Paraplanner's Daily Compliance Checklist for SOA Preparation

Client Information and Fact Finding

Before drafting the SOA, confirm that the client's personal details, financial situation, goals, and risk profile are accurately recorded. Check that the fact find is complete and signed. Errors or omissions at this stage can lead to unsuitable advice.

Best Interests Duty Documentation

For each recommendation, verify that the SOA clearly explains the reasoning, identifies alternatives considered, and shows why the recommended option best meets the client's needs. The safe harbour steps should be evidenced in the document, not just assumed.

Fee Disclosure

Check that all fees are clearly disclosed, including upfront costs, ongoing fees, commissions, and any exit fees. Confirm that the fee table is accurate, complete, and easy to understand. Compare the disclosed fees against the product disclosure statement and adviser agreement.

Regulatory References

Ensure that the SOA references the relevant regulatory obligations where appropriate, including s961B (best interests duty), s961G (appropriate advice), and any applicable ASIC regulatory guides. The document should demonstrate regulatory awareness without being overly technical.

Language and Clarity

Review the document for plain language. Avoid excessive jargon, boilerplate text, and overly complex explanations. The document should be readable by the client. If a section could apply to any client without changes, it may need more tailoring.

File Quality

Before finalising, confirm that the document is complete, all sections are present, and the file is properly named and saved. Check for broken links, missing pages, and formatting issues. A quality check before submission saves time in the review stage.

Pre-Drafting Compliance Checks

Before beginning the SOA drafting process, paraplanners should verify that the client file is complete and the advice scope is clear. Check that: the fact find or client information form is fully completed and signed, the client's objectives and goals are clearly documented, the adviser's strategy notes are comprehensive, and any product research or comparison data is current and complete. Starting the drafting process with incomplete information leads to rework and potential compliance gaps.

Also verify that the client's risk profile has been assessed and documented, that any existing products or strategies have been reviewed, and that the adviser has identified all relevant client circumstances (including spouse, dependants, insurance cover, and Centrelink entitlements). Incomplete client information is one of the most common compliance issues identified in file reviews.

Drafting Stage Compliance Checklist

During the drafting stage, paraplanners should check each section of the SOA for compliance. For the executive summary: does it accurately reflect the advice recommendations? For the basis of advice: is the client's situation clearly described and linked to the recommendations? For the recommendations section: are all products identified, with clear reasoning for each recommendation? For fees: are all costs disclosed including ongoing fees, establishment fees, and exit fees?

Additional drafting checks include: verifying that all required warnings are present (general advice warning if applicable, risk warnings, cooling-off rights), checking that the scope of advice is clearly defined and consistent throughout the document, confirming that any product replacements are adequately justified and disclosed, and ensuring that the document language is clear and appropriate for a retail client.

Final Review and Sign-Off Checklist

Before the SOA is provided to the client, the paraplanner should conduct a final compliance review. Check that: all client information is accurate and consistent throughout the document, all calculations are correct (fee projections, contribution amounts, insurance cover levels), all required signatures are obtained, the document formatting is professional and consistent, and the document is dated correctly.

Final review should also include: checking that the document version matches the client file, verifying that any supporting documents (PDSs, SOA warnings) are attached, confirming that the document is saved in the correct location with the appropriate naming convention, and ensuring the file is ready for the adviser's final review. A well-organised final review process reduces the risk of client-facing errors and compliance issues.

Frequently Asked Questions

Should paraplanners use paper or digital checklists?
Digital checklists are strongly recommended. They can be integrated with practice management software, provide automated compliance checks, maintain audit trails, and ensure consistency. Digital tools also facilitate reporting and monitoring of compliance performance.

How often should the compliance checklist be updated?
The checklist should be reviewed at least quarterly and updated whenever there are regulatory changes. The responsible manager should approve checklist changes and ensure all paraplanners are trained on updated requirements.

What is the most common compliance issue identified in checklists?
Incomplete or inaccurate client information is the most common issue, followed by inadequate disclosure of fees and insufficient justification for product recommendations. These issues are often identified during the pre-drafting stage and can be addressed before significant work is done.

Can AI assist with compliance checklists?
Yes. AI-powered compliance tools can automate many checklist items, including checking for disclosure completeness, verifying calculations, and flagging potential issues. However, human review remains essential for judgment-based compliance assessments.

Regulatory Context

Consumers evaluating advice documents benefit from knowing the recent timeline. Since FOFA took effect in 2013, advisers have owed a best interests duty and been barred from conflicted remuneration. The DBFO reforms, phased through 2024-25, removed the Fee Disclosure Statement and simplified ongoing fee consents while clarifying how advice fees can be deducted from super. Further change is queued: the Quality of Advice Review’s proposals for simpler SOAs and a new adviser class were progressing through draft Tranche 2 legislation as of March 2025.