Price expectation of buyers and sellers

Recently Radar Results conducted a simple poll among the LinkedIn group called ‘Selling or buying a financial planning practice Australia’, and received 103 responses. The single question asked was “What multiple or recurring revenue today would you pay for a quality financial planning (FP) business?” There was a lot of debate over what might be considered to be a quality FP business. Below are the results of the poll.

Multiple of recurring revenue % Poll responses

1.5 to 2.0x 8%

2.0 to 2.5x 43%

2.5 to 3.0x 34%

3.0 to 3.5x 7%

3.5 to 4.0% 8%

Some financial planners said the multiple would depend on whether they were buying or selling; which is an interesting position to take. If they were buying, then they would pay only 2.0 to 2.5x RR; but if they were selling, then they would want a higher multiple. I know it’s human nature to want to have your cake and eat it too, but you can’t have it both ways.

The situation of ‘having your cake as well’ will cause many sales to stagnate. Whilst there may be both a willing buyer and a willing seller, a very wide price-differential starts everyone on the wrong foot. I’m aware of planners who wanted to sell their businesses in 2007/2008 and, as at today, those businesses are still on the market. Both the revenue of those businesses and the multiples they will achieve are now lower. A keen seller could have an offer from a buyer within a week, assuming that they (the seller) are organised and that the sale price of the practice is realistic. A financial planning business will sell easily at a commercially-realistic price, or market price. Radar Results is not in the business of ‘talking prices down’. We are very happy to have our associates around Australia consult in an endeavour to have a commercially-acceptable and happy outcome. I think it’s important that planners realize that, when selling their business to a Radar Results client, the seller does not incur any fees.

Financial planning values stabilise

The price paid for a financial planning (FP) business seems to be on everyone’s mind; whether you’re a vendor planning to sell, a prospective buyer or a licensee. Naturally, everyone agrees that financial planning businesses reached their pinnacle just before the GFC in 2007/2008; and that since then the prices have been trending down. However, the Future of Financial Advice reform (FOFA) hasn’t had the impact on FP values that everyone thought it would, mainly due to the Government’s watering-down, and therefore, FP values have now stabilised.

I’ve been told by a few people that the value of FP businesses, or client registers, may even increase from now on. I’d like to know on what basis – and why. Grandfathering has been mooted as a reason; but haven’t we always had grandfathering?

As consultants, Radar Results is usually involved with about 50 FP transactions per year. These may include the acquisition of a small client register by a Radar client or the sale of a large financial planning business with $1M to $2M of recurring revenue (RR). Radar also provides consultancy services to licensees wanting to help their Authorised Representatives (AR) grow their business. This can be achieved in two ways: organically, with the introduction of professional business coaches into the practice; or by helping the AR with an acquisition. During 2011, Radar Results and RadarBC (Radar Business Coaching) were able to help Licensees in both these areas. There’s recently been a trend which indicates that FP businesses are merging, in order to save on infrastructure costs and staff.

It’s going to be interesting to see where values move during the next few years and what trends develop within the financial planning industry.

The real cost of FOFA

The real cost of complying with the new Future of Financial Advice (FOFA) rules may be much higher for financial planning practices than the Government had thought; and as a consequence, some of the fundamental reasons for introducing FOFA may not be achieved.

Banning commissions is obviously the most radical change, but unfortunately it has come 20 years too late. Changing the entire remuneration system to fee-for-service is merited and will provide certainty of fees paid to the financial planner; and, therefore, added security for the investor. However, it will be difficult for the public to adopt a fee-for-service system which is similar to that used by accountants, since most financial planning clients are used to receiving advice, and not being invoiced. From 1 July 2012 onwards, the effect of FOFA on financial planning revenues could be damaging.

The annual opt-in cost of $11 per client was the result of research conducted by an actuarial consultancy firm, commissioned by Industry Super. Earlier in the year Treasury officials indicated to a Senate Committee that they had seen industry research which suggested opt-in would cost around $100 per client per annum; possibly even $200 per client per annum.

Irrespective of the opt-in cost, the new opt-in reform will only apply to new clients who join a financial planning practice after 1 July 2012. The grandfathering rules have finally been confirmed and they will help maintain the value of financial planning practices; particularly those with many inactive clients, known as Cs and Ds or ‘orphans’.

Research by our consultancy firm, Radar Results, reveals that each of the 71 financial planning practices selling today contains, on average, 544 clients. When you further analyse the figures, these practices can have up to 5 times more inactive clients than active. Over the past few years many financial planning practices have been selling off their inactive clients, wanting to concentrate only on the higher-revenue clients and ignore the inactive ones.

There’s a concern that the sale of a client register from one adviser to another after July 2012 may stop the flow of trail commission and trigger the start of the opt-in rule. On this matter, a spokesperson from Treasury said, “At this stage, I don’t think that transferring the book would necessarily turn the grandfathered commission off or trigger opt-in, but circumstances might vary.”

Inactive clients are usually not offered any service or advice and can be rated either as a C or D grade client or classed as an ‘orphan’. It’s going to be very difficult to have inactive clients sign a renewal notice; or, for that matter, even find out where they are now living in order to issue a renewal notice. And if the trail commission ceases because you can’t get a renewal notice signed, then the value of the client register may disappear.

Inactive clients can make up a large proportion of a practice’s revenue and the cost to make contact with all these inactive clients may be prohibitive. With grandfathering still allowing for the passive trail commission to continue, there’s little incentive to contact them. When FOFA was first announced, the Government said, via the former Minister for Financial Services, Chris Bowen, “These reforms should ultimately encourage more people to seek financial advice”. I suggest the opposite may occur.

Born out of the inquiry into the collapse of Storm Financial and Opes Prime, the intention of FOFA reforms was to make financial planning advice more affordable to a larger number of people within the community, improve quality of advice and strengthen investor protection by having a less conflicted playing field in relation to commissions and volume bonuses. Unfortunately, the opt-in rule will not encourage more people to seek financial advice and neither will it improve the quality of advice; but it will offer more investor protection and certainty of fees. The ban on commission and other volume-based incentives will be a real bonus for the public and offer a high level of protection. FOFA will improve the quality of advice to the public, but not make it more affordable to a larger number.

Clients of Radar Results have been acquiring inactive clients by the thousands and are taking a positive stance on FOFA, providing service and advice to as many of these clients as possible; and, at the same time, growing their practices by cross-selling other products and services.

The insurance industry and life insurance agents and advisers, who specialise in risk products, are blessed. The FOFA reforms will basically have no impact on them – and rightly so. The reversal on banning risk commissions made common sense. Possibly opt-in may be now be reversed?

The Government’s reforms will have little or no effect on fee-for-service practices, particularly those with only A Grade clients; but the majority of financial planning practices are not pure fee-for-service yet and the reforms may be onerous.

Recurring revenue multiples update

Dear John,

 

Below is an indication of FP recurring revenue multiples since the 2nd FOFA announcement on 28 April 2011, which is also based on actual prices paid for financial planning practices or client registers since May 2011.

 

                                                                    City CBD                   Regional and Country

 

                                                           Recurring Revenue                 Recurring Revenue

                                                                    Multiple                                      Multiple

 

Investment clients with                              2.5x to 2.7x                               2x to 2.2x

average age over 60 yrs  

 

Accumulator inv. clients                            2.7x to 3x                                      2.5x  

 

Risk clients                                                   3x to 3.5x                               2.7x to 3x

(average age under 50 yrs)   

 

SMSF clients any age                              2.7x to 3x                                  2.2x to 2.5x

 

Corporate super clients                               1x to 2x                                0.75x to 1.5x

 

Cs and Ds (Inv and risk)                                   2x                                            1.5x

 

 

 

 The multiples above can vary, depending on terms offered by the vendor, actual location of the clients, client ages and the particular investment products recommended. Other factors that influence the prices paid for a FP business are the number of advisers, number of clients, grade quality of the clients, systems and processes within the practice, fee for service arrangements (FOFA ready or not) and the client value proposition CVP that’s currently being provided.

 

 

Accounting practices in big demand

 

Not surprisingly, a number of financial planners are now looking to acquire accounting practices so they can cross-sell risk, investment, loan and SMSF services. Prices paid for accounting fees can vary from city to regional country areas, with $1 paid for each $1 of annual accounting fees being standard in the city and lower prices for country regions. The Cooper Review has had an impact on prices paid for non-business tax fees (Individual tax returns). If you would like your accounting business valued or appraised, then please contact John Birt 02 4384 5670.

 

 

 
 
 

 

New Adelaide Office

Introducing our New Associate – Andrew MacDonald  
 
 
 
Andrew entered the industry in 1984 following a career as a Land and Business Agent. He became a regional manager with Monitor Money and then in 1989 founded his own Securities Licence, Financial Management Services (FMS), as a joint venture with a CA practice. That year he was elected State Chairman and Board member of ASIFA.

In 1993 Andrew established Symetry, and 6 years later he negotiated a joint venture with Perpetual Trustees that included a large payment to Symetry’s stakeholders. In 2004 the business had $1.4 billion FUM and Andrew participated in the negotiations leading to a sale of the business to the CBA group. In the next year he sold FMS into the WHK group and established a new business in funds management involving Equity Trustees, which raised over $300 million in FUM. During this time he was also a Director of MMC Funds Management and was instrumental in assisting it to grow from $15 million FUM to $560 million. These businesses where sold in 2005. In total Andrew has been involved with 14 transactions, either acquiring or selling financial services businesses.

 

Andrew is the current Chairman of FinaMetrica, one of the world’s pioneers in financial risk profiling methodologies and systems.

 

If you wish to contact Andrew MacDonald, Phone 0419 791 020 or Email andrew@radarresults.com.au

 

 

 

 

RadarBC, a division of Radar Results, now has six of Australia’s best business coaches engaged to provide its unique business coaching program to financial planners. Using RadarBC‘s coaches will increase the value of a financial planning practice, leading to a higher sale price, a shorter succession timeframe for an existing partner, or just making the planning business more profitable. Increased profits can then flow into many areas, ensuring a happier business and a happier personal life for everyone. Clients of RadarBC vary from small boutique businesses, earning at least $500K in revenue, through to larger institutions.

 

RadarBC is unique, offering a blend of coaching, consulting, mentoring and implementation services to supplement a practice’s operational resources. You pay only for what you need, when you need it. Upfront there are strategy coaches working with the principals and executive team, and mentors who have been there and done it. The strategy plan and set of projects are prepared specifically for your culture, for your development and for your business’s vision; they are designed to increase the value of your business, usually within a time frame of 6 to 12 months. However, you choose the speed and depth of implementation.

 

 

 

 

 

 

 



Future of Financial Advice (FOFA) reforms and the value of your business

Over the past 2 weeks, as a consequence of the recent FOFA announcements, a number of Radar Results clients have said they will not now pay the same level of recurring revenue, or EBIT multiple, that they were prepared to pay before the FOFA announcements. Depending on the style of the planning business, the products used, the client ages and, in particular, their current fee arrangements; Radar Results has seen a decrease in many financial planning firms’ valuations. Radar Results valuers have reduced EBIT multiples by 0.5X since the recent FOFA announcement, equal to a reduction of approximately 10% of a practice’s value.

In the late 1990s I recall being asked to visit a retiree in Charlestown, Newcastle, who had invested $450,000 with a local planner 3 years earlier and, since investing, hadn’t seen the planner again, although he was working in the CBD some 12 minutes away. The retiree was after some service and wasn’t happy; he had been receiving a quarterly statement directly from the licensee for the funds under management (FUM) that he held. The FUM was held entirely in one Master Trust, and the licensee was being paid an annual service-fee payment of 0.8% or $3,600; so over 3 years the retiree had paid $10,800 to his licensee and planner, and had received basically no service. That’s what FOFA wants to alter; as The Hon Bill Shorten, MP, said in his press release on 28 April 2011, “The policy reflects the need to ensure that advisers do not charge ongoing fees where the client is receiving little or no service.”

Shorten went on to say that “volume rebates from platform providers to dealer groups must cease”. Herding clients into a particular administration vehicle for the financial benefit of the adviser and licensee may not be considered credible. Irrespective of whether there were other reasons for substantially using one particular platform, FOFA will eliminate any temptation for revenue to be paid based on volume.

A concern I have with FOFA is the proposal for a 2 year Opt-in. An annual renewal notice must still be sent to all clients specifying what work was performed by the adviser in the previous year, and what was received by them in fees over that period; as well as providing the same details for the coming year. The only difference from the first reform paper, on 26 April 2010, to this latest announcement (28 April 2011) is the requirement for the client to sign, i.e. Opt-in, every second year. If the client is unresponsive or, in other words, if you can’t find them to sign, you must stop taking the commission, trail or service fee.

 But of far greater concern is the Government’s inability to outline a definite grandfathering arrangement. Grandfathering has been presumed by most advisers to be automatic, however, Shorten’s recent statement that “issues around grandfathering arrangements will still be subject of further consultation” is certainly not what planners wanted to hear. The question is whether life insurance agents, who have been building up client registers for many years, may have a part of their register rendered worthless. Certainly, retail risk policies written inside a personal super plan seem to be in the firing line.

Also, the Government’s FOFA proposals have watered down the adviser’s fiduciary duty to a ‘statutory best interest duty’; stating that they, the individual adviser, will not be held financially liable for any breach of their duty.

Last, but not least, is the Government’s tougher stand on gearing. The 26 April 2010 paper banned any adviser fees being charged against the component of an investment that’s geared, but last week Shorten said “an asset-based fee cannot be charged, even on the ungeared component.” This is certainly an attempt to discourage gearing; and any financial planning practice that has a large component of clients geared may need to take swift action to protect their revenue, and the value of their business.

Valuation changes

Radar Results has seen a decrease in requests for valuations on financial planning practices; however, it’s interesting to note an increase in valuations for divorce and property settlements. Before the GFC, most valuations were for finance applications, or for the lender to check on the equity-to-loan ratio. These days, very few are for this reason.

Whilst the total number of requests for a valuation has fallen to approximately 10 per month, down 31% on 2010, Radar Results has seen a surge in the number of valuations required for divorce.  Another change is the higher percentage of valuations requested to change the shareholding between partners in a financial planning business. Younger partners wish to buy a larger stake in their planning business, and require a valuation by an independent, registered valuer.

A concern within the financial planning industry is that there appear to be valuations prepared by unqualified and unregistered valuers, leading to incorrect pricing, which can, in turn, lead to problems if there is a dispute; and, therefore, a court hearing.

Another concern is that not all valuers are prepared to appear in court or, for that matter, even travel. A valuer providing a valuation for a divorce settlement is often required to appear in the Family Court to answer questions.

Loan books in big demand

Surprisingly, a number of financial planners are now looking to acquire loan books so that they can add additional revenue to their businesses. Cross-selling opportunities are also enhanced. The banks had moved to take much of the loan work back into their branches, which put a squeeze on trails and upfront revenue. The last 2 years had seen the multiple paid for loan book recurring revenues reduce to between 1 and 1.5 times. More recently, and on the back of demand from financial planners, the multiple has increased. If you would like to know more about how much a planner or mortgage writer would currently pay for your book of clients, please email me at john@radarresults.com.au.

RadarBC – Business coaching for financial planners

In 1995 I hired a business coach and then went on a 2 day business-coaching workshop. From there a new client value proposition was established, and within 6 months my revenue had doubled. I continued to pay my business coach a retainer for the next 7 years. I changed business coaches in 2004, appointing Radar’s current principal coach, Michael Wynter. I’ve been with Michael for 7 years and have since formed Radar Business Coaching (RadarBC), engaging 5 more business coaches.
The main problem I identified with business coaching is that the coach will provide you with advice, but you’re the one that needs to implement that advice. RadarBC provides a Strategy Coach and an Implementation Coach, solving the problem known as FTI, or Failure to Implement. To learn more about RadarBC go to our website
www.radarbc.com.au

Radar wins marketing award 2 years running

Radar is proud to receive the 2010 All Star Award for the second year running, chosen out of over 400,000 organisations. 

Businesses work hard to build strong relationships with their customers through marketing and some, such a Radar, truly excel in this effort,” said Gail Goodman, CEO, Constant Contact. “We’re proud of the role we play in helping Radar be successful and we look forward to continuing to assist them with their marketing efforts.”

Advisers will pay price for fiduciary duty reforms

Fiduciary duty ‘beefed up’

 

Fines for financial advisers breaching their fiduciary duty could increase dramatically, moving the current maximum fine of $500 up to $200,000 when new legislation is introduced next month. The Government wishes to amend the Corporations Act to explicitly include a statutory fiduciary duty for financial advisers operating under an AFSL, requiring them to place their clients’ interests ahead of their own.

 

Currently an authorised representative’s defence is to simply rely on the Licensee’s instructions and advice. If this new legislation is passed, then the authorised representative becomes liable. The proposed reform may place the adviser (authorised representative) in a position similar to that of a company director, where if found to be reckless, the fine under a civil action may increase from a maximum $500, to $200,000. If ASIC also decides to be involved in the complaint, then the new reform will allow for criminal liability, and a prison sentence of up to 5 years. At the moment, it’s not considered a criminal offence if an adviser is found guilty of being reckless, and not acting in the client’s best interest. The new law will allow for court awarded compensation, paid by the adviser to the client.

 

Media reports have indicated that planners feel that the fiduciary duty that currently exists, is not much different to the one that’s being introduced to parliament next month. In summary, we now have a $500 fine, no jail, no compensation and next year, $200,000 fine, 5 years jail and compensation. It would be interesting to see if any court awarded compensations will be covered by Professional Indemnity insurance if the adviser is found to be ‘reckless’.

The Results – Radar’s Survey

Financial Planners and the Future of Financial Advice Reforms

Consultancy firm, Radar Results, has done a survey of financial planners, to gain feedback on the Future of Financial Advice Reforms, which are expected to be implemented in July 2012. The survey required answers to questions about the adviser’s gender, age and whether they own the business.  Over 85% of responses (349) came from males and 66% were aged 45 to 64. Radar’s survey revealed a high proportion were self-employed, 319 in total, or 78%. The principal of Radar Results, John Birt, said he was surprised by the high level of self-employed, but, then again, the new reforms would have a greater impact on business owners than on their employees.

A total of 405 financial planners responded, with 584 comments and remarks. Mr Birt said, “I was taken aback by the number of comments and the many business owners who said they would have to lay off staff, or even close their doors. I once owned a planning business that took 20 years to build and, if a sudden change in the law had seen its value plummet, I wouldn’t have been happy either.”

All the 584 anonymous comments, some of which were quite lengthy and impassioned, together with the overall results, will be passed on to, The Hon Mr. Bill Shorten MP. The results will also go to every member of the newly-formed 18-member advisory panel on Financial Advice and Professional Standards.

There were other interesting responses to the survey: when asked the question ‘Which of the following proposed reforms do you want?’ 91% of respondents (356) said ‘no’ to the Opt-In proposal.

Furthermore, 57% (233) answered ‘very likely’ when asked ‘With each client having to sign an agreement every year [by opting in], do you think you will lose clients? ’ and 20% answered ‘somewhat likely’; a total of 77%. Other questions in the survey revolved around the size of the business based on Funds Under Management (FUM): ‘Have you moved to fee-for-service yet?’ and ‘How will the new reforms impact on your business?’

To view the results online, minus the comments, click here. Open until 14.12.2010

To request a copy of the results, including comments, send a blank email to survey@radarresults.com.au

Financial planning valuations – History is not a good guide

Past sale prices of financial planning practices are really not a good indicator of how much you should pay for them in the future. The past is the past, and if someone paid 3x, 3.5x or even 4x, the recurring revenue (RR) for a business previously, what relevance would that have for today’s purchaser? Very little, I would say.
Planners have tended to look at past transactions to guide them for the future. If, in 2007, you purchased a FP business at 3.5xRR, and the RR of the business halved during 2008/09, you will have ended up paying 7xRR.
Towards the end of the GFC planners thought they could acquire a FP business at a bargain price. They paid RR multiples of around 3x or more, hoping revenues would double and therefore halve the RR multiple they had paid to, say, 1.5x. This didn’t quite happen, but some planners did pick up bargains and, from March 2009 onwards, some made nice recoveries.

Looking to the future. What prices are planners asking for their financial planning businesses today? Through Radar’s marketing, we have developed a summary of nearly 100 practices wanting to sell. Approximately one third of these practices do not provide a clear sale price, but simply say ‘price and terms negotiable’.
The balance are asking for between 2x and 4xRR; however their asking price averages out at 2.79xRR. Larger practices, which ask for a multiple of EBIT, were excluded from this exercise. Note that 2.79xRR was the asking price, the eventual sale price being somewhat less.
Sale terms will also change, from the seller requiring only a 20% clawback to meeting half way at 25-30%. Instalment payment terms will also alter during the sale-negotiation phase, possibly ending with a final instalment after 1 year; whereas the purchaser may have originally required 2 years.
In the future, I see accounting sale multiples blending with FP multiples and moving away from the ‘recurring revenue scenario’, which has existed for the past decade. Looking ahead, total revenue and EBIT will form the new valuation methods. The larger practices and institutions will consume the smaller players, and RR valuations will disappear.

What should you pay for a financial planning business?
Based on acquisitions made by clients of Radar Results over the past 4 years, it’s apparent that risk insurance portfolios are ‘king’, followed by accumulator client registers. The perceived value of the portfolios of older investment clients, many of which were ‘smashed’ during the GFC, is certainly not as high as it once was. A reducing investment-account balance, as retirees live off their money, together with a lack of cross-selling opportunities, has seen them fall from grace. During the 1980s and 90s the retiree market was sought after, due to the easy servicing of their portfolios; they were always on holiday and never annoyed you.  
Today buyers are more cautious, and if they are going to pay 3xRR for a business then it needs to perform. The ability to increase the revenue by selling aligned products, a better value proposition through IT enhancements, and reduced expenses from dealer’s fees, have all encouraged quick growth by acquisition. Adding a $400K book to your business can instantly increase the bottom line by $300K.  So, at the right price, why wouldn’t you do it?

An indication of FP prices today:-         

                               City           Regional

Retirees                     2.5x               2x
Accumulators             3x                 2.5x
Risk clients          3.5 to 4x          3 to 3.5x
SMSF any age        3 to 3.5x        2.5 to 3x
Corporate super      1 to 2x         0.5 to 1.5x

The multiples above can vary depending on terms offered by the vendor, actual location of the clients, client ages and the particular investment products recommended.

Can you sell a volume bonus?

Consulting firm Radar Results (Radar) has provided valuations to the financial planning industry for many years. It became apparent volume bonuses were to be securitized by the government as being an incentive paid by the product provider to attract funds under management (FUM) and hence, may be banned. The latest Financial Services Reform paper released 26 April 2010 has confirmed this scenario.
 
Since 2008 Radar has not included the revenue from volume bonus payments in valuations based on recurring revenue multiples. It’s difficult to see how the government can legislate to stop volume payments being paid under a different disguise. The payment of a volume bonus or over-ride has been a common practice amongst many platform providers to attract and retain higher FUM. The platform providers, who seem to be the main culprits, may pay the bonus under a different name, say “a marketing allowance”. It’s also been muted that advisers may end up buying their own platform, which will then pay the adviser the volume bonus in the form of a higher Adviser Service Fee (ASF).
 
The dilemma is that when selling a financial planning practice today, should you include the volume bonus in the calculation of recurring revenue? It’s been common for advisers to receive the minimum ASF of say 0.4% plus another 0.2% as a volume bonus, often paid monthly in one lump sum, quite separate from ASF. Advisers may need to convert their clients to a true “fee for service” arrangement by 1 July 2012 and then substitute the “lost” volume bonus as a higher ASF. With revenue multiples falling combined with lost volume bonuses, the value of a planning business could be worth a lot less. Radar provides advisers with a free appraisal service – go to Appraisals on our website if you wish to receive an appraisal by email.
 
INSURANCE COMMISSION BANNED OR REPLACED?
 
The Cooper Review is particularly harsh and we would be surprised if it’s implemented in its current form, especially in relation to risk insurance. The debate between industry funds and the non-industry fund financial planning sector is ridiculous. The industry funds should be tipping all the costs of those adverts back into their member’s super accounts. If I had an Industry Fund, I wouldn’t be too pleased seeing all that money wasted. As a whole, its effect on the financial planning industry is serious and unwarranted. Many advisers who have relied on trails and commission for their lively hood over say 20-30 years, particularly life insurance agents, will be seriously affected by the Cooper Review; a Review which some say is politically motivated. 
The government wants the adviser to replace the commission that’s paid by the insurance company from selling an insurance product, with a professional fee. They (the government) would also like financial advisers to eventually replicate the fee system of accountants and lawyers. The perceived benefit to the superfund member is a higher end payment at retirement. The work that’s been provided to the member/client now needs to be paid directly to the adviser by the superfund member. This could be a very difficult task, invoicing and collecting all these fees. The signing of an annual Renewal Letter by the client also makes this servicing task more difficult and brings into question client retention. After June 2012 the member may have to pay for advice on any insurance within a superfund. So, how does the financial adviser replace the banned commission that he or she had been receiving on the existing insurance policies if the superfund member decides they don’t want any ongoing service?