The FAAA is recommending the incoming client consent obligations be adopted by advisers well before the 9 July deadline to avoid penalty payments for non-compliance.<\/p>\n
The organisation is reminding advisers that it is the date of issue or sale of a policy that determines if the new consent requirements apply, not the date the adviser provides their advice.<\/p>\n
\u201cGiven the time that it may take for the insurance policy application to be processed and underwriting to be undertaken, it might mean that there will be a reasonable delay between when the advice is provided and when the policy is issued or sold,” states the FAAA.<\/p>\n
The organisation adds that\u2019s it important advisers provide the required disclosure information to their client and obtain a compliant client consent before any commission has been paid for insurance policies issued or sold from 9 July 2025.<\/p>\n
\u201cOtherwise, the commission would be classified as conflicted remuneration, be considered non-compliant, and attract penalties,\u201d states the FAAA.<\/p>\n
It recommends licensees start this new requirement by:<\/p>\n
For further information on the Life Insurance Client Consent obligation see ASIC Information Sheet 292<\/a>.<\/p>\n