Why record-keeping matters
Record-keeping isn't a back-office chore, it's the mechanism that lets an adviser demonstrate the steps they took were reasonable at the time. AFCA disputes, internal compliance reviews, ASIC surveillance, and licensee oversight all start by asking for the file. A weak file forces the adviser to argue from memory; a strong file lets the documents speak.
The advice file is the artefact of the decision. If it isn't in the file, the decision happened in your head, not in evidence.
What an advice file holds
- The fact-find / client questionnaire and supporting documents
- The Statement of Advice (or Record of Advice for an update)
- Any product research and the rationale for the recommendation
- The PDS and TMD versions relied on at the date of advice
- Any conflicts disclosed and how they were managed
- The fee disclosure / FDS / consent records (under the OFC reforms)
- Email correspondence and meeting notes that influenced the advice
- Implementation records, applications submitted, confirmations received
- Annual review notes and any revised SOAs
Retention periods
The Corporations Act and regulations require advice records to be kept for at least 7 years after the advice is provided. Some related records, AFSL financial records, FDS-related records, complaints records, AML records, have their own retention rules that can run longer.
“Kept” means accessible and reproducible. A PDF that sits on a former staff member's laptop isn't kept; a PDF in a system the practice still has access to is.
PDS and TMD versions in the file
Two practical rules:
- Reference the version, not the product.A file note that says “XYZ Super PDS” without an effective date is a maintenance burden for future you. “XYZ Super PDS, effective 12 March 2024” is the same effort and survives an audit.
- Make the version reproducible. Either save the actual PDF into the file, or link to a source that reliably holds the archived version. Issuer websites periodically wipe earlier PDS versions, so depending on the issuer source alone is not enough.
How FundFetch helps. The archive view holds prior PDS / TMD versions and is intended specifically as the re-checkable reference the file needs. Cite the FundFetch archive link as a backstop to the issuer source.
Habits that survive a review
- One file index per client, kept up to date as work happens
- PDS / TMD references captured at the moment of advice, not later
- Saved copies of relied-on documents, not just URLs
- A weekly “is the file complete?” check, not a quarterly panic
- Backups that include both the SOA and its supporting research