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General Insurance Brokers – what fee can I charge? A compliance perspective

As more and more Insurance Brokers move away from a commission only based remuneration model to charging client fees, questions arise around obligations in respect of fees. Principles of equity and indemnity apply to the charging of fees however regulations and the brokers Code also apply. Providing financial services efficiently, honestly and fairly. The overarching general obligation for AFSL Licensees to provide financial services to clients ‘efficiently, honestly and fairly’, extends to the systematic practice of charging fees. The phrase (‘efficiently, honestly and fairly’) has been subject to significant judicial analysis, it is clear that the general obligation of a Licensed insurance broker and their [authorised] representatives means that they must, relevantly: perform their functions to a reasonable standard of performance by an insurance broker that the public is entitled to expect; a broker must be ethically sound; and includes where a licensee pursues its own self-interest and disregards the best interests of its clients . Conflicts of interests An AFS Licensee must adequately manage its conflicts of interests. (refer RG 181 Section B) Insurance brokers have a fiduciary duty to their clients. Subject to any terms governing the fiduciary relationship including Terms of Engagement, a broker will need to act in the client’s best interests, prioritise their interests, not profit without consent, and address any conflicts. A broker must take this duty into account when complying with its conflicts management obligation. This will also inform the adequacy of their conflict management arrangements. (ASIC RG 181.22) Best interests obligations An insurance broker (includes licensees and authorised representatives) providing personal advice to a retail client must act in the best interests of the client. This duty requires the broker to have: identified the objectives, financial situation and needs of the client in respect of the subject matter; identified the subject matter of the advice; and make reasonable enquiries to obtain complete and accurate information relevant to the client’s circumstances. This activity should be included in the factors for calculating the fee in addition to arranging the insurance cover, policy administration and claims advocacy. FSG AFS Licensees and, independently their authorised representatives, must provide a FSG to a retail client before providing their financial services (i.e. before any advice is provided). The FSG must be up to date and contain information about the remuneration being received for providing the services. ASIC INFO 291 is informative Information about remuneration should be presented in one location and in a way that is easy for the client to understand, consistent with the requirement when a client requests more detailed remuneration information in regulations 7.7.04A(4) and 7.7.07A(4). This could include ranges, rates, comparisons, simple tables and formulas. Price fixing and Bid rigging Under the Competition and Consumer Act, cartel activity is illegal. Types of cartel activity include price fixing and bid rigging: A broking practice must not collude with another unrelated broking pratice(s) in connection with the fees being charged or proposed to be charged. Price fixing Competing businesses must not agree to fix, control or […]
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ASIC cancels AFS Licence for serious and sustained breaches of duties – lessons for general insurance

𝐭𝐡𝐞 𝐢𝐦𝐩𝐨𝐫𝐭𝐚𝐧𝐜𝐞 𝐨𝐟 𝐚𝐝𝐞𝐪𝐮𝐚𝐭𝐞 𝐜𝐨𝐦𝐩𝐥𝐢𝐚𝐧𝐜𝐞 𝐦𝐞𝐚𝐬𝐮𝐫𝐞𝐬 ASIC has cancelled the Australian financial services (AFS) licence of securities dealer Pulse Markets Pty Ltd (Pulse Markets), effective from 11 February 2026. (ASIC Media Release 26-027MR) The licence was cancelled after ASIC found Pulse Markets had serious and sustained breaches of its duties under s912A of the Corporations Act 2001. These included Pulse’s failure to adequately supervise its corporate authorised representatives (CARs) providing financial services under its AFS licence, increasing the risk they will not comply with financial services laws and put clients at risk of financial loss. ASIC found that Pulse Markets failed to comply with its obligations, including failure to: maintain the competence required to provide the financial services it offered take reasonable steps to ensure that its representatives comply with the financial services laws by failing to: – undertake appropriate due diligence prior to the appointment of its CARs; – take adequate steps to monitor the websites and marketing of its CARs; – maintain adequate compliance, breach and incident registers; – and maintain compliance manuals with accurate information about AFS licence authorisations ensure adequate resources, including staffing, to provide the financial services covered by the licence and to carry out supervisory arrangements prepare and lodge financial statements (being a balance sheet and a profit and loss statement) for financial years 2024 and 2025 obtain an opinion by a registered company auditor regarding Pulse Market’s compliance with the financial conditions on their licence for the financial years 2024 and 2025 pay its Industry Funding Levy for the 2023-2024 financial year. Pulse Markets may apply to the Administrative Review Tribunal (ART) for a review of ASIC’s decision. Pulse Markets is a Queensland-based securities dealer and has held AFS licence number 220383 since 7 June 2002. The licence authorised Pulse Markets to provide financial product advice, deal in financial products and underwrite an issue of securities, for wholesale clients. Lessons for General Insurance It should be noted that Pulse Markets provided financial services to Wholesale clients. This case demonstrates that while firms operating in general insurance providing services to Wholesale Clients (typically Underwriting Agencies offering casualty or specialist general insurance products), don’t have some of the disclosure or other obligations of firms providing services to Retail Clients, they still have obligations that must be documented and managed. In addition, Authorised Representatives must be subject to due diligence, onboarding and ongoing monitoring and supervision irrespective of whether providing general insurance services or products to Retail or Wholesale Clients. The case also highlights the importance of documenting compliance measures for both the AFS Licensee and their authorised representatives. The documents should be tailored to the business of the licensee and its authorised representatives (and not an off-the-shelf manual) and be suitable to use in staff training and development and sharing with business partners. Typical documents for small-medium sized insurance brokers, underwriting agencies and TPA’s are: Risk and Compliance Manual; and Monitoring Program Insurers and larger firms require a taxonomy of risk and compliance documents (framework) […]
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Applying for motor insurance – a review by the General Insurance CGC

The General Insurance Code Governance Committee (CGC) has called on insurers to improve transparency and communication with customers after a review of online applications for motor vehicle insurance. The review looked at how 13 insurers handle online applications across 58 motor insurance brands. Authors note: the Design & Distribution obligations (inlcuding making a TMD available) together with Australian financial services laws requirements assists in understanding why there is a large number of brands compared to a smaller number of insurers. The review found that insurers could be doing more to clearly explain to customers why they ask for certain personal details. The report noted that some insurers could not demonstrate how some questions in the applications were relevant to their decisions. The review also found that when insurers decline to offer insurance, customers are often left with vague or confusing messages that do not clearly outline the reasons or what they can do next. Executive Summary The CGC found that: Insurers often ask for personal information, such as relationship or employment status, without clearly explaining why it is needed or how it affects the outcome. When insurers decide not to offer cover online, the messages provided are frequently vague, unhelpful, or lack guidance on next steps. Some underwriting practices, such as excluding applicants based on past bankruptcy or a lack of prior insurance, may unfairly penalise otherwise low-risk customers. Most insurers are meeting their Code obligations relating to declined applications, with some demonstrating best practice by including tailored explanations and clear guidance for declined applicants. Greater transparency, fairness, and relevance in data collection and decision-making will help insurers meet their obligations under the Code and improve the customer experience. Insurers do not always explain the relevance of their questions clearly to customers The Code obligations: When an insurer is unable or unwilling to explain the relevance of a question, it breaches its commitments to transparency and fairness in the Code (Paragraph 21). This also means the CGC cannot be satisfied the insurer is meeting its obligation to only ask for and rely on relevant information (Paragraph 45). Authors Note:failure to explain the relevance of a question, may impact the insurer’s reliance on an insured’s failure to meet their duty to take reasonable care not to make a rmisrepresentation. What the CGC found: CGC reviewed the online motor insurance application forms of 13 insurers. For six of these insurers, CGC had no concerns with the relevance of the questions they asked. However, for the remaining seven, CGC identified several types of questions where the relevance to the decision to provide motor insurance was not made clear to customers. These included questions about: Relationship status Employment status and occupation Ownership of other vehicles. The CGC noted – [w]here possible, insurers should request information directly, rather than making inferences or assumptions based on indirect questions. By asking specific and direct questions, insurers treat customers more fairly, based on their individual circumstances, and are more transparent about why the information is being requested The […]
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ASIC renews guidance on managing conflicts of interest in financial services – RG 181

ASIC has updated its regulatory guidance on managing conflicts of interest for Australian financial services businesses. One of the general obligations of an AFS Licensee is to have in place adequate arrangements for the management of conflicts of interest that arise from the licensees financial services (or from the services provided by the authorised representative of the licensee). Section 912A(1)(aa) Corporations Act. This obligation is a civil penalty provision. Action required Licensees should review their arrangements (and those of their authorised representatives) for identifying, raising and managing conflicts of interest, against the updated RG 181, specifically update Risk & Compliance Manual and/or Conflicts of Interest Policy; update conflicts of interest training modules; and update monthly attestations. It would be timely for Licensees to reiterate Conflicts of Interests obligations with staff and ARs based on the updated RG 181 and to submit any fresh conflict of interest declarations using the Appendix to RG 181. The Appendix provides a catalogue that outlines some key legal obligations and information relevant to conflicts management that may apply to an AFS licensee, representative, or AFS licence applicant. Key updates in the revised RG 181 include: how the law applies to conflicts of interest, including the scope of the conflicts management obligation and links to other related obligations the types of conflicts AFS licensees should identify and manage the need for robust, tailored arrangements to manage conflicts practical steps for effective conflict management, and a non-exhaustive ‘catalogue’ of related legal obligations and information. Scope of the obligation The conflicts management obligation is broad and is intended to apply widely—it is not limited in its application. It applies to all conflicts of interest other than those wholly outside (i.e. completely separate to) the financial services business of you or your representative. It applies to conflicts of interest that arise within the financial services business. It also applies to conflicts that arise between something within the financial services business and something outside it, particularly where the relationship, interest or activity may affect (or reasonably appear to affect) how financial services are provided by the business. For example, an employee prioritising their competing personal or financial interest outside the business may affect how they provide financial services within the business, as well as the quality of the services they provide. What is a conflict of interest? A conflict of interest can arise where there are competing financial interests, personal interests, business or related party interests—whether direct or indirect—or competing loyalties and obligations. In some circumstances, a combination of these may give rise to a conflict. You should take a ‘common-sense’ and objective approach to determining if there is a conflict of interest. Whether there is a conflict of interest will ultimately turn on the facts and circumstances of a situation. Conflicts of interest can be: (a) actual—where a conflict currently exists that could sway your judgement or actions (or those of your representatives); and (b) potential—where circumstances do not currently give rise to an actual conflict but could reasonably […]
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Looking ahead to 2026 – key regulatory compliance impacts for General Insurance

Key areas of focus for 2026 AFCA Claims handling Approach – consultation on AFCA’s Approach to general insurance claims handling has closed. The new Approach is expected to be released shortly. Insurers have key obligations under the Insurance Contracts Act 1984 (Cth), including the duty of utmost good faith, which requires them to handle insurance claims fairly, transparently, and efficiently. This Approach provides information about how AFCA considers various types of complaints relating to the handling of general insurance claims, against an insurer’s legal obligations and has regard to industry standards. Cash Settlements. In ASIC’s Corporate Plan 2025-26 – 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. CAsh Settlements were also called out as an area of 2026 focus by the Code Governance Committee and in AFCA’s [new] Claims Handling Approach. Industry use of external experts. has highlighted improvements in how insurers oversee and engage external experts, with better measures to strengthen accountability and quality assurance. The CGC, in its Oversight of external experts: follow up 8 December 2025 has identified areas of ongoing work. Pricing promises and pricing transparency. ASIC Corporate Plan 2025-26 We will examine the accuracy and transparency of general insurers’ disclosures about premiums and work to better understand consumer experiences. Complaints (IDR). In 2024, ASIC reviewed 11 general insurers to understand how they are supporting customers who make a complaint. ASIC’s Report 802 highlighted a failure to identify 1 in 6 complaints and a lack of identifying systemic issues. ASIC has also indicated that it will be moving to publishing IDR data at a firm-level (refer CP 383). The General Insurance Code Governance Committee highlighted complaints handling as a main priority for 2025-26. The Insurance Brokers Code Compliance Committee in their Annual Report 2024-25 found 42% of brokers reported no breaches or complaints Incident and Breach Reporting. ASIC’s review of reportable situations (4th December 2024) revealed a number of poor practices among licensees including deficiencies in Licensee’s incident mangement. The Insurance Brokers Code Compliance Committee in their Annual Report 2024-25 found 42% of brokers reported no breaches or complaints Privacy changes were introduced in December 2024 with automated-decision making to be regulated by December 2026. The OAIC launched a new Notifiable Data Breaches (NDB) statistics dashboard 4 November 2025. Additional changes are contemplated to the Privacy Act. CPS 230 – operational resilience and BCPs. The new prudential standard CPS 230 introduces strict requirements for insurers to strengthen operational resilience, meaning they must effectively manage operational risks and ensure continuity of critical functions during and after a disruption event and oversee “material service providers” such as claims processing and underwriting agencies. APRA will conduct a review of the large insurers during 2026 with learnings shared for all other insurers and there material servcie providers. GI Code of Practice. The insurance Council of Australia and insurers are moving to the next stage of the development […]
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AFCA’s updated Approaches to family violence and elder financial abuse – General insurance

AFCA have published its updated Approach to family violence and Approach to financial abuse of older people following a comprehensive consultation process. AFCA have: expanded and refreshed the Approach to family violence, which will replace AFCA’s existing Approach to joint accounts and family violence revised and updated the Approach to financial abuse of older people, which will replace the superseded Approach to financial elder abuse. I have extracted the parts of the Approaches relevant to General Insurance however the full Approaches should be considered and can be accessed here. The AFCA Approach to family violence What is family violence? The Family Law Act 1975 (Cth) defines family violence as: “…violent, threatening or other behaviour by a person that coerces or controls a member of the person’s family (the family member),or causes the family member to be fearful.” Family violence can have serious and lasting effects on a person’s physical, psychological and financial wellbeing. These impacts may compound over many years. Family violence impact does not necessarily end when the relationship does. In some cases, it can begin or escalate after the relationship has ended. Family violence refers to both intimate partner violence and violence between family members. This includes (but is not limited to): physical, psychological, sexual and emotional abuse coercive control financial abuse parental or elder abuse General insurance Family violence in the misuse of insurance products is a growing risk. Insurance policies can be exploited to perpetrate abuse by changing or cancelling policies, changing beneficiaries, restricting access to information, interfering with the claims process, or preventing victim-survivors from obtaining a payout. Warning signs of potential family violence and financial abuse There are warning signs that a customer may be experiencing family violence and/or financial abuse specific to insurance products. These may include when one policyholder may: not understand, or is not aware, that: > cover has been taken out in their name or covering their property > they have been removed from a policy or the policy has been cancelled by a joint policyholder have concerns about protecting their personal privacy or safety or the security of their policies be reluctant to involve the other joint policyholder when making changes to the policy, making a claim or seeking hardship assistance. Warning signs that a policyholder may be a perpetrator of family violence include that they: ask questions about a joint policyholder’s behaviour or activities request to remove the other joint policyholder from a policy or claim are reluctant to involve the other joint policyholder when making changes to the policy, making a claim or seeking hardship assistance. Common issues that may arise In the context of insurance, issues that may arise with jointly held policies in situations involving family violence, include: cancellation of the policy by one policyholder payment of benefits under a jointly held policy disadvantage to innocent co-insured by a perpetrator’s failure to disclose perpetrators forcing victim-survivors to pay an excess following an accident policies that may exclude damage to property by the perpetrator of family […]
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Disclosure documents – it’s all about the timing (and content)

I’m often asked when must a certain document be provided to a client? Disclosure documents for general insurance generally have have 2 requirements: content requirements; and timing requirements This article will focus on the timing requirements. Customer/client journey The simplest way to think about the timing requirements for disclosure documents is to think about the various customer touchpoints or the customer journey. Insurance brokers often send an important noticedocument when invoicing clients containing all relevant information such as FSG, general advice warning, duty to take reasonable care, duty of disclosure etc. While convenient, care should be taken with this approach to ensure the regulatory timing requirements are met Code requirements Brokers and insurers (including underwriting agencies, TPAs and other material service providers) also have requirements under respective industry Codes to provide certain information at a specific time. The customer/client journey should not only be mapped out to cover regulatory disclosure documents but should also pick up Code requirements such as providing a Terms of Engagement (brokers). The regulatory disclosure cycle It should be noted that disclosure documents are only required to be provided to Retail clients however it is common practice for a FSG to be provided to both retail and wholesale clients. A TMD is not a disclosure document as it only must be made available by a product issuer before it distributes a general insurance product. The product issuer must make a TMD available and a distributor must not engage in retail product distribution conduct unless a TMD is available or not required (see RG 274). It’s important to note that a TMD is not only relevant for Retail clients. The test is whether a Retail client could purchase the product, even if intended for Wholesale clients. Let’s explore the disclosure documents relevant for general insurance based on the customer experience or journey. I’ve included the reference in the Corporations Act for the content requirements in case you wish to have a look at these requirements in addtiion to the timing requirements. FSG Obligation to give a FSG if financial services provided to a Retail client (s941A for licensees and s941B for authorised representatives) Timing of FSG (s941D) Content requirements (s942A – 942E including a combined FSG/PDS) A FSG must be given to the (retail) client as soon as practicable after it becomes apparent that the financial service will be, or is likely to be, provided to the client, and in any event must be given to the client before the financial service is provided. (s941C provides situations in which a FSG is not required). Practically speaking, the FSG will be provided before any financial product advice is provided, this means on appointment (for brokers) or at quote stage (for underwriters). A claimant intermediary must provide a FSG before they provide any claims handling settling services to the client (s941C(7A)). This is because they are acting on behalf of the insured. A claims manager, acting on behalf of the insurer, is not required to provide a FSG, as […]
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Complaints – the voice of the customer, but are you listening?

In 2024, ASIC reviewed 11 general insurers to understand how they are supporting customers who make a complaint. ASIC’s review focused on how general insurers are complying with select enforceable obligations in Regulatory Guide 271 Internal dispute resolution (RG 271). While ASIC’s review focused on general insurers, the findings in this report are relevant for all financial firms that must comply with RG 271, this includes Underwriting Agencies, Claim Managers (TPAs), Claimant Intermediaries and Insurance Brokers. ASIC‘s key findings included: Insurers failed to identify 1 in 6 customer complaints Insurers only identified 85 systemic issues from over 1.4 million complaints Insurers had immature systems for handling complaints and reporting on complaints 1 in 8 IDR responses for rejected complaints did not meet mandatory content requirements 1 in 5 delay notifications failed to meet mandatory content requirements All insurers failed to provide delay notifications within required timeframes The General Insurance Code Governance Committee highlighted complaints handling as a main priority for 2025-26. Respondents to our consultation raised significant concerns about how insurers identify and handle complaints. We raised our own concerns about the handling of complaints in our Industry Data and Compliance Report FY24, with the number of complaints increasing by 18%. The Insurance Brokers Code Compliance Committee in their Annual Report 2024-25 found 42% of brokers reported no breaches or complaints (that) suggests continued underreporting and issues with internal monitoring… These failures represent service gaps that can expose clients to risk. Regulatory requirements AFS Licensees, as part of their general obligations (refer s912A(1)(g) and (2) Corporations Act) must have a dispute resolution system that consists of: an internal dispute resolution (IDR) procedure that complies with the enforceable paragraphs of RG 271; covers complaints against the licensee (and representatives) in connection with the provision of the financial services; and be a member of AFCA. All AFS Licensees that provide financial services to retail clients must submit an IDR report to ASIC. Firms must submit an IDR report to ASIC every six months. The reporting periods are: 1 January to 30 June, and 1 July to 31 December. A two-month submission window opens at the end of each reporting period. Submission windows are: 1 January to end of February, and, 1 July to 31 August. Financial firms that had complaints during the relevant six-month reporting period must submit an IDR report through ASIC’s Regulatory Portal that contains an IDR data file in machine-readable format, consistent with the specifications in the IDR data reporting handbook. In a recent media release, ASIC has confirmed that it will proceed with plans to publish IDR data at firm-level. The IDR dashboard will be published later this year. Code Complaint requirements Part 11 of The GI Code of Practice applies to Retail Insurance products. In addition, it is available to an uninsured person making a claim against a customer who is insured under a Retail Insurance policy (see paragraph 60). Part 11 also applies to Wholesale Insurance products where you are entitled to Financial Hardship support under […]
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How to make General insurance compliance training effective for your people

Compliance training in general insurance is not only a legal and Code requirement, it is also necessary to ensure that you have adequate compliance measures and for an individual’s growth and development as they progress through their insurance career. Compliance training for front-line staff, compliance teams, responsible managers and boards is one of the core compliance services that I offer to my clients. Over the years, I have identified what works. How do you know whether your compliance training has been successful? The measures of success Some of the metrics that can be adopted to measure the success of your compliance training are: a sustained increase in the number of incidents and complaints being identified and reported internally; an increase in the level of complexity of compliance questions being asked by front-line staff; a decrease in issues that were previously identified as pain points; a desire to attend future compliance training; better customer conversations (as assessed by monitoring); feedback from post-training surveys aimed at engagement and knowledge retention; and an increase in the maturity of compliance discussions within business team meetings. Importantly, some metrics that should not be used to assess the success of your compliance training are: the number of CPD/CIP points attained or annual hours of training completed. ; and the cost of training per employee. However these metrics are useful for other purposes The key requirements to conducting successful compliance In my professional experience, the following are some of the strategies that I adopt to ensure successful compliance training outcomes: Target the audience – training on financial services laws is not a one size fits all approach. Training for front-line staff differs to training for senior management, responsible managers or the board. Similarily, training must be tailored for different groups such as IDR teams, Authorised representatives, claims staff, sales & underwriters, onshore teams v offshore based teams. Understanding the lens of your audience is critical in how you poistion the same topic but to different audiences. For example RG 271 training for a mature IDR team will be different to complaints training for front-line customer service and claims teams. Fun and engaging – when an invite to a compliance training session pops in to your diary it may not necessarily generate your enthusiasm especially when accompanied by the dreaded words ‘attendance is compulsory.’ I consider that I have a training duty to ensure that the time that a person spends with me is of value and justifies them spending time away from their important day-to-day job (which continues even in their absence). Reading through the verbiage of s912A(1) Corporations Act may not be everyone’s cup of tea however, ensuring that s912A(1) is presented and discussed in a fun and engaging manner through, for example, story telling and case studies will faciliate learning as part of an overall enjoyable experience; Story telling – story telling brings compliance to life. I have 40 years experience in general insurance and in the last 8 years (as Compliance Advocacy Solutions) have […]
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Advertising in general insurance – tips to avoid misleading or deceptive conduct

Misleading or deceptive regulatory obligations The Corporations Act prohibits engaging in conduct, in relation to a financial product or a financial service, that is misleading or deceptive or is likely to mislead or deceive (s1041H). Further, under the the ASIC Act, a person must not, in trade or commerce, engage in conduct in relation to financial services that is misleading or deceptive or is likely to mislead or deceive (s12DA). A breach of the misleading or deceptive conduct provisions is a Reportable Situation to ASIC unless: the breach has been rectified including consumer remediation within 60 days; and the number of impacted consumers is less than 10; and the total financial loss or damage to consumers is less than $1000. If a breach satisfies all these thresholds, it is not deemed reportable to ASIC. What is misleading or deceptive conduct? The key requirement is that the impugned conduct leads, or is likely to lead, a person into error. Advertising financial products and services (including insurance): Good practice guidance ASIC has developed good practice guidance (RG 234) to help promoters comply with their legal obligations to not make false or misleading statements or engage in misleading or deceptive conduct. The promoter will sometimes be the insurer, underwriting agency or broker but can also be a distributor or agent. ASIC’s guidance applies to advertising communicated through any medium in any form, including: magazines and newspapers radio and television; outdoor advertising, including billboards, signs at public venues, and transit advertising; the internet, including webpages, banner advertisements, video streaming (e.g. YouTube), and social networking and microblogging (e.g. LinkedIn); social media and internet discussion sites; mobile phone messages (e.g. SMS, MMS, text messages); product brochures and promotional fact sheets; direct mail (e.g. by post, facsimile or email); telemarketing activities and audio messages for telephone callers on hold; and presentations to groups of people, seminars and advertorials. Overview of Good practice guidance The following is extracted from RG 234, I have added general insurance context where relevant to do so. Returns, features, benefits and risks Advertisements for general insurance products should give a balanced message about the returns, features, benefits and risks associated with the product. Benefits should not be given undue prominence compared with risks. Warnings, disclaimers, qualifications and fine print Warnings, disclaimers and qualifications should not be inconsistent with other content in an advertisement, including any headline claims. Warnings, disclaimers and qualifications should have sufficient prominence to effectively convey key information to a reasonable member of the audience on first viewing the advertisement. Consumers should not need to go to another website (or other page of the website) or document (such as a PDS or TMD) to correct a misleading impression. Fees and costs Where a fee or cost is referred to in an advertisement, it should give a realistic impression of the overall level of fees and costs a consumer is likely to pay, including any indirect fees or costs. The premium, commission and government charges should be clearly identified. Comparisons Comparisons should […]
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