FSG
Financial Services Guide (Version 14)
Date: 20 May 2019
Financial Services Guide Version 14 (Date: 20th May 2019)
Important Information about our Licensee
We are authorised representatives of GWM Adviser Services Limited ABN 96 002 071 749, Australian Financial Services Licence Number 230692 (“GWM Adviser Services”) of Level 1, 105-153 Miller Street, North Sydney NSW 2060.
GWM Adviser Services is recognised as one of Australia’s leading financial advice networks, with approximately 400 experienced financial planners across Australia managing over $14 billion of investments.
GWM Adviser Services is a professional partner of the Financial Planning Association, the professional body representing qualified financial planners in Australia, and therefore adheres to set standards in terms of ethics, conduct and continuing professional development.
Our associations and relationships
GWM Adviser Services is part of the National Australia Bank Limited (“NAB”) group of companies (“NAB Group”).
As the NAB Group is an issuer of financial products, we are not able to refer to ourselves or our advice as ‘independent’, ‘impartial’ or ‘unbiased’. If you would like further information about independence, conflicts or selecting a financial adviser you can visit ASIC’s Money Smart website (www.moneysmart.gov.au/investing/financial-advice).
GWM Adviser Services Financial Planners are required by law to provide financial advice that meets the obligations set out in the Corporations Act to act in the best interests of each client.
We may recommend financial products issued by companies within the NAB Group or companies in which a shareholding is maintained by a NAB Group member (including MLC Limited).
These include products and services with the following branding:
• NAB, National
• MLC
• JANA
• JB Were
• Plum
• Pre Select Funds
• Private Investment Consulting
• WealthHub Securities
• Altrinsic Global Advisers
• Antares Capital
• Fairview Equity Partners
• Intermede Investment Partners
• Presima Inc
• Redpoint Investment Management
If we recommend a product or service issued by a NAB Group company, they will benefit from our recommendation by receiving product and management fees from you as well as fees paid by fund managers to distribute the fund manager’s product. Please refer to the relevant PDS and/or offer documents for further information.
We generally recommend products that are listed on GWM Adviser Services’ approved product list. These will include NAB Group products. Before any products are added to this list a review process is undertaken and products are required to meet minimum standards. If these products are not appropriate for your circumstances then we may recommend a product outside of this list. At all times, we will ensure that our recommendations are in your best interests. You can view a copy of our approved product list on the Garvan website garvan.mlc.com.au
NAB does not guarantee or otherwise accept any liability in respect of the financial advice or services provided by GWM Adviser Services or its authorised representatives.
NAB and its related bodies corporate distribute insurance products issued by MLC Limited ABN 90 000 000 402. MLC Limited is part of the Nippon Life Insurance Group and not a part of the NAB Group.
MLC Limited will pay National Wealth Management Services Limited, a related body corporate of NAB, a distribution allowance as described in the ‘Distribution Allowance’ section of this FSG. If appropriate to your requirements, objectives and circumstances then a GWM Adviser Services adviser may an insurance policy issued by MLC Limited.
About us
Who we are
Your Financial Adviser Pty Ltd ACN 159 886 647, as trustee for Your Financial Adviser Unit Trust, ABN 96 338 686 530 trading as Your Financial Adviser Authorised Representative Number 430475.
The following financial advisers are authorised to provide the financial services referred to in the ‘What we do’ section of this FSG to you on behalf of GWM Adviser Services:
Julie Van Meegen
Authorised Representative No. 342112
GWM Adviser Services Limited has authorised us to provide you with this Financial Services Guide.
What we do
We are authorised by GWM Adviser Services to provide financial advice in relation to:
• Wealth Accumulation
• Income & Asset Protection
• Tax Strategies
• Superannuation
• Retirement & Redundancy Planning
• Estate Planning
• Government Benefits
• Debt Management
and to provide financial advice and deal in the following financial products:
• Basic Deposit Products
• Non-basic Deposit Products
• Non-cash Payment Facilities
• Life Products – Investment Life Insurance
• Life Products – Life Risk Insurance
• Superannuation
• Retirement Savings Accounts
• Managed Investment Schemes, including Investor Directed Portfolio Services (IDPS)
• Derivatives
• Government Debentures, Stocks or Bonds
• Securities
• Standard Margin Lending Facilities
Julie Van Meegen is not authorised by GWM Adviser Services Limited to provide financial product advice in the following financial products:
• General Insurance Products
We are not authorised to provide any other financial services or financial products on behalf of GWM Adviser Services.
Where we are unauthorised to provide you with a financial service or financial product that you are interested in, we will advise you of this and refer you to an alternative source of advice.
Contact us
For more information on anything you have read in this FSG, to obtain a copy of our privacy policy or if there is anything else we can help you with, please contact us at:
Street Address: Unit 7, Level 2, 63B Market Street, Wollongong NSW 2500
Poastal Address: PO Box 5067, Wollongong NSW 2520
Phone: 02 4226 2795
Julie Mobile: 0421 926 511
Website: www.yourfa.com.au
Julie Email: julie@yourfa.com.au
Your confidence in our advice
Your satisfaction is very important to us and we have procedures in place to resolve any concerns promptly and fairly.
Our complaints procedure
If you’re unhappy with the advice you receive or other aspects of our service please follow the steps outlined below.
1. Please let your financial adviser know so we can act on it immediately.
2. If your adviser has not satisfactorily resolved your complaint, please contact our Advice Dispute Resolution Team on:
Phone: 1800 611 950
Email: advice.complaints@nab.com.au
In writing to:
Advice Dispute Resolution Team
GWM Adviser Services
Level 2, 105-153 Miller Street
North Sydney NSW 2060
3. If your complaint isn’t resolved within 45 days or to your satisfaction, then you may refer the matter to the Australian Financial Complaints Authority (AFCA):
Website: www.afca.org.au
Email: info@afca.org.au
Telephone: 1800 931 678 (free call)
In writing to: Australian Financial Complaints Authority
GPO Box 3, Melbourne VIC 3001
AFCA provides fair and independent financial services complaint resolution that’s free to consumers.
Time limits may apply to lodge a complaint with AFCA, so you should act promptly. You can check the AFCA website to find out if a time limit applies or when the time limit relevant to your circumstances expires.
GWM Adviser Services holds professional indemnity insurance that satisfies the requirements of section 912B of the Corporations Act. This insurance also covers the conduct of our advisers who were authorised by GWM Adviser Services at the time of providing the advice, but are no longer authorised representatives of GWM Adviser Services at the time of your complaint.
Payments and benefits we receive
You can pay for the services you receive on a fee for advice basis. This allows you to know that you are paying for our advice irrespective of any product you use, clarifies the services you are entitled to, and ensures all recommendations are driven by your needs.
We will agree with you the amount you pay based upon:
• a flat dollar fee;
• an hourly rate;
• the amount you invest; or
• a combination of the above.
You can pay in the following ways:
• as a fee for advice that will be deducted from your investments as a one-off payment or in instalments;
• by direct invoice from us for initial and ongoing advice;
• via commission we may receive from a financial product provider when you commence an insurance contract; or
• a combination of the above.
If you are not already on a fee for advice package, you can move to this payment at any time.
Other payments we may receive
We will provide you with details of all fees, commissions or other benefits we may receive when we provide advice to you and, where possible, will give actual dollar amounts. If we cannot provide this accurately, we will provide worked-dollar examples.
Even if you don’t receive personal financial advice from us, you can still request the details of any fees, commissions or other benefits we receive in relation to any other financial service we provide you.
Benefits we may receive
Sometimes in the process of providing advice, we may receive benefits from product providers.
Conferences
We may attend conferences and professional development seminars that have a genuine education or training purpose. GWM Adviser Services Limited, or our employer, may pay for the costs of our travel and accommodation, and events and functions held in conjunction with the conference or seminar.
Non-monetary benefits
We keep a register detailing certain non-monetary benefits that we receive e.g. benefits valued between $100 and $300, and those that relate to genuine education or training and technology software or support.
You can view an extract of the register by contacting us. Please be aware that GWM Adviser Services Limited may charge you for the cost of providing this information to you.
Sponsorship
GWM Adviser Services Limited receives cash payments from product providers who sponsor and attend training presentations, conferences and/or professional development days. Amounts vary between product providers and we do not directly share in the sponsorship payment; however, we may indirectly benefit as these payments subsidise the costs associated with these training and professional development events.
Distribution Allowance
MLC Limited pays a distribution allowance to National Wealth Management Services Limited, a related body corporate of NAB, in respect of the distribution of MLC Limited’s insurance products by licensees in the NAB Group (including NAB). This amount is not ascertainable at this time and will depend in part on the value of MLC Limited’s insurance portfolio relating to insurance distributed through NAB and its related bodies corporate and the performance of NAB and its related bodies corporate against agreed annual performance criteria.
This allowance is not shared with us and does not represent an additional charge to you.
Referrals
Referrals from a third party
We have arrangements in place to pay a referral fee, commission, or other benefit to certain third parties when they refer new clients to us. Our current arrangements for referrals from a third party are set out in the table below and specific details of any benefit we provide in relation to our advice to you will be included in the advice documentation we provide to you.
Table – Details of arrangements for referrals from a third party:
Name of referral partner Payment we provide for the referral
Example
MoneyQuest Wollongong Receives both:20% upfront commissions or fees and 20% ongoing commissions or fees
If Your Financial Adviser receive a fee or commission of $1,000 then MoneyQuest Wollongong will receive an upfront fee of $200 and an ongoing fee of $200 p.a.
Referrals to a third party
We have referral arrangements in place with third party providers. If we refer you to one of these providers we may receive a payment, fee, commission or other benefit from those providers.
Details of these arrangements are set out in the table below and specific details of any referral payments we may receive will be provided in our advice documents to you. Alternatively, you can request further details about our referral arrangements prior to us providing you with financial advice.
Table – Details of referral arrangements in place:
Name of referral partner Services
Payment we will receive for referral
Example
MoneyQuest Wollongong Mortgage Broking
Receives both:
20% upfront commissions or fees and 20% ongoing commissions or fees
If Moneyquest Wollongong receives a fee or commission of $1,000 then Your Financial Adviser will receive an upfront fee of $200 and an ongoing fee of $200 p.a.
Please note that Garvan is not responsible for the advice and services provided by these providers.
Referrals to an associated entity or related third party
How we charge for our services
All fees and commissions are inclusive of GST and the fees could be greater than those disclosed below in complex cases. In these instances, we will inform you of the exact fee payable promptly in writing.
Initial consultation Free of charge.
Advice preparation If you elect to pay us a fee for advice the following fees will apply. The fees will depend on the size of the investment portfolio and the complexity of the advice. The minimum fee charged is $550 while the maximum fee is $5,500. For example complex advice that contain multiple goals, strategies and/or tax structures including but not limited to; self-managed superannuation Funds, family trusts and companies, are likely to be charged closer to the maximum. Less complex advice that addresses limited goals, strategies and tax structures are likely to be charged closer to the minimum.
Implementation If you elect to pay us a fee for implementing the advice the following fees will apply. The fees will depend on the size of the investment portfolio and the complexity of the advice. The minimum fee charged is $550 while the maximum fee is $5,500.
Borrowed funds – if we recommend you acquire investments using borrowed funds then your implementation fee will be a minimum of $550 and a maximum of $5,500.
Ongoing fee for advice If you elect to pay a fee for the ongoing review of your financial planning strategy, the ongoing fee is based on the complexity of ongoing advice and the services provided.
The minimum fee is $330 while the maximum is 2.5% of the value of your portfolio each year. For example for investment valued at $200,000 the maximum ongoing fee would be $5,000 pa.
Borrowed funds – if we recommend you acquire investments using borrowed funds then your ongoing fee will be a minimum of $550 and a maximum of $5,500 pa.
The ongoing advice fee will be based on the level of service needed and the complexity of the advice. Complex advice requirements include the use of trusts and ownership structures, overseas assets or incomes, executive options or multiple investment entities. The frequency of the review will also impact on the fee charged.
Ad hoc advice Where you do not wish to participate in an ongoing service fee arrangement but require ongoing advice on an ad hoc basis, the ad-hock appointment cost is $440 and an hourly fee of between $165 and $330 may apply if further work is required.
Execution only service Where we provide a financial service to facilitate buying or selling of a specific financial product as instructed by you, a one-off minimum of $100 and a maximum of $330 fee may apply.
Stamping Fees Where we receive stamping fees from issuer companies for raising capital or debt on behalf of that company, we will offset this payment against the cost of our advice to you.
Pre-existing arrangements
For clients already in a pre-1 July 2013 commission arrangement, we may receive commission on investment and superannuation products or margin lending products. For investment products and superannuation products, the relevant product issuer will pay initial commission between 0% and 5.5% and ongoing commission between 0% and 0.88% of the value of your investments for as long as you hold the product. For margin loans the relevant product issuer will pay an ongoing commission between 0% and 0.88% of the outstanding loan balance. Commissions are paid to us by the product provider and are not an additional cost to you.
Insurance products Where we arrange a life insurance product for you, the relevant insurer will pay an initial commission to us. The commission is calculated as a percentage of the premium paid (and may include health, occupational, frequency and modal loadings and policy fees, but excludes stamp duty).
Annual commission will also be paid when you renew your policy each year.
The rates of initial and ongoing commission will depend on the date the policy is issued and are set out in the table below:
Date policy is issued Initial Commission (% of annual policy cost including GST) Ongoing Commission
(% of annual policy cost including GST)
Before 1 January 2018 or before 1 April 2018 (where the application was received before 1/1/18)
up to 130%
up to 33%
From 1 January 2018
up to 88%
up to 33%
From 1 January 2019 up to 77% up to 33%
From 1 January 2020 up to 66% up to 33%
We may receive commission at pre 1 January 2018 rates if:
• you increase your cover, add new cover or otherwise amend a policy purchased by you before 1 January 2018; and
• that policy amendment results in commission receivable by us, and
• that policy amendment is eligible for pre-1 January 2018 commission rates.
Example (all figures include GST):
You purchase the policy for $1000 on 1 December 2019. We may receive an initial commission of up to $700 ($1000 x 77%) in the first year and ongoing commissions of $330 per annum ($1000 x 33%) for as long as you continue to hold the policy.
If you increase your cover on 1 July 2020 for a cost of $500, we may receive an initial commission of up to $330 ($500 x 66%). The ongoing commissions on the additional cover may be up to $165 ($500 x 33%). This is in addition to the ongoing commissions of $330 per annum when the policy was purchased. Total ongoing commissions payable to us may be up to $495 ($1500 x 33%).
Please note that the initial and ongoing commissions on life insurance products are paid to us by the product provider and are not an additional cost to you.
Privacy Notification
How we manage your personal information
We are grateful for the trust and confidence you have in us to safeguard your privacy. This notification covers us and tells you how we collect your information, what we use it for and who we share it with. It also points out some key features of our Privacy Policy. For a copy of our Privacy Policy, please ask us.
If you would like more information about our Licensee GWM Adviser Services (and other members of the NAB Group), please also refer to the National Australia Bank Privacy Policy available at www.nab.com.au/privacy.
Collecting and using your personal information
We need to collect and use your personal information (which may include your sensitive information, such as health information) for a variety of purposes, including to provide you with the financial services you have requested (including answering your requests and complaints, varying products and services and managing your relevant product portfolios) and to contact you about other products and services that may be relevant to you. It is also necessary for us to collect personal information in order to prevent or investigate any fraud or crime, or any suspected fraud or crime.
We’ll collect your personal information from you directly whenever we can. Sometimes we collect your personal information from other sources or third parties such as your Accountant. We do this only if it’s necessary to do so, for example where:
• we can’t get hold of you and we rely on publicly available information to update your contact details;
• we need information from an insurer about an insurance application you make through us;
• at your request, we exchange information with your legal or financial advisers or other representatives.
You may not be aware that we have done so. If we collect information that can be used to identify you, we will take reasonable steps to notify you of that collection.
We may collect information about you because we are required or authorised by law to collect it. There are laws that affect financial institutions, including company and tax law, which require us to collect personal information. For example, we require personal information to verify your identity under Commonwealth Anti-Money Laundering law.
What happens if you don’t provide your information to us?
If you don’t provide your information to us, we may not be able to:
• provide you with the product or service you want;
• manage or administer your product or service;
• verify your identity or protect against fraud; or
• let you know about other products or services that might better meet your financial and lifestyle needs.
Protecting your privacy
Protecting your privacy is essential to our business. Your file, containing your profile, personal objectives, financial circumstances and our recommendations, is kept securely.
Disclosing your personal information
We may share your personal information (which may include your sensitive information, such as health information where we have your consent) with third parties for any purposes for which we use your information. This may include to the following types of third parties:
• those involved in providing, managing or administering the products or services you have requested, including other advisers, paraplanners and organisations who work with us, including GWM Adviser Services and other members of the NAB Group, depending on the financial services and products you have requested;
• insurance providers, superannuation trustees and product providers related to the financial services you have requested;
• professional associations and organisations that help us operate our business, such as those that provide administrative, financial, accounting, insurance, research, legal, strategic advice, auditing, computer or other business services, including our Licensee GWM Adviser Services and other members of the NAB Group;
• your representatives, service providers, or other organisations, such as your accountant, solicitor, tax agent, stockbroker or bank;
• organisations involved in a business restructure or a transfer of all or part of the assets of our business; and
• government and regulatory authorities and other organisations when required or authorised by law (in some instances these bodies may share it with relevant foreign authorities)
• where you have given your consent.
We run our business in Australia. In order to provide you with our services however, we may share your information with organisations outside Australia (for example information technology service providers). You can view a list of the countries in which those overseas organisations are located in our Privacy Policy.
We may also store your information in cloud or other types of networked or electronic storage. As electronic or networked storage can be accessed from various countries via an internet connection, it is not always practicable to know in which country your information may be held. If your information is stored in this way, disclosures may occur in countries other than those listed.
Overseas organisations may be required to disclose information we share with them under a foreign law. In those instances, we will not be responsible for that disclosure.
Sharing with MLC Limited
NAB distributes MLC Limited’s life insurance products. MLC Limited is no longer part of the NAB Group of companies. NAB may exchange personal information with MLC Limited or their service providers in order to administer and manage your life insurance products that are issued by them. We may also need to share information with MLC Limited so as to ensure:
• your insurance premiums are correctly calculated;
• insurance claims and benefits are paid;
• NAB and MLC Limited can both tell you about our respective marketing and products offers (including ensuring customers who hold MLC Limited products are excluded from NAB Group campaigns marketing MLC Limited products);
Some of the information exchanged will be stored and visible within NAB Group customer databases; with some of these databases being accessible to MLC Limited for a transition period. All information stored in these databases is subject to NAB’s privacy policy as well as NAB Group’s security procedures and controls.
Consent to marketing activity
We presume you consent to being contacted by us (including GWM Adviser Services and other members of the NAB Group) about suitable products and services via the contact details you have provided. We may continue to contact you for these reasons until you withdraw your consent. You can do this at any time by contacting us (see the ‘Contact us’ section of this FSG). We will process your request as soon as practicable.
Gaining access to your personal information
You can gain access to your personal information that we hold about you. This is subject to some exceptions allowed by law. We will give you reasons if we deny access. You can find out how to access your information by reading our Privacy Policy, available by contacting us.
Correcting your Information
You can ask us to correct information we hold about you. You can find out how to correct your information by reading our Privacy Policy or by contacting us.
Complaints
If you have a complaint about a privacy issue, please tell us about it. You can find out how to make a complaint and how we will deal these complaints, by reading our Privacy Policy (by contacting us) or by referring to the ‘Your confidence in our advice’ section of this FSG.
Further information
If you have any questions or comments about our Privacy Policy and procedures, please contact us by using the contact details set out in the ‘Contact us’ section of this FSG.
For more information about your privacy, you can also visit the Office of the Australian Information Commissioner’s website at www.oaic.gov.au