RG 90 — ASIC Example SOA for Scaled Advice

What ASIC's example Statement of Advice shows about clear, scoped advice

What Is RG 90?

Regulatory Guide 90 (RG 90) — issued 7 December 2017 — is ASIC's example Statement of Advice for scaled advice for a new client. It was built with industry consultation as a communication tool, not a template to copy. The example covers personal insurance advice where the scope is deliberately narrow, and walks through how sections 947B, 947C and 947D of the Corporations Act apply in practice.

The guide runs to about 53 pages including commentary. Section B sets out the legislative requirements for SOAs, Section C explains design choices — why the table of contents is included, why fees are shown in dollars, why alternatives and risks are addressed up front. ASIC's view is that style, length and layout will vary with complexity, but the principles of clear, concise and effective disclosure do not change.

Why Scaled Advice Matters for Consumers

Scaled or limited-scope advice is personal advice limited to one topic — for example, insurance only, not super, investments and retirement together. It is cheaper and faster than comprehensive advice, and under the DBFO reforms the government wants more of it to improve affordability. But limited scope does not mean limited duty.

Your adviser must still act in your best interests (s961B), give appropriate advice (s961G), and prioritise your interests where there is a conflict (s961J). The scope must be agreed with you in writing, usually in the Financial Services Guide or a scope document, and the adviser must warn you if there are issues outside scope that you should consider. If they spot an underinsurance gap plus a super problem but you only asked about insurance, they must at least flag the super issue.

What the Example SOA Gets Right

RG 90 emphasises five practical features consumers can look for. First, a table of contents — ASIC considers it particularly useful where an SOA runs beyond about 10 pages. Second, a concise summary of advice and why it meets your goals, not buried on page 30. Third, personal circumstances recorded accurately with a clear link from each fact to each recommendation.

Fourth, dollar-figure disclosure of fees, commissions and ongoing costs, plus explanation of alternatives considered including a no-action option. Fifth, warnings about risks, replacement-product consequences under s947D where relevant, cooling-off rights, and complaints contacts for the licensee and AFCA. The example also models plain language — short sentences, defined jargon, and a clear statement of scope boundaries.

How to Use RG 90 to Check Your Document

Compare your SOA, ROA or CAR against this RG 90 checklist: is the scope stated on page one and does it match what you agreed? Are your details — age, dependants, income, debts, health, existing cover — correct? Does each recommendation have a why that references your objectives? Are fees, commissions and the cost of insurance over 1, 3 and 5 years shown in dollars?

Check for missing pieces that ASIC calls out: no discussion of alternatives, no risk section, no explanation of why a product was retained versus replaced, no statement about information gaps where you declined to provide data. Where advice recommends replacing a policy, s947D requires disclosure of lost benefits, new waiting periods, and fee differences. If any element is absent, ask your adviser for an amended document before you sign.

RG 90, RG 175 and INFO 267 Together

Think of the three as a set. RG 175 states the conduct and disclosure rules for financial product advisers. RG 90 shows one compliant application for scaled insurance advice. INFO 267 provides shorter plain-English examples of how disclosure can be done well. AdviserCheck encodes all three — RG 175 content standards, RG 90 clarity patterns, and INFO 267 good-practice cues — into its six-layer checks for completeness, best interests, contradictions, suitability, language clarity, and fees and conflicts.

ASIC has not reissued RG 90 since 2017, but its principles remain current and are referenced in RG 175 updates through the DBFO reforms. Where DBFO changes documentation — for example Client Advice Records and FSG website disclosure under INFO 291 — the same clarity test applies: can an ordinary consumer understand what was recommended, why, at what cost, and with what risks?

Frequently Asked Questions

Is RG 90 legally binding?
No. Like RG 175, it is ASIC guidance on how the law should be applied. Courts give it significant weight, and following it is strong evidence of compliance, but the legal obligations sit in the Corporations Act.

Does scaled advice mean lower protection?
No. The advice is limited in scope but must still satisfy s961B, s961G and s961J for that scope. Your adviser must obtain your agreement to the scope and warn you about matters outside scope that may need attention.

How long should a scaled SOA be?
ASIC says length varies with complexity. The RG 90 example is deliberately full to explain reasoning. A real scaled insurance SOA should be as short as clarity allows, with a table of contents if it exceeds about 10 pages.

Can I ask for a scaled SOA instead of comprehensive advice?
Yes. Agree the topic in writing before advice is prepared, confirm what is excluded, and check the final document records that scope. If new needs emerge, agree to expand scope rather than proceeding on an incomplete record.