Australian Financial Services Licensing (AFSL) Forum

Home Forums Australian Financial Services Licensing (AFSL) Forum Training and Compliance Policy

This topic contains 1 reply, has 2 voices, and was last updated by  Archived User 8 years, 3 months ago.

Viewing 2 posts - 1 through 2 (of 2 total)
  • Author
    Posts
  • #2384 Reply

    Hi there,

    The Group I represent is a ‘Holding’ company that wholly owns two ARs, who are the issuers.
    I have attempted to buid the AFSL compliance framework from zero and I’m floudering a bit with regards to the above. I wish to include monitoring and supervision into this document as well as training and legal compliance matters. As a Group we only provide general advice, with regards to a non cash payment product, and I do not want to overburden managers with unneccessary compliance tasks. If anyone can suggest an acceptable level of training/supervision/monitoring with regards to Compliance for the purposes of AFSL it would be appreciated.

    #3067 Reply

    The standard answer to your question is that your systems need to be scalable to the nature of your business.  That said, ASIC has a bunch of expectations that effectively set a minimum benchmark.  There are plenty of off the shelf compliance procedures kits that include a monitoring program and a compliance diary or equivalent (we have one, for example).  However, when implementing the supervision and monitoring, that comes down to actual practice and can be difficult to do in a way that doesn’t stifle business – as you rightly point out.  For example, call centres may require a script to be used and then compliance staff will monitor a percentage of calls and check them off against a compliance checklist.  We have a client that only offers one product and gives some general advice but primarily gives no advice.  We provide no-advice training to their staff approximately annually.  There are also various “do’s and don’ts” checklist using traffic-light systems that are used in their office.  Monitoring and supervision in their instance is fairly “light touch”, but is scaleable and appropriate to the amount of financial services provided. I would be interested to know how the two ARs (I assume you mean Authorised Representatives) are issuers.  Is this via an Intermediary Authorisation?  Using ARs as issuers throws up a few complex and interesting legal issues.

     

     

    If you require further information, please feel free to contact our office.

     

    Author: Paul Derham

Viewing 2 posts - 1 through 2 (of 2 total)

Reply

Reply To: Training and Compliance Policy

Your information:


<a href="" title="" rel="" target=""> <blockquote cite=""> <code> <pre> <em> <strong> <del datetime=""> <ul> <ol start=""> <li> <img src="" border="" alt="" height="" width="">

  • Free answers to common Financial Services Regulation (FSR), Consumer Credit and AML/CTF issues.

    Click here to join our LinkedIn group for responsible managers and compliance professionals.
    joinUsOnLinkedIn
  • trex

    Tailored Regulatory Exchange

    what is this and does it bite ?

    Find OutLogin

  • Legal Advice

    Review your AFSL or ACL disclosure documents, conduct a licensee audit and more…

    Get Legal Advice

  • Compliance support

    Responsible Manager Training, AFSL, and ACL applications and variations and more…

    Compliance support