Through the practical implementation of the new DBFO fee consent obligations, an additional issue has emerged that members should discuss with their licensee and product providers.
The client consent form is required to include an account number of the product the advice fee is to be deducted from. In practice, for new products the adviser is recommending, this number is not provided to advisers until after the client has successfully applied for the product. This puts advisers at risk of submitting an incomplete fee consent form, which may result in an automatic termination of the fee arrangement under the law.
The FAAA is in discussion with Treasury, ASIC and other stakeholders seeking a solution for this issue.