“We strongly believe that there is no room for conflicted remuneration in financial services, even where the financial advice being provided does not specifically take into account the consumer’s personal circumstances,” the submission stated.

“We believe the best consumer outcomes must be achieved independently from any links with product remuneration.”

SPAA also said a “major concern” with the amendment to provide a limited exemption for general advice from the ban on conflicted remuneration is that it will cause AFS licensees and their authorised representatives to move from providing personal advice to general advice in a vertically integrated arrangement “to take advantage of commission remuneration”.

“The limited scope of the exemption from the ban on conflicted remuneration is clearly targeted at general advice provided by vertically integrated financial services firms, which may encourage greater consolidation and integration in the industry,” SPAA stated.

“While SPAA does not contend that vertical integration of financial services is inappropriate or should be prevented, allowing these firms to structure remuneration around commission-based payments linked to general advice will be detrimental to consumers seeking financial advice.”