In updated guidance from ASIC in relation to the financial
resource requirements that apply to some types of Australian
Financial Services Licensees (Licensees) published
in
Report 769 (Report), ASIC has also made
comments on the issue of dormant Licensees.
ASIC's guidance in relation to dormant Licensees means that
any Licensee which is subject to a financial obligation by way of
the authorisations included on its Licence, must meet the
applicable requirement, from the date the Licence
authorisations take effect. For many Licensees, and those
looking to apply for or acquire an AFSL, this will mean future
planning to ensure the appropriate cash reserves are held.
ASIC's commentary states that where a Licensee holds an
authorisation which triggers particular financial obligations,
these obligations apply regardless of whether the Licence
authorisation is currently being utilised by the Licensee. An
example of this is the NTA requirement that applies to
custodians.