Disclaimer
These tips are provided on the basis that you confirm each tip with your licensee before proceeding with producing documents for your files.
By reading the below tips, you confirm that acknowledge the general nature of this information.
By reading the below tips, you confirm that acknowledge the general nature of this information.
General Financial Planning File Note Tips
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Content & Format of FilesThe client file must contain originals or copies of the following documents:
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Advisers must use a file note to record the substance of any conversation with a client at the time of the conversation or in any event on the same day. Good file notes are invaluable in the event of a client complaint and are essential to enable third parties such as ASIC and external complaints resolution schemes to understand the reasons for your recommendations and any subsequent transactions.
Details RequiredFile notes must include the following details:
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Please Note: File Notes are not required where client conversations are fully recorded and stored electronically as audio files or are converted to text. Advisers must however obtain the client’s prior consent to have their conversation recorded. Consent can be verbal however this must be noted on the client file by way of a file note.
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Electronic FilesAdvisers must have a documented Electronic Files Process detailing the following:
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Archiving Client FilesDocuments that must be retained in the current file for at least one year prior to archiving are:
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Loss of client filesAdvisers must notify their licensee in writing immediately a client file or file document is lost.
The adviser must then reconstruct as near as possible the lost file/document by undertaking the following procedures in relation to documents that were retained on the client file:
At the first available opportunity (or in any event prior to providing additional advice and services) the client must complete a new Client Profile/Fact Find. A file note explaining that the file is a reconstruction and the date of reconstruction must be inserted at the front of the file. If a file or document is stolen, the adviser must report this to their Licensee who will provide the adviser with further instructions. |
Further Information
Regulations RG 175 Financial Product advisers – Conduct and Disclosure RG 36 Licensing: Financial Product Advice and Dealing Financial Planning Association FPA Rules and Guidance Notes – particularly Guidance Note #4 |