ASIC Report 515 looked at KRIs for advice licensees to consider when monitoring and supervising Advisers. There were quite a number of key risk indicators mentioned. Without going through them all, consider the following that were mentioned in the “Adviser Profile” category:-
- Adverse complaints history in terms of both the number and value of complaints
- Adverse adviser audit outcomes
- High level of recorded incidents, issues and events, and breaches
- Poor training history (e.g. training not completed by due dates or failure rates)
- Identified conflicts of interest
- Customer signature irregularities
- Customer file integrity issues (e.g. unexplained additions, omissions, or variations to a customer file)
- Advisers working in the same office as an identified high-risk adviser
The advantage of having an online platform for monitoring and supervision of Advisers is that most, if not all this information is held on the platform. This is very different to having a few disparate databases or programs that need to be investigated making the information hard to find. Business Health’s RTC (Real Time Compliance) contains all this information on one platform, in real time (cloud based live data) and on an individual AR basis. RTC provides:-
- A Complaints Register on an individual AR basis that records client complaints and outcomes with the ability to provide collated information on the individual AR, as well as a collated view of the practice and the overall license.
- All file audits are conducted through the RTC platform meaning all adverse adviser audit outcomes are collected and stored.
- There is direct connectivity with the Incident Register (recorded incidents) with an automated email process to the appropriate manager in the Licensee.
- There is also a Breach Register to record potential breaches. The Complaint, Incident and Breach Registers are connected – Incidents can be escalated meaning information only has to be entered once and flows through seamlessly.
- Training history is recorded. Poor training history (e.g. training not completed by due dates or failure rates) is part of the information provided.
- A Conflicts of Interest Register is kept, again on an individual AR basis that can be updated by the AR themselves or by the Licensee. The register can be connected directly to the Audit process to document and warn of any potential conflicts.
- The Audit question set can include questions about customer signature irregularities or customer file integrity issues (e.g. unexplained additions, omissions or variations to a customer file). Data can be investigated for each of these questions to quickly understand if there is an issue for an individual AR, a practice, a location or indeed the Licensee.
- It is also very easy to see if an Adviser is working in the same office as an identified high-risk adviser, or in the same CAR or in the same geography.
RTC has a built-in Risk Assessment algorithm that can easily put all this information together (with other important criteria) to create a risk matrix. The Licensee can then decide what the systems and procedures are to manage those Advisers with a higher risk.
For your consideration,
Tony Stephens, Director
Business Health Pty Ltd
If you’d like to learn a little more about RTC you may contact Tony Stephens directly: firstname.lastname@example.org.