When it released the new Code of Conduct for AFAs last week, the Financial Markets Authority cautioned that it expected advisers to be working in line with it, with updated adviser business statements, by March.

Code Committee chairman David Ireland said the communication from the FMA around the new code was "not how the code committee would have penned such a thing".

He said it was possible that some business statements would not need to be changed much.

“What advisers should take from it is that it’s important to look at your ABS and see whether it is still fit for purpose.

“The code has changed and an adviser’s ABS is supposed to reflect how you are operating to comply with the code.”

He said the Christmas break would be a good chance for many advisers to dust off their ABSs and remind themselves what was in them. “Use this as an opportunity or a prompt. Your ABS is likely to be good for another year, we are not expecting any changes to hit prior to 2018, so it’s not wasted time.”

Advisers should consider their service proposition and business model and make sure the ABS reflected that, he said.

“Another key action revisit your professional development plan and look at it in light of the changes to the competence requirements – is your PDP appropriate, is there any adjustment you need to make both in light of the changes and any change to the way you envisage operating in the year ahead? That should be part of your regular cycle each year.”

The new version of the code recognises new qualifications.

The Financial Advisers Act review will bring big changes for the code as it will have to apply to all advisers.

Ireland said he had been expecting an announcement on what the composition of the committee and its processes and scope might be expected to be in September but it was now due in December, with the release of the exposure draft of the Act.

Financial advice firms that plan to be licensed under the new regime will need to see the new version of the code to develop the processes to demonstrate their capacity to operate in accordance with it – but that cannot be done until the new code committee is in place and the code finalised.

In the meantime, existing code committee members are rolling over on to new terms. But Ireland said it was likely they would have little to do for now. There was no appetite for further change to the code with the FAA review under way.

He said it was likely the positions on the code committee would come up for review as part of that, to ensure it was populated with people who had the right skill sets and perspective to guide the new regime and reflect the broader scope of the code.