From time to time I see Auth Reps providing their own FSG and other times the AR gives out the licensee’s FSG. Can anyone shed any light as to why the AR would be providing their Licensee’s FSG and not having their own FSG?
The providing entity, whether it is the licensee or the AR, needs to give an FSG when it provides financial product advice to retail clients. One licensee can prepare an FSG for all of its ARs to give out, provided that it meets the content requirements in the Corps Act; one of these requirements is to list the authorised representatives.
Do the licensee’s FSGs being given out by the ARs you have seen state that the providing entity is an AR of the licensee? If not, there may be an issue.
If you have any specific concerns, you can contact our office and speak to one of our financial services lawyers for advice.
Well David, very good question. Here at Compliance Specialists Australia we see this often and the facts are, AR’s cannot operate under the FSG of their licensee. In practice, the FSG of the licensee is fundamentally different from the AR in respect to authorised products and services and numerous other material particulars. The licensee should assist and approve the FSG of the AR, only after review and tailor making to the needs and requirements of the AR. Should you need further clarification, please call one of our specialist’s staff.