---
title: "Screen and record wholesale or sophisticated client status"
url: "https://ailawframework.com/practice/financial-services-regulation/screen-and-record-wholesale-or-sophisticated-client-status"
type: "task"
site: "AI Law Framework"
id: "A28-X20260927-8"
practice_area: "Financial Services Regulation (AFSL/ASIC/credit)"
tier: "green"
lawyer_review: "required"
last_reviewed: "2026-10-22"
---

# Screen and record wholesale or sophisticated client status

> Extract the test relied on, the figures, the certificate date and the certifier's details from each client file into the classification record, and flag certificates outside the period the regulations allow, figures…

Canonical page: https://ailawframework.com/practice/financial-services-regulation/screen-and-record-wholesale-or-sophisticated-client-status  
Last reviewed: 2026-10-22

Site index for agents: https://ailawframework.com/llms.txt

## Key facts

| Fact | Value |
| --- | --- |
| Practice area | [Financial Services Regulation (AFSL/ASIC/credit)](https://ailawframework.com/practice/financial-services-regulation.md) |
| Human involvement | Green: AI drafts, lawyer checks |
| How AI is used | Extract the test relied on, the figures, the certificate date and the certifier's details from each client file into the classification record, and flag certificates outside the period the regulations allow, figures that do not meet the threshold, and files with no evidence at all. |
| What the lawyer must review | The lawyer decides which test applies to this client and this product, confirms the certificate is from a qualified accountant and certifies what the regulations require, checks the product value against the actual investment, and decides the consequences for any client wrongly treated as wholesale. |
| Written for / versions | 1 jurisdiction versions below |

## Checking plan

**Lawyer review required**

The responsible lawyer reviews the work against the instructions, sources and intended use.

- What the AI does: Extract the test relied on, the figures, the certificate date and the certifier's details from each client file into the classification record, and flag certificates outside the period the regulations allow, figures that do not meet the threshold, and files with no evidence at all.
- What the lawyer does: The lawyer decides which test applies to this client and this product, confirms the certificate is from a qualified accountant and certifies what the regulations require, checks the product value against the actual investment, and decides the consequences for any client wrongly treated as wholesale.
- Who reviews: Responsible lawyer with competence in the matter
- Basis: Practical workflow informed by the linked primary sources; the traffic light and working checks are editorial guidance, not a court classification.
- Why: The level reflects what the work is, the consequence of an error, and how much of the output the lawyer must independently re-derive.

## Checks the lawyer makes

1. Confirm the instructions, the jurisdiction and the complete relevant material before starting.
2. The lawyer decides which test applies to this client and this product, confirms the certificate is from a qualified accountant and certifies what the regulations require, checks the product value against the actual investment, and decides the consequences for any client wrongly treated as wholesale.
3. Check the output against the source documents named in it before it is relied on.

## Notes

- These are suggested working checks. Confirm the required checking with the responsible lawyer before work starts; the checking approach does not establish permission to use AI.

## Sources

- [https://www.asic.gov.au/regulatory-resources/financial-services/financial-product-disclosure/certificates-issued-by-a-qualified-accountant](https://www.asic.gov.au/regulatory-resources/financial-services/financial-product-disclosure/certificates-issued-by-a-qualified-accountant) (checked 2026-09-27)
- [https://www.aph.gov.au/Parliamentary_Business/Committees/Joint/Corporations_and_Financial_Services/Wholesaleinvestor/Report/Chapter_2_-_The_wholesale_investor_and_client_tests](https://www.aph.gov.au/Parliamentary_Business/Committees/Joint/Corporations_and_Financial_Services/Wholesaleinvestor/Report/Chapter_2_-_The_wholesale_investor_and_client_tests) (checked 2026-09-27)

## Forms and precedents for this task

| Form or precedent | Kind | AI level | Summary |
| --- | --- | --- | --- |
| [Record of retail, wholesale or sophisticated client status](https://ailawframework.com/precedents/financial-services-regulation/wholesale-client-status-record.md) | Memo | Yellow | Working record under sections 761G and 761GA of the Corporations Act 2001. Dollar thresholds that sit in the regulations are left blank. The principal decides the status. |

Signed-in accounts can read the full text of each one.

## Jurisdiction versions

| Jurisdiction | Level |
| --- | --- |
| [United States](https://ailawframework.com/practice/financial-services-regulation/screen-and-record-wholesale-or-sophisticated-client-status/united-states.md) | Yellow |

*Practice guidance for planning and review. Confirm current primary sources and the requirements of the actual matter. This is general information, not legal advice.*