In addition to gaining efficiencies by commoditising the packaging of its advice in Storm's back office, Storm Financial used its large flow of funds to obtain significant discounts in fees charged by financial product manufacturers such as Fund managers and Margin Lenders. This enabled Storm to pass on significant savings to its clients, effectively allowing its clients to be charged wholesale prices for retail advice and retails products. Storm offered two alternative fee options to its clients. The first fee option was a fee for service structure consisting of a relatively higher upfront fee and lower ongoing trail commission. The alternative option had a nil upfront fee component with higher ongoing trail commissions, similar to traditional financial advice models. Storm's Statement of Advice indicated that, on average, the cost of the two fee options to the client converged after a period of approximately four and a half years. Before this period the nil upfront fee option with the higher trail commission favoured the client, whilst after this period the client was better off under the fee for service option with the fee advantage increasing exponentially over time. The upfront and ongoing fees charged by Storm in both fee options were identified in general terms in Storm's Financial Services Guide ("FSG")  as well as a more detailed breakdown with specific pricing in each individual client Statement of Advice. On 12 December 2008, after having discussions with the Commonwealth Bank, the Australian Securities and Investment Commission (ASIC) began investigations on Storm Financial's advice to its clients. From the early days of Storm Financial, ASIC played an integral role in monitoring and advising Storm on its activities. Storm was well known for its proactive approach to understanding and desiring to comply with Corporations Law.  1 October 1993 Storm queries the ASC re upcoming regulations  Evidence emerged from as early as 1 October 1993 when Storm's (then Emmanuel Cassimatis & Assoc Pty Ltd ) CEO and managing director Emmanuel Cassimatis demonstrated a diligent approach in complying with the upcoming Australian Securities Commission's (as ASIC was known at the time) regulations when he wrote to the ASC to express concern and receive clarification about pending regulatory changes. The ASC replied to these concerns with advice and copies of ASC practice notes relating to sections of Corporations Law.  8 October 1993 the ASC queries Storm on advice  On 8 October 1993 the ASC wrote to Storm requesting clarification about Storms advice strategy as espoused by Storms principal Emmanuel Cassimatis in a Townsville newspaper article. Storm responded to the ASC addressing the points raised  which the ASC later acknowledged via a response letter and also advised that no further enquiries were necessary.  19 August 1994 Storm clarifies client fees with the ASC  Further evidence of diligence on the part of Storm came on 19 August 1994 when one of the directors of Storm (then Cassimatis Securities) sought clarification from the ASC about the treatment of fees and investment funds from clients.