Adviser disclosure
Insurance adviser disclosure statement in NZ: what to check
An insurance adviser disclosure statement can help you see who is providing the advice, what the advice can cover, which providers may be considered, how the adviser is paid, where conflicts may arise and how complaints are handled. Under New Zealand's current rules, that information may be provided in stages rather than in one document.
The short answer
Disclosure information is there to help a retail client decide whether to seek advice from a person or provider, and later whether to act on the advice. It should identify the advice business, explain the intended scope and limits, describe relevant fees and conflicts, and show the complaints path that applies.
Do not assume everything will sit in one PDF called a disclosure statement. The Financial Markets Conduct Regulations set different disclosure points: information made public, information given when the nature and scope of advice are known, further information when advice is given, and complaints information if a complaint is received. You can also ask for applicable disclosure information in writing.
Start with who provides the advice and its scope
The public disclosure should identify the financial advice provider and give contact details. It should also explain the types of financial advice products the service covers and any material limits or restrictions. When the scope of your own conversation becomes clear, the adviser should explain the product types relevant to that advice and any important limits that apply to it.
For insurance, the useful question is not simply whether an adviser can discuss life, health, income or business risk. Ask which of those areas are inside this engagement, which are outside it, and whether the adviser is considering products from particular providers only. A broad service list on a website is not the same as the agreed scope of your advice.
- Who is the financial advice provider responsible for the service?
- Which insurance needs and product types are included in this conversation?
- Which areas, risks or product types are outside the scope?
- Is advice limited to particular product providers, and where is that list recorded?
- Has anything material changed since the disclosure was last provided?
Read provider limits before comparing recommendations
A disclosure can tell you whether advice is based on products from particular providers. That does not by itself decide whether the eventual recommendation suits you. It tells you the pool from which the adviser may be working, so you can understand what was and was not considered.
Ask for the relevant provider names or a clear way to identify them. If a recommendation follows, keep the scope disclosure beside the written advice and the policy documents. That makes it easier to separate three different questions: what the adviser could consider, why a particular option was recommended, and what the policy wording actually covers.
Check fees, commissions and other conflicts
The disclosure should explain applicable fees or other amounts you may have to pay, including when they may become payable and either the amount or how it will be worked out. It should also address commissions, incentives and other conflicts of interest that may materially influence the advice.
Commission disclosure is useful context, not a shortcut to a conclusion. Ask who pays it, what event triggers it, how its amount or value is determined, whether different providers or products pay differently, and what steps are used to manage the conflict. The FMA's 2024 monitoring report found that some providers needed more detail about commissions and incentives, which is a practical reason to ask for a clear written explanation rather than rely on a general sentence.
- Will I pay any fee now, later, on cancellation or for additional work?
- If the amount is not yet known, how will it be calculated?
- Who pays any commission or incentive, and when?
- Could payment differ between providers or products?
- How is the conflict identified, recorded and managed for this advice?
Match each disclosure to the stage of the advice
Timing matters because the detail available changes as the conversation develops. Once the nature and scope of advice are known, you should have enough information to decide whether to continue with that person or provider. When advice is given, further applicable details about fees, commissions, incentives and conflicts should be provided, together with material updates to earlier information.
Keep dated copies or emails. If earlier information remains current, it may not need to be repeated each time, but you can ask for it again. The regulations require disclosure to be clear, concise, effective, prominent when presented with other information, easily readable when written, and free of charge.
Know what the disclosure does not decide
A disclosure is not a personal recommendation, a policy schedule or proof that a claim will be accepted. It does not replace a fact-find, the reasons for advice, insurer underwriting, the policy wording or your own decision about affordability and trade-offs.
If a problem arises, ask for the provider's internal complaints process and the name and contact details of its free independent dispute resolution service. Keep the disclosure, written advice, policy records and key messages together. This article is general information only; a one-to-one conversation is needed before any recommendation can take your circumstances into account.
- What is the agreed scope of this advice, in writing?
- Which providers and products were considered, and which were not?
- What will I pay, and what will another party pay the adviser or provider?
- What conflicts apply to this recommendation and how are they managed?
- Where are the internal complaint and independent dispute-resolution details?
Sources
- New Zealand Legislation: Financial Markets Conduct Regulations 2014
- FMA: What to expect from your financial adviser
- FMA: Financial Advice Provider monitoring insights
- FMA: Problems with your financial adviser
This article is general information only. It does not take your personal circumstances into account and is not financial advice.