the
Licensee General Manager (or delegate) and the Head of Advice Quality and Assurance (or delegate)
(with the Risk Adviser informed).
A template Statutory Declaration form is saved here:
Advice Delivery\04. Advice Process & Systems\03. Operations & Payments\Adviser
Appointments & Resignations\Authorisation\Statutory Declaration
Enhanced Due Diligence Review
In the following instances Enhanced due diligence must be undertaken via a review and assessment
by the Advice Assurance team of a minimum of 5client files (per Adviser) ahead of the appointment:
Where the Recruitment Fact Find due diligence assessment has identified that an enhanced
due diligence review is required;
The outcome of the Recommended Product Review is ‘Further information / review
recommended’ or the outcome of the Advice Assurance Review is ‘Enhanced due diligence
required’. Or
As part of the overall assessment of application completed by the Risk Adviser (refer to the
Risk Adviser section).
ANZ.800.390.0022
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If a concern is raised during the file review process, then the review should be broadened to ensure
appropriate due diligence. This review is carried out by the Advice Assurance Team via an on-site
review or remotely through Xplan (if applicable). This review may also cover the following area:
Complaints register and full details of any complaint
Incident/Breach Register and full details of any incident
Conflict of Interest Register
Alternative Remuneration Register
Business set up
Referral Arrangements/ Comingling
Depending on the business risks identified, there may be a requirement to conduct a practice focused Enhanced due diligence.
On completion of the Enhanced due diligence review, the Advice Assurance Team will provide a
report on their findings to the Risk Adviser, Licensee General Manager (or delegate) and the Head of
Advice Quality and Assurance (or delegate) to determine whether further action needs to occur or
the appointment needs to be rejected.
If Enhanced due diligence and access to previous client files or compliance reports is not possible,
provide the details to the Licensee General Manager (or delegate) and the Head of Advice Quality
and Assurance (or delegate) for advice on next steps and whether a waiver can be approved in this
instance.
3.1.2.d) Background checks
Police check
As part of the Application Process, Applicants must undergo a Police check. The standard process is
that Authorised Representatives must not be appointed until the return of a clean police check.
In some instances, however, the Applicant can be appointed on a conditional basis prior to the Police
Check clearing provided the following conditions are met:
A minimum period of five business days has passed after receipt of the police check Interim Report notification
Approval has been given by the Licensee General Manager (or delegate) and the Head of Advice Quality and Assurance (or delegate) )
the Adviser has signed a Statutory Declaration.
The Police checks are lodged through First Advantage and conducted by the Australian Federal
Police. Police checks are valid for 6 months and the cost of the check is covered by the Licensee. A
First Advantage police check case is lodged online at: https://cspi.fadv.com/cspi/
ANZ.800.390.0023
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To lodge the police check case:
The Applicant is then sent an automated email with logon details so that they can logon to the site
and complete the relevant documents in order for the Police check to be completed. Therefore it is
essential that the email address is correct for the adviser to proceed.
The Australian Federal Police will send back a Certificate confirming whether or not there are any
disclosable outcomes.
! Crucial: It generally takes up to 1 week for the Australian Federal Police to send back the Certificate when using First Advantage, however, if the check goes into further investigation the process can take longer so it is important to lodge the police check case ASAP.
In the event of a disclosable outcome the matter must be referred to the Head of Advice Risk
Compliance (or delegate) for review and further reference to Group Investigations. A Police Check
Decision Outcome form must be completed and provided together with the decision from Group
Investigations and the National Police Certificate to the Licensee for acceptance and sign-off. Place a
copy of all Police check documents in the Applicant’s File in the “Compliance” section.
Head of Advice Quality and Assurance Head of Advice Quality and Assurance
SBU: select relevant dealer group Email Template: select ‘Invitation Email – OnePath’ Package: select ‘Standard Criminal Check v1’
Enter the applicants first & last names, email address, and
Cost Code (this is either FSP, RI, M3, etc).
Select ‘Order Case’
ANZ.800.390.0024
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Credit & Bankruptcy check
A Credit & Bankruptcy check on the Applicant is performed through Veda Advantage. Veda's
Individual Trading History Reports provide you with credit information on an individual along with a
summary of key credit and adverse information on each alias or related organisation. For example,
an Individual Commercial Trading History Report includes individual identity details, commercial
credit information, trading history summary table and a summary of business relationships.
Visit the Veda website https://www.vedacheck.com Enter your Username and password (refer table below)
On the left hand side of the Home page, select "Working with Individuals"
For Type of Information you require, select "VedaScore Financial Commerical 1.1"
Type of Credit you are providing will be "Commercial"
Input the following mandatory fields for the Applicant: o Surname o First Name o Gender o Birthdate o Drivers Licence number o Current address (residential)
Enter the following mandatory credit enquiry data: o Account type: 30 day account o Amount: $0 o Role: Principal
Click on the Submit button to process the request
Save the PDF Report in the Adviser's file
The Licensee will be invoiced for any credit checks conducted
Make a note on the Appointment Checklist if the credit rating is below average (in the 500s
and lower) or if there are Adverse results in the summary and ensure that the Licensee
General Manager (or delegate) and the Head of Advice Quality and Assurance (or delegate)
is notified.
ASIC checks
Authorized Representative Register
To identify Applicant’s existing Licensee, go to the ASIC website:
https://connectonline.asic.gov.au/RegistrySearch/faces/landing/ProfessionalRegisters.jspx?_adf.ctrl-
state=1kmezcfzc_13
Enter Applicant's Surname or ASIC Authorised Representative Number
Select the "Australian Financial Services Authorised Representative" Register
Click the Search button
Any existing Licensee details will appear in the results section
Screen capture the results page and place in the Adviser File in the “Compliance” section
Where the Applicant will act as an Authorised Representative or a Director of more than one AFSL, search for each AFSL number and print out the latest “License Authorisation Conditions” of the other Licensee(s). This must also be flagged with Compliance & the Licensee General Manager (or delegate).
ANZ.800.390.0025
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Australian Credit Representative Register (if applicable)
Go to the Australian Credit Representative Register: https://connectonline.asic.gov.au/RegistrySearch/faces/landing/ProfessionalRegisters.jspx?_adf.ctrl-state=1kmezcfzc_13
Enter Applicant's Surname or ASIC Authorised Representative Number
Select the “Credit Representative” Register then Click "Search"
Screen capture the results and place in Adviser File in “Compliance” section
Banned & Disqualified Register
To check the Banned & Disqualified Register, return to the ASIC Connect page of the ASIC website:
At mid page there is a drop down called “Select Register”, select "Banned & Disqualified"
Register.
Enter Applicant’s Surname and Given Name then Click "Go"
Screen capture the results and place in the Adviser File in “Compliance” section
Tax Practitioners Board (TPB)
All advisers must be registered with the TPB before they can be authorised under any of the
Licensees. If the adviser is not registered, they must register themselves and provide evidence of this
(i.e. TPB certificate) before they can be authorised on ASIC.
To check if an adviser is registered with the TPB go to:
http://www.tpb.gov.au/TPB/Finding_and_using_a_practitioner/Search_the_register/tpb/agent_regi
ster.aspx
Enter the advisers name into the search field and click “Search”
Take a screen shot of the results and save in the advisers due diligence folder
Enforceable Undertakings Register
To check the Enforceable Undertakings Register go to:
http://www.asic.gov.au/online-services/search-asics-registers/additional-searches/enforceable-
undertakings-register/
Control F on this page, do not use the page’s search function
Enter Applicant’s Surname and Given Name then Click "Go"
Screen capture the results and place in Adviser File in “Compliance” section
Financial Advisers Register (FAR)
To check the Financial Adviser Register go to: https://www.moneysmart.gov.au/investing/financial-
advice/financial-advisers-register
Type in the Applicant’s name
Tick the Terms & Conditions check box
Click ‘Search’
Screen capture the results and place in the Adviser File in “Compliance” section
ANZ.800.390.0026
ANZ.800.390.0027
Internal use only
APRA check
An APRA disqualification check must also be conducted on the Applicant to ensure they are not, or
have not been banned by APRA. Go to:
http://www.apra.gov.au/crossindustry/pages/disqualification-register.aspx
• Control F on this page
• Search the APRA disqualification register by surname and/or entity name.
Sanctions check Sanctions (also known as embargoes) are steps taken by a national government or international
organisation intended to bring about changes in the policy or behaviour of others. They are often
imposed on countries to prevent crimes against humanity, financing of terrorists and terrorist acts,
the sale of weapons of mass destruction, illegal arms trading and narcotics trafficking.
ANZ Economic & Trade Sanctions Policy aims to protect ANZ's reputation and manage its risk
globally in relation its sanctions obligations.
Sanctions screening must be conducted on all new Advisers applying to become an Authorised
Representative of an ANZ Aligned Licensee. It is illegal for us to do business with anyone on the
Sanctions list.
This check is conducted via World-Check.
1. Go to: http://www.world-check.com/
2. Login using ADG username and password as follows:
o Username:
o Password:
• Enter the advisers full name into Worldcheck
• If 'hits' are displayed check the category. If the Worldcheck category is "Political Individual"
these can be ignored and no further action is required. For all other "hits" compare the DOB to the advisers DOB. If the difference in DOBs is greater than 1 year (plus or minus) then this can be treated as de-identified and no further action is required.
• If the DOB difference is less than 1 year, or no DOBis available refer to Wealth MLRO or email 'AML Compliance') to obtain further guidance.
3. If it is determined that the person with the 'hit' is the same person as the adviser, ensure
that the Wealth MLRO is informed and await instructions. Also notify the Licensee General
Manager and Head of Advice Quality and Assurance (or delegate) if any discrepancies are
found.
• If it is determined that the person with the 'hit' is not the same then the application can
proceed.
• Appropriate records need to be retained to evidence the decision making processes
Screening of all existing Authorised Representatives must also be conducted on an ongoing basis.
This is currently done weekly by sending a consolidated spreadsheet of all existing Authorised
Representatives across all ADG Licensees to the ANZ FlO Office every Friday. This is coordinated
centrally on behalf of the ADGs.
Procedure Page 24 of 68 Version 5.0 December 2017
Procedure Page 25 of 68 Version 5.0 December 2017
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This spreadsheet can be found: \Adviser Appointments & Resignations \ Reporting \ Sanctions
Checking\Running List
Internet & social media check
An internet Google search (www.google.com.au) must be conducted on the Applicant to check for:
Any evidence of illegal / criminal activity
Inappropriate content on social media sites ie Facebook, Twitter, LinkedIn
Areas that may require a specialist review such as advice, newsletters, articles, blogs either via newsletters, or other social media including YouTube etc.
Relationships that haven’t been disclosed (where a conflict could exist, eg property developers, credit providers, Stock brokers or other relationships)
Affiliations/ past conduct that are inconsistent with what would be acceptable to licensee.
Media quotes or reports that could give rise to concerns for the licensee.
Type the Applicant’s name into the search engine and include catch words, examples such as:
Gambling
Property
Gearing
SMSF
FX (forex)
Agribusiness
Borrowing
Where the Applicant has a common name include the Adviser’s old dealer group name, or their Business name.
If any discrepancies are identified during this search they must be printed off and provided to the Licensee General Manager (or delegate) and Head of Advice Quality and Assurance (or delegate) for review as part of appointment process.
Entitlement to Work in Australia check
Adviser Appointments team must check the nationality of the Applicant to ensure they are entitled
to work in Australia. This is done by checking the Applicant’s passport, birth certificate or marriage
certificate for Australian citizenship.
If the Applicant is not an Australian Citizen then check with the Department of Immigration and
Citizenship to ensure that the Applicant holds a current working visa or has Australian residency. This
check is done using the Visa Entitlement Verification Online (VEVO) system, a free internet service.
Before undertaking a search in VEVO you will need to request to see the Applicant's foreign
passport. You should check the personal details page of their passport to verify the person's identity.
You will then need to obtain their permission to check their visa details. Only holders of non-
Australian passports can be checked in VEVO.
ANZ.800.390.0028
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You will firstly need to register to use VEVO (as accounts expire after a relatively short period of
time). To register for VEVO, use the following link: http://www.immi.gov.au/e_visa/vevo.htm
Select "VEVO for Organisations"
Select "Register for VEVO"
Press "Register Now" and "I agree to the terms and conditions"
Complete the registration details including business and contact details and ABN
For VEVO Category, select "Work entitlements"
For Industry type, select "Finance and insurance"
For Description of industry, enter "Financial Planning Dealer Group"
When you have submitted the registration request, you will receive an email in the next few days.
Once you have obtained your Logon ID and password, logon to VEVO using the above link.
Select "VEVO for Organisations"
Select "Logon to VEVO"
Press "Query Now" and "I agree to the terms and conditions"
Enter Logon ID and password
Using the Applicant's passport, you can enter the following information into the VEVO system:
o name o date of birth o passport number o passport country of issue
Save a copy of the work entitlement confirmation page and place in the Adviser's file.
Identification check
When reviewing the Applicant’s Application form and supporting documents, the Adviser
Appointments team must complete a 100 points identification check. The Adviser identification
documents are to satisfy AML requirements and copies of identification must be certified as true
copies in line with ANZ’s list of authorised persons, which includes:
A Justice of the Peace
An officer / employee with 2 or more continuous years of service with one or more Australian financial institutions, finance company or AFSL holder. (e.g. ANZ, NAB, Elders, M3, etc)
An accountant who is a member of the ICAA, CPA or NIA.
An Applicant can easily provide 100 points identification by providing a combination of the following
documents:
copy of Passport (70 points)
Australian Driver’s License (40 points)
Copy of full Birth certificate (not extract) (70 points)
Medicare card (25 points)
Credit or Account card (25 points)
Utility Bill (20 points).
ANZ.800.390.0029
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For more information on Primary or Secondary documents for identification purposes, refer to the
Identification Check – 100 points checklist can be found:
03. Operations & Payments\ Appointments & Resignations\Authorisation\Authorisation
Administration\Appointment Tools\ADG
Copies of this identification must be kept with the Adviser’s file under ‘Compliance’.
Note: Where there are non-AR directors, certain background checks need to be completed for these
directors. These checks include:
Search of the ASIC Banned & Disqualified Register*, the Authorised Representative Register*, the Enforceable Undertakings Register*, the Financial Advisers Register (FAR), and the Authorised Credit Representative Register (if applicable)*
Search of the APRA Disqualification Register*
Sanctions check*
3.1.2.e) Reference Checks
A minimum of two (2) references familiar with the Applicant’s ability to provide advice must be provided. The criteria for the references are as follows:
References must be professional business references.
One referee is required from the Applicant’s previous Licensee (if applicable, eg green adviser would not have a Licensee reference). The application can be approved subject to a satisfactory Licensee reference being obtained prior to Agreements being issued. This is in situations where the applicant does not want their current Licensee made aware of their intention to resign.
Business referees must be Australian Residents and have known the Applicant for a minimum of 2 years.
Business references must be obtained verbally using the Licensee’s reference checking form
Licensee references can be provided verbally using the Licensee reference checking form or via a written reference
Referees cannot be family members or other members of the Applicant’s business or members of the recruiting Licensee’s staff (eg Regional Managers, SDMs, RPMs, product BDMs) due to potential conflicts of interest.
Reference Checks must be performed as part of the Application process, as follows:
Ensure that the relevant Reference checking consent forms have been signed by the Applicant (Refer table below for specific sections that must be signed in each Licensee’s Application forms)
Send an email to the person responsible for conducting the Licensee Reference Checks (refer table below) requesting that they contact the referees supplied by the Applicant and record the referee’s answers and comments on the Work Reference Check Form.
Attach a copy of the Work Reference Check Form found at: Advice Delivery\04. Advice Process & Systems\03. Adviser Appointments & Resignations\Authorisation\Authorisation Administration\Appointment Tools (under the relevant licensee folder)
Upon receipt of the completed Reference Check Form, place in the Applicant’s Adviser File under ‘References’.
ANZ.800.390.0030
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Note: The reference checks must be completed by the Licensee’s RPM/SDM/PDM/RM and the reference interview is in line with Standards Australia guidelines (AS 4811—2006) Employment Screening and the associated Handbook, HB 323-2007, Employment Screening Handbook.
3.1.3. Additional Licensee specific procedures
Technical Competency test (RI Advice only)
RI requires Applicants to complete an industry knowledge test. The test is conducted via Kaplan
Professional Kudos Testing. Should the Applicant fail this test, a decision is required by the Licensee
as to whether onboarding the applicant should continue. Alternatively the Licensee may provide a
waiver or conditional appointment on the basis that any gaps are addressed in the Advisers training
plan.
This test can be waived if the Applicant is known to have competent industry knowledge.
Alternatively an Applicant can be given a conditional authorisation, which allows them to complete
the test within 30 days of appointment. The waiver or conditional appointment must be signed by
the Licensee General Manager (or delegate) and the Head of Advice Quality and Assurance (or
delegate) and kept on file.
3.1.4. Additional checks for new Practices only The following additional pre-approval steps must be conducted on new Practices:
3.1.4.a) Review of financials
As part of the due diligence on a new Practice, the Licensee requires confirmation that the entity
applying for a Corporate Authority is financially sound. This is captured via a question in the
Corporate Application form regarding confirmation that the key attributes of the entity are
financially sound. As part of the Application form, sign-off from two (2) Directors (if applicable)
acting on behalf of the entity is required.
RI Only
RI Advice requires the Senior National Manager Advice & Operations of the Licensee to review the
most recent Profit and Loss statement of the company to ensure it is a profitable business. The
Senior National Manager Advice & Operations must sign off that they have completed this review.
3.1.4.b) Practice background checks
Company Credit check
A Credit & Bankruptcy Check on the Company is performed through Veda Advantage. To request the
report:
Visit the Veda website https://www.vedacheck.com
Enter your Username and password
On the left hand side of the Home page, select " Organisations"
Input the following mandatory fields for the Applicant:
ANZ.800.390.0031
Procedure Page 29 of 68 Version 5.0 December 2017
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o ABN or ACN o Account type: 30 Day account o Amount: $0 o Role: Principal
Click on the Submit button to process the request
From Product List drop down, Select “Company Business Trading History” and GO
Save the PDF report in the Practice file
The Licensee will be invoiced for any credit checks conducted
Make a note on the Appointment Checklist if the credit rating is below average (in the yellow and
lower) or if there are adverse results in the summary. Refer to this report to determine Company
Directorship for the drafting of the Corporate Agreements.
ABN review
If a new applicant wishes to come on board with their own Practice, an ABN search must be done to
ensure that the business is registered with the Government and is registered to receive GST. To
perform this search you go to: http://www.abr.business.gov.au/Index.aspx
Type in the ABN that has been provided by the applicant and click on the “Search” button. The details of the company will then show up. Take a screen capture of the results (include any trading names) and save in the Practice due diligence file.
APRA Disqualification Check
An APRA disqualification check must also be conducted on the Practice (entity). To perform the
APRA disqualification check, use the following link:
http://www.apra.gov.au/crossindustry/pages/disqualification-register.aspx
Search the APRA disqualification register by entity name. Take a screen shot of the results and save
in the Practice due diligence file.
1.1.2.b) Risk Adviser Review
The Recruitment Fact Find must be sent to the Risk Adviser (or delegate) to assess the level of due diligence required, namely:
Standard; or
Enhanced – client file review/ and or practice review
The following documentation must be included for the recruitment fact find review to be completed:
Recruitment Fact Find
Application form
CIO review (where applicable)
Advice Assurance review
Waivers (where applicable)
Internet and social Media Check
ANZ.800.390.0032
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If enhanced due diligence is required then notification, together with the reasons, must be sent to the Licensee General Manager (or delegate). Adviser Appointments is also notified of the recruitment fact find review findings. If the Licensee wishes to proceed with application, the Advice Assurance team is notified and a review of 5 client files (per Adviser) must be completed.
The outcome of this review must be provided in writing to the Licensee General Manager and the Head of Advice Quality and Assurance (or delegate) to determine whether the Applicant is suitable to move forward in the process.
3.1.4.c) Marketing Materials & Website
All Practices must adhere to the Licensee’s Marketing and Professional Standards guidelines, found
on respective intranet sites. This also applies to the Practice’s website.
Send an email to the Marketing team requesting that they provide details of the Licensee’s brand
guidelines to the practice (save a copy of this request in the Practice due diligence folder). During the
pre-authorisation period, Adviser Appointments will email the Practice details to the Marketing
team, who will email a copy of the brand guidelines to the adviser and request a copy of their
licensee branded material, once they have been authorised.
Following authorisation, it is up to the adviser to email their marketing materials and website to the
Marketing team to demonstrate that they have read, understood and implemented the required
brand guidelines in their Practice.
Note: New practices using Licensee branding are provided with design templates during the set-up
process, which ensures adherence to Licensee standards.
Send an email to the Marketing team requesting that they provide details of the Licensee’s
brand and marketing standards to the practice, and coordinate a review of the practice’s
collateral and website with the Professional Standards team. A copy of this can be found
Appointments & Resignations\Authorisation\Email Templates\Appointments.
File a copy of the confirmation from marketing that this will be done on the Applicant’s file.
3.1.5. Waivers or variations to standard appointment process If a waiver or request for a variation to the standard Appointment process is received for an
Applicant, these requests must be forwarded to both the General Manager of the Licensee (or
delegate) and the Head of Advice Quality and Assurance (or delegate) ADG for approval. Ensure a
copy of the waiver/variation approval by both parties is kept on the Applicant’s file (hard or soft-
copy).
! If approval of the waiver or variation is not received by both parties then the standard appointment process must be followed.
! If the Applicant’s previous Licensee is PIS, AAA, Storm or AFS, additional questions and due diligence may be required above the standard appointment process. Refer any
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cases to the Licensee General Manager (or delegate) and the Head of Advice Quality and Assurance (or delegate) for further guidance on what is required in these circumstances.
3.1.6. Subsidiary / Non-controlled entity arrangements ANZ’s Standard and Procedures outlined in regards to ADG Authorised Representative Recruitment
and Authorisation also apply to subsidiary / non-controlled entity arrangements with ANZ eg Elders
Financial Planning.
In instances where a waiver or variation from the standard procedure is requested the final sign-off
lies with the Licensee, and sign-off by the Head of Advice Quality and Assurance (or delegate) is not
required. In these instances the subsidiary / non-controlled entity must accept the risks associated
with them accepting any exceptions. This should also be escalated to the Managing Director – Advice
& Open Markets. Where appointment occurs these need to be referred to the Advice Business
Controls & Governance team to capture in reporting and escalate.
3.1.7. Due diligence sign off Once all of the pre-approval steps above have been completed, provide the files and checklist
(Adviser File and/or Practice File) to the Adviser Appointments team supervisor (or delegate) for
review of due diligence completeness and sign-off. The Adviser Appointments team supervisor must
sign-off on the Appointment Checklist that all steps in the process have been satisfactorily completed.
3.1.8. Final approval The Application must now be submitted to the Licensee General Manager (or delegate) and the
Head of Advice Quality and Assurance (or delegate) for final approval. The process is as follows:
1. Standard applications with no waivers or variations
Email Head of Advice Quality and Assurance (or delegate) the completed and signed Appointment checklist
Include Licensee sign off in email (either on checklist or attached email approval)
Copy Licensee General Manager (or delegate) in on the email
The Head of Advice Quality and Assurance (or delegate) must confirm back in writing that the application is approved
2. Applications containing waivers &/or variations
Send to Licensee General Manager (or delegate) for approval / review first
Forward licensee's recommendation and relevant docs to Head of Advice Quality and Assurance (or delegate) for approval
The Head of Advice Quality and Assurance (or delegate) must confirm back in writing that the application is approved
Both parties must sign-off on the checklist or via email approval that the Application has been
approved and a copy must be kept on the Applicant’s file.
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Escalation Process
In the event that the Risk Adviser and Head of Advice Quality & Assurance recommend that the
application does not proceed, but the Licensee disagrees, the application must go to the Managing
Director – Advice & Open Markets (or delegate) (MD A&OM) for final review and decision.
Special Conditions on Appointment
Where an applicant has been approved subject to additional conditions such as when the first audit
is scheduled or additional prevetting requirements (Special Conditions), these conditions must be
documented. The Special Conditions must be provided by Head of Advice Quality & Assurance (or
delegate) to the Adviser Appointments team to include in the Advisers Letter of Appointment.
Both the Adviser & the SDM/RPM/PDM must sign the Special Conditions and return to the Adviser
Appointments team. The SDM/RPM/PDM will be responsible for ensuring that the adviser adheres
to the Special Conditions on appointment.
Notification and Reporting
Where an appointment has been escalated for approval to the MD A&OM this information must be
forwarded to the Advice Business Controls & Governance team for inclusion in appropriate
reporting.
Where an appointment has been approved with Special Conditions, the Advisor Appointments team
will provide a final confirmation to the relevant licensee staff and advice delivery teams. The Advice
Business Controls & Governance team for inclusion in appropriate reporting and the Licensee
General Manager and MD A&OM for awareness.
The Adviser Appointments team will forward to the Advice Business Controls & Governance
team information on appointments which have been escalated to the MD A&OM for approval
and/or which have been approved with special conditions.
The Advice Risk Officer (Governance) will maintain this information in a tracking register for each
Licensee. Advisers will be tracked until any special conditions have been met. If the condition
involves a compliance review or vetting, Kathy will obtain that information from CoMetrix or
the Advice Quality & Assurance team. In regards to tracking other conditions (for example,
enhanced supervision or mandatory use of the ANZ Paraplanning team), the Licensee General
Manager or Supervisor will be required to provide updates at the Licensee Risk Forum.
The Advice Risk Officer (Governance) will provide an extract from the adviser onboarding
tracking register to the Risk & Compliance Adviser for tabling at the monthly Licensee Risk
Forums.
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If there are any issues with an adviser not meeting any special conditions, the matter is to be
escalated to the Consequence Management Committee (CMC) by the Risk & Compliance
Adviser.
The Advice Risk Officer (Governance) is to receive a copy of the minutes from the Licensee Risk
Forum in order to process any updates to the tracking register.
CMC outcomes will then be reported in the Advice Quality & Assurance Update for the quarterly
Advice Risk and Compliance Board Committee.
! Note: if the Head of Advice Quality and Assurance or the Licensee General Manager is away then the responsibility can be passed on to the delegated authorities as outlined in the table below in section 2.1.9.
3.1.9. Delegated authority The table below provides details on who has delegated authority to undertake the key sign off /
approval responsibilities identified in the absence of the primary authorised person:
Primary Authority Delegated Authority (in order)
Head of Advice Quality and Assurance Manager Risk & Compliance
Risk & Compliance Adviser
Head of Advice Delivery
Licensee General Manager National Manager Licensee Operations
Operations & Payments Manager
Operations & Payments Supervisor
Head of Advice Process & Systems Operations,
Advice Delivery
3.2 Authorisation steps The post-approval authorisation steps involved with the Appointment of an Adviser / Practice with
the Licensee comprise the following:
Legal Agreements - Organise Individual Authorised Representative Agreement and
Corporate Authorised Representative Agreement (if applicable)
ASIC notification - Upload the Authorised Representative on the ASIC Register
Initial Appointment notification (only applicable for Advisers/Practices not already
registered with the TPB) – issue the Initial Appointment letter which is subject to successful
TPB registration.
Authorisation notification – Inform Applicant of successful Application and issue Authority
Notice. (Where an Initial Appointment notification was issued, adviser must provide TPB
registration evidence before this can be issued).
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Transfer Agreement – transition of brokerage – start the process to arrange Client Transfers
with Fund Managers (if applicable) and organise new Adviser codes (if required)
Update Internal Registers with the Authorised Representative’s details
Notify all Licensee support staff of Applicant’s appointment
Authority probation (if applicable)
Maternity leave (if applicable)
3.2.1. Legal Agreements All Authorised Representatives need to complete and sign an Authorised Representative Agreement.
Corporate Authorised Representative Agreements will be required if a company is to become a
Corporate Authorised Representative.
Agreement templates are located under:
Advice Delivery\04. Advice Process & Systems\Appointments &
Resignations\Document Control\Agreement Templates
Schedule 1 (in each agreement) and the RCTI Agreement need to be pre-populated before organising for the agreement to be signed.
Refer to section 2.2.1.a) below for information on internal agreement execution and signing
requirements.
Once the agreements have been executed, scan a copy into:
Advice Delivery\04. Advice Process & Systems\Appointments &
Resignations\Document Control\Agreement Soft-copies
Send a hard copy of the agreements to the Adviser/Practice and keep a copy on file.
3.2.1.a) Agreement execution and signing requirements
A Power of Attorney Deed for each of the Aligned Licensees (RI, FSP, M3) has been executed, which
allows a number of pre-defined Senior Executives (appointed as an attorney to the company) to
execute and enter into “Standard Form Agreements” under Power of Attorney.
The Standard Form Agreements that can be executed in this manner are listed in the Annexure to
the respective Deed and include Standard Representative Agreements, Transfer Deeds,
Confidentiality Agreements, Tripartite Deeds etc.
This means that these Standard Form Agreements can now be executed using the “Execution by
Authorised Signatory” execution clause (our preferred clause) or the “Execution by Power of
Attorney” execution clause.
The roles that have been appointed as an attorney of their company (and can therefore execute
under this power) are:
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RI FSP M3
Head of RI
Senior National Manager Advice & Operations, RI
General Manager, Advice & Open Market Channels
Head of FSP
Senior National Manager Advice & Operations, FSP
General Manager, Advice & Open Market Channels
Head of M3
Chief Operating Officer M3
General Manager, Advice & Open Market Channels
3.2.1.b) Authorising a Trustee
A Trust has no legal capacity and cannot enter into any contracts or agreement, therefore the
Licensee cannot authorise a Trust.
In instances where a Trust is involved the following important points should be noted:
Licensee must authorise the company in its capacity as Trustee
The Trustee will hold legal title to the clients and holds them beneficially for
the beneficiaries of the Trust.
Both the Trust and Trustee details must be documented in the Agreement and on the RCTI
agreement.
o The Trustee A.C.N and the Trust ABN should be used to clarify the links between the
two entities and reduce the confusion of noting 2 ABNs.
o Ensure the ABN that is recorded in the RCTI Agreement is the ABN for the entity that
is being Authorised
This allows for the licensee to deposit funds into the bank account attached
to the trust without the need for any further documented instructions.
This is often requested for taxation purposes by the practice.
3.2.2. ASIC Notification We must inform ASIC of the Authorised Representative joining the Licensee once their application
has been approved and the Authorised Representative has:
o resigned from their previous Licensee (if applicable) o received a Letter of Release from their previous Licensee (if applicable) and o signed the Authorised Representative agreement (and Corporate Authorised
Representative agreement if required) o Checked both ASIC connect & the FAR to ensure their previous Licensee has revoked
their authorised representative status
Note: Licensee AFSL numbers are as follows:
FSP RI/FPW M3/Elders
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AFSL Number 237590 238429/357306 244252/224645
To authorise an Adviser under one of the above Licensees, go to:
https://asicconnect.asic.gov.au/public/faces/landingPage?_afrWindowMode=0&_afrLoop=1354881
648512000&_adf.ctrl-state=fufcjsljy_4
Note: Each Adviser Appointments Officer must have their own individual login for this site.
A detailed procedure document on how to authorise an Applicant on ASIC Connect can be found in:
Advice Delivery\04. Advice Process & Systems\03.Operations & Payments\Appointments &
Resignations\Authorisation\Authorisation Administration\Appointment Tools\ADG
To obtain the AR number for a green adviser once you have authorized them go to: https://connectonline.asic.gov.au/RegistrySearch/faces/landing/ProfessionalRegisters.jspx?_adf.ctrl-state=12uu3zw0qt_16
Select "Professional registers" on the bottom right hand side of the page
Enter the AFSL Number in the correct field
Select the "Australian Financial Services Licensee" Register
Click the Search button
Click on “Show all representatives” towards the bottom of the page
Type the Adviser's surname in the “Start from” box and click “Go To"
The Adviser should be shown
Click on their name and details of the Adviser should appear
Record the AR Number on the Checklist
Enter the Adviser’s Authorised Rep Number on all internal registers Follow the above steps of the CAR has not previously been authorised.
2.2.3. Authorisation Notification Initial Appointment notification (only applicable for Advisers/Practices not already registered with the TPB) Issue the Initial Appointment letter which is subject to successful TPB registration. Inform applicant of their ASIC number and TPB registration requirements. The Adviser/Practice must complete and return an acknowledgement that they understand they cannot provide advice until Adviser Appointment issues their Final Authorisation Notice following their TPB registration.
Authorisation notification – Inform Applicant of successful Application and issue Authority Notice.
(Where an Initial Appointment notification was issued, adviser must provide TPB registration
evidence before this can be issued).
Inform Applicant of successful Application
Inform Applicant of successful Application/Authorisation and outline the following topics (where
applicable):
a. Legal agreements b. Welcome Email/Pack c. Vetting standards
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Note: Where an Initial Appointment notification was issued, the adviser must provide TPB
registration evidence before this can be issued.
Authority Notice
Once the Licensee has authorised a new Adviser, prepare the Authority Notice letter.
Templates can be found here:
Advice Delivery\04. Advice Process & Systems\03. Operations & Payments\Appointments
& Resignations\Authorisation\Authorisation Administration\Appointment Document Pack
If any other conditions of authority (eg: restrictions) are required, obtain wording from the
Licensee and get sign-off from Compliance to add to the Authority Notice. Save a copy of the
Authority Notice in their file for future reference.
3.2.4. Transfer Agreement - transition of brokerage (if applicable) Generally, when a book of business is being transferred from one Licensee to another, the Adviser
will need to adhere to the exiting requirements of the Licensee they are leaving with respect to
client communications. A release of clients from the former Licensee will usually not occur until the
Licensee has entered into a Transfer Agreement with the previous Licensee.
These Agreements must be submitted to the Licensee’s Legal Representatives for sign-off before
they can be executed and returned to the previous Licensee who will then issue a client release
letter. The Transitions Team manages this sign off process and will then use this letter to contact the
fund managers to transition the payment of commissions from the previous Licensee as part of
Stage 3: Set-up & Induction.
3.2.5. Updating Internal Registers Update all internal registers with the Adviser/Practice’s details. These include:
Licensee Register Location (file path)
RI, Fortnum & FSP Listings and Stats (monthly
register)
T:\Adviser Appointments &
Resignations\Reporting\Planner Movements
M3 Listing and Stats (monthly
register)
MyWorkSpace
T:\Adviser Appointments &
Resignations\Reporting\Planner Movements
https://secure.mydigitalspacelive.com/index.a
sp?site=30&p=security/logon.asp
3.2.6. Notify Licensee Support Staff Send an email to all Licensee Support Staff and Advice Delivery teams informing them of the Adviser
being authorised. Template emails for each Licensee can be found in: Advice Delivery\04. Advice
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Process & Systems\03. Operations & Payments\Appointments & Resignations\Authorisation\Email
Templates
This email initiates the set-up and enablement of relevant services for the new starter as outlined in
Stage 3 Set-up & Induction.
3.2.8. Maternity Leave (if applicable) When an existing Adviser goes on maternity leave, their status is changed to inactive on the “Planner
Movements” register
For RI & FSP the Licensee ceases deducting PI premiums from the Practice for the duration of the
maternity leave. To arrange this send an email to the Brokerage team instructing them to cease
deduction of the PI.
M3 continues to deduct premium from Corporate Authority.
The authority will remain active with ASIC and the Adviser is required to maintain CPD.
3.3 Confirmation / Follow-ups It is important that all of the Appointment procedures (pre and post-approval) are confirmed as
completed or followed up until completed.
It is essential that at all stages of the Appointment process the Adviser is kept informed of the
progress by their RPM/PDM/SDM as well as any potential issues which could prolong their
Appointment.
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4. SET-UP & INDUCTION Once an authority is issued, multiple teams are involved in the set-up and induction process for new
starters.
The process for the new starter is initiated as follows:
4.1. Welcome email to the Applicant The following information is sent to the new applicant:
FSP RI M3
Welcome email
Authority notice/letter of
appointment (hard copy) (hard copy)
AR/CAR Certificate
Authorisation T&Cs N/A (hard copy)
Copy of Licensee AFSL N/A N/A
Copy of PI Policy N/A Accounts Team
Copy of signed Representative
Deed (hard copy) (hard copy)
Copy of Vetting Standards (hard copy) (hard copy)
FSG* Marketing Engine
Adviser Profile* Marketing Engine
Adviser code – Fund Manager
request form
N/A N/A
Intranet login ARC RI Prac Dev team N/A
Stationery ordering login Marketing
Team/Bluestar
Marketing
Team/Bluestar
N/A
Adviser Stamp template N/A N/A
PI Payment form N/A Accounts Team
Notification that they have been
added to distribution list for
Licensee
newsletter/communications
Focus Point RI Report Business Operations
Team
Notification that they have been
added to Licensee website N/A N/A
Quick Reference Guide: Set-up &
induction – NEW – (effective 1 Sept
2013)
(hard copy) (hard copy)
* Note: the FSG & Adviser Profile must be given to the Adviser before they can provide any advice.
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4.2. Licensee Support Staff enable access to systems and services The Adviser Appointments team sends an email to the following teams as part of the Authorisation
procedures (Refer Section 2.2.6.) notifying them of the new appointment, which initiates the set-up
and enablement of the following services for the new starter:
Team Service / System
Bluestar Marketing Engine FSG & Adviser Profile
Adviser Appointments ARC login details (in welcome email) (FSP only)
Marketing Public website (RI only) – add Adviser/Practice
Adviser Appointments Professional Indemnity cover (applied automatically once
authorised)
Adviser Development Training System/Learning Management System
Adviser Development Induction programs/training/accreditation
Advice Systems & Support Advice template access
Advice Systems & Support Technology system (Xplan & CommPay) licenses and access
Advice Systems & Support Data conversion process
Advice Systems & Support Research tools - ChantWest & Mercer access
Investment Research Research tools – Morningstar access
Marketing Stationery ordering & printing access
Marketing Add to email distribution lists for communication (RI & FSP)
Marketing Public website (FSP only) – add Adviser/Practice
OnePath distribution OnePath BDM allocation
Operations & Payments Brokerage system set-up and access to DMS Online
Operations & Payments Client transition process and transition of brokerage,
including new Adviser code set-up with Fund Managers
Practice Development Licensee Adviser / Practice lists
Practice Development Adviser Services website login details (RI)
Advice Assurance Vetting program an d clearance
A high-level overview of the set-up procedures and processes for each of these services / systems is
provided below. For more detailed procedure or process information, refer to the relevant teams.
ANZ.800.390.0043
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4.2.1. Adviser Website Access The Licensee's Adviser website (ARC, Adviser Services, M3 Website) is an accessible resource centre
for all Authorised Representatives.
Once the Adviser has been appointed and an email is sent notifying all Licensee Support Staff,
Adviser website access is set-up as follows:
1. FSP: Adviser Appointments team will send a welcome email to the Authorised Representative
with details of website login and password.
2. Rl: Practice Coordinator notifies Authorised Representative of website login and password
3. M3:Systems and Support Team will send a welcome email to the Authorised Representative with
details of website login and password
4.2.2. Brokerage system set up and access A crucial part of the set-up process is the establishment of the Adviser on the Brokerage System so
they can be remunerated .
Send an email to the Brokerage team ( CONFIDENTIAL
CONFIDENTIAL requesting the Adviser be set up on the OMS Online System and
provide the Brokerage team with the following information:
Banking Details: Bank Name, Branch, BSB, Account Number, Account Name
Practice Details: Practice Name & Practice ABN
Contact Details: Email Address
Proposed start date Dealer split (this needs to be confirmed in writing by the Licensee Practice Development team or in
the letter of offer/terms & conditions)
Use the following documents to provide this information to the Brokerage team:
• Commissions Update Form & Bank Account Details form
4.2.3. Brokerage transition- client transfers and Adviser codes If a book of business is transferring, the Transitions Team) is responsible for reviewing the
Applicant's list of product issuers to ensure the Licensee has an RCTI agreement in place to be able
to receive brokerage from the product issuer. If no agreement is in place then the Transitions team
liaises with the product issuer and the Licensee to establish an agreement.
The Transitions team requires the completion of a spreadsheet to enable it to determine which fund
managers we do not have an RCTI agreement with and to organise the transfer of the brokerage:
Procedure
• Advice Delivery\04. Advice Process & Systems\03. Operations & Payments\Appointments & Resignations\Document Control\ Transitions
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The incoming Adviser/Practice should complete this form and email it to [email protected].
Any issues found are to be reported to the RPM/SDM/PDM for review and acceptance.
Client Transfers are necessary if the newly appointed Adviser has existing clients with their previous
Licensee. The previous Licensee will forward a Release Letter to the Adviser authorising for us (the
new licensee) to facilitate Client Transfers on behalf of the Adviser.
Forward the Release Letter to the Transitions team (Adviser Appointments team for M3) with a list
of the Adviser's current Adviser codes with their previous licensee. Ask the Transitions team to
organise the client transfers as per the Release Letter and have clients and brokerage transferred
from all the applicable fund managers.
4.2.4. Financial Services Guide and Adviser Profile RI & FSP
The Marketing Team/Bluestar will organize for the new Adviser/s to be issued with login details for
the Bluestar Online Marketing Engine. It is through the engine that Advisers will order copies of the
FSG, and create their Adviser Profiles.
Once an Adviser logs on and creates their adviser profile, they need to submit their order which will
come to the Adviser Appointments inbox for review and approval.
The Adviser Appointments Officer needs to click on the link in the email which will take them
to the online profile for review
Review the documents details to ensure they are correct:
o ABN
o Entity name
o AR & CAR numbers
o Contact details
o Issue date
o Iteration number
o Areas of advice (ensure they have accreditations for any specialist areas selected)
o Background information
If applicable, send a screen shot of the Adviser’s background information to Advice Delivery
Compliance for review if you are unsure if the wording is appropriate
If the profile is acceptable, save a PDF before you approve the order and save in Advice
Delivery\04. Advice Process & Systems\03. Operations & Payments\Appointments &
Resignations\Adviser Profiles\Current\dealer group\adviser name
If the details are incorrect, you must reject the order and provide details to the adviser in
regards to the amendments that need to be made
Templates can be accessed via:
Advice Delivery\04. Advice Process & Systems\03. Operations & Payments \Appointments &
Resignations\Document Control\Adviser Profile Templates
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M3 & Elders
The SDM will send through a drafted profile for review with the application. Review and approve or
deny with requested changes. If a draft profile has not been submitted with the application, draft
the adviser profile and save as a PDF. Send the drafted profile to the adviser (in PDF format). The
adviser profiles are saved in Advice Delivery\04. Advice Process & Systems\03. Operations &
Payments\Appointments & Resignations\Adviser Profiles\Current\dealer group\adviser name
4.2.5. Induction Adviser Development has established a framework for a comprehensive induction solution that is
consistent across all ADGs, although M3 is more involved in the planning stage.
Adviser Development has provided ADG Practice staff with a tool to support new advisers in
adopting Licensee required business practices and co-ordinates Orientation Sessions on
request from the ADG.
For M3: Induction program materials (checklists, webinars and presentations) are
embedded within ‘My Workspace’ and / or loaded onto the website for deployment by the
licensee.
4.2.7. Ongoing Training system To ensure Advisers satisfy their ongoing training obligations, the Licensee provides access to an
online training tracking and planning solution for the ongoing Professional Development
requirements of the Financial Services Industry.
When Adviser Appointments notifies Adviser Development of a new appointment, the Adviser Development team must set up the new starter and allocate a training plan based on the adviser’s Authority type. The training plan includes:
Initial mandatory learning articles which must be completed within 3 months from the date of appointment. If the training is not completed, this will be escalated to the Consequence Management Committee to determine the best course of action.
o Fortnum - “Fortnum New Starter Mandatory Learning” o RI - “New Starter Mandatory Assessments” o FSP – “New Starter Mandatory Assessments” o M3 – “New Starter Mandatory Assessments”
The Adviser Development team is responsible for communicating the completion of all training to the Adviser and the Licensee, as well as checking for completion within the required timeframe. A detailed process on setting up an adviser can be found: xxxxxxxxxxxxxxxx
4.2.8. Professional Indemnity Insurance The Licensee’s Professional Indemnity Insurance Policy provides cover to Authorised Representatives
automatically once ASIC notification of Authority is complete.
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The Licensee’s PI cover only covers activities performed in their capacity as Authorised
Representatives of the Licensee. As part of the Application process, all Advisers must complete a PI
Declaration form.
PI premiums are charged to the Adviser / Practice by the Licensee as follows:
FSP: Authorised Representatives must to complete and return the PI Payment Form (sent to
them as part of the Welcome email). Prior to sending the form, the PI Insurance Calculator is
used to work out the pro-rata amount payable by the Adviser. Enter the start date and
amount payable in a tailored PI Payment Form.
o The form is located:
Advice Delivery\04. Advice Process & Systems\03. Operations &
Payments\Adviser Appointments &
Resignations\Authorisation\Authorisation Administration\Appointment
Tools
o The adviser should forward the completed form to the Brokerage team for
processing.
RI: All Authorised Representatives are charged a fixed amount for PI. This is deducted from
their brokerage on a monthly basis.
M3: Authorised Representatives must complete and return the PI Declaration Form as part
of the appointment process
o Once the form is received and Authorised Representative is appointed the Accounts
Team raise these invoices for payment. This will be a pro-rata amount dependent
upon the start date.
4.2.9. Research Tools
Mercer and Chant West access
Adviser Appointments team sends a spreadsheet to the Advice Systems & Support team on a weekly basis (note: if no new starters are appointed then the spreadsheet is not sent that week).
The Advice Systems Support team then notifies the Research Houses and asks them to set up the new users and notify them of their login details.
Spreadsheet is kept in: Advice Delivery\04. Advice Process & Systems\03. Operations & Payments
\Appointments & Resignations\Authorisation\Research Access\In Progress
4.2.10. Stationery Ordering The process for stationery ordering varies by Licensee as follows:
FSP: Once the Adviser Appointments team has sent the Marketing team the pre-
authorisation email, the team will set up an adviser log in to the Marketing Engine. Once the
adviser is authorized they will receive the log on details and can use this system to create
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their stationery. Alternatively, they can organize stationery through their own local supplier,
adhering to the brand guidelines and seeking Marketing team sign-off before using.
RI: Once the Adviser Appointments team has sent the Marketing team the pre-authorisation email,
the team will set up an adviser log in to the Marketing Engine. Once the adviser is authorized they
will receive the log on details and can use this system to create their stationery. Alternatively, they
can organize stationery through their own local supplier, adhering to the brand guidelines and
seeking Marketing team sign-off before using.
M3: the standard process for M3 is that Adviser / Practice arrange the printing of their own
stationery.
4.2.11. Technology, data conversion & access to advice templates The approved software platform for ADG Licensees is Xplan, including a CommPay module for Fee
Disclosure Statement (FDS) generation.
Process for RI & FSP
The Adviser Appointments team must notify the Advice Systems & Support team to set this up on
behalf of the Adviser by forwarding the Advice Systems Technology Set-up Form to the team as soon
as it is received from the Adviser/Practice.
! Note: this form may be submitted with the Application documents. If so, it should be submitted to the Advice Systems Support team as soon as it’s received so they can assess the Applicant’s requirements and tentatively schedule any required data conversions with IRESS and system set-up work.
In some cases, Xplan training and set-up may be organized via the SDM / Practice Development
Coach well before this stage of the appointment process.
This team also manages the data conversion process, as well as access to Advice templates via Xplan.
Appendix 1 contains process maps for a Standard and Custom Data Conversion.
Process for M3
The Advice Systems & Support team is notified to set this up on behalf of the Adviser by receiving
the Systems Technology Set-up Form from either the adviser appointment team, SDM or for the
Authorized Representative directly.
4.2.12. Vetting Standards The Vetting Program ensures that Advisers are producing advice which meets the Licensee’s expected standards prior to being provided to clients.
In regards to new starters, Vetting is applied to all new entrant Advisers immediately after the
successful completion of their induction.
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! All vetting requires each advice document to be approved before it is presented to a client.
It is important for both Licensees and Advisers to have confidence that an appropriate level of
competence can be demonstrated in giving advice across a range of types of authorisations and
specialist accreditations. Consequently Advisers need to progress through pre-vetting for each of
their specific authorisations and specialist accreditations according to the following groupings:
Authorisation Accreditation
Risk Protection Self Managed Super Fund (SMSF)
Superannuation & Investment Direct Equities
Retirement Planning Gearing
Business Insurance
Aged Care
The Adviser Appointments team must include a copy of the Vetting Standards as part of the
Welcome email/pack. Refer to the Advice Vetting Standard for further details.
4.2.13. Website - Licensee public website listing Once a new Adviser / Practice starts they are added to the Licensee’s public website by the following
teams:
RI: Marketing team
FSP: Marketing team
M3: N/A - These are not added to the M3 Website
4.3. Quick Reference Guide: Set-Up & Induction It is important that all of the Set-up & Induction procedures are confirmed as completed and done so
in a timely manner.
To help manage Adviser / Practice expectations around this process and to ensure they know who to
contact if they have any queries regarding the set-up of these services and systems the Adviser
Appointments team sends the ‘Quick Reference Guide: Set-up & Induction’ to all new starters in
their Welcome email/pack.
A copy of this is located:
Advice Delivery\04. Advice Process & Systems\03. Operations & Payments
\Appointments & Resignations\Authorisation\Authorisation
Administration\Appointment Document Pack
It is then the Adviser/Practice’s responsibility to contact the relevant teams if they have any issues
regarding set-up and enablement of Licensee services.
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5. TERMINATION PROCEDURES When an Authorised Representative leaves the Licensee, the Senior National Manager Advice &
Operations needs to determine the following:
Last Date with Licensee (Resignation Date)
Client Register being released with Authorised Representative to new Licensee
Client Register being transferred to another Authorised Representative within the Licensee
New contact details for the Adviser
Once this information has been obtained, the following tasks need to be completed:
Terms of Agreement – preparing for termination o Receipt of resignation o Adviser File & Termination/Cancellation checklist o Notifying the Adviser of obligations and next steps in the termination process o Settlement of Outstanding Debts (if any) o Review of Tripartite Arrangements (if any)
Revoking the Authorised Representative’s Authority on ASIC Website
Client Communication (by Adviser/Practice)
Signing Transfer Deed to allow release of clients
Client Release Letter for New Licensee (if applicable)
Transferring Client Register to another Authorised Representative (if applicable)
Forwarding Exit Survey to Adviser for completion
Notifying all Licensee Support Staff
Authorising an Xplan Data Conversion (if applicable)
Removing access to services and systems on termination date: o Cancelling Software o Removing Adviser's Details from Lists and Database o Cancelling Website Access / Stationery ID o Notifying the Brokerage Team o Cancelling OnTrack access o Cancelling Research Tools
Retaining copies of client files / information in case of future complaints of litigation
Destroying adviser personal information after termination
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5.1.1. Terms of Agreement – preparing for termination
5.1.1.a) Receipt of resignation Practices must provide written notification as outlined in their Agreement in advance of their date of
termination unless otherwise agreed by both parties to the agreement. Advisers must provide a
period of notice as specified in their individual agreement unless otherwise agreed with their
employer/Licensee.
A copy of this resignation notification must be kept on the Adviser’s file.
5.1.1.b) Adviser File and Termination/Cancellation checklist Locate the hard copy Adviser’s File. Print out Termination Checklist and place in the Adviser File
Advice Delivery\04. Advice Process & Systems\03. Operations & Payments \Appointments &
Resignations\Authorisation\Authorisation Administration\Cancellation Tools\ADG
Complete all steps as required in the Termination/Cancellation checklist.
It is imperative that all documentation relating to the Authorised Representative is maintained and
kept in their file, including any emails sent during the termination process.
This information should be kept for reference purposes, any potential disputes/queries relating to
the termination and for any auditing requirements.
5.1.1.c) Notifying the Adviser of their obligations and the next steps in the termination process Upon receipt of the notification of resignation notify the Adviser of their obligations under their
Agreement and provide an overview of the next steps in the process (using the standard email /
booklet template), ie:
Adviser to send the Licensee a copy of the negative consent letter for approval. Attach the relevant negative consent letter template as guidance.
Adviser to provide contact details for the new licensee.
Once the negative consent period has expired, confirm whether any clients chose to opt out.
Licensee to provide a client release letter to the new licensee (excluding the clients who have opted out).
If applicable, the Licensee will authorise an Xplan data conversion after the negative consent period. In the meantime, the new Licensee can liaise and book in the conversion directly with IRESS, but Licensee will need to give final permission after the negative consent period.
Exit survey – Adviser to complete prior to departure. This is not compulsory for them to complete and return. The exit survey is not sent to the adviser if they have been terminated by the Licensee.
Licensee to terminate the Adviser's AR status on the agreed termination date.
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5.1.1.d) Payment of outstanding debts Advisers/Practices must settle all outstanding debts before the Licensee will revoke their Authority.
Debts incurred by an Authorised Representative would generally relate to PI Insurance Premiums (if
paying via weekly deductions), software subscription and DMS Online.
The Adviser Appointments team should:
Send an email to Brokerage / Finance team requesting outstanding debt amounts (if any)
Request Accounts draw up an Invoice for the outstanding amounts
Take copy of Invoice and place in Adviser’s File
Send Invoice to Adviser with payment options
Confirm payment of the invoice before terminating the Adviser.
5.1.1.e) Review of Tripartite arrangement (if applicable) The Finance Department (RI & FSP) maintains a register of Tripartite Agreements for M3 all tripartite
agreements are noted against the Adviser in ‘My Workspace’. Determine if the departing Practice
has a Tripartite in effect. If so, the Licensee is required to notify the third party of the resignation of
the Practice per the terms of the agreement.
5.1.1.f) Review of outstanding complaints, incidents & remediation On termination of the Agreement, the Licensee requires the Incidents & Disputes team (Advice
Delivery Compliance & Professional Standards) to notify them of any outstanding complaints,
incidents & remediation. This must be provided in writing and a copy kept on the Adviser’s file.
A template email can be found in: Advice Delivery\04. Advice Process & Systems\03. Operations &
Payments\Appointments & Resignations \Authorisation \Email Templates\Terminations
5.1.1.g) Licensee sign off on any outstanding matters The Licensee must provide final sign off prior to termination of a Practice that all outstanding
matters have been resolved. This must be provided in writing to the Adviser Appointments team and
a copy kept on the Adviser’s file.
5.1.2. ASIC Notification - Revocation of Authority To ensure that the Authorised Representative is no longer recognised as an Authorised
Representative with the Licensee, the Adviser Appointments team is responsible for revoking their
Authority from ASIC Connect & the FAR. Go to:
https://asicconnect.asic.gov.au/public/faces/landingPage?_afrWindowMode=0&_afrLoop=1354881
648512000&_adf.ctrl-state=fufcjsljy_4 Note: Each Adviser Appointments Officer must have their
own individual login for this site. A detailed procedure document on how to terminate an Applicant
on ASIC Connect can be found in:
Advice Delivery\04. Advice Process & Systems\03. Operations & Payments \Appointments &
Resignations\Authorisation\Authorisation Administration\Appointment Tools\ADG
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5.1.3. Client Communication As required under the terms of their Agreements, the Adviser/Practice is required to notify their
clients that they wish to transfer the client’s portfolios and information to the new Licensee. They
are required to provide them with the means to object to this transfer and remain a client of current
Licensee. To do so, they must send them a negative consent letter in advance of their termination
date. Specific requirements are outlined in the Agreement, however, this letter is generally required
to be sent a minimum of 35 days in advance of termination. The client letter must be in line with the
Licensee’s letter template, a sample of which is included in the Agreement.
5.1.4. Transfer Deed The new Licensee must sign the Licensee’s Transfer Deed before a client release letter can be issued
to release the book of business. Should the new Licensee request changes to the Transfer Deed, it
must be approved by the Licensee’s Legal representatives before obtaining the signature of the new
Licensee. Once approved by legal, the Deed is issued in duplicate for signing by the new Licensee. On
receipt of both copies of the Deed, arrange for execution by the Licensee Authorised Signatory.
5.1.5. Client Release Letter Letter template location: Advice Delivery\04. Advice Process & Systems\03. Operations & Payments
\Appointments & Resignations\Authorisation\Authorisation Administration\Cancellation Tools
Once the negative consent period has expired and the Adviser has confirmed whether any clients
chose to opt out, the Adviser Appointments Officer needs to prepare the Release Letter and have
this signed by the Licensee General Manager (or delegate). The Release Letter authorises the Life
Companies and Fund Managers to transfer the brokerage and servicing rights of the Adviser’s Client
Register to the New Licensee. It contains the following information:
Name of Authorised Representative(s)
Authorised Representative Number(s)
Licensee agrees to transfer brokerage and servicing rights of Client Register to New Licensee
Any clients to be excluded from the transfer
New Licensee responsible for any write backs incurred after Release Date
Place electronic soft copy as well as hard copy of letter in Adviser File
Email a copy of the letter to the Adviser and the new Licensee
For any clients who elect to remain with the Licensee a new Adviser will need to be nominated to
service them. The Licensee is responsible for managing this process and notifying clients of their new
Adviser.
Once the allocation is made to the new Adviser, and at termination date, send notification to the
Advice Systems and Support team requesting the re-allocation of the Xplan data to the new Adviser.
It is the Licensee Practice Development team’s (RPM/SDM) responsibility to secure the client files
from the Practice and provide them to the new Adviser.
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5.1.6. Transferring Client Register to another internal Adviser (if applicable) If the Authorised Representative is transferring their Client Register to another Adviser within the
same Licensee, the following process applies:
Adviser Appointments team will notify the Practice that it is their responsibility to organise
client transfers to the new Adviser, send requests to the relevant Fund Managers and follow
them up.
5.1.7. Authorising an Xplan Data Conversion (if applicable) If applicable, once the negative consent period has expired, send an email to Advice Systems and
Support requesting that they authorise an Xplan data conversion excluding any clients who have
opted out. Advice Systems and Support will send this email to the relevant contact person at IRESS.
If all clients are transferring to the new Licensee, Advice Systems can accept the ‘Notification of
terminated Adviser/Practice’ sent to all Licensee support staff as instruction to begin the conversion.
Note: in regards to the client data in Xplan, the Licensee retains a snapshot of this data in case of
future complaints or litigation.
M3 Process
A terminated Authorised Representative must inform their new Licensee that there is to be a data
conversion within XPlan. M3 Systems and Communication area then receives a request from Iress to
removed data from the Xplan site.
5.1.8. Exit Survey The Exit Survey should be sent to all departing Advisers, with the exception of those Advisers /
Practices that are terminated by the Licensee or ANZ.
The exit survey is included in the ‘Notice of Obligations upon Resignation’ email sent to the Adviser.
If the adviser completes and emails back a survey, email this to the Licensee General Manager
and/or Senior National Manager Advice & Operations for their records.
5.1.9. Notification of termination to all Licensee Support Staff The Adviser Appointments team sends and email to all Licensee Support Staff advising them of the
terminating Adviser / Practice, which then prompts them to shut-down and remove access to all
Licensee systems and services on the termination date.
5.1.10. Removal of services & system access On the termination date of the Adviser / Practice, the Licensee Support teams will turn off access to
the Licensee services and systems as follows:
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5.1.10.a) Notifying Brokerage The Brokerage team must be informed when an Adviser is leaving so that they can make the
necessary adjustments to the DMS System.
It is the responsibility of the Authorised Representative’s new Licensee to arrange the transfer of
business with the Life Companies and Fund Managers.
The Brokerage team will continue to receive and process brokerage on behalf of the Adviser for a
period of 90 days during the transition process. This brokerage will be passed on to the Adviser with
the Licensee's margin deducted as per normal.
5.1.10.b) Cancelling software Upon notification of termination by the Adviser Appointments team, the Advice Systems & Support
team will cancel any Xplan licences, if this has not already been organised.
5.1.10.c) Updating internal registers It is important that the Adviser/Practice’s details are removed from all Lists, Databases and Outlook
Email Address Books when they decide to leave to ensure they don’t receive any unintended emails
or mail outs after their resignation date.
Refer back to the Authorisation task: “Updating Internal Registers” for details of all internal registers.
5.1.10.d) Cancelling Website Access / Stationery ID Once an email is sent advising all Licensee Support Staff of the termination, this will prompt the
Marketing Team to organise cancellation of the Adviser’s website access and stationery ID (FSP & RI
only).
This process is managed by the Systems and Communication team for M3.
5.1.10.e) Cancelling Adviser Website access Once an email is sent advising all Licensee Support Staff of the termination, this will prompt the
following teams to cancel access to the Licensee’s Adviser Website:
RI Adviser Services – Licensee Practice Development team
FSP ARC – Adviser Appointments team
M3 – Systems and Communication team
5.1.10.f) Cancelling Training System Access The Adviser Development team will manage cancellation of training system access. A detailed
procedure on how to do this can be found: xxxxxxxxxxxxxx
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5.1.10.g) Cancelling Research Tools Send an email to the following teams requesting that they notify the Research Houses to remove
access for the departing Adviser:
Advice Systems & Support – Mercer & Chant West access
Investment Research team – Morningstar access
5.1.10.h) Cancellation of PI Insurance Cover When an Adviser leaves they are noted as a “Past Adviser” on the Licensee’s Professional Indemnity
Insurance Policy from their resignation date.
This means that the Adviser will be covered for all business written whilst they were an Authorised
Representative with the Licensee but not for business written after their resignation date.
When an Adviser’s Authority is revoked on the ASIC register, this will be taken as having notified the
PI Insurer of the Authorised Representative's departure.
5.1.11. Retention of Client Data As part of the Termination process, the Licensee must obtain a copy of the departing Adviser’s client
files/information in case of future complaints or litigation. The current process is as follows:
RI: the Licensee retains a snapshot of all client data in Xplan.
FSP: the Licensee retains a snapshot of all client data in Xplan (if applicable). If the Adviser /
Practice does not use Xplan then a copy of client data is provided by the Adviser to the
Licensee on a USB stick/CD.
M3: Transfer deed under section 4.6 states that: o The New Licensee will ensure that, within 90 days of this agreement, the
Representative will provide copies to M3 of all client files on disk where advice has been provided while under the licence of M3. The documents required are:
File notes and Fact Finders Risk Profile questionnaires SOAs, SOAAs and ROAs
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5.1.12. Destruction of Adviser's personal information after termination After a period of 7 years from when an Authorised Representative leaves a Licensee, unless there
are specific business requirements to retain the information the Licensee must take reasonable
steps to destroy or de-identify all personal information (both hard-copy and soft-copy files) relating
to that individual.
I~ Note: this process also applies in instances where an Applicant withdrew their application or their application was unsuccessful ie information must be kept for 7 years
and then destroyed or de-identified.
G. AUSTRALIAN BANKING ASSOCIATION- RESPONDING TO A REQUEST
In responding to an ABA Protocol Reference Check request from other licensees that has been
received in the ABA email inbox, the Risk Liaison Officer will ensure the
following steps:
Procedure
• Request applies to a Financial Adviser providing personal advice on Tier 1 financial products,
within the last five years.
• Cross check the adviser name against Financial Adviser Register
https:/ /www.moneysmart.gov.au/investing/financial-advice/financial-advisers-register
• Confirm the adviser name has been employed by our ANZ Group (eg: ANZFP, Financial
Services Partners, Millennium3, Elders, Rl Advice)
• Create a folder for the adviser on the ABA Reference Checking folder on the Advice Risk
Share drive and enter details into the ABA Protocol Requests Log
• Create a Standardized Reference Checking Form using the templates in the share drive.
• Email the advisers supervisor to answer QS) "Was there an inquiry or investigation by the
Current/Previous Licensee in progress at the time of the Financial Adviser's
termination/resignation?" and Sa) "Is the Financial Adviser aware of any of these enquiries
or investigations?"
• Complete all sections of the ABA Reference Checking form with factual information by
accessing information in CoMetrix, Adviser Hub, COR, Compliants Register, Incidents
Registers and Reportable Breaches.
• Only include factual information based on our reports, documentation or records.
• Completed form to be sent to licensee head (or delegate) for approval.
• Completed form emailed in pdf format to the requesting licensee by COB 10 business days
after receiving the request.
• Update the ABA Requests log and the adviser file on the share drive.
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Internal Response Timeline
1. Risk Liaison Officer to complete the ABA Protocol Reference Check Form within 5 working days
2. Risk Liaison Officer to forward the completed draft of ABA Protocol Reference Check form to
the Licensee Head ( or nominated delegate) by day 6 if not earlier for review and sign-off
before responding to requesting Licensee.
3. The Licensee Head (or nominated delegate) to review and provide final sign-off within 5
working days if not earlier before it is responded to the requesting Licensee.
NOTE: If an adviser has been reported to ASIC for any breaches, the information disclosed in the
ABA Protocol Reference Check form must be forwarded to Legal Team for review of the wording.
Record Keeping Risk Liaison Officer to record the signed ABA Protocol Consent Form and completed ABA
Protocol Reference Check Form on our Shared Drive in a folder created for each adviser
Risk Liaison Officer to update the ABA Protocol Log for incoming requests and necessary
information
EMAIL TEMPLATE TO MAKE REQUEST TO OTHER LICENSEE
DEAR < Sir | Madam >
< Our Licensee Name> is a subscribing AFSL to the ABA Protocol, and we are requesting
information from < Other Licensee Name> also a subscribing AFSL to the protocol), for < Adviser Full
Name >, and AFSL < Number>
In accordance ABA Protocol, would you please provide your responses within 10 working days by
CBB DAY | DATE| MONTH| YEAR
A copy of the signed ABA Protocol Consent Form and ABA Industry Reference Check Form for your
reference.
We look forward to your response within 10 business days. Thank you for your cooperation.
Kind Regards,
Risk Liaison Officer
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ABA Consent Form Protocol
RI Advice Group Pty Ltd
Consent to the collection, use and disclosure of information
By applying for this position you consent to and expressly authorise RI Advice Group Pty Ltd (which for the purposes of this consent includes any of its related entities) and any persons or organisations acting on its behalf, to collect and use, and any of your current or previous employers/principals/licensees to disclose to RI Advice Group Pty Ltd information about your current or previous employment or appointment for the purpose of RI Advice Group Pty Ltd assessing your application for employment/appointment and complying with the ABA's Reference Checking & Information Sharing Protocol (Purpose). You agree that the information that may be collected, used and disclosed includes, but is not limited to, information in relation to:
(i) the scope and length of your authority (ii) your compliance record, including any results/outcomes from any internal monitoring and
supervision programs (audits) (iii) other risk management history, including in relation to any inquiry or investigation concerning
your conduct that was in progress at the time of your departure (iv) material incidents or ASIC reportable breaches caused or contributed to by you (v) any compensation paid due to your compliance, risk management or advice activities.
Information collected by RI Advice Group Pty Ltd will be used by RI Advice Group Pty Ltd for the Purpose and will be treated confidentially (unless disclosure is required or authorised by law or regulatory order, or you consent to a particular disclosure).
If you become appointed/employed by RI Advice Group Pty Ltd or one of its related bodies corporate, you also consent to and expressly authorise the disclosure of your personal information and information relating to your appointment/employment held by RI Advice Group Pty Ltd (including the information set out above relating to that employment/appointment), to anyone who is seeking to employ you or engage you as their Authorised Representative or Credit Representative or in any other capacity or to a person acting on their behalf
Declaration
I declare that I have read and understood the content of this consent form, including the future disclosures that may be made of my information if I become employed/appointed by Ri Advice Group Pty Ltd and understand that my consent will continue indefinitely.
Release
I release RI Advice Group Pty Ltd any current or previous employer, principal or licensee and its or their related entities, employees, officers, agents and representatives (Releasees) from liability for any loss, damage, claim or cause of action (including in relation to any obligation of confidence), I may otherwise have had in connection with or arising from the collection, use or disclosure of my information for the Purpose (including the RI Advice Group Pty Ltd reliance on the information) unless such liability is due to the gross negligence, malicious or fraudulent action of the Releasee.
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Full name (print):
________________________________
Adviser ASIC ID
________________________________
Signature:
_______________________________
Date:
________________________________
ANZ.800.390.0060
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Financial Services Partners Pty Ltd
Consent to the collection, use and disclosure of information
By applying for this position you consent to and expressly authorise Financial Services Partners (which for the purposes of this consent includes any of its related entities) and any persons or organisations acting on its behalf, to collect and use, and any of your current or previous employers/principals/licensees to disclose to Financial Services Partners information about your current or previous employment or appointment for the purpose of Financial Services Partners assessing your application for employment/appointment and complying with the ABA's Reference Checking & Information Sharing Protocol (Purpose). You agree that the information that may be collected, used and disclosed includes, but is not limited to, information in relation to:
(i) the scope and length of your authority (ii) your compliance record, including any results/outcomes from any internal monitoring and
supervision programs (audits) (iii) other risk management history, including in relation to any inquiry or investigation concerning
your conduct that was in progress at the time of your departure (iv) material incidents or ASIC reportable breaches caused or contributed to by you (v) any compensation paid due to your compliance, risk management or advice activities.
Information collected by Financial Services Partners will be used by Financial Services Partners for the Purpose and will be treated confidentially (unless disclosure is required or authorised by law or regulatory order, or you consent to a particular disclosure).
If you become appointed/employed by Financial Services Partners or one of its related bodies corporate, you also consent to and expressly authorise the disclosure of your personal information and information relating to your appointment/employment held by Financial Services Partners (including the information set out above relating to that employment/appointment), to anyone who is seeking to employ you or engage you as their Authorised Representative or Credit Representative or in any other capacity or to a person acting on their behalf
Declaration
I declare that I have read and understood the content of this consent form, including the future disclosures that may be made of my information if I become employed/appointed by Financial Services Partners and understand that my consent will continue indefinitely.
Release
I release Financial Services Partners any current or previous employer, principal or licensee and its or their related entities, employees, officers, agents and representatives (Releasees) from liability for any loss, damage, claim or cause of action (including in relation to any obligation of confidence), I may otherwise have had in connection with or arising from the collection, use or disclosure of my information for the Purpose (including the Financial Services Partners reliance on the information) unless such liability is due to the gross negligence, malicious or fraudulent action of the Releasee.
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Full name (print):
________________________________
Adviser ASIC ID
________________________________
Signature:
________________________________
Date:
________________________________
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Millennium3 Financial Services Pty Ltd
Consent to the collection, use and disclosure of information By applying for this position you consent to and expressly authorise Millennium3 Financial Services Pty Ltd (Millennium3) (which for the purposes of this consent includes any of its related entities) and any persons or organisations acting on its behalf, to collect and use, and any of your current or previous employers/principals/licensees to disclose to Millennium3 information about your current or previous employment or appointment for the purpose of Millennium3 assessing your application for employment/appointment and complying with the ABA's Reference Checking & Information Sharing Protocol (Purpose). You agree that the information that may be collected, used and disclosed includes, but is not limited to, information in relation to:
(i) the scope and length of your authority (ii) your compliance record, including any results/outcomes from any internal monitoring and
supervision programs (audits) (iii) other risk management history, including in relation to any inquiry or investigation concerning
your conduct that was in progress at the time of your departure (iv) material incidents or ASIC reportable breaches caused or contributed to by you (v) any compensation paid due to your compliance, risk management or advice activities.
Information collected by Millennium3 will be used by Millennium3 for the Purpose and will be treated confidentially (unless disclosure is required or authorised by law or regulatory order, or you consent to a particular disclosure). If you become appointed/employed by Millennium3 or one of its related bodies corporate, you also consent to and expressly authorise the disclosure of your personal information and information relating to your appointment/employment held by Millennium3 (including the information set out above relating to that employment/appointment), to anyone who is seeking to employ you or engage you as their Authorised Representative or Credit Representative or in any other capacity or to a person acting on their behalf
Declaration
I declare that I have read and understood the content of this consent form, including the future disclosures that may be made of my information if I become employed/appointed by Millennium3 and understand that my consent will continue indefinitely.
Release
I release Millennium3 any current or previous employer, principal or licensee and its or their related entities, employees, officers, agents and representatives (Releasees) from liability for any loss, damage, claim or cause of action (including in relation to any obligation of confidence), I may otherwise have had in connection with or arising from the collection, use or disclosure of my information for the Purpose (including the Millennium3 reliance on the information) unless such liability is due to the gross negligence, malicious or fraudulent action of the Releasee.
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Full name (print):
________________________________
Adviser ASIC ID
________________________________
Signature:
________________________________
Date:
________________________________
ANZ.800.390.0064
Procedure Page 62 of 68 Version 5.0 December 2017
Internal use only
Elders Financial Planning Pty Ltd
Consent to the collection, use and disclosure of information By applying for this position you consent to and expressly authorise Elders Financial Planning Pty Ltd (Elders) (which for the purposes of this consent includes any of its related entities) and any persons or organisations acting on its behalf, to collect and use, and any of your current or previous employers/principals/licensees to disclose to Elders information about your current or previous employment or appointment for the purpose of Elders assessing your application for employment/appointment and complying with the ABA's Reference Checking & Information Sharing Protocol (Purpose). You agree that the information that may be collected, used and disclosed includes, but is not limited to, information in relation to:
(i) the scope and length of your authority (ii) your compliance record, including any results/outcomes from any internal monitoring and
supervision programs (audits) (iii) other risk management history, including in relation to any inquiry or investigation concerning
your conduct that was in progress at the time of your departure (iv) material incidents or ASIC reportable breaches caused or contributed to by you (v) Any compensation paid due to your compliance, risk management or advice activities.
Information collected by Elders will be used by Elders for the Purpose and will be treated confidentially (unless disclosure is required or authorised by law or regulatory order, or you consent to a particular disclosure). If you become appointed/employed by Elders, or one of its related bodies corporate, you also consent to and expressly authorise the disclosure of your personal information and information relating to your appointment/employment held by Elders, (including the information set out above relating to that employment/appointment), to anyone who is seeking to employ you or engage you as their Authorised Representative or Credit Representative or in any other capacity or to a person acting on their behalf
Declaration
I declare that I have read and understood the content of this consent form, including the future disclosures that may be made of my information if I become employed/appointed by Elders and understand that my consent will continue indefinitely.
Release
I release Elders any current or previous employer, principal or licensee and its or their related entities, employees, officers, agents and representatives (Releasees) from liability for any loss, damage, claim or cause of action (including in relation to any obligation of confidence), I may otherwise have had in connection with or arising from the collection, use or disclosure of my information for the Purpose (including the Elders reliance on the information) unless such liability is due to the gross negligence, malicious or fraudulent action of the Releasee.
ANZ.800.390.0065
Procedure Page 63 of 68 Version 5.0 December 2017
Internal use only
Full name (print):
________________________________
Adviser ASIC ID
________________________________
Signature:
________________________________
Date:
________________________________
ANZ.800.390.0066
Procedure Page 64 of 68 Version 5.0 December 2017
Internal use only
ABA INDUSTRY REFERENCE CHECKING FORM
INDUSTRY REFERENCE CHECKING FORM
Financial Adviser (Full
Name):
ASIC ID:
Date completed:
Completed by:
All information should relate to the period up to 5 years preceding the date of the request. (Hand
written notes will not be accepted).
Background
1. What is the scope of the Financial Advisors authority?
2. For what period?
Response Applicable Dates
Compliance, Risk Management and Advice Quality.
Questions 2-4 should be answered in relation to the Financial Advisors compliance, risk management
and advice quality only
3. What are the Financial Advisor’s internal monitoring and supervision program (Audit)
results/outcomes
Response Applicable Dates
Guidance for Current/Previous Licensees:
Include description of the meaning of the audit result at the time, the results/outcomes was
determined and as it was applied
4. Has the Current/Previous Licensee undertaken any of the following which has caused or
contributed to by the Financial Adviser’s action/ in action (e.g. not in system or Licensee
issue)
ANZ.800.390.0067
Procedure Page 65 of 68 Version 5.0 December 2017
Internal use only
a) Reported a breach to ASIC (whether under the corporations Act s912D or otherwise
Response Applicable Dates
Guidance for Current/Previous Licensees: Include the nature/type of breach reported.
b) Identified a material incident
Response Applicable Dates
Guidance for Current/Previous Licensees:
A material incident could be identified through internal assessment or external notification (i.e.
regulatory investigations, complaints received etc.) When assessing the materiality of an incident,
consideration should be given, but not limited to the factors listed below.
It is up to the Current/Previous Licensee to determine the extent to which the factors contribute to
the assessment of materiality on an incident by incident basis.
i. The actual or potential impact on the client, including financial loss
ii. The number or frequency of similar previous incidents
iii. The relevance or importance of the breached obligation in managing risk for the client and/
or the current/previous Licensee
iv. Whether the incident resulted in an intervention or action by the Current/Previous Licensee
as a consequence of the incident and in order to correct the situation
v. Complaints received including the nature, type and frequency of the complaints, and/or
vi. Known civil actions resulting from the provision of financial advice
c) Provided compensation as a result of an impact on any of the Financial Adviser’s client base
due to the compliance, risk management and advice activities of the Financial Adviser.
Response Applicable Dates
Guidance for Current/Previous Licensee:
ANZ.800.390.0068
Procedure Page 66 of 68 Version 5.0 December 2017
Internal use only
Compensation refers to a financial payment offered to a client and/ or any other non-financial
remedy given to a client e.g. free financial advice. When considering the impact on the client base,
consideration should be given, but not limited to:
i. Whether categories of the client base were affected, for example all clients who received a
particular category of Tier 1 financial product advice or recommended a particular product
or strategy, and/ or
ii. Significance, as determined by the Current/Previous Licensee, of the amount of
compensation made.
The Current/Previous Licensee is not required to disclose actual compensation amounts paid, nature
of the non-financial compensation provided, or the reasons for providing compensation. The
Current/Previous Licensee is also not required to disclose compensation provided on commercial
terms, where this does not relate directly to the compliance, risk management and advice activities
of the Financial Adviser.
5. Was there an inquiry or investigation by the Current/Previous Licensee in progress at the
time of the Financial Adviser’s termination/resignation?
Response Applicable Dates
a) Is the Financial Adviser aware of any of these enquiries or investigations (Yes/No)
Guidance for Current/Previous Licensees include the following:
i. Progress/ status of the inquiry/ investigate on, and
ii. Cause/ trigger of the inquiry/ investigation.
If the inquiries/ investigations undertaken by the Current/Previous Licensee into the Financial
Adviser are in the early stages, provide
Information on the status of the inquiry/ investigation.
ANZ.800.390.0069
ABA Protocol Subscribers Key Contact List
Financial Planning (AFSL 232706) Charter Planning (AFSL 234665) Hillross Financial (AFSL 232705) ipac (AFSL 234656) SMSF
234664)
Financial Planning (AFSL 234527) Elders Planning (AFSL 224645) Financial Services (AFSL 237590) Millennium3 Financial Services
Ri Advice Group (AFSL 238429)
Group (Westpac): Magnitude Group (AFSL Financial Group (AFSL 240687)
Banking Corporation (AFSL 233714)
BW Financial Advice (AFSL 230727) ICo>mnlon;' '"'lth Financial Planning (AFSL 231139) IComnlonv.e,,lth Private (AFSL 314018) Commonv.ealth
(AFSL 238814) Count Financial (AFSL Financial Wisdom (AFSL 231138)
Procedure
Version 5.0 December 2017
CONFIDENTIAL
CONFIDENTIAL
CONFIDENTIAL
CONFIDENTIAL
CONFIDENTIAL
CONFIDENTIAL
CONFIDENTIAL
ANZ.800.390.0070
Internal use only
Page 67 of 68
Procedure Page 68 of 68 Version 5.0 December 2017
Internal use only
XPLAN DATA CONVERSION PROCESS
ANZ.800.390.0071
..... ft , . .,. .. ,, Standard Data Conversion Process
RPM I RPC
Adv ice S yOt <!,. Support
New Practice
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...... --
Custom Data Conver sion Process
Advi c:e S yOte,. Suppo rt
I I CUSTOM ! DATA
I COII'I£IIS10II I
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New Practice
RE I :! c.s~.bl ::, e>..S:S ':OC.OI"""4le~e 'J" sstec Al!'vfco llrstef'l"' 5 I~ o~to It, &. cp:c -~ dc6 r04' a,ne;• , e:..:s. ':0 ca-pe·e ... I
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