Coalition Senators' Dissenting Report

1.1Coalition Senators note that this Bill is the first legislative response to the Quality of Advice review, which was commissioned by the former Coalition Government and delivered to the Albanese Government in December 2022.

1.2Coalition Senators note the significant delay in this bill’s arrival, which has caused deep uncertainty for the struggling financial advice sector, who have been slugged with higher fees, higher taxes, and more red tape under this Government. This Bill arrives over 15 months after the Government received the Quality of Advice Review final report from independent reviewer, MsMichelleLevy.

1.3Furthermore, as the FSC noted, the Bill in itself is not a significant step forward in terms of implementing the Levy Review:

This bill is a very, very small piece in that broader objective. I think it would be difficult to reach a conclusion that this bill is a significant step forward.[1]

1.4Despite this significant delay, Coalition Senators note that this bill contained several widely publicised drafting errors that would have gutted the financial advice industry’s revenue streams. In addition to this, the Bill contains fundamental flaws that will make it harder for Australians to pay for financial advice through their super.

1.5Unsurprisingly, the Albanese Government has decided to include this schedule alongside the location offset and producer offset for films in another omnibus Bill. The location and producer offsets reflect a continuation of Coalition policy in the 46th Parliament, that formed part of the JobMaker plan that underpinned the 2020-21 Budget and supported a revival of Australia’s film industry.

1.6The increase to the Location Offset which this Bill implements, will build on the success of the Coalition Government’s Location Incentive measure, which demonstrated that we can successfully build a long-term pipeline of large-scale global screen productions in Australia – in turn generating thousands of jobs for Australian screen professionals.

1.7Severe deficiencies with the provisions of Part 1 Schedule 1 put at risk the passage of important tax incentives for the Australian film industry.

1.8The Labor Government has decided to play politics with these measures by combining them into an omnibus Treasury Laws Amendment Bill that purports to implement the recommendations of the Quality of Advice Review.

The proposed Section 99FA fails to achieve the aim of Quality of Advice review

1.9Recommendation 7 of the Quality of Advice Review pertained to the deduction of adviser fees from superannuation.[2]The independent reviewer, Ms Michelle Levy, recommended that superannuation trustees be able to pay a fee from a member’s superannuation account to an adviser for personal advice provided to the member about the member’s interest in the fund on the direction of themember.

1.10Ms Levy clarified the objective of this recommendation:

The objective of this recommendation is to provide superannuation fund trustees with more certainty about paying advice fees agreed between a member and their financial adviser from the member’s superannuation account and ensure that adviser fees are not paid in breach of the SIS Act and are not taxable benefits for members.[3]

1.11Submitting to the inquiry, the Financial Advice Association of Australia (FAAA) laid out what they believed to be the intent of the recommendation, which the Bill purports to reflect:

The intent of the changes in the Bill, as recommended by Michelle Levy and agreed to by the Government, was to address this issue and provide certainty to allow consumers to choose to pay for financial advice from their superannuation account in accordance with the SPT [Sole Purpose Test], to make advice more affordable and accessible for consumers.[4]

1.12However, the Committee has heard from numerous industry witnesses that the proposed measures in Part 1 Schedule 1 of this Bill do not achieve the policy intent and objective of this recommendation.

1.13The Stockbrokers and Investment Advisers Association said in their submission that the proposed changes to Section 99FA of the Superannuation Industry (Supervision) Act 1993 are unworkable:

… the proposed changes to section 99FA of the SIS Act will establish a particularly excessive obligation on trustees to closely review advice and fee arrangements to confirm compliance with the sole purpose test. Under the proposed legislation, superannuation trustees that allow fee deductions will need to check every piece of advice individually and duplicate valid checks already undertaken by financial advisers and their licensees. The proposal is unworkable and worse for all than the current situation.[5]

1.14Furthermore, it was argued that this provision would undermine the intent of the recommendation to provide members the choice to use their super to cover financial advice costs:

What is of the most concern is that the Bill provides that a superannuation trustee is not required to agree to the member’s request to charge the relevant costs even when the requirements are satisfied. Superannuation is the member’s money and no trustee should have the right to override a member’s decision in the context of all legal requirements having been met.[6]

1.15Whilst the Government has claimed that this Bill is intended to reduce red tape, the Stockbrokers and Investment Advisers Association said ‘this provision increases it exponentially’.[7]

1.16At the public hearing, the Law Council of Australia said that ‘the provision does not achieve the stated policy intent’ of the change or the recommendation.[8]In their submission they noted that:

The new drafting does not include any substantive provisions which provide a clear legal basis for the charging of the fee.[9]

1.17At the public hearing, the Law Council confirmed that the drafting was effectively prohibitive on advice fees being paid out of super:

Senator BRAGG: I want to know whether I understand your evidence correctly. To the Law Council: is the bill, as drafted, effectively prohibitive on people who want to use super to pay financial advice fees?

Mr Hodge: Yes. The current section 99FA contains limits on the use of superannuation for advice fees. The new section 99FA also contains a prohibition on the use of superannuation for personal advice fees, unless the conditions are satisfied.[10]

1.18In their submission, the Law Council argued that the ‘proposed replacement paragraph 99FA(1)(d) could not be regarded as an instance of “reducing red tape” and, contrary to the EM, it would not “provide superannuation fund trustees with more legal certainty about paying advice fees agreed between a member and their financial adviser from the member’s superannuation account” (at [1.14]).’[11]Furthermore, the new proposed Section 99FA ‘would provide less legal certainty’ than the current provisions.[12]

1.19Chartered Accountants Australian and New Zealand (CAANZ) and CPA Australia submitted that the proposed Section 99FA is ‘an inappropriate solution to the payment of personal advice fees from superannuation funds because, in our view, it creates too many risks for the trustees of APRA regulated superannuation funds’.[13] Furthermore, it would lead to ‘inefficiencies and a lack of certainty’.[14]

1.20At the hearing, CAANZ argued that providing clarity through the Explanatory Memorandum or through ASIC assurances was not sufficient:

Unfortunately, the steps that trustees take to meet those obligations in the law are spelt out in the EM and ASIC's assurances. Those do not have the weight of law. They may change at any time, and so, at the end of the day, the law itself is not clear and is open to interpretation. That is our primary concern.[15]

1.21This was confirmed by the Law Council during their appearance, noting that having the procedures and policies detailed in the EM with respect to the payment of advice fees through super would not hold sufficient legal weight:

As a result, we would say that the courts would likely place limited weight on the explanatory memorandum in this situation. The courts have come across this type of issue before, and the following statement, which has been adopted by the High Court, states, 'Where the extrinsic material appears to cast doubt on the construction of words favoured by a plain meaning of those words, then the explanatory memorandum cannot override the clear purpose of the act as deduced from its own language.' In effect, the words in the explanatory memorandum cannot be substituted for the text in the law. That means that trustees would be faced with a choice of relying on robust processes and controls and accept the risk of breaching 99FA in a particular situation or take steps to comply with 99FA in relation to each advice fee.[16]

1.22The FAAA submitted that the proposed new Section 99FA is ‘impractical and inconsistent with the overall objective’ of the reform package, and would in practice ‘significantly increase red tape for both super fund trustees and for financial advisers’.[17]

1.23FAAA argues that this is because the new section would effectively require advisers to provide full Statements of Advice (SOAs) to superannuation funds to review individually in order for funds to fulfill the legal requirements, ‘which would be costly and inefficient for both trustees and advisers, with the cost ultimately being paid by consumers’.[18]

1.24At the public hearing, the FAAA explained risks of this approach, and why it would increase costs in providing advice:

Firstly, for advisers, answering an audit request from a super fund generally involves giving copies of documents, such as statements of advice, which include their clients' sensitive personal information. Providing this unredacted to trustees could be a breach of the Privacy Act. Completing this redaction task is time-consuming, as it is for super funds who must read these documents and form a view on whether that advice meets the sole purpose test. Thus, we're concerned that this new wording could significantly increase the costs of both providing financial advice and administering super funds. That is certainly not in the best interests of members.[19]

1.25Submitting to the inquiry, the Institute of Public Accountants agreed, noting that proposed Subsections 99FA(1)(a) and (b) would ‘drive up compliance costs of both the trustee and the adviser and serve as further red tape, slowing down the provision of financial advice’.[20]

1.26In a submission from the Joint-Licensees Group, which includes ‘senior executives of leading AFS licensees’, it was put to the Committee that the current drafting of the Bill ‘will likely reduce access to quality financial advice and increase its cost through the introduction of additional red tape that consumers will pay for’.[21]

1.27They further explained how the changes grant considerable discretion to superannuation trustees with respect to ‘whether or not accept a member’s request/direction to pay advice fees from their superannuation account’.[22]The consequences would be that funds have greater control over member choice:

This change effectively makes superannuation funds act as gatekeepers or monitors of the fees their members wish to pay for financial advice; and requires they make subjective determinations as to whether the fees align with the member's superannuation interest. This added layer of scrutiny would see super funds taking on a role as quasi AFSL regulators. That is, the fund would be duplicating the role and responsibilities of both AFSLs and ASIC.

…

With its current drafting, the Bill, by increasing superannuation funds' required oversight of members’ wishes with respect to the payment of financial advice fees, will reduce consumer agency. Members who seek financial advice will face additional hurdles in getting their adviser fees paid from their superannuation accounts, as these payments will now require rigorous vetting by the fund trustees. This could limit members' freedom and ease in choosing and using financial advisers. Some funds (quite understandably) may decide the burden of responsibility is all too much and choose to not allow members the freedom they seek.[23]

1.28Appearing before the Committee at the public hearing, the Managing Director of WT Financial Group said that the new proposed s99FA would be devastating to members financially, and estimates it could cost members $400 more per advice request:

With respect to 99FA, the bill as currently drafted is a ticking time bomb. It threatens the financial wellbeing of Australians. It aims to reshape provisions for advice fee deductions from super in a way that, in our view, will inflate costs with redundant compliance requirements and potentially devastate access to quality of advice while adding no value for consumers at all.

…

The proposed changes to 99FA add nothing but confusion, uncertainty and cost, when this is the exact opposite of what was being sought to be achieved through recommendation 7. We estimate that the additional cost burden, if trustees are forced to scrutinise each advice document, would be in the order of $400 per member request, and this will siphon away literally hundreds of millions of dollars of consumers' retirement savings annually. That doesn't just fail to make advice more affordable; it's a sabotage of consumers' financial security.[24]

1.29Furthermore, the Committee heard evidence that this one provision alone created the risk that the new arrangements could mean funds do not permit their members using their super to pay advice fees:

Senator BRAGG: Is there a risk here, though, that cherry-picking one provision out of the whole package creates a risk of misuse of the new arrangements by the super funds?

…

Mr Cullen: I certainly think that there is a risk of having the exact opposite outcome than the implementation of the recommendation seeks to have. As Mr Younger and Ms Abood have said, there's a real risk here that super funds will take this legislation, notwithstanding what the EM says, on its literal meaning. I draw everybody's attention to the drafting of that relevant section, 99FA, as is before the parliament and this committee at the moment. It does not say that superannuation funds can charge a fee. The first thing it says is that they must not. So it's an outright prohibition to start with.[25]

1.30The Financial Services Council (FSC) submitted that the Bill as drafted ‘will on the whole make advice less affordable and more inaccessible for consumers’, and that the legislative changes in Schedule 1, Part 1 ‘are defective’.[26] Furthermore, if enacted as drafted, the provision would ‘make the existing situation worse’.[27]

1.31The FSC, in their submission, said the proposed Section 99FA departs from both the existing law and the policy intent of the Levy Review recommendations:

The legislative stance of the amendments may result in a black letter interpretation of the provision by superannuation trustees. This interpretation will necessitate superannuation trustee to move beyond their existing risk-based practices of ensuring compliance with the sole purpose test and best financial interest duty when deducting adviser fees from member accounts. As a result, superannuation trustees will instead need to check every single piece of advice, which is inconsistent with current industry practice and the stated policy intent of the Government.

…

The impacts of these unintended consequences may be that some superannuation trustees will decide not to facilitate advice deductions from members accounts where the adviser is independent of the superannuation fund. The choice by some superannuation trustees to remove the facility to allow a member to fund financial advice through their superannuation account will have a chilling effect on the access to professional financial advice provided by independent, appropriately trained and qualified individuals, as members will not be able to fund advice on their superannuation from their own superannuation account.[28]

1.32Appearing before the Committee, the FSC also disputed claims that ASIC would be able to clarify and interpret the law appropriately later:

Public statements from the regulator don't bind the regulator. So, with all due respect to the current commissioners, they could say whatever they like now, and the future commissioner, or even themselves at a future point in time, would not be bound by those comments. This would not be the only possible situation where ASIC has changed its opinion or changed a course of action after legislation has come into effect. What you've heard today from all of the superannuation representatives is called a diversity of opinions on how these provisions work. So, if the intent was to provide legal certainty, the drafting has absolutely failed to do that, and it can't be rectified by a regulator saying that its current interpretation at this point in time is as follows, because it has no legal effect.[29]

1.33In evidence before the Committee, the Association of Superannuation Funds of Australia (ASFA) confirmed that funds will have different risk tolerances, and some may determine that they will have to check every SOA, noting that:

… funds will reconsider their risk tolerances to that particular edition in the legislation. They will have differing views about whether or not they need to react in a way that suggests that they check every piece of advice or that they can take a risk based approach.[30]

1.34Evidence given to the Committee demonstrating the flawed drafting of the new Section 99FA also coincided with comments from the Super Members Council (SMC), claiming that ‘dodgy advisers are using click bait-style social media posts, cold calls and high-pressure sales tactics to convince people to change super funds.’[31] The comment was in reference to an ASIC report released lastmonth.

1.35The FSC described these comments as not contributing to a sensible debate, and questioned why ASIC wasn’t enforcing the law instead of just writing another report:

Some of the language, around dodgy advisers and that, that we've seen from the industry super side of things probably hasn't contributed to a sensible policy debate

…

It's quite extraordinary, to be honest. My observation would be: if the ASIC report found evidence of dodgy advisers, ASIC has the power to take action in relation to those advisers. It's done its report. If it found evidence of dodgy advisers, we would encourage it to take legal action. If all it has done is written a report on it, whilst it's found evidence of misconduct, then you do have to ask: what's ASIC doing with its time?[32]

1.36At the hearing, the FAAA described the language as inappropriate and misleading:

I think that language is pretty inappropriate. It is not the case that financial advisers are dodgy, and I think it's unfortunate that that language was used. I mentioned in my opening statement that ASIC report 781 found that less than one per cent of advice cases that they reviewed showed evidence of fee for no service, and even smaller proportions showed evidence of excessively high fees. That report did not provide any statistics on cold calling.[33]

1.37The Chair of the FAAA described the comments as ‘offensive’ and ‘a broad brush slur’.[34] WT Financial managing director Keith Cullen said that the SMC is ‘evidently out to undermine the advice profession’.[35]

1.38Even ASFA described the comments as inaccurate:

I don't think it's correct to use the term 'adviser' in that particular categorisation, because, by and large, there are not many licensed advisers left, as I have said, and I wouldn't say you could categorise them as doing cold calling.[36]

1.39Given these derogatory comments directed towards the advice profession, it is therefore no surprise that the SMC recommended that the Parliament ‘fast-tracks’ this Bill without amendments.[37]

1.40When asked about the prohibitive drafting of Section 99FA, as detailed in evidence from the Law Council provided to the Committee, the Treasury officials at the hearing said they hadn't listened to that evidence because they were apparently too busy:

Senator BRAGG: You think that the Law Council was wrong?

Dr Moore: I didn't hear the Law Council's evidence earlier today, so I can't comment on that, but what I can say is that the existing test and the new test are both objective tests. They both reflect trustee obligations in the law, and the difference is that the new one, as opposed to the current one, provides greater clarity by more fully stepping out the elements of that objective test.

Senator BRAGG: You didn't listen to the evidence today?

Dr Moore: I did listen to some of the evidence, but, you know, I've got a few things on my plate, so I wasn't able to sit right through the whole morning.[38]

1.41ASIC said it was given a copy of the Bill prior to it being introduced to the Parliament as part of ‘a quality assurance process’.[39] Regrettably, ASIC, along with the Minister's office, was unable to detect a drafting error in the Bill which would have effectively banned the current exemption for financial advisers from life insurance commissions:

Senator BRAGG: Did you know about this drafting error?

Mr Kirkland: I became aware of the drafting error when I saw the media reports of it.

Senator BRAGG: So ASIC didn't pick it up. That could have been one benefit of you guys being involved with drafting new laws.[40]

1.42Given this failure to detect drafting errors, it’s unclear what role ASIC’s ‘quality assurance process’ plays in the drafting process beyond that of policy formulation, which should be the domain of government and the Parliament.

1.43The FSC also noted that ASIC’s involvement in the policy formulation and drafting process lacks transparency, which is particularly concerning when supporters of the new Section 99FA are claiming that ASIC will provide clarity to the provision:

The other point I'll make is that ASIC hasn't released its submission on this bill. I think it would be a really useful evidence point to be able to see ASIC's submission and say, 'Okay, did what it submit on the draft of the bill align with what it is now saying publicly, or are they actually saying different things behind closed doors to what they're saying publicly?' We would love to have that transparency in the regulator's contribution on these issues to give the industry more confidence about what it says in public forums.[41]

1.44Ultimately, given the evidence provided to the inquiry, Coalition Senators are of the view that the proposed Section 99FA is not currently fit for purpose, and could lead to increased costs to financial advice. This would be entirely antithetical to the intent and recommendations of the Levy Review.

1.45The FAAA argued that the current risk-based approach for adviser fee deductions from super funds should continue:

The current generally accepted practice is for trustees to take a risk based approach. It's already been mentioned this morning—reviewing a sample of advice documents based on risk indicators, such as a high fee relative to the member's balance, to confirm that the fee is compliant with the sole purpose test. We're supportive of this approach and we believe it should continue.[42]

1.46In evidence to the Committee, CAANZ said that Part 1 Schedule 1 should be removed from the Bill and alternative solution considered later:

In light of these concerns and in the interest of this bill proceeding, we respectfully recommend that part 1 of schedule 1 be removed from the bill and further consultation take place to discuss a more efficient and less wasteful solution.[43]

1.47In order to advance the other parts of Schedule 1, the FSC also recommended that the new Section 99FA be excised, re-drafted and reconsidered as part of tranche 2:

So our recommendation at this point is that the bill shouldn't be held up. It is actually quite easy to excise the offending provisions from this bill, get the remainder of the items through and deal with this specific provision as part of the tranche 2 legislation that is expected to be released before the end of the month. It gives the government plenty of space to consult further with industry and come up with a suitable solution but not hold up other provisions relating to financial services in other sectors that might have great merit to them.[44]

1.48In a letter to the Committee from the Joint Associations Working Group (JAWG) of 12 industry and professional bodies, including the FAAA, FSC and CAANZ, it was submitted that ‘the proposed Section 99FA, as it stands, imposes several significant challenges that will lead to poor outcomes for consumers, particularly in terms of access to financial advice.’[45]

1.49To consider the necessary legislative amendments required, as made clear by their senior counsel advice, the JAWG recommended that Part 1 Schedule 1 be removed:

We urge the Committee to recommend that the Government remove Part 1 of Schedule 1 from the DBFO Bill and return with an updated proposal in Tranche 2 of the Delivering Better Financial Outcomes Package after transparent consultation with industry, including the JAWG associations.[46]

1.50If the Albanese Government is serious about providing cheaper and more accessible financial advice to Australians, rather than tailoring legislation to their favourite vested interests at the super funds, then they should take their proposed Section 99FA back to the drawing board.

1.51Financial advisers and Australian consumers should not have to bear the brunt of Labor’s incompetent legislative drafting.

1.52By removing Section 99FA in Division 1 of Schedule 1 from the Bill, speedy passage of the rest of the Bill through the Senate and the House can be facilitated. The Coalition believes such an approach would deliver certainty to a range of affected sectors including Australia’s screen production sector.

1.53That Part 1 Schedule 1 of the Bill be removed and the provisions re-consulted on by the Treasury in anticipation of Tranche 2 of the Government’s legislation implementing the Quality of Advice review recommendations.

Senator Andrew BraggSenator Dean Smith

Deputy Chair Liberal Senator for Western Australia

Liberal Senator for New South Wales

Footnotes

[1]Mr Blake Briggs, Chief Executive Officer, Financial Services Council, Committee Hansard, 13June2024, p. 20.

[2]Department of the Treasury, Quality of Advice Review - Final Report, 8 February 2023, https://treasury.gov.au/publication/p2023-358632 (accessed 19 June 2024), p. 7.

[3]Department of the Treasury, Quality of Advice Review - Final Report, 8 February 2023, https://treasury.gov.au/publication/p2023-358632 (accessed 19 June 2024), p. 117.

[4]Financial Advice Association of Australia, Submission 41, p. 4.

[5]Stockbrokers and Investment Advisers Association, Submission 29, p. 2.

[6]Stockbrokers and Investment Advisers Association, Submission 29, p. 2.

[7]Stockbrokers and Investment Advisers Association, Submission 29, p. 2.

[8]Mr Nathan Hodge, Head of Submissions, Superannuation Committee, Legal Practice Section, Law Council of Australia, Committee Hansard, 13 June 2024, p. 17.

[9]Law Council of Australia, Submission 31, p. 4.

[10]Mr Nathan Hodge, Head of Submissions, Superannuation Committee, Legal Practice Section, Law Council of Australia, Committee Hansard, 13 June 2024, p. 20.

[11]Law Council of Australia, Submission 31, p. 4.

[12]Law Council of Australia, Submission 31, p. 4.

[13]Chartered Accountants ANZ and CPA Australia, Submission 39, p. 3.

[14]Chartered Accountants ANZ and CPA Australia, Submission 39, p. 3.

[15]Mr Michael Davison, Financial Advice Leader, Chartered Accountants Australia and New Zealand, Committee Hansard, 13 June 2024, p. 28.

[16]Mr Nathan Hodge, Head of Submissions, Superannuation Committee, Legal Practice Section, Law Council of Australia, Committee Hansard, 13 June 2024, p. 17.

[17]Financial Advice Association of Australia, Submission 41, p. 1

[18]Financial Advice Association of Australia, Submission 41, p. 5

[19]Ms Sarah Abood, Chief Executive Officer, Financial Advice Association of Australia, Committee Hansard, 13 June 2024, p. 12.

[20]Institute of Public Accountants, Submission 48, p. 3.

[21]Joint Licensees Group, Submission 53, p. 2.

[22]Joint Licensees Group, Submission 53, p. 3.

[23]Joint Licensees Group, Submission 53, p. 3.

[24]Mr Keith Cullen, Managing Director, WT Financial Group Ltd; and Representative, Joint Licensees Group, Committee Hansard, 13 June 2024, pp. 13–14.

[25]Mr Keith Cullen, Managing Director, WT Financial Group Ltd; and Representative, Joint Licensees Group, Committee Hansard, 13 June 2024, p. 16.

[26]Financial Services Council, Submission 54, pp. 1–2.

[27]Financial Services Council, Submission 54, p. 2.

[28]Financial Services Council, Submission 54, p. 2.

[29]Mr Blake Briggs, Chief Executive Officer, Financial Services Council, Committee Hansard, 13June2024, p. 19.

[30]Ms Mary Delahunty, Chief Executive Officer, Association of Superannuation Funds of Australia, Committee Hansard, 13 June 2024, p. 8.

[31]Cliona O’Dowd, ‘Industry, retail super funds clash over advice reforms’, The Australian, 11 June 2024, https://www.theaustralian.com.au/business/industry-retail-super-funds-clash-over-advice-reforms/news-story/13724d85d9e641d759a4e4e5cad01752 (accessed 19 June 2024).

[32]Mr Blake Briggs, Chief Executive Officer, Financial Services Council, Committee Hansard, 13 June 2024, pp. 18–20.

[33]Ms Sarah Abood, Chief Executive Officer, Financial Advice Association of Australia, Committee Hansard, 13 June 2024, pp. 15–16.

[34]Keith Ford, ‘‘Broad brush slur’: Broader profession unites against SMC’, Independent Financial Adviser, 14 June 2024, https://www.ifa.com.au/news/34378-broad-brush-slur-broader-profession-unites-against-smc (accessed 19 June 2024).

[35]Keith Ford, ‘‘Broad brush slur’: Broader profession unites against SMC’, Independent Financial Adviser, 14 June 2024, https://www.ifa.com.au/news/34378-broad-brush-slur-broader-profession-unites-against-smc (accessed 19 June 2024).

[36]Ms Mary Delahunty, Chief Executive Officer, Association of Superannuation Funds of Australia, Committee Hansard, 13 June 2024, p. 10.

[37]Super Members Council, Submission 51, p. 2.

[38]Dialogue between Senator Bragg and Dr Andre Moore, Acting First Assistant Secretary, Retirement, Advice and Investment Division, Department of the Treasury, Committee Hansard, 13 June 2024, p. 33.

[39]Mr Alan Kirkland, Commissioner, Australian Securities and Investments Commission, Committee Hansard, 13 June 2024, p. 34.

[40]Dialogue between Senator Bragg and Mr Alan Kirkland, Commissioner, Australian Securities and Investments Commission, Committee Hansard, 13 June 2024, p. 34.

[41]Mr Blake Briggs, Chief Executive Officer, Financial Services Council, Committee Hansard, 13June2024, p. 19.

[42]Ms Sarah Abood, Chief Executive Officer, Financial Advice Association of Australia, Committee Hansard, 13 June 2024, p. 12.

[43]Mr Michael Davison, Financial Advice Leader, Chartered Accountants Australia and New Zealand, Committee Hansard, 13 June 2024, p. 26.

[44]Mr Blake Briggs, Chief Executive Officer, Financial Services Council, Committee Hansard, 13June2024, p. 19

[45]Joint Association Working Group, Submission 57, p. 1.

[46]Joint Association Working Group, Submission 57, p. 2.