AI for Financial Planners Australia: Advice Records and Client Notes

An Australian planner can use AI to turn meeting recordings into file notes and to draft advice-record wording, if clients are told and consent where needed, personal information is minimised, the tool's data location is verified, and the adviser reviews and signs every output. Privacy and ASIC duties stay with the adviser and licensee, whichever tool wrote the first draft.

Buying a note-taker is the easy part. What protects the practice is the sequence around it: consent before recording, a tool whose data location you can name, a draft the adviser corrects line by line, and a record you would be comfortable showing a licensee review or a complaint handler. ASIC's guidance expects advice records to be kept for at least seven years, so the AI-assisted record has to stand up for that long.

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What the regulators have said that bears on this work

Two sources are worth reading before you buy anything. The Office of the Australian Information Commissioner (OAIC) has published guidance on privacy and the use of commercially available AI products. Its main points, in summary: privacy obligations apply to personal information put into an AI system and to AI output that contains personal information; entering information may be a use or a disclosure under APP 6; organisations should minimise what they enter and ask whether AI is necessary; privacy policies and collection notices should describe AI use; consent for sensitive information must be informed, current and specific and cannot be implied just because someone was notified; and, as best practice, personal information, particularly sensitive information, should not be entered into publicly available generative AI tools. The guidance also covers accuracy: AI can produce wrong output, organisations need reasonable steps to ensure accuracy, and human oversight is expected.

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ASIC's report REP 798, released on 29 October 2024, analysed 624 AI use cases at 23 AFS and credit licensees in banking, credit, insurance and financial advice, as they stood in December 2023. Its central concern is a governance gap: some licensees were adopting AI faster than they were updating their risk and governance arrangements. Two of its findings speak directly to a small practice. Only 10 of the 23 licensees had policies that referenced disclosing AI use to affected consumers, and many relied heavily on third parties for their AI models without appropriate governance arrangements for the associated risks. The report's foreword also stresses that current licensee obligations, consumer protection laws and director duties are technology neutral.

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For a planner, the useful reading is the question the report implies: if a supervisor asked how you control AI use, what would you show? A short written policy, a register of tools naming the vendor behind each one, a line in your client notices about AI use, a record of checks and evidence of adviser review is a reasonable answer. Take your licensee's guidance on how the report applies to you.

Nothing here is legal advice. Your licensee's compliance team defines what an acceptable advice record looks like. The workflow below fits inside whatever standard they set.

Step 1: consent, notice and the privacy paperwork

Start with paper, not software.

Update the privacy policy and collection notice

The OAIC says privacy policies and collection notices should describe AI use. Add a plain paragraph: you use an AI note-taking tool in client meetings; it records and transcribes with the client's agreement; the tool is provided by a named company; data is stored in a stated location; and the notes are reviewed by your adviser. Name where clients can ask questions or withdraw agreement.

Ask for agreement at the start of each meeting

A line in the meeting invitation helps, but saying it aloud and recording that you did is better: "I use a note-taking tool that records this meeting and creates a transcript. It is stored as described in our privacy policy and I review the notes. Are you comfortable with that?" Record the answer in the file note. If a client declines, take notes by hand without argument.

Sensitive information needs particular care

Planner meetings often cover health, family breakdown, disability and income. Where a tool generates or infers sensitive information, the OAIC says consent is usually required. Ask your compliance team for a rule such as "no summarising of health details by the tool; the adviser records those by hand" if that suits your risk appetite.

Step 2: choose a tool, and verify where its data lives

List what you need: records the meeting or accepts an upload; produces a transcript; lets you correct and delete; stores data where you can name; and exports to your client file system. Then compare the options in three groups.

• General note-takers. Otter Pro is $8.33 per user per month billed annually ($16.99 monthly); Fireflies Pro is $10 a seat annual ($18 monthly); Fathom Team is $15 a seat annual with a two-user minimum. These are USD list prices checked in November 2026 (Fathom Team is $19 on monthly billing, and Otter was showing a temporary discount on Pro), so read each vendor's page before you decide.
• Adviser-specific note-takers. Several products are built for advice firms and file notes in an adviser's format. Compare them in the tutorial on AI note-takers for advisers, and ask each vendor the data-location questions below.
• Features inside systems you already use. Meeting software and practice management tools may include summaries. Check whether they sit under the same data terms as the rest of the product.

The vendor questions to ask, and to keep in writing: Is business content used to train models? Where is data stored and processed, and is any of it outside Australia? Who at the vendor can access recordings? How long do recordings and transcripts stay, and can you delete them? Which sub-processors does the vendor use? Does the product keep an audit trail of edits? The OAIC points out that for cloud-hosted AI, organisations should consider where servers are located and whether personal information could be disclosed overseas, so the answer to the second question determines what you must tell clients. If a vendor cannot answer, choose another. Safety questions in general are covered in are AI note-takers safe for client calls.

Step 3: from transcript to file note

The file note is the contemporaneous record of what happened. Keep its purpose in mind: it should let someone who was not there understand what was discussed, what was advised and what the client decided.

From the transcript below, write a file note with these headings:
Date, attendees, meeting type
Client circumstances (changes since the last meeting)
Goals and objectives discussed
Risk tolerance and capacity (use the client's own words where given)
Information provided by the client (list documents mentioned)
Advice or options discussed (what the adviser said, not what you think)
Client decisions and instructions
Actions with owner and due date
Items unclear or needing confirmation
Rules: use only the transcript. Mark any number you are unsure about as
[CHECK]. Do not add advice that was not given. Do not infer feelings.
Do not summarise health information; write [HEALTH TOPIC: adviser to record].

Illustrative output extract: "Client circumstances: partner retired on 30 June; household income now about $6,400 a month before tax [CHECK: transcript says 'six thousand four hundred or thereabouts']. Goals: client wants to reduce the home loan before retiring in three years. Advice or options discussed: adviser outlined making extra repayments, using the offset account, and the effect on contributions; no product recommendation made. Client decision: wants a written comparison before choosing. Actions: adviser to prepare comparison by 14 March. [HEALTH TOPIC: adviser to record]." Notice how the [CHECK] and health placeholders make the draft safe to review: they show the adviser exactly where to look.

Verification steps for every note

1. Read the note within one working day while the meeting is fresh.
2. Check each [CHECK] item against the recording.
3. Spot-check the advice section against the recording: did the adviser actually say that?
4. Add what the tool cannot know: documents the client brought, body language you want to record, the health points.
5. Finalise, initial and date the note in your client system.

The routine of draft, check and sign-off is set out in more detail in can AI write file notes from adviser meetings.

Step 4: advice-record drafts from the file note

ASIC's Regulatory Guide 175 (issued 21 November 2024) sets out when a statement of advice is not needed for further advice: the client has previously been given a statement of advice setting out their relevant circumstances, those circumstances are not significantly different now, and the basis on which the further advice is given is not significantly different either. In that case you keep a record of the advice instead, for seven years after the day the further advice is provided. The guide notes that the record may be kept in any form and that the client may ask for a copy while it must be kept. Whether a given meeting meets those conditions is a judgement for the adviser and the licensee, never for the tool. What AI can do is prepare the repeatable parts for your template.

Give it facts, not discretion

As with any letter, the tool must not make the recommendation. Hand it the adviser's decision and the supporting facts, labelled, and ask it to fill your template headings only. A pack looks like this (illustrative):

TEMPLATE HEADINGS: Client circumstances | Advice given | Reasons | Risks and
  disadvantages | Fees and costs | Client instructions | Next steps
CIRCUMSTANCES: couple, both 61, home loan 182,000 at 6.1%, super balances
  348,000 and 290,000, planning to retire in three years.
ADVICE GIVEN (adviser's words): direct 800 a month to the offset account instead
  of additional super contributions until the loan is cleared.
REASONS: guaranteed saving at the loan rate; flexibility; liquidity.
DISADVANTAGES: forgoes concessional contributions and the tax treatment
  that goes with them; money in the offset account is accessible and may be spent.
FEES: advice fee 3,300 as agreed on [date].
CLIENT INSTRUCTIONS: proceed; adviser to arrange the bank transfer set-up.

Then the instruction: "Draft each heading in plain English using only this pack. Quote numbers exactly. If something needed for a heading is missing, write [MISSING]. State disadvantages as clearly as reasons. No guarantees." Check the result as you would a letter. A realistic fault is the tool merging "forgoes contributions" into a vague "less super", losing the specific trade-off. Put the adviser's words back. The related question of whether AI can draft a full statement is covered in AI for Australian financial planners: can it draft a statement of advice.

A worked example: one meeting, start to finish

Illustration. A two-adviser practice meets a client for a 60-minute review. The adviser opens by explaining the note-taker, records the client's agreement and starts the transcript. Afterwards the tool produces a draft file note in four minutes. The adviser reads it and makes five changes: confirms two figures marked [CHECK], rewrites the sentence on the client's concern about market falls using her own words, adds a health topic the transcript omitted by design, corrects a date the tool misheard, and adds the documents received. The review takes eighteen minutes, compared with about forty when the adviser typed notes from memory and a scribbled page. The adviser then builds a pack for the record-of-advice template, generates a draft in minutes and spends twenty-five minutes checking it. Retention follows the practice's policy: the file note and record of advice are kept for at least the seven years ASIC's guidance sets for advice records, the transcript and recording are kept for the period the licensee requires, and both are deleted from the vendor's system once exported. Treat the minutes as an illustration and time your own cases across ten meetings before you plan on them.

Four slips that undo an AI file note

Mixing clients in one conversation

Pasting two clients' notes into one chat risks bleed-through. Use a fresh conversation per client, and turn off any memory feature unless your licensee has approved it.

Accepting the tool's tone as the adviser's

A tool tends to write that a client "was pleased" or "understood" something. Neither is in the transcript unless the client said so. Remove inferred states. If understanding matters, ask a check question in the meeting and record the answer.

Forgetting the cross-border question

A note-taker that processes in another country is not forbidden, but the OAIC's guidance on overseas disclosure means you must understand and tell clients. Keep the vendor's written answer on file with the date.

Letting the transcript replace the note

A raw transcript is long and may include chatter, which becomes personal information you must manage. Decide whether to keep audio, and if you do not, record that the decision was deliberate.

Wording you can adapt for clients

Clients accept AI notes more readily when the explanation is short and honest. Here is an illustrative paragraph for the privacy policy and a shorter spoken version. Have your licensee approve the final wording.

Policy paragraph: "We use an AI-assisted note-taking service in some client meetings. With your agreement, it records the meeting and produces a transcript and draft notes. Your adviser reviews and corrects the notes before they are filed. The service is provided by [vendor], which stores the data in [location] and does not use our client data to train its models. Recordings are kept for [period] and then deleted. You can decline recording at any time, and we will take notes by hand."

Spoken version: "I use a note-taking tool that records and writes up this meeting. I check the notes afterwards and the recording is deleted after [period]. Are you comfortable with that, or would you prefer I take notes by hand?"

The vendor name, location and retention period must be filled from the answers you collected in Step 2; never fill them from guesses, because a wrong statement in a policy is worse than none.

Before and after: tightening one advice section

This is an illustrative contrast from a draft record. The first version came from the tool when the pack was thin.

Draft: "You will be better off by moving your savings to the offset account, which is a safe and tax-effective option for you."

Problems: "better off" is a prediction; "safe" is a claim that the client's situation does not support; "tax-effective" was never discussed; and the trade-off with super contributions is absent.

Adviser version: "We recommended directing 800 a month to the offset account rather than making extra super contributions. This reduces the interest you pay on the loan at the loan rate. In return, you forgo the tax treatment of concessional contributions, and money in the offset account remains accessible, so it could be spent."

The adviser version names the trade-off and avoids claims about the future. Keep such pairs in a shared document; they are the quickest way to teach a new team member what a good record looks like, and the best test set when you trial a different tool.

A second scenario: a couple who disagree

Illustration. In a joint meeting, the partners disagree about risk. One wants growth, the other wants security. Transcripts often attribute statements to the wrong speaker when voices overlap. For this reason, ask the tool to quote each partner's stated position separately and mark any attribution it is unsure of as [SPEAKER?]. The adviser listens to those passages in the recording and corrects them. The file note should record both views, what the adviser explained, and what the couple agreed. Smoothing the disagreement into "the clients agreed on a balanced approach" would erase the evidence of how the decision was reached, and that is exactly what a later complaint turns on.

Annual reviews and other follow-on uses

Once file notes are consistent, they become useful beyond the day. Before an annual review, paste the last year's coded file notes (with identifiers removed, or into an approved business tool) and ask for a list of open actions, stated goals and changes in circumstances. The result is an agenda draft, not a summary of the client's life; check each line against the file. The tutorial on preparing annual client reviews with AI carries that idea further. Another use is a short email after each meeting: "Draft a plain-English summary of the actions agreed, with dates, no advice." The adviser reads and sends it. A recap with dates gives the client something to act on and gives you a record that the actions were communicated.

Client requests for their records

Clients can ask what personal information you hold. AI-generated notes, transcripts and recordings are all records about them, so your systems must be able to find them. Keep a simple index: client, meeting date, files held (recording, transcript, draft, final note) and where each is stored. When a client asks, you can respond completely, and when a retention period expires you can delete everything in one pass. If your tool keeps a separate copy in its own cloud, include that in the index and in your deletion routine; deleting the file from your system alone does not delete the vendor's copy.

Staff habits that make or break the policy

• One short briefing for every adviser and paraplanner: what the tool is for, what it must never be asked to do, and where the register lives.
• A banned list in plain words: no personal information in public chat tools, no health details in prompts, no auto-join of meetings, no pasting of one client's material into another's conversation.
• A named person who can answer "can I use AI for this?" within a day, so staff do not guess.
• A review every quarter: new features, changed vendor terms, faults found in the sample audit, and updates to your prompts.

The test of a policy is whether the newest member of staff follows it on a busy Friday. Keep it short enough that they can.

A checklist for the licensee's compliance lead

The wider governance items for an advice firm are in the AI governance checklist for small advice firms. If you would like help setting up the templates and review routine with your team, that is the work of my AI implementation consultation.

Planner questions on AI notes, consent and privacy

Can I paste client details into ChatGPT?

The privacy regulator's guidance recommends, as best practice, not entering personal information, particularly sensitive information, into publicly available generative AI tools. Use a business-grade tool with stated data terms, minimise what you enter and tell clients how you use it.

Do I need client consent to use an AI note-taker?

Tell clients clearly, update your privacy policy and collection notices, and get consent where sensitive information such as health details is involved. The regulator says consent must be informed and specific, and cannot be implied just because someone was notified.

Where does my note-taker store data?

Ask the vendor in writing, and keep the answer. The regulator tells organisations to consider server locations and whether personal information could be disclosed overseas. If storage or processing is offshore, your privacy duties on overseas disclosure apply and clients should be told.

Who is responsible for an AI-drafted advice record?

The adviser who gives the advice and the licensee. A tool does not share the duty. Every figure and statement is checked against the meeting and the file before the record is finalised, and the review is evidenced.

Further reads

• AI Agents for Financial Advisers: What They Can Do Without Advising — What agents may do in admin without giving advice.
• How to Redact Personal Data From Documents With AI Before Sharing — Strip personal data from text before it reaches a tool.
• AI CRM for Financial Advisers: What Is Built In and What Is Bolted On — Which CRM features are native and which are bolted on.
• How Much Does an AI Note-Taker Cost per Seat? — What a note-taker really costs per seat.
• Can Financial Advisers Use ChatGPT? What Compliance Allows — What compliance allows when advisers use ChatGPT.
• AI Receptionist for Financial Advisers: Cost, Scripts and Limits — Cost, scripts and limits for an AI receptionist.
• AI Tools and AI Development: The Complete 2026 Guide — the AI hub, including every tutorial in the AI-for-business series.

Sources: OAIC guidance on privacy and the use of commercially available AI products (updated 17 January 2025); ASIC REP 798 report page and full report PDF; ASIC Regulatory Guide 175 (21 November 2024) on further advice and record keeping; Otter, Fireflies and Fathom pricing pages, checked November 2026.