NIBA / Professionalism
Have Your Say: Targeted Implementation Feedback NIBA is seeking more detailed input on the implementation of three recommendations in particular. For each, we have set out NIBA’s position and specific questions to guide your response. These are the areas where your practical experience is most needed to get the implementation details right.
4.1 Recommendation 3: Extended Remuneration Disclosure THE RECOMMENDATION Support (6 recommendations): Recommendations 3, 6, 8, 11, 12, and 14 — Section 6.1 of the Code should oblige signatories to provide all individual and small business clients with remuneration disclosure regardless of the type of insurance product. NIBA’s Position: NIBA supports the principle of extending remuneration disclosure. Transparent remuneration disclosure helps clients understand the costs of their broking services and make informed decisions. Questions: 6. What specific information should the extended disclosure contain? 7. Where should this disclosure appear in client documentation, and at what point in the client relationship? 8. What timeframe would be needed to implement extended disclosure requirements? 9. Are there current practices that work well and could inform implementation? 10. Extending remuneration disclosure requires determining which clients should receive it. Various definitions exist across the regulatory landscape — the Corporations Act ‘retail client’ definition and wholesale tests, AFCA’s small business definition rules, and the Code’s existing scope of ‘individuals and small businesses.’ Each has different practical implications. What definition or approach should the Code use to determine which clients receive extended remuneration disclosure, and why? 11. NIBA has published guidance on disclosure practices in strata insurance, which will be incorporated into the revised Code. Are there other market segments or business structures where tailored guidance on remuneration disclosure or conflict management would help brokers meet client expectations?
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