The regulator has previously said only that its work was ongoing.
But Russell Hutchinson, of Chatswood Consulting, said some of the advisers who had been interviewed had now received a letter from the FMA.
"Most advisers in the process will have something to improve upon - that doesn't surprise us as our interaction with advisers suggest that we are going through a step-change in how advisers approach record-keeping and written documentation of their advice processes. Or put another way - those things have been poor in the past and many insurance advisers have been improving them a lot recently," he wrote.
Hutchinson said the issues highlighted by the FMA included client files and fact finds. "That one can be an RFA and not keep advice files is probably a good criticism of the current law."
It was also concerned about whether RFAs were putting clients first and dealing with their comparison requirements properly when replacing business.
"When advising on replacement the FMA's current guidance is clear: you either need to warn that you aren't doing a comparison, or prepare a good side-by-side comparison including strengths and weaknesses and details of any stand-down periods, if applicable," Hutchnson said.
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