“A breach or likely breach of a core obligation captures a wide range of scenarios and includes any contravention of a civil penalty provision. “Considering the scope of civil penalty provisions and what may amount to trivial breaches, AIST considers that high-level guidance does not provide sufficient objectivity to assist AFS licensees determine if a breach or likely breach of a core obligation is a reportable situation. AIST supports measures that enhance breach reporting but notes that there is scope in Draft RG 78 for additional and targeted guidance on what constitutes ‘core obligation’.” AIST said there needed to be guidance on how to determine whether a breach or likely breach of a core obligation was “significant”.