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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
No
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
Yes
(list the set)
Yes
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
YesYes
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
No
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.
Yes
Yes
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
YesYes
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
Yes

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