1. Financial Services Regulation (FSR)

1.1 Repetition of information in a Statement of Advice

The legislation provides that a client does not have to be given a Financial Services Guide if they have already received a Financial Services Guide containing all of the information that the new Financial Services Guide would be required to contain. This approach makes practical sense when distributing Financial Services Guides and could be extended to Statements of Advice.

Amendments to the Corporations Regulations, which came into effect on 20 December 2005, provide an exemption from the need to provide a Statement of Advice in respect of further advice. The significance of the change is that the exemption potentially applies to any provider of personal advice, and in respect of advice in relation to any financial product. There are no limitations on the means by which the further advice is provided.

The exemption applies where the client has previously been given a Statement of Advice which sets out the client’s relevant personal circumstances and those circumstances are not significantly different at the time further advice is provided from the circumstances that existed at the time the advice in the Statement of Advice was given.

If there is a significant difference in either the relevant personal circumstances of the client or the basis of the further advice (to the extent the advice is based on other matters) then the exemption cannot be relied upon, and a Statement of Advice for the further advice is required.

The law could be changed so that where information has already been given to a client in a Statement of Advice, it does not have to be repeated in a Statement of Advice regarding further advice.

Consultation Issue Comments are sought on whether it is appropriate to provide that information already given to a client in a Statement of Advice does not have to be repeated in a subsequent Statement of Advice, and whether any conditions should apply.

 

1.2 Situations where a Statement of Advice does not have to be prepared

Generally, a Statement of Advice must be provided to the client when, or as soon as practicable after, advice is provided. In any event, the Statement of Advice should be given before the adviser provides the client with any further financial service that arises out of, or is connected with, the advice. The requirement to provide a Statement of Advice may include situations where no financial product is recommended to the client and no remuneration is received in respect of the personal advice given. This may potentially lead to annoyance of consumers. It also imposes additional costs on industry.

Currently, ASIC provides some limited guidance to deal with the situation where the adviser is involved in preliminary fact-finding. ASIC does not require a Statement of Advice in a fact-finding process as long as:

• the consultations have a genuine fact-finding purpose relating to the preparation of a Statement of Advice and the adviser limits each consultation to this purpose; and
• the adviser clarifies with the client, at the outset of each fact-finding consultation, that:
  • the purpose of the discussion is for the adviser to find out about the client’s personal circumstances so that they can prepare personal advice that they will provide to the client in a Statement of Advice; and
  • on this basis, the client should not act on any representations made during the consultations.

While going some way to addressing the concerns of advisers, this guidance still does not make the rules clear enough.

A response could be to clarify the law so that in a situation where personal advice is given, but no financial product is recommended and no remuneration is received for the advice, a Statement of Advice does not need to be prepared.

Consultation Issue Comments are sought on whether it is appropriate to specify that in a situation where personal advice is given, but no financial product is recommended and no remuneration is received for the advice, a Statement of Advice does not need to be prepared.

 

1.3 Issue of disclosure documents when product or advice is rejected

A Financial Services Guide and Statement of Advice generally have to be given to a client, even if the client makes it clear that no product will be acquired. This can be annoying to consumers and adds additional costs to providers.

To address this issue, the law could specify that if a client clearly rejects a product and/or advice, a Financial Services Guide and Statement of Advice do not have to be provided in respect of that product and/or advice. This provision could be similar to an existing provision that a Product Disclosure Statement does not have to be given if the client makes it clear that the financial product will not be acquired.

Consultation Issue Comments are sought on whether the law should specify that if a client clearly rejects a product and/or advice, a Financial Services Guide and Statement of Advice do not have to be provided in respect of that product and/or advice.

 

1.4 Provision of Financial Services Guide by third party custodian or administrator

Where a custodian provides advice to the responsible entity of a managed investment scheme, the custodian will generally need an Australian Financial Services Licence covering the advice activities and would be required to provide a Financial Services Guide.

The receipt of a Financial Services Guide from a third party custodian or administrator of a superannuation fund or managed investment scheme has the potential to confuse the members of the fund or scheme, who may have no direct contact with the custodian or administrator.

To deal with this potential confusion, the law could be changed to exempt a third party custodian or administrator of a superannuation fund or managed investment scheme from the Financial Services Guide requirements.

Consultation Issue Comments are sought on whether it would be appropriate to exempt a third party custodian or administrator of a superannuation fund or managed investment scheme from the Financial Services Guide requirements and, if so, whether any conditions should apply to such an exemption.

 

1.5 Combining a Financial Services Guide and Prospectus

Under the legislation, a Financial Services Guide is required to be provided separately to the disclosure documents (such as a prospectus) required under the Chapter 6D fundraising provisions of the Corporations Act for the offer and issue of securities.

The legislation enables a Financial Services Guide and a Product Disclosure Statement to be combined.

For reasons of convenience and consistency, the law could allow a Financial Services Guide to be combined with a prospectus and the other forms of offer documents specified under Chapter 6D dealing with the offer of securities.

Consultation Issue Comments are sought on whether a provision should be made to allow a Financial Services Guide to be combined with a disclosure document under Chapter 6D, similar to the provision which enables a Financial Services Guide and Product Disclosure Statement to be combined.

 

1.6 Updating Financial Services Guides

ASIC provides relief (Class Order 03/237) from the requirement to include updated information in addition to, or in substitution for, any information the Product Disclosure Statement contains at the time it is given, provided the information is not materially adverse. This exemption does not extend to Financial Services Guides.

The law could be changed so that a Financial Services Guide does not need to be updated where the change relates to information that is not materially adverse.

Consultation Issue Comments are sought on whether it is appropriate to remove the requirement to update a Financial Services Guide where the change would relate to information that is not materially adverse, provided there is disclosure on how access can be made to the updated information.

 

1.7 Standardised Financial Services Guide

Some banking institutions have community-owned branches, which are established as separate legal entities that are required to issue separate Financial Services Guides. Employees of these community bank branches are required to be formally appointed as authorised representatives and are required to include their individual details in the Financial Services Guide. This creates an administrative burden that does not apply to institutions which have company-owned branches and are able to produce a standardised Financial Services Guide.

The law could allow community branches of banking licensees and individuals that are sub-authorised by authorised representatives to have a standard Financial Services Guide.

Consultation Issue Comments are sought on whether it is appropriate to allow for a standard Financial Services Guide for community-owned branches of banking licensees and individuals that are sub-authorised by authorised representatives.

 

1.8 Small business test

The test for what constitutes a small business in Chapter 7 of the Corporations Act dealing with financial services regulation takes account only of the number of employees of the business and does not include other relevant criteria such as assets and turnover. In this context, a small business means a business with 10 or fewer people directly involved in providing financial services, excluding administrative and support staff.

For the purpose of determining what is a small business, the law could be changed to include asset and/or turnover criteria based on specified thresholds.

Consultation Issue Comments are sought on whether it is appropriate to amend the small business test to include asset and/or turnover criteria, and what would be appropriate thresholds if those criteria were applied.

 

1.9 Treatment of superannuation trustees

The legislation determines when a superannuation fund trustee is considered to be a retail or wholesale client in respect of the provision of financial services relating to superannuation products. Trustees of individual funds with more than $10 million are currently considered wholesale clients.

There are quite a few trustees that hold significant assets overall in a number of funds, but individually each fund falls below the $10 million threshold. There may be scope to enable trustees of multiple funds to aggregate those funds for the purposes of meeting the asset threshold, to enable them to be treated as wholesale clients.

Consultation Issue Comments are sought on whether it is appropriate to allow for aggregation of funds for wholesale test purposes, where a superannuation fund trustee administers more than one fund.

 

1.10 Treatment of employers

The legislation provides that all employers are retail clients in respect of the provision of financial services relating to superannuation products.

This situation causes difficulties for large employers with sophisticated human resources capabilities which have to go through the irrelevant exercise of receiving retail disclosure regarding the superannuation funds they are considering.

There may be scope to enable employers, other than those who operate a small business, to be classified as wholesale clients.

Consultation Issue Comments are sought on whether employers operating businesses other than small businesses should be considered to be wholesale clients in respect of the provision to them of financial services relating to superannuation products.

 

1.11 ‘Bundled’ general insurance products

Under the legislation, consumers must be treated as retail clients when acquiring a group or ‘bundle’ of general insurance products that have a small component of products to which the retail client obligations apply, but which are predominantly products for which the consumer should be treated as a wholesale client. This creates excessive disclosure for consumers and increased obligations for insurers and brokers who are required to meet the retail client requirements.

The law could be changed to allow ‘bundled’ general insurance products that are predominantly directed at wholesale clients to be treated as totally wholesale.

Consultation Issue Comments are sought on whether it is appropriate to treat bundled general insurance products that are predominantly wholesale as totally wholesale and, if so, what conditions or protections should apply to ensure that genuinely retail clients are not prejudiced.

 

1.12 ‘Badging’ of disclosure documents

‘Badging’ or branding of products with information about persons other than the product issuer is permitted. However, any such information must not include anything that might create the impression that the other person is the issuer or seller of the product.

If a subsidiary does act as an authorised representative of its (licensed) parent company when providing a financial service, it needs to ensure that there is proper disclosure of this relationship. This is significant in terms of badging a financial product, and disclosure documents relating to a product. The licensee and subsidiary need to ensure that the way in which a product or document is badged does not create the impression that the representative is conducting a business in their own right, that is, acting as a principal.

There may be scope to amend the legislation to clarify that badging of documents does not constitute the provision of a financial service (that is, it is not an implied recommendation).

Consultation Issue Comments are sought on whether the issue of badging needs to be clarified and whether conditions should be applied to any exemption from badging being considered the provision of financial product advice.

 

1.13 Jurisdictional reach

1.13.1 Australian financial services licence holders acting on behalf of others

The law was recently refined to provide an exemption from licensing for overseas service providers, where they deal with an Australian Financial Services Licence (AFSL) holder acting on its own behalf. This recent change does not take into account the situation where the AFSL holder’s financial services business includes acting on behalf of others in the form of a trustee of a superannuation fund or a responsible entity of a managed investment scheme.

The exemption from licensing for overseas financial service providers, where they deal with an AFSL holder, could be extended to situations where the overseas service provider is dealing with an AFSL holder that is acting on behalf of others (such as a trustee of a superannuation fund or responsible entity of a managed investment scheme).

Consultation Issue Comments are sought on whether it would be appropriate to extend the new licensing exemption and if so, whether any conditions should apply to ensure those on whose behalf the AFSL holder is acting are adequately protected.

1.13.2 Offshore branches

At present, offshore branches of AFSL holders, such as banks, are subject to Australian financial services regulation.

Further clarification is desirable on the jurisdictional scope of Australian financial services regulation with respect to the application of the legislation to financial products and services being offered by AFSL holders (particularly authorised deposit taking institutions, such as banks) in other countries through offshore branches.

The clarification would relate to the exemptions in the law applying to foreign financial service providers being extended to foreign branches of AFSL holders.

Consultation Issue Comments are sought on whether the exemptions from licensing and disclosure applying to foreign financial service providers can be extended to offshore branches of AFSL holders.

 

1.14 Dollar disclosure for general insurance

The dollar disclosure provisions require Australian Financial Services Licensees and their representatives to disclose the costs and benefits of financial products as amounts in dollars. The provisions apply to documents such as the Product Disclosure Statement and the Statement of Advice.

Costs and benefits do not have to be disclosed in dollars where ASIC determines that, for a compelling reason, dollar disclosure is not possible, would be unreasonably burdensome or would be contrary to client interests. In such cases, costs and benefits must be disclosed as a percentage or description instead, together with worked dollar examples (unless inappropriate).

The dollar disclosure provisions for general insurance Product Disclosure Statements may result in confusing, lengthy and possibly false or misleading disclosure because a general insurer cannot determine the exact dollar costs and benefits of a general insurance product until they have assessed the risk of a consumer and determined the consumer’s required level of coverage. An insurer makes these assessments after they give a consumer a Product Disclosure Statement. As such, general insurance Product Disclosure Statements currently include many broad descriptions of how costs and benefits would be calculated.

The dollar disclosure provisions could be refined so that they apply appropriately to general insurance products. This may include allowing dollar disclosure to occur through a document other than the Product Disclosure Statement, for example, a policy schedule.

Insurers provide a consumer with a policy schedule after they have assessed the risk of the consumer and after the consumer has specified their desired level of coverage. The policy schedule specifies costs and benefits in dollar amounts that may only have been described in the Product Disclosure Statement.

Consultation Issue Comments are sought on whether specific dollar disclosure requirements should be prescribed for general insurance products.

 

1.15 Incorporation by reference in disclosure documents

Disclosure documents can be lengthy due to the inclusion of information that is repeated in other disclosure documents or is otherwise available, such as on websites.

Various measures to reduce duplication between disclosure documents and to eliminate unnecessary information have been implemented through recent refinements to the law. However, there may be scope for a more general ability to ‘incorporate information by reference’ into disclosure documents from other sources – such as websites or client files – rather than having to set that material out in the disclosure document itself.

It may be possible to expand on the circumstances in which incorporation by reference is permissible to include standardised or general information prepared by industry. For example, in relation to a superannuation product, information about preservation rules is set by legislation and is therefore ‘standard’, and may not need to be set out in a Product Disclosure Statement or Statement of Advice.

Consultation Issue Comments are sought on the extent to which disclosure documents should be permitted to 'incorporate information by reference', including information provided in other documents required under the legislation and from other sources.

 

1.16 Exemption from FSR retail client obligations for secondary service providers

A secondary service provider is one who provides a financial service to an intermediary who then passes it on to a retail client.

Recent refinements to the law relieve a secondary service provider from the need to give the retail client a Financial Services Guide. In situations where the intermediary (who is a licensee or authorised representative) accepts responsibility to the retail client for the provision of a financial service, it may be possible to relieve the secondary service provider from all obligations it has to the retail client (not just the Financial Services Guide obligation). Situations may also arise in which the secondary service provider accepts responsibility to the retail client for the provision of the service and there may be scope in such circumstances to relieve the intermediary from some or all of its obligations to the client in respect of the service.

Consultation Issue Comments are sought on relieving secondary service providers from their obligations to retail clients in specific situations. Relief could be provided where the intermediary accepts responsibility to the retail client for the financial services provided by both. Comments are also sought on relief in the converse situation where the secondary service provider accepts responsibility for the services provided by the intermediary.

 

1.17 Changes to the scope of general advice

The definition of general advice is broad, as it constitutes any financial product advice that is not personal advice. The definition of financial product advice includes recommendations, statements of opinion or reports of either of those things intended to influence people in making a decision about a financial product.

The law requires persons giving financial advice to do so only if the advice is within the scope of their licence conditions. Licensees are subject to qualification and training requirements. The law has had the benefit of significantly improving the quality of advice being given. However, the framework within which financial advice can be given is quite restrictive and subject to significant legal liabilities. The result has been that far fewer people are willing to give financial advice in the form of general educational seminars. In addition, the licensing and training requirements mean that it is not financially viable for advisers to give personal financial advice where the amounts involved are small. This detracts from efforts to improve financial literacy in the Australian community.

Recent refinements to the law have narrowed the scope of general advice to make it clear that a financial product issuer can give advice about its own products without it amounting to financial advice. In addition, ASIC clarified the interpretation of the law so that the mere possession of information about a client’s relevant personal circumstances does not mean that advice is automatically deemed personal advice.

While these changes have been widely welcomed, there is potential to make the system more practical, particularly as the broad scope of the general advice definition in some situations results in excessive obligations on providers to adhere to licensing, training and disclosure requirements. Further work could be done on the boundaries of where financial advice begins imposing training and licensing obligations, and on the question of whether the divide between general and personal advice should be moved so as to limit when advice can be regarded as personal advice, thereby avoiding the accompanying licensing and disclosure obligations.

There is scope to consider how the boundaries of what constitutes general advice could be adjusted so as to avoid licensing and disclosure requirements for general educational activities and how this relates to the scope of personal advice.

Consultation Issue Comments are sought on the appropriate boundaries for, and between, general and personal advice.

 

1.18 Exemption from the requirement to provide a Financial Services Guide

The Corporations Act states that a providing entity does not have to give a client a Financial Services Guide in situations where the financial service is general advice provided in a public forum. However, under the Corporations Regulations, a public forum is defined as an event which ‘any person is permitted to attend’. This definition of public forum excludes such forums as educational seminars that are specifically directed at a group of employees, for example.

In seminars such as these, the providing entity is required to provide its Financial Services Guide to attendees because they are excluded from the public forum definition and therefore, the providing entity is excluded from the exemption from providing its Financial Services Guide to attendees.

Extending the definition of public forum may reduce the amount of excessive disclosure to attendees of educational and other such seminars.

Consultation Issue Comments are sought on broadening the definition of ‘public forum' to include such forums as employee educational seminars. This would make the exemption from the need to provide a Financial Services Guide more widely available, subject to any necessary conditions.

 

1.19 Threshold requirements for Statements of Advice

The legislation requires that a Statement of Advice be given to a client in all circumstances relating to a financial service, even in situations where the advice is relatively minor. The requirement to prepare a Statement of Advice in all circumstances means that it is not commercially viable for advisers to give advice where the amounts involved are small. This creates an access problem. While the investment amounts might be small from an advisor’s point of view, they can be very significant to the wellbeing of an investor who might like to get professional help with their investment decision.

One way to address this issue is to consider introducing thresholds for the Statement of Advice requirement. Where no Statement of Advice is required, the recently introduced record of advice arrangements for further related advice could also be applied to below threshold advice.

Consultation Issue Comments are sought on whether it is appropriate to provide an exemption from the Statement of Advice requirements for minor advice that falls below a certain threshold and what an appropriate threshold might be.

 

1.20 Oral disclosure

The law prescribes the information to be disclosed orally in time critical situations where the client requires the financial service or advice to be provided immediately or by a specified time, and it is not reasonably practical for a written disclosure document to be given to the client before that service or advice is provided. The information that is required to be disclosed orally is certain information that would be required to be included in the written Financial Services Guide and/or Statement of Advice.

Recent refinements to the law amended the oral disclosure requirements for financial products with a cooling off period by reducing the amount of information that is required to be orally communicated in time critical cases where a written Product Disclosure Statement is provided later.

There may be scope to reduce the oral disclosure requirements in respect of Financial Services Guides and Statements of Advice for products with a cooling off period, in line with the reduction in Product Disclosure Statement oral disclosure for these products.

Consultation Issue Comments are sought on the desirability of reducing oral disclosure requirements that apply to Financial Services Guides and Statements of Advice, for products with a cooling off period.

 

1.21 Sickness and accident insurance

Under the law, sickness and accident insurance is treated as a financial product and would normally be provided to retail clients. It is therefore subject to the standard disclosure requirements.

This causes difficulty where sickness and accident insurance forms part of a workers’ compensation arrangement. Typically the coverage is provided to an employer for the benefit of an injured employee. Because of variations in arrangements across Australian jurisdictions, the sickness and accident insurance component in workers’ compensation may be treated as a wholesale or retail financial product. Where it is treated as a retail product, unnecessary disclosure is required. Sickness and accident insurance is subject to statutory requirements in this context and forms part of standard workplace arrangements. Retail financial services disclosure is therefore superfluous.

To create consistency in the treatment of sickness and accident insurance where it forms part of a workers’ compensation arrangement, the law could be revised so that where the client is an employer seeking liability coverage for the benefit of employees, the employer would be deemed to be a wholesale client.

Consultation Issue Comments are sought on whether any amendments to the legislation are warranted to clarify that a provider of sickness and accident insurance can treat a client as wholesale where cover is for the liability of the employer for the benefit of an employee.

 

1.22 Sophisticated investors

The tests that determine whether a client is retail or wholesale are, necessarily, somewhat arbitrary. There may be some people who are regarded as retail clients by definition in the legislation, but possess sufficient experience or knowledge to make financial investment decisions such that they do not need the consumer protections offered to retail clients.

Recent refinements to the law amended the definition of a professional investor to a person with a minimum of $10 million in gross assets.

There are sophisticated investors who are professionally trained in financial management and investment but do not meet the $10 million assets threshold. Such sophisticated investors may consider retail disclosure an unnecessary hindrance to activities they well understand.

There may be scope to allow retail investors that wish to be treated as wholesale clients to obtain accreditation that enables them to be treated as wholesale investors with respect to dealing in financial products traded on markets.

It would be necessary to consult with industry and representatives of sophisticated investors on the feasibility of such an accreditation system.

Consultation Issue Comments are sought on whether retail investors should be allowed to obtain accreditation that enables them to be treated as wholesale investors with respect to dealing in financial products traded on markets.

 

1.23 Authorised representatives

Insurance agents may act for a number of insurance companies. Each insurance company would typically be a financial services licensee responsible for the activities of the insurance agent as an authorised representative. As a licensee, the insurance company may be concerned that it could become liable for the activities of the insurance agent acting on behalf of another insurer. The Corporations Act requires insurance companies to consent to their insurance agent acting as an authorised representative dealing in a nominated competitor’s product. This is often referred to as cross endorsement.

The current law relating to cross-endorsement enables liability to be allocated according to the type of activities an authorised representative undertakes, such as providing advice or dealing in a financial product. In these circumstances where the type of activity is different, the licensees are not jointly and severally liable. However, with regard to risk insurance, generally the insurers authorise their representatives to provide a range of financial services in relation to a particular class of product. As a result, the current liability arrangements do not address the liability issue appropriately as most insurers are effectively jointly and severally liable for most activities of their authorised representatives.

To address this concern, the law could be changed to refer to classes of risk insurance products rather than the type of services. This would mean that insurance companies would only be jointly and severally liable with another insurance company for the actions of an insurance agent where that agent provides financial services in relation to the same class of insurance product, such as motor vehicle insurance.

Consultation Issue Comments are sought on the scope to refine the cross-endorsement requirements of the legislation, taking closer account of the different classes of financial products that authorised representatives may provide on behalf of their authorising licensees.

 

1.24 Group licensing under FSR

One of the main intents of the legislation regulating financial services was to reduce regulatory burden and overlap where a number of financial services businesses are conducted in the one company group or conglomerate. The law was intended to remove or reduce the need for each of the businesses within the group to be licensed and regulated as a separate entity by allowing for group licensing. In practice, this aim was difficult to realise, due to the complexity of group structures and the need to ensure clear lines of accountability and liability.

The group licensing option has not been taken up in a significant way. It may be the case that better recognition of group structures in the licensing process could assist.

It is proposed that there be an examination of the factors that have inhibited the take up of group licensing and what could be done to facilitate such licensing.

Consultation Issue Comments are sought on why the group licensing option has not been taken up in a significant way and what could be done to facilitate such licensing.

 

1.25 Overlap of requirements in the Corporations Act and ASX Market Rules

There are some overlapping requirements in the Corporations Act and the ASX Market Rules in relation to:

• client order priority;
• confirmation of trades;
• managed discretionary accounts;
• principal trading;
• staff trading;
• trading records; and
• trust accounts.

There appears to be scope for the ASX to rationalise these requirements to reduce duplication in regulation.

The ASX has announced that it will rewrite its Market Rules to reduce complexity, compliance costs and overlap between the Rules and the Corporations Act requirements, while maintaining and strengthening market integrity.

Consultation Issue Comments are sought on the rationalisation by the ASX of the overlapping requirements in the Corporations Act and the ASX Market Rules relating to client order priority, confirmation of trades, managed discretionary accounts, principal trading, staff trading, trading records and trust accounts.

 

1.26 Policy Statement 146 – training requirements

ASIC Policy Statement 146 (PS 146) sets out the detailed training and competency requirements for authorised representatives and employees of financial services licensees. Some aspects of these training requirements are excessive, particularly in relation to the level of training required for persons who deal in, or provide advice on, relatively straightforward financial products.

Although ASIC has modified or clarified PS 146 in certain respects (including as part of the refinements to financial services regulation), some aspects of the policy are still not sufficiently flexible.

The Australian Government could consider comments from the community and consult with ASIC to determine how PS 146 could be revised to avoid a ‘one size fits all’ approach and allow for greater differentiation in the training requirements, recognising the different skills and competencies needed for advisers in different streams of business.

Consultation Issue Comments are sought on the streamlining of the training requirements in ASIC's Policy Statement 146.

 

1.27 Register of sanctioned financial service providers

If a person is sanctioned for breaching financial services regulation, this is usually made public by ASIC. However, this information is not recorded in an easily accessible and searchable form, such as through a public database.

There are a number of examples of an individual moving from firm to firm causing legal and regulatory problems for the organisation, and significant losses for clients, because the firm was not aware of sanctions imposed on that individual in the past.

There may be scope to aid businesses to easily and accurately identify past misconduct of prospective employees relating to corporate and financial services, which is on the public record, if a register of sanctioned individuals was established, for example, on the ASIC website.

In addition, a register that provided information on licensees that had been sanctioned for past misconduct might assist consumers when choosing a financial service provider.

Consultation Issue Comments are sought on the desirability of establishing a public register of sanctioned financial service providers and where such a register should be made available.

 

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