Word came through a while back that our licensee had been slapped with a complete client file request from the corporate regulator. A meeting was called.
“Right then, everyone is going to remain calm,” declared our venerable chief executive, inducing most of us into a mild panic. “We have five weeks to run through the books and show ASIC that we’ve delivered statements of advice and provided appropriate services.”
This was different from the annual audits we were used to, he reckoned. There would be no selecting a handful of robustly administered cases with an array of fastidiously recorded advice documents. They were after every client record. It was finally happening.
I was emailed an excel spreadsheet with columns to populate with details for each client in terms of documentation delivered, and a USB stick on which I was to attach service agreements and service evidence. An accompanying email reminded me that our practice is responsible for any remediation amounts owing to clients, which makes me wonder what the billions of dollars our institutional overseers are putting towards remediation are actually for. Nevertheless.
Thing is, I see all my clients at least every year. I’m a decent adviser, and I’ve come to call myself a decent record keeper as well. But that last one wasn’t always the case.
Most clients I’ve had for longer than five years have a file on our hard drive with a dizzying list of word documents, PDFs, statements and records of advice, saved pictures of diagrams on scrap paper, scanned bills, spreadsheets, letters, tax returns, sale agreements and assorted clerical detritus. The diligent creature that I am, everything gets saved.
A half dozen of my more Jurassic clients have the bulk of their files in a collection of bulging and frayed manilla folders under my desk. Sometimes I rest my foot on the box they are housed in.
I expressed some concern to the aforementioned CEO about the state of my record keeping affairs and was told to do my best. After explaining several doubts I harboured that ‘my best’ was even partially adequate for the task I was allocated the services of Jenny, the work experience girl.
As luck would have it, Jenny is eminently capable, thoroughly organised and a social recluse. In other words, a born compliance specialist. In between grunts of disgust she’s been peeling apart reams of yellowing documents and scanning them within a brilliantly sequenced filing system she created on my formerly slipshod hard drive. Somehow, this is also being exported onto Xplan. What a world.
Much to Jenny’s surprise, I have managed to provide service agreements and retained service records for all my clients so far. Except, ironically enough, my own mother, who despite being my client for almost 20 years remains reluctant to let me see her accounts. I suspect she’s still punishing me for re-gifting a sewing kit she gave me for Christmas in ’94. I assumed she wanted it back.
A good outcome looms. My spreadsheet and my thumb drive are both full of righteous evidence. The venerable CEO is relieved we won’t have to figure out exactly who would be paying client remediation.
And Jenny, the unsung hero, the foil to ASIC’s stinging inquiry, is considering her offer of full-time employment. No doubt I’ll be the Robin to her Batman before long.