How Finance Frank operates

1. Coach, not advisor — and why the distinction matters

Frank is a financial coach — focused on the process and habits of managing your money. We are deliberately not a financial advisor.

Under section 766B of the Corporations Act 2001 (Cth):

• Personal advice (s766B(3)) is a recommendation or opinion intended to influence a person's decision about a particular financial product, given in circumstances where a reasonable person would expect the provider to have considered that person's objectives, financial situation, or needs.
• General advice (s766B(4)) is financial product advice that is not personal advice. Providing either category of financial product advice is a regulated activity that requires an Australian Financial Services Licence (AFSL).

Frank is designed and intended to provide none of the above. Frank's outputs are designed to be one of: (a) a fact about your own data, (b) a calculation derived from your own data using a documented formula, (c) factual information that is publicly available (rates, thresholds, definitions), or (d) educational content about how financial concepts work in general terms. In the rare event that an AI-generated output strays beyond these categories — for example, due to an AI hallucination — we treat that as a defect, retract or correct the response if a user reports it, and review whether a guardrail update is needed. Our security and quality controls are described at /security.

We do not recommend specific financial products, funds, ETFs, stock codes, super funds or providers. We do not provide opinions on whether a particular product is suitable for you, or on whether one product is better than another. We do not match your financial profile to a class of product.

Model portfolios. Frank may display a published model portfolio from a third-party source (e.g. a Vanguard model portfolio or an AustralianSuper allocation breakdown) only when you have explicitly asked to see one as an educational example. The portfolio is presented as published, with attribution and a clear “educational example only — not a recommendation” label. Frank does not select which portfolio to surface based on your personal financial profile; if you ask for “a model portfolio” without specifying, Frank will list available examples and let you pick. We are aware that ASIC's Regulatory Guide 255 (Providing digital financial product advice) treats the act of matching user characteristics to portfolios as the regulated activity, not the portfolio itself, and we have built around that.

This is a structural choice — not a marketing posture. We are aware of Westpac Securities Administration Ltd v ASIC [2019] FCAFC 187, ASIC Regulatory Guides 244 (Giving information, general advice and scaled advice) and 255 (Providing digital financial product advice), ASIC Information Sheet 269 (Building resilient digital advice), the Quality of Advice Review reforms (Delivering Better Financial Outcomes Act 2024 (Cth)), and ASIC's December 2024 statement on AI in financial services. Together they broaden the circumstances in which a reasonable person may expect personal-advice consideration in AI-driven and personalised tools. We treat that as a continuing constraint on what Frank is allowed to surface and how, and we will not introduce features that materially shift Frank into personal-advice or general-advice territory without first obtaining the appropriate licensing.

2. Evidence-based methodology

Where Frank does present information about your finances — tax brackets, super caps, contribution thresholds, peer benchmarks, cost-of-living rates — every constant is sourced and dated.

• Tax and government rates: sourced from ATO, Services Australia, and state revenue offices. Each rate in our public registry has a source URL and a last-verified date. A regular automated verifier checks the source pages and alerts us on drift; if a rate becomes stale beyond our threshold, the relevant in-product surface displays a stale-rate banner so you can choose whether to rely on it.
• Peer benchmarks: drawn from published external datasets — ABS Survey of Income and Housing, ATO Taxation Statistics, APRA superannuation tables, RBA household finance statistics. Sources cited on /benchmarks. The peer comparisons shown in-product today are computed against these published figures, not aggregated from our own user base.
• Financial frameworks Frank uses: standard bucket-strategy retirement income (as published by Vanguard and similar institutions), the four-bucket budget heuristic (Needs / Wants / Savings / Debt), and a dual savings-rate methodology (gross-of-super and net-of-super) so the figure can be compared like-for-like across employed and self-employed users.
• SMSF compliance checks: sole-purpose test, in-house asset rules, and minimum pension drawdown calculations follow the Superannuation Industry (Supervision) Act 1993 (Cth) and ATO published rules.
• Health score: a transparent weighted average of components documented at /benchmarks; not a proprietary black-box score.

3. Boundaries — what Frank cannot do, and what stays with you

Knowing what Frank doesn't do is as important as knowing what it does:

• Frank does not lodge anything to the ATO. It does not act as your registered tax agent or BAS agent.
• Frank does not give personal financial advice (see Section 1 above) and does not hold an AFSL.
• Frank does not move money. It does not have the ability to transact on your accounts, transfer funds, or initiate payments.
• Frank does not connect to your bank via Open Banking / Consumer Data Right or any third-party transaction aggregator. You decide what data enters Frank by manually entering it, importing CSVs, or uploading documents.
• Frank's AI responses can contain errors. You should verify any number you intend to act on against a source document or a licensed professional.

You remain the decision-maker. Frank exists to help you understand your money clearly, not to make decisions for you. Every financial outcome — good or bad — is your responsibility, informed by your own judgement and the professionals you choose to consult. We are an input to your thinking, not a substitute for it.

3a. Automated processing — what Frank does and doesn't do

Frank uses AI and rule-based automation to surface insights, calculations, narrative summaries and educational suggestions. None of these outputs constitute a substantially automated decision with a legal or similarly significant effect on you within the meaning of the new APP 1.4(b) automated-decision-making transparency obligation (commencing 10 December 2026). Frank doesn't lend money, set premiums, decide tax positions, lodge returns, or otherwise determine an outcome that binds you or a third party — you remain the decision-maker. The full list of automated processes we use, and the safeguards around them, lives in Privacy Policy Section 8a. If we ever introduce a feature that does involve a substantially automated decision (e.g. an automated underwriting feature), we will update this page and the Privacy Policy in advance and provide a human-review pathway.

4. Independence — how we make money

Conflict of interest is one of the largest risks in the financial-services-adjacent space. We are structurally independent and intend to stay that way:

• Customer subscriptions are our only revenue source. We make money from subscriptions paid by you (personal tier) or by your firm (practice tier). We do not currently receive, and have no current plans to introduce, referral fees, kickbacks, revenue-share arrangements, paid placement, or sponsorship from any bank, super fund, broker, ETF issuer, insurance provider, or other financial product provider.
• No paid placement in Frank's suggestions, comparisons, or model portfolios. Where a third-party fund or product is referenced, it is because the underlying methodology cites it as a published example, not because of any commercial arrangement with the issuer.
• No data sales. We do not sell, rent, or share your personal information or any de-identified data with third parties for their own marketing or commercial purposes. We do disclose data to the sub-processors listed in our Privacy Policy Section 4 strictly to operate the Service on your behalf — that is the only third-party data flow.

If our independence model changes in any material way (e.g. we introduce a directory of practitioners or any form of affiliate revenue), we will obtain any required regulatory authorisation under the Corporations Act before introducing any such arrangement (which may include an AFSL or AFS authorised-representative arrangement, plus FSG and PDS obligations where applicable), and we will update this page accordingly. We will mark every affiliated reference clearly in-product, and ensure the logic of any in-product suggestion is not influenced by the commercial arrangement. Until that happens, the position is as stated in the bullets above.

Last reviewed: 2026-05-10. We will update this page when material changes are made to the platform or to the regulatory environment.

See also: Security · Privacy · Terms · Benchmarks · Practitioner posture (B2B)