Have a question about adviser fees? Here’s where to find an answer.

Tranche 1 of the Quality of Advice Review reforms introduces amendments to the Corporations Act 2001 and the Superannuation Industry (Supervision) Act 1993 to:

  • clarify when a superannuation trustee can deduct advice fees from a member’s account, 
  • streamline consent processes for ongoing fee arrangements; and 
  • enable the provision of a mandatory industry form (not yet released) that can be used to manage fee arrangements across multiple accounts and account providers. 

We have updated our adviser service fee (ASF) consent forms in line with new legislative requirements, which take effect on 10 January 2025. These changes are a result of tranche 1 of the Quality of Advice Review reforms. 

 

For FirstChoice advisers, this means that from 10 January 2025, the new ASF consent form(s) must be used for all new arrangements and for all ongoing fee renewals with an anniversary date on or after 10 January 2025. The new forms will be available on the website from 9 January 2025.  

 

For FirstWrap advisers, this means that from 10 January 2025, the updated ongoing consent form must be used for all new arrangements and for all renewals with an anniversary date on or after 10 January 2025. The new form will be available on the FirstWrap platform from 9 January 2025. 

 

For CFS Edge advisers, this means that from 10 January 2025, the digital experience and pre-populated application forms will be updated to be compliant with the new legislative requirements. Later in January 2025, we’re introducing pre-populated forms for ASF charged after onboarding. In the meantime, for offline client consent post onboarding, the new ASF consent form(s) must be used for all new arrangements and for all ongoing fee renewals with an anniversary date on or after 10 January 2025. The new forms will be available on the website.

  • The requirement to provide a Fee Disclosure Statement (FDS) will be removed 
  • A description of services will be required for super/pension ongoing fee arrangements  
  • The ‘anniversary date’ (also known as the ‘reference date’) is no longer static and has been replaced with a ‘reference date’, which can be set to any date up to a maximum of 12 months after the arrangement was entered into, or for existing arrangements, the previous reference date; and 
  • The fee renewal window has increased to 210 days, being 60 days before the reference date and 150 days after. 

The new rules apply to all new arrangements for all fee types (ongoing, fixed term and one-off) from 10 January 2025. For existing ongoing arrangements, a transition periods applies. This is described in detail below. 

Scenario 1: Old regulations apply for all existing arrangements with an anniversary date on or before 9 January 2025
Scenario 2: Modified transition renewal window for those with an anniversary date on or shortly after 10 January 2025
Scenario 3: Full renewal window anniversary date on or after 10 March 2025
Scenario 1: Old regulations apply for all existing arrangements with an anniversary date on or before 9 January 2025

FDS will still need to be provided. 

 

Old fee renewal window of 120 days applies. 

 

Old ASF consent form can be used even if handed in after 10 January 2025. 

 

Next renewal in 2026 will need to use the new form. 

Scenario 2: Modified transition renewal window for those with an anniversary date on or shortly after 10 January 2025

New ASF consent form will be required to be used. 

 

New fee consent can be signed from 10 January until 150 days after the anniversary date. 

Scenario 3: Full renewal window anniversary date on or after 10 March 2025

If the anniversary date is after the 10 March 2025, the new consent rules apply. 

 

New ASF consent form must be used. 

Scenario 1: Old regulations apply for all existing arrangements with an anniversary date on or before 9 January 2025

Example: Existing anniversary date is the 9 January 2025. A renewal must be submitted within the existing 120-day window. 

 

The next renewal in 2026 will be under the new rules. 

Scenario 2: Modified transition renewal window for those with an anniversary date on or shortly after 10 January 2025

Example: Existing anniversary date is 20 January. The arrangement remains valid with a renewal required (on the updated form) to be submitted between 10 January 2025 and 19 June 2025. 

 

This gives a modified renewal window of 10 days prior and 150 days after. 

Scenario 3: Full renewal window anniversary date on or after 10 March 2025

Example: Existing anniversary date is 1 June 2025. The arrangement remains valid with a renewal required (on the updated form) to be submitted between 2 April 2025 and 29 October 2025. 

 

This gives the new full renewal window of 60 days prior and 150 days after. 

No, existing fixed term fees will be unaffected. At the completion of the fixed term fee arrangement, any new fixed term arrangement will need to be use the updated ASF consent forms. 

Under the old legislation, the anniversary date for ongoing fee arrangements was fixed at 12 months from when the adviser and client entered into the arrangement. This date started the 120-day renewal period.  

 

The reference date operates very similarly to the current anniversary date however, it has increased flexibility. Like the anniversary date, the reference date initiates the renewal process for ongoing arrangements. For new arrangements, it can be set to any date up to a maximum of 12 months from the date the arrangement was entered into (the current anniversary date).  

 

To further increase flexibility, the renewal window has also changed to allow consent to be obtained anytime between 60 days before and 150 days after the reference date.  

 

At each renewal, a new reference date must be specified and can be up to a maximum of 12 months from the current reference date. 

We are maintaining our current suite of ASF consent forms. We will maintain separate forms per fee type (fixed term, one-off and ongoing) and account. We have updated these to comply with the new legislative requirements. 

 

When an industry form is released, we will align to this process to remove duplication and allow for a consolidated form per client across all products, accounts and account providers. 

New forms will only be accepted from 10 January 2025. 

 

FirstChoice 

CFS Edge 

FirstWrap 

  • ASF ongoing consent form will be available on the platform from 9 January 2025

 

    The new fee consent forms will be available on the night of 9 January 2025, including all digital journeys.  

    Any forms that are in progress will need to be completed prior to the night of the 9 January 2025 and submitted. All incomplete in-flight digital consent journeys will need to be restarted as of 10 January 2025. 

    Depending on the contents of the form and the transitional arrangements, we would look to use the industry standard form as provided. This will help to reduce the duplication in adviser service fee forms. 

    We’re only able to deduct advice fees if they relate to personal advice about the interest in the fund. We have a high-level checklist to indicate the services that will be provided, which is selected during the digital experience or when completing the form. 

    You can elect to switch between fee arrangement types – if switching before the current fee arrangement ends, you need to choose if you wish to terminate the existing arrangement or wait for the arrangement to end. Once the current fee arrangement has ended, you can submit a request for the new fee arrangement. 

    FirstChoice's newly enhanced client onboarding experience, powered by Elemnta, integrates with Midwinter, Morningstar AdviserLogic, and Xplan planning software. You can reduce FirstChoice account setup time by up to 80% when your data comes automatically with you. This provides a simplified and integrated flow to set up ASFs within the application journey. You can find more information here

     

    CFS Edge is integrated with a number of leading advice software solutions and we’re continuing to expand our range of integration partners. CFS Edge provides API based integration to help streamline the client onboarding process (and avoiding re-keying) and also EPI (v4.3) data feeds to push detailed client portfolio information out to advice solutions. Existing integration partners include: Iress (Xplan), AdviserLogic, MyProsperity, and PlatformPlus. In January 2025, we’re also extending EPI integration partners to include BGL, Class, Plutosoft, and Investment Link (Midwinter). We're committed to working with advisers to drive efficiency through integration to enable you to spend more time servicing your clients.

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    Avanteos Investments Limited ABN 20 096 259 979, AFS Licence 245531 (AIL) is the trustee of the Colonial First State FirstChoice Superannuation Trust ABN 26 458 298 557 and issuer of FirstChoice range of super and pension products. AIL is also the trustee of the Avanteos Superannuation Trust ABN 38 876 896 681 and issuer of FirstWrap Plus Super and Pension and FirstWrap Super and Pension (closed to new investors 28 March 2011). Colonial First State Investments Limited ABN 98 002 348 352, AFSL 232468 (CFSIL) is the responsible entity and issuer of products made available under FirstChoice Investments and FirstChoice Wholesale Investments. CFSIL is also the Investor Directed Portfolio Service (IDPS) operator, administrator and custodian of the Avanteos Wrap Account Service and issuer of products which includes the FirstWrap Plus Investments and FirstWrap Investments (closed to new investors 28 March 2011). Colonial First State (CFS) is Superannuation and Investments HoldCo Pty Limited ABN 64 644 660 882 and its subsidiaries which include AIL. This document is based on current requirements and laws as at 1 November 2023. While all care has been taken in the preparation of this document (using sources believed to be reliable and accurate), to the extent permitted by law, no person including AIL or CFSIL, nor any related parties, their employees or directors, accept responsibility for loss suffered by anyone from reliance on this information. This document provides general information for the adviser only and is not to be handed to any investor. It doesn‘t take into account anyone’s individual objectives, financial situation, needs or tax circumstances. You should read the relevant Product Disclosure Statement (PDS), Investor Directed Portfolio Service Guide (IDPS Guide) and Financial Services Guide (FSG) before making any recommendations to a client. The FirstChoice PDSs and the FSG can be obtained from www.cfs.com.au or by calling us on 13 18 36 and FirstWrap PDSs, FSGs and IDPS Guides can be obtained from www.firstwrap.com.au or by calling us on 1300 769 619.