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Thanks for your question.
The Corporations Act requires that financial services licensees ensure their representatives are adequately trained to provide the services under their license. As you noted, RG 146 sets out the minimum training standards required for some financial product advisers. Generally, RG 146 requires that natural persons who provide financial product advice to retail clients must meet the relevant training standards. However, those training standards do not apply to the provision of advice to wholesale clients.
RG 146 may nonetheless serve as a guide for licensees whose representatives provide wholesale financial product advice. The guidelines specifically note that it does not diminish any overriding duties prescribed by the Corporations Act or the common law – such as the duty to act as a reasonable professional adviser and to provide your services with due care and skill. The training guide is flexible, and the Corporations Act places responsibility on you to decide how you will comply with your obligations. You may also want to refer to RG 104 – Licensing: Meeting the general obligations.
If you have specific questions about how your organisation can comply with training obligations please feel free to contact our Financial Services Team.