Fair and Reasonable Conduct

Guidance

The purpose of the Fair and Reasonable Guidance is to give Participants and their customers better insight into how the IFSO Scheme applies our fair and reasonable jurisdiction. For Participants, we hope that this will also help you apply the principles in paragraph 12 of the TOR to your own processes.

It is important to note that fairness is subjective. What you may think is fair can be completely different to your neighbour or colleague. Therefore, the Guidance is not intended to define fairness; rather, we want to give you practical examples of circumstance the IFSO Scheme will consider, when deciding what is fair and reasonable in accordance with paragraph 12 of the TOR.

This links in to the new CoFI legislation, which has grown out of the conduct and culture reviews of the banking and insurance industries, starting with the Hayne Royal Commission in Australia, and in New Zealand in 2018. According to the FMA, the focus is on putting conduct and the fair treatment of customers at the heart of every business. The framework is for registered banks, insurers and non-bank deposit takers, to be 1. licensed by the FMA in respect of their conduct towards consumers, 2. comply with a “fair conduct principle” to treat consumers fairly, through the requirement for financial institutions to implement a “fair conduct programme” (FCP) and 3. comply with regulations that ban target-based sales incentives.

In early 2025, financial institution licences come into effect.

Participant Resources

Watch the July 2023 webinar on Guidance on the Fair and Reasonable Jurisdiction of the IFSO Scheme (30 minutes), download slides.