When is a client really a client?

It made a submission on the proposed disclosure regulations for the new regime.

The Government is proposing staged disclosure, through which advisers make certain generic information publicly available but then move to more specific and relevant information as the client relationship progresses.

Advisers would be required to keep a record of the disclosures given.

But Katrina Shanks, chief executive of the association, said more clarification was needed on when a consumer was considered a client because this would affect what record-keeping was required and for whom.