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Kaplan supports raising Tier 1 advisers to higher AQF levels and extending required study topics, particularly ethics, but opposes requiring Tier 2 advisers to exceed the current Certificate III level. Key concerns address regulatory complexity from multiple consultations, transition impacts across AQF levels, uncertainty around future CPD guidance, and implementation cost effects for licensees and education providers.",{"@graph":69,"@context":122},[70,84,105],{"@type":71,"itemListElement":72},"BreadcrumbList",[73,77,79,82],{"item":74,"name":75,"@type":76,"position":8},"https://docshare.wps.com","Home","ListItem",{"item":78,"name":9,"@type":76,"position":14},"https://docshare.wps.com/document/",{"item":80,"name":20,"@type":76,"position":81},"https://docshare.wps.com/document/exam/",3,{"item":83,"name":65,"@type":76,"position":19},"https://docshare.wps.com/document/submission-on-asic-consultation-paper-212-licensing-training-of-financial-product-advisers-update-to-rg-146/394063/",{"url":83,"name":65,"@type":85,"image":86,"author":91,"headline":65,"publisher":94,"fileFormat":97,"inLanguage":63,"description":67,"dateModified":98,"datePublished":99,"encodingFormat":97,"isAccessibleForFree":100,"interactionStatistic":101},"DigitalDocument",{"url":87,"@type":88,"width":89,"height":90},"https://docshare.wps.com/thumbnails/submission-on-asic-consultation-paper-212-licensing-training-of-financial-product-advisers-update-to-rg-146/394063.png","ImageObject",300,407,{"name":92,"@type":93},"Melati","Person",{"url":74,"name":95,"@type":96},"DocShare","Organization","application/pdf","2026-11-04","2026-09-26",true,{"@type":102,"interactionType":103,"userInteractionCount":39},"InteractionCounter",{"@type":104},"ViewAction",{"@type":106,"mainEntity":107},"FAQPage",[108,114,118],{"name":109,"@type":110,"acceptedAnswer":111},"What does Kaplan support in ASIC CP 212?","Question",{"text":112,"@type":113},"Kaplan supports educating Tier 1 financial advisers at higher minimum AQF levels and generally supports expanding study topics, especially the mandatory ethics requirement.","Answer",{"name":115,"@type":110,"acceptedAnswer":116},"What position does Kaplan take on the Tier 2 adviser training requirement?",{"text":117,"@type":113},"Kaplan does not agree with requiring Tier 2 financial advisers to be educated or trained at levels higher than the current Certificate III level.",{"name":119,"@type":110,"acceptedAnswer":120},"What are Kaplan’s main concerns about implementing the proposed changes?",{"text":121,"@type":113},"Kaplan highlights confusion and risk from multiple overlapping consultations and initiatives, lack of coordinated guidance for CPD requirements, uncertainty related to CP 215 and future exam content, and the likely cost impacts on licensees and education providers.","https://schema.org",{"og:url":83,"og:type":124,"og:title":65,"og:site_name":95,"og:description":67},"article",{"robots":126,"canonical":83},"index,follow",{"doc_id":128,"site_id":62},394063,1790600306,{"code":4,"msg":5,"data":131},{"doc_id":128,"user_id":132,"nickname":92,"user_avatar":133,"doc_module":4,"category_id":19,"category_name":20,"doc_title":65,"doc_description":67,"doc_content":134,"file_id":135,"file_url":136,"file_type":137,"file_size":138,"view_count":39,"is_deleted":4,"is_public":8,"is_downloadable":8,"audit_status":8,"page_count":139,"language":140,"language_code":63,"site_id":62,"html_lang":63,"table_of_contents":141,"faqs":142,"seo_title":143,"seo_description":67,"update_tm":144,"read_time":145,"preview_page_count":4},962085570644,"https://ap-avatar.wpscdn.com/davatar_994ba38a5ba835b3df7d355c54d3ed8d","24 September 2013  \nNicole Chew  \nLawyer, Financial Advisers  \nAustralian Securities and Investments Commission Level 5, 100 Market Street Sydney NSW 2000 Email: [policy.submissions@asic.gov.au](policy.submissions@asic.gov.au)  \nDear Nicole  \nSubject: Submission on ASIC Consultation Paper 212  \nLicensing: Training of financial product advisers – Update to RG 146  \nKaplan Professional Education (Kaplan) welcomes the opportunity to provide feedback on the proposals set down in Consultation paper (CP) 212.  \nAs a leading provider of education to the financial advice industry in Australia at both the vocational and higher education levels, as well as the leading provider of continuing professional development (CPD) to the industry, we are in a strong position to offer comment on the considered proposal detailed in the consultation paper. We note the interrelatedness of the proposals in CP 212 to other ASIC proposals contained in CP 153 and CP 215.  \nKaplan supports ASIC’s desire to have Tier 1 financial advisers educated/trained at higher minimum AQF levels (Tier 1 at degree or equivalent), which in our view reflects what is progressively occurring in the financial advice market place i.e. employers/licensees are encouraging relevant higher educational qualifications above the minimum in their adviser recruitment and remuneration structures. Kaplan strongly supports the concept that formal education is a hallmark of any profession.  \nHowever, after due consideration, we do not agree with the proposal to have Tier 2 financial advisers educated/trained at levels higher than the current Certificate III level. We believe the current level is appropriate for those providing advice on less complex Tier 2 financial products.  \nKaplan also generally supports within the proposals extensions to the study topics in various knowledge and skill areas. The mandatory requirement for studies on ethics is of particular note as many of the causes behind past major financial collapses and inappropriate advice was rooted not so much in deficiencies in technical knowledge of advisers and product promoters, but in unethical behaviour. The following considerations have generally guided Kaplan’s responses to the proposed changes in ASIC’s consultation paper:  \n• Are the proposed changes relevant to the objectives of many stakeholders in the industry to improve the quality of advice that consumer’s receive in the future  \n• Are the proposed changes valid, and workable within the implementation timetable set  \n• Are the proposed changes flexible and equitable in terms of recognising prior learning and CPDfor existing advisers who change their advice activity  \n• What are the likely cost impacts on the implementation of the proposed changes for licenseesand education providers  \nAlthough Kaplan is in general agreement with the essence of the proposed changes to RG 146, there are aspects where we have concerns and have recommended alternatives for consideration. Those key areas of concern, most of which are also reflected within our feedback to ASIC’s specific questions, are as follows:  \nKey Issues  \n1. Multiple consultations and initiatives on planner education standards – resultant complexity and risk  \nKaplan is respectful of ASIC’s goals to improve the quality of advice of those providing financial product advice. Other leading industry stakeholders have similar goals. However, the current environment of a myriad of proposals from various government consultations is becoming increasingly complex and increasingly difficult for industry stakeholders to understand.. There appears to be a distinct lack of a co-ordinated strategic framework for industry stakeholders to work within, given:  \na) The initiatives and issues proposed in multiple consultation papers currently for consideration (ASIC CP 153, 215 and 212); and relatedly, the impact of  \nb) TASA regulations in respect of training for financial advisers on tax  \nc) TPB guidance in respect to training ","cbCaicPmEeC7UNgx","https://ap.wps.com/l/cbCaicPmEeC7UNgx","pdf",365771,17,"English","# Key Issues\n## Multiple consultations and initiatives on planner education standards\n## Transition of AQF levels from 5 to 7","[{\"question\":\"What does Kaplan support in ASIC CP 212?\",\"answer\":\"Kaplan supports educating Tier 1 financial advisers at higher minimum AQF levels and generally supports expanding study topics, especially the mandatory ethics requirement.\"},{\"question\":\"What position does Kaplan take on the Tier 2 adviser training requirement?\",\"answer\":\"Kaplan does not agree with requiring Tier 2 financial advisers to be educated or trained at levels higher than the current Certificate III level.\"},{\"question\":\"What are Kaplan’s main concerns about implementing the proposed changes?\",\"answer\":\"Kaplan highlights confusion and risk from multiple overlapping consultations and initiatives, lack of coordinated guidance for CPD requirements, uncertainty related to CP 215 and future exam content, and the likely cost impacts on licensees and education providers.\"}]","Submission on ASIC Consultation Paper 212 - Licensing: Training of financial product advisers - Update to RG 146 | PDF",1790398274,43]