Angus-Dale Jones, PAA board member and NZAM head of compliance, said the goals the paper identified to drive the review of the legislation would be vital to the direction it took.

The paper says the goal for financial advice is that consumers have the information they need to choose an adviser, advice is accessible and public confidence in advisers is promoted.

But Dale-Jones said this was too much of a “one-size-fits-all” approach and did not consider the possibility that many consumers did not want a full financial plan each time they sought advice.

At present, offering limited advice is difficult because of advisers’ requirements to prove the suitability of their advice to clients. He said that needed to be addressed in the legislation, not left to the Code Committee to manage.

“I would add as a goal statement something about the extent and scope of advice and how the Act can make it more viable to tailor advice to a specific context.”

The Financial Service Providers Register (FSPR) and external dispute resolution schemes are also up for review.

Dale-Jones said the paper seemed to have missed an opportunity with the FSPR. "It doesn't take advantage of the beautiful monopoly the Companies Office has on all this data."

He suggested the FSPR could be used in the same way MBIE's "disclose" site handles the primary disclosure statements for investment offers, under the Financial Markets Conduct Act.

Clients could be directed to the register for access to adviser disclosure statements and to compare advisers.

And when it comes to external disputes resolution services (EDRS), Dale-Jones said he was not sure the approach being taken was the right one at all.

The issues paper says its goals for EDRS are that consumers should be aware of disputes resolution schemes, be able to access and have confidence in them.

But Dale-Jones said that missed the point that they might not be the right solution to the problem of a lack of consumer redress.

He said it was worth asking whether there were other options. In Australia, NAB has started a consumer advocacy division, which he said could produce better consumer outcomes at an institutional level.

But Dale-Jones said there were a number of aspects of the issues paper that he was happy about, such as the commentary about the role of professional associations and the cost of regulation. "It gives us the opportunity to work with members to make sure the information comes through."