Monitoring and Supervision Framework
Financial advice is only as good as the governance behind it. That is why Insight Investment Partners has released two companion documents—our Monitoring and Supervision Policy and the Compliance File Review Policy & Procedure—that together create a clearer, more data-driven oversight program for advisers operating under our AFSL. Below is a practical explainer you can share with your team or bookmark for future reference.
1. Why the Framework Has Been Updated
Technology-enabled supervision: The policies embed the SARA pre-vetting tool at the first line of defence, moving manual checks later into the process where they add the most value.
Risk-weighted resourcing: Time is now spent where it matters—files, advisers or advice topics that present higher inherent or emerging risk.
2. How the Three-Level Supervision Model Works
| Level | Purpose | Your Role |
|---|---|---|
| Level 1 – Adviser Pre-Vetting (Self-Assessment) |
First-line quality control. Every Statement of Advice (SOA) must pass through the SARA pre-vetting tool before client release; exceptions are rectified and signed off in the Projects App. |
|
| Level 2 – Quarterly Compliance Spot Checks |
Independent, retrospective review. The Compliance Manager selects ≥ 1 SOA per adviser from the prior quarter; findings and required actions issued within 10 business days. |
|
| Level 3 – Targeted Reviews & Enhanced Supervision |
Triggered where recurring deficiencies or high-risk advice patterns emerge. Can include extra file reviews, coaching, CPD or—where warranted—disciplinary action under the breach & remediation policy. |
|
3. Inside the Compliance File Review
A structured checklist assigns each finding a Low, Medium or High risk rating; files then receive an overall Green, Orange or Red status:
Green – Clean file or only low-risk issues.
Orange – Two + medium-risk issues; remediation plan required.
Red – One + high-risk breach; immediate escalation to the Responsible Manager and potential regulatory reporting.
Advisers have 60 days to close out remediation actions, after which the Compliance Manager verifies completion. Persistent delays move the matter into formal performance management.
4. What You Need to Do Differently (If Anything)
Embed SARA early. Make SARA your non-negotiable final gate before sending any advice to a client.
Document everything. Store research notes, file-notes, fee consents and client communications neatly in your CRM —these are prime evidence in spot checks.
Respond quickly. Treat Compliance Review Reviews as a priority.
Ask for help. The compliance team can arrange coaching or template updates if you are seeing repeat flags on similar issues.
5. Benefits for Advisers
Reduced rework: Catching issues at Level 1 prevents time-consuming rewrites later.
Clear remediation roadmap: You know exactly how long you have, what to fix and who to talk to.
Demonstrable professionalism: A strong oversight record differentiates your practice when clients or referral partners conduct due diligence.
6. Key Resources
Monitoring & Supervision Policy – The latest policy version is available in the Polic Register, in the iC2 Compliance Hub.
Compliance File Review Policy & Procedure – The latest policy version is available in the Polic Register, in the iC2 Compliance Hub.
SARA User Guide – Refer to the link below for a step-by-step guide for uploading and resolving exceptions.
https://www.icomply2.com.au/sara-tips/adviser-pre-vetting-guide
Responsible Manager & Compliance Team Contacts – For tailored support
Final Word
These policies are not just compliance documents—they are a blueprint for delivering consistently high-quality, client-centric advice. By embracing the three-level model and the SARA technology stack, you will spend less time on remedial work and more time where it counts: helping clients achieve their goals.
For any questions or to schedule a training refresher, please reach out to support@iip.net.au