The SMSF Association has proposed that advisers with 10 or more years of experience in the last 12 years be given the option of demonstrating that they have the necessary core competencies to continue to provide advice.
The organisation said the bipartisan support for a 10-year adviser experience pathway did not meet the “original policy intent of enhancing professional standards”.
SMSF Association chief executive, John Maroney, wrote in his submission: “Years of service or the number of years on a register alone are not an appropriate measure of skill, knowledge, or capability. An alternative model is needed to allow experienced advisers to have their competencies assessed or allow education providers to use existing recognition of prior learning (RPL) frameworks.”
He recommended that advisers on the Financial Advisers Register (FAR) with requisite experience of at least 10 years in the 12 years prior to 1 January 2019, be given the opportunity to apply to have their competencies assessed by a tertiary education provider.
“RPL should be available to be applied by the education providers consistently for all industry participants, regardless of their pathway, and in line with established, strict standards and processes that apply within the tertiary education sector,” he said.
“Consideration should be given to previous education, including those with relevant degrees and relevant professional association certification.”
He said the current RPL framework ‘shoehorned’ all industry participants into a single cohort.
“The industry has a number of different types of ‘advisers’, including those who provide limited advice service, such as risk, superannuation, self-managed superannuation, or stock broking,” he said.
“We strongly encourage the Government to work with industry and the professional associations to develop an appropriate framework that meets the underlying policy intent.
“We support the model proposed by the Financial Planning Association (FPA), acknowledging the possible addition of SMSF Advice as a separate and distinct individual competence and that, as proposed, it would apply to advisers providing full financial advice services.”
Maroney said those with international degrees assessed by the Financial Adviser Standards and Ethics Authority (FASEA) should have the opportunity to elect to complete their education pathway under the pathway approved under FASEA or seek RPL from an education provider.
Whilst the organisation said it encouraged further education and specialisation, it did not support the Professional Year (PY) standard to require an additional graduate certificate or diploma level specialisation.
“Whilst we support measures that require or encourage specialisation, the PY program is not the appropriate point in time,” he said.
He said the SMSF Association would support any measure that sought to raise education standards for self-managed super funds (SMSFs).
“Raising of education standards of SMSF advisers will increase their knowledge relating to specific and complex legislation. It would also discourage advisers who wish to give SMSF advice but have not undertaken specialist SMSF training,” Maroney said.