“When it comes to digital solutions, there are some concerns about the quality of information currently being issued but quality comes back to the source, which is why qualified and experienced advisers should be leaders in general information,” Mr Baker said.

“General information, educational content and financial planning tools prepared and approved by advisers are always going to be better and lower risk than services offered by product manufacturers and unqualified finfluencers.

“Advisers are also strongly positioned to determine if a person is better suited to a personal advice proposition or general information. An integrated approach would maximise the probability of clients receiving high-quality information and advice throughout their life.”

Scientiam’s submission also question if employees of product issuers should be known as financial advisers and representing their services as financial product advice.

“Financial product advice is not advice. It should be called information. Intra-fund advice is not advice. It is a form of financial product information and that is not immediately clear to members,” he said.

“People linked to a super fund or product issuer can only provide information. To use a medical analogy, doctors provide independent advice. They may recommend medication and treatment, but they don’t sell it. Pharmacists sell product. The two propositions are very different and separate.”

Scientiam’s QAR submission comes just weeks after Mr Baker, who is also managing director of Arch Capital, called for advisers to unite and submit a “considered, fact-based submission” to the QAR directly or in collaboration with a professional association.

“If advisers want to help more people, they must take the lead in showing the government and regulators how quality advice can be delivered differently,” Mr Baker wrote in an opinion piece published on ifa.

“They must build advice models and solutions that meet the needs of consumers.”