SMSF licensing for accountants Is this the land of plenty?

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1 SMSF licensing for accountants Is this the land of plenty? With the licensing exemption for accountants providing SMSF advice due to be removed at the end of the 2016 financial year, accounting practices around the country are considering their options. So what s really involved in gaining an authority or your own license? What are the alternatives? And how significant is the opportunity? Since 2004, CPA, ICAA and IPA members have been able to provide advice on establishing SMSFs without either obtaining an Australian Financial Services Licence (AFSL) or gaining an authority from an existing AFSL-holder. That s set to change on 30 June 2016, when the exemption will be removed and a new licensing regime introduced. This is a watershed moment for the accounting profession. Currently, accountants are exempt from the exacting of the AFSL regime, including the requirement to ensure that employees are competent, qualified and adequately trained, the need for adequate dispute resolution mechanisms, and the need for ongoing training and compliance. Meeting those and acquiring a license can be both expensive and time-consuming, often requiring practices to re-engineer their business models from the ground up. So while two years might seem ample to prepare for the new regime, it s important for accounting firms to start considering how they will respond. Those who act now have the opportunity to gain a significant competitive advantage by creating a broader and more attractive advice offering targeted towards high-value clients. The options So how should accountants prepare for the new regime? There are four main options, each with its pros and cons. Option Pros Cons 1. Enter into a referral agreement with a licensed advisory group holding an AFSL 2. Become an Authorised Representative of an AFSLholder with a limited authority to provide class of product advice only Simplicity The potential for some additional revenue without The opportunity to continue to provide general advice to your SMSF clients The potential for some additional revenue without Limited revenue opportunities Limited opportunities to tap into a growing SMSF market No or limited opportunity to create a higher value advice offering Potential loss of clients interested in SMSFs Additional training, administrative and compliance Some additional expense 1

2 Option Pros Cons 3. Become an Authorised Representative of an AFSLholder with full authority to advise on SMSFs and other investment matters A somewhat broader and more attractive advice offering The opportunity to partner with an AFSL holder whose philosophy and client service model are aligned with your own The potential for increased additional revenue with more A comprehensive advice offering An opportunity to take full advantage of the fast-growing SMSF segment The potential to harness the infrastructure and skills of a specialist advice business Limited ability to access a broader advice market directly Leverage the services of your preferred AFSL provider Additional training, administrative and compliance Considerable expenses, including compliance expenses and private indemnity insurance Your business is likely to be subject to the AFSL holder s sales targets and objectives 4. Obtain your own limited AFSL The potential for significant additional revenue A somewhat broader and more attractive advice offering An opportunity to take full advantage of the fast-growing SMSF segment Far-reaching and exacting compliance Significant additional expense for both licensing and advice services Additional administrative and risk management, with significant costs The option you choose will depend on your view of the growth potential of the SMSF market and the style of service you would like to be able to offer your clients: providing simple class of product advice under a Limited Authority; providing actual advice yourself via a Full Authority; or going all the way and by obtaining your own AFSL. Remember your AFSL holder will determine the extent of your focus on and involvement with the client, so it s essential to choose carefully. But it s also important to understand the practical realities of obtaining and maintaining a license. Even meeting the for a limited AFSL can be onerous, potentially distracting principals from the core business of building strong client relationships and providing high-value advice. Becoming licensed what s really involved ASIC Release 179 makes it clear that accountants seeking a limited AFSL will in time (the exempt licensee status will be repealed on 1 July 2019), need to meet the same as a full licensee, providing comprehensive written proof that the business can operate an AFSL. Among other things, they need to demonstrate that: the Responsible Manager has appropriate qualifications to operate the license (not simply a practicing certificate); the business meets the compliance of the Corporations Act; and advisers operating under the license are RG 146 compliant. 2

3 Then there is the expense. After factoring in the costs of SMSF accreditation courses, licensing fees, professional indemnity insurance, compliance services, training, coaching and ongoing professional development, a Limited Authority is likely to cost approximately 5,000 $6,000k pa, while a Full Authority may cost around $30,000 pa and a full AFSL up to $50,000 plus a year. That s without considering time invested in ongoing professional development, updating systems for full compliance, and carrying out audits and technical testing. Finally, while many firms may prefer just to hold a Limited Authority, they must also consider the practicalities of how they should refer their clients for any advice need. To ensure the accountant avoids any possibility of additional liabilities any referral should logically be made to their respective AFSL holder and not to any other financial planning business licensed or another AFSL holder. While they themselves may have provided sound class of product and strategic advice they may be held accountable for any issues arising from advice, given to the external adviser even extending to legal action. Partnering with a full AFSL holder The advantage of this approach is that it not only fulfils the new licensing, it also enables you to leverage the skills and infrastructure of a proven advice business. By selecting the right partner, you can benefit from ongoing support with a range of related activities, potentially including: SMSF licensing and business services Training Monitoring and supervision Dispute resolution Managing conflicts Risk management systems Written service and compliance procedures Approved compensation arrangements Yearly file audits Compliant advice documentation Advice specific obligations Wealth and Advice services A referral program for ongoing income Strategic wealth advice Insurance Property services Lending and finance Operational support Marketing and business development Client collateral and events Client profiling and diagnostics Business coaching As a result, the right partner can help you create a more profitable and sustainable business by establishing a compelling value proposition for one of the fastest growing wealth segments in Australia today. The wrong partner, however, may place undue pressure on your business for example, favouring restricted product and service offerings in their Approved Product List, issuing agreements with unnecessary sales and revenue targets, and insisting you work within a very limited advice offering. The opportunity The scale of the opportunity offered by the SMSF segment should not be underestimated. As at December 2013, there were more than 522,000 SMSFs managing over $543 billion in assets around 30% of Australia s super assets, more than any other sector. The ongoing growth of the sector is underpinned by government legislation and increasing client demand for control and flexibility. Around 65% of SMSFs are in the accumulation phase, while the age of new SMSF members is falling. In summary, the SMSF segment is a growth industry that all accountants should aim to be involved in. 3

4 By partnering with an established advice business to create a professional SMSF offering, accounting practices can generate an ongoing income stream with significant growth potential, enhancing the capital value of the business. They can also access new generations of clients as the SMSF market continues to expand. And they can diversify away from increasingly commoditised compliance services by moving to higher value advice offerings, underpinning sustainable value creation. Case study The value of establishing an integrated wealth and SMSF advice offering To illustrate the potential value of a comprehensive wealth and SMSF offering, let s consider a hypothetical case study based on our real-life experiences working with accounting practices. Smith & Partners is an accounting firm currently servicing 50 SMSF clients. In preparation for the end of the accountants licensing exemption, they enter into partnership with a licensed financial planning business with a Limited Authority. That allows them to create a compelling, integrated wealth and SMSF advice offering. But what is the financial outcome for their business? The outcome We ll assume that, as a result of their new partnership, Smith & Partners successfully maintain an ongoing client base of 50 SMSF clients. They also attract an average of two new advice clients a month, some of whom opt for a full-service advice offering, while others require more limited transactional services, such as insurance, finance or property services: Service Client take up Initial income Ongoing income SMSF services 50 clients Deed upgrades 50% $22,500 $ Advice 40% $28,000 $ Insurance 40% $21,000 $ Investment management 40% $20,000 $20,000 Accounting 100% $25,000 Wealth services 2 new clients a month Financial planning (combination of simple and complex plans) 100% $24,000 $10,530 Insurance 50% $13,500 Nil in year 1 Finance 40% $5,200 Nil share Property 10% $6,750 Nil Investment 100% Nil $6,880 Total $140,900 $17,410 On these assumptions, Smith & Partners could earn a total of $665,451 in additional wealth related revenue over the first five years of the partnership (excluding the SMSF revenue). Assuming a valuation multiple of 2.5 times recurring revenue, they could also increase the capital value of the business by more than $376,000,with the potential for further growth in the future.* Your critical decision: selecting the right partner For this approach to be successful, it s essential to select the right advice partner. Remember, when an accountant becomes an Authorised Representative of an AFSL holder, they are legally required to 4

5 refer all clients to that organisation for any financial advice they may need, regardless of the circumstances. So it s essential to choose an AFSL holder whose business model and client service philosophy reflect your own values, rather than an organisation that simply wants to sell product. We suggest aligning your practice with a genuine partner who will collaborate with you to enhance the value of your business and your client relationships. At a minimum, they should provide: Specialist SMSF advice documentation and technical support State-of-the-art SMSF administration and auditing services Relevant business coaching to help you define the right strategic services for your practice and your clients High quality, non-aligned wealth and advice services for your clients Be establishing a partnership on these terms, you can create a fully integrated wealth and advice service and a significant value driver for your client relationships and overall business results. Find out more by contacting Unison Financial Group Pty Ltd. George Haramis is the Managing Director of Unison Financial Group Pty Ltd (Unison Wealth Management Pty Ltd AFSL ), a specialist and integrated Wealth, Advisory and SMSF (advice.& licensing) business. George can be contacted at or by calling

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