From 1 July 2016, accountants will no longer be able to rely on
the "SMSF recommendation" exemption. So far in this blog
series, tackling the changes, the four-stage process for licensing
changes and the potential need for a limited AFSL, have been
But if a limited licence didn't sound right for you,
accountants do have these other options:
1. Obtain a full AFSL
Accountants can apply for a full AFSL. In order to do so, the
business would need to submit evidence that their RMs meet the
regulated experience requirements demanded by ASIC – the
requirement has not changed since licensing came into effect on 11
March 2004. See below about getting a full AFSL. A full AFSL allows
you to recommend specific financial products to your clients.
2. Don't get an AFSL
Becoming a licensee isn't for everyone. Accountants who
aren't currently licenced have made a decision to avoid the
compliance burden imposed by the licensing regime, and are happy
with the current exemptions available to accounts (such as the SMSF
recommendation exemptions). Even under a limited AFSL, you will
have to comply with a wide range of obligations. Your business will
face additional internal processes, membership with an external
dispute resolution scheme, further RG 146 training, increased
professional indemnity costs, and more. Some accountants will
review their business to ensure they stop providing any financial
services prior to 30 June 2016. Remember – you can still rely
on the "
asset allocation" and "
taxation" exemptions after this date.
3. Become an Authorised Representative
If you want to continue providing services after 30 June 2016
but want to minimise the compliance burden associated with
obtaining your own AFSL, you could become an Authorised
Representative (AR) of another licensee. You will have to identify
a licensee that fits with your business and you will have to pay
them fees, but you can access their compliance framework without
building it yourself. Many accounting practices have ARs working
under the same roof. Also, many financial planning dealer groups
example) are pitching different AR models to accountants, as an
alternative to getting a full AFSL or limited AFSL.
This table briefly summarises your options:
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
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