Diploma of Financial Counselling - Draft 1

CHCFIN010 Apply basic concepts of small business to financial counselling_Draft 1.0

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Unit application and prerequisites

UNIT CODE

CHCFIN010

UNIT TITLE

Apply basic concepts of small business to financial counselling

APPLICATION

This unit describes the performance outcomes, skills and knowledge required to identify the structure and current financial position of a small business and to use this information when providing information and advice as part of the delivery of financial counselling services to a client with a small business.

 

This unit applies to financial counsellors who work in agencies that meet the requirements for the Australian Securities and Investments Commission (ASIC) exemptions from holding a financial services or credit licence and provide services to clients who operate small businesses.

 

The skills in this unit must be applied in accordance with Commonwealth and State or Territory legislation, Australian standards and industry codes of practice.

 

No occupational licensing, certification or specific legislative requirements apply to this unit at the time of publication.

PREREQUISITE UNIT

CHCFIN006 Establish the financial counselling relationship

CHCFIN007 Provide counselling, advice and represent the client

CHCFIN008 Apply professional practice in financial counselling

CHCFIN009 Provide financial counselling within a social justice framework

COMPETENCY FIELD

 

UNIT SECTOR

 

47 Comments

Stand alone unit

"The benefit of small business being a 'stand alone' unit means that existing FC's are more likely to consider completing the unit as an 'upskill' option, it becomes a pathway to further education. Whereas having it included within the Diploma suggests it is mainly advertised to new FC's entering the sector. "

Michelle Ludwig 11.11.2021 03.39PM

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Generalists need basic small business knowledge

"Generalist financial counsellors need a basic understanding of small business concepts. This unit is designed to give generalist financial counsellor some basic knowledge about small business so that they can assist with simple issues and refer appropriately for more complex issues. This is a new aspect of the financial counselling role and requires some extension of the skills and knowledge that financial counsellors already have. For this reason, we are proposing that small business concepts are both addressed in a stand- alone unit and embedded in the other financial counselling units. This unit is not designed for specialist small business financial counsellors (that would require much more in-depth training). An important part of the unit will be a focus on financial counsellors understanding the scope of the role – when they can assist and when they can refer. "

Domenique Meyrick 11.11.2021 01.02PM

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1 Reply

"AIPC agrees with this - it is important that financial counsellors have knowledge of small business. If the unit is designed in a way that students are not overwhelmed, and that can be assessed in the generalist financial counselling space, we would support its inclusion as a core unit."

Hayley Wood 11.11.2021 04.48PM

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Specialised unit of competency

"Demand for small business financial counselling due to the current economic landscape i.e. COVID-19 supports the need for generalist FC’s to have a basic understanding of small business operations. Within the current Diploma, students could receive training on the basic structures of a business and hardship provisions available, but most importantly where to refer to i.e. accountant, lawyer, business advisor because it is a complex area for generalist FC’s to delve into. As a result, establishing a stand-alone area of specialty, an advanced unit of competency, might be a better option. This is because new students, especially those who do not currently have a background in small business operations or community service work might find the unit quite challenging. There is so much to learn throughout the Diploma, this could be better suited as a pathway for additional learning for more experienced FC’s who have been in the sector for a couple of years. For generalist FC’s, this would alleviate concerns regarding legal liability, as it would ensure there are specialist FC’s who would be very clear on the scope of their role and not step outside of the boundaries."

Michelle Ludwig 10.11.2021 12.26PM

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Overall comments on CHCFIN010

"This unit is better suited as a stand-alone skill set such as a problem gambling skill set. It requires the specialist knowledge and experience of an accredited financial counsellor. "

Jill McKinlay 10.11.2021 12.12PM

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1 Reply

"100% agree"

Sarah Davidson 10.11.2021 12.26PM

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Stand alone skill set

"Small business is better to be a stand-alone skill set, the same as Gambling, Family Violence, and other specialties; that way all FC’s that are fully quantified with years of experience would be ready to take on this new role within the sector without distorting the role of the financial counsellor. "

Robyn d'Argent 10.11.2021 11.14AM

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1 Reply

"100% agree with this also Robyn"

Sarah Davidson 10.11.2021 12.26PM

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Application

"If this unit was a unit in the Diploma there needs to be a clear description of small business in this section since this will assist the financial counsellor to determine their practice limits from the outset. there are too many definitions - e.g. The Australian Bureau of Statistics (ABS) defines a small business as a business employing fewer than 20 people. ... Micro-businesses (businesses employing between 1 and 4 people including non‑employing businesses) Other small businesses (businesses that employ between 5 and 19 employees); ATO- you are a small business [small business entity] if your turnover is less than $2 million [based on turnover or income not employees] or as in 2021 - may use one of 3 methods to determine whether a business is a small business etc. etc. "

Bernadette Pasco 09.11.2021 02.42PM

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1 Reply

"If ABS and ATO have different definitions of "small business", why not Financial Counselling Association also defines small business as "sole traders" with 1-2 employees in order limit the complexity of the financial issues? The course description includes "Access, assemble and interpret financial data about current financial position of the small business. Determine the tax status of the business and implications for the business. Use financial data to determine if the business is able to pay its debts and obligations". This is the job of an accountant, because it's not as simple as reading a personal financial position. When in business, it involves depreciation method on the business assets, which should be added back to the financial statement when assessing its business solvability. Is an FC capable of doing this even as a generalist? It may end up referring the client to an accountant any way. Basic concept of small business should be defined to "understanding the complexity of the business, then making referral to the right specialist". "

Harry Santosa 10.11.2021 12.21PM

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Apply basic concepts of small business to financial counselling

"Small Business units are areas of Advanced Specialisation, and should be delivered accordingly. Generally, Generalist FCs are not funded to work in this space, hence referring a relevant client to a "specialist small business financial counsellor" makes common sense, and accordingly specialist training provided as an ongoing requirement according to the role and funding and or FCA membership requirements. Small business, Rural FC, Gambling, Domestic Violence could all become "Advanced Specialties" as a higher level of competency given the complexities of the work we undertake in these fields of work. And more importantly maintaining the level of knowledge, and tools required for the level of competency and skill-set required in each of these specialties."

Mandy Jackson 08.11.2021 11.56AM

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1 Reply

"I agree this is for Advanced Specialisation FC's not for new students coming in to the sector "

Robyn d'Argent 09.11.2021 06.08PM

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Comment - Small Business Financial Counselling as a specialisation.

"Over 12 months ago team commenced its' service. We work with Small Business owners - specifically those currently impacted by the covid-19 pandemic. The majority of our team are/were graduates and this appointment is their first role in financial counselling work. Our recruitment process was heavily driven by consideration of each individual applicant's previous career experience - in equal measure to their understanding of the financial counselling role. We were acutely aware that the work would require financial counsellors that we well versed in the specific skillsets that regularly support small business operators ie accounting, insolvency, banking/lending and small business ownership. While we are not expected to provide these various areas of expertise, the combined knowledge within the team certainly contributes to the strength of the service we can offer the small business owners we met. Overall understanding of the intricacies of small business operation has formed the basis of the significant training that has followed. We do consider that this small business specific financial counselling training has resulted in a 'specialisation' within the financial counselling sector. We are continuing to build our knowledge as we progress. A constant within our processes is the end goal of empowerment for the client as defined within the Community Health model. To provide the SBO with an informed choice of available options to suit their circumstances with the focus on immediate benefit as well as long term improvement of their financial situation."

Liz McCarthy 05.11.2021 04.35PM

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1 Reply

"Great comment, agreed."

Mandy Jackson 08.11.2021 11.59AM

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Scope of FC role

"Small business financial counselling services, in some jurisdictions, cannot provide assistance to clients living in metro areas or to clients who have already closed their business. It is really important for generalist Financial Counsellors to have a base line understanding of how they can help a small business owner, this includes knowing when to refer onto other services"

Robyn Harris 05.11.2021 04.22PM

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1 Reply

"I do not disagree with what Robyn has written, but experiences FC's only "

Robyn d'Argent 09.11.2021 06.10PM

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Unit

"I believe financial counsellors require a general understanding of business structures, frameworks, regulations, etc. They also need to have a very clear understanding of when to refer on to an accountant / business advisor / lawyer etc. Business structures can be simple, and they can be incredibly complex, therefore FCs need to have enough knowledge to recognise where, and how, they can assist and where they cannot assist. Small business knowledge will also add value to cases where FCs and professionals work alongside each other to achieve the best outcomes for their client. For these reasons I believe the small business unit is important in terms of building the knowledge and capacity of FCs. Agree with other comments that Small Business Financial Counselling could be a specialist area of work, but that doesn’t negate the need to educate all FCs on small business finances so they can assist where appropriate and quickly identify where the support of another professional is required. "

Anne Crouch 05.11.2021 01.15PM

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3 Replies

"Very much agree with you Anne. FC (as generalist) should be equipped with basic knowledge in multiple disciplines (counselling, basic finance, credit law, community service & small business), but when the problem is more complex we need to refer to specialist. In addition to problem gambling & rural financial counselling, small business in greater depth can be added to specialisation unit. I initially wanted to specialise in small business FC, but this unit wasn’t available yet. Small business skill is just like a “mini MBA” in which the students need to study micro management skills including knowledge of operation, finance, marketing & Human Resources."

Harry Santosa 08.11.2021 03.08PM

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"Agree with these comments, very relevant to the applicable of knowledge and within the scope of practice."

Mandy Jackson 08.11.2021 07.09PM

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"Agree with your comments, Anne Crouch. The Diploma absolutely needs to cover more than what it currently does in this area, even if just so that a generalist FC's knows when a referral to another professional is required. "

Peter Thompson 09.11.2021 12.10PM

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In addition to the Financial Counselling course

"This subject should be an elective after the course has been completed. Some basic information could be completed. In my background I have studied a commerce degree and it is high risk to teach this module and expose a financial counsellor to a small business. In the first instance the client should have a qualified accountant to prepare their financial statements. It is unfair to expose a financial counslelor to legal liability for providing some assistance that the client takes as gospel. "

Domenic Vitalone 04.11.2021 11.08AM

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2 Replies

"I agree with this comment"

Sarah Davidson 04.11.2021 02.23PM

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"agree let it be a stand alone unit ( a skill set) after the Diploma "

Robyn d'Argent 09.11.2021 06.11PM

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Application

"Considering the application of this unit and the elements outlined, this should be delivered as a skill set rather than a single unit of competency within the Diploma of Financial Counselling. Financial counsellors would benefit from this an an upskill to their current qualification along with competency in a specialised area. This will support employment in the small business financial counselling roles and also assist with professional supervision for small business financial counsellors."

Natasha Syed Ali 01.11.2021 02.26PM

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1 Reply

"I agree with this comment"

Sarah Davidson 04.11.2021 02.23PM

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advanced skills

"Advanced skills are required for this unit and it would be good as part of an advanced skillset. Agencies that are engaged in smallbusiness financial counselling [very few] would then require the skillset to be completed as part of the small business role. this would protect clients and allow knowledge advancement once core knowledge about the social justice aspects of the work are embedded before dabbling in small business matters. "

Bernadette Pasco 29.10.2021 07.26AM

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1 Reply

"I agree with this comment"

Sarah Davidson 04.11.2021 02.23PM

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exemption statement

"should include in brackets [ASIC exemption 2017/293 and amendment 2020/635]"

Bernadette Pasco 29.10.2021 07.23AM

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1 Reply

"I agree with this comment"

Sarah Davidson 04.11.2021 02.24PM

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pre-requisite units

"having the other financial units in this course as pre-requisite units will not assist students to understand aspects of the australian monetary system required to understand this unit. "

Bernadette Pasco 29.10.2021 06.59AM

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2 Replies

"I agree with this comment"

Sarah Davidson 04.11.2021 02.24PM

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"Agreed"

Jill McKinlay 10.11.2021 12.14PM

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Unit application and pre-requisites

"in relation to the descriptor- which relates to exemptions from holding a financial services or credit licence and provide services to clients who operate a small business- the majority of agencies do not identify that they provide services to small business - with intake criteria not covering this. Financial counsellors do have clients with ABNs which is also defined as someone who has a business. Whilst this is the case, this descriptor provides a false outline of the work of financial counsellors , does not define small business and could blur professional boundaries significantly, putting the client at risk. "

Bernadette Pasco 29.10.2021 06.57AM

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2 Replies

"I agree with this comment"

Sarah Davidson 04.11.2021 02.24PM

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"The correct description in relation to the ASIC exemption is that it only applies to agencies that have an exemption from holding an Australian Financial Services Licence. Lending to small businesses is not covered by the National Credit Code, so the reference to the Australian Credit Licence isn’t correct and needs to be removed. The AFSL exemption allows financial counselling agencies to provide advice, within the scope of a financial counselling service, to individuals and small businesses. Small businesses are defined in the AFSL exemption as having fewer than 100 employees. This is consistent with the definition used by AFCA, the Banking Code of Practice and the Australian Small Business and Family Enterprise Ombudsman (the latter two have some other criteria too eg around turnover). It is up to each agency to decide whether they will extend their services to small businesses, or even a sub-set of small businesses. Professional boundaries in this sense will be set by each agency. It is also important to note that the licensing exemptions only apply to parts of the work of financial counsellors. Agencies and financial counsellors don’t operate under the exemption for lots of the work they do, for example, there is no licensing regime for providing advice about bankruptcy. "

Domenique Meyrick 11.11.2021 01.05PM

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should not be a core unit in the Diploma

"the important contexts of elements of small business can be emedded into the existing financial counselling units by outlining the knowledge elements that are important as part of assessment - e.g. identifying the nature / type of small busines/ working out links to personal debt and liability and immediate risk to personal assets etc. Beyond that, this content will make cloud the role of the financial counsellor and associated boundaries. This unit could be part of a skillset in the future at an advanced level - post Diploma completion and after a couple of years of practice [e.g. full membership eligibility ] "

Bernadette Pasco 28.10.2021 06.20PM

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2 Replies

"I agree that small business should not be a core unit but a specialisation unit for those who are really interested. It’s like a mini MBA program with complex knowledge to learn. The core units better strengthen financial counselling cluster, general counselling, co-assisting needs & credit law, then offer small business, problem gambling & rural counselling as electives. "

Harry Santosa 02.11.2021 12.49PM

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"I agree with this comment"

Sarah Davidson 04.11.2021 02.24PM

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ABS definition of small business is more aligned to financial counselling

"The Australian Bureau of Statistics (ABS) defines a small business as a business employing fewer than 20 people. Categories of small businesses include: Small businesses are more likely to have independent ownership and be operated independently. Microbusinesses in this model are 5 employees or less- this is much more aligned to the work of generalist financial counsellors who may deal with sole traders who have one or two employees. Agreed that the 100 employee limit opens pandora's box and is not a definition that suits an entrant to the financial counselling profession due to the complexities that brings on top of an already heavy financial counselling complex client focus"

Bernadette Pasco 28.10.2021 06.16PM

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1 Reply

"I agree with this comment"

Sarah Davidson 04.11.2021 02.24PM

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Small business definition with AFCA

"Small business definition is an organisation with less than 100 employees - thats quite large"

Christine Raymond 21.10.2021 08.25AM

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4 Replies

"I agree with this comment"

Sarah Davidson 04.11.2021 02.24PM

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"there are various definitions of small business - the ABS is different to the ATO - there is no consistency or definition in this unit"

Bernadette Pasco 10.11.2021 07.17AM

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"I agree with this"

Sarah Davidson 10.11.2021 08.07AM

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"The definition of small business in the AFSL exemption for financial counselling agencies is 100 employees or less. This is the same as that used by AFCA. The Banking Code of Practice and the ASBFEO also use 100 employees, but they also include some other elements (eg a turnover test). The Government is also planning to amend the Competition and Consumer Act so that its unfair contract terms provisions apply to any business with 100 employees (and a turnover test). In other words, the AFSL exemption for financial counselling agencies is broadly consistent with other key definitions of small business that are part of our world. There are however numerous definitions of “small business”. We understand that a recent consultation for the Australian Banking Association identified over 60. The financial counselling definition means that the test is simple to apply. The key question for an agency therefore is whether the debt issues for the business are too complex or not, rather than having to go through a process of assessing information about number of staff. (Do part-time staff count? What if there are lots of casuals? What if the small business is not sure? These were the kind of issues that AFCA had to deal with when it had a 20 employee limit in its rules - it was a nightmare.) For example, a business with 5 employees might have such a complex mix of debts, legal action etc that a financial counsellor should not get involved. Having say a 20 employee definition of small business is meant to be a proxy for complexity, but it may not be a good one. The practical reality though is that it is highly unlikely that a financial counselling agency is only ever going to hear from very, very small businesses. Small businesses with less than 20 employees represent 98% of all Australian businesses. The experience of the Small Business Debt Helpline is that 90% of callers have 5 employees or less, and just over half have no employees. Finally, if an agency wants to put in place a different definition (eg 5 employees, less than 20 employees) there is nothing to stop that. "

Domenique Meyrick 11.11.2021 01.06PM

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Concern

"Generally have a concern that the knowledge required is quite specific and should be a specialist field - the same as consumer credit and rural financial counselling just some examples"

Christine Raymond 21.10.2021 08.24AM

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1 Reply

"I agree with this comment"

Sarah Davidson 04.11.2021 02.25PM

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Elements and performance criteria

ELEMENTS

PERFORMANCE CRITERIA

Elements describe the essential outcomes

Performance criteria describe the performance needed to demonstrate achievement of the element.

  1. Adapt practice to small business context.
    1. Apply financial counselling professional practice frameworks to small business owners.
    2. Assist non-complex small businesses to manage debts and financial stress.
    3. Use secondary consultations and referral where matters are beyond the scope of the role.
  1. Confirm current business structure.
    1. Work with client to identify current small business structure.
    2. Identify legal and operational requirements of business that impact on businesses financial position.
  1. Assess and interpret financial data of small business.
    1. Work with client to identify and retrieve financial data that is missing or incomplete.
    2. Access, assemble and interpret financial data about current financial position of the small business.
    3. Determine the tax status of the business and implications for the business. 
    4. Use financial data to determine if the business is able to pay its debts and obligations.
  1. Provide advice to client.

 

 

    1. Provide client with information and advice regarding the financial position of the small business, within scope of own job role.
    2. Provide client with information and advice regarding the impact of the business on their personal financial position.
    3. Identify options available to the client, based on analysis of financial information and business position, including insolvency and closing the business.
    4. Identify and assist client to access external small business advice and support options.

41 Comments

Work loads

"Will agencies be are able to give the time to clients who need small business support. Our workloads are already large and I would hate to think that someone in financial hardship cannot access a Financial Counsellor when they need help due to the complexities of working with clients with small business needs. "

Anna O'Loughlin 11.11.2021 03.08PM

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Debt amounts

"Who will determine when the amount of debt is beyond the scope of the role of the FC "

Anna O'Loughlin 11.11.2021 02.57PM

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Non-complex small business

"1.2 How do we determine what is a 'non-complex small business'. Does this refer to the business structure, number of employees, business turnover, profit margin etc? "

Michelle Ludwig 11.11.2021 02.49PM

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1 Reply

"Agree with you Michael, only an accountant can assess the complexity of a “small business”, depending on its structure, operating system, number of employees, turnover, etc. Even when I have a small business, my accountant would charge different fees every year subject to evolving complexity. How can an FC assess such complexity with only basic knowledge? Assessing involves an analysis that needs to be based on expertise, not simply basic knowledge. A GP can assess whether a patient may have a heart issue, but determining what sort of specific heart issue needs a specialist assessment. This could be a relevant analogy. "

Harry Santosa 11.11.2021 03.28PM

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Element 4 and Performance Criteria

"Provide advice to client - these descriptors are outside of the scope of a generalist financial counsellor. More specifically performance criteria "...provide advice...including insolvency and closing the business..." these work tasks are of a higher level of competency than generalist training, and additionally insolvency practitioners are registered with ASIC. This area of work is an advanced BA specialty and should not be described or contained at Diploma level. An element that identifies/ describes financial equity ratios, perhaps, or liabilties vs asset ratios could be used as a basic tool for a referral pathway onto a specialist insolvency practitioner (as an example). We need to be mindful that graduates of the Diploma may not have the experience or life skills to understand financial principles associated with small business, and may not have the opportunity to be mentored in the workplace/ agency they are placed."

Mandy Jackson 10.11.2021 06.24PM

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1 Reply

"I agree with your comments"

Michelle Ludwig 11.11.2021 09.37AM

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Element 4: 4.1, 4.2, 4.3 and 4.4

"When reading the 4 performance criteria of this element, they appear to sit outside the generalist scope of practice and within a completely different skillset that would require business advice, insolvency and financial analysis knowledge. My immediate concern is whether this unit is considered an introductory/overview to further knowledge building within the workplace and who will be available to facilitate that? Also, what kind of risk is the sector willing to hold for mis-intepretation and action outside the scope? If we are moving into delivering a professional service free of charge that would commonly be delivered (on some initial level), by a registered/licensed practitioner (accountant, bookkeeper, business adviser, insolvency practitioner) where does the risk or liability for error sit? The importance of appropriate service and administration of these activities would require significant monitoring and regulation."

Liz McCarthy 10.11.2021 05.48PM

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Element 3.3

"Determine the tax status of the business and implications for the business. - This is element requires specialist financial advice - certified practicing accountancy or insolvency liquidators comes to mind"

Jill McKinlay 10.11.2021 12.26PM

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Primary concern

"My primary concern from a teaching perspective is that we are taking students from a basic level of understanding of personal financial management to rapidly proceeding to complex small business financial management concepts. I am concerned that this unit would be difficult for students to complete without industry experience."

Jill McKinlay 10.11.2021 12.20PM

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3 Replies

"That is an excellent point Jill"

Sarah Davidson 10.11.2021 12.25PM

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"Absolutely agree !"

Mandy Jackson 10.11.2021 06.26PM

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"I am concerned about who will be responsible for training the trainers and who will pay for this to occur if this becomes part of the Diploma "

Anna O'Loughlin 11.11.2021 03.19PM

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Element 3: 3.1, 3.2, 3.3 and 3.4

"It may just be in the wording but on first reading these descriptors: 3.1 This appears to require bookkeeping skills 3.2 This appears to require an analysis skillset 3.3 This appears to require an accounting skillset 3.4 This appears to require a viability study Is this considered basic diploma level training? If it is an introductory or overview only – how would these skills be further developed in the workplace? What staff within the current FC sector/workplace are going to be able to support, mentor and further build on these skills (without specific training – advanced diploma). It would be unsuitable to expect graduates to tend to the specific needs of SBOs without strong guidance and direction of senior clinicians. There appears to be a distinct gap in knowledge and practice here. "

Liz McCarthy 09.11.2021 08.19PM

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1 Reply

"totally agree Liz"

Bernadette Pasco 10.11.2021 07.14AM

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Element 1: 1.3

"'The scope of the role', would need to be constantly referred to, well understood, and relayed to potential clients to ensure boundaries are clearly defined. There is a risk to any FC in provision of service that is outside the scope and potential detriment to a SBO. As with our generalist work, this boundary is well known and outlined in our initial engagement with a new client into service. How easy will it be for a FC to identify when something is outside the scope? What are the secondary consults that are available to FCs (free of charge) for the matters that are beyond the scope of the role?"

Liz McCarthy 09.11.2021 07.56PM

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Element 3

"1. Work with the client to identify and retrieve financial data that is missing or incomplete. ---- Retrieve financial data means that you have a clear understanding of the client whole business, hours of work with no funding to do this 2. Access, assemble and interpret financial data about the current financial position of the small business. ---- Access means to understand all LMS that are available out there for small businesses (this is an accountant role). Assemble and interpret financial data another skill set on its own. Again, FC’s do not have the funding (time) to do this. 3. Determine the tax status of the business and implications for the business. ------ No FC’s should be giving advice on a person's tax status without years of training in this skill set. eg accountant 4. Use financial data to determine if the business is able to pay its debts and obligations.---- this is a big call for any FC.s "

Robyn d'Argent 09.11.2021 06.40PM

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2 Replies

"Agreed - this unit is very large with required knowledge evidence far exceeding the role of the financial counsellor "

Bernadette Pasco 10.11.2021 07.15AM

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"I agree with this 100%"

Sarah Davidson 10.11.2021 08.08AM

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Element 2

"1. Work with the client to identify the current small business structure. –-- There are so many different structures to a small business you are open a whole new skill set just in this one element 2. Identify legal and operational requirements of the business that impact on business's financial position. ----- FCs would need hours to just go over a client’s operational requirements and there is no funding available for general FC’s to spend this much time with a client to go over this information on top of all their financial positions. "

Robyn d'Argent 09.11.2021 06.30PM

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Element 1

"Apply financial counselling professional practice frameworks to small business owners. - We do this in all our units now Assist non-complex small businesses to manage debts and financial stress. - How and Who decides what is non -complex Use secondary consultations and referrals where matters are beyond the scope of the role. - This makes no sense at all FC’s always refer to the right person – who decides what is and what is in the scope of the role – our Code of Ethics is very clear this is not clear at all "

Robyn d'Argent 09.11.2021 06.21PM

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Assist Non-complex....

"Perhaps this unit could be replaced with a unit focused on referral pathways/ case management approach as a generalist approach to case management/ case planning. There is a real need for agencies to integrate and collaborate with secondary specialist agencies, and understand the relevance process and or referral pathway into relevant specialist services such as a specialist small business financial counsellor, mental health counsellor, specialist case worker in domestic violence, Specialist Gambling Health practitioner, AOD Practitioner etc"

Mandy Jackson 08.11.2021 07.19PM

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4.1 Provide client with information and advice regarding the financial position of the small bus

"This needs more definition of "financial position". It assumes access to accurate financial data to determine this. An example of what this means in the scope of a FC job role would be helpful. "

John Morris 06.11.2021 02.49PM

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3.4 Use financial data to determine if the business is able to pay its debts and obligations.

"I'm concerned with the expectation that a student can competently "determine" if a business is able to pay it's debts... as a result of this unit. I would think that is more the domain of an accountant or a t least a small business specialist. Could this be a referral to a specialist if the business is at risk of not being able to pay it's debts. What's the line between determining a business is not able to pay it's debts and negotiating payment arrangments with creditors?"

John Morris 06.11.2021 02.39PM

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Access, assemble and interpret financial data...

"I don't think general FC's have the skills to assemble financial data and would need a bookkeeping course to even begin. The scope of interpreting financial data needs to also be considered and guidelines provided."

John Morris 06.11.2021 02.30PM

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general comment

"really important for generalist FC to be able to identify what is now personal debt, even if the origin was business debt in company structure. Also important to refer clients for expert corporate insolvency advice if they have assets at risk, "the most expensive advice can be free""

Robyn Harris 05.11.2021 04.41PM

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3.2 access & assemble financial data

"It is not up to FC to assemble data, our role should be to look at available data and know about referral points eg Tax clinic so that financial data can be prepared. Current financial statements will be required by financiers if seeking hardship assistance for small business owner. "

Robyn Harris 05.11.2021 04.38PM

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3 Assess & Interpret financial data

"Perhaps should read "available' data. If client comes to FC with completed financial statement, FC will need to understand enough to pull out relevant information into a cash flow (short term money plan for business) 3.3 Determine tax status of business and implications for the business, also the implications for the individual. Company directors may become personally liable for ATO debt, important FC working knowledge of this"

Robyn Harris 05.11.2021 04.35PM

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3. Assess & Interpret Data

"3.1 FC need to have basic understanding of what financial records are required by ATO and then can help client identify what is missing. Obviously records must be kept for taxation and other reporting, this information underpins analysis of business viability, Small business clients who present for financial counselling assistance will have a business under financial stress. "

Robyn Harris 05.11.2021 04.32PM

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1.3 refer when beyond scope

"I think this should read beyond scope of role and expertise of FC (some FC will have more experience working in small business than others)"

Robyn Harris 05.11.2021 04.25PM

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3. Assess and interpret financial data of small business.

"Depending on the business structure there is a level of complexity and ongoing specialisation required to do this. As highlighted by the "knowledge evidence" for this unit, this is significant body of knowledge to have on top of what is already a very broad knowledge base that financial counsellors are currently required to have. "

Jillian Williams 05.11.2021 09.30AM

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1.3 - Use secondary consultations and referral where matters are beyond the scope of the role.

"Assumes access to expert small business knowledge is available within a secondary consultation setting. Greater resourcing would be required to ensure that financial counsellors across all states and communities can access regular and comprehensive pro bono advice and support."

Jillian Williams 05.11.2021 09.26AM

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1.2 Assist non-complex small businesses

"1.2 Assist non-complex small businesses to manage debts and financial stress. Why then is the content so heavy & at bachelor level or above. Without industry experience or qualifications I believe the majority will struggle to work through this content. I also believe if the knowledge is then not applied regularly it will be of no benefits to FCs. Would it not be better having a module that is generalist and easily applied in the current setting? & have the toolkit regularly updated so when required relevant information is easily accessible? Complex matters should be referred to specialists in the area or you are opening up FCs to getting in above their head and the businesses suffering due to ill advice. "

Kristy Wilson 04.11.2021 02.18PM

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2 Replies

"I agree with this comment"

Sarah Davidson 04.11.2021 02.26PM

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"I agree with this comment."

Natasha Syed Ali 11.11.2021 03.15PM

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Very specialised

"With the small business clients that I have worked with I have asked them to visit with their accountant in the first instance and then when they have the information then an analysis can be undertaken as to how it impacts them in the form of personal income. "

Domenic Vitalone 04.11.2021 12.05PM

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"PC element 1.2 should be moved to element 4 because it is about assisting non-complex small businesses so is about providing advice to clients (which would mean you would need to confirm the business structure first (element 2) and complete element 3 also before you can assist a small business. "

Rosalie Duke-Stanley 02.11.2021 07.15PM

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Performance Criteria - Element 3

"All of this is concerning as its another sill set"

Christine Raymond 21.10.2021 08.28AM

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2 Replies

"Sorry meant the skill set required is very specific"

Christine Raymond 21.10.2021 06.34PM

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"I agree with this comment"

Sarah Davidson 04.11.2021 02.26PM

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Performance Criteria - Element 2

"Concerned about the knowledge required re small business structure Legal and operational requirements"

Christine Raymond 21.10.2021 08.27AM

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1

"Concerned that we dont have the referral resources in South Australia - always being defunded"

Christine Raymond 21.10.2021 08.26AM

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Foundation skills

FOUNDATION SKILLS

Foundation skills essential to performance in this unit, but not explicit in the performance criteria are listed here, along with a brief context statement.

SKILLS

DESCRIPTION

Reading skills to:

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Writing skills to:

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Oral communication skills to:

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Numeracy skills to:

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Learning skills to:

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Problem-solving skills to:

  •  

Initiative and enterprise skills to:

  •  

Teamwork skills to:

  •  

Planning and organising skills to:

  •  

Self-management skills to:

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Technology skills to:

  •  

UNIT MAPPING INFORMATION

No equivalent unit.

LINKS

Companion Volume Implementation Guide

5 Comments

pre-requisite units

"having the other financial units in this course as pre-requisite units will not assist students to understand aspects of the australian monetary system required to understand this unit. "

Bernadette Pasco 29.10.2021 06.58AM

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2 Replies

"I agree with this comment"

Sarah Davidson 04.11.2021 02.26PM

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"I agree - given that the previous financial units apply to generalist (personal) financial counselling skills. It does not necessarily follow that a student has the capacity to understand a complex business financial statement of position, P&L; tax laws etc "

Jill McKinlay 10.11.2021 12.31PM

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foundation skills

"foundation skills for this unit would have to be at AQF level 5 and above and also have significant expertise and understanding of the Australian monetary systems; many participants in the Diploma of financial counselling are from Indigenous and multicultural backgrounds and it takes them a long time to learn concepts relating to Australian financial systems. Including this unit as part of the core of the diploma does not consider entry level students without other backgrounds, nor does it consider the nature of financial counselling which is grounded in community development and community services, not business. "

Bernadette Pasco 28.10.2021 06.42PM

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1 Reply

"I agree with this comment"

Sarah Davidson 04.11.2021 02.26PM

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Performance evidence

TITLE

Assessment Requirements for CHCFIN010 Apply basic concepts of small business to financial counselling

PERFORMANCE EVIDENCE

Evidence of the ability to complete tasks outlined in elements and performance criteria of this unit in the context of the job role, and:

  • work in collaboration with one client to:
    • identify business structure
    • use financial data to assess whether the business can pay it’s debts
    • identify the impact of the business on the personal financial position of the client
    • make an appropriate referral for further support.

6 Comments

Accuracy of the financial date - It may not be up to date

"In order to be able to assist the client reports need to be obtained from the clients records. To totally rely on the accuracy of the statements without auditing them first is very high risk. The clients I have dealt with in small business have not been able to pay their accountant and as a result are not given access to up to date information. In my previous life as an external auditor of financial statements there are many things that could be missing in accounting records that can either overstate a financial position or understate the records. To allow a financial counsellor with minimal training is opening up a can of worms."

Domenic Vitalone 11.11.2021 03.37PM

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Financial data

"Would this mean that a Financial Counsellor would need knowledge on bookkeeping and the many and various programs that small businesses use to document their financial business operations? IE MYOB Zero Quick Books "

Anna O'Loughlin 11.11.2021 03.24PM

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"I agree with Domenic - this is too high risk for a financial counsellor - All Financial Counsellor will need to return to studies and get a higher qualification to do this work - not suitable Stand alone skill set only "

Robyn d'Argent 09.11.2021 06.48PM

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Sounds like obtaining an accounting diploma, accounting degree

"It is important to understand these concepts as a financial counsellor at a basic level. To expose a financial counsellor to work with a client and to take the place of a qualified accountant is high risk. It took me three years doing a commerce degree to gain understanding in this area. "

Domenic Vitalone 04.11.2021 11.22AM

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1 Reply

"I agree with this comment"

Sarah Davidson 04.11.2021 02.27PM

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"Again concerned that this skill set is specific and although in some other states we have few if any referral pathways for a client"

Christine Raymond 21.10.2021 06.36PM

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Knowledge evidence

KNOWLEDGE EVIDENCE

Demonstrated knowledge required to complete the tasks outlined in elements and performance criteria of this unit:

  • definitions of small business:
    • ASIC exemption for financial counselling agencies for the purposes of the AFSL exemption
    • AFCA definition
    • Banking Codes of Practice Definition
    • Funding body or other requirements that go to scope or definition
    • Rural financial counselling funding agreements
    • Agency policies or State association policies
    • FCA scope of role
  • distinguish between simple and complex small business financial issues, based on business structure, type of problem, parties involved
  • agency protocols around referring and secondary consultations
  • types of small business structures:
    • sole trader
    • partnerships
    • companies
    • trusts
  • business models:
    • franchise
  • setting up a business:
    • business plans
    • ABNs
    • business names
  • determining business structures
    • accessing the ABR
  • legal frameworks applying and not applying:
    • Application of the National Credit Code
    • Ability or otherwise to access EDR schemes (AFCA, TIO, energy and water)
    • Banking Codes of Practice
    • Australian Consumer Law
  • basic operational requirements for a small business:
    • financing arrangements
    • business insurance
    • commercial and property leasing arrangements
  • types of financial data relevant to small businesses and how to access or assemble this information:
    • cash flow
    • balance sheet
    • profit and loss
  • types of main taxes paid by small business and processes for collecting and reporting tax and income:
    • GST
    • Business Activity Statements
    • PAYG and PAYG Withholding
    • Company tax
  • indicators of business ability to pay its debts and obligations
  • scope of role in relation to what the financial counsellor cannot do:
    • business plans
    • advice about managing the business
  • impacts of small business on a client’s personal finances:
    • distinguishing between business and personal debt
    • personal liability for business debt
    • legal obligations and implications
  • impact of relationship breakdown:
    • ownership of assets and debts
    • financial or economic abuse
  • advice and actions that may assist the client to improve their financial position:
    • government grants and loans
    • accessing small business advisory/mediation services
    • decreasing business expenses or selling assets
    • debt prioritisation
    • payment arrangements with creditors, ATO
    • IDR and EDR (where available)
    • accessing business insurance
    • challenging unfair contracts
    • legal action through courts and tribunals
  • insolvency:
    • difference between bankruptcy and insolvency
    • referral options to paid services for insolvency advice
  • closing a business:
    • business name cancellation
    • finalising ATO obligations and all employee entitlements
    • terminating any licences, leases or contracts on foot
    • advising customers, contractors
    • referral options for advice regarding companies
  • processes for making referrals to external services:
    • identifying when client need is in scope, or beyond scope of own job role
  • external resources and services that can assist small businesses including:
    • government grants and loans
    • small business advisory and assistance services
  • small business mediation/dispute resolution services.

16 Comments

"KNOWLEDGE EVIDENCE - This means we need to teach all of this in the course - this would take about 2 years to teach all this information and even then not too sure you could get insurance to give this advice as a Financial Counsellor Not suitable for FC's "

Robyn d'Argent 09.11.2021 07.00PM

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types of financial data relevant to small businesses and how to access or assemble

"As notes in element 3, assembling data such as profit & loss and balance sheet is highly skilled activity and unrealistic to teach in one unit. In terms of assisting in negotiating with creditors a cash flow tool is important."

John Morris 06.11.2021 03.01PM

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1 Reply

"Yes, I agree. From a teaching perspective, the level of knowledge and learning required here is unrealistic for the type of delivery and volume of learning in a single unit of competency."

Natasha Syed Ali 11.11.2021 03.18PM

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Severe knowledge gap

"Tend to agree with all of the comments below. The information is nice to know but to apply it for clients. It is like reading about being a pilot, It does not mean that you can fly the plane."

Domenic Vitalone 04.11.2021 11.26AM

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Business Structures

"Although trusts are used, the trustee of the trust is the more important consideration. Good for students to be aware that trusts exist, but don't seem to have much bearing on where responsibility for debts lie. Too much about trusts will be confusing."

Robyn Harris 29.10.2021 03.03PM

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1 Reply

"agreed - knowing about the trust is important - and should be part of any normal financial counsellor's assessment of the client's financial position. knowing how this trust money impacts negotiations is important, but too much information about trusts is confusing and not relevant"

Bernadette Pasco 01.11.2021 09.23AM

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advice or action that may assist client to improve their financial position

"in addition to selling assets (although this may only be a short term cash flow boost and not assist the overall position) and decreasing expenses: increasing revenue and using benchmarking may be useful. Also debt restructuring is useful to be aware of, as another option for business owners"

Robyn Harris 29.10.2021 03.00PM

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1 Reply

"it's more about how the trust impacts the financial position of the client- is there money coming in/ likely to come in or is the client deriving income or likely to derive income that will impact the way debts are negotiated and the way creditors could see the client's financial position- this is the only concern of the financial counsellor. "

Bernadette Pasco 01.11.2021 09.26AM

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Knowledge evidence

"a large amount of the knowledge evidence includes potential to put the client into a worse financial situation due to lack of knowledge of the financial counsellor. This content should relate to the BUS training package or be packaged into a skillset at advanced level with associated professional recognition of expertise. adding this unit places consumers at risk "

Bernadette Pasco 28.10.2021 06.39PM

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1 Reply

"I agree with this comment"

Sarah Davidson 04.11.2021 02.27PM

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Knowledge evidence

"I have serious concernt about the following being core learning in the Diploma of financial counselling in terms of small business: setting up a business: business plans ABNs business names determining business structures accessing the ABR legal frameworks applying and not applying: Application of the National Credit Code Ability or otherwise to access EDR schemes (AFCA, TIO, energy and water) Banking Codes of Practice basic operational requirements for a small business: financing arrangements business insurance commercial and property leasing arrangements types of financial data relevant to small businesses [lots of the information above can also increase financial liability and open financial counsellors up to being sued for financial loss] and how to access or assemble this information: cash flow balance sheet profit and loss types of main taxes paid by small business and processes for collecting and reporting tax and income: GST Business Activity Statements PAYG and PAYG Withholding Company tax indicators of business ability to pay its debts and obligations impacts of small business on a client’s personal finances: legal obligations and implications impact of relationship breakdown: ownership of assets and debts financial or economic abuse advice and actions that may assist the client to improve their financial position: government grants and loans accessing small business advisory/mediation services decreasing business expenses or selling assets debt prioritisation payment arrangements with creditors, ATO IDR and EDR (where available) accessing business insurance challenging unfair contracts legal action through courts and tribunals insolvency: referral options to paid services for insolvency advice closing a business: business name cancellation finalising ATO obligations and all employee entitlements terminating any licences, leases or contracts on foot advising customers, contractors referral options for advice regarding companies processes for making referrals to external services: identifying when client need is in scope, or beyond scope of own job role external resources and services that can assist small businesses including: government grants and loans small business advisory and assistance services small business mediation/dispute resolution services."

Bernadette Pasco 28.10.2021 06.36PM

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1 Reply

"I agree with this comment"

Sarah Davidson 04.11.2021 02.27PM

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Knowledge evidence

"this knowledge evidence will be extremely difficult to police in terms of both delivery and assessment. there are insufficient people to deliver this content who are financial counsellors and have this expertise. the risks to clients are enormous. "

Bernadette Pasco 28.10.2021 06.22PM

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1 Reply

"I agree with this comment"

Sarah Davidson 04.11.2021 02.27PM

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Knowledge evidence

"I have previously worked for a bank and one of my roles was to assist small business and that is all I did for 4 years. Some of the suggestion ie franchises is a mine field"

Christine Raymond 21.10.2021 06.37PM

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1 Reply

"I agree with this comment"

Sarah Davidson 04.11.2021 02.27PM

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Assessment conditions

ASSESSMENT CONDITIONS

Skills must be demonstrated in the workplace or with simulations and scenarios developed by Financial Counselling Australia capturing the full range of contexts and situations.

 

Assessment must ensure access to:

  • suitable facilities, equipment and resources, including:
    • client information
    • organisational policies, procedures and resources
  • modelling of industry operating conditions, including:
    • scenarios that involve complex interactions with other people
    • scenarios that involve problem-solving.

 

Assessors must satisfy the Standards for Registered Training Organisations’ requirements for assessors.

LINKS

Companion Volume Implementation Guide

6 Comments

Students on placement

"Who will ensure that students are able to get the practical experience while on placement and ensure that they have the knowledge and understanding of what it means to provide information and support to someone who has a small business. "

Anna O'Loughlin 11.11.2021 03.03PM

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assessment conditions not possible to replicate in real terms

"there are very few agencies that deliver small business financial counselling services. Those that do are working to develop their own knowledge. This could not be assessed in any real way, aside from potentially STEPS agency setting up a small business unit specifically to test knowledge and its application. e.g. this could not be included in the 220 hours of learning in the workplace because there are no workplaces that would provide this expertise. This is a national qualification and many jurisdictions are not at all able to deal with learning in the workplace with the current Diploma - this would mean that a graduate would work with students after ONLY having simulated experience. This does not produce quality graduates. "

Bernadette Pasco 28.10.2021 06.26PM

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4 Replies

"I agree with this comment"

Sarah Davidson 04.11.2021 02.27PM

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"I also agree with Bernadette comments "

Robyn d'Argent 09.11.2021 07.02PM

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"I also agree, demonstrating skills in the workplace or with simulations and scenarios developed by Financial Counselling Australia will be challenging as there are limited people who will be equipped/qualified and experienced to mentor this process."

Michelle Ludwig 10.11.2021 12.52PM

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"I agree with the above comments. The current financial counselling sector is not equipped with supervisory and mentoring staff who are qualified to support the delivery of small business financial counselling services"

Jill McKinlay 10.11.2021 12.56PM

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