Cheng, a relevant provider, has four clients who want advice this month. Three of them received an SOA from him last year; the fourth is new. For which client is a record of advice, rather than a new SOA, MOST likely to be enough?
Under s946B of the Corporations Act 2001 (compilation 19 Sep 2026), as substituted by reg 7.7.10AE of the Corporations Regulations 2001 (compilation 1 Sep 2026), no SOA is needed for further advice if the client has had an SOA setting out her relevant circumstances and neither those circumstances nor the basis of the advice is significantly different (RG 175.93, Nov 2024). Nell meets those conditions; Cheng must still keep a record and give her the remuneration and conflict information. Ivy's change in health is a significant change for insurance advice. Joan has never had an SOA from Cheng, so further-advice relief cannot apply. Lucy's separation and house sale change her circumstances substantially.
Being an existing client is not enough; circumstances and the basis of advice must be unchanged in substance.
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