Transcript Slide 1
FOS reporting of systemic
issues and serious
misconduct
-ASIC’s perspective
Delia Rickard
Senior Executive Leader
Consumers, Advisors and Retail Investors
(and ACT Regional Commissioner)
ASIC
FOS reporting of systemic issues and serious misconduct
-ASIC’s perspective
The FOS obligation to report
‘systemic issues’ and ‘serious
misconduct’ to ASIC – an RG 139
requirement
2
How to spot a ‘systemic issue’ or ‘serious misconduct’?
FOS reporting of systemic issues and serious misconduct
-ASIC’s perspective
How to spot a ‘systemic issue’ or ‘serious misconduct’?
RG 139
reference
Key
features
Examples
Systemic issue
RG 139.121 – 139.125
Serious misconduct
RG 139. 126 – RG 139.128
Has implications beyond the
immediate actions and rights of
the parties to the
complaint/dispute
May be evident from a single
complaint
Includes:
deliberate or fraudulent
conduct
grossly negligent or
inefficient conduct
willful or flagrant breaches of
the relevant laws
Fraud
Inappropriate advice
resulting in significant client
losses
Persistent or deliberate
failure to have a properly
working IDR process
Persistent or deliberate
failure to properly co-operate
with the FOS process
poor disclosure/
communication (eg faulty
disclosure given to a class of
clients)
administrative/ technical/
computer error (eg wrongly
calculating fees and charges)
Improper interpretation or
application of standard terms
(eg applying an exclusion
wrongly across a class of
clients)
3
FOS reporting of systemic issues and serious misconduct
-ASIC’s perspective
• What do we expect FOS to do once
they have identified systemic issues
and serious misconduct reports?
• Three step process:
– Identify the issue,
– Refer to the relevant member, and
– Report to ASIC
4
FOS reporting of systemic issues and serious misconduct
-ASIC’s perspective
What we expect to see in FOS’
quarterly systemic issues
and serious misconduct reports
5
FOS reporting of systemic issues and serious misconduct
-ASIC’s perspective
What ASIC does when we get
these reports
6
FOS reporting of systemic issues and serious misconduct
-ASIC’s perspective
• Key steps ASIC would encourage you to take
to properly identify and address systemic
issues and serious misconduct:
– Have a system as part of your IDR process
to identify and record systemic issues (RG
165)
– Work with FOS to resolve the systemic
issue/serious misconduct
– Notify ASIC of any significant or likely
breach within 10 business days
7