Financial Services Guide
Why you are receiving this document
This Financial Services Guide (FSG) is an important document which provides you with information to help you decide whether to use our financial services.
It has been authorised for distribution by Barbacane Advisors Pty Ltd trading as Walbrook Wealth Management (‘Walbrook’, ‘we’, ‘us’ or ‘our’), the holder of Australian Financial Services Licence number 512465 (AFSL).
Walbrook is responsible for the financial services provided to you and is required to provide you with this FSG when we provide financial services to you as a retail client.
This FSG provides you with the following important information:
- Who we are and how you can contact us
- The financial services we may provide to you
- Important documents you may receive from us
- How we provide you with personal financial product advice and how to instruct us
- The cost of our advice and services and how we are remunerated
- Any conflicts of interest, associations or relationships that may affect our advice
- How we protect your personal information
- How you can make a complaint and our compensation arrangements
Not Independent |
|---|
Walbrook may receive regulated commissions from life insurance product issuers where financial services are provided in relation to these products. |
About Walbrook
Walbrook is the holder of AFSL 512465 and is authorised to provide you with financial advice and dealing services in relation to the following financial products:
- Deposit and payment products
- Securities
- Government debentures, stocks or bonds
- Derivatives
- Foreign Exchange
- Interests in Managed Investment Schemes
- Managed Discretionary Account services
- Standard Margin Lending facilities
- Investment Life Insurance Products
- Life Risk Insurance Products
- Superannuation
- Retirement Savings Accounts
Please note that we are registered with the Tax Practitioners Board to provide a tax (financial) advice service. This service involves the provision of advice around how tax legislation (including superannuation) interacts with the financial advice and services provided to you.
How you can contact us
Our office contact details are set out below.
Physical Address |
Postal Address |
|---|---|
| Level 2, Rialto Podium East | GPO Box 1717 |
| 525 Collins Street | Melbourne VIC 3001 |
| Melbourne VIC 3000 |
Email |
Telephone |
|---|---|
| info@walbrook.com.au | +61 3 9013 6262 |
Personal financial product advice
We are authorised to provide both general and personal financial product advice. Personal financial product advice is advice that considers your objectives, financial situation and needs. We must act in your best interests when providing you with personal financial product advice. Within the subject matter of the advice we provide to you, we must ensure that:
- the scope of the advice includes all the issues for the advice to meet your objectives, financial situation and needs (including your risk tolerance and risk ability);
- where the scope of the advice changes, the change is consistent with your objectives, financial situation and needs; and
- we consider whether to provide advice that recommends a specific product, whether you should dispose of a product or whether you should do nothing.
To provide you with this advice, we will make reasonable enquiries about your current financial situation, objectives and needs. We ask that you:
- provide us with complete, current and accurate details of your personal objectives, financial situation and needs; and
- inform of us of any changes in your situation.
Delivery of advice
By law, you are entitled to receive a Statement of Advice on the first occasion that we provide you with personal advice. The Statement of Advice will contain:
- the specific advice;
- the basis of the specific advice;
- information about fees and commissions;
- any associations or relationships we have that may influence the advice we provide to you;
- any other relevant matters.
If we provide further personal advice to you after we have issued an initial Statement of Advice, and your circumstances have not significantly changed, we may provide you with a Record of Advice. We will retain copies of each Statement of Advice and Record of Advice on your file for at least seven (7) years. You may request a copy of either document within that period by contacting your financial adviser.
We are not required to provide you with a Statement of Advice or a Record of Advice where the advice relates to certain basic deposit products or other approved financial products and meets certain thresholds.
As our ongoing advice will refer to previous documentation, you should keep all Statements of Advice provided to you.
General financial product advice
At times, we may provide you with general financial product advice. Where we provide you with general advice or an execution only service, we will also provide you with a general advice warning. You should note that general advice does not relate specifically to you and does not take into consideration your objectives, financial situation and needs. Whilst Walbrook believes the general advice provided is accurate and reliable, neither Walbrook nor its directors or employees assume any responsibility for the accuracy or completeness of the information provided.
Product Disclosure Statements
Where a recommendation has been made to acquire a financial product, we will provide you with a Product Disclosure Statement. The product provider issues the Product Disclosure Statement, which contains information about the features, costs, risks and benefits. It will help you to make an informed decision about whether or not to invest in the financial product.
It is essential that you read and understand this document before implementing any recommendation made in the Statement of Advice or Record of Advice. We will readily explain any part of this document that you do not understand.
Your adviser will also provide other documents as needed. These documents may include educational material, client agreements or other offer documents.
Electronic Disclosure
We may provide disclosure documents, including this FSG and the documents outlined above, by making them available digitally, e.g. by email attachment or as a hyperlink in a document or email. You can contact us to opt-out of this method of disclosure at any time.
How you may instruct us
You may give us instructions verbally or in writing, such as by email or letter. In limited circumstances and where required by third parties, we may require your instructions in writing. Where you do not wish to receive our advice or reject the advice we have provided, we may still act on your instructions to deal in financial products. However:
- you must acknowledge and accept the risk that the financial product you select may not be suitable or appropriate for you, and
- we may require you to sign a document that records your intention to proceed without or against advice in relation to the financial products.
How you pay for the financial services we provide to you
If you receive personal advice from us, we will tell you about any fees, commissions and any other benefits, in actual dollar amounts (where possible) in the Statement of Advice or orally when providing further advice to you.
There are several ways that Walbrook may be paid for the services we provide to you, including:
- Fixed Fees, where you pay a fixed dollar or percentage-based fee for the services that we agree to provide;
- Asset-Based Fees, where you pay a percentage-based fee for the investment services that we agree to provide;
- Commission, which is paid by product and service providers to Walbrook, in the form of initial (up-front) and/or ongoing (trail) commission; or
- A combination of Fixed Fee, Asset-Based Fee and Commission.
Under the Fixed Fee option, fees are calculated based on the level of service needed and the complexity of the advice required. All fees and commissions are inclusive of GST.
|
Initial Consultation |
Free of charge |
|
Advice Preparation |
Following the initial consultation, we will agree a fee for the preparation of your initial Statement of Advice. The fees will depend on the complexity of your personal circumstances and the advice required to meet your objectives.
For example, complex advice that contains multiple goals, strategies and/or tax structures such as Self Managed Superannuation Funds, Family Trusts and Companies are likely to be charged closer to the maximum fee. The agreed fee may be reduced or offset by any commissions payable on recommended products, and this will be agreed with you before the engagement commences. Please note, we do not charge implementation fees under the Fixed Term Investment Advice Engagement or the Fixed Term Strategic Advice Engagement. |
|
Advice Implementation |
On completion of the Statement of Advice, we will calculate an implementation fee. This fee will be calculated on a time basis. If you request our assistance to implement the recommendations made, we will charge the implementation fee. We will disclose this fee and the implementation services it covers in the Statement of Advice. There is no minimum implementation fee. Advice implementation incorporates:
Please note, we do not charge implementation fees under the Fixed Term Investment Advice Engagement or the Fixed Term Strategic Advice Engagement. |
|
Fixed Term Investment Advice Engagement |
You may elect to enter into a 12 month Fixed Term Engagement to receive regular investment advice and administration services. The monthly fee is set at the commencement of the engagement, is based on the amount invested and the complexity of the advice and service required, and is invoiced monthly in advance. The minimum fee is AUD 100 per month, including GST. The maximum fee is 1.00% pa, including GST, on the assets under advice at the commencement of the engagement. |
|
Fixed Term Strategic Advice Engagement |
You may elect to enter into a 12 month Fixed Term Strategic Advice Engagement to receive comprehensive advice and administration services, including investment advice. The fee is set at the commencement of the engagement, is based on the complexity of the advice and required services, and invoiced monthly in advance. The minimum fee is AUD 275 per month (AUD 3,300 pa), including GST, and the maximum fee is AUD 1,250 per month (AUD 15,000 pa), including GST. |
|
Ad hoc advice |
Where you do not wish to participate in a 12 month Fixed Term Engagement, but require further advice on an ad hoc basis, an hourly fee of AUD 330 including GST may be applicable. |
|
Execution only |
Where we are asked to process transactions on an execution-only basis, we may charge a fee of between AUD 50 and up to 1.00% of the transaction value. This fee does not include third-party costs. |
|
Administration Services |
Where we are required to provide administration services on an execution-only basis, we will charge a fee of 0.25% pa of the account value. This fee does not include third-party costs. |
|
Insurance products |
Walbrook may receive payments of initial commissions and ongoing commissions from the life insurance providers for any product that we have recommended and you elect to use. You do not make these payments to us, however, the life insurance provider incorporates these distribution costs in the premiums you pay. Initial commission from a life insurance provider is typically up to 66% (inclusive of GST) of the first year’s premium that you pay. For example, if you pay AUD 500 in premium for a life insurance product we have recommended to you and the applicable commission is 66%, then Walbrook will receive an initial commission of AUD 330 (i.e. AUD 500 x 66%). Ongoing commission can be up to 33% (inclusive of GST) of the premium you pay, from year two onwards for the life of the policy. If your premium is AUD 500 per annum and the applicable commission rate is 33%, Walbrook will receive an ongoing commission of AUD 165 per annum. Your Statement of Advice will disclose the actual commission that Walbrook and your Adviser will receive. In accordance with APES 230: Financial Planning, we must write to you each year to disclose the commissions that we expect to receive. |
|
Credit Products |
If authorised by an Australian Credit Licence holder as a Corporate Credit Representative, Walbrook may receive payments of initial commission and ongoing commission from lenders for any credit product that we have recommended and you have successfully applied for. You do not make these payments to us, however, the lender typically incorporates these distribution costs in their quoted interest rates and product fees. Further information may be found in the Credit Guide, which we will provide to you if it is likely that credit assistance will be provided. |
If you receive ongoing services from us over a period of more than 12 months, then we are also required to provide you with an annual Fee Disclosure Statement which will set out the fees paid, and the services offered and provided in the previous 12 months.
You can settle your fees by deduction from your investment portfolio or via bank transfer. In certain circumstances, you may be able to have charges deducted from your superannuation balance.
Fees you pay for using other financial services or products
The total initial and ongoing costs of using our service will depend on the fees charged by third-party issuers of the financial products and services we recommend.
These fees will be outlined in the Statements of Advice and Records of Advice that we prepare, to provide you with a clear understanding of the total initial and ongoing costs of the recommended actions. The Product Disclosure Statements that we will provide, issued by the relevant third parties, will also give more detail.
Conflicts of interest, associations or relationships that may affect our advice
As a wealth manager that is not owned by a bank or product manufacturer, we do not manufacture or distribute our own financial products. Any assistance we provide is concerning financial products from third parties. We have an obligation to act in your best interests, to avoid conflicts and prioritise your interests.
Approved Product List
Our investment Approved Product List (APL) is based on research conducted by the third-party provider Lonsec. As Lonsec receives payments from financial product providers to be rated, this has the effect of limiting our investable universe to products whose issuers have paid Lonsec a fee. Our advice process provides clear guidelines for your adviser to recommend a product or security that is not on the APL, to avoid situations where the APL is unduly restrictive.
Adviser remuneration
Your financial adviser, Damien Crommie, receives a base salary and has an indirect beneficial interest in Walbrook. This means that he may receive a share of any profits distributed by Walbrook after licensing, legal, compliance, paraplanning, technology and administrative costs.
Non-monetary benefits
We may receive non-monetary benefits from product providers. Walbrook representatives may only accept non-monetary benefits that are valued at less than AUD 300 and we are required to keep records of non-monetary benefits valued between AUD 100 – AUD 300. Records of non-monetary benefits received by our representatives are kept in our Alternative Forms of Remuneration Register. If you would like a copy of the Register, please contact us.
Referral Arrangements
If you have been referred to us and we decide to pay a referral fee, the details will be disclosed in your Statement of Advice and paid as agreed with you and permitted by law.
We may refer you to third parties where you are interested in receiving their services or using their products, or where we consider that their advice or other services may be useful to you. Walbrook may receive a referral fee where you decide to receive services from third party providers. This will be disclosed in writing and received as agreed with you and permitted by law.
Employee Trading
We and our representatives may invest in similar or the same investments as those recommended to you. Walbrook implements a Staff Trading Policy to mitigate risks and conflicts which may arise from trading activity in such investments. If you would like to discuss this with us or obtain further information about our policy, feel free to contact us.
How we protect your personal information
Protecting your privacy is important to us and central to our commitment to meeting the highest level of professional standards. We will handle your personal information per our Privacy Policy, which outlines how the information we collect from you is used, stored and disclosed.
We will collect your personal information from the conversations you have and forms you complete with our representatives. As a financial service provider, we are obligated to verify your identity and the source of any funds, pursuant to the Anti-Money Laundering and Counter-Terrorism Financing Act (AML/CTF Act) and its corresponding rules and regulations.
Accordingly, we will request identification documents, such as your passport or drivers’ licence, and may hold certified copies of these documents on file.
With your consent, we may also share your full name, date of birth, residential address and contact details with an identity agent to help us verify your identity against government and non-government electronic data sources. Electronic verification allows us to verify your identity by using electronic tools and external data sources.
The main reason we collect, use and disclose your personal information, is to provide you with the products and services that you request. This reason may also include the following related purposes:
- to help us provide you with financial advice and ongoing financial services;
- to facilitate internal administration, accounting, research, risk management, compliance and evaluation of products and services;
- to establish and maintain insurance protection that you may request; and
- to provide you with information about other products and services that may be suitable for you.
We may be required to obtain information about you at the time of providing financial services to you and from time to time in order to meet our legal obligations. We have certain reporting obligations pursuant to the AML/CTF Act, and information obtained from or about you may be provided to external third parties and regulators in accordance with the requirements imposed on us.
We may also disclose your information to external parties, some of whom act on your or our behalf. These parties may include:
- External compliance consultants
- Banks or other financial institutions
- Insurers and reinsurers and their claims agents and assessors
- Product providers; and
- Mail houses.
We are also permitted to collect and disclose your personal information when required or authorised to do so by law. To obtain a copy of our Privacy Policy, please contact us or visit www.walbrook.com.au.
If you have concerns about the accuracy and completeness of the information we hold, you may request access to your data by contacting the Privacy Officer on +61 3 9013 6262.
How you can make a complaint
If you would like to make a complaint, please contact us in the first instance using the details below:
Postal Address |
Email |
|
|---|---|---|
| GPO Box 1717 | info@walbrook.com.au | |
| Melbourne VIC 3001 |
Telephone |
|---|
| +61 3 9013 6262 |
When your complaint is received, we will enter the details in our complaints register and investigate the circumstances. Within 30 days we must provide you with a written response to your complaint.
The timeframe for a response may be extended under certain circumstances, in which case we will write to you explaining the reason for the delay, your right to complain to the Australian Financial Complaints Authority (AFCA) if you are dissatisfied and the contact details for AFCA.
If we have provided you with a written response to your complaint and it has not been resolved to your satisfaction, you can lodge a complaint with the Australian Financial Complaints Authority (AFCA). AFCA provides fair and independent financial services complaint resolution that is free to consumers.
Postal Address |
Email |
Telephone |
|---|---|---|
| GPO Box 3 | info@afca.org.au | 1800 931 678 |
| Melbourne VIC 3001 | (free call) |
You can find further information at www.afca.org.au. Please contact us should you wish to receive more information about our dispute resolution policy.
What compensation arrangements are in place?
In compliance with the requirements of section 912B of the Corporations Act 2001, we have professional indemnity insurance in place in respect of financial services we provide to our clients. This insurance also covers claims concerning the conduct of representatives no longer working for us (but who did at the time of the relevant conduct).
Please note that as Damien Crommie is the holder of a Certificate of Public Practice issued by Chartered Accountants Australia & New Zealand, liability is limited by a scheme approved under Professional Standards Legislation.
Version |
Issue Date |
|---|---|
| 1.80 | 25 October 2023 |
Issued by |
|---|
| Barbacane Advisors Pty Ltd (A.C.N 626 694 139) trading as Walbrook Wealth Management |
| Level 2, Rialto Podium East |
| 525 Collins Street |
| Melbourne VIC 3000 |
| Australia |
Australian Financial Services Licence number 512465. Credit Representative Number (534783) authorised under Australian Credit Licence 389328. Liability limited by a scheme approved under Professional Standards legislation.