WealthCo Advisory is a wholly-owned subsidiary of a life insurer and recommends, among others, its parent's policies. It pays its representatives no product-biasing commission and represents six providers per class. May WealthCo promote itself as 'independent'?
Regulation 21(1)(iii)/FAA-G05 requires the adviser to operate without any conflict of interest created by a connection to, or association with, a product provider. WealthCo's ownership by an insurer whose products it recommends is exactly such a conflict, so it cannot be independent even though it satisfies the commission and four-provider limbs.
Passing the commission and four-provider tests does not cure a conflict arising from association with a product provider.
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