COTA Australia does not support all the proposals made.
We thank the Reviewer for consulting on her proposals for reform and appreciate the effort taken to holistically consider the issues and potential solutions contained within the broad suite of proposals.
COTA has commented on four areas of the proposals:
- Superannuation – recommendations regarding intra-fund advice and advice fees in superannuation (Proposals 5 & 6).
- Disclosure – recommendations around disclosure
- What should be regulated – recommendations regarding scope of personal advice and the removal of general advice protections (Proposals 9 & 10).
- How should it be regulated – recommendations around to replace best interest test with a good advice test.
In the final report of the review, COTA would welcome the greater use of cameos. The interaction between the recommendations is such that only when they are applied in practice does the true impact of the proposals come to light.