Kosten für fehlerhafte Geeignetheitserklärungen und Beratungsdokumentation
Definition
ASIC’s financial advice updates emphasise licensees’ obligations to ensure advice files demonstrate compliance with best‑interest and related obligations, including adequate investigation of the client’s circumstances and appropriate product selection.[1] ASIC’s review work often involves sampling advice files (e.g., for SMSF establishment or large super rollovers) to assess whether the advice was in the client’s best interests, which is heavily dependent on the quality of the suitability assessment and risk profile.[1] Where files are deficient, AFS licensees typically must conduct re‑advice, compensate affected clients, or run remediation programs, all at their own cost. Industry practice indicates that full file remediation—including adviser time, compliance review, and potential compensation—commonly costs on the order of AUD 500–2,000 per client file as a logic‑based estimate, and more for complex cases such as SMSFs or large‑balance superannuation. For licensees with thousands of historical files, this results in multi‑hundred‑thousand to multi‑million dollar total remediation costs driven largely by poor suitability and risk‑profiling processes.
Key Findings
- Financial Impact: Quantified: Logic-based estimate of AUD 500–2,000 per advice file requiring re‑work or remediation due to inadequate suitability assessment or risk profiling, aggregating to AUD 250,000–2,000,000 for 500–1,000 affected clients in a typical remediation program.
- Frequency: Moderate to high; suitability and documentation deficiencies are common findings in ASIC thematic reviews of financial advice, especially in areas like SMSF establishment and superannuation rollovers.[1]
- Root Cause: Manual fact‑finds and risk questionnaires with missing fields; lack of mandatory data validation; fragmented storage of client information across CRM, advice tools and spreadsheets; absence of pre‑SOA quality checks; inconsistent adviser training on demonstrating best‑interest compliance in the file.
Why This Matters
The Pitch: Investment advisers in Australia 🇦🇺 can lose AUD 500–2,000 per client file in rework, complaints handling and remediation when suitability assessments are incomplete. Digitising fact‑finds, risk profiling and automated file‑quality checks reduces this recurring cost of poor quality.
Affected Stakeholders
Financial advisers and paraplanners, Compliance review teams, AFS licensee responsible managers, Client remediation project teams
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Financial Impact
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Current Workarounds
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Methodology & Sources
Data collected via OSINT from regulatory filings, industry audits, and verified case studies.
Related Business Risks
Bußgelder wegen ungeeigneter Anlageempfehlungen (Zielmarktabweichung)
Strafen für unregistrierte oder unqualifizierte Finanzberater
ASIC Brochure Non-Delivery Fines
Manual Brochure Preparation Labour Costs
Client Acquisition Delays from Brochure Friction
ASIC Advertising Compliance Fines
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