DBFO reforms · Advice-record readiness

Are you DBFO-ready? Eight questions.

The Delivering Better Financial Outcomes (DBFO) reforms continue to reshape financial advice. The first tranche is in force; the second tranche, which includes replacing Statements of Advice with Client Advice Records and modernising the Best Interests Duty, remains under development and is not yet law. This scorecard checks where you stand against the advice-record and audit obligations that apply today. Answer in 60 seconds, see where you stand.

  • 01

    Have you mapped your ongoing fee arrangements to the new Section 5 Notice consent format?

    Corporations Act s962F

  • 02

    Can you produce, on 24 hours notice, a complete supervision trail for any SoA in the last 7 years?

    RG 175 + RG 105

  • 03

    Is the s961B seven-step safe harbour captured in line with every SoA (not in a separate compliance form)?

    Corporations Act s961B

  • 04

    Do you have an automated trigger for the RG 271 30-day complaint response clock the moment dissatisfaction is expressed?

    ASIC RG 271

  • 05

    Are all fact-find captures stored in a way that satisfies APP 11 reasonable steps?

    Privacy Act 1988 APP 11

  • 06

    Have you reviewed all fee deduction-from-superannuation arrangements against the DBFO ongoing-fee-consent rules?

    DBFO reforms

  • 07

    Is your replacement product reasoning captured against every recommendation (not just on request)?

    Corporations Act s947D

  • 08

    Is every fact-find, SoA, BID assessment, and revision tamper-evident and timestamped?

    RG 105 record-keeping

This scorecard is an indicative readiness signal, not legal or compliance advice. Specific obligations turn on the structure of your AFSL and the products you are authorised to advise on. Confirm with your licensee and legal counsel.