Client Compensation and Unit Pricing Error Policy Template (ASIC | AFSL)

This policy sets out how a fund operator identifies, contains, investigates, rectifies and compensates for unit pricing and valuation errors. It is drafted for Australian responsible entities, trustees, fund managers, life companies and superannuation trustees that calculate or oversee unit prices, and is designed principally for a managed investment scheme operator. It covers unit allocation, valuation and unit price errors only — fee, disclosure, advice and misconduct matters are routed to your complaints, breach and remediation frameworks.

Use this policy if you:

• operate or oversee a managed investment scheme, trust, investment option or unitised pool
• calculate, review or publish unit prices, or supervise a provider that does
• need a documented, repeatable method for rectifying unit pricing and valuation errors
• must evidence to ASIC how each compensation decision was calculated and approved
• outsource unit pricing or fund administration and retain supervisory responsibility

It is suited to:

• Australian responsible entities and trustees
• fund managers, life companies and superannuation trustees
• pricing, operations, product and finance teams accountable for unit price accuracy
• compliance and legal teams managing the breach, IDR and remediation interfaces
• APRA-regulated entities, provided the policy is separately tailored to their prudential obligations

What this policy covers:

• a five-stage detect, contain, triage, escalate and plan workflow with an owner at each stage
• root-cause analysis and affected-population rules covering current, exited, transferred, deceased and uncontactable holders
• calculation methodology for unit and price reconstruction, investment performance, time value, fees, tax and consequential loss
• materiality thresholds, including the 0.30% RG 94 reference point, treated as guidance rather than a safe harbour
• payment methods for current holders, tracing obligations for exited holders and recovery from advantaged holders
• complaints and RG 271 assessment, reportable situations under sections 912D to 912DAA of the Corporations Act 2001 (Cth), and privacy, APRA and AFCA notifications
• outsourced provider oversight, notification testing, assurance rights and cost recovery
• seven schedules: configuration and fund inventory, error notification form, compensation assessment and approval, error and compensation register, communication plan checklist, closure and lessons-learned checklist, and regulatory reference guide

You receive an editable Word document with every purchaser input highlighted, including [Company Name], [insert name], [insert approving body] and [insert outsourced provider], so roles, thresholds, retention periods and fund details can be configured before approval. It carries a regulatory currency note current at 8 August 2026 and a reference guide to the Corporations Act, the ASIC Act, RG 94, RG 132, RG 78, RG 271 and RG 256. Obtain legal review before adoption — the policy is a starting point and does not account for your constitution, licence conditions, products, tax position or outsourcing model.