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Section 947D applies when you recommend replacing one product with another. It does not apply to recommendations to change options within the one super fund. If there are two products involved, it is immaterial that the products are offered by the same provider and not relevant that the advice is considered a ‘strategy’. The advice to switch from a super account to pension account will be subject to the disclosure requirements of s947D (2) and (3).
RG 175.165 is about SOA content requirements, including but not limited to s947D. If a change of product is recommended within a master trust arrangement as part of a change of investment option, s947D will apply. If the structure is such that there is no change of product, the costs and benefits of the change in investment option should be discussed but the broader s947D obligations do not apply.
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Hope that helps!
Author: Andrew Ham