RG97 Fees and Costs Disclosure: Clear, Consistent, Defensible
Understanding RG 97
ASIC Regulatory Guide 97 (RG 97) sets the standards for how fees and costs must be calculated and disclosed for superannuation products and managed investment schemes. It aims to ensure consumers can compare products like for like, with transparent totals and consistent treatment of indirect costs, performance fees and transaction costs across disclosure documents and ongoing communications.
Why RG 97 Matters
Poor fee disclosure drives complaints, remediation and enforcement. Clear, consistent RG 97 compliance builds trust, reduces dispute risk and supports product governance (DDO) by aligning what’s promised with what’s actually charged. It also strengthens board oversight via reliable MI and supports distributors with accurate, up-to-date data for advice and marketing.
Key implications for firms include:
Like-for-like comparability across PDSs, TMDs and ongoing communications.
Consistent calculation methodologies for indirect costs, performance fees and transaction costs.
Alignment across channels (PDS, website, calculators, fact sheets, adviser materials).
Timely updates and controls when fees change, benchmarks move or market conditions shift.
Key Challenges Facing Firms
Interpreting and operationalising calculation rules across complex product structures.
Gathering data from external managers and platforms with sufficient granularity and audit trail.
Ensuring one source of truth for digital content, PDS updates and distributor feeds.
Avoiding inadvertent inconsistencies between marketing, advice tools and mandated disclosure.
Sustaining quality assurance and sign-offs during frequent pricing or product changes.
How OCG Can Help
Oceanic Consulting Group (OCG) embeds RG 97 compliance that is practical, repeatable and audit-ready.
Our services include:
Fees & costs operating model: roles, RACI, calculation playbooks and approval gates.
Data & methodology uplift: sourcing, manager due diligence, calculation templates and evidence packs.
Disclosure alignment: PDS, website, TMDs and adviser materials drawn from a governed single source.
QA & assurance: sampling, change controls, MI/dashboards and periodic independent reviews.
Remediation support: identify inconsistencies, quantify customer impact and execute corrections swiftly.
FAQs
What products are in scope?
Superannuation products and managed investment schemes, including platform menus and multi-manager structures where indirect costs must be captured.
How do we handle performance fees and transaction costs?
Apply defined methodologies consistently, retain calculation evidence and ensure totals reconcile across all disclosures and tools.
How does RG 97 link to DDO?
Accurate fee data underpins TMDs, distribution conditions and ongoing monitoring; inconsistencies can trigger complaints and potential stop-order risk.
Strengthen Your RG 97 Framework
Work with OCG’s Product Governance & Disclosure Specialists
Make fees and costs disclosure clear, consistent and defensible. Contact OCG to implement calculation playbooks, data governance and assurance that align PDS, digital content and distributor materials.
