The answer depends on the nature of actions the staff member takes and the services provided. If the staff member provides advice, then they will need to be an RFA or AFA as appropriate.

However, the provision of information only about a financial product, in the absence of any recommendation or opinion about that product, is not “financial advice”. Whether a staff member provides information only, or something more than that, is likely to be construed relatively narrowly.

Specific examples are difficult to provide but you can consider the following contrasting situations:

• “There is a thirteen week wait period before the benefit under your policy will be paid”

This is providing information only, not financial advice
 

• “You can reduce your premium by reducing the level of your cover.”

This is providing information only, not financial advice.
 

• “I recommend you reduce your life cover to $50,000 to reduce your premium.”

This is providing financial advice.
 

• "You should remain with company A as it is better than company B.”

This is providing financial advice.

There is a fine line between giving advice and providing information. If a client believes on reasonable grounds that advice is being given, then it is likely that what your staff member says will be classified as providing financial advice. Therefore, we advise caution.

That depends on whether they provide advice, a financial planning service (or perform an investment transaction). If so, they need to be an RFA or AFA as appropriate.

Please see the comment above about the provision of factual information only.

That depends on whether they provide advice or a financial planning service (plus potentially an investment transaction) - see definitions below. If so, they need to be an RFA or AFA as appropriate.

Please see the comment above about the provision of factual information only