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AMP has also been recommended for criminal charges for presenting to ASIC a report by Clayton Utz as independent, despite making the law firm change the report 25 times. The charges were recommended under 1308 (2) and 1308 (3) of the Corporations Act which deals with misleading statements to ASIC.

"Having regard to changes made to the report, there is a reasonable basis for concluding that AMP, by one or more of its senior employees or officers, knew that the representation that the report and the findings made within it were entirely independent was materially incorrect," Ms Orr said.

Ms Orr also recommended AMP be charged for breaching Section 64 of the ASIC Act, which is a criminal breach.

The commission's recommendation came after Treasurer Scott Morrison suggested AMP and its executives be recommended for criminal charges.

The royal commission heard that AMP misled the Australian Securities and Investments Commission 20 times about its lack of issues with fees for no service.

Ms Orr said it was open to the royal commission to find AMP had made material breaches under 1308 (4) and 1308 (5), which both carry criminal penalties. Companies can be fined as much as $210,000 for each breach.

She added that AMP may have breached its duty to provide fair, honest and efficient services when failing to move customers out of its platforms.

In a statement AMP said it acknowledged the seriousness of the submissions and would review them "closely" before responding next week.

It noted that Commssioner Kenneth Hayne would have AMP's full submissions, including one to be made next week, before making any findings.

Ms Orr also invited Commissioner Hayne to find that the Commonwealth Bank of Australia had breached its financial licence provisions, the Corporations Act by not reporting its fees for no service issues to ASIC for two years.

The law requires all licence holders to report significant breaches to the regulator in 10 days.

These breaches included CBA charging dead clients fees for services. CBA, referred to by the royal commission as the gold medallist of fees for no service, has so far confessed to charging tens of thousands of clients $119 million in fees for services they did not receive.

Ms Orr said CBA's lack of breach reporting was a result of the size of the bank's planning arms.

“It is open to the Commissioner to find that a reason for CBA's failure to give timely notice of a breach to ASIC may be a consequence of the manner in which CBA’s practice for considering whether to notify a breach takes into account the size of CBAs advice licensees,” Ms Orr said.

"Each of the CBA advice licensees have many clients, exponentially more than the number of clients than a small independent operator would have," Ms Orr said.

Ms Orr said that the evidence suggest that if an authorised planner under CBA’s Count licence, for example, made a significant breach of the law it would not be treated as a significant breach at the level of Count rather than just the individual.

“Therefore, the size of CBA may reduce the likelihood that ASIC receives timely notice under section 912D of risks to members of the public who are dealing with CBA or its subsidiary licensees," Ms Orr said. Section 912D of the Corporations Act relates to breach reporting by financial services licencees.

Ms Orr also said it would be open for the commission to find that the Commonwealth Bank’s Colonial First State had breached the Corporations Act for charging investment platform fees inappropriately.