What “informed consent” means in practice
Clients should understand three facts before we share contact details: (1) Wealth Insurance is not providing personal product advice unless separately disclosed; (2) the licensee will have its own duties, fees and dispute resolution channels; (3) the client may decline the introduction or choose another licensee. Consent should be recorded in writing — email confirmation is acceptable for many engagements — and should capture the general nature of the referral (for example, business property insurance, personal life cover, or super consolidation).
Why we decline “warm handoffs” without scope
Pressure to “just introduce my friend to your broker” bypasses suitability assessment at the consulting stage. We ask for a short written brief of objectives and circumstances at a high level. If the matter is clearly outside our consulting competence — for example, complex derivatives — we say so early rather than passing the problem downstream.
Written consent artefacts
Email confirmation, signed forms or engagement-letter clauses can record consent. Files note the licensee category discussed and whether the client proceeded or declined.
Disclosure of referral benefits
Where permitted arrangements exist with licensees, we disclose material benefits in line with applicable requirements. Clients receive this before proceeding. Undisclosed referral economics undermine the educational role we take in settlement and cross-border work.
Handover artefacts we expect licensees to provide
- Financial Services Guide appropriate to the advice relationship
- Clear statement of fees and commissions
- Privacy collection notice
- Product Disclosure Statements before recommendations are acted upon
When we will not refer
We do not refer when clients lack capacity to engage, when we suspect fraud or when the requested product category does not match any licensee authorisation we can verify. We also pause when clients have not accepted that licensees may decline business based on their own AML policies.
Referrals are a handover, not a sales lead sold to the highest bidder. Licensees must treat referred clients properly after introduction — our consulting file closes at that point.
Record-keeping and file notes
We record the date of consent, the licensee category discussed, and whether the client declined or proceeded. If a client proceeds, we retain a copy of our introductory email for seven years unless a longer period is required for dispute resolution. We do not retain licensee SOAs or PDS acceptance — those belong in the licensee file. Internal reviews occur quarterly to sample referral files for completeness of consent artefacts.
Training and escalation
Staff who conduct client-facing consultations complete annual refreshers on advice categories and referral disclosure. Ambiguous cases — for example, a client requesting “investment migration” products — are escalated to senior consulting staff before any introduction. We would rather delay a referral by one week than introduce prematurely.
Comparing consent to a casual introduction
A casual WeChat introduction to “my broker friend” rarely includes disclosure of referral economics, licensee authorisations, or complaints rights. Documented consent forces clarity: the client knows Wealth Insurance is exiting the advice pathway, knows the licensee’s role, and can decline without damaging the consulting relationship. We have seen clients refuse referral and later return for additional settlement consulting — proof that consent-based processes do not require aggressive sales.
Interaction with privacy law
Sharing contact details with a licensee is a disclosure under the Privacy Act. We rely on consent and our Privacy Policy. Clients may limit what we share — for example, email only, no phone — though licensees may then decline to proceed without adequate contact methods.
Client scenarios we see often
Scenario A: New migrant referred by a property agent to “a finance guy” — we reset expectations and offer orientation before any licensee call. Scenario B: HK parent company wants Australian key person cover — we clarify that the employing entity and residency of the life insured affect underwriting; licensee must assess. Scenario C: Client already has a bank adviser — we document that no referral is needed unless they request a second opinion category.
Related: Referral Process · Compliance & Licensing · SME referral case study