ABZ Bank (ABZ), an ADI and AFS Licensee, operates through 700 branches across Australia. Z Super is a superannuation product issued and promoted by Zpac Super, a wholly-owned subsidiary of ABZ. ABZ runs an aggressive marketing campaign to distribute Z Super through its retail branch network. Any branch staff who sells Z Super is paid a substantial commission. Z super is sold to customers by ABZs branch staff who are authorized to provide general advice to retail customers and to assist retail customers to apply for superannuation products. The distribution process developed and implemented by ABZ involved the following steps:

- Firstly, the branch staff member asks the retail customer to fill in a questionnaire of 25 questions (called 1-25 review) on the financial situation, needs and circumstances of the retail customer.

- Secondly, the branch staff member asks whether the retail customer would like to be provided with information about Z Super.

- Thirdly, if the retail customer agrees, the retail customer is provided with a detailed Product Disclosure Statement and brochure. The branch staff also provides a quick appraisal of benefits to invest in Z Super and provides them with a general advice warning. Fourthly, the branch staff obtains (1) signatures on blank forms for Z Super and (2) a letter of authorization for cancelling the existing superannuation account.

The application will only be proceeded upon confirmation from the retail customer through an email or telecall. ASICs surveillance on branch sales of Z Super has revealed that 45-50% of customers opted for Z Super soon after the 1-25 review on the same day.

ASIC is concerned about the promotion of Z Super through branches and initiates an investigation. You are employed in the legal division of ABZ and are asked to review if the sale and distribution of Z Super breach any provisions of Chapter 7 of the Corporations Act, 2001 (Cth). You are specifically asked to include a detailed analysis of whether ABZ's staff comply with the best interests duty and related obligations under C7.7A of the Corporations Act, 2001 (Cth).