There is no ASIC policy which sets out how many AFSLs a Responsible Manager (“RM”) can act for. We know from experience that ASIC is reluctant to allow an RM to be on more than 3 AFSLs. However, depending on how many other RMs there are on each licence, and the nature of your role in each licence, ASIC may only allow you to be on 1 or 2 AFSLs. As you may know, it is through its RMs that a licensee maintains its competency (competency requirements are summarised in ASIC’s RG 105). ASIC considers that an RM should:
be directly responsible for significant day-to-day decisions about financial services;
decide how financial services are provided and supervise the provision of those services;
play an active role in fostering compliance culture; and
oversee the financial services being provided.
Before agreeing to join more than one AFSL, you should also also consider: your availability, potential conflicts of interest, confidentiality and how your experience matches up with each AFSL’s licence conditions.