Of the 1900 AFAs registered with the FMA only around 500 are 'non-affiliated' to a large provider. There are a number of reasons that we have all chosen that status.  For me, it is for 'independence' and so that I can assist my clients without any 'product allegiance'.  It is also so that I can run our business in the way that I want to.  The other 499 AFA's will have their own reasons.

But the reactions on Good Returns to the recent propososed changes to DIMs and the Adviser Return indicate that many more people are planning on becoming 'affiliated'.  Personally, I believe that would be a shame and mean that the consumers have far less real choice.

We are already seeing less and less choice available to investors.  A colleague shared a story last week, where she was the third adviser that a new client (with significant assets) had visited as the other two had proposed the same investment portfolio to her.

Do you want to retain your  'non affiliated' status? I certainly do.  And I am not going to make the mistake that we all made in 2007-2010 of not letting my voice be heard.

Yes, we are small businesses.  Yes, we do have a lot on our plate, juggling all the demands. 

But that is the price we pay for the privilege of being self-employed. The development of the Financial Advisers Act 2008 saw very few 'small business' businesses heard.  That is why we have the legislation we have now.  It is heavily influenced by the 'big players'.  Remember, the banks and large institutions have the ability to have dedicated teams inhouse, or contracted legal experts to make submissions for them.

Do we want this to happen to us again?

Many of our financial planning clients are senior Public Servants, senior policy analysts or policy analysts.  We have talked to them at length about their jobs.  These are the people that give the advice to the Minister about what to put in the rules, regulations and legislation. 

The important thing is - they aren't the experts.  They can only write rules, regulations and legislation based on the information they are provided with.  If the only information that they get is from the banks and big players, t be heard.

Our clients tell us that they do read each submission.

They also tell us that the submissions that make a difference are those that give good reasons, that make alternative suggestions.  But having said that, a volume of responses that voice concern against something will also have an effect.  We have seen that with the submissions on the reporting requirements for AFA's.  There were 38 submissions (plus 5 confidential submissions.)  A number of these were from advisers saying that they couldn't understand why we should report our income.  Now this requirement has been taken out of the reporting.  It works!!

Your submissions doesn't have to be a novel.  It doesn't have to erudite.  But it does have to be polite, and make sense and if you can - give reasons, so that the policy analysts and people who are reading it at the other end can understand where you are coming from.

I personally believe that these two issues - DIMs and Adviser Return are really important to my clients and business going forward. 

Yes, like you I am really busy.  But I have set aside the time to read the documents, do my research and put in my return.

Why don't you do this too - if you want to retain your non-aligned perspective?

The more of us that make a submission, the more submissions have to be read.  We might make a difference.

Here are the links

DIMs consultation

Adviser Reporting consultation

Carey Church
Authorised Financial Adviser, CFP, CLU, F Fin