Big wealth adviser AMP has hit back at the banking royal commission, strenuously denying it has committed any criminal offence and arguing its failings should be dealt with by ASIC, not the commission.

Key points: AMP strenuously denies it has committed any criminal offence over allegations it misled ASIC

AMP strenuously denies it has committed any criminal offence over allegations it misled ASIC The wealth manager says ASIC, not the commission, is the "proper forum" to deal with allegations of misconduct levelled against it

The wealth manager says ASIC, not the commission, is the "proper forum" to deal with allegations of misconduct levelled against it AMP says Craig Meller and Catherine Brenner did nothing wrong regarding changes to independent report

AMP's rebuttal of the commission's actions and line of inquiry by counsel assisting Rowena Orr, QC, are included in a 28-page submission into the company's alleged misconduct in financial planning and dealings with ASIC that have been aired at recent hearings.

"AMP acknowledges its failings consistent with the evidence which is before the commission, but does not accept all of the open findings which counsel assisting submits should be made," AMP said in a statement.

"AMP further submits that the proper forum for a determination regarding AMP's conduct is before ASIC, and any judicial proceeding ASIC may commence.

AMP's argument is ASIC had already been looking at the matters, which include charging clients "fees for no service", since 2015 and its investigation is nearing completion.

"AMP fully expects that ASIC will deal with them in an appropriate manner consistent with ASIC's enforcement priorities, and under a proper process, with affected parties having had an opportunity to be heard," the statement read.

Sorry, this video has expired AMP's Jack Regan loses count of how many misleading statements were made to ASIC

The company is particularly upset with the treatment it received from Ms Orr during her forensic examination of executives, as well as her invitation to Commissioner Kenneth Hayne to find AMP had engaged in criminal conduct during the preparation of a report by lawyers Clayton Utz.

"The questions put to [AMP head of advice] Mr [Jack] Regan suggested or implied that both Mr [Craig] Meller, the CEO of AMP, and Ms [Catherine] Brenner, the chairman of AMP, sought to improperly influence the content or findings of the report, particularly in respect of Mr Meller's role in the conduct being investigated," AMP said.

"There is no basis for such a finding. The evidence discloses no reasonable basis for a finding that either Mr Meller or Ms Brenner acted inappropriately."

Craig Meller and Catherine Brenner departed AMP following the royal commission revelations. ( AAP: David Moir )

AMP described Ms Brenner's actions in relation to the Clayton Utz report as "appropriate and consistent with good governance".

"Ms Brenner received two versions of the report. There was no indication in the email from Clayton Utz sending her that version that the report was still a draft.

"Nor did that email [or any other] offer Ms Brenner advice about the manner in which the document ought to be treated.

"Irrespective of any criticism that might be levelled at the production of the Clayton Utz report, it was an important and powerful catalyst for the actions AMP has taken and is taking to address the findings which it made."

Both Mr Meller and Ms Brenner left the company with days of allegations being raised at the commission that the report's supposed independence had been compromised by the board's involvement in its preparation.

Misleading ASIC 'overstated'

AMP also said Ms Orr overstated the number of times it had misled ASIC, arguing it was more like seven, rather than the 20 instances raised.

"AMP recognises that any misrepresentation to ASIC is plainly unacceptable. However, the number of separate misrepresentations said to have been made by AMP to ASIC was nonetheless overstated by counsel assisting," the company said.

"The evidence is that there were seven misrepresentations [in 12 communications], not 20."

AMP said its communications with ASIC fell below community standards and expectations, but there was no evidence before the commission that ASIC would deal with the matter appropriately, or that the commission should make any findings on whether there had been breaches of the corporations act.

While all the banks and financial institutions fronting the commission have suffered significant reputational damage, AMP so far appears to have been the most battered.

Apart from losing its chief executive, chair and chief counsel, it has also been abandoned by investors worried about its current predicament and the future of its advice-driven model.

The banks have lost less than 5 per cent of their value since the commission started, while AMP's share price has plummeted more than 20 per cent.