Speaking at the Association of Financial Advisers conference at the Gold Coast, Mr Kell said it is important for advice providers to understand the “nature and limitations” of third parties.
“This has come up quite a bit in our recent surveillance work … it is too often a source of problems for licensees,” he said.
“It should be obvious that you can’t outsource your compliance [completely],” said Mr Kell.
He also stressed the importance of doing due diligence on new authorised representatives.
Mr Kell pointed out that advisers will be more likely to fail the best interests test if they dispense “cookie cutter” advice.
Cookie cutter compliance is the reason cookie cutter advice was allowed to thrive in the first place. Compliance departments and ASiC struggle to understand that.