Our Financial Services Guide (FSG) Version 12
Dated 4th July 2018
Financial Services Guide
This Financial Services Guide (FSG) is designed to clarify who we are and what we do, and help you decide whether to use our services.
To make things simple, this guide explains:
the services and types of products we’re able to offer you
how we and our associates are paid and any other benefits we may receive
any potential conflicts of interest we may have
how we protect your privacy and handle your personal information
how we resolve disputes, and what you should do if you have one.
Please read through the whole FSG, as it’s full of useful information – and is also worth holding on to for future reference. And of course, if you ever have any questions, please contact us.
Other documents you may receive
In addition to this FSG, when we provide you financial advice we will also present you with a written Statement of Advice (SOA).
This will describe the strategies, products and services we recommend and outline any fees or commissions we will receive and any associations we have with financial product providers or other parties that have not already been disclosed in this FSG.
If you receive further financial advice from us, we will present you with either another SOA or keep our own written Record of Advice (ROA). You can request a copy of this by contacting us any time up to seven years from the date of the advice provided. Please refer to the “Contact us” section of this FSG for our contact details.
To help you make an informed decision about a financial product you generally will be given a Product Disclosure Statement (PDS) which outlines the product features and costs in detail. In certain circumstances it is not a requirement that you be given a PDS (including, for example, where you already have one).
Giving us instructions
If you want to make changes to your financial plan or provide other instructions, please contact us. Please refer to the “Contact us” section of this FSG for our contact details.
Generally, you will need to give us instructions in writing (eg fax, email or letter) or another method agreed with us.
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 over 400 experienced financial planners across Australia managing over $15 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”). GWM Adviser Services is a wholly owned subsidiary within the NAB Group. 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.
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:
JANA / JCIS
Pre Select Funds
Altrinsic Global Advisers
Redpoint Investment Management
Private Investment Consulting
Fairview Equity Partners
Intermede Investment Partners
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. In some categories these may be all 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.
GWM Adviser Services maintains a relationship with the following insurance providers (AIA, Zurich, Colonial First State and One Path) which pay GWM Adviser Services a licensee commission payment as described in the ‘Commissions received by our Licensee from product providers’ section of this FSG.
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 recommend a risk insurance policy issued by one of these insurers, or an insurance policy issued by MLC Limited.
About us - Who we are
Warringal Financial Services commenced in 1994 by the amalgamation of two (2) smaller financial planning practices’ that were established originally in 1978, and have now grown to a large and successful wealth management advisory firm with 9 staff supporting clients’ needs.
We provide a complete service that can be tailored to cater to your specific requirements and are supported in this by the vast resources of MLC Financial Planning, giving us access to a wide network of technical and financial specialists including respected industry experts, accountants, and solicitors.
At Warringal Financial Services we ask thought provoking questions, taking the time to listen closely to your answers, so that we can clearly understand what is really important to you.
The Financial Services we offer are provided by NICA Group Pty Ltd ACN 145 861 132, ATF The Englezos Trust
ABN 40 439 274 113 trading as Warringal Financial Services, Authorised Representative (AR) No. 404917
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:
Chris Yena - CFP®
Authorised Representative No 404918
Catherine Corr – FChFP®
Authorised Representative No 329890
Jeremy Morrison – CFP®
Authorised Representative No 419978
Rebecca Poynton - BCom Grad Dip (FP)
Authorised Representative No 1265663
Quality Advice Program
Catherine Corr has been Quality Advice accredited by GWM Adviser Services Limited under their internal Quality Advice Program. The Program involves a defined set of standards for measuring quality of advice.
In order to receive Quality Advice Accreditation, we were required to meet a number of essential criteria in relation to financial planning principles and have a number of our financial plans assessed against the Quality Advice standards.
What we do
We are authorised by GWM Adviser Services to provide financial advice in relation to:
Income & Asset Protection
Retirement & Redundancy Planning
Managed Discretionary Accounts
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
Retirement Savings Accounts
Managed Investment Schemes, including Investor Directed Portfolio Services (IDPS)
Government Debentures, Stocks or Bonds
Standard Margin Lending Facilities
Managed Discretionary Account Services
GWM Adviser Services Limited offers a Managed Discretionary Account Services through an agreement with clients called a Managed Discretionary Account (MDA) Contract.
By accepting the terms of a MDA Contract you will be granting your adviser an authority to take action on your investment portfolio (eg, buy or sell investments) without first consulting you.
This will change the nature of the adviser-client relationship.
Normally, your adviser provides you with advice and recommendations supported by research or other information to assist you make an informed decision on those recommendations. Your adviser then implements whatever action you decide to take.
If you accept the terms of an MDA Contract, you will, to some degree depending on the limitations/restrictions detailed in the MDA Contract, provide your adviser with the authority to make decisions on your investment portfolio and to implement investment transactions without consulting you.
The decision to surrender full or partial control of your investment portfolio to your adviser is an important decision.
You should not accept the terms of a MDA Contract provided by your adviser unless you are confident that he/she has a clear understanding of your circumstances, needs and objectives.
The significant risks of accepting the terms of a MDA Contract provided by your adviser are:
Your adviser may make investment decisions that you disagree with. Provided your adviser’s actions are within the law and the scope of the authority you have granted and the adviser has acted efficiently, honestly and fairly, you will have no right of recourse.
This means that you will have to accept the tax consequences, transaction costs and any capital loss resulting from any transaction validly executed by your adviser and any “reversal” of that transaction that you may request.
If you do not promptly inform your adviser of any changes in your situation, needs and objectives, there is a risk that your adviser may make inappropriate investment decisions.
You may only accept the terms of a MDA Contact where your investment portfolio is held via a regulated platform such as an investor directed portfolio service (IDPS), IDPS-like scheme, superannuation wrap or master trust.
You must accept the terms of the MDA Contract provided by your adviser before he/she can provide you with MDA services. As part of your MDA Contract you will be provided with an Investment Program that complies with Division 3 of Part 7.7 of the Corporations Act and that will contain:
Statements about the nature and scope of the discretions your adviser will be authorised and required to exercise under the MDA Contract and any investment strategy that is to be applied in exercising those discretions;
Information about any significant risks associated with the MDA Contract;
The basis upon which your adviser considers the MDA Contract to be suitable for you; and
Warnings that the MDA Contract:
May not be suitable to you if you have provided limited or inaccurate information relating to your relevant personal circumstances;
May cease to be suitable if your relevant personal circumstances change.
Note that your adviser will exercise, on your behalf, all rights that relate to your portfolio arising from corporate actions and communications about your portfolio assets.
The suitability of the Investment Program that forms part of your MDA Contract to your relevant personal circumstances will be reviewed by your adviser at least once every thirteen (13) months unless terminated earlier by you.
This FSG complies with the relevant requirements of ASIC Class Order 04/194 ‘Managed discretionary accounts’.
Warringal Financial Services 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.
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 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);
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
Correcting your Information
For more information about your privacy, you can also visit the Office of the Australian Information Commissioner’s website atwww.oaic.gov.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.
Please let your financial adviser know so we can act on it immediately.
If your adviser has not satisfactorily resolved your complaint, please contact our Advice Dispute Resolution Team on:
If your complaint isn’t resolved within 45 days or to your satisfaction, then you may refer the matter to the Financial Ombudsman Service (FOS), an independent complaints handling body. We are a member of FOS. FOS provides a free, accessible, fair and independent dispute resolution service to consumers. You can contact FOS on:
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.
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.
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.
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 your financial adviser does not directly share in the sponsorship payment; however, they may indirectly benefit as these payments subsidise the costs associated with these training and professional development events.
Commissions received by our Licensee from product providers
GWM Adviser Services has ongoing commission arrangements with a number of risk insurance providers. Where you acquire a risk insurance policy issued by AIA, Zurich, Colonial First State and One Path the insurer may pay GWM Adviser Services a commission payment which based on total in-force premium and lapse rates for risk insurance policies recommended by all advisers within GWM Adviser Services adviser network. The payments received by GWM Adviser Services may be up to 2% of the premium amounts paid by policy holders to the relevant insurer. As this amount is calculated in the future, we cannot provide an exact amount at this time; however, as an example, if as a result of services provided to you by GWM Adviser Services, a participating insurance provider receives $5,000 in premium, then GWM Adviser Services will receive up to $100 as a commission (2% of the premiums held).
The above payments are not shared with your adviser. These payments do not represent an additional charge to you and your adviser will disclose in your Statement of Advice insurance products for which these arrangements may apply.
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 your adviserand does not represent an additional charge to you.
If you have been referred to us or we refer you to someone else, we may have arrangements in place to or receive a referral fee, commission, or other benefit.
Details of any arrangement will be provided in our advice to you.
Corporate Superannuation Fund - Trustee Arrangements
Where we assist you in relation to a corporate superannuation fund we may receive a payment from the fund Trustee or Administrator, for services we provide to the employer sponsor and/or members within participating corporate super funds. The payment is based on the number of members within the relevant corporate plan.
Where these arrangements are in place, there are some restrictions on the type of advice we can provide you and in some cases we may be unable to provide you advice as to whether to join or consolidate your super into the fund. Where we can provide you with advice we will provide further information about the limitations and any potential Trustee payments in our Statement of Advice.
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.
At our expense
Included in the advice preparation fee
From $3,500 - $10,000
Costing depends on complexity of work and timeframe for completion
Implementation (fee for advice)
We do not charge an implementation fee
Ongoing fee for advice
For the ongoing review of your financial planning strategy, the ongoing service fee is based on the complexity of ongoing advice and the services provided. The minimum fee is $3,500 per annum to a maximum of $20,000 per annum.
The ongoing service fee may be collected monthly through the product issuer or paid directly by you via credit card, direct debit or cheque.
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.
The relevant insurer will pay initial commission between 0% and 130% and ongoing commission between 0% and 33% of the annual premium for as long as you hold the product.
Commissions are paid to us by the product provider and are not an additional cost to you.
For existing clients already in an established commission arrangement, we may receive commission on investment products or margin lending products held. For investment products he 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.