Understanding Advice Fee Caps

What are regulator expectations in relation to advice fees?

APRA and ASIC released joint letters to superannuation trustees in April 2019 and June 2021 regarding superannuation trustee’s obligations with respect to advice fee deductions from super accounts. These letters outlined (and then reinforced) the regulators’ expectations of Trustees in respect of:

member consent for fee deductions
provision of services and review of advice
sole purpose test, and
deductions being in member best interests.

In May 2024, ASIC released Report 781, Review of superannuation trustee practices: Protecting members from harmful advice charges (Report 781) and outlined its expectations of trustees including:

proactive checks of a sample of advice documents
use of appropriate fee caps
robust practices for onboarding advisers and licensees, and
active monitoring of advisers and licensees.

Macquarie Investment Management Limited (MIML), as trustee of the Macquarie Superannuation Plan, has obligations to oversee advice fees being paid from members’ accounts and to meet the expectations of APRA and ASIC.

What are Macquarie’s caps on advice fees?

In the application, Advice Fee Form and switch forms available in Adviser Online, we’ve placed limits on what can be entered as advice fees from your client’s Macquarie Wrap account. In limited circumstances, we may consider exceptions for advice fees that exceed these caps. If you or your client requires an exception, please connect with us via live chat.

We reserve the right to update the Advice Fee Caps at any time without notice.

Advice Fee Caps – Super and Pension accounts

Advice Fee Caps that apply for Super and Pension accounts are reviewed annually and have been revised from 1 October 2024 for new advice fee arrangements and renewals. In revising the caps we’ve considered:

demographics, account balances and advice fees of members and their super and pension accounts within the Macquarie Superannuation Plan (MSP), and
average cost of advice per industry research on advice fees.

Advice Fee Caps – Super and Pension accounts from 1 October 2024

Fee type	Fee structure	Cap (ex GST)
One-off advice fee	Flat dollar	$17,500
Fixed term and Ongoing advice fees	Flat dollar	$17,500 pa
	Flat percentage	1.75% pa of total account balance
	Tiered percentage	1.75% pa of account balance in each tier
Transaction advice fee (excluding auto plans)	Flat dollar	$200 per transaction
Transaction advice fee (excluding auto plans)	Flat percentage	1.75% of each transaction
Minimum balance, under which no advice fees are allowed to be paid¹		$10,000 minimum account balance

1. One-off and Transaction advice fees will accrue on the account and will only be collected when the account balance exceeds $10,000 on the last day of the month or just prior to account closure. Fixed term and Ongoing advice fees will not be charged if the account balance does not meet the minimum requirement and will not accrue on the account.

Different caps on advice fees apply to IDPS accounts in the Advice Fee Form.

When does Macquarie withhold advice fees?

We may choose to withhold or not charge advice fees in certain circumstances including where:

your client’s super or pension account balance is below the minimum account balance of $10,000 at either the end of a month or just prior to account closure
we become aware of concerns about you or your licensee and consider that it is reasonably required to protect your client, or
we believe they may not be permissible under superannuation law.

We reserve the right to ask you and/or your client for evidence of the services that are to be, or have been, provided for advice fees to comply with our obligations under law.

How do I request a fee outside of the caps?

As a trustee, we have obligations to oversee advice fees being paid from members’ accounts.  In the first instance, we encourage advisers to set their fees within the fee caps to have the most streamlined experience possible. However, we understand that in some circumstances a higher fee for particular clients is warranted, given the more complex nature of the advice being provided.

In these circumstances, we will consider requests above the caps, however these requests will require upfront provision of evidence before the fees can be accepted. To request a fee above the caps, we’ll require:

a request to be lodged via Request Centre in Adviser Online, detailing the amount, frequency and structure of the fee you intend to charge
a signed and completed Statement of Advice (all pages), detailing all information including the specific advice provided for the client’s account you intend to charge the fee fo
any other supporting documentation (ongoing service agreement, evidence of a periodic review, fee disclosure statement or client service agreement) that may support your request.

All documents must be uploaded via Request Centre by creating a request and selecting Maintain account fees under What would you like to do?’

When considering your fee request, please note we can’t guarantee each request will be approved and we won’t provide reasoning behind each decision. When our review is complete, we’ll promptly notify you of this outcome.

If approved, we’ll send you a paper form for you and your client to complete.

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