Submission – Proposed update to RG 234 Advertising financial products and services

The Super Members Council (SMC) welcomes and supports ASIC’s proposed revisions to RG 234 to enhance clarity and improve consumer protection. These updates help modernise the 2012 guidance, incorporating post-2012 enforcement insights and RG 53’s past performance principles, enabling super trustees to proactively align marketing with ASIC expectations. SMC considers that ASIC has even greater opportunity in the revision of RG 234 to protect the interests of Australians and their retirement savings. This includes a focus on the potential for AI to be used to promote financial products through Agents. To strengthen RG 234 further, ASIC should also finalise the guide with more examples of modern aggressive advertising behaviours and tactics, including those that contributed to the collapses of Shield and First Guardian.