Hi Team! Tranche 1 of the QAR has effectively removed the requirement of a FSG and replaced it with the option of Website disclosure. Here is the background on all this as well as Templestone policy.
Purpose: To provide cost effective and flexible alternative solution to provide information currently required in the FSG.
Commencement Date: 10 July 2024
(The delay in getting this to you was largely due to the lack of guidance available to any Dealer Group)
Current State: The printed PDF version as we know it which had to be delivered/handed to the client before any Personal Advice.
New Alternative Options
The same information can be provided on the website under a title ‘website disclosure information’. You are not required to do both, however you may still choose to use the printed version with certain clients, as well as Website disclosure – your call.
Requirement
- Must contain same statements/information as currently required in an FSG
- Must be complete, accurate and up to date
- Must take reasonable steps to ensure its complete, accurate and up to date
- Must specify the day it was prepared or last updated
- Changes to the website disclosure information must be approved by the licensee
Where can it be located/appear on the website?
- Anywhere on the website
- Must be freely available and readily accessible to the public
- Not password protected
When should you make ‘website disclosure information’ available?
- When you give advice to a retail client
- Exceptions
- If the client is not a retail client i.e. a wholesale client
- Client has already been given an FSG and the information has not changed
- Advice relates to a basic deposit product e.g. bank account
Amendments/updates
Any changes to the website content must be submitted to compliance for approval
Penalties
Penalties apply for
- distribution/update/alterations of information without licensee approval
- defective information
- not up-to-date info
- if it does not contain date of preparation or last date of update
- Making the information available recklessly so that a person will or may rely on that information
So, it’s extremely important you get this right, particularly as Templestone makes changes to the information required in the FSG. As always – whichever method you choose – work with us.
In summary, our approach is flexible and we will continue to provide you with a PDF version, however you should include the FSG on your website as well.
Our view is this is a great step in the right direction and we welcome the change. It does not actually lift the weight off our shoulders in terms of improving business efficiencies however applaud the efforts of those involved in making financial advice affordable and accessible
We will keep you posted on changes proposed that come into effect from 10 January 2025. So watch this space.
Finally, a few of our team have General Advice type people in their business. Please check with me on what you should be doing in the FSG space.
Chandar Varadhan
Professional Standards Manager