Prepared by Peter Hagias
The weeks leading up to June 30 are a blur for many limited Australian Financial Services Licence holders and the few weeks after are spent trying to recover. Therefore mid-July is probably the right time for those holding a limited AFSL, be they accountants or financial planners, to begin to think about the new financial year. To get you off on the right foot for FY 2018/19 Peter has prepared this checklist, with baseline items to ensure you are heading down the compliance pathway for the new “year”.
- Make sure the ‘ASIC financial register’ is up to date.
- Review a random sample of client files to make sure they are compliant and report any significant breaches to ASIC.
- Arrange training schedule to cover any areas of deficiency identified as part of client file reviews.
- Prepare new representative training plans for those who have based their plans on a financial year schedule. Note you may wish to make them based on a 6 month period ending 31 December, 2018 given new CPD standards come into effect on 1 January, 2019.
- Ensure FOS/CIO membership is being transitioned to AFCA.
- Think about the entries on your breach, complaints and outsourcing registers and whether your risk framework needs to be revised to better protect your business.
- Review adequacy of PI Insurance, particularly if you have made material changes to your financial advice practice since obtaining the cover. Ensure that any EDRS sub-limits reflect the increased amount of compensation that AFCA can award.
- Make sure your FSG is up to date and revise it for any new arrangements.
- Obtain fresh conflict of interest declarations from representatives and responsible managers and consider updating your processes if any conflict has been identified.
- Test disaster recovery plan and amend processes and plan as required.
- Review outsourcing arrangements.
- Make sure you have a data breach response plan and that data breaches are being handled in accordance with that plan.
Please get in touch if you require any further information and for our “Rescue” package subscribers don’t forget you have access to us anytime through your helpdesk!