As part of their reporting obligations, Licensees are required to report on the number of clients who, at the time of lodging the report, are believed to have been impacted, or are likely to have been impacted, by the reportable situation. Licensees are to include non-financial loss or damage (e.g., inconvenience, distress). 

ASIC provides guidance on how to calculate the number of ‘affected’ clients in the following situations:

Joint account holders 

Joint account holders should be counted individually. If a Licensees system does not allow them to disaggregate data in this manner, each joint account holder can be counted as a client. Licensees must disclose this in the free-text field along with an explanation as to why they are unable disaggregate joint account holders.

Broadly advertised incorrect offers

The number of ‘views’ of the incorrect offer should be recorded as the number of instances to be reported. The number of applications received during the incorrect advertisement offer should be recorded as the number of ‘affected’ clients.

Error made in disclosure document

The number of clients to which the document was sent should be recorded as the number of instances to be reported, as well as the number of clients ‘affected’.

For more information get in touch with our friendly team at King Irving team today.