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Thanks Mark, I have wasted some more time on the issue and concluded you are absolutely correct. But this retrospective change is interesting AFCA are currently having problems with it as shown by case 526729. "The lack of primary records provided by the complainant or the financial firm from 2004 has limited the financial firm’s ability to conduct a full and fair review of the advice. " This case was released in May 2019 so it is relatively recent. I am interested in what people think of the implications of this.