From the AIOFP. FSC WHITE PAPER – $25,000 ASIC FEE PROPOSAL

Hi, if you have not read our attached paper on Association objectives, structure and performance released in April 2026, please take the time to do so here. It will put the FSC White Paper into perspective on how the ‘FSC Fox has got into the Adviser coop’, the damage they have done to the Adviser Profession and what can be done about it.

As expected, this White Paper is a self-serving instrument to further the commercial interests of the dominant FSC faction within their membership [the Financial Institutions] but on this occasion there are benefits for the minority player – large Dealer Groups members.

If the Adviser community ever needed ample evidence on how the ‘battle lines’ are drawn in our Profession, this FSC White paper clearly sets it out. It should be noted that there are currently 1,843 AFSL active Licenses where 98.5% [1815] have less than 100 AR’s and around 30 groups have more than 100 AR’s or 1.5% of the total. You will appreciate the significance of these numbers later in this response.

What the Adviser community has to realise is the FSC is not a friend of the Adviser community, they are dominated and funded by the Financial Institutions and are brilliant at working behind the scenes to achieve their objectives in Canberra with their Treasury contacts both in the Bureaucracy and Ministerial offices.

There is absolutely no doubt that the FSC were behind the LIF, FASEA, Grandfathered revenue ban, difficult compliance obligations and secured the CSLR MIS amendments to exclude MIS from the Levy. They have been the brilliant ‘silent smiling assassin’ of the Adviser community during the 2014 – 2022 horror period which removed 50% of the Adviser population.

You may recall the famous Al Pacino Godfather movie quote, ‘keep your friends close but your enemies closer…’, FSC are accomplished exponents of this strategy. Ie the FPA/AFA cooperating with them to support former Minister O’Dywer to legislate the above Horror period legislation.

The FSC has been targeting the large Dealer Groups to become members over the recent years which unfortunately [for Advisers] gives FSC the credibility to inform Canberra that they also represent the Advice Profession and should be listened to. This is despite the Dealer Groups being a minority faction in their membership and on the FSC board, they have no real power, but it gives the FSC credibility to convince Canberra that they represent the Adviser Profession –a notion the Adviser Profession needs to dispel.

What has surprised us is the FSC giving such an insight into their strategic thinking. It certainly looks like they have given up on trying to recruit individual Advisers or smaller practices into their membership, only targeting the larger Dealer groups who may see themselves as being quasi Financial Institutions or just like the ‘FSC ego trip’ of sharing in the FSC success.

Unfortunately, the success of the FSC over the years has been to the direct and profound detriment of the Adviser community, that is the fundamental problem for Advisers.

The suggestion to charge every AFSL holding practice $25,000 pa ASIC levy [and a resultant reduction for individual Advisers] is playing right into the hands of their Dealer Group members wish list. Dealer Groups obviously want to discourage Advisers getting their own AFSL and they want to recruit those smaller practice Advisers who cannot afford to operate under the FSC preferred regime.

These new conditions will also be appealing to ASIC with less AFSL’s to monitor and an annual initial levy revenue stream of $46,075,000. [ie 1843 x $25,000]

Let’s also don’t forget the FSC is behind excluding MIS from the CSLR Levy which places another significant monetary obligation on AFSL’s to survive – it should be no surprise that all of FSC institutional members own and operate MIS. It can be argued the CSLR/MIS play has been a deliberate manoeuvre to financially force Advisers out of the market.

The dated Adviser ‘blame game’ is central to the FSC paper which is typical of an Association that has the stakeholders responsible for MIS product failures over the past decades as members. They are also careful to not upset ASIC with their role in product failure over the past 26 years.

ASIC were informed of the Shield/First Guardian[SFG] activities well before it failed but did not act. The 2011 Senate Inquiry into the 2009 TRIO fraud levelled the blame at Trustees, Custodians, Research Houses, Auditors, ASIC but as always, the Advisers were ultimately blamed as the other stakeholders ran for legal cover.

These findings are also mirrored in the SFG debacle where Trustees, Auditors, Research Houses and Advisers are being blamed, BUT due to the lack of accountability of these stakeholder’s behaviour in the past, nothing changes.

These ‘ground hog’ days just keep happening with this FSC Paper spinning the SFG blame onto the Adviser community with no mention of ASIC’s conduct and the profoundly flawed MIS process that allows poor products onto the market with only a pathetic ‘caveat emptor’ warning to Consumers.

This FSC paper must be a huge wakeup call to the 1815 AFSL with less than 100 authorised representatives that the FSC are hovering in case they fail to entice the Advisers to join their large Dealer Group members.

You may recall during the horror 2014 – 2022 legislative period intimidation and starvation was used to cull advisers; it is happening again.

The other piece to this elaborate strategic jigsaw are the retail platforms taking control of Adviser clients FUA where the Manager is also the Trustee – surprise surprise, all of these retail platforms are FSC members and you can bet that SMSF, White Labels, MDA and Managed Accounts will not be on the APL menu.

The FSC objectives are very clear, take control of distribution by controlling Advisers which then allows their Dealer members to take control of product by only offering retail platform conditions dominated by bland Institutionally owned fund managers, who are their members.

This outcome cannot be in the best interests of consumers or the majority of the Adviser Profession.

As requested, please read the attached document, it is time for the Adviser Profession to stand as one consolidated group to survive the forces acting against us whilst the sub 100 Adviser practices still dominate numbers.