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Property investment licensing, a guide by Dotto

Guide 4 · Calls after a click

Calls after a click: lead generation and the licence

How a click on an advertisement turns into a phone call about your money, what ASIC’s 2026 review is looking at, and the features it says to be wary of.

The bands of the core this guide reads
  1. The property
  2. The loan
  3. The landlord’s insurance
  4. Superread here
  5. Schemes and funds

Lead generation is the work of finding people who might buy something and passing them to a business that sells it, and Moneysmart says that clicking an advertisement, filling in a comparison form or doing an online quiz can put you on such a list without your knowing. In 2026 ASIC began reviewing advice licensees that use lead generation, and warned that lead generators who mislead people, use high-pressure tactics or provide financial services without a licence risk breaking the law, a risk shared by the licensees who use them.

General informationThis page summarises ASIC’s media release and Moneysmart’s guidance on lead generation, not advice about any call, offer or super fund. Moneysmart’s lead generation page is the place to check; ASIC and Moneysmart keep the list of businesses on their own pages.

From a click to a call

ASIC describes lead generation as marketing meant to build interest in a product or service so that people will buy it, using a range of techniques to introduce people to financial services businesses, some of which encourage people to switch their super. The path Moneysmart and ASIC describe runs in four steps.

  1. A click, a form or a quiz

    Moneysmart’s example is an advertisement offering to compare your current investments for free. Clicking it may mark you as a sales target for financial advice or super.

  2. You become a lead

    Moneysmart’s definition is plain: a lead is someone identified as a potential sales target, and the aim is to connect that person with a business selling something they might want. The same method sells anything from shoes to solar panels, Moneysmart notes, and financial products are among them.

  3. The call

    ASIC says a call can follow a click on a social media advertisement or a form on a super comparison website, or come with no invitation at all. Offers of a free “super health check”, or to find lost super, can be sales tactics designed to push people into switching, even when their fund is performing well.

  4. The decision

    ASIC’s message to consumers on this point is short: “If you are feeling pressured or unsure, you should just hang up.”

What ASIC’s review is doing

ASIC’s media release 26-029MR says the review aims to identify financial advice businesses that use lead generation, to understand how those arrangements work, and, where appropriate, to take disruptive or enforcement action. ASIC places it within its continuing work on practices that push people to switch super inappropriately or without need.

As part of the review, ASIC publishes a list naming known lead generators, the businesses that pass people on to them, and the advice licensees or their corporate authorised representatives who have bought leads since 1 July 2024, and it says it will keep the list updated as the review goes on. ASIC is careful about what the list means: being named on it is not, in ASIC’s words, an indication “that a contravention of the law has occurred”. This guide names none of them.

The release speaks to the industry as well. ASIC asks advisers and licensees to think carefully about whether they can meet their legal obligations if they deal with lead generators that show the features below, and asks super trustees to compare those features against their own data for signs of high-risk switching.

The eight features ASIC names

ASIC’s release lists the features in these words:

“Consumers should be wary of the following features:

  • Being pressured to act immediately
  • Claims that your existing fund is underperforming
  • The touting of free superannuation ‘health checks’ and prizes (often via social media advertisements or websites)
  • Offers to find and consolidate ‘lost super’ for free
  • The involvement of unlicensed people in the advice process
  • Predominant engagement over the phone with limited client contact with a financial adviser
  • Poor or no product disclosure
  • Promises of high or unrealistic returns”
ASIC, media release 26-029MR

Moneysmart repeats the same list on its own page. ASIC adds that people should take extra care with any business that uses lead generation and shows these features, including by hanging up on unsolicited calls when they feel pressured to decide.

Where the licence comes in

Two of the eight features are about the licence itself: unlicensed people taking part in the advice, and advice delivered mostly over the phone with little contact with a financial adviser. They point back to the rule underneath the whole core. Moneysmart says personal advice, and most general advice, can come only from someone who holds an AFS licence or is authorised by a licence holder.

ASIC’s warning covers both ends of the chain. In its release it says:

“ASIC warns that lead generators that mislead consumers, utilise high pressure tactics or provide financial services without a licence will risk contravening the law. Licensed persons or entities that engage the services of lead generators acting in this way, share this risk.”

ASIC, media release 26-029MR

ASIC’s 2020 letter about estate agents and tenants’ super, set out in the first guide, turned on the same point: it objected to advice from people who held no licence and were not authorised representatives of a licensee.

Moneysmart’s own line

Moneysmart closes its page with a short rule of thumb: be careful if someone you do not know contacts you about your super, because super matters too much to discuss with strangers. ASIC’s release adds where the official tools are: comparing the performance of MySuper products and finding lost super accounts can both be done on the ATO’s website.