FOFA Platforms Response

Transcription

1 FOFA Platforms Response

2 Agenda Overview Regulations and views from our advisers Our FOFA roadmap so far Keeping you informed from here Open forum

3 FOFA passage through Parliament 29 August 2011 Tranche 1 Exposure draft legislation released Opt In Best Interests Duty ASIC powers 13 October 2011 Tranche 1 Bill and EM introduced to Parliament Opt In ASIC powers 29 February 2012 Parliamentary Joint Committee 22 March 2012 FOFA Legislation passed by the House of Representatives Amendments to Fee Disclosure Notices, Best Interests Duty and Opt In Parliament on break until Budget announcement 8 May 29 September 2011 Tranche 2 Exposure draft legislation released Conflicted Remuneration Soft Dollar 24 November 2011 Tranche 2 Bill and EM introduced to Parliament Best Interests Duty Conflicted Remuneration Soft Dollar 14 March 2012 Senate Economic Legislation Committee report released

4 FOFA passage through Parliament Next steps 1. FOFA Bills passed by the Senate 2. If Senate makes amendments, Bills to go back to the House of Representatives 3. Draft FOFA Regulations released for public consultation, then finalised 4. Draft ASIC regulatory guides released for consultation and then finalised This full process is expected to take several months to finalise FOFA compliance dates 1 July 2012 FOFA reforms Voluntary compliance 1 July 2013 FOFA reforms Mandatory compliance End of July 2014 First Fee Disclosure Statements Due 30 days after first anniversary End of July 2015 First Opt In Notices Due 30 days after second anniversary

5 Recent announcements Enabling ASIC to exempt planners from Opt In Adviser exemption available from Opt In if member of professional body with ASIC approved code of conduct Still required to give clients ability to Opt Out and meet annual fee disclosure obligations Fee disclosure statements Future fees and services information not required Level of disclosure detail required reduced Given at any time within 13 months of date of arrangement or end of last statement period Must relate to the last 12 months (30 day buffer)

6 Recent announcements Opt-in renewal notices Given at any time within 25 months (includes 30 day buffer) of date of arrangement or date of last renewal The word send amended to give expanding the ways disclosure statements and renewal notices can be provided Grandfathering Amended to clarify that the ability to provide grandfathering relief is broad Any further details will be included in the regulations released after the legislation is passed

7 Opt In/Opt Out: last minute amendment Opt In will not be required where: An adviser is a member of a professional body The body has an approved professional code of conduct; and ASIC has provided a class order excluding them from the requirement What are the implications? Some advisers may not want to use the class order (or may not be able to) and may still want us to support them on Opt In Further clarification required - What will be needed if the class order doesn't come in for a few years? - Will Opt In be required in the interim? The Sleeper There is a sleeper in the FPA/ISN deal on Opt In around the code of practice

8 Our lobbying activity BTFG has spent considerable time engaging with the Government on these reforms We are pleased that several amendments were made, many of which we asked for in our submissions We do not believe the amendments go far enough to provide the clarity and certainty needed in some areas, such as the best interests duty and scaled advice We will continue to engage with the Government to seek this clarification We support what the government is trying to achieve: improved transparency, raising professional standards and increased investor confidence in the industry

9 FOFA insights from our advisers From a platform perspective we would expect our platform provider to supply technology solutions for the implementation of certain FOFA changes e.g. Opt In. Moreover we would also require a platform provider to supply a range of products that will allow us to offer different service packages to a range of clients depending on the service required and the ability to pay for ongoing services. I will look for an efficient and fully featured platform to help me service clients and take the Opt In burden from my practice. Source: Investment Trends Planner Business Model Report, July 2011

10 FOFA insights from our advisers I will seek product providers that indicate their willingness and ability to assist in the gaining of, implementation of and ongoing servicing of business within the constraints of the new FOFA regulations. Will use a single platform that offers a broad range of investments online, at a more competitive fee i.e. direct shares, managed investments, term deposits, high interest cash rate. Cheaper, more transparent options will be looked at. Source: Investment Trends Planner Business Model Report, July 2011

11 FOFA insights from our advisers Clients are needing more transparency so I would need cheaper platform fees as part of the total costs. Focus will be on low cost products, as every cost to the client will be more greatly scrutinised; both by clients & the industry. Lower cost simple platforms and high functionality platforms offering whole of life client solutions. Lower cost, efficient providers with good levels of support would be the desired relationship. Source: Investment Trends Planner Business Model Report, July 2011

12 Fee for service across both BT and Asgard One off advice fees including flat dollar at any time or on contributions

13 Improved insurance offers across the platforms Enhanced capabilities and integration

14 Equities improvements across both platforms BT Wrap Models, Tax optimisation, Multi-client, Bulk Order equities trading Asgard Share trading, Corporate actions, Templates

15 Why platforms are relevant post FOFA Consolidation Platforms continue to offer you and your clients the same benefits of consolidated reporting, tax reporting and integration of margin lending, cash and insurance Efficiency Platforms continue to offer you efficiency when executing your advice recommendations. This includes delivering on the services outlined in the disclosure notices. and easily administering legislated requirements Choice We will be providing dealers and advisers with flexibility around how they choose to service and collect fees from clients- dial up fees, fees for service and tracking of services provided Scale benefits We will continue to explore opportunities that allow us to exercise our scale and deliver benefits to users and investors. This includes the existing benefits of access to wholesale managed investments

16 Wrap Up Keeping you informed Updates on reform passage through parliament and regulations to provide you with information you need to prepare for change Information sessions with Dealer Groups, advisers and Fund Managers. Engage with you on solution design Platform solution rollout through Wrap Desktop and AdviserNet

17 Wrap Up Training and support Training and support for you and your support staff Tools to help you educate and inform clients on change, and demonstrate the value of advice. Disclosure documents updated and your clients informed (where legally required) Ongoing updates through regular publications, events and your BDM

18 Open forum

19 Thank you!