A good problem to have
Given that we’ve reviewed over 1,630 advice files in 2019 alone, I’m not surprised that we’re often referred to as ‘compliance auditors’.
Although I’m slightly happier when we’re referred to as ‘Australia’s best compliance auditors’, I think that even that recognition trivialises the scope and scale of the Assured Support business and the innovative technology that we apply to what is often a reactive and conservative function.
Even when I worked at larger institutions, I never had access to the technology, tools and analytics that Assured Support has developed and uses. The granular analysis, clear and consistent reporting and comparative benchmarking that’s at the heart of our qualitative Advice Assurance methodology, delivers a superior review. When the reviewers themselves are commercial, practical and experienced, the review delivers real and substantial benefits; advisers improve both the quality of their advice and their advice processes while licensees can clearly see how their risk profile changes over time.
This may not seem that important to some Licensees, at least until the Regulator comes knocking – at which point, detailed reporting and comparative data become more of a ‘must have’ than a ‘nice to have’.
Although I don’t want to simply focus on audits, I think our ability to measure advice quality in a consistent and predictable manner over time is a standard to which the larger institutions aspired but never reached. I love sitting down with clients and being able to show them how they compare against the law, their peers and the industry benchmark. It’s thrilling to see how engaged they become when we present them with their progress over time compared to the industry median.
We’re one of the few independent AFSL compliance businesses with the scale and expertise required to pivot from dispute resolution to large-scale remediation, to move from building Responsible Manager frameworks to training on ethics and standards, and then completely redesign supervision and monitoring frameworks to integrate remediation and effective consequence management.
We have an impressive flexibility and a capability that extends far beyond ‘adviser audits’. I’m happy to talk to anyone about why they need assured support, but I’ll limit myself to presenting eight reasons why you should call or email me.
Organisational design and operational effectiveness
You review your advisers to ensure they comply with the financial services laws and your license. Shouldn’t your business get a regulatory health check to ensure that you don’t uncover issues when it’s too late to address them.
As an Australian Financial and/or Credit Licensee, you operate in a highly scrutinised, highly regulated and frequently changing environment.
Laws, regulations, policies, commercial pressures, ethical and professional obligations, consumer expectations and industry standards create a complex web of duties and obligations with which you must comply.
In addition, you’re expected to regularly assess your culture, compliance frameworks and governance arrangements to reassure Regulators, Insurers and other stakeholders that your business operates “efficiently, honestly and fairly”.
We start by considering the measures, processes and procedures you have in place and, through analysis and interviews, appropriately expand the review beyond compliance to encompass an assessment of other matters including your:
- governance structure
- approach to advertising and promotion
- application of FASEA Code of Ethics
- regulated documents
- remuneration model; and
- your human, financial and technological resources.
The report you receive is a detailed, objective and insightful assessment of your compliance arrangements, culture and controls.
Tailored compliance documents
You need measures, processes and procedures appropriate for the nature, scale and complexity of your business. We can help and ensure that they’re current, practical and effective.
Instead of the generic, boilerplate solutions mass-marketed as transactional services, we work with our clients to develop and maintain customised solutions including:
- Compliance framework
- Obligations Register
- Licensee Standards
- Policies and Procedures
- Tools and templates
- Advice document templates.
Tailored, engaging and effective content
As an adviser, I sat through hours and hours of ‘professional development’ that did little, if anything, to improve the quality of my advice or my knowledge of the regulatory environment. Given that experience, I didn’t anticipate that ‘compliance’ could be engaging, challenging and confidence-building.
You might expect me to say that, but that’s been consistent feedback from course participants. If you get a chance, enrol in the Best Interest Duty workshop and come prepared for a highly interactive session, challenging your assumptions, understanding and processes.
Our Responsible Manager sessions elicit similar feedback.
Our suite of workshops – mapped against FASEA’s requirements – are designed to provide participants with the skills, strategies and techniques they need to thrive in a complex and frequently changing industry. Participants benefit from practical insights of experienced subject-matter experts, devour content designed to enhance advice skills and benefit from content informed by extensive industry data and benchmarked compliance outcomes.
If you’re reviewing your CPD program in light of the new requirements, then I think you’d benefit from reviewing our suite of workshops that address:
- Technical Competence
- Client Care and Practice
- Regulatory Compliance and Consumer Protection; and
- Professionalism and Ethics.
4. Pre-vetting and Advice coaching
We approach “compliance audits” differently because we believe that advisers should aspire to consistently providing exceptional advice, rather than simply complying with minimum industry standards. We also believe that resources are better spent identifying and preventing compliance issues than remediating the impact of those failures.
Since the Royal Commission, more Licensees have embraced the practicality of this approach and made external pre-vetting a more significant component of their monitoring and supervision arrangements. By more effectively managing these inherent risks, and doing so within tight services standards, we help improve advice outcomes, client engagement and their business.
Of course, correctly identifying problems, or even opportunities for improvement, is of limited benefit unless it’s supported by a practical, commercial and considered approach to dealing with them. Thankfully, we have the team and culture to deliver.
5. Regulatory assistance and ongoing support
One of the things I like about being part of the Assured Support Team, is that we’re a diverse, complementary team that’s open about our experience, qualifications and capabilities. Check out our profiles to satisfy yourself but I think that, if you do, you’ll be impressed with the qualifications, reputation and experience of our team.
Simply, we’re commercial and practical subject-matter experts that are driven to help our clients.
What this mission means for you is that you get objective and practical advice from people that know what they’re talking about. If you call us, we’re real live people who’ll answer your compliance questions in real time. Better yet, we’re friendly compliance experts who are genuinely interested in helping you out.
You have alternatives. You can ignore the significant costs of engaging financial services lawyers to provide you with balanced and often ambiguous recitations of the law or you can seek independent advice from institutionally-supported dealer services businesses. You can do that, but if you want clarity, certainty and confidence I think you’re best to start with us.
Experience-driven compliance technology
ASIC have repeatedly, and consistently, encouraged Licensees to invest in the regulatory technology they need to comply with the laws and their obligations. Most solutions offered to solve this problem are inflexible, poorly-designed or confuse formal compliance with effective governance.
Our solution is different because experience, expertise and deep understanding built into an intuitive platform that will lessen your compliance burden. Because it’s flexible, and because we don’t use lock-in contracts, our clients can use OpenAFSL as much, or as little, as they need, to enhance their governance and compliance framework.
In simple terms, OpenAFSL is a flexible, real-time cloud-based Licensee platform that provides you with:
- A conduct-focussed monitoring and supervision framework;
- Risk based methodologies;
- Integrated registers;
- Board and Regulatory reporting;
- Intuitive interface;
- Robust recruitment and appointment process;
- Operational risk assessment;
- An effective risk management framework;
- Granular reporting and benchmarking;
- Comparative reporting;
- Flexible dashboards;
- Integrated remediation and consequence management;
- APL management and product training;
- Embedded advice metrics and trend analysis; and
- Consistent and fully auditable management of complaints, incidents and breaches.
7. AFSL applications and variations
I admit we don’t do this like some providers.
We won’t simply go through the motions and submit an application on your behalf and without your active involvement.
You’re liable for the outcome so we’ll take a constructive and collaborative approach.
We’ll project manage the application through the initial analysis, RM selection and validation to the development of the core proofs and underlying framework documents. We’ll work hard to ensure that your application is likely to be accepted but we’re more focused on ensuring that your license is sustainable.
We will work with you on this process but you control it. We can make your application process easier, we can help you build or demonstrate your capacity or vary your license matches your business and your clients’ needs.
You may be facing challenges, or decisions, that require objective and expert advice.
This is an increasingly important part of our business and one that provides enormous benefits to our clients. For everything from regulatory engagement to process reviews and remediation, we have a proven record for delivering value.
We consult to a wide range of clients from C-suite Executives to Heads of Compliance to Executive Committees/ Boards of large institutions to the small boutique firms and Industry Funds. So you can be confident that we bring a broad perspective and rich context to our advice.
Personally, I think that our investment in technology and our long-term and active engagement in the industry means we have the capacity (and the data) to provide advice and insights that are based on wide samples, proven metrics and detailed analytics.
I haven’t even addressed the full suite of services we can provide, but I think I’ve demonstrated enough reasons why we’re more than just audit. To be clear, I think we’re safe hands for adviser compliance issues, but we can offer so much more than just process and conduct reviews.
If you want more information about these eight exceptional services, or dispute resolution and due diligence, you can email me or call me on 02 8330 6628.