Perspectives on the Future of Financial Advice (FoFA) Deloitte Deloitte Actuaries & Consultants Limited

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Constance Carpenter
7 years ago
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1 Perspectives on the Future of Financial Advice (FoFA) Deloitte Deloitte Actuaries & Consultants Limited

2 Where are we at The Future of Financial Advice (FoFA) journey is a moving feast: Key purpose to remove conflicted remuneration and protect clients seeking financial planning services or advice by ensuring that financial advisers are putting their clients needs ahead of their own The proposals have gone through the House of Representatives and are now with the Senate In the current legislative position much uncertainty remains The industry now looks to ASIC to draft guidelines in order to determine how to comply

3 Revised time line

4 Summary of key reforms Opt in and Annual Fee Letter Best Interest Fiduciary Duty Scalable Advice Removal of conflicted remuneration Volume related payments Planner Capability Renewal notice entered into with client every two years to confirm whether the client wishes to continue with services (opt in) Annual fee disclosure letter to confirm what services were received and were entitled to be received; and what services had cost Aimed at increasing transparency and removing hidden costs to client via a formal arrangement Financial advice given to Australians must be in the best interests of the client and ahead of the financial adviser s interests Introduction of a best interests statutory duty subject to a 'reasonable steps' qualification ASIC powers extended Advice does not have to be comprehensive and could be tailored thereby reducing the cost of delivery and the cost to the client Measured against what is reasonable in the circumstances and commensurate and scalable to the client s needs Clients will be given the opportunity to choose and agree on fees up front Banning of conflicted remuneration structures (e.g. up front and trailing commisisons and soft dollar benefits in excess of $300) Targeted at removing payments that have similar conflicts to product provider set remuneration such as commissions and scale /volume benefits Removes incentive to recommend usage of a particular platform Includes MIS, superannuation and margin loan structures Providing training and capability development to ensure planners understand their clients, products and services and can be successful in the new environment

5 Many perspectives Association of Financial Advisers: Remove - - retrospective fee disclosure requirements - Opt-in proposals Senate Economics Committee: Recommend - - No significant changes to the legislation - Annual fee disclosure statement; opt-in provisions and Best Interest duty are necessary Financial Planning Committee: Remove - - retrospective fee disclosure requirements - Opt-in proposals Amend - - Best interest duty - Definition of group life in Super - retrospective fee disclosure requirements Industry Super Network: Don t delay - - best interests test - ending of commissions Parliamentary Joint Committee: Recommend - - Opt-in proposals - Annual fee disclosure Everyone has a different view and debate continues on the detail of FoFA Financial Planning businesses welcome the grace period to 1 July 2013 but still grapple with a number of challenges including: Determining strategic position with the amount of uncertainty still in the legislation as it stands The balance with other regulatory change such as Stronger Super The enormity of tactical changes required to IT infrastructure, Compliance, Business process and training ASIC continues to have an active focus on quality of advice

6 The impact of FoFA varies, depending on your position in the value chain Asset Managers Product Manufacturers/ Platforms Dealer Groups Advisors Payment of volume related shelf space or other fees under question Ban on volume based fees from platforms to dealer groups Ban on commissions. Changes to advisor remuneration models. Introduction of scaled advice Increased planner professionalism Customers Two year opt in/professional code is required. Statutory best interests test.

7 What can be done now Understand your current quality of advice Understand what pricing and profitability means under the new regime Understand the optimum design of your operating model Have you considered Understand the implications on culture and change management Where do your customers fit in your approach? How are you differentiated from your peers? How your approach may impact the attraction and retention of: Salaried/unsalaried financial advisers Their clients, and Product subscriptions? Support your efforts by strong project management to include the right people and ensure an efficient and smooth transition to FoFA

8 FOFA product and pricing

9 Existing Fee Flows Client Adviser Dealer Group Product Platform Asset Manager Asset Manager Client Initial Fee Initial Commission Initial Commission Product and Asset fee Asset Fees Shelf Space Fee Share of Comm Commission

10 Post FOFA Fee Flows Client Adviser Dealer Group Product Platform Asset Manager Asset Manager Advice Fee Share Advice Fee Product and Asset Fee Asset Fee Or Advice Fee within Product Share of Advice Fee Advice Fee

11 FOFA Impact on Client Fees Explict agreement to advice fee Paid directly or deducted from product Scaled to extent of advice Opt in every two years Lower product and asset fee (commission removed) Aversion to advice fees will reduce fees Opting out will reduce fees Some may miss out on advice

12 FOFA Impact on Adviser and Dealer Group Income No commission Negotiated fee for advice (scaled) No participation in shelf space fees Increased cost of compliance Lower Income and cost pressure Develop lower cost advice models Improve lead generation

13 FOFA Impact on Product/Platform Providers Pay no commissions Receive no shelf space fees But may negotiate volume based asset fees with asset managers Reduce product fees (commission removed) Receive and pay advice fees Products and investment choices to support advisors best interest test Develop products to handle advice fees Assess impact on volumes and margins Repricing

14 FOFA Impact on Asset Managers Withdraw shelf space fees (cannot influence adviser through commissions) Pay volume based fee rebates to product/platform providers, and/or Reduce asset fees (since withdrawing shelf space fees) Reprice Compete on product range and performance

15 QUESTION?

16 General information only This presentation contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms, or their related entities (collectively the Deloitte Network ) is, by means of this presentation, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte Network shall be responsible for any loss whatsoever sustained by any person who relies on this presentation. About Deloitte Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited, a UK private company limited by guarantee, and its network of member firms, each of which is a legally separate and independent entity. Please see for a detailed description of the legal structure of Deloitte Touche Tohmatsu Limited and its member firms. Deloitte provides audit, tax, consulting, and financial advisory services to public and private clients spanning multiple industries. With a globally connected network of member firms in more than 150 countries, Deloitte brings world-class capabilities and deep local expertise to help clients succeed wherever they operate. Deloitte's approximately 170,000 professionals are committed to becoming the standard of excellence. About Deloitte Australia In Australia, the member firm is the Australian partnership of Deloitte Touche Tohmatsu. As one of Australia s leading professional services firms. Deloitte Touche Tohmatsu and its affiliates provide audit, tax, consulting, and financial advisory services through approximately 5,400 people across the country. Focused on the creation of value and growth, and known as an employer of choice for innovative human resources programs, we are dedicated to helping our clients and our people excel. For more information, please visit our web site at Liability limited by a scheme approved under Professional Standards Legislation. Member of Deloitte Touche Tohmatsu Limited 2012 Deloitte Actuaries & Consultants Limited.

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