Obligations Register
Reviewed: 02/08/2025 – Rupert Gough
Unsolicited Electronic Messages Act 2007
Policy
Advertising and Fair Dealing Policy
Obligation
This Act requires financial service providers, authorised bodies and financial advisers to be registered on the FSPR.
Key Control
Annual Confirmation on FSPR
Monitoring Frequency
Annual, Ongoing
Financial Markets Conduct Act 2013
Part 2 Fair Dealing, 431P
Policy
Advertising and Fair Dealing Policy
Obligation
Part 2 of the Financial Markets Conduct Act 2013 (FMC Act) sets out the requirements for “fair dealing”. The principles of fair dealing prohibit:
• misleading or deceptive conduct
• false or misleading representations
• unsubstantiated representations
• offers of financial products during unsolicited meetings.
Key Control
Complaints or breaches will be recorded
Monitoring Frequency
Ongoing
Financial Markets Conduct Act 2013
Part 2 Fair Dealing
Policy
Advertising and Fair Dealing Policy
Key Control
Complaints Register
Monitoring Frequency
Ongoing
Financial Markets Conduct Act 2013
Part 2 Fair Dealing
Policy
Advertising and Fair Dealing Policy
Key Control
Sign off checklist
Monitoring Frequency
Annual
Financial Markets Conduct Act 2013
Part 2 Fair Dealing, 431P
Policy
Advertising and Fair Dealing Policy
Obligation
Part 2 of the Financial Markets Conduct Act 2013 (FMC Act) sets out the requirements for “fair dealing”. The principles of fair dealing prohibit:
• misleading or deceptive conduct
• false or misleading representations
• unsubstantiated representations
• offers of financial products during unsolicited meetings.
Key Control
Sign off process for new advertising material.
Monitoring Frequency
Bi-Annual
Financial Markets Conduct Act 2013
Part 2 Fair Dealing, 431P
Policy
Advertising and Fair Dealing Policy
Obligation
Part 2 of the Financial Markets Conduct Act 2013 (FMC Act) sets out the requirements for “fair dealing”. The principles of fair dealing prohibit:
• misleading or deceptive conduct
• false or misleading representations
• unsubstantiated representations
• offers of financial products during unsolicited meetings.
Key Control
MoPro Module Complete
Monitoring Frequency
Annual
Consumer Guarantees Act 1993
Policy
Advertising and Fair Dealing Policy
Obligation
Ensure the services are carried out with reasonable care and skill, is fit for purpose and of reasonable quality.
Key Control
MoPro Module Complete
Monitoring Frequency
Annual
Fair Trading Act 1986
Policy
Advertising and Fair Dealing Policy
Obligation
The Fair-Trading Act 1986 protects clients against being misled or treated unfairly by traders or shops.
The Act prohibits misleading and deceptive conduct, unsubstantiated claims, false representations and certain unfair practices.
It also sets out when information about certain products must be disclosed to Clients and helps ensure products are safe. https://www.Client.org.nz/articles/fair-trading-act
Key Control
MoPro Module Complete
Monitoring Frequency
Annually
Financial Markets Conduct Act 2013
Part 2 Fair Dealing
Policy
Advertising and Fair Dealing Policy
Obligation
Part 2, Fair Dealing sets out the obligations for misleading or deceptive conduct generally in relation to financial products and services.
A person must not, in trade, engage in conduct that is misleading or deceptive or likely to mislead or deceive in relation to any dealing in financial products; or the supply or possible supply of a financial service or the promotion by any means of the supply or use of financial services.
A person must not engage in conduct that is misleading or deceptive or likely to mislead or deceive in relation to any dealing in quoted financial products.
Key Control
MoPro Module Complete
Monitoring Frequency
Annually
Financial Markets Conduct Act 2013
Schedule 5, part 1, clause 4
Policy
Advice for Wholesale Clients
Obligation
The FMC Act sets out various categories of what constitutes a wholesale client.
Key Control
Complaints or breaches will be recorded
Monitoring Frequency
Financial Markets Conduct Act 2013
Schedule 5, part 1, clause 4
Policy
Advice for Wholesale Clients
Obligation
The FMC Act sets out various categories of what constitutes a wholesale client.
Key Control
Staff awareness and education
Monitoring Frequency
Financial Markets Conduct Act 2013
Schedule 5, part 1, clause 4
Policy
Advice for Wholesale Clients
Obligation
The FMC Act sets out various categories of what constitutes a wholesale client.
Key Control
Written material
Monitoring Frequency
Financial Markets Conduct Act 2013
Schedule 5, clauses 8 -18
Policy
Advice Types – Non-Advice and Partial Advice Policy
Obligation
The FMC Act sets out various exclusions from what constitutes ‘regulated financial advice’.
Key Control
Complaints or breaches will be recorded
Monitoring Frequency
Financial Markets Conduct Act 2013
Schedule 5, clauses 8 -18
Policy
Advice Types – Non-Advice and Partial Advice Policy
Obligation
The FMC Act sets out various exclusions from what constitutes ‘regulated financial advice’.
Key Control
Monitoring Frequency
Annually
Financial Markets Conduct Act 2013
Schedule 5, clauses 8 -18
Policy
Advice Types – Non-Advice and Partial Advice Policy
Obligation
The FMC Act sets out various exclusions from what constitutes ‘regulated financial advice’.
Key Control
Non advice disclaimer for products not providing comprehensive financial advice
Monitoring Frequency
Annually
Financial Markets Conduct Act 2013
Schedule 5, clauses 8 -18
Policy
Advice Types – Non-Advice and Partial Advice Policy
Obligation
The FMC Act sets out various exclusions from what constitutes ‘regulated financial advice’.
Key Control
MoPro – Staff awareness and education
Monitoring Frequency
Ongoing
Financial Markets Conduct Act 2013
Policy
Client Onboarding Policy
Obligation
Code of Professional Conduct for Financial Advice Services Part 1, Ethical Behaviour, Conduct and Clients Care
(All code standards under part 1 apply)
FMC Act 2013 Part 2 – Fair Dealing
FMC Act 2013 431J – Duty to ensure client understands the nature and scope of advice
Key Control
Client file reviews
MoPro Module Complete
Monitoring Frequency
Annual
Code of Professional Conduct for Financial Advice Services
Policy
Client Onboarding Policy
Obligation
Part 1, Ethical Behaviour, Conduct and Clients Care
(All code standards under part 1 apply)431J – Duty to ensure client understands the nature and scope of advice
Key Control
Client file reviews
Monitoring Frequency
Annual
Code of Professional Conduct for Financial Advice Services
Policy
Client Onboarding Policy
Obligation
Part 1, Ethical Behaviour, Conduct and Clients Care
(All code standards under part 1 apply)431J – Duty to ensure client understands the nature and scope of advice
Key Control
MoPro Module Complete
Monitoring Frequency
Annual
Code of Professional Conduct for Financial Advice Services
Policy
Client Servicing Policy
Obligation
Part 1: Ethical Behaviour, Conduct and Client Care
431M – Duty to comply with the code of conduct
Key Control
Client file reviews
Monitoring Frequency
Annual
Code of Professional Conduct for Financial Advice Services
Policy
Code of Conduct and Ethics
Obligation
FMA’s guide to conduct
431Z Application of conduct obligations
Part 1, Ethical Behaviour, Conduct and Clients Care
Part 2, competence, knowledge and skill.
(All code standards under Part 1 and 2 apply)
Key Control
MoPro Module Complete
Monitoring Frequency
Annual
Code of Professional Conduct for Financial Advice Services
Policy
Code of Conduct and Ethics
Obligation
FMA’s guide to conduct
431Z Application of conduct obligations
431M Duty to comply with code of conduct
Part 1, Ethical Behaviour, Conduct and Clients Care
Part 2, competence, knowledge and skill.
(All code standards under Part 1 and 2 apply)
Key Control
MoPro Module Complete
Monitoring Frequency
Annual
Code of Professional Conduct for Financial Advice Services
Policy
Code of Conduct and Ethics
Obligation
FMA’s guide to conduct
431Z Application of conduct obligations
431M Duty to comply with code of conduct
Part 1, Ethical Behaviour, Conduct and Clients Care
Part 2, competence, knowledge and skill.
(All code standards under Part 1 and 2 apply)
Key Control
Material Issues and Breaches Register
Monitoring Frequency
Ongoing
Code of Professional Conduct for Financial Advice Services
Policy
Code of Conduct and Ethics
Obligation
The Code is part of a wider regulatory regime for financial advice. Subpart 5A of Part 6 of the FMC Act imposes statutory duties on persons who give regulated financial advice to retail clients.
Those duties include:
to comply with the standards of ethical behaviour, conduct, and client care required by the Code
to meet the standards of competence, knowledge, and skill (including any continuing professional development requirements) provided in the Code for giving the advice.
Key Control
MoPro Module Complete
Monitoring Frequency
Annual
Complaints -FAP Licence Requirement and/or Standard Condition
Policy
Complaints Handling Policy
Obligation
Standard condition of licence
Key Control
Complaints Register
Monitoring Frequency
Bi-monthly
Complaints -FAP Licence Requirement and/or Standard Condition
Policy
Complaints Handling Policy
Obligation
“Person in business of providing financial service must be registered and member of approved dispute resolution scheme”.
Key Control
DRS Memberships
Monitoring Frequency
Annual, Onboarding
Financial Service Providers (Registration and Dispute Resolution) Act 2008
Clause 11, 12, 17, 49f
Policy
Complaints Handling Policy
Obligation
Requires the appointment of a disputes resolution service to act as mediator when a complaint cannot be resolved directly with the client;
Key Control
MoPro Module Complete
Monitoring Frequency
Annual
Financial Markets Conduct Act 2013
Policy
Conflicts of Interest Policy
Obligation
Comply with the duties and code of conduct.
Key Control
Conflicts of Interest Register
Monitoring Frequency
Annual
Code of Professional Conduct for Financial Advice Services
Policy
Conflicts of Interest Policy
Obligation
Part 1, Ethical Behaviour, Conduct, and Client Care.
Code Standard 2, Act with Integrity,
A person who gives financial advice must always act with integrity
Avoiding or appropriately managing any conflict of interest
Key Control
MoPro Module Complete
Monitoring Frequency
Annual
Financial Markets Conduct Regulations 2014
229C – 229I
Policy
Disclosure Policy
Obligation
Ensure that the prescribed information about the FAP is publicly available. This means on the website and can be provided in writing if so requested.
Ensure that information is provided when the nature and scope of the advice is known.
Ensure the Financial Adviser/FAP provides appropriate information when the recommendations are made.
Ensure information of the FAP’s complaint handling process and disputes resolution scheme is given if a complaint is received.
Key Control
Disclosure review
Monitoring Frequency
Annual
Financial Markets Conduct Regulations 2014
229C – 229I
Policy
Disclosure Policy
Obligation
Ensure the client is not overburdened by repetition of information that they have already received.
Ensure that any information (in any format) that you make available or give is presented in a clear, concise and effective manner; and if it is prescribed with other information it is given prominence and is made available or given free of charge.
Key Control
Compliants review
Monitoring Frequency
Annual
Domestic Violence – Victims’ Protection Act 2018
Policy
Disclosure Policy
Obligation
Ensure the client is not overburdened by repetition of information that they have already received.
Ensure that any information (in any format) that you make available or give is presented in a clear, concise and effective manner; and if it is prescribed with other information it is given prominence and is made available or given free of charge.
Key Control
Compliants review
Monitoring Frequency
Annual
Financial Service Providers (Registration and Dispute Resolution) Act 2008
S11, 12, 17, 49f
Policy
Disclosure Policy
Obligation
Ensure the client is not overburdened by repetition of information that they have already received.
Ensure that any information (in any format) that you make available or give is presented in a clear, concise and effective manner; and if it is prescribed with other information it is given prominence and is made available or given free of charge.
Key Control
Compliants review
Monitoring Frequency
Annual
Companies Act 1993
Policy
Financial Management Policy
Obligation
We have a duty of care to comply with our Licensing conditions and the Companies Act 1993 in relation to the financial viability of our business.
Key Control
Delegations Register
Monitoring Frequency
Annual
Companies Act 1993
Policy
Financial Management Policy
Obligation
You must, at all times, have adequate financial resources to effectively perform the licensed service.
Minimum standards
You have a sufficiently strong balance sheet.
You are able to pay your debts as they become due in the normal course of business.
You maintain an appropriate level of liquid assets at all times to cover reasonably expected contingencies in your business.
You have adequate and effective systems, policies, procedures and controls to:
Monitor your financial resource levels
Consistently calculate an appropriate level of liquid assets to hold for your business
Assess the risk of your financial resources not being adequate to continue to provide the service, or a serious financial problem occurring
Key Control
Financial management processes
Monitoring Frequency
Ongoing
Companies Act 1993
Policy
Financial Management Policy
Obligation
Solvency, tax records etc.
Key Control
Financial management processes
Monitoring Frequency
Annual
Companies Act 1993
Policy
Financial Management Policy
Obligation
Key Control
Budget, Profit and Loss and Cashflows
Monitoring Frequency
Annual
Financial Markets Conduct Act 2013
S396
Policy
Fit and Proper Policy
Obligation
Section 396, part b, directors, senior managers, and proposed directors and senior managers are fit and proper persons to hold their respective positions and otherwise satisfy the requirements that are prescribed by the regulations for licences for that service
Key Control
Fit and Proper attestation
Monitoring Frequency
Annual
Financial Markets Conduct Act 2013
S396
Policy
Fit and Proper Policy
Obligation
Ensure Directors and Senior Managers meet the fit and proper requirements.
Key Control
Policy Review & recruitment process
Monitoring Frequency
Annual
Code of Professional Conduct for Financial Advice Services
Policy
Gifts and Incentives Policy
Obligation
Part 1, Ethical Behaviour, Conduct and Client Care
Code Standard 2 – Act with Integrity
Key Control
Gift Register
Monitoring Frequency
Annual
Health and Safety at Work Act 2015
Policy
Health & Safety
Obligation
The main purpose of this Act is to provide for a balanced framework to secure the health and safety of workers and workplaces. Ensure that the business meets all the H&S obligations.
Key Control
Incident and Hazard Registers
Monitoring Frequency
Bi-Annual
Policy
Health & Safety
Obligation
Provide training to staff as part of meeting H&S obligations.
Key Control
MoPro Module Complete
Monitoring Frequency
Annual
Employment Relations Act
Policy
Induction Policy
Obligation
https://www.employment.govt.nz/starting-employment/hiring/induction/
Key Control
Staff onboarding process
Monitoring Frequency
Annual
FAP Licence Requirement and/or Standard Condition
Policy
IT Systems and Security Policy
Obligation
Standard condition of licence
Key Control
Material Issues and Breaches Register
Monitoring Frequency
Ongoing
FAP Licence Requirement and/or Standard Condition
Policy
IT Systems and Security Policy
Obligation
Standard condition of licence
Key Control
MoPro Module Complete
Monitoring Frequency
Ongoing
FAP Licence Requirement and/or Standard Condition
Policy
IT Systems and Security Policy
Obligation
Standard condition of licence
Key Control
Review and test BCP
Monitoring Frequency
Ongoing
Code of Professional Conduct for Financial Advice Services
Policy
IT Systems and Security Policy
Obligation
Code Standard 5. PROTECT CLIENT INFORMATION
Key Control
Review CERT NZ guidance
Monitoring Frequency
Quarterly
AML/CFT Act
Class Exemption (AML CFT Notice 2018, Part 8)
Policy
KiwiSaver AML/CFT Policy
Obligation
Effective from 15 March 2021 – FAPs are exempt from the core provisions of the AML/CFT Act in relation to retirement schemes (including KiwiSaver)
Key Control
AML/CFT training
Monitoring Frequency
Annually
AML/CFT Act
Class Exemption (AML CFT Notice 2018, Part 8)
Policy
KiwiSaver AML/CFT Policy
Obligation
Effective from 15 March 2021 – FAPs are exempt from the core provisions of the AML/CFT Act in relation to retirement schemes (including KiwiSaver)
Key Control
KiwiSaver Provider agreements
Monitoring Frequency
Annually
AML/CFT Act
Class Exemption (AML CFT Notice 2018, Part 8)
Policy
KiwiSaver AML/CFT Policy
Obligation
Effective from 15 March 2021 – FAPs are exempt from the core provisions of the AML/CFT Act in relation to retirement schemes (including KiwiSaver)
Key Control
Client File reviews
Monitoring Frequency
Annually
Financial Markets Conduct Act 2013
Policy
Material Issues and Breaches Policy
Obligation
412 Licensee must report certain matters
(1) Every licensee must ensure that there are in place effective methods for—
(a) monitoring the licensee’s and every authorised body’s compliance with
the market services licensee obligations; and
(b) identifying material changes in circumstances.
Key Control
Directors training
Monitoring Frequency
Annual
Financial Markets Conduct Act 2013
Policy
Material Issues and Breaches Policy
Obligation
Section 410 amended (Meaning of material change of circumstances)
Key Control
Directors training
Monitoring Frequency
Annual
Financial Markets Conduct Act 2013
Policy
Material Issues and Breaches Policy
Obligation
411 Licensee must deliver reports to FMA
Every licensee must, at the prescribed times or on the occurrence of the prescribed events and otherwise in the prescribed manner, send to the FMA reports that contain the prescribed information.
Key Control
Material Issues and Breaches Register
Monitoring Frequency
Ongoing
Financial Markets Conduct Act 2013
Policy
Outsourcing Policy
Obligation
Licensing requirement – standard condition for Outsourcing
Key Control
Outsource agreement and checklist
Monitoring Frequency
Ongoing
FAP Licence Requirement and/or Standard Condition
Policy
Outsourcing Policy
Obligation
Licensing requirement
Key Control
Outsource agreement, DD and review
Monitoring Frequency
Annual
Privacy Act 2020
Policy
Privacy Policy
Obligation
The Privacy Act 2020 deals with the collection, storage and use of personal information about identifiable individuals and therefore principally affects Client marketing. Everyone in the organisation who handles personal information should have an understanding of the Information Privacy Principles and the objectives
Code Standard 5. PROTECT CLIENT INFORMATION
Key Control
MoPro Module Complete
Monitoring Frequency
Annually
Privacy Act 2020
Policy
Privacy Policy
Obligation
Assess the likelihood of serious harm being caused by a privacy breach.
Notify the Privacy Commission of a serious privacy breach.
Notify affected individuals or give public notice if there is a serious privacy breach.
Key Control
Material Issues and Breaches Register
Monitoring Frequency
Ongoing
Privacy Act 2020
Policy
Privacy Policy
Obligation
Key Control
Review Privacy Statements
Monitoring Frequency
Annual
Privacy Act 2020
Policy
Privacy Policy
Obligation
Appoint a Privacy Officer.
Comply with the information privacy principles.
Key Control
Breach Register
Monitoring Frequency
Annual
Privacy Act 2020
Policy
Privacy Policy
Obligation
The Privacy Act 2020 deals with the collection, storage and use of personal information about identifiable individuals and therefore principally affects Client marketing. Everyone in the organisation who handles personal information should have an understanding of the Information Privacy Principles and the objectives
Code Standard 5. PROTECT CLIENT INFORMATION
Key Control
MoPro Module Complete
Monitoring Frequency
Annual
Code of Professional Conduct for Financial Advice Services
Policy
Privacy Policy
Obligation
Code Standard 5
Key Control
Review records and record-keeping procedures
Monitoring Frequency
Bi-Annual
Code of Professional Conduct for Financial Advice Services
Policy
Product Selection Policy
Obligation
Competence, knowledge and skill, keep knowledge up to date
Key Control
Review Client Files
Monitoring Frequency
Bi-Annual
FMC General Licensing Requirement
Policy
Professional Indemnity Insurance Policy
Obligation
Good practice. Licensing obligation for most licence types.
Key Control
Confirm Annual Renewal & Cover
Monitoring Frequency
Annual
Code of Professional Conduct for Financial Advice Services
Policy
Record Keeping Policy
Obligation
Part 1, Ethical Behaviour, Conduct and Client Care
Code Standard 5, Protect Client information
Key Control
Review records and record keeping procedures
Monitoring Frequency
Annually
Privacy Act 2020
Policy
Record Keeping Policy
Obligation
Your business must ensure the information is protected against loss, misuse, or unauthorised disclosure.
Your business must not keep the information for any longer than it is needed for the purposes for which it was collected.
The information must not be disclosed except in certain situations. These include where the disclosure is directly related to the purpose for which the information was collected, where the source of the information is a publicly available publication, and where the disclosure is authorised by the individual concerned.
Where the information can be readily retrieved, your client is entitled to confirmation of whether the information is held, and to have access to it. There are exceptions, for example, where disclosure would prevent detection of a criminal offence, or would involve a breach of someone else’s privacy.
431O – Duty to make prescribed information available
Key Control
Review records and record-keeping procedures
Monitoring Frequency
Annual
Code of Professional Conduct for Financial Advice Services
Policy
Recruitment and Vetting Policy
Obligation
Part 2, Competence, Knowledge and Skill
Key Control
Staff onboarding process
Monitoring Frequency
Annual
Employment Relations Act
Policy
Recruitment and Vetting Policy
Obligation
https://www.employment.govt.nz/starting-employment/hiring/
Key Control
Completed and signed employment agreement
Monitoring Frequency
Annual
Code of Professional Conduct for Financial Advice Services
Policy
Replacement Business Policy
Obligation
Part 1 of the Code of Conduct sets out the minimum standards of ethical behaviour, conduct and client care.
Part 2 of the Code of Conduct sets out the minimum standards of competence, knowledge and skill.
431J • Duty to ensure client understands nature and scope of advice
431K • Duty to give priority to client’s interests
431L • Duty to exercise care, diligence, and skill
431M • Duty to comply with code of conduct
Key Control
Client file reviews
Monitoring Frequency
Annual
FMC General Licensing Requirement
Policy
Risk Management Policy
Obligation
Licensing requirements
Key Control
Risk Register
Monitoring Frequency
Annual
Code of Professional Conduct for Financial Advice Services
Policy
Staff and Supervision Policy
Obligation
Part 2, Competence, Knowledge and Skill
Key Control
MoPro Modules & Other Staff Training
Monitoring Frequency
Annual
Companies Act 1993
Policy
Staff and Supervision Policy
Obligation
Ensure we meet the directors duty including the solvency test, under the Companies Act 1993.Part 2, Competence, Knowledge and Skill
Key Control
Directors training
Monitoring Frequency
Annually
Code of Professional Conduct for Financial Advice Services
Policy
Training and Development Policy
Obligation
Part 2, Competence, Knowledge and Skill
(all code standards for part 2 apply)
Key Control
MoPro Module Complete
Monitoring Frequency
Ongoing
Policy
Vulnerable Clients
Obligation
Key Control
Complaints Register
Monitoring Frequency
Bi-Annual
Policy
Vulnerable Clients
Obligation
Part 1, Std 4 A person who gives financial advice must take reasonable steps to ensure that the client understands the financial advice
431J – Duty to ensure client understands nature and scope of advice
431K – Duty to give priority to clients’ interests
431L – Duty to exercise care diligence and skill
431M – Duty to comply with the code of conduct
P17. 4.6c. If the client is a vulnerable borrower.
P19. 5.122. Enquiries into substantial hardship.
P23. 6. If the guarantor is a vulnerable guarantor.
Further Guidance on page 27 and page 58 section 15.
Key Control
MoPro Module Complete
Monitoring Frequency
Annual
Protected Disclosures Act 2000
Policy
Whistleblower Policy
Obligation
The purpose of the Protected Disclosures Act (the Act) is to encourage people to report serious wrongdoing in their workplace by providing protection for employees who want to ‘blow the whistle’. This applies to public and private sector workplaces.
Key Control
MoPro Module Complete
Monitoring Frequency
Annual
Human Rights Act 1993
Policy
Employment, Ethics and Diversity Policy
Obligation
Employers must not discriminate based on sex, age, race, marital status, disability, sexual orientation, religion or political opinion. This applies to recruitment, promotion, remuneration and training.
Key Control
Staff onboarding process and employment agreements
Monitoring Frequency
Annual
Privacy Act 2020 – Credit Reporting Code
Policy
Privacy Policy
Obligation
Credit information must be collected, stored and used in accordance with the Credit Reporting Privacy Code.
Key Control
Review third-party contracts with credit reporters
Monitoring Frequency
Annual
Electronic Identity Verification Act 2012
Policy
Client Onboarding Policy
Obligation
When using RealMe or similar electronic verification systems, advisers must ensure appropriate consents are obtained and records are kept.
Key Control
Client file checklist includes ID verification method
Monitoring Frequency
Annual
Search and Surveillance Act 2012
Policy
Privacy Policy
Obligation
If compelled to provide client records to authorities, the business must follow legal process and document requests.
Key Control
Register of data access by external authorities
Monitoring Frequency
Ongoing
Financial Reporting Act 2013
Policy
Financial Management Policy
Obligation
Financial statements must be prepared in accordance with applicable accounting standards.
Key Control
Annual accounts prepared and reviewed by accountants
Monitoring Frequency
Annual
Credit Contracts and Consumer Finance Act 2003 (CCCFA)
Policy
Vulnerable Clients Policy
Obligation
Ensure clients are not placed in unaffordable debt. Consider substantial hardship and ensure responsible lending practices are followed.
Key Control
Affordability and vulnerability check in file notes
Monitoring Frequency
Annual
Contract and Commercial Law Act 2017
Policy
Advice Policy / Terms of Engagement
Obligation
Ensure all electronic communications and client agreements meet contractual requirements for validity and consent.
Key Control
Template Terms of Engagement reviewed and stored
Monitoring Frequency
Annual
Health Information Privacy Code 2020
Policy
Privacy Policy
Obligation
Applies to collection and handling of medical information, particularly relevant for Life & Health insurance clients. Must inform clients why data is collected and how it will be used.
Key Control
Privacy statement included in health insurance forms
Monitoring Frequency
Annual