Compliance Review – Example Advice Limited (a made-up firm)
Website: www.example-advice.co.nz · Reviewed 15 November 2026 · Knowledge base: sample
The law: 5 not fine · 4 need looking at · 24 fine
This review compares the provider's website and the documents it sent with the provisions of New Zealand law in our approved knowledge base, as named on this report. Every finding quotes the provider's own words and the provision it rests on, and every quote was checked word for word against its source. Each check was answered once by Compleye; a second, independent answer was not used. It is general information only: it is not legal advice, not an audit and not a guarantee, and it covers only what we were able to read. Where something is marked Needs looking at, a person should check it.
What to fix first
- Disclosure is easy to find from the home page. Put a clear "Disclosure" link in the home page's main menu or footer.
- Dispute resolution scheme is the same everywhere. Name one scheme with the same contact details everywhere.
- Fees and commission statements match. Use the same fees and commission wording everywhere.
- Fees: when, how much and payment terms. Set out each fee: when, how much or how worked out, and when payable.
- Information collected from others. Add a section on information collected from other sources and what people are told.
These are the checks marked "No – it's not fine", in the order they appear below. Another 4 need looking at. The detail, with the law, is under each check.
Public disclosure
Public disclosure information is on the websiteYes – it's fine
The website has a "Disclosure" page and a downloadable disclosure statement covering the required items.
The law:Financial Markets Conduct Regulations 2014, regulation 229C(2): “(2) A financial advice provider (P) must make all of the applicable information set out in clause 4 of Schedule 21A publicly available.”
Disclosure is easy to find from the home pageNo – it's not fine
The home page has no link to the disclosure information. It can only be reached from the "About us" page.
How to fix it: Put a clear "Disclosure" link in the home page's main menu or footer.
The law:Financial Markets Conduct Regulations 2014, regulation 229B(4): “that the information, or a link to the information, is prominently displayed either on the home page or on an appropriate section of the site”
The provider's own name and contact detailsYes – it's fine
The disclosure statement gives the firm's registered name, address, phone number and email address.
The law:Financial Markets Conduct Regulations 2014, regulation 229C(5): “The information made available under this regulation must include P’s name and contact details and be clearly identified as having been provided by P.”
Licence statusYes – it's fine
The disclosure statement says the firm holds a licence issued by the Financial Markets Authority.
What you said:“Example Advice Limited holds a licence issued by the Financial Markets Authority to provide a financial advice service.” – Disclosure statement
The law:Financial Markets Conduct Regulations 2014, Schedule 21A clause 4(1)(a): “(A) to the effect that P is authorised by a licence issued by the FMA to provide a financial advice service; and”
Licence conditions that limit the adviceNeeds looking at
The disclosure statement says nothing about licence conditions. We couldn't tell whether there are none, or whether they were left out.
How to fix it: Summarise any licence conditions that limit the advice, or confirm there are none.
The law:Financial Markets Conduct Regulations 2014, Schedule 21A clause 4(1)(b): “a brief summary of the effect of each condition of the licence that limits or restricts the advice that may be given by P”
Types of products advised onYes – it's fine
The disclosure statement lists home loans, personal risk insurance and KiwiSaver.
The law:Financial Markets Conduct Regulations 2014, Schedule 21A clause 4(1)(c): “(c) the types of financial advice products in relation to which advice is given:”
Product providers (lenders or insurers)Yes – it's fine
The disclosure statement says advice is only about products from the lenders and insurers it lists.
The law:Financial Markets Conduct Regulations 2014, Schedule 21A clause 4(1)(d): “if P gives advice in relation to financial advice products from particular product providers only,—”
Material limitations on the adviceYes – it's fine
The disclosure statement explains that the firm does not give advice on investments or general insurance.
The law:Financial Markets Conduct Regulations 2014, Schedule 21A clause 4(1)(e): “a brief explanation of any material limitations or restrictions on the scope of financial advice services that P gives”
Fees and when they are payableYes – it's fine
The disclosure statement says when a fee may be charged and when it is payable.
The law:Financial Markets Conduct Regulations 2014, Schedule 21A clause 4(1)(f): “a brief explanation of when, or in what circumstances, those amounts will or may be payable:”
Conflicts of interest and how they are managedYes – it's fine
The disclosure statement describes the conflicts of interest that can arise and how they are managed.
The law:Financial Markets Conduct Regulations 2014, Schedule 21A clause 4(1)(g): “a brief explanation of the steps that have been or will be taken to manage each conflict of interest:”
Commissions and incentivesYes – it's fine
The disclosure statement explains that lenders and insurers pay commission, and how that conflict is managed.
The law:Financial Markets Conduct Regulations 2014, Schedule 21A clause 4(1)(h): “(h) if any commission or other incentive will or may be given in relation to advice given to P’s clients,”
How to complain and the internal complaints processYes – it's fine
The complaints page explains how to complain and what happens next.
The law:Financial Markets Conduct Regulations 2014, Schedule 21A clause 4(1)(i): “(i) an explanation of how to make a complaint:”
Dispute resolution schemeYes – it's fine
The disclosure statement names a dispute resolution scheme, says it is free and independent, and gives its contact details.
The law:Financial Markets Conduct Regulations 2014, Schedule 21A clause 4(1)(k): “a statement to the effect that a complainant has access to a free, independent dispute resolution service”
The duties statementYes – it's fine
The disclosure statement includes the duties statement.
The law:Financial Markets Conduct Regulations 2014, Schedule 21A clause 4(1)(l): “a statement to the effect that P and any person giving advice on P’s behalf is bound by the duties in sections 431I, 431K, 431L, and 431M of the Act”
Clear, concise and freeYes – it's fine
The disclosure information is easy to read on screen, free, and not behind a login or form.
The law:Financial Markets Conduct Regulations 2014, regulation 229H: “(a) is presented in a clear, concise, and effective manner; and”
Consistency between the website and the documents
Firm name and FSP number are the same everywhereYes – it's fine
The website, the disclosure statement and the scope of service documents all use "Example Advice Limited" and the same FSP number.
The law:Financial Markets Conduct Regulations 2014, regulation 229C(5): “The information made available under this regulation must include P’s name and contact details and be clearly identified as having been provided by P.”
Licence holder is the same everywhereYes – it's fine
Each one says the firm holds its own financial advice provider licence.
The law:Financial Markets Conduct Regulations 2014, Schedule 21A clause 4(1)(a): “a statement to the effect that P holds a licence issued by the FMA to provide a financial advice service; or”
Dispute resolution scheme is the same everywhereNo – it's not fine
The website's complaints page names one dispute resolution scheme. The disclosure statement names a different one, with a different phone number.
How to fix it: Name one scheme with the same contact details everywhere.
What you said:“If we can't resolve your complaint you can contact Scheme A on 0800 000 001.” – Complaints page
“Our dispute resolution scheme is Scheme B. You can call them on 0800 000 002.” – Disclosure statement
The law:Financial Markets Conduct Regulations 2014, Schedule 21A clause 4(1)(k): “(ii) the name of the dispute resolution scheme that P is a member of; and”
Products, providers and limitations matchYes – it's fine
The lenders and insurers on the "Who we work with" page match the list in the disclosure statement.
The law:Financial Markets Conduct Act 2013, section 431P: “a statement in the information that is false or misleading or is likely to mislead”
Fees and commission statements matchNo – it's not fine
The home page says the service is free. The disclosure statement says a fee may be charged if a loan is repaid within 28 months.
How to fix it: Use the same fees and commission wording everywhere.
What you said:“Our service is completely free.” – Home page
“We may charge a fee if you repay your loan within 28 months.” – Disclosure statement
The law:Financial Markets Conduct Act 2013, section 431P: “a statement in the information that is false or misleading or is likely to mislead”
Advisers shown on the websiteNeeds looking at
The "Our team" page shows three people as advisers. The documents you sent cover two of them, so we couldn't tell whether the third gives advice.
How to fix it: Check each person shown as an adviser is a registered financial adviser engaged by the firm.
What you said:“Sam – Mortgage Adviser” – Our team page
The law:Financial Markets Conduct Act 2013, section 431F: “(1) A person (A) must not give regulated financial advice on behalf of a financial advice provider (P) to a retail client unless—”
Documents are currentNeeds looking at
The disclosure statement linked from the website has no date or version, so we couldn't tell whether it is the current one.
How to fix it: Date and version each document and remove links to superseded documents.
The law:Financial Markets Conduct Regulations 2014, regulation 229C(2): “A financial advice provider (P) must make all of the applicable information set out in clause 4 of Schedule 21A publicly available.”
Scope of service documents
Products the advice coversYes – it's fine
Each scope of service document lists the products the advice will cover.
The law:Financial Markets Conduct Regulations 2014, regulation 229D: “A must give the client all of the information set out in clause 5 of Schedule 21A that is applicable.”
Product providers the advice coversYes – it's fine
Each one names the lenders the advice will cover.
The law:Financial Markets Conduct Regulations 2014, Schedule 21A clause 5(1)(b): “if some or all of the advice will be given in relation to financial advice products from particular product providers only,—”
Limitations of the adviceYes – it's fine
Each one explains what the advice will not cover.
The law:Financial Markets Conduct Regulations 2014, Schedule 21A clause 5(1)(c): “a brief explanation of any material limitations or restrictions on the nature and scope of the advice that the client will be given”
The adviser and who they advise forYes – it's fine
Each one names the adviser, says they are a financial adviser and that they advise on behalf of Example Advice Limited.
The law:Financial Markets Conduct Regulations 2014, Schedule 21A clause 5(2)(a): “(ii) a statement that A gives advice on behalf of P; and”
Fees: when, how much and payment termsNo – it's not fine
The scope of service documents say a fee "may apply" but not how much it is, how it is worked out, or when it must be paid.
How to fix it: Set out each fee: when, how much or how worked out, and when payable.
What you said:“A fee may apply in some circumstances.” – Scope of service – adviser A
The law:Financial Markets Conduct Regulations 2014, Schedule 21A clause 5(2)(b): “a brief explanation of how the amount will be determined and, if practicable, an estimate of the amount; and”
Conflicts of interestYes – it's fine
Each one describes the conflicts of interest and how they are managed.
The law:Financial Markets Conduct Regulations 2014, Schedule 21A clause 5(2)(c): “if any conflict of interest (other than a commission or other incentive) currently exists or is likely to arise in the future”
Commissions: who pays, how much, how managedYes – it's fine
Each one says who pays commission, who receives it, when, and how the amount is worked out.
The law:Financial Markets Conduct Regulations 2014, Schedule 21A clause 5(2)(d): “if any commission or other incentive will or may be given in relation to the advice the client is seeking or given”
Reliability eventsNeeds looking at
The scope of service documents don't mention reliability events. We couldn't tell from the documents whether one has happened.
How to fix it: If a reliability event has happened, add the required statement.
The law:Financial Markets Conduct Regulations 2014, Schedule 21A clause 5(1)(d): “if a reliability event has happened to P or to A (if A is a financial adviser or a nominated representative)”
Privacy
Privacy statement on the websiteYes – it's fine
There is a privacy statement, linked from the footer of every page and from the enquiry form.
The law:Privacy Act 2020, information privacy principle 3: “the agency must take any steps that are, in the circumstances, reasonable to ensure that the individual concerned is aware of—”
What the privacy statement tells peopleYes – it's fine
The privacy statement says who collects the information, why, who it may be shared with, and how to see or correct it.
The law:Privacy Act 2020, information privacy principle 3(1): “the agency must take any steps that are, in the circumstances, reasonable to ensure that the individual concerned is aware of—”
Information collected from othersNo – it's not fine
The privacy statement only covers information people give the firm themselves. It says nothing about information collected from others, such as lenders or credit reporters, or what people are told when that happens.
How to fix it: Add a section on information collected from other sources and what people are told.
What you said:“We collect personal information directly from you when you fill in our forms or talk to us.” – Privacy statement
The law:Privacy Act 2020, information privacy principle 3A: “The steps referred to in subclause (1) must be taken as soon as is reasonably practicable after the information has been collected”
