Finally, what a great article (https://www.professionalplanner.com.au/2019/01/accountants-carve-out-request-reveals-professions-wounds/). To hear this uttered from an accountant is truly heartening but very long overdue. As a practising planner for 11 years, I have often come across the poor ethics of accountants, especially in the SMSF space, with the implementation of SMSF with no investment strategies and questionable advice supporting investments and especially property advice. Many of the ‘failings’ of advisers have in fact been accountants and they should have their own royal commission. When an accountant can give significant advice to a client verbally without any written or follow up information there is a problem in the industry.
Les Hayward, Prosperity Wealth Management in Applecross, WA
This (https://www.professionalplanner.com.au/2019/01/asics-adviser-levy-to-be-invoiced-this-week/) is why I have no option but to charge my clients an ongoing retainer fee; to help pay for the ongoing charges & raft of regulatory expenses being imposed on us by the Federal Government. FoFA has been a major cost impost on consumers, with the only result being an actual fall in the level of advice being provided. And if you have ever seen a fee being charged for doing nothing (which advisers are continually accused of), this latest annual fee from ASIC is an excellent example.
Steve Blizard, Roxburgh Securities in Guildford, WA
This article (“Accountants’ carve-out request reveals profession’s wounds”, Professional Planner Online, January 24) is a thoughtful and succinct expose of the state of play for accountants in their intersection with the provision of financial services.
I started out life as an accountant and saw very clearly how the profession/designation of Financial Planner was complementary and, in my specialisation, essential for end to end advisory services. It was this dynamic that forced my hand. I made the move to skill up in the financial advice profession and will never forget the parting words of “why are you going across to the dark side?” I idealistically imagined my return to accounting as someone that could provide end to end services; a qualified tax and accounting professional that could also provide financial service advisory. Sadly, the accounting profession didn’t embrace this concept and never found that perfectly blended role. I am however valuable in financial services as I can bring my tax and accounting experience to the role and provide a complete understanding of client advice needs. Parts of the professions are ‘hand and glove’ or, more aptly described, two sides of the same coin.
I only wish the accounting profession had been more pro-active in building out operating models to incorporate this service offering into their practices. Perhaps it wouldn’t have taken the banking royal commission to finally identify that some things need fixing as the accounting profession could have brought its significant experience (and longevity as a profession) to the table and added meaningful value to the financial planning professional journey. Instead, as Mr Brown pointed out, it suffered from being up the top of the high and mighty mountain peak and now is feeling the impact from the inevitable fall.
Kym Bailey, JBWere in Sydney, NSW
Indeed, it is not a lack of self-confidence in women, nor do women need to be fixed (“Stop trying to fix the women”, Professional Planner Online, December 3). It is more the case from my observation that many men are uncomfortable around strong intelligent attractive women who seem to distract them from the task at hand. Hence, why many women in position of leadership end up emulating men in the way they dress and conduct themselves. These women become rather masculine to fit in. Femininity and authenticity among female leaders are seemingly discouraged in the board room or in management positions in predominantly male dominated industries.
Angelique McInnes, Central Queensland University
The sooner industry funds have to disclose their true costs and all superannuation funds – including SMSF’s – are treated with the same reporting requirements, the better (https://www.professionalplanner.com.au/2019/01/super-transparency-rules-to-impact-advisers/). Saying a fund can be run for $1.50 per week is a joke when there is advertising run on every TV station in every city, every day to promote industry funds. Last time I saw, TV stations did not do this stuff for free as a community service. There needs to be a ‘one rule for all’ mentality and not what we currently have. However, does anyone with a vested interest really want a level playing field?
The industry fund lobbyists have very deep pockets and significant political clout, particularly if we have the expected change of government this year. I encourage you to look at the annual accounts of any industry fund and determine the true cost to the members. I did this a few years ago with CBUS and the cost was around 6 per cent of AUM. A far cry from just $1.50 per week but industry funds were carved out of FoFA legislation and they hide these as ‘costs’, not fees – at the end of the day it is coming from the retirement assets of the members and whatever name you call it, it does impact the bottom line for a member.
Have the confidence to investigate how these funds work and how they charge – you will be surprised how quickly you are contacted by IFS or a similar body to ask you to remove any article!
Martin Watson, Bellwether Financial in Perth, WA
Regarding the poll, (“65% say advisers not obligated to help clients’ parents”, Professional Planner Online, January 22) the client and their parents may well have conflicting interests. Unless the parents are also clients the adviser to their children may well (probably does) have a moral duty of care to discuss the situation, [and] any advice must be given in the context of “who is my client?”, with all the potential conflicts of interest set out.
A better idea is to bring the parents in as clients and address their issues separately, but with reference to their adult children’s situations (and even wishes) in an open discussion. Advisers should be very careful NOT to deal with parents of their adult children clients.
Philip Carman, Personal Asset Services in Perth, WA
Yes, I do also agree with Richard Dahl (https://www.professionalplanner.com.au/2018/08/heaps-of-education-may-not-be-enough/)that education is very important to help raise the standards of advisers and the quality of advice given. I am not as ‘qualified’ because all I have is the new Advanced Diploma in Financial Planning and yes I have a few other accreditations and a Diploma in Mortgage Broking and with a fair bit of experience, but all that still puts me directly in the path of doing a full degree before January 2024.
This is a very complex and worrying time for me, because I have been giving personal advice since 1981 and when Jan 2024 comes around (yes, 43 years at the age of 63) I am looking at 4 years before I plan to retire. I see no point in spending Time and Money on a degree that will not help improve the quality of advice for my clients in a 4-year period. I am also in the firing line of spending thousands of dollars with the prospects of never paying the “HELP” debt back to the government because my taxable income and the time frame I have left to work will not be enough pay the debt off. Plus the hundreds of hours I am not putting into my business to increase my income to help towards my retirement. I also know I do not have the time to devote three years full time to a degree or possibly 5 years part-time . I have one employee, so all of the pressure is on me to see the clients and keep the business running.
I see this course of action will more than impact my business it will damage my business value, my clients, my family life and my retirement.
Roland Knight, Infocus Financial Advice in Caboolture
Your article on older planners leaving the industry is almost absurd (https://www.professionalplanner.com.au/2018/11/faseas-impact-coming-into-view/) I am one of those older planners who is likely to leave the industry as the changes take place. I was planning on retiring in the next 5 years anyway, as would be a large number of planners in my age group. Your article implies that our retirements are due to the changing educational requirements.
I fully support the changes and will probably act to meet them purely because I enjoy building my knowledge, but I am still intending to retire about then. And I accept that others in my age group may bring forward their retirement because they do not wish to invest a lot of time to extend their careers by 1 or 2 more years.
Steve Trevisiol, Western Financial in Perth, WA
Regarding your article https://www.professionalplanner.com.au/2018/11/time-to-stop-the-diversionary-tactics/ The Royal Commission highlighted that there are people who lack ethics and integrity. However, if you look closely, you will find that the foot soldiers of the organisations raised the issues whilst middle and senior management and executives over ruled them. Those people have degrees. As a financial planner seeing clients every day, our ability to provide advice is becoming more difficult and more expensive. On average I estimate that compliance-related issues now account for at least 1 working day per week. Clear systems and processes are the answer and a compliance department should assist rather than hinder them. Senior planners are exiting the industry because they do not want to shuffle documents. Their aim has been to help people with investing and financial planning. A career in financial planning is no longer attractive or rewarding.
Gail Gadd, Lifespan Financial Planning in Cherrybrook, NSW
Good pickup, Tahn https://www.professionalplanner.com.au/2018/11/cost-of-youth-sport-blindsiding-parents/ As a parent and adviser there is no doubt this is an area of expenses that catches most parents out. If your children’s interests are more in the arts (dance, music, etc.) then it gets a lot more expensive. Ask a parent with a child into dance and you’ll find the costs are 3-4 times more than in your article. Throw in private school education and the numbers go through the roof.
Even parents with really good incomes are often treading water or going backwards financially during their children’s teenage years.
Jason Smith, Think Independent in Melbourne, VIC
As an Adviser who has been practicing for over 20 years and achieved CFP in 2000, I find the FASEA recognition of prior learning and experience very disappointing https://www.professionalplanner.com.au/2018/11/fasea-deals-fpa-afa-members-a-rough-hand/
I would also question why we would now need to have membership to the FPA to maintain a CFP designation that no longer has any relevance. I will now need to spend between $16,000 and $32,000, depending on the institution, just to retain my career I have spent over 20 years building. The one area they have not addressed is character. Knowing rules and code of conduct means nothing if you don’t have the right character to do the right thing by the client.
Craig Ives, Crowe Horwath in Hamilton, VIC
It would appear that the more experienced you are as an advisor and therefore holding qualifications that were the best at the time, the more you are disadvantaged under the FASEA guidelines. https://www.professionalplanner.com.au/2018/11/fasea-deals-fpa-afa-members-a-rough-hand/
Being a 62 year old with a 30 year unblemished career and a CFP since 1992 makes no difference in FASEA’s thinking. It’s very clear they want older advisors gone, even if they are experienced and well trained.
Gerry Lenihan, Internexus Planners in Sydney, NSW
As an adviser who obtained my CFP designation prior to 2007, I wonder what the relevance of the designation will be moving forward. https://www.professionalplanner.com.au/2018/11/fpa-says-cfp-designation-up-for-review/. Also, why I would continue to pay a premium for my FPA membership when, although it is the gold standard designation in financial planning, I won’t have achieved the minimum standard required to do the role I have been doing for the past 20 years. I look forward to the FPA’s review of the CFP Designation over the next few months.
Todd Davis, Politis Investment Strategies in Wickham, NSW
How can they listen? https://www.professionalplanner.com.au/2018/11/fasea-open-minded-about-changing-proposals/ They dont even make their location or telephone number known. If they were serious about listening there would have been a proper and time considered consultative process, not just 8 days before the Legislative Instrument is passed. One of the most opaque and unsatisfactory processes, not taking into account the voice of the advisers. Based on the information obtained, not even listening to the members of Parliament who have expressed their concerns.
Paul Goethel, Let’s Make Money in Cheltenham, VIC
Robert, thank you for your thoughtful article –https://www.professionalplanner.com.au/2018/11/top-10-reasons-reform-is-unlikely/ Many of the points you raise are valid, and yet asset based fees have persisted in financial planning and it’s not just fear mongering. There is now a large body of study on ‘The principle/agent problem’ that explains why asset-based fees persist and are happily accepted by clients. That is, that the interests of client and the adviser are aligned with asset-based fees; if a client’s balance goes up, the adviser is paid more, if the clients balance goes down, the adviser is paid less. It’s the classic ‘skin in the game’. Before you counter with ‘too much risk is taken on’, remember that flat fees likely encourage the polar opposite result (and we see it with financial planning clients using accountants all the time) –the investments are too conservative in risk solely to protect the adviser being sued for negative results, and so underperformance is rife. Ultimately my take is that asset-based fees are appropriate where clients want returns maximised, and flat fees have a place where a client’s focus is on managing risk. In that way, the interests of the client and adviser are aligned in both scenarios.
Grant Simpson, Future Funds in Mona Vale, NSW
I am wondering what the 100 basis points refers to? – https://www.professionalplanner.com.au/2018/11/fix-your-fee-game/ I mean is this 100 basis points on top of: Trustee fee; Manager Fees; Wrap or platform fees; indirect costs? I for one would like to see total expense ratios where one can clearly decide what the cost and value proposition is.
Ian Bailey, Bailey Roberts Group in Wollongong, NSW
How refreshing to discover that I do not have to rely upon the missing “confidence” chromosome that I wasnt’t born with – https://www.professionalplanner.com.au/2018/12/stop-trying-to-fix-the-women/ Great read Leith. It is all about targets; what you want to achieve and the how to! Quotas are disruptive on all levels. My question for all: how do you become the best version of yourself and bring that to the table? Isn’t all of this really competition between the sexes? If you are good enough or competent enough you get the gig. If not, then simply find the way. Just do what it takes and eliminate excuses, Girls.
Kerry Mitchell, Live Smart Financial Group in Brighton, VIC
Perhaps all advisers should establish a return on investment (ROI) or business case for each dollar of fees one spends on them. If the client is better off by a certain percentage after paying fees, then it is worthwhile. This should be done on an annual basis for OSA fees. https://www.professionalplanner.com.au/2018/12/are-osas-in-the-clients-best-interests/
George Manka, CPS Private Wealth in St Leonards, NSW
This article is so ill informed, it’s another case of an ‘outsider’ from another profession is trying to influence her uneducated opinion on another profession https://www.professionalplanner.com.au/2018/12/are-osas-in-the-clients-best-interests/. She obviously has no understanding or has never been through the process of what ‘real financial advice’ encompasses, which is helping clients make smart decisions with their money, and this cannot be done on a transaction basis like the legal profession.
Duncan Essery, ARA Consultants in Kew, VIC
Ms Plater raises an interesting issue – https://www.professionalplanner.com.au/2018/12/are-osas-in-the-clients-best-interests/, however, it also raises the issue that if OSAs are removed it may result in planners becoming fund managers to preserve revenue streams from OSAs, which presents another set of risks for consumers. Careful consideration needs to be given to unintended consequences arising from any legislative change or recommendation and given the uncertainty surrounding the introduction of FASEA’s education standards and the as yet unknown recommendations from Hayne’s Royal Commission. Speculating about what will or won’t be recommended by Commissioner Haynes, or an individual’s personal views on the provision of advice does not add to the debate.
David Barber, Pario Financial Management in Kew, WA
You could also argue that people are better off by simply exercising and eating more healthy rather than utlising Personal Trainers & Dietitians and yet these fields are still big industries – https://www.professionalplanner.com.au/2018/12/are-osas-in-the-clients-best-interests/. Do not underestimate the importance of a guiding hand to encourage you and motivate you to do what is in your best interest and stick to your goals.
Jonathan van Omme, BOS Financial Strategies in Osborne Park, WA
The idea that Bowan will rubber stamp the Royal Commission’s recommendations is belligerent at best. None of the recommendations will come with economic costing as this has not been requested in the terms of reference. By saying this he could well do irreparable harm to the Australian Financial sector. That can’t be in anybody’s best interest.
Susie Erratt, Advanced Financial Planning Solutions in Darwin, NT
This is one of the better and more even-handed approach I have seen in the media- https://www.professionalplanner.com.au/2018/12/advisers-not-pre-empting-commissions-ban/. While it shuts up screeching media about advisers to have a ban on grandfathering I don’t believe that the media understands what grandfathering is for income and the client. I extend an open invitation to any journalist hack to work for a week in my office and do the compliance documentation, sit in the client interviews, do the study and run my business. The reality is that business older than 2010 will have legacy clients with some small amount left of training commissions. The clients will be in allocated pensions and annuities that are running down after 10 or 15 years. The elderly clients in receipt of the age pension cannot be moved to a new contract or product because of the changes to the age pension 1 January 2017 because they will lose their benefits and most of their pension income. Moving them will not be in their best interests and rebating trail send it back to the product manufacturer to line their pocket. Also, the clients are well aware of all fees as these are disclosed in their advice, reviews, fund manager statements. The media headlines look like the clients don’t have the intelligence or the wit to know what they are paying for nor the relationship with their adviser.
The other reality that is clearly promulgated in the article is that the industry built their business based on the current legislation and rules. Many single parents, many of whom are women, bought existing client bases to grow a business that has flexible working hours, can be run from a home office and go out to meet clients. Succession planning uses the older client bases to build a business or take over an existing family business.
Politicians that blithely state that the RC recommendations that grandfathering will be banned without consultation will send advisers to the wall and how will these advisers repay their loans? What will happen to their clients? Not in the clients best interests again.
Philippa Hunt, Seachange Strategic Investments on the Gold Coast, QLD
Regardless of what the employment contract says about “ownership” of a client (Who owns the client?, Professional Planner Online poll, October 11), the client is the one who determines whom they wish to deal with. An employment contract may build protection for the firm around who “owns” the right to contact clients and retain transactional or ongoing fee arrangements but these cannot defend against the client deciding to leave their business with the employer or move it away, either to a departing adviser’s new business or somewhere else. I believe the employment contract cannot overrule or disallow a client’s right to deal with whomever they wish. This is further evidenced by the new opt-in/opt-out rules, which give further weight to clients’ right to move their business. The employment contracts deal more with the conduct of the employer and of the adviser whilst employed or in the event of departure.
Rob Maroni, Patersons Securities in Albany, WA
The simple, fundamental fact regarding franking credits (“Assistant treasurer attacks Labor’s ‘retiree tax’ ”, Professional Planner Online, October 30) is that few people, and even fewer politicians, understand what they are, let alone how they work, nor their integral relationship with company tax. ‘Company tax’ is, in fact, a misnomer; tax that companies pay should rightly be called shareholder dividend tax. In principle, ‘company tax’ is no different to PAYG tax remitted on behalf of employees, with the accrued tax credit taken into consideration at the time of each individual’s income tax assessment. Just as the ‘paid in advance’ shareholder dividend tax is a credit (though we refer to it as a tax ‘offset’) against total assessable income tax liability. That’s why reducing or increasing so-called company tax ultimately remains tax neutral to companies, shareholders and, of course, to Treasury. Ask a politician to explain the relationship between company tax and imputation credits. Paul Keating, the architect of the imputation system, fully understood.
Jack Wellings, WellInvest in Hornsby, NSW
The FPA has been caught with its pants down (“CFPs wait nervously for FASEA ruling”, Professional Planner Online, September 14). The CFP is clearly not one of the highest qualifications advisers can attain or else FASEA would recognise it immediately. We who have completed the CFP at significant cost and time sacrifice will have nothing to show for it. At least a university qualification does not require an ongoing membership. I have no doubts that if the FPA get this wrong (and it looks like it is going wrong), there will be a class action waiting on the other side.
Geoffrey Swanepoel, Compound Wealth Management in the Gold Coast, QLD
Great article (“Fintechs, Koch clash over branding”, Professional Planner Online, October 23). We were at the launch but not on the panel. Your article highlights the main take-away we had. We actually agree with David Koch. We believe fintechs need to get validation and build trust and you can’t do this when you’re not a brand.
Ashleigh Swayn, Absolute Advice in Sydney, NSW
There is no doubt listed investment company issuance has increased dramatically over recent years (“LICs at the high water mark?”, Professional Planner, November issue). Whilst there are now more than 100 LICs on the stock exchange, this is small in comparison with the platform market, which can have up to 3000 investment strategies on a menu. A structural trend supporting the growth of this market is that SMSF investors feel more engaged to make their own investment decisions and use the exchange as a platform.
Whilst capital raising is cyclical, we believe building a sustainable LIC and LIT sector with reputable investment managers focused on shareholder outcomes is of great benefit. Furthermore, discounts to [net tangible assets] NTA currently present an opportunity for investors; however, access to insightful information about the manager is critical to understand if the discount is likely to persist. Investors should also ensure they understand how an LIC would fit into their portfolio, rather than basing an investment decision on past returns – especially at this point in the cycle.
Conor O’Daly, Pinnacle Investment Management in Sydney, NSW
I have been in the industry for 20 years. FASEA is a big concern. But right now, for me, the fallout from the royal commission (“Advice in the wake of Hayne”, Professional Planner, November issue) in relation to ongoing service arrangements has the ability to ruin my practice financially.
This has to do with the way dealer groups are auditing client files as requested by ASIC and, in some cases, refunding fees. Throughout the audit process – spanning a time when I’ve been licensed under my current and previous licensees for several years – I have had to correct the auditors’ interpretation that ASIC would perceive a client had not been serviced. For instance, in one case, when a client turned pension age, instead of an annual review, I did a new SoA. I did not charge the client, as this is part of the ongoing services provided. This was discounted by the auditor and the ongoing service fee and interest were refunded to the client. This is just one example of many. Further, the auditors directly contact the clients without my knowledge and issue the refunds without consultation with me.
How can it be legal for ASIC to clarify what they meant FoFA to be now, post-royal commission, and then make this retrospective? Planners have relied on their compliance managers to decipher and advise how to implement FoFA in their practices. Over that time, planners have paid their dealer fees, worn operating costs, been liable for advice in relation to strategy, portfolios, insurances etc, and paid tax on the income and business activity statement. So if advice businesses have to pay back fees covering a seven-year period, how do they get compensated for the over-payment in dealer fees and taxes? Being a small practice, I don’t have a cash reserve to do any refunds. Further, I have taken out a business loan based on the revenue to buy out a partner. I have to maintain a level of cash flow as part of the lending requirements. I feel alone in this process and have been told I have no legal standing. Where does an adviser turn to get support through this process? Where is the voice for the planners in the whole royal commission process?
Lisa Watzek, Compass Wealth Strategies in Cleveland, QLD
Couldn’t agree more – “FASEA, ASIC ‘ambivalent’ on investment oversight”, Professional Planner September 2018. A lot of the continuing education required now and in the future seems to be around ethics, which is fine, but what might be getting lost is the investment knowledge of advisers. ASIC has a role, but unfortunately it has spent a long time listening to the big end of town tell them what advising is about, and has not consulted with independent thinkers who actually have a licence to deal in securities.
Ian Bailey, Bailey Roberts Group in Wollongong, NSW
Forget about TMI “Super sector’s bad case of TMI”, Professional Planner September 2018”. They have deliberately misled the royal commission. The main issue is NOT the fee refund, it is the fact that they levied fees for not doing anything. In any civilised society this is theft. Put another way, the funds are holding the money for the members. Taking fees, without justification, is theft. The words “trustee of the fund” should be a real giveaway.
George Lawrence, George Lawrence Chartered Accountant in Bowral, NSW
It’s sad to hear the vitriolic of the likes of Ray Miles “Ray Miles fronts ASIC’s Macaulay on licensing”, PP Online August 9. There are always two ends to any spectrum. The world has changed and might I add that ASIC has significantly enhanced its process in approving AFS licenses. We just went through an AFSL approval and we had to demonstrate financial competence in presenting a balance sheet with forward projections and demonstrate all competencies to run an AFSL for the advice authorisations we are approved for. I dare say, this was not something that was prevalent in the past. There has been too much pressure applied on the regulator by the bigger end of town forcing the regulator to act as a gate keeper in my opinion and this more evidence of this stale type of thinking. Times have changed and it’s far more important that participants get on with it, than argue over the state of AFS Licensing. The irony is this is a result of the end of vertical integration and the small, the medium and the big all deserve the opportunity to practice and put their best foot forward, much to the chagrin, it would seem, of the established.
Robert Joseph, Freedom Wealth Advisers in North Sydney, NSW
Regarding your article “Death of the licensee as we know it, PP Online August 31 – approved product lists have long acted to preserve the status quo in product selection. In my time trying to establish the first managed accounts, it proved impossible to break into the product lists of large groups that were controlled by banks, undoubtedly because my efforts posed a threat to the bank owned unit trusts and expensive platforms. In the end, in recent years, the sheer appeal of managed accounts for clients has led to the growth of independent licensees who now use them in droves as HUB 24 alone is taking 10 per cent of new monies.
John Aldersley, Aldersley Capital in St Huberts Island, NSW
Mr Reddacliff’s idea to restructure the financial planning industry more along the lines of an accounting industry with a public practice certificate, is one of the most sensible proposals I have seen touted for a long time Death of the licensee as we know it,” PP Online August 31. Advisers definitely need support, but this should be without product conflict, as any profession would expect. The only way the client’s best interest can be truly served if all the temptations are removed from the Planners’ line of sight. A focus on adviser capability and compliance has not improved the system, so let’s look at whether it is possible to conduct this business without the current structural arrangements that have developed with Licensees.
Kym Bailey, JBWere in Sydney NSW
I disagree with your article Death of the licensee as we know it,” PP Online August 31. Licensees are not dead, they are transforming. You reference an unnamed industry expert, who doesn’t want their name to get out? I’m a 30 year veteran in our industry, and am half way through my post grad studies through Griffith Uni. Not all us older guys are the reason the industry is where it is. If you truly represent the professional planner, then my question to you is what does that look like?
Mick Sykes, EZI Protect in Sydney NSW
Good article David “Everything’s going to be ok” Professional Planner September 2018, exactly what clients are looking for, the “I can realistically achieve my goals factor”.
Mark DiPietro, Shadforth Financial Group in Sale, Victoria
Regarding the article “Facebook gives me an edge”, PP Online August 17. In the Facebook Help Centre they state “It’s against the Facebook Community Standards to maintain more than one personal account.” Find this by searching “multiple accounts”. That’s important to know before following the strategy this adviser uses if you’re also intending to be ethical.
Matthew Hern, AMP Advice Subiaco in Subiaco, WA
Regarding the article “Opt-in rules put premium on insurance strategies”, PP Online August 13. This will be very restrictive on choice of superannuation going forward. The key issue is that most group insurance can’t be taken over by another fund so if the member has health issues they can’t get new insurance and may well have to stay with the fund they start with even if it isn’t their choice.
Damian Ebzery, Lifestyle & Investment Planning Solutions in Graceville, QLD
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