Compliance Checklist

Prior to completing this Checklist please refer to the Compliance Policy & Procedures to ensure the effective use of the document. It is critical that
the review process achieves a complete & truthful identification & communication of all breaches.
Completion of this form by the Compliance Officer involves confirmation that where possible & practical all Indicators of Compliance have been
verified & any compliance issues identified have been documented in the Comments field, the Compliance Breach Register has been updated & all
reporting requirements as stipulated in the Compliance Policy & Procedures have been completed. It also serves to confirm that all significant
breaches as indicated in the RG78 – Breach Reporting By AFS Licensees RG78 Breach Reporting By AFS Licensees have been reported.
Abbreviations – B Board, O Operational,
Period Ended      /      Name & Title       Signature       Date       /       /      
Compliance Question Applies Source Level Impact Indicators of Compliance Comments
To
If there has been a All General O Med If new Compliance Officer have they undergone Not answered
change in Compliance AFS training as follows:
     
Officer from Previous obligation  MSM Training Module,
Checklist have they  Read Compliance Policy & Procedures,
been trained  Completed formal handover from previous
appropriately etc.? Compliance Officer
 Has Org Chart been updated, all staff &
representatives advised of change.
Are all relevant All ASIC O Low  The formal process for retention, storage & Not answered
documents stored & Guidelines destruction of documents & computer      
retained as required? records as laid out in the Staff Policies &
Procedures is implemented & effective.
 SOA’s/Statements of Additional Advice, &
samples of Financial Services Guides &
Product Disclosure Statements kept for 7
years

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Compliance Checklist
Compliance Question Applies Source Level Impact Indicators of Compliance Comments
To
Have the APRA Form Licensee Reg 7.6 B O Med  Requirement to lodge Form 701 with APRA Not answered
701 Reports been s placing  Table 1 for all general insurance      
completed & lodged with general intermediaries.
APRA as required. insuranc  Table 2 is required to be lodged if dealing
e directly with overseas insurers. This must
business be done using the APRA D2A software.
 Reports due 20th Jan & 20th July each year.

Has the business lodged All ASIC O Med  Annual lodgement has been made. Not answered
its annual business AFSL’s Supervisor
     
activity metrics with required y Cost
ASIC by end of to lodge Recovery
September. metrics Levy Act
2017
Is a list of all Retail ASIC O Low  A document register of all PDS’s/FSG’s is Not answered
PDS’s/FSG’s used in the Client Guidelines maintained.      
business maintained? business  A formal process regarding the use &
replacement of PDS’s & FSG’s is being
followed.
If electronic delivery of All RG221 & O Low  Option for client to opt out of electronic Not answered
FSG / PDS / SOA is clients ASIC delivery.      
there opt out provision Corps  FSG / Client Documentation highlights
provided to client of Inst. electronic disclosure process.
electronic delivery 2015/649  Electronic delivery meets ASIC’s Best
process. Practice guidelines.

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Compliance Checklist
Compliance Question Applies Source Level Impact Indicators of Compliance Comments
To
Is the General Insurance U/W General O Mediu  All relevant staff have either all read the new Not answered
Code of Practice 2020 Agents & Insurer m Code or have received Training on the      
being effectively Brokers Code of Code.
complied with by the acting Practice  No breaches of code identified in review
business? under 2020 period as confirmed by Complaints Register
Binders & Compliance Breaches Register
 Any significant breaches of Code advised to
AFCA within 10 days or to Lloyds within 7
days.
 March 2018 Guidance Note on Hardship
Assistance process provided to all relevant
staff.
Are Duty of Disclosure All Insurance O Mediu  DOD included on the front or reverse of all Not answered
(DOD) & other notices Contracts m invoices or included as an attachment to all      
provided when required? Act, invoices.
AFCA,  Staff understand & have access to the
Insurance Insurance Contracts Act.
Brokers  All relevant notices sent out or included on
Code of stationary.
Practice  DOD Notice updated to refer Consumer
Insurance Contracts no later than 5/9/21.
Are Key Fact Sheets AFSL’s Insurance O Mediu  KFS created for all relevant policies that Not answered
(KFS) being provided to that act Contracts m provide Home Building & Contents cover      
clients where required? under Reg’s including Strata/Landlords & Farm covers.
Binders Amendme  All new staff are provided with training on the
& deal nts 2012 KFS requirements.
directly No.2.  Systems in place to send out KFS at time of
with policy commencement & whenever KFS
home & changes.
contents  No identified breaches of requirements.
clients

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Compliance Checklist
Compliance Question Applies Source Level Impact Indicators of Compliance Comments
To
Is the Insurance Brokers Brokers Insurance O Mediu  All existing Staff have had training on the Not answered
Code of Practice being who are Brokers m new Code      
effectively complied with NIBA Code of  All new staff are provided with training on the
by the business? members Practice Code as part of Induction.
& those  Staff know where to access the Code.
who  Fees disclosed on all written documents &
have email’s, faxes, letters & invoices where
formally required.
subscrib  Advice on Wholesale brokers included on all
ed invoices or attachments or standard letters.
 No breaches of code identified in review
period as confirmed by Complaints Register
& Compliance Breaches Register
Is any Approved Product Licensee License O Low  Listing exists with indicators that the list is Not answered
Listing maintained & up s who Applicatio being reviewed on a regular      
to date? advised n (monthly/quarterly) basis.
ASIC  If no listing a file note at a management
that they meeting that a list is no longer to be
had an maintained & explanation of how staff are to
Approve select products.
d
Product
Listing
Has an external ASIC Nil O Low  Documentation showing the review being Not answered
compliance firm been expectati undertaken on past six to twelve months.      
engaged & conducted a ons and  A Board/Senior Management note (Board
review? Best Minutes/Business Plan) advising that a
Practice Compliance review is not to be undertaken.

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Compliance Checklist
Compliance Question Applies Source Level Impact Indicators of Compliance Comments
To
Have all new staff had Refer to License O Low  Review of new staff indicates compliance Not answered
all relevant checks answer Applicatio with staff checking processes.      
completed? on n  Note in file signed by RM, waiving check
Licence processes with explanation.
Applicati  Note in management documents explaining
on a formal change in checking process.
 Use of comprehensive & current Staff
Induction form.
Have clients been All License B High  In event of banning, advice to clients of staff Not answered
advised of any banning Condition in past 3 years.      
of staff/representative?
Does business record All Licence O Med  A date sent is individually recorded for each Not answered
the date the FSG is Condition client.      
supplied to each client,  FSG Versions & dates are recorded either
including Version No. individually or across the business.
where relevant?  Other business wide systems in place to
have FSG sent & date able to be confirmed.
If the AFS Licence Licenses License B High  No change in sole Responsible Manager has Not answered
includes a Key Person with Key Condition occurred or expected.      
condition in relation to Person
an RM & the RM has condition
been or is expected to (Sole
no longer be an RM RM)
have the conditions
been met?
Is there an effective All Privacy O Low  Staff understand & know where to access Not answered
Privacy Policy & Act the Policy; Staff can explain key objectives      
approach operational? of the Policy.
 There are no identified systemic breaches of
Policy.
 There are no complaints recorded in the
Complaints Register regarding Privacy.

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Compliance Checklist
Compliance Question Applies Source Level Impact Indicators of Compliance Comments
To
Is there an effective All Privacy O Low  The business has created & maintains a list Not answered
identification & analysis Act of all overseas suppliers (Ex UK/ EU & USA)      
where information is that are sent/ share/ store personal
sent / stored / shared information.
with overseas  The business plan includes commentary that
businesses. Table is reviewed annually.
Is there an effective All Privacy O Low  The business has created & maintains NDB Not answered
National Data Breach Act related policies & procedures.      
(NDB) management &  All staff have been provided an overview of
compliance program in NDB obligations.
place?  NDB obligations included in new staff &
representative induction processes.
 Privacy officer is aware of NDB obligations.
 The business plan includes commentary that
Privacy Policy is reviewed annually.
Does the business only All Procedure O Low  Review use of unauthorised/non preferred Not answered
use insurers approved s Manual suppliers & documentation supplied to /      
by the Responsible received from client at time of usage.
Manager?
Is the Organisational All RG104 O Low  Confirm current Organisation Chart Not answered
Chart / Table current? accessible to all staff.      
Are Directors of All RG104.49 B Med  Documentation showing directors are Not answered
business kept informed provided with copies of Compliance Breach      
on Compliance issues? Register at each Board Meeting & all “B”
level breaches are reported to Board.

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Compliance Checklist
Compliance Question Applies Source Level Impact Indicators of Compliance Comments
To
Is the business All RG166 O High  Effective implementation of our Financial Not answered
complying with its Policy & Procedures Monthly financial      
Financial obligations? reports received in a timely fashion.
 Actual business finances in line with or
exceeding our plan.
 No adverse financial issues likely to impact
business.
 Current year financial budgets likely to be
achieved.
Is the business All RG104 O Mediu  Staff understand & know where to access Not answered
complying with its IT m Information Technology Policy &      
Policy & Procedures? Procedures.
 A current IT Co-Ordinator & back up staff
member in place.
 Back up procedures implemented.
 Restore test completed quarterly or as
scheduled.
Is the business All RG104 O Low  No changes in outsourcing arrangements Not answered
complying with its made without Board approval & update to      
Outsourcing Policy & the Policy.
Procedures?
Are all of the Internal All RG104 O Low  Staff access & understand Position Not answered
Controls of the business Descriptions/Task Allocation Table (where      
operative? implemented) & Organisation Chart.
 Position Descriptions/Task Allocation Table
(where implemented) kept up to date.
Is the business All RG181 & O Low  Conflict management allocated to staff Not answered
complying with its S912A (1) member in Organisation Chart, Staff briefed      
Conflicts of Interest (aa) on Conflict Management requirements.
Policy & Procedure? Identification table created.
 Management Plans implemented & followed,
annual review included in Business Plan.
 No complaints regarding conflict situations.
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Compliance Checklist
Compliance Question Applies Source Level Impact Indicators of Compliance Comments
To
Are active All Reg O Low  Check Spotter/Referrer marketing material Not answered
Spotter/Referrers 7.6.01 E includes relevant remuneration disclosure.      
disclosing their (iii)  Confirm with S & R that remuneration is also
remuneration at time of provided in all verbal referrals.
referral?
If there are/have been All Reg. B High  No change in Directors/Secretary expected. Not answered
change in Directors or 7.6.03  ASIC advised in 10 days if changes are      
Secretary, details have being made. (Existing requirement).
ASIC been advised?  Directors not on ASIC Banned Register.
Is the business expected All Reg. B High  No significant adverse change in overall Not answered
to continue 7.6.04(1) business circumstances, business continues      
successfully? (a) trading.
 ASIC advised in 3 business days if change.
Has there been any All Reg. B High  Change of name advised within 14 days, all Not answered
change in Licensees 7.6.04(1) other changes within 10 days.      
particulars – names, (b)
addresses, RM’s?
If there have been any All Reg. B High  No change in ownership/board control Not answered
change in control of the 7.6.04(1) expected. (Control means 51 % of voting      
business has this been (i) shares or majority control of Board).
advised by ASIC?  ASIC advised in 10 days via FS20 Form.
Are all remuneration Retail Reg. O Low  SOA templates all include provision for all Not answered
amounts received by the Clients 7.7.10A remuneration received or paid by us to be      
Licensee & paid to Only expressed in dollar terms.
AR’s/Spotters expressed  Sample of SOA’s checked to ensure client
in dollar terms in the SOA’s show dollar amounts. (Effective from
SOA’s 01/3/05)
Are payments of Client All Reg. O Low  All payments of Client Monies to other Not answered
Monies to other 7.8.02 AFSL’s (U/W Agents & Wholesale Brokers)      
Licensees appropriately (1A) includes advice that payment is Client
identified? Monies & must be banked into a Trust A/c..

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Compliance Checklist
Compliance Question Applies Source Level Impact Indicators of Compliance Comments
To
Have all premium All Reg. O Low  Relevant staff aware of requirement. Not answered
payments been made to 7.8.08  Exception reports in place, reviewed &      
insurers within 90 days actioned.
of inception?  No consistent non-payment identified.
 System must be set up so that 100 % of
payments are made within 90 days.
Have all payments from Broker Reg. O Low  Relevant staff aware of requirement. Not answered
insurers to clients been 7.8.08  Exception reports in place, reviewed &      
made within 7 days of actioned. (Winbeat users to run Reports –
receipt? Trust Account Analysis – Code 104
(Amounts due to insureds) on a weekly
basis)
 No consistent non-payment identified.
 Date of receipt is date taken up from insurer
or date received.
Have all cases of Broker Reg. O Low  Relevant staff aware of requirement to Not answered
premium unpaid over 90 7.8.08 advise insurers.      
days advised to insurer (03)  Exception reports in place, reviewed &
within 7 days? actioned.
 No consistent non-advice identified.
Does business only Broker Insurance O Med  Relevant staff aware of requirement to get Not answered
cancel policies due to Contracts instructions from insurer.      
non payment on Act  Sampling of cancelled policies indicates
instructions from process being followed.
insurer?
Do business records All Reg. O Low  Staff aware of requirements. Not answered
identify unauthorised business 7.8.11  Appropriate records maintained.      
foreign Insurer (UFI) es  Identify & check sample of policies involved.
transactions as required dealing  Can only be effectively controlled if there is a
& document appropriate with foreign insurer flag at the Policy Level.
exemption? UFI’s  UFI’s only used where an exemption applies

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Compliance Checklist
Compliance Question Applies Source Level Impact Indicators of Compliance Comments
To
Unable to use the words AFSL’s S923C O Low  The words are not used in the business. Not answered
Financial Planner or not  Check standard letters      
Financial Adviser authorise  Check Website & Marketing Material
d for
Personal
Advice or
only
authorise
d in Gen.
Insuranc
e / Cons.
Credit /
Basic
Deposits
If Personal Advice is Personal Reg O Mediu  All relevant advisers have been added to Not answered
provided to Retail Advice & 7.6.06B m ASIC Register.      
Clients for Investment Retail  All details are current & up to date
style products the Clients &  All ex Advisers have been removed.
business must register select
all relevant advisors on products.
the ASIC Connect site
as Advisers.
If Personal Advice is Retail S961B O Mediu  Business has commenced implementing Not answered
provided to Retail Clients m processes to comply.      
Clients there is an Only  Business has allocated task of compliance to
obligation for advisers to an individual or team.
act in the best interests  Staff have been trained in “Best Interest”
of the client. obligation.
 Policies & Procedures have been updated
accordingly.

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Compliance Checklist
Compliance Question Applies Source Level Impact Indicators of Compliance Comments
To
If Personal Advice is Retail S962 O Mediu  Business has made a formal assessment of Not answered
provided to Retail Clients m whether the FDS obligations apply.      
Clients & an annual fee Only  FDS have been sent to clients as verified by
is charged for this reviewing sample of client files.
service are clients  Policies & Procedures in place detailing
provided with a Fee processes for sending FDS to clients.
Disclosure Statement  Staff have been trained in FDS obligations.
(FDS).
If Advice is provided to Retail S963 O Mediu  Business has made a formal assessment of Not answered
Retail Clients is there an Clients m whether it receives Conflicted Remuneration.      
effective ban on Only  All identified Conflicted Remuneration
receiving & / or paying arrangements have been terminated or
Conflicted amended as required.
Remuneration. Does  Policies & Procedures in place detailing
not apply to General processes for avoiding Conflicted
Insurance or Life Remuneration.
Insurance (outside  Staff have been trained in what is Conflicted
Super). Remuneration.
Are Product Disclosure Retail S1010 – O Mediu  Relevant staff aware of requirements. Not answered
Statements (PDS) Clients S1016 m  PDS issued with all New Business      
provided to clients as Only quotations/transactions.
required?  Process in place to replace old PDS
documents.
 Staff advised of PDS changes/updates.
 Standard letters & emails refer to PDS
where relevant.

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Compliance Checklist
Compliance Question Applies Source Level Impact Indicators of Compliance Comments
To
If the business receives U/W S1017E O Low  Relevant staff aware of requirements. Not answered
Client Money prior to Agents  No Client Money received for policies or      
arranging insurance is it Only renewals that have not been issued.
banked to the Trust A/C  Unmatched cash transactions would be
& refunded within 30 trigger.
days if the insurance is
not placed?
Does the business Retail S1017F O Low  Broking Policy & Procedures implemented & Not answered
confirm all new covers, Clients effective.      
changes, cancellations Only  Relevant staff aware of requirements.
as soon as practical?  Transactions confirmed as required.
 Invoices raised on day transaction occurs.
If there is any product All S1018 O Low  No changes in advertising expected. Not answered
advertising does it  Advertising checked for compliance with      
disclose AFS Licence S1018.
No & refer to FSG where  Reference FSG made in all advertising
relevant? where relevant.
Are clients made aware Retail S1019 O Low  Relevant staff aware of requirements. Not answered
of Cooling Off periods in Clients  Oral Disclosure script includes cooling off      
time critical situations? Only information.
 Advice provided when required.
Is the business All S1041E, B High  All information provided by the business is Not answered
complying with the S1041F, checked for accuracy, is not misleading or      
requirements to not S1041G, deceptive.
involve itself in false & RG234  The business has a philosophy of doing the
misleading conduct, right thing by the client & being a good
inducing clients to deal corporate citizen.
or deceptive conduct?  All promotional material has been checked
that it meets the guidance set out in RG234

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Compliance Checklist
Compliance Question Applies Source Level Impact Indicators of Compliance Comments
To
Is the business All S45 – S50 O Mediu  Staff understand & have access to the Not answered
complying with the m Competition & Consumer Act 2010.      
requirements of the  The business does not engage in any anti
Competition & competitive activities, price manipulation etc.
Consumer Act 2010?
Is the business General S911B M Mediu  Is there a register of all Distributors Not answered
complying with its Insuranc 1(a) & m appointed by the business? (On      
requirements in regard e Only ASIC Organisation Chart)
to the appointment of & Legislative  Have all Distributors been appointed in
disclosure required of Instrument writing.
Distributors? 15-682  Do Distributors make the necessary
disclosures to Retail Clients?
Do all AR’s & All S911C O Med  All Business Cards, Promotional Material, Not answered      
Distributors clearly Letterhead, Invoices, Quotes (that relate to
disclose their Financial Services) show them as
representative status on representative of ours & include our AFS
all relevant documents? Licence No.
Is the business providing All S912A O High  Compliance Register & Complaints Register Not answered
its services efficiently, 1(a) indicates no systemic, significant or      
honestly & fairly? continuing issues being identified.
Is the business All S912A B High  License conditions specific to the business Not answered
complying with all AFS 1(b) included in Compliance Checklist.      
Licence Conditions  No changes in AFS Licence conditions since
imposed on it? last Compliance Review.
Is the business All S912A B High  Compliance Register & Complaints Register Not answered
complying with the 1(c) indicate no systemic, significant or ongoing      
Financial Services Law? breaches.

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Compliance Checklist
Compliance Question Applies Source Level Impact Indicators of Compliance Comments
To
Is the business taking All S912A O High  Where felt necessary check all staff annually Not answered
reasonable steps to 1(ca) on their knowledge & performance by the      
ensure that all completion of a questionnaire on the various
representatives comply procedures, policies, responsibilities &
with the Financial legislation impacting the business.
Services law?  Ensure a review of their work & client advice
has occurred via use of a Client File
Checklist.
 Staff understand & have access to the
External Representative Policy &
Procedures.
 Training & monitoring being performed in
line with policy.
 No complaints recorded in the Complaints
Register regarding Authorised
Representatives
Does the business All S912A B High  Compliance Register & Complaints Register Not answered
maintain the necessary 1(d) indicate no systemic, significant or ongoing      
financial, technological & breaches.
human resources to  Financial Policy & Procedures, Information
provide & supervise our Technology Policy & Procedures, Staff
services? Policy & Procedures all in place.
Does the business All S912A B High  Compliance Register & Complaints Register Not answered
maintain the 1(e) indicate no systemic, significant or ongoing      
competence to provide breaches.
Financial Services?  Training Policy & Procedures being adhered
to.

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Compliance Checklist
Compliance Question Applies Source Level Impact Indicators of Compliance Comments
To
Does the business All S912A 1(f) O Mediu  Compliance training updates or refreshers & Not answered
ensure that its staff are m relevant Information Technology upgrades      
appropriately trained & should be implemented if:
competent to provide  New law or code is introduced that impacts
financial services? on the business, or requires new procedures
 New procedures have been introduced to
address compliance issues
 Compliance breach or complaint has
occurred particularly on a systemic &
recurring basis
 Upon evaluation of staff needs.
If there are any AR’s All S912A 1(f) O Mediu  Regular reviews of work being conducted. Not answered
acting for the business RG146 m  Training Policy & Procedures being followed.      
are they effectively  Appraisal & Development processes being
managed & monitored? complied with.
Is the business meeting All S912A 1(f) O High  Staff understand & know where to access Not answered
its obligations to RG146 the Training Policy & Procedures.      
maintain the training for  Training Register, Position
its advisers? Descriptions/Task Allocation Tables (where
implemented) kept up to date.
 Appraisal & Development forms completed,
Training Completion Forms completed.
 Training actively followed up.
 Training Needs Survey completed &
assessed for all new staff where required.

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Compliance Checklist
Compliance Question Applies Source Level Impact Indicators of Compliance Comments
To
Is the business Licensee S912A O Mediu  Staff understand & know where to access Not answered
operating an effective s dealing 1(g) m the Complaints Policy & Procedures.      
Complaints system? with  All disputes handled in accordance with
RG165 –
Retail policy.
Internal &
Clients  Membership of External Dispute facility
External
only maintained or ASIC advised of change within
Dispute
Resolution 10 days.
& RG271 -  AFCA common renewal date is 30th June
Internal each year.
Dispute  Complaint Register reviewed & any systemic
Resolution issues investigated.
 Complaint numbers consistent with at least
one per 250 clients per annum.
 All complaints handled as per Policy & the
external dispute facility timeframes
 Website provides prominent links to AFCA &
Codes of Practice and Complaints Brochure
(effective from 5th October 2021).
Is the business All S912A O Mediu  Staff understand & know where to access Not answered
operating an effective 1(h) m the Risk Management Policy & Procedures.      
Risk Management  Any significant changes or new risks have
RG104
system? been included in plan.
 All triggers to a review have been complied
with.
Does the business Licenses RG126 O High  PI Policy current for Licenses that deal with Not answered
maintain adequate dealing Retail Clients.
S912B,      
compensation with  Minimum Sums Insured & excesses apply;
R10.2.44
arrangements? Retail refer to Complaints Policy & Procedures.
Client  Specific statement included in FSG
only  Annual PI Assessment against RG126
requirements completed.

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Compliance Checklist
Compliance Question Applies Source Level Impact Indicators of Compliance Comments
To
If the business is unable All S912D 1 B High  No significant or serious breaches identified. Not answered
to meet its License  ASIC advised within 10 business days if      
obligations have ASIC significant or serious breach occurs.
been advised?
Is the AFS Licence All S912F O Low  All relevant documentation Not answered
Number displayed on all (SOA/SOAA/FSG/Regular Statements) has      
relevant documentation? AFS Licence Number shown.
 Any new relevant documentation has AFS
Licence No.
 It is recommended that the AFS Licence No.
is also displayed on any relevant Websites,
brochures, marketing material & email
signatures.
If the business has All S916 B High  Any new Authorised Representatives Not answered
appointed any new approved by Board.      
Authorised  External Representative Policy &
Representatives have Procedures complied with.
they been  Any AR’s providing Financial Services
appointed/terminated in Advice have Training Plans.
accordance with the  All AR’s on Organisation Chart. All AR’s (or
law? their representatives) providing Personal
Advice have there own individual FSG’s &
SOA’s.
If there have been any All S916F B High  No new Authorised Representatives Not answered
new/changes Authorised Reg. appointed/terminated.      
Representatives 7.6.04(1)  Board approval & ASIC advised in 15 days if
appointed/terminated (c) changes are being made.
have they been
appropriately
authorised/terminated &
advised to ASIC?

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Compliance Checklist
Compliance Question Applies Source Level Impact Indicators of Compliance Comments
To
Does the business All S923A (5) O Low  All newly created printed material, Not answered
ensure that it does not promotional & advertising material & web      
use the words site changes are signed off by a Responsible
“independent, impartial Manager.
or unbiased” when  Words such as independent, impartial or
describing advice given? unbiased are not used within the business or
to describe ownership / status etc.
 Any suggestion that we do not act for or on
behalf of insurers should be removed.
Does the business use All S923B O Mediu  If Binders are used, they should be disclosed Not answered
insurer binders? m in FSG’s if they relate to Retail Clients & on      
all invoices where relevant.
 There is an entry in the Conflict of Interest
Table regarding Binder Conflict.
Are Financial Services Retail S941 – O Mediu  Relevant staff aware of requirement. Not answered
Guide’s prepared & Client S943 m  Financial Services Guide provided with all      
provided as required? Only services to Retail Clients.
 FSG kept up to date & accurate.
 FSG reviewed as part of the annual
Business Review process.
 FSG includes “Lack of Independence”
statement (1/7/21 onwards)
 FSG referred to in relevant standard letters
& email templates.
Has there been any Retail S941 – O Mediu  No change in FSG in past 12 months. Not answered     
change in the FSG in the Client S943 m  If changed FSG has been vetted by
past 12 months & has it Only management & External Compliance
been vetted. Provider

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Compliance Checklist
Compliance Question Applies Source Level Impact Indicators of Compliance Comments
To
Are SOA’s/Statements Retail S944 – O Mediu  Business has guidelines on Personal Vs Not answered
of Additional Advice Client S947 m General Advice.      
prepared & provided & Only  Relevant staff aware of requirements.
stored for 7 years?  SOA’s/Statements of Additional Advice are
always given when providing Personal
Advice to Retail Clients.
 SOA’s/Statements of Additional Advice are
accurate & comply.
Are General Advice Retail S949A O Mediu  Business has a written procedure on when Not answered
Warnings (GAW) Client m General Advice is given (Business Plan).      
provided to Retail Only  Business has a standard GAW & a process
Clients as required? to send the GAW out.
 GAW’s are sent with all Retail Client
Invoices where an SOA is not provided.
 A review of files indicates that the GAW is
sent where required.
 GAW included in Oral Disclosure Script
Are Client Monies All S981B (1) O Low  Client Monies banked daily into bank Not answered
banked on the day of account or next business day.      
receipt or day after?  Bank statement indicates daily banking.
Are all non Client Insuranc S981B O Low  All Licensee monies must be transferred out Not answered
Monies & associated e Reg of Trust A/C within one month of banking,      
GST transferred out of Brokers 7.8.01 except where unable to identify such funds.
Trust Account within one (11,12,13)  Evidence that Licensee monies are
month or as soon as transferred on a monthly basis as shown in
identified (if after one Bank Reconciliation / Broking system
month)? reports.
Does the business All S988 B High  Full financial records of all transactions with Not answered
maintain adequate clients being documented.      
financial records?  No other identified problems flagged by bank
reconciliation processes, supplier
correspondence etc.

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Compliance Checklist
Compliance Question Applies Source Level Impact Indicators of Compliance Comments
To
Did the business lodge All S989 B High  Audited annual return lodged with ASIC Not answered
its Profit & Loss & within 4 months of the end of the Financial
Reg.      
Balance Sheets (ASIC Year.
7.8.12-16
Form FS70 & FS71) by
required date last year &
reminders in place for
the coming 30/10 ?
Has the business All S990 B High  No change in auditor. Not answered
retained the same  Replacement required within 14 days if      
auditor from last year? auditor resigns.
 Change in auditor to be advised to ASIC
within 14 days of vacancy.
Do staff use the Oral Retail Various O Low  Business has developed script, all staff have Not answered
Disclosure Script where Client Sections easy access to script, staff use script when      
required? Only required.
Has the business Retail RG126 O Med  A documented review of the PI coverage has Not answered
satisfactorily completed Client been conducted against the requirements for      
& documented a review Only such cover as laid out in RG126.
of it’s Professional  The review confirmed the coverage met the
Indemnity coverage prior requirements & has been signed off by a
to accepting renewal? Responsible Manager.
Does the business All WorkCove O Low  Staff understand & know where to access Not answered
comply with its r Reg’s the Workplace Health & Safety Policy &      
Workplace Health & Procedures.
Safety requirements?  Quarterly inspections of potential hazards &
risks, any claims or incidents being
appropriately handled, posters in place, first
aid kits maintained, first aid officers in place,
W H & S Officers in place.

631226967.doc 5/12/2022 Page 20 of 23

Compliance Checklist
Compliance Question Applies Source Level Impact Indicators of Compliance Comments
To
Does the business All Standards O Low  Note on invoices regarding not to send Not answered
comply with the Credit Card details via email / fax.      
Payment Card Industry  Credit Card details
Data Storage Standard destroyed/de-identified/stored.
 Credit Card details not faxed/emailed to 3rd
parties
Does the business only All The O Low  Documented approach to Credit Card Not answered
charge clients the Competitio charging.      
Acceptance Cost & other n &  Minimum annual review of the Acceptance
Direct Costs for using Consumer Cost s & other Direct Costs of providing
Credit Cards? Amendme Credit Card Facilities.
nt  Fees charged for each type of card that
(Payment matches the Acceptance/Direct Costs or
Surcharge matches the lowest cost structure if all
s) Act clients are charged the same Fees.
2016
Does the business have All U.K. B Low  Implementation of MSM Mission Control Not answered
an effective set of Anti business Bribery policies & procedures.      
Bribery Policies & that deal Act 2010  Development & maintenance of own Policies
Procedures? with UK & Procedures.
business
es
Does the business have All Banking B Med  Implementation of MSM Mission Control Not answered      
an effective process to business Finance & policies & procedures.
ensure all employees es that Insurance  Management have access to the BFI & are
are paid at or above the employ Award made aware of changes to BFI.
minimum levels set out staff. 2020  Computerised Payroll system.
in the current Banking  All staff have Letters of Engagement
Finance & Insurance including their BFI level where applicable.
Award 2020 (BFI).?  Check one staff members pay against the
BFI minimum.

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Compliance Checklist
Compliance Question Applies Source Level Impact Indicators of Compliance Comments
To
Has the business General Not O Low  All staff have received training as per Staff Not answered      
conducted training on communi Applicable Meeting minutes or entries in Training
Financial Hardship? ty Registers.
expectati
on.
Has the business Large Modern O Low  Addressed in Risk Management system, Not answered      
implemented and client Slavery Business Plan, Outsourcing and Staff Policy
maintained an effective requirem Act 2018 and Procedures.
Modern Slavery policy? ents.  No exposures identified requiring action.
If the business handles AFSL’s Corps Act O High  No claims handling done on behalf of Not answered      
claims on behalf of handling insurers, or
insurer(s) (post ciaims  AFSL variation lodged/accepted.
30/6/2021) has
application been made
to vary AFSL?
Is the business All Fair Work O Med  All staff provided with Fair Work Information Not answered      
complying with the Fair employer Act 2009 Statement when starting.
Work Act obligations. s  All Casual Staff provided with Casual
Employment Information Statement when
starting.
Is the business AFSL’s Corps Act O Med  Policies and procedures updated to address Not answered      
complying with Design dealing DDO.
and Distribution with  All staff provided with training on DDO or
Obligations effective Retail have read the Briefing Note on DDO as
from 5/10/21. Clients confirmed by Training Registers.
 TMD’s accessible for all relevant products.
 Where we act as issuer we have prepared
TMD’s as required and have Statement on
Website

631226967.doc 5/12/2022 Page 22 of 23

Compliance Checklist
Compliance Question Applies Source Level Impact Indicators of Compliance Comments
To
Is the business Retail S992 & O Med  Policies and procedures updated to address Not answered      
complying with the Anti- Clients Do Not Anti-Hawking.
Hawking obligations Call  All staff provided with training on Anti-
effective from Register Hawking or have read the Briefing Note on
5/10/21and the Do Not Act 2006 Anti-Hawking as confirmed by Training
Call & Industry Registers.
Standards  No outbound unsolicited telemarketing to
Retail Clients.
 No complaints reported in Complaints
Register regarding hawking.
 Business complies with Do Not Call Register
Act & the Industry Standards.
Is the business AFSL’s Corps Act O Med  Policies and procedures updated to address Not answered      
complying with the dealing DSM.
Deferred Sales Model with  All staff provided with training on DSM or
for Add on Insurance Retail have read the Briefing Note on DSM as
(DSM) restrictions Clients confirmed by Training Registers.
obligations effective from on  All insurance sales connected to the sale of
5/10/21 General other products or services have been fully
Insuranc reviewed to ensure they comply with the
e DSM.
Has the business AFSL’s Corps Act O Med  Invoices and all other documentation Not answered      
updated all Duty of dealing containing the Duty of Disclosure have been
Disclosure notices to in reviewed and the changes made as
reflect the change to general required.
Consumer Insurance insuranc  All staff have been made aware of the
Contracts where the e. change in documentation.
duty is now limited “to
take reasonable care not
to make a
misrepresentation’.

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