Posted April 17, 2020

Posted By Meghann Cannon

To ROA or SOA?

Published 1 April, 2020

Prepared by Catherine Evans

Government policy is rapidly adapting in light of the unprecedented challenges presented by the COVID-19 crisis. This includes changes to superannuation such as the reduction in minimum pension payments and temporary early release measures. 

A common question we’re asked is whether advice on these measures can be provided by an ROA or whether an SOA is required.

The starting position is that advice stemming from legislative change will usually require an SOA because the basis of advice provided to address those changes will be materially different to previous strategic advice provided to clients on their superannuation affairs.  

There are options though.

  • Advisers are permitted to provide scaled advice, which obviously streamlines the fact-finding, research and analysis required to provide compliant advice. Inquiries should be limited to what is relevant to provide the advice. 
  • Information can be incorporated by reference into the SOA simplifying the content required to be included in the document. Client circumstances and goals and objectives are commonly incorporated by reference where they have been previously established and remain the same.
  • Advisers may consider preparing general advice or factual information brochures instead of providing personal advice. They’re usually great tools to prevent the friction that otherwise arises from not being able to provide clients with relevant and timely information that they probably require to make a call themselves on a particular course of action.


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