We have been operating as an authorised representative for close to 2 years now, we run a financial services comparison site. My question is, if a member of our team attains RG146 certification will this represent sufficient experience and qualifications to apply for our own AFSL?
Under ASIC’s RG105 there are five options available to demonstrate the skill and knowledge required of a responsible manager. To demonstrate skill, the minimum relevant experience is 3 years within 5 years. Note that this must be ‘relevant experience’. It may be that not all industry experience is accepted, depending on the circumstances. The knowledge component must also be satisfied. RG146 alone may not be enough to meet the requirements, and it’s likely that 2 years industry experience would be insufficient.
David makes a valid point, in that both a licensee and an AR are required to meet the RG146 standards in order to provide financial advice. Given the nature of the forum we refrain from discussing current business structure and compliance.
The requirements are complex and we would advise you to seek legal advice on the matter to ensure potential RM’s meet the minimum requirements set by ASIC.