The FSC, a notable entity representing fund managers, superannuation funds, and financial advisory services, conveyed these concerns before a Parliamentary Committee. They specifically referred to the current reliance on wholesale accountant certificates as a verification tool, which members consider vital.

When approached by the Parliamentary Joint Committee on Corporations and Financial Services, the FSC chose not to delve into the perceptions of primary accounting groups regarding the persistence of the accountant certificate system. As for their take on the daily operations tied to generating qualified accountant certificates, the council admitted they weren't in the best position to comment.

"By necessity, many fund managers rely on qualified accountant certificates to verify that prospective clients meet the wholesale client/investor test,” affirmed the FSC. It emphasized its approval for the system, reasoning that individual accountants have superior insights into their clients’ eligibility compared to fund managers.

Highlighting the competitive pressures, the FSC said, “Australian wholesale fund managers already need to compete with:

  • domestic retail funds; and
  • offshore asset managers,

neither of which are burdened by the compliance expectations linked to the wholesale client/investor test requirements." The undercurrent is that increased due diligence demands would only add cost layers that could impact customers.

The necessity for rigorous due diligence, typically managed by accountants, if shifted to fund managers, would transform into an administrative hitch, subsequently impacting consumers. "This would make these wholesale products less attractive," the council explained. Addressing investment shortages within sectors like domestic venture capital, which rely heavily on such funds, was another key point highlighted in the discussion.

Sourced originally from a detailed account by Mike Taylor (Financial Services Council), these insights illuminate the delicate balance within fund management competition and regulatory responsibilities.