A guide to help you ‘not be the person uninvited to Friday night drinks’.
A peer review is essentially a risk control, and a lot of practices use it. It is another set of eyes confirming the advice is appropriate for the client, meets licensee rules, and satisfies the clear, concise and effective requirement.
However, the review process can quickly become inefficient, and frankly, a waste of everyone’s time, when it focuses on low-impact formatting issues or stylistic preferences. No client has ever complained about whether the word “superannuation” is capitalised. But clients do complain (and regulators will intervene) when advice is unsuitable, unclear, or misleading.
When peer reviewing another colleague’s work it is a skill that requires proper judgement, diplomacy and a focus on what genuinely matters.
This guide outlines how to provide effective, constructive feedback when reviewing a colleague’s SOA.
What the review is checking
- Compliance with ASIC Regulatory Guide 175 and the Corporations Act 2001
- The Best Interests Duty under s961B demonstrated clearly and reasonably
- Disclosures, product comparisons and fee statements that are accurate and consistent
- Writing the client can follow
- Alignment with licensee rules
1. Start with a measured tone
Tracked comments carry tone. Review on a day when you're not rushed or irritated, or the author will be defensive before they reach the substance.
Sort comments into three categories so the author knows what to act on:
- Required: must be changed
- Suggested: would improve clarity, tone or accuracy
- Consider: an observation, question or preference
Phrase points as questions or recommendations.
- Works: "Could we clarify how this strategy links to the client's goal of retiring at 60?"
- Avoid: "Where did you get this from??"
2. Prioritise high risk areas
Compliance obligations, client risk and miscommunication of the advice produce the complaints, breaches and liability. Spend the review time there.
Check:
- Fee disclosures
- Product replacement comparisons
- Conflicting statements or numbers
- Paragraphs that do not make sense
- Legislative application
- Client details
Leave alone:
- Capitalisation of terms like superannuation and account-based pension
- Passive voice, which is a style question rather than a compliance one
- Decimal places
- Spacing and minor formatting
Where the same formatting problems recur across the team, fix the template or run group training.
3. Anchor feedback to formal guidance
Citing RG 175, the Corporations Act or licensee policy depersonalises the comment and makes the change easier to justify.
A lot of what gets reviewed sits in a grey area. Licensees interpret the law differently and experienced paraplanners can reasonably disagree on the level of disclosure required. Where a point is contestable:
- Flag it for discussion rather than rewriting it
- Check with compliance or the internal policy
- Record your reasoning in the comment
Example: "Level premiums are recommended but I can't see the stepped versus level comparison, and I think the licensee wants it in the SOA rather than on file. See the Insurance Guide. Happy to confirm, the policy isn't clear."
4. Be specific
A highlighted sentence, or a comment reading a hostile "???", leaves the author guessing and creates avoidable back and forth.
Each comment should cover:
- The concern
- What it affects: compliance, clarity or accuracy
- A way to resolve it
Example: "This mentions a Centrelink benefit without stating the amount. Suggest adding the pension benefit in dollar terms so it's clear for the client."
5. Recognise the good
Naming the strong sections reinforces good practice and stops the review reading as a list of failures when most of the SOA is sound. Everyone misses things under time pressure or on complex advice.
Where a section is written particularly well, put it forward for the shared strategy library.
Example: "Good explanation of the Division 293 implications, ties in well with the contribution strategy. A couple of tweaks to the table and it's done."
6. Say something
Holding back a concern because it might offend, or because it feels picky, is how compliance risks get through. Raising a question shows diligence.
Example: "Not sure the transfer balance cap has been picked up here, worth checking the calculation against the cap history."
7. The standard is appropriate, not perfect
There is no legal requirement to give the best possible advice. The Best Interests Duty requires the client's interests to be prioritised over the adviser's, and the advice to be appropriate for their circumstances. Advice that is well reasoned and suitable meets the threshold, even where you would have approached it differently.
- Works: "This fits the client's goals. I wondered about an annuity for the Centrelink outcome and couldn't see it in the alternatives, happy to talk it through."
- Avoid: "This isn't correct, why wouldn't you use an annuity??"
Areas to cover
Finally, when reviewing a peer’s SOA, focus on areas most likely to carry compliance, client, or business risk.
Look at the SOA from a birds-eye view, rather than getting stuck in the weeds and over-correcting minor details.
Concentrate on:
- Best interest and strategy alignment
- Goals, Scope and Assumptions
- Product recommendations and replacement of product
- Basis of advice and risks and consequences
- Fees and remuneration
- Client information and accuracy
- Licensee disclaimers
- Legislative and Technical Accuracy
- Clarity and Communication
It would be particularly concerning if a peer review is returned with only formatting or stylistic suggestions. That usually indicates the reviewer has either missed the more critical aspects of the SOA or is focusing on lower-risk issues out of habit or lack of confidence. In either case, the review process isn’t functioning as it should and further training would be required.
Refer to the attached Sample Peer Review Document to help identify the areas that should be checked.
Remember…
Peer review should never feel combative. Done well, it is a collaborative process that strengthens advice quality, protects clients, and supports professional development across the team.
Access Melanie Drago’s Peer Review checklist here.
Melanie Drago, Founder of Tanngo - an innovative new platform to help advisers and contractors work together online.
