Super consolidation advice and AI confidentiality: what a rollover recommendation gives away in ChatGPT or Claude.

Consolidation advice is the bread and butter of retail financial advice, and the Corporations Act asks a lot of it: the charges of switching must be set out, the lost benefits identified, and the reasons recorded. It carries member numbers, balances, the insurance that would lapse, and usually a tax file number for the rollover form. This page marks every item in a routine consolidation advice that the Corporations Act, the TFN Rule and the Privacy Act protect, and shows how the same advice is drafted on Ermos inside the practice.

The superannuation consolidation advice

Prepared when an adviser recommends moving a client from one superannuation product to another, in which case section 947D of the Corporations Act requires the Statement of Advice to set out the charges the client will or may incur, the benefits the client may lose and any other likely significant consequences.

Product replacement advice
Lucy Anne Harrington, DOB 2 August 1981¹ · Harbourview Wealth Partners⁸ · 24 October 2025

Current product. Lighthouse Retirement Fund, member 87654321, balance $186,000, Balanced option. Insurance: death and TPD $250,000 (unit-based, ceases at 50), no income protection. Fees $1,980 per year.²

Recommended product. Southern Cross Super, member 12345679 (new), Balanced option. Insurance: death and TPD $600,000 and income protection $4,300 per month, subject to underwriting. Fees $880 per year.²

Comparison. Fees fall by $1,100 per year on the current balance. The existing death and TPD cover would be lost; replacement cover is subject to underwriting and may carry an exclusion for the client’s thyroid condition. The client should not close the existing fund until the new cover is in force.³

Tax file number. 123 456 782, to be quoted on the rollover and contribution forms.⁴

Reasons. The client’s stated priority is income protection, which the current fund does not offer. The fee saving is secondary. The risk is the gap in cover during underwriting, which the sequencing above addresses.⁵

Client acknowledgement. The client understands that cover in the existing fund ceases on rollover, that the new cover is subject to underwriting, and that she has a thyroid condition that may affect terms. Signed 24 October 2025.⁶

Adviser remuneration: no commission on the superannuation product. Commission on the insurance as disclosed in the Statement of Advice.⁷

An invented advice. The TFN is the ATO’s published example value. Hover or tap any highlighted item for the analysis; the full list is below.

What leaves the practice

The client and her date of birth

Identity, with one of the standard verification facts. Privacy Act guide.

Frontier Models (ChatGPT, Claude)	Transmitted to the provider, generally offshore on personal plans
Ermos Edge	Stays on your instance in Australia; leaves only inside a permitted excerpt, per question, to the named provider
Ermos Dominion	Stays on the unit in your office

Funds, member numbers and balances

Two superannuation accounts with their member numbers. The identifiers needed for a fraudulent rollover, with the balances that make it worth attempting. Privacy Act guide.

Frontier Models (ChatGPT, Claude)	Member numbers and balances transmitted
Ermos Edge	Stays on your instance in Australia; leaves only inside a permitted excerpt, per question, to the named provider
Ermos Dominion	Stays on the unit in your office

The comparison and a health reference

The lost benefits analysis the Corporations Act requires, and the condition that may affect underwriting. Advice, and sensitive information. Patient data guide.

Frontier Models (ChatGPT, Claude)	The comparison and a health reference transmitted; on consumer tiers it can train future models
Ermos Edge	Stays on your instance in Australia; leaves only inside a permitted excerpt, per question, to the named provider
Ermos Dominion	Stays on the unit in your office

A tax file number

The TFN Rule permits TFN information to be used or disclosed only for authorised purposes, with access restricted to people who need it. A rollover form is such a purpose; a frontier model provider is not such a person. Privacy Act guide.

Frontier Models (ChatGPT, Claude)	A tax file number transmitted to the provider
Ermos Edge	Stays on your instance in Australia. If it sits in a permitted excerpt, it goes only to a named Australian provider that answers and keeps nothing
Ermos Dominion	Stays on the unit in your office

The reasons

The adviser’s reasoning and the sequencing that manages the risk. The kind of record the licensee must ensure is kept to show the best interests duty was met.

Frontier Models (ChatGPT, Claude)	Your reasoning now on a third party’s servers
Ermos Edge	Stays on your instance in Australia; leaves only inside a permitted excerpt, per question, to the named provider
Ermos Dominion	Stays on the unit in your office

The client’s acknowledgement

A signed record of what the client understood, including her health condition. The practice’s protection if the rollover goes wrong.

Frontier Models (ChatGPT, Claude)	The client’s signed acknowledgement transmitted
Ermos Edge	Stays on your instance in Australia; leaves only inside a permitted excerpt, per question, to the named provider
Ermos Dominion	Stays on the unit in your office

Remuneration

What the practice earns. Disclosure the client is owed, and commercial information about the practice.

Frontier Models (ChatGPT, Claude)	Remuneration transmitted
Ermos Edge	Stays on your instance in Australia; leaves only inside a permitted excerpt, per question, to the named provider
Ermos Dominion	Stays on the unit in your office

The practice

Ties the advice to the licensee responsible for it.

Frontier Models (ChatGPT, Claude)	Transmitted, and the leak is traceable to you
Ermos Edge	Stays on your instance in Australia; leaves only inside a permitted excerpt, per question, to the named provider
Ermos Dominion	Stays on the unit in your office

What happens in Frontier Models (ChatGPT, Claude)

The whole document is transmitted to the provider’s servers. On personal plans the user cannot choose where it is stored or processed, and for the major providers that has generally meant outside Australia, under that country’s legal process. Some business plans offer storage in Australia, but the provider still receives the content.
On consumer tiers, prompts can be retained and used to train future models.
The provider’s staff and systems can reach the content under the provider’s own policies.
Once sent, the practice no longer controls it. Retention and deletion happen on the provider’s terms.

The same document on Ermos

Ermos Dominion

The document is drafted on a unit in your office, from your own templates and the client file. Every marked item stays on the unit, which keeps working with the internet switched off. Nothing in it is transmitted to an AI provider, so there is no disclosure to analyse: the confidentiality work is the same as for your file server.

Ermos Edge

Your documents, the index and your access boundaries stay on your own instance in an Australian data centre. When a staff member asks for this draft, only their question and the excerpts they are permitted to see go to a named Australian provider, who is contractually barred from keeping the content or training any model on it. Nothing is processed outside Australia.

	Frontier Models (ChatGPT, Claude)	Ermos Edge	Ermos Dominion
Where the document is processed	Provider servers, generally offshore on personal plans	Your instance in an Australian data centre; answers generated in Australia	The unit in your office
Who can read it	Provider staff and systems, under policy	Your staff, within the boundaries you set. The named Australian provider processes only permitted excerpts, under contract, and keeps nothing	Your staff only
Is it kept	On the provider’s terms	Kept on your instance; the provider is barred from retaining it	Stays on the unit
Can it train a model	On consumer tiers, yes	No, by contract	Only your own unit learns from it, on your hardware

Part of AI data leakage in financial advice practices. See how this works in practice: SOA drafting on Ermos.

Common questions

Do ChatGPT and Claude use the information in a superannuation consolidation advice document?

Yes, pasted advice is sent to the AI company's servers and processed there. As at October 2026, whether a conversation on a personal plan (ChatGPT Free, Plus or Pro; Claude Free, Pro or Max) can be used to train the models depends on a setting each user controls. Business plans (ChatGPT Business and Enterprise, Claude Team and Enterprise) and the developer APIs sit under commercial terms, and OpenAI and Anthropic each say they do not train on that content by default (OpenAI, Anthropic). On either product, the thumbs up and thumbs down buttons can send a whole conversation back for training. It joins a tax file number to two member numbers, a fund balance and the insurance cover that would lapse.

Can we use ChatGPT or Claude for superannuation consolidation advice if we remove the names?

No, because the date of birth, the member numbers and the tax file number identify the client without a name. Removing names rarely makes a document anonymous. Information stays personal information while the person is reasonably identifiable, and the OAIC warns that information can be at risk of re-identification even when it has been de-identified or anonymised. Together with the balance, they are the identifiers a fraudulent rollover needs. The comparison also names a thyroid condition that may affect the new cover. The Office of the Australian Information Commissioner (OAIC) recommends in its guidance on commercially available AI products that organisations do not enter personal information, and particularly sensitive information, into publicly available generative AI tools, because of the significant and complex privacy risks.

Can ChatGPT or Claude be trusted to draft superannuation consolidation advice?

Not without a qualified person checking every figure against the fund statements. A language model can produce confident text containing details that are not in the source, wrong figures, wrong dates and citations to documents that do not exist. In consolidation advice the costliest errors would be the fee saving and the amount of insurance that lapses. A wrong sequence that lets the client close the old fund before the new cover starts would be worse. A member number or tax file number out by one digit could derail the rollover itself.

How can an advice practice use AI for superannuation consolidation advice without sending it to ChatGPT or Claude?

Ermos is built so the document stays under your control. On the Dominion AI unit it is drafted inside your office and none of it is sent to an AI provider. On Ermos Edge your documents and index stay on your own instance in an Australian data centre, and only the question and the excerpts the user is permitted to see go to a named Australian provider that is contractually barred from keeping them or training any model on them. The advice is drafted from the fund statements, the fact find and the practice's comparison template. The adviser checks the figures against the statements it cites and signs it.

Why do advisers hold tax file numbers at all?

Superannuation rollover and contribution forms ask for the member's TFN, and advisers complete them on the client's behalf. That makes the TFN Rule part of an advice practice's obligations, and consolidation advice the document most likely to carry one.

Does the product comparison make the advice more sensitive?

It makes it longer and more detailed. The Corporations Act requires a replacement recommendation to set out the charges and the benefits the client will or may lose, which means naming the funds, the member numbers, the insurance and the reasons. All of that is in one document, which is what gets pasted.

How is consolidation advice drafted on Ermos?

From the fund statements, the fact find and the practice's comparison template, on your own unit. The adviser confirms the figures against the statements the draft cites, and signs it. The TFN and the member numbers never leave the practice.

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