Chapter 6 - SARA
Who is SARA?
Meet SARA, IIP’s Statement of Advice Review Assistant (SARA).
SARA is an AI powered AFSL Compliance Assistant, built to assist in the pre-vet of advice document,
We have developed a state-of-the-art AI powered compliance assistant to help you pre-vet advice documents.
SARA is NOT like other compliance solutions!
Most compliance technology (regtech) solutions are built around a ‘rules-based’ approach to reviewing advice. Meaning that every SOA needs meet the pre-determined ‘rules’ to pass the compliance checks. These rules only check if the SOA contains mandatory sections and disclosures.
SARA is different - because the technology uses Artificial Intelligence (AI), SARA is able to understand the clients objectives, relevant circumstances and the recommendations provided.
SARA is able to subjectively test the appropriateness of the advice, and how the advice leaves the client in a better position.
How does it work?
Simply upload your SOA to the SARA App.
SARA will extract the text from the SOA for indexing in a vector database. The app will then run a set of automated prompts using Artificial Intelligence to pre-vet the advice document..
Once the compliance checks have been completed, the SARA app will display the responses in a report builder. The AFSL Compliance Manager will then need to review and assess the AI responses.
How accurate are the responses?
The responses are based on the text in the Statement of Advice. It is important to remember that SARA is a compliance assistant, not an experienced compliance manager.
Whilst SARA will provide in depth analysis of the document. The accuracy of the responses will still need to be reviewed by a an experienced manager or peer-reviewed adviser.
What does it test for?
Best interests duty - s961B(1): An advice provider must act in the best interests of the customer in relation to the advice they provide to the customer.
Safe harbour for complying with the best interests duty - s961B(2): Section 961B(2) provides a ‘safe harbour’ that advice providers may rely on to prove they have complied with the best interests duty. If an advice provider shows they have taken the steps in s961B(2), they have met their obligation to act in the best interests of the customer.
Providing appropriate advice - s961G: Advice providers must only provide advice if it is reasonable to conclude that the advice is appropriate for the customer, assuming the best interests duty has been complied with.
Prioritising the interests of the customer - s961J: When providing customers with advice, advice providers must place the interests of the customers ahead of any interests they have or those of their related parties.
Sole Purpose Test - section 62 of the SIS Act: When charging fees for advice from superannuation, the sole purpose test ensures that fees are charged for the members benefit in that fund, and not for advice outside superannuation.
Fee Consent Obligations - ensuring that the adviser has provided an appropriate fee consent form when entering into an ongoing fee arrangement.
What does it not test for?
SARA is not a complete file review (yet). It focuses on the advice document and the appropriateness of the advice. You are able to upload supporting documentation including fact find, file notes, product comparisons etc. However, the compliance check is primarily built to review the appropriateness of the advice and is not a complete file review.
What technologies are used?
SARA is a RAG solution (Retrieval-Augmented Generation). All resources are deployed in Microsoft’s Azure AI.
Workflows including chunking, embedding, indexing, and querying are completed within Microosft Azure service. All vectors and indexes are also stored within our secure Azure environment, hosted within Australia.
Once the SOA has been reviewed, the Statement of Advice document is automatically deleted from our database.
What Large Language Model (LLM) is used?
SARA currently uses OpenAI’s GPT4o deploy in our secure Microsoft Azure environment.
What personal information is shared with OpenAI?
SARA uses Responsible AI. The GPT o-1 model has been deployed to our own secure environment using the Microsoft Azure’s OpenAI service.
No personal information is shared with the ChatGPT model.
What Personal Identifiable Information (PII) Does SARA Process?
We’re pleased to announce that SARA’s now uses Microsoft Azure Personal Identifiable Information (PII) to automatically identify and redact personally identifiable information (PII) across all documents and responses.
When you upload an SOA and another supporting documentation to SARA, Microsoft Azure Personal Identifiable Information (PII) automatically identifies and redact personally identifiable information (PII) across all documents and responses.
File Import – Drag your SOA and supporting documents into SARA.
PII scan – Using Azure PII, SARA scans the files in real time.
Redaction – SARA redacts any responses containing PII as an asterisk.
Citations - Where you click on a citation from a source file that contains PII, the source data citation is redacted.
All workloads run in the Australia East region in our private Azure container, ensuring data residency and ISO 27001 alignment.