AMP has denied committing criminal offences in the fees-for-no-service scandal, telling the Hayne royal commission it lacks evidence to make such a finding and further action should be left to the corporate regulator.

In a submission to the commission it blames underskilled licensees and individual planners, the “pace of regulatory change” and its former group general counsel, and denies any systemic failures in risk management practices.

The commission lacks relevant evidence on the question of requisite intent, and there is no evidence the Australian Securities and Investments Commission (ASIC) will not deal with the issue in an appropriate manner, AMP says.

It argues the proper forum for determining its conduct is before ASIC.

AMP has also accused Counsel Assisting the Commission Rowena Orr QC of inflating the number of times the group lied to ASIC.

There were only seven misrepresentations, not 20, it claims.

AMP admits its licensees breached their financial services licence requirement to provide services efficiently and fairly, but this is attributable to the “personal circumstances” of advisers, the pace of regulatory change and advisers’ skill sets.

It insists the board was unaware of the extent of communications between general counsel Brian Salter and Clayton Utz regarding the latter’s report on fees for no service.

But there is no evidence Clayton Utz disagreed with the changes Mr Salter made, or that the law firm did not stand behind the report, the submission says. Mr Salter was fired last week.

Ms Orr also inflated the number of emails exchanged, AMP says.

The submission argues that case studies show AMP Financial Planning’s supervision and monitoring processes identified and managed advisers who charged fees for no service.

The group concedes it has been too slow to remediate customers and it is committing more resources to this process. It has paid out $4.71 million in compensation.