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FINANCIAL SERVICES GUIDE
VERSION 20.1 – 24th FEBRUARY 2021
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:
advice and strategies we recommend and the reasons why;
the financial products and services we recommend and the reasons why;
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 and may influence the advice we provide.
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.
We are authorised representatives of Count Financial Limited ABN 19 001 974 625, Australian Financial Services Licence Number 227232 (‘Count’) of Level 8, 1 Chifley Square, Sydney NSW 2000.
Count is recognised as one of Australia’s leading financial advice networks, an ASX listed company worth over $130M.
Count 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
Count Financial Limited is 85% owned by CountPlus Limited CAN 126 990 832 (CountPlus) and 15% owned by Count Member Firm Pty Ltd ACN 633 983 490.
ABOUT US
Who we are
Michael Milne has been providing advice in Melbourne for over 23 years.
We are representatives of and offer our services on behalf of Count Financial Limited.
Michael Milne
Authorised Representative No. 000242280
Daniel Benigno
Authorised Representative No. 001258221
The Financial Services we offer are provided by
Milne Asset Management Pty Ltd (ABN 74 077 638 236)
Milne Asset Management Pty Ltd Authorised Representative No. 000242397
Count Financial Limited has authorised us to provide you with this Financial Services Guide.
WHAT WE DO
We are authorised by Count Financial Limited 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:
· Deposit & Payment Products
· Government Debentures, Stocks or Bonds
· Life Products
· Investment Life Insurance Products
· Life Risk Insurance Products
· Managed Investment Schemes
· Retirement Savings Account Products
· Securities
· Superannuation
· Margin Lending Facility
We are not authorised to provide any other financial services or financial products on behalf of Count Financial Limited.
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:
83 Sydney Road, Coburg VIC 3058
T (03) 9384 8000
M (61) 0412 332 207
E michael@milnecapital.com.au
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 Count Financial Limited, please also refer to Count Financial Limited Privacy Policy available at https://www.count.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 Count Financial Limited, and others, 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 Count Financial Limited;
– 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.
Consent to marketing activity
We presume you consent to being contacted by us (including Count Financial Limited) 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 (or 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
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: 1300 650 432
Email: reportcomplaints@count.com.au
In writing to:
Advice Dispute Resolution
GPO Box 1453
Sydney NSW 2001
3. If your complaint isn’t resolved within 45 days or to your satisfaction, then you may refer the matter to an External Dispute Resolution Scheme as follows:
A) If lodging before 1 November 2018 contact the Financial Ombudsman Service (FOS). FOS is an independent complaints handling body. FOS provides a free, accessible, fair and independent dispute resolution service to consumers. You can contact FOS on:
Website: www.fos.org.au
Email: info@fos.org.au
Phone: 1800 367 287
In writing to: Financial Ombudsman Service Limited GPO Box 3 Melbourne VIC 3001
OR
B) If lodged on or after 1 November 2018 contact the Australian Financial Complaints Authority (AFCA)*:
Website: www.afca.org.au
Email: info@afca.org.au
Phone: 1800 931 678 (free call)
In writing to: Australian Financial Complaints Authority, GPO Box 3, Melbourne VIC 3001
*The Australian Financial Complaints Authority or ‘AFCA’ is a new external dispute resolution (EDR) scheme to deal with complaints from consumers in the financial system.
AFCA replaces the three existing EDR schemes of the Financial Ombudsman Service (FOS), the Credit and Investments Ombudsman (CIO) and Superannuation Complaints Tribunal (SCT) so that consumers have access to a single EDR scheme.
Count Financial Limited 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 Count Financial Limited at the time of providing the advice, but are no longer authorised representatives of Count Financial Limited 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. Count Financial 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 Count Financial Limited may charge you for the cost of providing this information to you.
Sponsorship
Count Financial 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 do 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
Count Financial Limited has ongoing commission arrangements with a number of risk insurance providers. Where you acquire a risk insurance policy, the insurer may pay Count Financial Limited a commission payment which is based on total in-force premium and lapse rates for risk insurance policies as at 31 December 2017, recommended by all advisers within Count Financial Limited adviser network. Class Super is Count’s preferred third-party service provider of software to assist in the administration of Self- Managed Super Funds. In situations where you purchase this software Count receives 17.5% of the annual software licence fee.
• SUPERCentral is Count’s preferred third-party service provider for preparing trust deeds. In situations where you utilise their services, Count receives between 25% and 46% of revenues that SUPERCentral receives as a result of the referral.
• Count also has a referral arrangement in place with Townsends Business and Corporate Lawyers (Townsends). If you use the services of this provider as a result of a referral from us, Count will receive up to 10% of the invoice payable by you to Townsends and this is not an additional cost to you.
• For Wealth Insurance recommendations we have a referral arrangement in place with Total Financial Solutions Australia Limited ABN 94 003 711 579, AFSL 224954 (TFS). Count will be entitled to 12.5% of the yearly commissions paid by the insurance provider to TFS in the first and subsequent years that you hold the policy. The remaining 87.5% of the yearly commission is split between TFS and the franchise at 62.5% and 25% respectively.
The above payments are not shared with me. These payments do not represent an additional charge to you and I will disclose in your Statement of Advice insurance products for which these arrangements may apply.
REFERRALS
Referrals from a third party
At present we do not have any referral arrangement in place to pay a third-party referrer a referral fee, commission or other benefit. If this change, we will make you aware of this prior to providing advice, or further advice, to you.
Referrals to a third party
At present we do not have any referral arrangement in place to provide referrals to third parties in return for payment or other benefit. If this change, we will make you aware of this prior to providing advice, or further advice, to you.
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
At our expense
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 $22,000.
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.
Borrowed funds – if we recommend you acquire investments using borrowed funds then your implementation fee will be a minimum of $330 and a maximum of $10,000.
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 $330 and a maximum of $10,000 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, an hourly fee of between $165 and $330 may apply.
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 $165 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.
Insurance products
Additional cover added to an existing product which was issued before 1 January 2018
The initial commission we receive on insurance products may be up to 124% of the first year’s premium. The ongoing commission we receive may be up to 33% per annum of the renewal premium.
Additional cover added to an existing product which was issued after 1 January 2018 and before 1 January 2020
Where additional cover is added on or after 1 January 2019 and before 1 January 2020, to an existing product issued after 1 January 2018, the initial commission that Count will receive will be no more than 77% of the increase in premium. The ongoing commission that Count can receive will not exceed
22% p.a. of the premium (33% p.a. of the premium for level commission structures).
Additional cover added to an existing product after 1 January 2020
Where additional cover is added on or after 1 January 2020, to an existing product issued after 1 January 2018, the initial commission that Count will receive will be no more than 66% of the increase in premium. The ongoing commission that Count can receive will not exceed 22% p.a. of the premium (33% p.a. of the premium for level commission structures).
New products issued on or after 1 January 2020
The initial commission that Count may receive on insurance products applied for and issued on or after 1 January 2020 will be no more than 66% of the premium in the year of issue. The ongoing commission that Count can receive will not exceed 22% p.a. of the premium (33% p.a. of the premium for level commission structures).
Pre-existing arrangements
For existing clients already in an established commission arrangement, we may receive commission on investment products or margin lending products held. For investment 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.