- Agree (75%)
- Disagree (19%)
- Not sure (6%)
Our latest poll seeks your view on the potential ‘shape’ of a new industry advice record that will replace Statements of Advice.
This conversation stems first from the Government’s acceptance in June of Quality of Advice Review Recommendation Nine, which calls for SoAs to be replaced, and more recently from a call made by Bombora Advice’s Wayne Handley at an industry Round Table jointly hosted by Riskinfo and MetLife, during which Handley argued the case for file notes to play an integral part in any future client advice record (see also: Call for File Notes to Replace SoAs).
Quality of Advice Review Recommendation Nine reads in part:
The requirement to provide a statement of advice (or record of advice) should be replaced with the requirement for providers of personal advice to retail clients to maintain complete records of the advice provided and to provide written advice on request by the client.
The recommendation ends with this observation that:
ASIC should provide guidance on how advice providers may comply with their record-keeping obligations.
Rather than ASIC providing guidance to the sector on how advice providers may comply with their record-keeping obligations – or at the very least in tandem with this guidance – there is a groundswell in the sector at the moment for the advice profession to develop its own proposal for the guidelines that should accompany whatever record or document that will eventually replace SoAs.
Handley’s statements at the MetLife Round Table have been reflected in other conversations involving representative bodies and other industry stakeholders, and these discussions are set to continue.
In the meantime, we’re keen to learn what you think about your file notes taking centre stage in future records of advice. Do you support the idea? Would you like to learn a little more about what the guidelines might be that would accompany such a move? Or do you hate the thought of your file notes being very prominent and ‘out there’?
Tell us what you think and we’ll come back to you next week…
File notes are hugely important and not only reinforce what was discussed in meetings with clients, they act as a reference point for all those who follow, be it staff, at an audit, if there is a query from the client, a possible complaint, or if an action requires further investigation.
It has been recognised by everyone that very few clients read SOA’s and those that did, came away very confused, so that whole Regulatory process needed to be changed.
People tend to have selective memories when things go right and when things go wrong.
They take the credit for the right equation and may forget what they decided on, when things go wonky.
It is amazing how quickly things can move on without undue fuss, when clearly articulated notes with dates, times and what was discussed and agreed upon can be quickly presented.
In another career I had access to shorthand typist who took dictation. In this career I now use Dragon dictating either onto Word or into a CRM which accepts dictated file notes.
But I’m amazed that, when I asked the question, of persons selling CRMs to advisers as to whether or not I can dictate straight into the file notes section of their CRM. I usually have to discover that I am indeed able to do that during any trial process, because the sales rep never thought about it.
They better change real quick, and providers of CRMs must ensure that a file note can be dictated straight into the CRM with one or two clicks, and not via the slower and clunkier cut-and-paste method from Word.
Over the years I developed a number of diagrams on Excel. The first ones were to emphasise with the client the lengths of waiting periods and benefit periods in income protection, and the impacts on budgets. These days I ask the client to initial my file copy and I leave them with their copy, all in the interest of proving to our friends at AFCA that I did indeed discuss the length of waiting periods and benefit periods with the client.
I think it’s what you have to do now, but I could be wrong!
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