The chief executive of both Matrix Planning Solutions and Clearview Financial Advice, Allison Dummett, says a lot has changed in the advice compliance landscape over 20 years.
But after two decades, she says, we’re “almost at the end of the journey”.
“We know specifically what’s expected in the advice journey end-to-end, what you’re expected to demonstrate in advice documents,” she says. “In 1999 you didn’t have to give the client a written advice document. 20 years later we know chapter and verse what the regulator expects in it.”
Dummett was part of the founding team at Matrix in 1999 and has spent all but a few years in the last two decades working as an executive for listed firm Clearview Wealth, which owns both the Clearview and Matrix brands that oversee around 230 advisers.
Back in 1999, Dummett recalls, license applications meant “a lot of paper” from ASIC. While technology has made the process less manual, becoming an Australian Financial Service License holder now involves more work now, she reckons.
“In 1999 you did a lot of background checks and you had to display a lot of organisational competence for the application,” she says. “But [it was] very different to how we lodged everything in 2004 when the Financial Services Reform came in and everyone’s license was varied.”
The FSR Act was a turning point, Dummett explains.
In 1999 you could “cut and paste from the Corporations Act and just dump it into the application”, but after the FSR Act – which brought financial services and products under one regime and introduced a raft of disclosure documents like Financial Service Guides and Statements of Advice – the process became more onerous.
“In 2004 you had to do a test on proofs and policies which was linked to your obligations as a licensee. You had to have written evidence to show you had thought through how you were going to monitor and supervise, how you were going to do disaster discovery, manage complaints, your financials etc,” she explains.
Fast forward to 2019, and Dummett reckons the financial planning industry is at a point where the licensing process, and the compliance and governance around providing advice, is almost as prescriptive as it can be. The extra compliance requirements that come with a strong regulatory framework have increased the cost to serve, which means growing a business organically can be problematic.
20 years ago, she says, an adviser could be a one-person operation and didn’t need a big capital reserve to start on.
“If you had a little bit to get by on you could build that business,” she says. “So many practises grew that way, incrementally, because you were able to build up that recurring revenue stream with clients.”
For someone starting an advice business today, she says, there is a “massive change” – one that would impact the swathes of advisers leaving institutional advice brands in the wake of the royal commission.
“You’ve got a cost to serve from day one and you need to think about how you capitalise that start up,” she says. “If you’ve got bank planners who no longer have an employer but they want to start an advice business it’s a different proposition for them.”