Most people assume their financial adviser is working for them. And most of the time, they genuinely are trying to. But trying to act in your interest and being structurally free to do so are two different things. The adviser's employer, their licensee, and who ultimately owns the business they work for — these things shape the advice you receive, often in ways that are never discussed.
The question most people never ask
Before asking about fees, returns, or strategies, there's a more fundamental question worth putting to any financial adviser: Who do you work for — and who do they work for?
This isn't a hostile question. It's a structural one. Because the advice you receive is shaped by the environment it comes from. An adviser employed by a bank recommends products from that bank's suite. An adviser within an industry super fund can generally only recommend that fund's own products. An adviser operating under a dealer group's licence works within that group's approved product list — which may itself be shaped by commercial relationships with product providers.
None of this is necessarily illegal, and plenty of advisers within these structures genuinely care about their clients. But the structure matters — because it shapes what gets considered, what gets recommended, and what doesn't get mentioned at all.
The main structures — and what sits behind them
Understanding who your adviser works for means understanding the structure they sit within. There are a few common models.
Potential conflict
The adviser is an employee of a financial institution that also manufactures and distributes its own products. The advice environment is shaped by what the institution offers — and the adviser's career sits within that institution. Even where best-interest obligations apply, the product universe is rarely neutral.
Potential conflict
Advisers employed directly by an industry super fund can typically only recommend that fund's own products. If your circumstances would be better served by a different fund, that option may not come up. The adviser is employed to serve the fund's membership — which is not always the same as serving your individual situation.
Potential conflict
The adviser operates under a dealer group's licence. Dealer groups often have preferred product lists shaped by commercial arrangements with product providers — shelf-space agreements, ownership relationships, or institutional ties. The individual adviser may genuinely try to work in your interests, but the product list and compliance framework they're working within isn't always neutral. Note that direct volume-based bonuses to individual advisers are prohibited under Australian law — the more relevant questions are about who owns the licensee and what commercial relationships shape the approved product list.
Fewer structural conflicts
The adviser holds their own Australian Financial Services Licence and operates without institutional ownership or dealer group alignment. Their approved product list is built on due diligence, not commercial relationships. There is no parent company with products to move, no volume targets, and no preferred shelf. The adviser answers directly for their advice — to their clients and to the regulator.
The question isn't just whether your adviser is honest. It's whether the structure they work within gives that honesty room to operate.
Real conflicts vs perceived conflicts
It's worth being precise here. There are two types of conflicts that can arise from advice structures — and both matter.
The adviser or their employer has a direct financial interest in the outcome of the advice. Recommending Fund A over Fund B earns more revenue. Keeping a product in place generates an ongoing fee. Recommending an in-house product grows the institution's funds under management. The incentive and the best advice point in different directions.
There may not be an active incentive at play, but the structure creates reasonable doubt. If your adviser works for a bank, you might reasonably wonder whether their recommendations are shaped by that. Perception matters because advice you're second-guessing has already lost much of its value.
Good advice structures remove both. Not because advisers within conflicted structures can't give good advice — many do. But because removing the conflicts means the advice doesn't need to overcome them first.
What self-licensed actually means
Being self-licensed is a specific and meaningful thing. It's not just a marketing term — it has real structural and regulatory implications.
Self-licensed. No dealer group. No institutional ownership.
Three layers to independence — and why each one matters for your advice.
We hold our own Australian Financial Services Licence. No dealer group sits above us. No licensee shapes our approved product list or sets our compliance framework for commercial reasons. We wrote our own obligations — and we answer for them directly to ASIC and to our clients.
We're not owned by a bank, insurer, fund manager, or any other product manufacturer. There's no parent entity with a commercial interest in what we recommend, no volume targets to hit on behalf of someone else, and no pressure — quiet or otherwise — to keep client money inside a particular product ecosystem.
Being self-licensed means the buck stops here — and we chose that deliberately. It means a higher obligation, more rigorous due diligence, and a higher standard of care. There's no dealer group to absorb a complaint or diffuse accountability. That keeps us sharp — and keeps our interests aligned with yours.
Like all licensed advisers, we maintain an approved product list — that's a regulatory and due diligence requirement, and an important one. The difference is that ours is built entirely on whether a product does the job for clients. If it works and serves a genuine need, it's on the list. If it stops performing, we remove it. No product provider, institution, or ownership relationship influences what goes on it, or what stays on it.
The term "independent" has a specific legal meaning under s923A of the Corporations Act and not all advisers can formally claim it. What we can say plainly: we receive no payments from product providers, no commercial benefits tied to what we recommend, and we have no institutional ownership shaping what we consider. Our only revenue is the fee our clients pay us — agreed upfront, before any work begins.
This structure matters because it removes the question entirely. There is no institutional pull on what we recommend. No product shelf to justify. No commercial relationship with a fund manager creating a preference. When we recommend something, it's because it's the right answer for that client — not because something else is easier, more profitable, or more aligned with whoever signs our payslip.
Fee-only — and why the payment model reinforces the structure
Structural independence is reinforced by how we charge. As a fee-only practice, our revenue comes entirely from the fees our clients pay us — fixed and agreed before any work begins. There are no percentage-based investment fees that grow as your portfolio grows, no insurance commissions, no referral payments, and no trailing revenue tied to products staying in place.
It's worth being precise here: direct volume-based bonuses paid to individual advisers have been prohibited under Australian law since the Future of Financial Advice (FOFA) reforms, and the Corporations Act's conflicted remuneration provisions ban benefits that can be shown to influence advice. But commercial arrangements at the licensee and institutional level — preferred product relationships, shelf-space agreements, ownership structures that create implicit preferences — remain real and relevant. The structural questions still matter. What sits behind the licence, who owns the business, and how the approved product list is constructed are the more important things to understand.
- Fixed, agreed fees for advice
- No % based fees on investments
- No insurance commissions
- No referral payments
- No ongoing trails
- % fees on funds under management
- Insurance commissions (upfront and trail)
- Commercial arrangements between product providers and licensees — including shelf-space and preferred product agreements
- Revenue tied to ongoing product holdings
- Institutional ownership creating implicit product preferences
The payment model and the ownership structure work together. A self-licensed adviser who still earns trailing revenue from product holdings has removed one conflict but not the other. Both need to be clear.
Does independent automatically mean better advice?
No — and it's important to say that plainly.
Structural independence removes conflicts. It doesn't create expertise, judgement, or the ability to think clearly about a client's situation. There are excellent advisers working within institutional structures who find ways to serve their clients well despite the constraints. And there are independent advisers who aren't particularly good at the actual work of financial planning.
What independence does is remove the noise. It means the advice can be evaluated on its merits — not on whether it was shaped by something the client never knew about.
Questions worth asking your adviser
Whoever you work with, these are reasonable questions to ask directly — and a good adviser should be able to answer all of them without hesitation.
| Question | What you're really asking |
|---|---|
| Who owns your licence? | Is your advice framework set by an institution with commercial interests? |
| Who owns your business? | Does a bank, insurer, or fund manager have a stake in what you recommend? |
| How is your approved product list determined? | Are products on it because they perform — or because of commercial arrangements? |
| Do you receive any payments from product providers? | Is there revenue you earn beyond what I pay you directly? |
| What happens to your revenue if I move to a different product? | Is there a financial incentive to keep things as they are? |
| Can you recommend products outside your group's preferred list? | Is the full market available to you — or only part of it? |
Where we sit — and why
Self-licensed, fee-only, and free of institutional ties. In practice that means:
- Our own AFSL — no dealer group above us
- No institutional or product-provider ownership
- Fixed fees, agreed before any work begins
- No % based investment fees
- No insurance commissions or trails
- No referral payments
- An approved product list built on due diligence, not relationships
- Full accountability for every recommendation we make
We chose this structure because we believe the cleaner the model, the better the advice. When there's no institutional pull, no product shelf to justify, and no commercial relationship with a fund manager creating a preference — the question of what's actually right for you gets a cleaner run every single time.
What this looks like day to day
- We can recommend any suitable product on the market — we're not limited to a shelf
- We don't earn more if you stay in a product longer
- We don't receive payments from fund managers or product providers
- Our approved product list is reviewed on merit — nothing else drives it
- We hold our own licence, so the responsibility for your advice rests squarely with us
- If the right answer is to do nothing, or to use a different product entirely, we'll tell you that
Diligent Financial Planning is a fee-only advisory firm that aims to help our clients achieve more with greater financial certainty. Read more about our services or get in touch with our team.
The information provided in this article is general information only and does not take into account your personal objectives, financial situation or needs. It is not intended to constitute personal financial product advice. You should consider whether the information is appropriate for you in light of your personal objectives, financial situation and needs, and consult a qualified financial adviser before making a decision.
References to adviser structures and licensing models are general in nature and intended to illustrate different advice environments. Individual arrangements vary significantly between licensees, dealer groups, and advisers. The use of descriptors such as "self-licensed" and "independent" in this article refers specifically to the structure of Diligent Financial Planning's own licensing and ownership arrangements. The term "independent" has a specific legal meaning under section 923A of the Corporations Act 2001 (Cth); this article does not constitute a formal claim under that provision.
Diligent Financial Planning Pty Ltd is a Corporate Authorised Representative (No. 1234150) of Diligent Financial Services Pty Ltd ABN 88 653 879 675 AFSL No. 535390. This work is copyright. Apart from any use permitted under the Copyright Act 1968, no part may be reproduced by any process without the permission of Diligent Financial Planning.
