I Received a SOA With No Fee Breakdown — Here's How I Checked It

The Situation

Sarah, 42, had recently engaged a financial adviser to help with her superannuation and insurance. She received a 30-page Statement of Advice outlining recommendations to switch super funds and take out income protection insurance. But when she looked for the fees section, all she found was a paragraph saying "fees and costs will apply" — no table, no dollar amounts, no breakdown of what she would pay upfront or ongoing.

Why This Matters

Under Australian law, a SOA must clearly disclose all fees and costs associated with the advice and any recommended products. This includes upfront fees, ongoing adviser fees, investment platform fees, and insurance premiums. A vague statement like "fees will apply" does not meet the standard. Without a clear fee breakdown, you cannot make an informed decision about whether the advice represents value for money.

What the Compliance Check Found

Sarah uploaded her SOA to AdviserCheck. The compliance report flagged the fee disclosure section as a finding — the document did not include a clear fee table, did not state the dollar amount of ongoing fees, and did not explain the fees associated with the recommended super fund and insurance policy. The report noted that under FOFA reforms, this level of disclosure is required and the SOA was likely non-compliant in this area.

What Sarah Did Next

Armed with the report, Sarah went back to her adviser and asked for a detailed fee breakdown in dollar terms. The adviser provided an amended SOA with a proper fee table. Sarah was then able to see that the ongoing fees would total $4,200 per year — higher than she expected. She negotiated a lower ongoing fee and felt confident proceeding because she now understood exactly what she was paying.

What Fee Disclosure the Law Requires

Under ASIC's Regulatory Guide 182 (RG 182), your Statement of Advice must disclose all fees and costs in dollar amounts, not just as percentages or vague descriptions. This includes: the upfront fee for establishing the advice or product, ongoing advice fees (including the amount and how often they are charged), any commissions or trailing commissions, fees for additional services, and exit fees or penalties for terminating the arrangement.

The fee disclosure must be presented in a clear, concise, and effective manner. A table format is recommended, showing each type of fee, the dollar amount, when it is payable, and to whom it is paid (the adviser, the licensee, the product issuer, or a third party). If the fees are deducted from your super or investment account, this must also be clearly stated. The purpose of these requirements is to ensure you can make an informed decision about whether the advice represents value for money.

Steps to Take If Your SOA Lacks Fee Disclosure

If your SOA does not include a clear fee breakdown, do not sign it. Instead, request in writing that your adviser provide an amended SOA with full fee disclosure in dollar terms. Under the Corporations Act, you are entitled to this information before you give your informed consent to proceed with the recommendations.

You can also ask for a comparison of the total fees over 1 year, 5 years, and 10 years (or the expected life of the arrangement). For ongoing advice arrangements, the fee disclosure statement must be sent annually, and you have 30 days to respond. If you do not respond, ongoing fees must stop. If your adviser is reluctant to provide fee details in writing, this is a significant red flag.

Using AdviserCheck for Fee Analysis

AdviserCheck's AI-powered compliance analysis includes a specific check for fee disclosure. When you upload your SOA, the system analyses whether fees are clearly disclosed in dollar amounts, whether there are any hidden or vague fee references, and whether the fee structure is consistent with the services described. This can help you identify gaps in disclosure that you might miss when reading the document yourself.

If AdviserCheck identifies issues with fee disclosure, you will receive a detailed report highlighting the specific sections of your SOA where fees are unclear or missing. You can share this report with your adviser as the basis for requesting a corrected document. Remember, you are not obligated to accept advice that does not meet the legal disclosure standards.

Frequently Asked Questions

Can I refuse to pay if the SOA has no fee breakdown?
If you have not signed the SOA, you are not obligated to proceed. If you have already signed and paid, but the SOA lacked proper fee disclosure, you may have grounds to dispute the fees. Contact your adviser or lodge a complaint with AFCA if you believe the fee disclosure was inadequate.

What fees should be disclosed in an SOA?
All fees must be disclosed: advice fees (upfront and ongoing), product fees (entry, management, exit), commissions (including any grandfathered commissions), and any other costs such as switching fees, establishment fees, or break costs. Each fee should be shown in dollar terms with a clear explanation of what it covers.

How are ongoing advice fees disclosed?
Ongoing advice fees must be shown as a dollar amount per year (or per month/quarter if applicable), with the total expected over the life of the arrangement. The fee disclosure statement sent annually must show the actual fees charged and the services provided in return. If the fee is deducted from your super, this must be clearly stated.

What if my adviser charges fees but I did not receive the services?
If your adviser charged ongoing fees but did not provide the agreed services (such as annual reviews, portfolio adjustments, or strategy updates), you may be entitled to a refund. AFCA has upheld complaints from clients who were charged fees for services not delivered. Keep records of your fee disclosure statements and the services you actually received.

What AFCA Complaints Data Shows

The Australian Financial Complaints Authority (AFCA) received 104,861 complaints in 2023-24, an 8% increase from the prior year. Of these, 3,559 were about investments and advice, though excluding Dixon Advisory complaints, investment and advice complaints reached an all-time low of 2,709 — reflecting improvements in education standards and industry professionalism.

Key findings from AFCA's complaints data:

• Inappropriate advice remains the most common complaint type in financial advice disputes.
• Dixon Advisory: 2,773 total complaints received since AFCA's inception. Of these, 98.2% of determined complaints were found in favour of complainants, with $35.6 million awarded in compensation and an average of $329,996 per determination.
• Financial difficulty complaints rose 18%, including concerns about inadequate responses to hardship applications.
• Scam complaints surged 81% to 10,951, though they declined in the latter part of the year (averaging 500 per month vs. 900 previously).
• Licensees with most advice complaints (FY24): AMP Financial Planning (30), InterPrac Financial Planning (14), Madison Financial Group (11), NextGen Financial Group (10).

AFCA resolved 70% of scam complaints within 60 days, with 67% resolved at the first stage (referral to the firm). Of complaints that progressed to investigation, 60% resulted in full or partial compensation. Only 2% went to formal determination by an ombudsman.

Source: AFCA Annual Review 2023-24, AFCA Datacube statistics, Parliamentary submission on DASS.

What Financial Advice Costs in Australia

Understanding typical advice fees helps you evaluate whether your adviser's charges are reasonable. Recent industry data provides clear benchmarks:

Fee Type	Typical Amount	Trend
Annual ongoing advice fee	$4,700 – $4,800 (median)	Up 67% over 5 years, but growth slowing to ~4%
Initial SOA / plan fee	$2,000 – $3,500	Varies by complexity
Hourly rate	$300 – $600 per hour	Higher for specialist advice
Funds under advice (FUA) fee	0.5% – 1.1% of balance	Average FUA: $758,000
Top 20% profitable practices	Nearly double median	Higher fees = leaner cost-to-serve models

Despite 68% of Australians seeing the benefit of professional financial advice, only 6% are willing to pay more than $2,500 for it. This gap between perceived value and willingness to pay is a key reason why regulatory reforms (DBFO, QAR) aim to reduce the cost of advice delivery.

If your adviser's fees are significantly above these benchmarks, ask for a clear breakdown of what you're receiving for the premium. Your SOA must disclose all fees and charges under FOFA requirements.

Sources: Adviser Ratings Australian Financial Advice Landscape 2025, Vanguard Adviser Best Practice Guide 2025, Investment Trends Adviser Business Model Report 2025.