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If you have any comments on the following, this would also be appreciated:
– It appears that the ASIC guidance at RG 245.61 and RG245.62 presents two different options/positions.
– It appears that the option presented at RG245.61 (which provides one EXAMPLE, being to provide the FDS to all existing clients within 30 days of 1 July 2013), leaves room for another “common-sense approach” to be determined (which is completely separate to any approach determined under RG245.62)
– It appears to follow then, that such a “common-sense approach” for existing clients who already receive comprehensive annual fee disclosure as part of their annual review, could be to continue using existing annual review dates (which may or may not relate to the original date arrangements were entered into), so long as there is consistency of approach?