A provider may be doing a good job day to day. For a licensed FAP, confidence still needs to be supported by clear scope, controls, and evidence.
The arrangement began simply. A support provider was brought in to help with document preparation, CRM updates, and client follow-ups. The work was getting done. Advisers had more breathing rooms, clients were receiving updates, and nobody had raised a concern.
Then a director asked five ordinary questions: What exactly are they responsible for? Which systems can they access? How do we check the work? What happens when something goes wrong? Could we move the work safely if the arrangement ended?
The answers existed, but not in one place. Part was in the service agreement. Part was understood by the operations manager. Access has changed over time. Reviews happened informally, usually when somebody remembered to ask.
Good service and good governance are not the same thing
A provider can be capable and responsive while the FAP’s own oversight remains too informal. That distinction matters because outsourcing changes in who performs a task. It does not transfer the FAP’s licence responsibilities.
Standard Condition 4 applies where a FAP relies on an outsourced system or process to meet its market services licensee obligations. The FAP must be satisfied that the provider can perform the service to the standard needed for the FAP to meet those obligations.
Five checks that make the arrangement easier to defend
- Capability: Is there evidence that the provider has the people, knowledge, supervision, and capacity required for the agreed work?
- Written scope: Do both parties understand what the provider may do, what remains with the adviser, and when a matter must be escalated?
- Data and access: Are system permissions appropriate to the role, reviewed when responsibilities change and removed promptly when no longer required?
- Monitoring: Can the FAP see work quality, overdue actions, exceptions, incidents and recurring problems without relying on reassurance alone?
- Continuity and exit: If the provider or a key system became unavailable, could the FAP recover records, reassign work and continue serving clients?
A current reminder about technology providers
On 6 August 2026, the FMA opened an exploratory thematic review into the use of artificial intelligence in financial advice. The review is fact-finding, not a new rule. Its focus on governance, oversight, record-keeping, data practices and consumer outcomes is still a timely reminder that FAPs should understand the external people and technology they rely on.
That does not mean every supplier needs the same level of scrutiny. The questions should be proportionate to the work, the information involved, and how heavily the FAP depends on the service.
Where A-Perform fits
A-Perform can work within an agreed scope, the FAP’s approved systems and defined escalation paths. Regular check-ins, visible task records, and documented handovers can help the FAP oversee the work. Due diligence, contracting, access decisions, monitoring and accountability remain with the FAP.
Practical takeaway
Choose one outsourced arrangement and answer the five questions without calling the person who manages it. Any answer that depends on memory is a useful place to strengthen the record.
Sources
Financial Markets Authority, Standard Conditions for Full FAP Licences: https://www.fma.govt.nz/assets/Licensing-guides/Standard-Conditions-for-full-FAP-licences.pdf
Financial Markets Authority, Thematic Review: Artificial Intelligence in Financial Advice, 6 August 2026: https://www.fma.govt.nz/library/reports-and-papers/thematic-review-ai-in-financial-advice/
General industry information only. Not legal, compliance, or financial advice.
