Key dates you need to know

ChangeCommencesWhat you need to know - The highlightsSupporting Policy TemplatesSupporting Training Webinar
Disclosure of lack of independence1 July 2021- You must update your FSG to address lack of independence if it applies to youYes
Updated FSG template
Ongoing Fee Arrangements1 July 2021- Fee Disclosure Statements (FDSs) are enhanced and are now also forward looking
- Express consent is needed annually
- There are rigid transition arrangements
- Fixed term agreements cannot easily replace Ongoing fee arrangements
- Renewal notices (RN) are no longer required
(list the set)
Breach Reporting1 October 2021- The legislation is much broader and now includes ‘reportable situations’.
- Some reportable situations are “deemed” reportable – you will be reporting more frequently to ASIC.
- The regime will also apply to Australian Credit Licensees
- You have 30 days to decide if a situation is reportable, or you need to report it anyway
Updated reference checking and information sharing1 October 2021- There are new requirements on recruiting licensees and referee licensees, which dictate how reference checks are to be conducted.Yes
Updated appointments policy
Internal Dispute Resolution (Complaints) Procedures5 October 2021- Response times have changed
- Definition of a complaint is much broader
- You must have a public complaints policy
- Parts of ASIC’s regulatory guide 271 are enforceable.
Design & distribution obligations5 October 2021- This obligation is in addition to Best Interest Duty
- Become familiar with relevant issuer Target Market Determinations (TMDs) and how they fit into the advice process, and what you need to do
Hawking prohibitions consolidated and broadened5 October 2021- Outbound promotions may need to be pared back in light of the new restrictionsYes
Updated Promotional Material Policy

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