For compliance managers overseeing licensed financial planners, one of the most overlooked—but critical—components of file compliance is the timely export and storage of the Fact Find from your financial planning software. While many planners diligently update client data at the time of advice, failing to evidence this update in the client file creates a risk that can be easily avoided.
Why the Fact Find Matters
The Fact Find is not just an administrative tool—it’s the foundation of compliant and quality advice. It demonstrates that the adviser had a complete and accurate understanding of the client’s goals, needs, financial position, and risk tolerance at the time the advice was given. This information underpins the rationale in the Statement of Advice (SOA).
Key Risks Without It
Without exporting and saving the Fact Find:
- No timestamped evidence exists to show data was up to date at the time of advice.
- Files may fail audits or ASIC reviews due to a lack of adequate records.
- Licensees risk increased reporting obligations and potential penalties for breaches.
What Compliance Managers Should Coach
- Export the Fact Find: Encourage advisers to export the completed Fact Find on the same day the advice is given or during the strategy meeting.
- Save to the Client File: Ensure the exported PDF (or equivalent) is saved to the document management system alongside the SOA and client notes.
- Use it as an Audit Checkpoint: As part of internal reviews, verify the Fact Find is present, recent, and consistent with the advice provided.
- Highlight Version Control: If the Fact Find was updated over time, ensure that the version history or final version is stored to reflect what was relied upon for the advice.
- Educate on Recordkeeping Obligations: Remind planners that under RG 175 and general recordkeeping provisions of the Corporations Act, documentation must support the basis of advice.
Final Thought
Taking the small but intentional step of exporting and filing the Fact Find ensures advisers have a strong compliance trail. It strengthens the licensee’s audit position, reduces regulatory risk, and reinforces a culture of accountability for advice. As a compliance leader, reinforcing this habit can make a meaningful difference across your network.
Call to Action:
Whether you’re navigating complex compliance requirements or want greater peace of mind, investing in internal audit coaching or engaging an independent auditor can be a strategic advantage, not just a regulatory checkbox. If your business is ready to strengthen its audit processes, uncover hidden risks, or validate your internal controls with an expert second opinion, now is the time to act.
Contact our compliance team today to explore tailored internal audit support or consultation with an experienced independent auditor at hello@aicsolutions.com.au.
