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100% correct. In discussing this issue with a former Employer Representative for the TWU Super fund (until 2007), she was stunned to learn how Intra-fund remuneration paid to advisers since 2013, had flown under the radar, primarily benefiting Industry super fund market share.

When this former Trustee read the ASIC website about Intra-Fund, her immediate response was that those Industry Fund employees are not really giving advice, but simply acting as paid marketing representatives, but without having to comply most of the FOFA red-tape.

It was clear to this former Industry Super Fund Trustee that “intra-fund advice” was effectively no different to the AMP “fees for no service” scenario as outlined in the Haynes Royal Commission.

It was explained to me like this: a trailing commission is a fixed amount that comes in on a regular basis post sale without it being tied to an intent of service delivery to an equivalent value. The only variation with the “intra-fund advice” seems to be that an advisory service may be called on by some on an ad hoc basis. Superficially it would appear that there is no administrative link between cost of service delivery and the amount charged. Normally admin fees have to be justified against actual services. Intra-Fund is simply ongoing trail fees, without the red-tape, & should be banned.