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Accountants still underestimating licensing paperwork requirements


While licensed accountants are completing the fact-finding or questioning process with clients in an effective and thorough manner, many are still failing to record adequate notes of this information, according to an industry consultant.

By Miranda Brownlee11 minute read

Mayflower Consulting director Sarah Penn said the main compliance issue for licensed accountants continues to be the substantiation of the basis of advice, and ability to demonstrate that they have all of the relevant information.

“It’s mainly the recording of the questioning process. I’m sure accountants are asking excellent questions, but they need to be all written down,” she said.


“To do that you need to have fact-find documents, and they’re often 30 to 50 pages in length. They’re long and they’re boring, but that’s how you demonstrate to ASIC that you have made all the right efforts to know your client properly in order to be able to give them personalised advice.”

Ms Penn said she continues to see a complete underestimation of what ASIC expects from licensees, with many accountants still finding the process of completing compliance paperwork highly unnatural.  

“This is the way ASIC operates; evidence is everything, and unless you can substantiate that you’ve got fact-finds, statements of advice [and] compliance plans in place, you are going to be in a great deal of trouble when ASIC comes knocking,” she said.

“ASIC has been very clear that they are going to go and find some people who are doing the wrong thing and make an example out of them.”



Accountants still underestimating licensing paperwork requirements
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Miranda Brownlee

Miranda Brownlee


Miranda Brownlee is the deputy editor of SMSF Adviser, which is the leading source of news, strategy and educational content for professionals working in the SMSF sector.

Since joining the team in 2014, Miranda has been responsible for breaking some of the biggest superannuation stories in Australia, and has reported extensively on technical strategy and legislative updates.
Miranda also has broad business and financial services reporting experience, having written for titles including Investor Daily, ifa and Accountants Daily.

You can email Miranda on:miranda.brownlee@momentummedia.com.au

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