Financial Services Guide
Financial Services Guide
Preparation date: 1 July 2021
FSG prepared by SuperEd Pty Ltd ABN 88 118 480 907 AFSL 468859
Purpose of Financial Services Guide
We are legally required to disclose the circumstances in which we do not meet the
Corporations Act 2001 (Cth) definition of “independence”. We operate a Managed Discretionary Account (MDA) service and our advice is limited to recommending our own MDA and Exchange Traded Funds, therefore our advice is not independent, impartial or unbiased.
What documents will I receive?
When we give you general advice, we will give you a general advice warning, but do not provide you any formal documentation other than this FSG.
Where we provide you personal advice services, we will provide you the following documentation from our website and/or via email
Statements of Advice (‘SoA’)
If we provide you with advice about your personal circumstances, we will confirm it in SoA. The SoA sets out our personal advice to you, including the scope of our advice you agreed to, the basis on which the advice is provided, your current personal and financial position, needs and objectives, the benefits of our advice and the risks associated with implementing our advice, and information on fees, remuneration and associations relevant to the provision of your of advice.
Should we believe our MDA service is suitable for you and this is a service you request, we will provide an MDA Contract which includes a Statement of Advice (SOA) and Investment Program that complies with Division 3 of Part 7.7 and Division 2 of Part 7.7A of the Corporations Act. This document is discussed further in the MDA Schedule.
Where a further review is conducted, or ad-hoc advice is requested from you
and personal advice is provided, the advice may be provided via a new SoA or a
Record of Advice (RoA) as applicable to the circumstances. Further advice may
be in the form of a RoA where the further advice does not significantly differ from
the original advice provided. You may request that we provide you with a copy of such an RoA by contacting us at/on [include contact details].
Product Disclosure Statements (‘PDS’)
If we recommend that you acquire a financial product, we will also provide you with a PDS or a hyperlink to the relevant PDS/s. The PDS will provide you with detailed information about the product we have recommended you acquire, including features, benefits, fees and associated risks, and contains important information you should read and understand in order to help you decide whether or not to buy that product.
SuperEd Pty Ltd (also trading as Clover.com.au) is primarily focused on providing services to assist superannuation (‘super’) fund members, pre-retirees and retirees plan for their retirement and assist them in achieving financial wellbeing in retirement.
We also provide digital wealth creation advice via our online MDA service to grow investments and reach savings goals. We do this through the provision of affordable online advice solutions encompassing forecasting, education and coaching, planning, general and personal advice and personal investment management. Should you request to use our MDA service you will be provided, at that time, our MDA Schedule to be read with this FSG providing further details regarding our MDA service.
SuperEd holds an Australian Financial Services Licence (‘AFSL’) which authorises us to provide both general and personal financial advice in relation to:, superannuation, interests in managed investment schemes, including: (A) investor directed portfolio services (IDPSs); (v) interests in managed investment schemes limited to: (B) MDA services; deposit and payment products, securities, government debentures, stocks or bonds, annuities and life risk and investment insurance products.
SuperEd is also authorised to deal in, by issuing interests in managed investment schemes limited to MDA services and deal in by applying for, acquiring, varying or disposing of a financial product on behalf of another person in respect of superannuation, interests in managed investment schemes, including IDPSs, deposit and payment products, securities, government debentures, stocks or bonds. SuperEd is also authorised to operate custodial or depository services other than IDPSs although we don’t maintain custody of your assets.
We are also registered with the Tax Practitioners Board (TPB) to provide tax (financial) advice services to clients according to the Tax Agent Services Act 2009 (TASA).
SuperEd is responsible for the general and personal advisory services provided to you as well as authorising the content and distribution of this FSG.
Our details and contacts
Company: SuperEd Pty Ltd (SuperEd) ABN 88 118 480 907 AFSL 468859
Head Office: Level 8,100 Walker Street, North Sydney, NSW, 2060
Postal: PO Box 527, North Sydney, NSW, 2059
Phone: (02) 8282 2982
How do we provide our services?
Our services are commonly provided through our website via online digital services. Access to all required documents will be via your online account and/or email and/or hyperlinks. When accessing our personal advice services you will be required to create an account (where you have not previously done so) or log into your existing account and provide your free and informed consent electronically.
About our services
SuperEd (also trading as Clover.com.au) may provide you information that is purely factual and is not tailored to your individual circumstances. This is generally provided to you in information articles on the website or via email.
SuperEd (also trading as Clover.com.au) may also provide general advice, which may give you only general information about a specific financial product or service or is tailored to a specific group of people, such as retirees. General advice can be useful as it can help you learn more about these products or services and assist you in personally assessing whether a product, service or retirement option may be right for you.
However, general advice should not be a substitute for seeking and or receiving personal advice from a licensed financial adviser or licensed personal advice technology platform who can provide personal advice tailored to you and in your best interests. General advice does not take into account your specific financial needs, circumstances or objectives. Therefore, it is important that you personally assess whether any action you take as a result of general advice is appropriate given your own financial situation and where applicable you read and understand any relevant Product Disclosure Statement (‘PDS’) before any decision regarding a financial product.
General advice can be provided to you in information articles on the website or via email and/or webinars, in our preliminary discussions, ideas, thoughts or projections, before you elect to receive personal advice and neither you or anyone else should act on these.
Personal advice is provided when we consider one or more of your personal circumstances and specifically offer to provide personal advice tailored to your circumstances about a product or service in a ‘SoA’ or ‘RoA’. Personal advice may be limited to a particular issue that you have or may encompass a number of issues. The type of advice provided, along with any limitations will be agreed and confirmed up front with you.
What limitations are there on the information, general and personal advice we provide?
Our advice and services are tailored and there may be a number of other areas you may require advice on which may be outside of the services we offer. We will make the scope of any advice or information we provide you very clear as well as highlighting any implications. We are unable to assist you or advise on the following specialist areas:
- general insurance
- derivatives or foreign exchange
- real estate and direct property advice
- taxation services, such as completion of tax returns
- accounting and audit services
- estate planning professionals such as a solicitor
- legal services
- administration and compliance of Self-Managed Superannuation Funds and
- credit product advice such as mortgage or finance broking
Any products we recommend are limited to the products we have researched.
How can you connect with us and provide us with instructions?
You can connect with us via our details on page 2 of this FSG.
We generally require that you instruct us in writing and to arrange financial products and services on your behalf we rely on your signature or written word consent as your authority.
It is important that you provide us with complete and accurate information about your circumstances and you take the time to check and understand the basis of our advice, such as any key assumptions we have used in formulating your advice before accepting it. If you don’t, there is a risk our advice may not be appropriate for your needs.
How are we paid?
Some financial institutions, such as super funds, pay SuperEd service fees to provide education and advice services to their members or clients. SuperEd may be paid a flat fee by these institutions for making the online information and advice solutions available to their members. Alternatively SuperEd may be paid directly by members or the institution based on the services utilised by their members.
General Advice Services
We charge simple, transparent fixed fees. We do not charge you based on a percentage of your assets. The cost of the service will be quoted prior to the service based on a flat dollar cost.
Personal Advice Services
Depending on the services you require, the costs of our services will either be quoted based on a flat dollar cost, a percentage based fee or a combination of both.
Both our flat dollar fees and asset based percentage fees will be GST inclusive and are determined based on the time and complexity involved in providing your personal service or advice.
For example a flat dollar fee might be $110, while an asset based fee will be determined based on a percentage of the funds invested. On an investment of $10,000 a fee of $110 (inclusive of GST) would equate to 1.1% of the investment amount..
Where an upfront fee is payable directly by you as a super fund member or client, this will be fully disclosed along with the basis for the amount before you agree to use any of our services.
When you are provided with personal advice on specific financial products, we will also disclose certain details of remuneration or other benefits received by SuperEd or another associated person as a result of that advice in your personal SoA.
SuperEd (also trading as Clover.com.au), is primarily focused on providing scaled investment only, digital advice via our online MDA service to grow investments and reach savings goals. Clover.com.au is authorised to provide both general and personal financial advice to retail and wholesale clients.
Retirement Essentials Pty Ltd (“Retirement Essentials”), a fully owned subsidiary of SuperEd, pays SuperEd license and service fees for its AFSL, technology, contract and employee services required for the provision of Retirement Essentials services to you. Retirement Essentials provides factual information, education, general and personal advice through their own online platform aimed at helping superannuation (‘super’) fund members, pre -retirees and retirees plan for their retirement and achieve financial wellbeing in retirement.
SuperEd may benefit through this association, via increased business growth and profits, however will only ever refer you to use the services of Retirement Essentials where you are likely to benefit from their specialist services.
AIA Australia pays SuperEd a license fee for the use of SuperEd’s technology platform.
For details of the specific fees related to our MDA service, please see the MDA Schedule to this FSG.
Who do we pay?
All fees you pay are paid directly to SuperEd Pty Ltd.
Representatives, employees and directors of SuperEd may be remunerated by a combination of salary, equity and incentives based on quality of advice and services indicators and business growth of SuperEd. We also do not receive commission or other benefits in connection with the advice we provide you.
If you were referred to us, we do not pay a referral fee to the organisation who referred you to us. Members who join us via financial institutions with whom we have alliance partnerships or referral arrangements with may be eligible for discounted fees on our advice and services.
Relationships, associations and other benefits we may receive
Some employees may own equity (or options in respect of equity) in the company, and thereby may stand to benefit from the profitability, or an improvement in the valuation, of the company.
SuperEd or its representatives are unlikely to receive any benefits, however will disclose any additional benefits received from product providers. These benefits may include education, training, meals and events provided at the cost of the product providers. These are not of a material nature and do not influence our advice to you. Any Payments or benefits received where the value of the benefit exceeds $100 will be disclosed in a register. A copy of the register is available to you upon request.
Retirement Essentials may directly offer their clients personal advice in selected areas where their clients may benefit from personalised advice SuperEd may refer you to Retirement Essentials where you are likely to benefit from their specialist services and through this association may benefit via increased business growth and profit.
SuperEd’s approved list of products and services includes products and services provided by entities with whom a SuperEd director, employee, have a relationship or association, either directly or via a related entity.
We believe that your interests should be placed first and that products and services
should only be recommended if it is in your best interests. However, it is important
that you know of, and are comfortable with, those relationships and associations and
any benefits that arise.
CPHIC Investments Pty Ltd, which is part of Challenger Limited, has a minority economic interest in SuperEd Pty Ltd. This relationship does not involve the use by SuperEd of any products or investments owned, operated or managed by Challenger Limited. The relationship SuperEd has with Challenger Limited does not conflict with the provision of financial services to you. SuperEd does not receive any financial incentive to provide advice that directs a client towards Challenger Limited.
PSC Insurance Group Ltd (PSC), a diversified insurance services group, has a minority economic interest in SuperEd Pty Ltd (SuperEd). This relationship does not involve the use by SuperEd of any products or investments owned, operated, recommended or managed by PSC.The commercial relationship SuperEd has with PSC does not conflict with the provision of financial services to you. SuperEd does not receive any financial incentive to provide advice that directs a client towards PSC.
Current SuperEd directors are or have participated on boards of directors/trustees at Unisuper, Vanguard, MLC Wealth, among others. SuperEd directors are not remunerated by any of these firms due to their roles at SuperEd.
SuperEd does not have any other associations or relationships, than those already disclosed, that might reasonably be expected to be capable of influencing the advice we provide to you and our clients.
Our professional indemnity insurance
SuperEd maintains a group policy which includes appropriate Professional Indemnity Insurance cover for SuperEd and its representatives as required by section 912B of the Corporations Act 2001. This cover is designed to offer some insured protection should any work carried out result in a claim against SuperEd or one of its representatives for work carried out by past and or present representatives.
What to do if you have a complaint
If you are not satisfied with the response you receive or your complaint cannot be resolved within the 45 business days, you have the right to contact the Australian Financial Complaints Authority (‘AFCA’). AFCA is an ASIC approved external dispute resolution body and provides fair and independent financial services complaint resolution that is free to consumers.
Australian Financial Complaints Authority
GPO Box 3, Melbourne VIC 3001
Telephone: 1800 931 678 (free call)
You may also contact the Australian Securities and Investments Commission (ASIC) by phoning +61 3 5177 3988 or 1300 300 630 to make a complaint and obtain information about your rights.
What personal information do we collect and disclose?
The privacy of your personal information is of the utmost importance to us, and the protection of your personal information is a vital part of our relationship. We request and collect personal information, including sensitive information (e.g. health information), from you to provide you with our services including personal financial advice and helping us run our business. We may need to use your information to comply with legislative or regulatory requirements in any jurisdiction for the purposes of preventing fraud, crime or other activity that may cause harm.
To ensure that any personal financial advice we provide is appropriate, we ask you to provide accurate information, free from error and omission. If you do not provide all the information we request, we may no longer be able to provide a product or service, including financial advice, to you.
We do not trade, rent or sell your information or disclose it to overseas recipients.
How do we protect your privacy?
We and our technology service providers ensure that any cloud hosted data services we use to maintain our members’ data are housed within Australian based data centres.
Where you have provided us information about another individual, you must make them aware of that fact and the contents of our privacy statement.
We may also use your information to tell you about products or services we think may interest you.