Here's a complex legal concept: A Frankenstein is a Frankenstein, irrespective of how many 'Tiers' it has.
Every kind of regulatory structure has its advantages and disadvantages.
The problem in my view is not the number of 'Tiers', but that the regulator is building them. The regulator is building the structure that determines the regulator's own role in the structure. And - surprise, surprise - Australia has ended up with a structure that relies on a myriad of approvals, exemptions, certificates, permits, ratings and licences granted at the discretion of the regulator, in return for a fee paid to the regulator.