1. Stage 1 publicly available disclosure information must be easy to find:
   We recommend having a link or button on your home page that takes the viewer to the detailed information. When positioning the button, test how it looks on a mobile device. Some commentators report over 70% of internet searches are now conducted via mobile devices. We have seen multiple instances where the button/link is really visible on a website homepage when viewed on a laptop, but moves right to the bottom when viewed on a mobile phone. Check that the button/link is ‘active’ and actually works when clicked. Have consistency of description as to what you call the stage 1 disclosure information.
2. Stage 1 disclosure content needs to be correct:
   Common issues include:
   • Still displaying the old disclosure statement from the Financial Advisers Act 2008
   • Not listing the authorised bodies who belong to the licensed FAP
   • Stating you don’t receive commission yet you have KiwiSaver clients where you get paid commission.
   • Using language a reasonable individual may struggle to understand. We recommend simple easy to understand language.
   • Not correctly customising a template and ending up with conflicting information in the document.
3. Incorporate stage 2 and 3 disclosure into existing advice documents:
   We are seeing many firms wanting to follow past practices and have stage 2 and 3 disclosure as separate standalone documents which they get clients to sign. There is no requirement to have clients sign the disclosure information. We recommend the staged disclosure be built into existing documents such as scope of service, client fact find, or statement of advice. Keep it simple and avoid duplication of information already disclosed in earlier stages. If the time frame from meeting a client to giving the advice is really short, then consider combining stage 2 and three.
4. List the authorised bodies:
   An authorised body is an unlicensed FAP and must provide stage 1 publicly available disclosure information. If the authorised body does not have its own website and instead operates under the brand of the licensed FAP, then a simple way to meet the disclosure obligations is to list all authorised bodies in the ‘licence status and conditions’ section of the licensed FAP stage 1 disclosure.
5. Consistency within a brand and FAP:
   A licensed FAP is responsible for the compliance of all those operating under its licence. We have noticed multiple situations where the authorised bodies and advisers are providing different services with different pricing to that of the licensed FAP. Our recommendation is for all those operating under a common public facing brand to promote the same services, have common pricing structures, use common documents and have consistency of methodology.

We are here to help. Contact us if you have questions or need assistance with streamlining your compliance.