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Key FOFA Changes
Enhanced ASIC Powers
Best Interests Duty
Ban on Conflicted Remuneration
Annual Fee Disclosure
Opt-in Requirement
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Impact of Legislation
Enhanced ASIC Powers— Not expected to require any changes to COIN
Best Interests Duty— Additional wording was added to clarify how the best interest duty is
expected to facilitate the provision of scaled advice.
— COIN's Quick Plan module, which allows the generation of short-form advice documents, is expected to be a key tool in the functionality for providing scaled advice.
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Impact of Legislation
Ban on Conflicted Remuneration— Will require product providers to clearly distinguish between adviser
and product fees.
— Expected to result in a change to data feeds and their representation in COIN.
— Changes to be dictated by fund managers – COIN to continue working with them.
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Impact of Legislation
Annual Fee Disclosure— Provide information about the ongoing services the client was
entitled to and the services actually received during the previous 12 months.
— Amendment removed requirement to disclose fees and services for the following 12 months.
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Impact of Legislation
Opt-in Requirement— Exemption available if ASIC is satisfied that an approved code of
conduct is in place.
— Professional bodies that have code of conduct will need to apply and gain ASIC approval.
— If opt-in does apply, Renewal Notice needs to provided to client every 2 years.
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What is COIN Doing?
Service Packages— Allow the creation of a number of different service level packages and
also the recording of package details and the associated fees.
— Services will be set up via the “Preferences” section in COIN.
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What is COIN Doing?
Service Packages— Details of which service package selected by the client can be
recorded in Fact Find.
— Each entity can have separate service packages or a single package can apply to the whole entity group.
— A record of which services were provided can be recorded to assist with the Fee Disclosure obligations.