ASIC Warns 7,639 Super Switch Clients Moved $678 Million Through Lead Generators

The Australian Securities and Investments Commission has put financial advice licensees on notice that using lead generators may put their licences at risk, after a review found unlicensed or unqualified salespeople involved in the advice process and more than $678 million switched or invested through the arrangements.

According to ASIC, lead generators referred 7,639 new clients to financial advisers across the 15 licensees reviewed between January 2025 and June 2026, equal to 35 per cent of all new clients at those firms. About 90 per cent of the money moved, roughly $610 million, came from superannuation savings.

Contents

01

How the sales model works

02

Fees, failures and the human cost

03

Enforcement and reform in the pipeline

04

What consumers can check

How the sales model works

Lead generation refers to marketing activity designed to create consumer interest in a product or service and connect people with financial services businesses. In superannuation switching models, it often begins with a social media advertisement that prompts people to question how their fund is performing, followed by a form and then phone calls promising more investment options and better returns.

ASIC's review, published as Report 845 Lead generation advice models: Putting consumers and licensees at risk, found some licensees allowed lead generators to carry out specialist tasks such as fact-finding, assessing a client's risk profile and discussing advice recommendations. Yahoo Finance reports that some were also permitted to conduct product research and provide Statements of Advice, the formal documents setting out personal advice.

The regulator also identified potentially misleading statements, fear-based claims and non-like-for-like performance comparisons used to encourage consumers to review or switch their superannuation. In one example shared by ASIC, a person was told that people typically received as low as 3 or 4 per cent a year on their money while others received as high as 10 or 11 per cent. In another, a person was told their fund offered only about 10 to 15 investment options, compared with 600 to 1,000 at a more professional fund.

The oversight gaps were practical as well as cultural. ASIC found limited access to lead generator call recordings, heavy reliance on manual supervision, insufficient monitoring of product recommendation patterns and inadequate limits on how many clients individual advisers could take on.

Fees, failures and the human cost

Advice businesses in the sample received $9.8 million in initial fees, with commitments to a further $4.5 million in ongoing fees. Yahoo Finance reports that five licensees lacked controls to prohibit or identify high-risk superannuation switching by their representatives, while a further four operated businesses with some features of high-risk switching models.

The review follows the collapses of the First Guardian and Shield investment funds, which Yahoo Finance reports cost more than 11,000 Australians around $1 billion from their superannuation accounts. One Queensland woman told the publication she was repeatedly called after clicking a Facebook advertisement and later lost $165,000 in the Shield Master Fund collapse. A Perth father, Richard Orr, said he moved his money from industry fund CBUS after being contacted by lead generators despite wanting something safe, paying a one-off $3,300 upfront fee, and later saw more than $200,000 disappear in the First Guardian collapse.

ASIC Commissioner Alan Kirkland said the findings send a clear warning to advice licensees. "Consumers should not feel pressured or be misled when making important financial decisions," he said. "Far too often, we have seen how harmful lead generation practices can steer people towards investment choices that leave them worse off." He added that commercial incentives must not come at the expense of consumers, and that only authorised advisers should provide personal advice.

Enforcement and reform in the pipeline

The regulator has been building its enforcement record in this area. It has brought Federal Court proceedings against Imperial Capital Group Australia over alleged misleading representations and its involvement in MWL Financial Services' alleged advice failings concerning the Shield Master Fund, and against Clark Family over allegations it misled consumers by promoting financial product comparisons while selling their enquiries to the highest-bidding broker. ASIC also banned advisers Andrew Hanley and Shane Monte Silva from providing financial services for five years over flawed superannuation advice models involving third-party marketers.

The review builds on ASIC's broader transparency work on high-risk superannuation switching, including an initial list of 44 entities published in February 2026 and 19 more added in June 2026. On 19 August 2026 the federal government announced proposed reforms to strengthen consumer protections in superannuation and financial advice, including measures to curb harmful lead generation. Assistant Treasurer Daniel Mulino has outlined plans for a ban on unlicensed communication about superannuation, with licensees required to take reasonable steps to ensure lead generation complies with the law, measures first floated in a consultation paper in April.

Kirkland said ASIC welcomes the proposed reforms but will keep taking enforcement action under current laws where it finds evidence of serious consumer harm.

What consumers can check

ASIC advises consumers to be alert to unexpected calls after clicking social media advertisements or completing online forms. People can check Moneysmart's Financial Advisers Register to confirm an adviser is authorised and to review their qualifications and employment history, and can compare MySuper product performance or find lost superannuation accounts through the Australian Taxation Office.

The lead generation findings sit alongside separate concerns about how funds handle member complaints. In Report 844, ASIC said close to one quarter of trustees were not regularly analysing complaints data to identify systemic issues, and 14 of the 45 trustees it regulates failed to identify a single systemic issue over a two-year period. Commissioner Simone Constant described complaints as "the canary in the coalmine" for problems including fraud and misconduct, and noted trustees manage $3.4 trillion in Australians' retirement savings.

For retail investors, the practical message is that a superannuation switch is a financial advice decision, not a marketing transaction. ASIC's position is that lead generation in financial advice is likely to be inconsistent with the obligations on advisers and licensees to act in clients' best interests and to give personal advice only when appropriately authorised.

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