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Thanks for your question.
There is no legislative provision that prevents multiple licensees from combining to use one Financial Services Guide (FSG). However, financial services disclosure is required to be clear, concise and effective, which may be difficult to achieve under this approach. We would normally suggest each licensee maintain its own FSG, but see here for an example of one FSG which covers several licensees.
ASIC Regulatory Guide 168 (Disclosure: Product Disclosure Statements (and other disclosure obligations)) sets out ASIC’s view of the principles of good disclosure. These include that disclosure should (among other things):
- be relevant and complete;
- highlight important information; and
- have regard to consumer needs.
Each FSG must also be kept up-to-date at the time it is given.
Presumably, this will be more difficult if the required disclosures for multiple licences are combined in the one FSG. As the structure of each FSG will depend on the nature of each business and the product being offered, we normally suggest that separate FSGs are maintained, or alternatively, seek further legal advice.
Please feel free to contact our Financial Services Team if you require further information.
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