The submission noted that the current education standards will result in very few accountants seeking to become licensed.

“The limited licensing regime in its current format is an obsolete model and will disappear in time as accountants continue to exit,” the association warned.

“Most accountants do not seek to provide financial product advice. Rather, they wish to provide advice that is within the realms of what many clients expect to be in the ordinary course of a tax agent service.”

The Association noted that with the declining number of financial advisers and the unmet advice needs in the community, accountants have a valuable role to play.

“Suitably qualified accountants should be able to provide certain limited advice, that does not involve a specific recommendation to acquire a financial product,” it explained.

For example, accountants should be able to provide simple advice on superannuation contributions that extends beyond the provision of factual information and how a type of contribution is treated for income tax purposes from the perspective of the party making the contribution and/or the super fund receiving it.”

In terms of the proposal to change superannuation trustee obligations and remove the restriction on collective charging, the association said caution is required when making amendments to the sole purpose test section 62 of the SISA.

“We acknowledge that superannuation fund trustees now have an obligation to provide information to certain members under the retirement income covenant and the issues this has created,” it stated.

“The superannuation legislation has existing mechanisms to address the allocation of costs and charging of fees to members. Superannuation Industry (Supervision) Regulation 1994 5.02(3) requires that costs are to be distributed in a fair and reasonable basis.”

Collective charging, it said, should apply only where it is in relation to the trustee discharging their duties under the retirement income covenant and for the provision of factual information to members.

“Where specific advice is provided to a member, no matter how simple or complex, the fee for the service provided should be deducted from the member’s interest in the fund, or nominated interest where they have more than one superannuation interest with that trustee,” it said.

“Expanding the collective charging of fees for the provision of personal financial advice allows for the cross subsidisation of advice services accessed by some but not all members of the fund. This is not equitable and is not fair or reasonable.”