While it might seem a bit harsh to be punished for a victimless crime, or even a crimeless crime, the case underlines the procedural standards advisers - and just about everybody really - must adhere to these days.
"The critical importance of proper record keeping cannot be minimised, particularly because of the influence it can have in an AFA determining whether he or she has an up-to-date understanding of a client's financial situation, needs, goals and tolerance for risk," the FADC says.
From what I understand, X was simply an old-school, deal-on-a-handshake adviser who probably found the admin tiresome.
The most interesting aspect of the case is the fact it was X's employer, QFE Y (owned by a well-known Australian financial services firm), that dobbed him in to the authorities.
The QFE's decision to turn in one of its own is an understandable risk management move given it is accountable for its advisers but there's probably more to it - some kind of relationship breakdown between X and Y looks likely.
At any rate, Y fired X at some point.
"This appears to have caused the loss of an anticipated opportunity for the AFA to sell the adviser business to the QFE," the FADC says. "It was said to be worth in excess of $200,000."
Looks like Y hit X for six.