In its submission to FASEA, the AFA said it was unclear why its CPD package includes three documents – the draft legislative instrument, the explanatory statement and the policy statement – when it was simply expecting a legislative instrument and a document that explains the legislative instrument.
Further, the AFA pointed to the commencement date of the CPD policy of 1 January 2019 as “absolutely unreasonable”.
“Put bluntly, this is an impossible proposition for over 2,200 advice licensees to implement, at this time of the year with only three weeks left before it is due to commence,” the AFA said in the submission.
“The best outcome is always achieved on the back of sensible, considered and pragmatic reform with time to plan, prepare and implement. In this context, the cost will be unnecessarily excessive, with a lot of wasted (or inefficient) activity and the overall outcome being sub-optimal.
“We can only ponder the reasons for an independent regulator, such as FASEA, to push such an unachievable time frame and proposal in the current environment.”
The AFA said it didn’t feel there was an adequate explanation from FASEA regarding its CPD legislative instrument.
“The policy statement refers to formal education and includes a requirement that a maximum of 25 hours of formal education will be included each year in the overall CPD outcome,” the AFA said.
“Surprisingly, this discussion and the requirement is not reflected in either the legislative instrument or the explanatory statement. We question how this 25-hour cap can be binding if it is not in the legislative instrument.”
Another example of a lack of clarity, according to the AFA, was around Section 7(1)(d) of the legislative instrument where it states “the activity is led or conducted by one or more persons who…”.
It said there was no further explanation within the explanatory statement around what “led or conducted” means, and noted the requirement isn’t even addressed in the policy statement.
“This appears to us to be an important requirement that might determine what form of delivery of CPD is approved and what is not, yet we cannot find an explanation across the three documents of exactly what ‘led or conducted’ actually means,” the AFA said.
“We believe that this highlights the lack of clarity and the complications in having three separate documents.”




Just Another Knee Jerk Reaction from a bunch of Yes Men and Women!!!
This will in NO WAY improve the quality of advice and if somebody wants to be a rat they will be a Rat, regardless of what qualifications they have.
I certainly consider myself a very sound and experienced adviser but I will be one looking to exit the industry due to the impost this will have on my business both now and ongoing. I am in no way happy to pass these costs on to my clients as I have done this enough with other crazy legislation passed on by out of touch politicians.
It is simply a time for governments to Wake up to themselves and increase the penalties to those who do the wrong thing, not penalise those doing a good job for all Australians.
I often hear “Where is the FPA”….. in Industry commentary, yep, they are under the radar mostly.. Seems to me ALL industry associations and stakeholders should form a single working group to develop, lobby and actively participate in useful and appropriate change, change that works in the best interests of all.. I cant believe that has not happened, what a huge hole left for the FSU to fill…And who is to blame for that…. The Industry we work in, shame on us, expecting a leftie Labour Union to bail us out, FFS !!
When I started in the industry in 1986, communication was 80% of the job. In 2018, communication is 80% of the job. Those who fail in the field get involved in academics. Those who are succeeding in the field get “educated” every day.
I’m not confident FASEA could even run a “trainwreck” on time or effectively.
Why is it when it is abundantly clear FASEA have no idea what they are doing nor the impact of what they do eventually propose, that only the AFA call this out? As an industry we should ALL be united one way or another in just saying NO to this rubbish…and demand they get real and co-operate to deliver sensible reform or get the hell out the way!!! People are taking their own lives over this sort of nonsense, the FASEA buffoons get paid either way but Advisers and stakeholders are bleeding over this and enough is enough.
How is this train-wreck that is the FASEA organisation being allowed to continue with its inept “leadership”, surely its time to get rid of the lot of them and replace them with people who are REAL leaders in this industry. Should only be a matter of time before there is a class action for the stress being caused to all of us.
Maybe more than a class action Gav. Soon we will have a federal anti corruption commission. FASEA Board members have refused to allow credit for perfectly good higher education that is within the spirit of the law. They are forcing advisers to pay for additional courses at institutions such as those many FASEA Board members are associated with. The FASEA Board should be investigated for corruption.
Add “arrogant” with a self-serving Board. They are in huge hurry because university enrolments are DROPPING and the Government is forecasting cuts to education funding. Simple as that. The Dept of Educ & Training notes a decrease in applications for a uni place of 3.3% down from 2017.
Great that the AFA is stepping up to the mark, when the FPA continues to let advisers down, operating in their own bubble without a member charter.
to quote the CEO of Kaplan Brian Knight from a recent national conference I attended in regards to FASEA, “….TRAINWRECK!”.
Only Government Bodies and Politicians can be so freaking useless.
TRAINWRECK is too good a description for the complete disaster mess they have made and continue to make ongoing, ongoing, ongoing !!!! 🙄