Wholesale Investor Advice

A Statement of Advice (SoA) is a formal document that financial advisers must provide to retail clients when giving personal advice. It's prescribed by the Corporations Act and must include:

• The advice itself and the basis on which it's given
• Your relevant personal circumstances as understood by the adviser
• Information about fees, commissions, and other costs
• Details of any associations or relationships that might influence the advice
• Warnings if the advice is based on incomplete or inaccurate information

An SoA can be a substantial document — often 20–60+ pages for comprehensive advice. This thoroughness serves an important protective function, but it also means preparation takes time and creates cost. For a simple portfolio adjustment or tactical decision, the SoA process can take longer than the market opportunity it addresses.

For wholesale clients: The SoA requirement is waived. Advice is instead documented through file notes, correspondence, and implementation records. The advice still happens — the formal packaging changes.

For retail clients, advisers must follow prescribed "safe harbour" steps to demonstrate they've acted in your best interests. This includes investigating your circumstances, identifying appropriate products, and documenting the basis for recommendations.

For wholesale clients, this statutory duty doesn't apply — but common law duties of care and fiduciary obligations still exist. The difference is the mechanism of proof, not the absence of all duty.

The Australian Financial Complaints Authority (AFCA) generally doesn't hear complaints from wholesale clients. This is one of the most significant practical differences.

What remains available:

• Internal Dispute Resolution (all licensees must have this)
• Civil litigation for breach of contract, negligence, or misleading conduct
• Complaints to ASIC
• Professional body complaints

These avenues exist but are costlier and slower than AFCA. This is a genuine trade-off that wholesale clients should understand.

(See "What is a Statement of Advice?" above for what an SoA contains and why it matters.)

There are other situations where an SoA isn't required, even for retail clients:

• Small contributions: Ongoing contributions to existing investments up to $15,000 (Reg 7.7.10AA)
• Record of Advice: Subsequent advice to existing clients where circumstances haven't materially changed
• Time-critical advice: Where the client expressly instructs to proceed urgently
• General advice: Advice that doesn't consider your personal circumstances

These exceptions are about documentation efficiency, not about reducing the quality or appropriateness of advice.

Because we service both retail and wholesale clients, our internal standards, training, and governance are aligned to retail advice requirements. We don't operate a two-tier system where wholesale clients receive reduced care.

Our advisers maintain the same professional approach regardless of client classification. The difference is in documentation, not in conduct.

Wholesale treatment is typically used selectively, not universally. Common situations include:

• Portfolio adjustments and rebalancing
• Investment substitutions within an existing strategy
• Tactical decisions where timing is relevant
• Discrete strategy execution
• Ongoing management within established parameters

A client may receive wholesale treatment for certain investments while retail protections apply to their superannuation, insurance, or other matters.

Wholesale treatment is not:

• A way to avoid accountability
• A signal that we're taking less care
• An excuse for poor communication
• A way to cut corners

It is simply a recognition that clients who meet certain thresholds — and who engage with us across a broad relationship — don't always need every interaction processed through formal documentation designed for different circumstances.