No, you may not. The Australian Securities and Investments Commission (ASIC) has issued a QFS on this matter, which is reproduced below:
Published 11 November 2003
If a retail client chooses to acquire a financial product, such as an interest in a managed investment scheme, and needs to fill out an application form to do so, what address should the client provide on that application form?
Section 1016A of the Corporations Act 2001 requires that application forms are attached to, accompany or are derived from a Product Disclosure Statement (PDS). This is to maximise the likelihood that the PDS has been received and read by the applicant before applying for the product.
Regulation 7.9.74(1) of the Corporations Regulations 2001 provides that the application form must contain the following information:
(a) the applicant's name;
(b) the applicant's date of birth;
(c) the applicant's address.
In ASIC's view, reg 7.9.74(1) is a stand-alone requirement. This means it does not contemplate that the address can be other than the address of the actual applicant. This allows the product issuer to have a means of identifying the applicant. However, the application may also contain room for a separate address for correspondence purposes.
We note it is common practice for some licensees or their representatives to provide their own business address as their client's address. In our view this is not permissible under the regulation.
Our view is consistent with s1015C of the Corporations Act 2001, which stipulates how a PDS is to be 'given' to a client. It provides that a PDS may be given to a person, or the person's agent, but cannot be given to a person's agent if the agent is acting in the capacity of a financial services licensee.
The provision of the licensee's address for correspondence purposes is not prohibited. We note, however, that to comply with good disclosure principles and the law it may be appropriate in some circumstances for disclosure documents and or periodic statements to be sent directly to the purchaser of the product. We therefore suggest that it is preferable for the correspondence address to also be the client's own address, and not the licensee's address.