Simplicity + Certainty = Confidence
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Secure

Secure

Your information is securely held, communications are safely encrypted. Our fully encrypted backups occur often and regularly. Flexible and secure user password security.

Fast

Fast

Fast interfaces, user experience and reporting through the latest database design and web technology. User management tools aide efficient processes

Simple

Simple

Uncluttered user interfaces, multiple browser tab access, effortless data links. Our user-friendly and easy to learn user interface means no steep learning curve. Logical data entry flow with what you expect where you expect.

Customisable

Customisable

You select the modules you use and customise to your needs. You control your reports' content, you tailor your installation to suit your businesses needs

Standardised

Standardised

We support the global standards on Risk Management (ISO 31000) and Compliance (ISO 19600) and APRA SSP 220

Centralised

Centralised

One stop for all of your risk and compliance office needs. View completed and incomplete controls. Retain all your controls and records in the one accessable data base

How it Works

Feature diagram

CRS Certus becomes your record of your risks, risk profile, risk mitigators, obligations, responsible managers and staff, policies and procedures. It holds your proof of control execution. It facilitates recording and managing issues, incidents and complaints. CRS Certus can be interrogated to deliver reports on all data it holds in a format your audience needs.

Risks

Full risk management system. Customisable risk register. Multiple entity ratings support. Links to mitigating controls and issues register. Risk appetites tied to strategic objectives. Risk tolerance triggers and questionnaire system.

Obligations

Record obligations. Link to legislative or regulatory sources. Reconcile obligations with business controls

Controls

Document business controls. Link to risks and obligations. Assign responsibilities to managers. Automatically generate controls self-assessment questionnaires. Managers alerted when questionnaires are ready, complete within CRS Certus

Assessments

Controls response assessment navigation. Record testing results. Full audit records of resolution and further action. Directly load adverse responses into Issues Register.

Incidents

Capture incidents originating from within CRS Certus and reported by your business. Customise incident categories. Workflow management. Assign activities. Capture reportability assessment, related documents and developments.

Complaints

Customise complaint categories. Seamless flag as incidents, breaches or risk mitigation controls failures.

Registers

Breach register with regulator reporting assessments. Personal dealing approvals and register, gifts & benefits, training, conflicts of interest, relatedy party, legal documents, administrative documents, publications, office holder registers amongst others.

Alerts

Email alerts issued out of the system directed to your defined positions. Customisable email content and triggers. Email service log validates that communications are sent.

Policies & Procedures

Policies and procedures library. Alert users to new content to review within CRS Certus. Capture user confirms of access and understanding of policies and procedures. The library becomes your single point of truth.

Reporting

Flexible reporting to PDF and XLS(X). Customisable report content, period and presentation, tailored and relevant for the audience. Reports returned immediately. Aides regulatory enquiry, annual audit, demonstrates the control you have over your business

Consultancy and Outsourced Management

In addition to providing CRS-Certus as a software service, we provide consulting and outsourced management services. These services are available separately from CRS-Certus.

We can help to:

  • Operationalise your risk and compliance management system.
  • Workshop your risks.
  • Build Controls.
  • Document your regulatory obligations.
  • Implement incident/complaints reporting.
  • Document your policies & Procedures

Compliance & Risk Services Pty Ltd has been providing risk and compliance management solutions for businesses for over 10 years.

Our speciality in financial expertise

We have particular experience with financial Australian financial institutions such as Australian Financial Services Licensee, APRA regulated entities, Australian Credit licensees and AUSTRAC reporting entities.

  • Australian Financial Services ('AFS') Licence applications and licence variations
  • RSE licence applications
  • AFS Licence compliance reviews
  • Managed investment scheme registrations
  • Draft compliance plans
  • Draft Product Disclosure Statements ('PDS')
  • PDS due diligence
  • MDA contracts
  • Provide outsourced compliance management
  • Anti-money laundering & counter terrorism financing ('AML/CTF') programs
  • Independent reviews of AML/CTF programs
  • External Compliance Committee members
  • Temporary compliance staff placements
  • Risk management frameworks
  • Local agent for foreign licensees
  • Technical and product advisory services
  • Responsible manager training

Our values and ideals

Experience

We are experienced risk and compliance management practitioners experienced in developing and operating risk and compliance management systems.
CRS-Certus is developed through our experience as risk and compliance management practitioners.

In-house programming team

Our programming team is retained in-house. We believe that the partnership of practitioner and programmer provides a strength that few competitors may match.

Secure IT architecture and backups

Our system uses contemporary database design, programming languages, and hardware. We have implemented a constant backup regime using offsite encrypted storage.

Trust

We have provided services to over 200 clients over the globe. We have acted as topic experts under ASIC enforceable undertakings, engaged as experts in litigation and ASX disciplinary reviews.

Articles

Consent to Deductions – Ongoing fee arrangements, information to be provided where a fee is to be deducted from a clients account: An updated.
By Terry Dalziel at 30/03/2021
Special Purpose Financial Statements ceasing from 1 July 2021
By Terry Dalziel at 30/03/2021
Disclosure of lack of independence – further disclosure via legislative instrument
By Terry Dalziel at 25/03/2021
Financial Sector Reform (Hayne Royal Commission Response No. 2) Bill 2020 now Law
By Terry Dalziel at 11/03/2021
Claims handling and settlement service and the need to be authorised
By Terry Dalziel at 01/03/2021
Wholesale and Sophisticated Clients can access AFCA
By Adam Bold at 22/01/2021
Financial Sector Reform (Hayne Royal Commission Response No. 2) Act 2020 - Impact on financial advisers
By Terry Dalziel at 16/12/2020
ASIC commences action against the RI Advice Group Pty Ltd
By Terry Dalziel at 24/08/2020
Deferral of mortgage broker reforms and design & distribution obligations
By Murray Jones at 12/05/2020
ASIC amends requirements where COVID-19 related advice is provided
By Terry Dalziel at 16/04/2020
AUSTRAC Industry engagement
By Adam Bold at 02/03/2020
Financial Sector Reform (Hayne Royal Commission Response - Stronger Regulators (2019 Measures) Act 2020
By Gerald O'Byrne at 24/02/2020
Code of Ethics Guide
By Terry Dalziel at 21/10/2019
ASIC's Corporate Plan to 2023
By Adam Bold at 13/09/2019
Update on information to be entered into the Financial Advisers Register (FAR)
By Terry Dalziel at 26/08/2019
Whistleblower policies - draft ASIC Regulatory Guide
By Murray Jones at 23/08/2019
Relief for amending registered schemes’ constitutions in particular circumstances
By Murray Jones at 23/08/2019
Update: Recognition of Prior Learning undertaken through a Professional Body / Financial Adviser Examination
By Terry Dalziel at 08/08/2019
Design and Distribution Obligations and Product Intervention Powers
By Malina Zhuang at 31/07/2019
Proposed changes to ASIC's Internal Dispute Resolution requirements
By Gerald O'Byrne at 28/05/2019
Consent to Deductions – Ongoing fee arrangements, information to be provided where a fee is to be deducted from a clients account: An updated.

Further to the recent article as to the disclosure requirements around independence coming into effect from 1 July 2021, the Australian Securities & Investments Commission issued two instruments on 23 March 2021 in relation to its powers under the Financial Sector Reform ( Hayne Royal Commission Response No 2) Bill 2020.   Both deal with the content of the consent required to be obtained before an ongoing fee can be deducted.  One Instrument relates to where the client is the account holder, the other where the ongoing fee is being deducted, either directly or indirectly, from a client’s superannuation account.   

The Instruments are,

  1. ASIC Corporations (Consent to Deductions – Ongoing Fee Arrangements) Instrument 2021/124. 
  2. ASIC Superannuation (Consent to Pass on Cost of Providing Advice) Instrument 2021/126.

ASIC Instrument 2021/124 requires a dated written consent be obtained from the client that details:

  1. the name of the account holder.
  2. the name and contact details of the [entity / person receiving the ongoing fee].
  3. in relation to an existing ongoing fee arrangement that might be renewed by the account holder the frequency and amount of each ongoing fee the account holder will pay during the upcoming year if the account holder were to renew the existing ongoing fee arrangement, where the upcoming year is a period of 12 months beginning on the next anniversary day for the ongoing fee arrangement.
  4. in relation to a new ongoing fee arrangement that might be entered into by the account holder the frequency and amount of each ongoing fee the account holder will pay during the upcoming year if the account holder were to enter into a new ongoing fee arrangement, where the upcoming year is a period of 12 months beginning on a day that is no more than 30 days after the fee recipient gives or makes available to the account holder all of the information that this subsection requires to be included in a written consent.
  5. in either case, if the amount of an ongoing fee the account holder will pay during the upcoming year cannot be determined then a reasonable estimate of the amount of the ongoing fees the account holder will pay during the upcoming year and an explanation of the method used to work out the estimate.
  6. details of each account from which the account holder will pay ongoing fees and, for each account the amount of each ongoing fee the account holder will pay from each account.
  7. statements to the effect that:
  8. the consent will cease to have effect up to 150 days after the anniversary day for the ongoing fee arrangement, and
  9. the account holder can withdraw their consent or terminate or vary the ongoing fee arrangement at any time by notice in writing to the fee recipient.

Under the newly inserted 99FA CA to the Superannuation (Supervision) Act (SIS Act), the trustee or the trustees of a regulated superannuation fund must not directly or indirectly pass the cost of providing financial product advice in relation to a member of the fund on to the member, unless consent has been given by the member.    A key concern of Commissioner Hayne about advice fees charged to superannuation products was that members have little visibility over ongoing advice fees and that there were instances where these fees were charged without the member’s awareness or informed consent.  

Trustees of a regulated superannuation fund will need to receive from the member a written, dated, consent containing the information (ASIC Instrument 201/126), namely: 

  1. the name of the member;
  2. the name and contact details of the fund;
  3. the name and contact details of the provider of the financial product advice;
  4. an explanation of why the member’s consent is being sought;
  5. how long the consent will last;
  6. information about the services that the member will be entitled to receive under the arrangement;
  7. as applicable:
  8. where the cost is passed on to the member by way of deducting fees from the member’s superannuation interest—a statement to that effect, including details of the interest;
  9. otherwise—an explanation of how the cost is passed on to the member, including details of the interest;
  10. as applicable:
  11. where subparagraph (7)(i) applies:
  12. the amount of the fees to be deducted from the member’s superannuation interest; or
  13. if the amount of the fees cannot be determined—a reasonable estimate of the amount and an explanation of the method used to work out the estimate;
  14. where subparagraph (7)(ii) applies:
  15. the amount of the cost; or
  16. if the amount of the cost cannot be determined—a reasonable estimate of the amount of the cost and an explanation of the method used to work out the estimate;
  17. a statement to the effect that the member can withdraw their consent at any time before the cost is passed on to the member by contacting the fund.

Advising clients on their superannuation appears to involve an increase in paperwork due to the different consent confirmation requirements. 

Other considerations

Providing consent approval forms to deduct ongoing fee.

If you use a platform provider to manage a client’s financial assets, the platform provider will most likely ask you to provide the information rather than the client directly.  Likewise, a Trustee of superannuation fund.  You will need to monitor what each platform provider or Trustee requires to facilitate the capture of the authorisation by the client. 

Amend your workflow to ensure the above is provided on a timely basis to the relevant entity(ies).

Accepting consent electronically

The client may provide their written consent electronically and receive that consent electronically.   It does not have to be a physical return of the signed consent.

Joint account holders

Joint account holders must give their written consent every year. 

Fee Disclosure Statement to all clients with ongoing fee arrangements – removal of grandfathering

Not only do the new FDS content requirements commence from 1 July 2021 but it applies to all clients. The grandfathering arrangements for ongoing fee arrangements entered into prior to 1 July 2013 will cease.  There is a transition period of 12 months to provide FDS to these types of clients.    You will need to identify the clients, tell them to expect to receive a FDS going forward and then determine when to have the 12-month period fall. 

Clients consent in a Self-Managed Super Funds environment.

The Act’s uses the wording, “indirectly pass on the cost ..”. A member of a SMSF is Indirectly paying for the ongoing service fee.  Either separate consents need to be obtained given the different consent requirements or one consent form is to be generated with two different parts covering the separate disclosures required.   If there is more than one member in the SMSF, then each member must provide the consent documentation.    

Consider the following circumstances for a SMSF:

  1. An ongoing service agreement is in place between the licensee and the corporate trustee for a SMSF.
  2. There are two members of the fund, member A and B.

Consents to be obtained by the licensee are:

  1. consent from the client (corporate trustee) to the licensee– content as ascribed in ASIC Instrument 2021/124, and
  2. separate consents from members A  and B to the trustee – content as described in ASIC Instrument 201/126.   Disclosure addressing paragraphs 7(ii) and 8(ii) would have to be provided. 

The reason including the separate consents under point 2 above with the licensee is because clients tend to rely on the licensee to ensure compliance obligations are being met. I It is in the licensee’s interest to ensure the trustee is provided with the correct documentation otherwise fees may not be paid. 

Reasonable estimate of fees over the next 12 months

Ongoing fee to be shown for a client in the coming 12 months is to be based on a reasonable estimate basis.  Staff calculating the amount will need to receive guidelines from the licensee about the matters they should consider to arrive at a reasonable estimate.

Contact Us

Feel free to drop us a message if you have any questions or requests.

Or give us a call at

P: 03 9663 4456

and post us at

P.O. Box 18009
Collins Street East
Melbourne, VIC 8003

We're located at

Level 25, 360 Collins St
Melbourne, VIC, 3000