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Insurance brokers as an Authorised Representative – how are you managing contagion risk?

I’m often asked by insurance brokers, who are authorised representatives of a licensee, whether they should hold for their own AFS licence. I talk them through the mechanics of obtaining an AFS Licence, the cost (plus ongoing costs) of applying for a licence and how I can support them with their AFSL application. However, such a question requires an initial analysis of the risks, costs and benefits of holding your own AFS Licence compared to being an authorised representative of another licensee. With the increased regulatory scrutiny by ASIC over AR networks there is a strong case for obtaining your own licence. This scrutiny will, most likely, continue to increase. What is contagion risk? Contagion risk, in context of an AR network, is the likelihood that an adverse event, such as a cybersecurity failure or misconduct of one or more authorised representatives, impacts the entire AR network for that Licensee. This impact includes the impact to all other authorised representatives within the network and the licensee. A recent Federal court case highlighted contagion risk: Australian Securities and Investments Commission v RI Advice Group Pty Ltd [2022] FCA 496 (see ASIC media release (22-104MR)). RI Advice The Federal Court found AFS licensee, RI Advice, breached its license obligations to act efficiently and fairly when it failed to have adequate risk management systems to manage its cybersecurity risks. The finding comes after a significant number of cyber incidents occurred at authorised representatives of RI Advice between June 2014 and May 2020. In one of the incidents, an unknown malicious agent obtained, through a brute force attack, unauthorised access to an authorised representative’s file server from December 2017 to April 2018 before being detected, resulting in the potential compromise of confidential and sensitive personal information of several thousand clients and other persons. In addition to the declaration of contravention, the Court ordered RI Advice to engage a cybersecurity expert to identify and implement what, if any, further measures are necessary to adequately manage cybersecurity risks across RI Advice’s authorised representative network. RI Advice was ordered to pay $750,000 towards ASIC’s costs. Increased regulatory scrutiny leading to enhanced monitoring and supervision A number of insurance broker Licensee’s are having to report ‘reportable situations’ to ASIC, due to the conduct of authorised representatives. The reporting of reportable situations to ASIC, profile cases such as RI Advice, existing regulatory obligations and responsibility for the conduct of authorised representatives under Part 8.1 of the Insurance Brokers Code of Practice, will continue the enhanced regulatory focus of ASIC in respect of the operation and management of AR networks. Licensees are responding through rigourous due diligence processes as part of the AR appointment process and robust AR Monitoring Programs. I have worked with a number of licensed Insurance Brokers to set-up robust AR Monitoring Programs and due diligence. Licenced or AR? Costs and benefits – a compliance perspective From a risk and compliance persepective there is a benefit for a new brokerage to be an authorised representative of a […]
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The cadence of compliance

Cadence refers to a regular, rhythmic flow of activity. The cadence of compliance refers to compliance infrastructure and the information and data that flows through the infrastructure. The cadence of compliance is critical to ensure that a firm’s compliance measures are adequate and documented, enabling self-regulation and self-reporting. A compliance cadence, importantly, enables the firm’s compliance measures to evolve and adapt through business growth, innovation, use of automation, and the development of new products, services, distribution channels and partnerships. Compliance infrastructure Think of a pipeline infrastructure in the energy sector. The network of pipelines, compressor stations, valves, and monitoring systems used to transport crude oil, natural gas, and refined products. Similarily, the pipeline infrastructure for compliance is the network of governance, IT systems, people and processes used to transport risk and compliance information and data flows. The components of compliance infrastructure Governance Including: roles and responsibilities, based on the 3 lines of defence accountability model; delegated authority for risk-decision making, based on the firm’s risk appetite statement; risk and compliance committees including sub-committees such as the breach management committee; monitoring and supervision including of the compliance system and of staff, authorised representatives, distributors and service suppliers; training and competency mechanisms; regulatory change management; product governance (design and distribution obligations); reporting to business operations, management, board, business partners, stakeholders and regulators; and record keeping. Licence management This includes those things that must be done to maintain an AFSL/APRA licence/authorisation such as: annual regulatory returns; ASIC IDR data reporting; notifying regulators of change of details including changes in responsibilities (such as responsibile managers); administrative matters; and changes to licence authorisations and conditions Risk management processes This includes how risks and complance obligations are managed: identification; analysis; evaluation; treatment; and monitoring Frameworks and sub-frameworks Aligned to governance however it is important to ensure that there is an overarching framework (enterprise risk management framework (ERMF)) and sub-frameworks such as obligations management, incidents , complaints, monitoring, product governance etc that align with and are connected to the ERMF. Information and data flows With the compliance pipeline infrastructure in place the test of the adequacy of the system is the information and data that flows through the infrastructure. Data and information enables risk decision-makers to self-regulate and self-report. Data and information This includes and is not limited to: incidents including regulatory/code incidents, operational risk incidents, cybersecurity incidents, people incidents and financial incidents; complaints conflicts of interest quality assurance, audits, and file reviews (underwriting, claims and broking) control testing outcomes risk profiling obligation management remediation and rectification activities training risk committee meetings business operational data attestations The cadence of compliance must be documented Documentation helps you demonstrate whether or not you are complying with the general obligations. When you document your measures, we [ASIC] expect this will include details of who is responsible, the timeframes involved and associated record keeping and reporting. (ASIC RG 104.26) In addition a documented cadence of compliance: supports training and education for staff, authorised representatives and service suppliers; provides assurance to management, […]
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AFS Licensees must provide website addresses to ASIC to protect against scams

Names, licence numbers and websites of Australian Financial Services (AFS) licensees are increasingly being impersonated online, exposing consumers to scams. To combat this, in April 2026 ASIC decided that AFS licensee website addresses should be added to the AFS licensee professional register. These websites addresses will be published on the ASIC Professional Registers Search (PRS) from June 2026. Listing website addresses will enable consumers and businesses to check that they are dealing with genuine AFS licensee websites and combat impersonation scams where criminals copy the name and licence details of AFS licensees to create fake websites. From 4 May 2026, ASIC will begin to collect AFS licensee website addresses for all existing AFS licensees via the Regulatory Portal on a voluntary basis. If an AFS licensee provides ASIC with its website addresses (or confirms that it does not operate a website) then they must keep those details up to date. For example, an AFS licensee must inform ASIC, in relation to the websites used to carry on its financial services business, when it starts operating a website, stops using a website address it previously listed, or changes its principal website address. Key actions for AFS licensees Prepare Check that the AFS licensee’s Regulatory Portal ongoing contact person details are up to date so that it receives emails from ASIC about this change. If the AFS licensee uses more than one website address to carry on its financial services business, it should select one to nominate as the ‘principal’ website address. Provide Log into the Regulatory Portal and provide ASIC with the AFS licensee’s website addresses used to carry on its financial services business. See ASIC FAQ for guidance on which website addresses to provide and what format to provide them in. Update If an AFS licensee provides ASIC with its website addresses (or confirms that it does not operate a website) then they must update ASIC within 10 business days if their website addresses used to carry on their financial services business change or they start operating a website. Late fees will apply for changes provided after 10 business days. What will ASIC publish on the Professional Registers Search (PRS) webpage? ASIC will display an AFS licensee’s principal website address (or the fact that they do not have a website) prominently on the PRS. Any additional website addresses the AFS licensee provides will appear lower down in an expandable section. Why this matters Make it easier to spot AFS licensee impersonation websites and reduce investment scam losses. Help detect and disrupt scam websites that misuse AFS licensee details. Support other agencies and businesses to verify website addresses as part of a broader anti-scam effort. Align ASIC’s AFS professional register with approaches used by other international regulators. Disclaimer: Reproduction of statements made in this article by media outlets, whether in full or in part, is strictly prohibited without the written express consent of the author. The views, opinions, and positions expressed within this article are those solely of the author and […]
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The General Insurance Code Governance Committee – role and responsibilities

The General Insurance Code of Practice is monitored and enforced by the Code Governance Committee (CGC) (paragraph 165 GI Code). The CGC’s constitution, functions and powers are set out in its Charter (paragraph 166). The CGC comprises: a consumer representative – Julia Davis an industry representative – Dallas Booth an independent chair – Veronique Ingram The Code Governance Committee Association Inc. (Association) powers and obligations are set out in the Charter (clause 5 Constitution). A management committee is responsible for controlling and managing the affairs of the Association. (clause 7 Constitution) CGC Charter The Code Governance Committee (CGC) is a committee of the Code Governance Committee Association Inc. The CGC is responsible for (Charter clause 1.2): (a) providing stewardship of the Code by helping the general insurance industry understand and comply with the Code; (b) identifying areas for improvement of insurance practices; (c) liaising with the ICA on relevant matters; (d) providing quarterly reports to the ICA Board; (e) publishing an annual public report containing aggregate industry data and consolidated analysis on Code compliance The CGC is also responsible for monitoring and enforcing compliance with the Code through (Charter clause 1.3 ): (a) investigations, analysis of data, analysis of evidence and stakeholder engagement; (b) receiving, investigating and making decisions about alleged breaches and giving Code Subscribers the opportunity to respond to any allegations that they have breached the Code; (c) considering whether it is more appropriate for ASIC or another enforcement agency to investigate an alleged breach of the Code; (d) agreeing with Code Subscribers on any corrective measures to implement within an agreed timeframe; (e) imposing sanctions; and (f) publishing breach decisions on a de-identified basis. The CGC is responsible for monitoring and enforcing compliance with the Code in the manner set out in the Code. Without limiting the CGC’s Code functions and powers, the CGC may for the purposes of monitoring compliance with the Code (Charter clause 4): (a) make reasonable requests for a Code Subscriber and/or the Service Provider to provide access to information, documents and systems, which the CGC considers necessary to discharge its functions; (b) seek independent professional legal, accounting or other advice; (c) request each Code Subscriber to lodge an annual data return and survey reporting on their compliance with the Code; and (d) enter into appropriate arrangements with the Service Provider or AFCA for the purpose of facilitating: (i) information exchange relevant to the CGC’s functions; and (ii) referrals to the CGC of an allegation that a Code Subscriber has breached the Code Additional powers CGC investigate Code Compliance (Charter clause 5) consider Code breaches (clause 5.3) and make breach decisions (5.4) impose sanctions (6.1) report Significant Breaches or serious misconduct to ASIC (6.2) publish significant breaches (7.1) publish an Annual report and provide to ICA Board and AFCA Board (9.2) develop policies, guidelines, reporting forms and operating procedure consistent with the Charter and Code (10) CGC reviews Upcoming review Motor insurance claims handling CGC are currently scoping a targeted review into motor […]
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Insurance brokers – general or personal advice – what is the difference?

I continue to receive questions from general insurance brokers on the difference between general advice and personal advice. Personal advice is where the provider of the advice has considered one or more of the person’s objectives, financial situation and needs or a reasonable person might expect the provider to have considered one or more of those matters. (my emphasis) It is important to note that general advice is narrow in application and ASIC and the Court will adopt an approach of ‘substance over form’ as to whether general or personal advice has been provided. That is, providing a general advice warning does not mean that financial product advice is general advice per se, an examination of the facts and circumstances is required. This question was revisited by the High Court of Australia Westpac Securities Administration Ltd v Australian Securities and Investments Commission [2021] HCA 3. Also refer to ASIC media release 21-013MR Corporations Act Section 766B(3)(b) of the Corporations Act 2001 (Cth) defines “personal advice” so as to include “financial product advice” given or directed to a person in circumstances where a reasonable person might expect the provider to have considered one or more of the person’s objectives, financial situation and needs. Section 766B(4) defines “general advice” as financial product advice that is not personal advice. As the High Court stated [T]he division of the universe of financial product advice into “personal advice” and “general advice” serves to organise the obligations owed by a financial product adviser to a retail client, with more onerous obligations being imposed upon the adviser where the circumstances are apt to suggest to the client that the financial product, the subject of the advice, is appropriate to the particular circumstances of the individual client. Circumstances Westpac Bank subsidiaries, Westpac Securities Administration Limited (WSAL) and BT Funds Management Limited (BTFM), conducted two telephone campaigns by the Westpac companies which recommended that customers roll out of their other superannuation funds into a Westpac-related superannuation account. As a result of the campaigns, Westpac increased its funds under management by almost $650 million between 1 January 2013 and 16 September 2016. The High Court confirmed that WSAL and BTFM breached financial services laws, including the requirement to act in their clients’ best interests and the requirement to act honestly, efficiently and fairly. The unanimous High Court judgment upheld the Full Federal Court decision regarding the conduct of WSAL and BTFM, dismissing their appeal and holding that they breached the Corporations Act by providing personal financial product advice in calls made to 14 customers. Neither company was licensed to provide personal financial advice. Judgment In the judgment, Justice Gordon reinforced that s766B(3) of the Corporations Act, which outlines the meaning of general and personal advice, ‘is directed to the protection of the retail client’ and clarified that ‘[…] the general advice warning must be assessed in light of all the circumstances. The general advice warning was given only once, at the beginning of the telephone conversation. Members were subsequently asked […]
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Complaints in General Insurance – RG 271 – what must you comply with?

AFS Licensee’s must; have a dispute resolution system (process) that complies with standards and requirements made or approved by ASIC and covers complaints made by [retail] clients in connection with the provision of the financial services; and, be a member of AFCA. (refer s912A(1)(g) and (2) Corporations Act). The licensee’s IDR must include complaints against representatives including authorised representatives. It follows that authorised representatives must immediately notify the licensee about the complaint. In addition, subscribers to the GI Code of Practice and Insurance Brokers Code of Practice must comply with parts 11 and 9.0, respectively. Understanding the nuances of RG 271 – enforceable paragraphs The general obligation for IDR in section 912A(1) gives rise to a legal obligation imposed on the Licensee. However, the legal requirement only applies to the enforceable paragraphs in RG 271and not all paragraphs RG 271. Any paragraph that is not identified by ASIC as an ‘enforceable paragraph’ in RG 271 is regulatory guidance only and not a legal requirement. (refer RG 271.8 and RG 271.9) What are the enforceable paragraphs of RG 271 for general insurance? definition of complaint RG 271.27 – RG 271.29 (including note) posts (that meet the definition of ‘complaint’ set out in RG 271.27) on a social media channel or account owned or controlled by the financial firm that is the subject of the post, where the author is both identifiable and contactable RG 271.32 small business complaints RG 271.36 outsourcing IDR processes RG 271.48 what an IDR response must contain RG 271.43- RG 271.54 (including notes) when an IDR response must be provided by RG 271.56 – RG 271.60 (including note) complaint management delays RG 271.64- RG 271.66 (including notes) complaints closed within five business days of receipt RG 271.71 IDR response within 5 business days RG 271.75 the role of customer advocates RG 271.109- RG 271.110 (including note 1) links between the IDR process and AFCA RG 271.111- RG 271.112 how to manage systemic issues RG 271.118- RG 271.120 (including note) accessibility of IDR process RG 271.134 no charges or detriment RG 271.141 resourcing and staff numbers RG 271.142 – RG 271.143 empowering staff and financial delegations RG 271.146- RG 271.147 maximum IDR timeframes and closing complaints RG 271.163 and RG 271.165 policy and procedures RG 271.172 data collection, analysis and internal reporting RG 271.179 report complaints data internally and publicly RG 271.183 Disclaimer: Reproduction of statements made in this article by media outlets, whether in full or in part, is strictly prohibited without the written express consent of the author. The views, opinions, and positions expressed within this article are those solely of the author and Compliance Advocacy Solutions Pty Ltd and not the views of other individuals, companies or organisations they may be affiliated with. The author and Compliance Advocacy Solutions Pty Ltd make no representations as to accuracy, completeness, currency, suitability, or validity of any information in this article and will not be liable for any errors or omissions or any loss or damage arising from […]
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Obtaining an AFS Licence for general insurance

I’m often asked to outline what is involved in obtaining an AFS Licence in Australia for general insurance. I have assisted many people to obtain a new AFS Licence, vary an existing Licence and add new responsible managers. The process to obtain an AFS licence to provide general insurance services or products is not overly complex however, it is time-consuming and labour-intensive, as ASIC’s information requirements are specific. All AFS licence applications (new and variations) must be submitted via ASIC’s online regulatory portal. I assist my clients in setting their business up in the portal and providing me with access so that I can facilitate the application for them. My typical clients requiring a new AFS licence include: insurance brokers who are currently authorised representatives; people who want to operate an Underwriting Agency in Australia (including Lloyds coverholders); foreign companies that want to provide financial services in Australia; and people wanting to provide claim services either for insurers (insurance claim managers) or insureds (claimant intermediaries) I manage AFS Licence variations (including adding responsible managers) for insurers, brokers, underwriting agencies, claim service providers and anyone who currently has an AFS Licence for general insurance products Typical general insurance authorisations AFSL authorisations relevant for general insurance are: providing financial product advice including general financial product advice only; dealing including issuing (when acting on behalf of insurers) and dealing on behalf of another person (insurance brokers including obtaining the use of restricted broker terms); and claims handling and settling services on behalf of insurers or on behalf of an insured. The financial services can be provided to Retail and/or Wholesale clients. The AFS Licence application process The process for a new AFS Licence application is more involved and complicated than a licence variation. This example deals with a new AFSL application however I can assist you with information requirements and the process for variations on request. Contact me here ASIC provides guidance on the process and information requirements in RG 1 and INFO 294. People requirements Information must be provided to ASIC on your fit and proper people and your responsible managers. Fit and Proper people Section 913BA of the Corporations Act requires that, before a licence is granted, ASIC must be satisfied that there is no reason to believe that certain people involved in the management or control of your financial services business are not ‘fit and proper persons’ to undertake that role. You will need to include details of your fit and proper people in the application (refer RG 1.138 – 1.166). A fit and proper person is your ‘officers’ and this is defined in section 9 Corporations Act, relevantly to include: a director or secretary of the corporation; or person: (i) who makes, or participates in making, decisions that affect the whole, or a substantial part, of the business of the corporation; or (ii) who has the capacity to affect significantly the corporation’s financial standing; or (iii) in accordance with whose instructions or wishes the directors of the corporation are accustomed to act […]
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The problem with cash settlements – a blight on our industry

Typically, for home building claims, a cash settlement payment is offered as a settlement option when a repairer can’t guarantee repairs due to concurrent wear & tear or maintenance issues. Under paragraph 86 of the GI Code of Practice, insurers who have authorised repairs must accept responsibility for the quality of the builders work and the materials they use. This clause has led to an unfair practice of offering cash payments as a first resort. Most customers aren’t aware of their rights at law and under the GI Code, and simply accept the cash settlement offer. Problems arise when repair costs escalate (due to the rising cost of living or petrol cost increases and commensurate impact on supply chain) and the risks associated with project managing repairs. The standard claims settlement process appears to be that whenever there is a mix of covered damage and damage caused due to wear and tear or lack of maintenance, there is a default to a cash settlement payment. This position is difficult to reconcile when the same builder (under the guise of an expert report) has clearly been able to distinguish between storm damage and wear & tear/maintenance and provides a causation report. Most consumers don’t want the inconvenience of having to arrange repairs, coordinate trades and generally project management the work. A simple solution would be to provide the customer with the option of being provided with a detailed Scope of Works itemising insurance covered work and excluded work. The Code guarantee would be provided for the insurance covered work with the customer acknowledging their liability and payment for excluded work. Regulatory view of cash settlements (and cash settlement fact sheets) Cash settlements and cash settlement fact sheets (CSFS) remain on the radar of regulators. ASIC We will review general insurers’ use of cash settlements to better understand the practices and disclosures surrounding the offers being made and to assess whether there are risks of consumer harm. ASIC Corporate Plan 2025-2026 Code Governance Committee As part of our 2024-25 workplan, we committed to reviewing the information insurers provided to customers on cash settlements and the processes they follow when deciding to offer a cash settlement. We note that, in the Industry Action Plan, insurers have committed to a range of actions to address recommendations relating to cash settlements. We also note ASIC’s recent report, finding that insurers need to provide better information to consumers around cash settlements. We will review what information insurers provide to customers, and what information those customers need to make effective decisions around cash settlements. CGC Priorities 2025-26 Cash Settlement Fact Sheets An insurer, underwriting agency or TPA acting on behalf of either must provide a cash settlement fact sheet where: the financial service is claims handling and settling; and the service is offering to settle all or part of a claim under a general insurance product using a cash payment; and the customer is a retail client; and the PDS provides repair or replacement as settlement options. […]
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ASIC’s approach to Civil Penalties – Reshaping General Insurance Conduct

The power of enforcement – ASIC’s perspective In the Enforcement session opening speech by ASIC Deputy Chair Sarah Court at the ASIC Annual Forum, 13 November 2025, the following example was provided as ‘the power of enforcement.’ I want to start though, with a reflection on ASIC’s enforcement posture. We are often asked why ASIC needs to take a strong enforcement approach. The suggestion seems to be that we should rather call out the issue of concern, allow the firm involved to remedy it, and avoid the cost and uncertainty of court-based litigation. Apart from the obvious answer that we are not, and never will be, the compliance arm of large corporations, the following example is telling. ASIC Commissioners are frequently guests around board tables where we engage with directors and senior executives about the important work that we do. At one recent such engagement I mentioned a 2023 ‘pricing promises’ case ASIC had taken against insurer RACQ. RACQ ultimately admitted to this misconduct, which involved misleading documents sent on millions of occasions, to nearly half a million customers. They collectively missed out on some $86m worth of discounts. A significant penalty was imposed, and there was widespread media attention. A woman at the board table was a former senior executive of another insurer. While that insurer had long been aware of pricing promise issues and the potential for problems of its own, until that point those problems had been secondary. Following this court action, she said the focus changed overnight. There was an immediate review of all pricing promises, whereupon widespread irregularities were discovered. What was interesting about this swift reprioritisation was the broader industry context. The sector was well on notice of ASIC’s concerns on this issue, and there was widescale remediation in place. Despite that fact it was only court action against another like firm that finally prompted this insurer to review, reprioritise and remediate. Therein lies the power of enforcement. Civil penalties as an enforcement action in General Insurance Over recent time, ASIC has commenced the following Federal Court proceedings seeking civil penalties: IAL penalised $40 million over pricing discount failures ASIC alleges QBE misled customers over pricing discounts ASIC takes court action alleging RACQ sent half a million misleading insurance renewal comparisons Cbus ordered to pay $23.5 million penalty for serious failures in processing members death benefits and insurance claims It should be noted that CBus was a superannuation matter.. Legal principles relevant to orders sought by agreement in regulatory proceedings O’Callaghan J. in Australian Securities and Investments Commission v United Super Pty Ltd [2025] FCA 1453 summarised the position: [8] There is an important public policy involved in promoting predictability of outcome in civil penalty proceedings.  The practice of receiving and, if appropriate, accepting agreed penalty submissions increases the predictability of outcome for regulators and wrongdoers.  Such predictability of outcome encourages corporations to acknowledge contraventions, which, in turn, assists in avoiding lengthy and complex litigation and thus tends to free the courts to deal with other […]
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Take care with using certain words and terms in General Insurance

Insurance brokers, Underwriting Agencies, TPAs, Claimant Intermediaries and Service Providers must take care in the use of certain words that are either restricted or their use may lead to misleading or deceptive conduct. Use of words “insurance” and “insurer” Section 114 Insurance Act places restrictions on the use of the words ‘insurer’ and ‘insurance’. This is relevant for discretionary mutual funds and warranties. Use of the word “insurance” A person commits an offence if the person carries on a business or is proposing to carry on a business; and the person uses the word insurance to describe (expressly or by implication) a product or service that the person supplies, or proposes to supply, in the course of carrying on the business; and the product or service is not insurance; and it is likely in all the circumstances (including the use of the word insurance ) that the product or service could be mistakenly believed to be insurance. Use of the word ‘insurer’ Use of the word “insurer” A person commits an offence if the person carries on a business or is proposing to carry on a business; and the person uses the wordinsurer to describe (expressly or by implication) the person in connection with a product or service that the person supplies, or proposes to supply, in the course of carrying on the business; and either: the product or service is not insurance; or the person would breach a requirement mentioned in subsection (3) [need to be authorised to carry on insurance business] if the person supplied the product or service in the course of carrying on the business; and in a case where the product or service is not insurance–it is likely in all the circumstances (including the use of the wordinsurer ) that the product or service could be mistakenly believed to be insurance. Insurance brokers receiving commissions, remuneration or benefits from insurer or underwriting agency Brokers who receive commissions, remuneration or benefits from an insurer or underwriting agency are not permitted to use the word independent , impartial or unbiased. Refer Section 923A Corporations Act Insurance brokers – restricted terms A person may only use the following terms if authorised by a condition on their AFS Licence: insurance broker, insurance broking or general insurance broker (Section 923B Corporations Act) Restricted terms in Advertising financial products and services Care should be taken when using certain terms and phrases in an advertisement, particularly where the way those terms and phrases are used is not consistent with the ordinary meaning commonly recognised by consumers (e.g. ‘free’, ‘secure’ and ‘guaranteed’). RG 234.91 Inappropriately using terms and phrases can: create expectations that cannot be met; indicate a certain level of security that does not exist; and indicate different levels of protection and different levels of risk. The use of such terms may lead to misleading or deceptive conduct. Use of technical language and industry jargon in advertising Industry concepts or jargon may not be well understood by many consumers and should be […]
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