RiverhorseCOMPLIANCE

RIVERHORSE COMPLIANCE REVIEW

Find the gaps in your website and client documents – before a client or the regulator does

A fixed-price check of your financial advice firm's website and client documents against New Zealand's disclosure, conduct and privacy rules. You get a plain tick-box report: what's fine, what isn't, and how to fix it.

Order a review – $249 + GSTOne-off. No membership needed. 33 checks. Report usually within 2 working days.

Demo: payments aren't connected yet, so no money is taken. Everything else is the real thing.

Checked against the law itself

Every finding names the provision of the law it relates to, so you can see exactly why it was raised.

A person checks every report

Compleye, our review system, does the reading. One of our people checks the report before you see it.

Fixed price, no membership

One payment. No subscription, nothing to install, and you can add documents over a few days.

Private to your firm

Your documents and your report stay inside Compliance. You reach them through your own private link or login.

How it works

  1. We read your website ourselves, so there's nothing to send us from it.
  2. You send us your documents through your private link.
  3. We check your website and documents against the law, one check at a time. The checks are listed below.
  4. We check the report ourselves before you see it. It then appears on the same page, usually within 2 working days of sending your documents, and we email you when it's ready.

How the review is done

Home page
  1. The home page, and the pages and documents it links to about disclosure, complaints, fees and privacy.

What's in your report

The report is a tick-box list: "Yes – it's fine", "No – it's not fine" or "Needs looking at" for each check, with the law it relates to and a suggested fix.

You read it on your private page and can download it as a Word document. See a full sample report.

An example of one finding (illustration only – not a real firm)
Disclosure is easy to find from the home page
No – it's not fine
What we foundThe home page has no link to the disclosure information. It can only be reached from the "About us" page.
The lawFinancial Markets Conduct Regulations 2014, regulation 229B(4)
Suggested fixPut a clear "Disclosure" link in the home page's main menu or footer.

It is not legal advice, not an audit and not a guarantee.

The documents we ask for

We will ask for a number of documents, including but not limited to:

We may ask for other documents on the page. If you don't have one of them, say so there. PDF, Word (.docx) or text, up to 20 MB each.

Where a document went to a client, please black out the client's name and details before you send it. We also take out email addresses and phone numbers before the review reads your documents.

The 33 checks we run

Every review runs all of them. For each one: what we look for, where we look, and the law it rests on.

What your website tells the public (15 checks)
Public disclosure information is on the website
What we look for: The website has the provider's public disclosure information (a disclosure page, section or downloadable disclosure document) that covers the Schedule 21A clause 4 items.
Where we look: Your website
The law: Financial Markets Conduct Regulations 2014, regulation 229C(2); Financial Markets Conduct Regulations 2014, regulation 229C(6); Financial Markets Conduct Act 2013, section 431O
Disclosure is easy to find from the home page
What we look for: The disclosure information, or a link to it, is displayed prominently on the home page or in a section the home page links to prominently, so the public can find it easily.
Where we look: Your website
The law: Financial Markets Conduct Regulations 2014, regulation 229B(4)
The provider's own name and contact details
What we look for: The disclosure information includes the financial advice provider's own name and contact details and is clearly identified as the provider's information.
Where we look: Your website and the documents you send us
The law: Financial Markets Conduct Regulations 2014, regulation 229C(5)
Licence status
What we look for: A statement of the provider's licence status: holds a financial advice provider licence, is an authorised body under another provider's licence (naming that licensee), or is exempt.
Where we look: Your website and the documents you send us
The law: Financial Markets Conduct Regulations 2014, Schedule 21A clause 4(1)(a)
Licence conditions that limit the advice
What we look for: If the licence has conditions that limit or restrict the advice that may be given, a brief summary of them.
Where we look: Your website and the documents you send us
The law: Financial Markets Conduct Regulations 2014, Schedule 21A clause 4(1)(b)
Types of products advised on
What we look for: The types of financial advice products the provider gives advice on.
Where we look: Your website and the documents you send us
The law: Financial Markets Conduct Regulations 2014, Schedule 21A clause 4(1)(c)
Product providers (lenders or insurers)
What we look for: If advice is only about products from particular product providers, a statement saying so, with their names or an identifying description.
Where we look: Your website and the documents you send us
The law: Financial Markets Conduct Regulations 2014, Schedule 21A clause 4(1)(d)
Material limitations on the advice
What we look for: A brief explanation of any material limitations on the advice services.
Where we look: Your website and the documents you send us
The law: Financial Markets Conduct Regulations 2014, Schedule 21A clause 4(1)(e)
Fees and when they are payable
What we look for: When clients may have to pay fees, expenses or other amounts, and when they become payable.
Where we look: Your website and the documents you send us
The law: Financial Markets Conduct Regulations 2014, Schedule 21A clause 4(1)(f)
Conflicts of interest and how they are managed
What we look for: Any conflicts of interest of the provider or its advisers, their nature, and the steps taken to manage them.
Where we look: Your website and the documents you send us
The law: Financial Markets Conduct Regulations 2014, Schedule 21A clause 4(1)(g); Financial Markets Conduct Act 2013, section 431K
Commissions and incentives
What we look for: Any commissions or other incentives the provider or its advisers may receive, when they apply, and the steps taken to manage the conflicts they create.
Where we look: Your website and the documents you send us
The law: Financial Markets Conduct Regulations 2014, Schedule 21A clause 4(1)(h)
How to complain and the internal complaints process
What we look for: How to make a complaint to the provider, and an overview of its internal complaints process.
Where we look: Your website and the documents you send us
The law: Financial Markets Conduct Regulations 2014, Schedule 21A clause 4(1)(i); Financial Markets Conduct Regulations 2014, Schedule 21A clause 4(1)(j)
Dispute resolution scheme
What we look for: That a free, independent dispute resolution service is available, the name of the provider's scheme and the scheme's contact details.
Where we look: Your website and the documents you send us
The law: Financial Markets Conduct Regulations 2014, Schedule 21A clause 4(1)(k); Financial Service Providers (Registration and Dispute Resolution) Act 2008, section 11; Financial Service Providers (Registration and Dispute Resolution) Act 2008, section 48
The duties statement
What we look for: A statement that the provider and anyone advising on its behalf is bound by the duties in sections 431I, 431K, 431L and 431M of the Financial Markets Conduct Act 2013, or words to the same effect.
Where we look: Your website and the documents you send us
The law: Financial Markets Conduct Regulations 2014, Schedule 21A clause 4(1)(l); Financial Markets Conduct Act 2013, section 431I; Financial Markets Conduct Act 2013, section 431K; Financial Markets Conduct Act 2013, section 431L; Financial Markets Conduct Act 2013, section 431M
Clear, concise and free
What we look for: The disclosure information is clear, concise and effective, easily readable, and free of charge (not behind a login, form or payment).
Where we look: Your website
The law: Financial Markets Conduct Regulations 2014, regulation 229H
Whether your website and documents say the same thing (7 checks)
Firm name and FSP number are the same everywhere
What we look for: The provider's name (legal and trading) and FSP number are the same on the website and in every document supplied, and agree with the firm details given for this review.
Where we look: Your website and the documents you send us
The law: Financial Markets Conduct Regulations 2014, regulation 229C(5); Financial Service Providers (Registration and Dispute Resolution) Act 2008, section 12; Financial Service Providers (Registration and Dispute Resolution) Act 2008, section 41; Financial Markets Conduct Act 2013, section 431P; Fair Trading Act 1986, section 13
Licence holder is the same everywhere
What we look for: The licence holder (or the licensee, for an authorised body) is the same on the website and in every document supplied, and agrees with the firm details given for this review.
Where we look: Your website and the documents you send us
The law: Financial Markets Conduct Regulations 2014, Schedule 21A clause 4(1)(a); Financial Markets Conduct Act 2013, section 431P
Dispute resolution scheme is the same everywhere
What we look for: The same dispute resolution scheme, with the same contact details, is named on the website and in every document supplied.
Where we look: Your website and the documents you send us
The law: Financial Markets Conduct Regulations 2014, Schedule 21A clause 4(1)(k); Financial Markets Conduct Regulations 2014, regulation 229F; Financial Service Providers (Registration and Dispute Resolution) Act 2008, section 48
Products, providers and limitations match
What we look for: The products, product providers and limitations on the website match those in the disclosure and scope documents supplied.
Where we look: Your website and the documents you send us
The law: Financial Markets Conduct Act 2013, section 431P; Fair Trading Act 1986, section 9; Fair Trading Act 1986, section 13
Fees and commission statements match
What we look for: What the website says about fees, commissions and incentives matches what the disclosure and scope documents say.
Where we look: Your website and the documents you send us
The law: Financial Markets Conduct Act 2013, section 431P; Fair Trading Act 1986, section 13
Advisers shown on the website
What we look for: People the website presents as advisers are described consistently with the documents supplied, and nobody is described as giving financial advice who the documents show is not an adviser.
Where we look: Your website and the documents you send us
The law: Financial Markets Conduct Act 2013, section 431F; Financial Markets Conduct Act 2013, section 431Q; Financial Service Providers (Registration and Dispute Resolution) Act 2008, section 12; Financial Service Providers (Registration and Dispute Resolution) Act 2008, section 41; Fair Trading Act 1986, section 13
Documents are current
What we look for: The documents supplied and linked from the website are current versions: dated or versioned, not naming a superseded entity, licence or scheme, and the website does not link to an older version than the one supplied.
Where we look: Your website and the documents you send us
The law: Financial Markets Conduct Act 2013, section 431P; Financial Markets Conduct Regulations 2014, regulation 229C(2)
Your scope of service documents (8 checks)
Products the advice covers
What we look for: The scope of service document states the types of financial advice products the advice is about.
Where we look: The documents you send us
The law: Financial Markets Conduct Regulations 2014, regulation 229D; Financial Markets Conduct Regulations 2014, Schedule 21A clause 5(1)(a)
Product providers the advice covers
What we look for: If the advice is about products from particular providers only, the scope document says so and names or describes them.
Where we look: The documents you send us
The law: Financial Markets Conduct Regulations 2014, Schedule 21A clause 5(1)(b)
Limitations of the advice
What we look for: A brief explanation of any material limitations or restrictions on the advice.
Where we look: The documents you send us
The law: Financial Markets Conduct Regulations 2014, Schedule 21A clause 5(1)(c)
The adviser and who they advise for
What we look for: A statement that the adviser is a financial adviser, that they advise on behalf of the provider, and the adviser's name or a way to identify them.
Where we look: The documents you send us
The law: Financial Markets Conduct Regulations 2014, Schedule 21A clause 5(2)(a)
Fees: when, how much and payment terms
What we look for: Any fees, expenses or other amounts payable: when they apply, the amount or how it is worked out (with an estimate), and the payment terms.
Where we look: The documents you send us
The law: Financial Markets Conduct Regulations 2014, Schedule 21A clause 5(2)(b)
Conflicts of interest
What we look for: Any conflicts of interest (other than commissions), their nature, and the steps taken to manage them.
Where we look: The documents you send us
The law: Financial Markets Conduct Regulations 2014, Schedule 21A clause 5(2)(c)
Commissions: who pays, how much, how managed
What we look for: For each commission or incentive: when it is given, who gives and receives it, its amount or how it is worked out, and how the conflict is managed.
Where we look: The documents you send us
The law: Financial Markets Conduct Regulations 2014, Schedule 21A clause 5(2)(d)
Reliability events
What we look for: If a reliability event has happened to the provider or adviser, a statement that it has, with enough detail to identify it.
Where we look: The documents you send us
The law: Financial Markets Conduct Regulations 2014, Schedule 21A clause 5(1)(d)
Privacy (3 checks)
Privacy statement on the website
What we look for: The website has a privacy statement or policy that is easy to find, especially where it collects personal information (forms, calculators, applications).
Where we look: Your website
The law: Privacy Act 2020, information privacy principle 3
What the privacy statement tells people
What we look for: The privacy statement says who collects the information, why, who it may be shared with, and that people can access and correct it.
Where we look: Your website and the documents you send us
The law: Privacy Act 2020, information privacy principle 3(1); Privacy Act 2020, information privacy principle 6; Privacy Act 2020, information privacy principle 7
Information collected from others
What we look for: The privacy statement covers personal information collected from someone other than the person themselves and what people are told when that happens.
Where we look: Your website and the documents you send us
The law: Privacy Act 2020, information privacy principle 3A

What it can cost when things aren't right

The Financial Markets Authority (FMA) licenses and monitors financial advice providers. This is what the law allows when a provider, or an adviser, doesn't meet the rules. These are the outer limits, not what happens every time.

The licence

The FMA can censure a provider, give it a direction, and cancel its licence. It has done all three to financial advice providers. Without a licence (its own, or cover under another firm's) a provider generally can't give regulated financial advice to retail clients.

Penalties from a court

For most breaches of the advice duties a court can order a penalty of up to $200,000 for an individual or $600,000 for a company. For false or misleading statements or omissions in disclosure information the limit is higher: up to $1 million for an individual or $5 million for a company, or three times the gain made or loss caused, whichever is greater.

Paying clients back

A court can order a provider to compensate clients, and a dispute resolution scheme can award a client compensation too.

Directors and managers

It isn't only the company. Anyone knowingly involved in a provider's breach, a director or senior manager included, can be held personally liable. The Act also keeps open criminal liability for a false or misleading statement in disclosure information.

An adviser's own registration

The Financial Advisers Disciplinary Committee can censure an adviser, require training, put conditions on their advice and fine them up to $10,000. An adviser's registration can be suspended or ended.

Reputation

The FMA's censures and licence cancellations are public. It publishes them, naming the firm, where clients and referrers can find them.

A review can't promise that none of this happens. It shows you what a careful reader of your website and documents would find, and how to fix it, before anyone else points it out.

General information only, not legal advice. Sources: Financial Markets Conduct Act 2013, sections 431H, 449, 495 and 533; MBIE – Liability in the new financial advice regime; MBIE – Enforcement in the new financial advice regime; FMA – Financial Advice Provider Monitoring Insights (May 2024). Last checked 15 November 2026.

What the review doesn't cover

The review looks for gaps. It isn't a sign-off: it isn't legal advice, an audit or a guarantee.

Questions

Is this an audit or legal advice?

No. It is a quick look at your website and documents against the law. It is not legal advice, not an audit and not a guarantee.

Who is it for?

New Zealand financial advice providers. It's for the firm, not each adviser.

How long does it take?

Sending your documents takes a few minutes, and you can come back to add more. Your report is usually ready within 2 working days of sending them.

What if we don't have one of the documents?

Tell us on your page. We review what you have, and the report says what wasn't supplied.

Who sees our documents?

Our staff and Compleye, our review system, which uses outside services to do the reading – our privacy page says how. They are not shared with any other firm or site, and they are never published.

What happens after the report?

You decide what to fix. If you'd like help, reply to our email and we can introduce a compliance specialist.

Order your review – $249 + GST

One-off. No membership needed. Straight after you order we email your private link for sending us your documents.

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