About 11,000 people put $1.1 billion into First Guardian and Shield, and most never complained

The loss figure is the part everyone has heard. About 11,000 Australians put roughly $1.1 billion into the Shield Master Fund and the First Guardian Master Fund. The ABC has reported higher figures, about 12,000 people and more than $1 billion, split between roughly 6,000 First Guardian investors and about 5,800 in Shield. The two counts do not reconcile precisely, and neither ASIC nor the liquidators have published a final reconciliation.

What is less reported is the plumbing, and the plumbing is what determines who pays.

Neither fund was sold to most of these people directly. The money arrived through superannuation platforms, each run by a trustee that decided to make the fund available to its members. ASIC records approximately $300 million invested into First Guardian between July 2020 and July 2024 through funds for which Diversa Trustees Limited was trustee, with about $243 million still held for 2,055 members as at April 2025. A further $128.5 million came through Netwealth for approximately 1,303 members, and more than $65 million through an Equity Trustees fund for about 2,700 members.

The court record begins on 27 February 2025, when the Federal Court froze assets connected with First Guardian and its responsible entity, Falcon Capital Limited. On 9 April 2025 the court appointed liquidators, Ross Blakeley and Paul Harlond of FTI Consulting, and made orders for the winding up of the fund. Further orders followed, including the appointment of a receiver on 22 August 2025.

Compensation has moved faster than litigation, and it has moved through admissions rather than judgments. On 17 December 2025 Netwealth agreed with ASIC to compensate affected members, admitting that as trustee it had failed to obtain and therefore did not assess sufficient information about First Guardian before making it available. Netwealth told members the payment took effect on 28 January 2026 and was calculated as the amount paid for units, less withdrawals and any gains realised on redemption. The total was approximately $101 million. ASIC states that by February 2026 about 4,000 consumers had received approximately $421 million from Macquarie and Netwealth under court enforceable undertakings.

The gap that follows is the complaint gap. ASIC recorded that fewer than 2,000 of roughly 11,000 investors had lodged a complaint with the Australian Financial Complaints Authority as at February 2026. ASIC has since noted that AFCA has received more than 3,000. Both numbers are well short of 11,000. The regulator has sent at least twelve rounds of direct mail and email to affected consumers, which suggests the shortfall is not simply a failure to make contact.

Complaining matters because of what sits at the end of the queue. The Compensation Scheme of Last Resort pays consumers whose AFCA determination goes unpaid, and it is capped at $150,000 per person. The ABC reported the case of one investor awarded $376,312.94 by AFCA whose recovery through the scheme is limited to $150,000. A person who never lodges a complaint reaches neither the determination nor the cap.

ASIC describes the matter as among the largest and most complex in its history, with nearly 50 staff working on 26 investigations. Several civil proceedings against platform trustees and advice businesses have been filed and are not yet decided, so nothing about those allegations has been established and this report makes no finding on them.

Three things remain unknown. The first is the recovery from the funds themselves: the liquidators have identified receivables but no distribution figure has been published. The second is the size of the shortfall that will land on the Compensation Scheme of Last Resort, which cannot be calculated until the pending cases and the AFCA determinations resolve. The third is the simplest and the least examined: why, eighteen months after the freezing orders, roughly two thirds of the affected investors have still not lodged a complaint.