The morning of Day Four, of round two of the Royal Commission into banking misconduct was dedicated to looking at financial planning, and continued as it had finished on the previous evening: with the culture at CBA's many brands under the microscope.  Senior counsel assisting Michael Hodge, continued with questions to Marianne Perkovic, from Commonwealth Private. He took her through a series of internal memos from Count, each explaining the circumstances of seemingly random complaints and misdemeanours - and then to a request from ASIC: the earliest of any such breaches. "We knew there were isolated complaints but not systemic to the nature in 2014," Perkovic said. "At that time, when we finished the investigation, we recognised the significance of the non-delivery of service.  So we did an early warning [letter to ASIC] because we were still investigating the extent of it, but by that stage, we knew that it was a systemic problem that … that we wanted to escalate and give an early warning to ASIC." She denied Hodge's suggestion that the purpose of this was an attempt to "manage" ASIC.  "You knew in 2012 that you had received many complaints in relation to fees being charged and no services being provided?"  "Yes." "You knew in 2012 that you had no systems capable of confirming whether services had been provided?" "Yes. "You knew in 2012 that you had systemic issues in relation to registers not being audited, not being handed over to financial planning managers and then having to be manually recreated?"   "Yes." One of the difficulties for CBA is that it has no real visibility on the services being provided by the Count authorised representatives. "Is it your understanding that until Count had figured out exactly how many clients it had taken money from without providing services, that it did not need to provide a breach notification to ASIC?    Perkovic: "With the breach process, you do need to determine the significance.  So at this time, we were still - yes, we still wanted to put in the details in - in the breach notice.  What we should have done at this time was actually switch off the fees and in hindsight or - well, when we actually went across and remediated, we did compensate for the clients." Hodge read out examples, concentrating on a few examples where the client had died but the advisers did nothing but collect fees for advice - whether not that advice was provided.Ongoing services had not been provided to clients.   Adviser provided advice to a client in 2003 who passed away in January 2004.  Adviser is aware that the client is dead but the ASF ("adviser services fee") continues to be charged.   Hodge also established that "one of the problems that Commonwealth Financial Planning had was that its remuneration and performance targets were not aligned so as to ensure delivery of service", before moving on to quiz Perkovic on the steps that CBA took in responding to the FOFA legislation in 2013. Hodge noted that the FOFA legislation took effect on 1