This document sets out the information that NZFSG is required to make publicly available in accordance with the Financial Markets Conduct Regulations 2014.

An overview of our business

NZFSG is a financial services group.

Businesses who are members of NZFSG (NZFSG Members) provide financial advice to their clients and trade under their own business name or brand. They pay fees to NZFSG to be a member of the group and for the services they receive from NZFSG.

• NZFSG Members are Financial Advice Providers under the Financial Markets Conduct Act 2013 and each NZFSG Member is required to be registered on the Financial Service Providers Register (FSPR).

• NZFSG Members engage Financial Advisers to provide financial advice to clients. The FSPR shows the Financial Advisers which have been engaged by a particular NZFSG Member.

Licensing information

NZFSG (FSP286965) holds a Financial Advice Provider licence issued by the Financial Markets Authority (FMA).

As set out below, some NZFSG Members are authorised under this licence and some NZFSG Members have their own licence from the FMA.

Authorised Bodies

The conditions on our licence authorise specific NZFSG Members to provide financial advice under NZFSG’s licence from the FMA (in this Disclosure Statement we refer to these businesses as “Authorised Bodies”). A full list of the Authorised Bodies is located on the FSPR (search ‘NZ Financial Services Group Limited’ and view the list of Authorised Bodies under the ‘Financial Services’ tab).

Own Licences

Some NZFSG Members are authorised to provide financial advice under their own licence from the FMA.

Scope of this Publicly Available Disclosure

This document sets out some information about NZFSG, its Authorised Bodies and Financial Advisers engaged by those Authorised Bodies, as required by the Financial Markets Conduct Regulations 2013.

The NZFSG Members, including the Authorised Bodies, have their own publicly available information which set out:

• whether they are authorised under the NZFSG licence or whether they hold their own licence from the FMA;

• the nature and scope of the financial advice service their Financial Advisers can offer; and

• other key information about fees, commissions and complaints.

The Financial Advisers have their own Disclosure Guides. These will be provided by the Financial Adviser when they are engaged to provide financial advice by a current or prospective client.

In this Disclosure Statement we refer to an Authorised Body’s publicly available information and a Financial Adviser’s Disclosure Guide collectively as the “Adviser Disclosures”.

Financial Advice and Product Providers

NZFSG does not provide financial advice directly to clients, however the Authorised Bodies and their Financial Advisers provide clients with financial advice about Life, Fire & General Insurance products and/or Lending products and/or KiwiSaver. They generally provide financial advice about products from certain product providers that are included in NZFSG’s approved panel of product providers.

The Adviser Disclosures:

• Set out the specific products that they can provide financial advice on.

• Set out the relevant product providers.

Fees and Expenses

Because NZFSG does not provide financial advice directly to clients, it does not charge fees and expenses to clients.

Information about fees and expenses that might be payable by a client to an February 2023 Authorised Body and/or a Financial Adviser in connection with receiving financial advice is set out in the Adviser Disclosures.

Conflicts of Interest

NZFSG is required to disclose any interests of NZFSG, of its Authorised Bodies or of its Financial Advisers which a client may expect to materially influence the financial advice a client may receive from a Financial Adviser.

Commissions & incentives

If a client receives advice from a Financial Adviser in relation to an insurance product and the insurance application is accepted, NZFSG may receive a commission payment from the applicable insurer.

Additionally, where a Financial Adviser refers a client to Tower Insurance for their insurance needs, or refers a client to XE Money or Prospa NZ for their other financial needs, NZFSG may receive a referral payment.

NZFSG manages the potential conflicts of interest arising as a result of these payments by ensuring:

• Terms of the payments are between NZFSG and the applicable product provider.

• NZFSG does not direct or influence Authorised Bodies or Financial Advisers to recommend products from, or refer clients to, a particular insurer or product provider.

• NZFSG requires Financial Advisers to recommend products by following an advice process that ensures the Financial Adviser understands the needs and goals of their clients and that their recommendations meet those needs and goals.

In relation to lending products and KiwiSaver, NZFSG does not receive commission payments from product providers (however see below under ‘Other interests’ for shareholder dividends NZFSG may receive in relation to one KiwiSaver scheme).

An Authorised Body and/or a Financial Adviser usually receive commission payments in connection with financial advice that they provide if a product is acquired following that financial advice. That commission payment may include an upfront payment, together with an ongoing renewal or trail payment. More information about those commissions, and any other incentives they may receive, is set out in the Adviser Disclosures.

To ensure that the Authorised Bodies and Financial Advisers manage the potential conflict of interest raised by the commission payments, NZFSG:

Provides guidance and training on conflicts of interest.

• Requires Financial Advisers to recommend products by following an advice process that ensures the Financial Adviser understands the needs and goals of their clients and that their recommendations meet those needs and goals.

• Requires Financial Advisers to provide, in their Disclosure Guide, a schedule showing commission rates and types by product provider.

• Carries out regular assurance in relation to the advice provided by a Financial Adviser which assesses, amongst other matters, how conflicts of interest have been managed.

Other interests

• NZFSG has an indirect shareholding in Koura Wealth Holdings Limited (Koura Holdings), which is the sole shareholder of Koura Wealth Limited (Koura Wealth), and an NZFSG employee is a director of Koura Holdings. Koura Wealth is the manager of the Koura KiwiSaver Scheme (Scheme) and receives an investment management fee which is based on the Scheme’s total funds under management. NZFSG may receive shareholder dividend payments based on the performance of Koura Holdings. NZFSG manages this potential conflict of interest by ensuring it does not direct or influence Financial Advisers to recommend the Scheme over other KiwiSaver schemes and by requiring Financial Advisers to recommend products by following an advice process that ensures the Financial Adviser understands the needs and goals of their clients and that their recommendations meet those needs and goals.

  • Some of the directors of NZFSG:

  • Have shareholding interests in NZFSG and/or parent companies of NZFSG and therefore may receive shareholder dividend payments based on the performance of NZFSG.

  • Receive a salary from NZFSG which includes a variable component based on the performance of NZFSG and its subsidiaries.
    
    NZFSG manages the potential conflicts of interest arising by these payments by ensuring that all interests are disclosed in a conflicts of interest register and that decisions made are in the best interests of clients.

• Loan Market Group Limited (Loan Market) is a wholly owned subsidiary of NZFSG. Two of the directors of NZFSG are each a director, shareholder and financial adviser of a business under Loan Market. NZFSG manages this potential conflict of interest by ensuring that all interests are disclosed in a conflicts of interest register and that these two directors do not participate in, or vote on, decisions in relation to which the directors have a conflicted interest.

• In relation to Adviser Businesses and Financial Advisers, NZFSG holds regular events for its Adviser Businesses and Financial Advisers that encourage learning and development. Some Product Providers contribute financially to these events and those Product Providers have opportunities at the event to highlight their product and in some cases provide attendees with information about their products. Additionally, Financial Advisers may be invited directly to events hosted by Product Providers.
  
  NZFSG manages this potential conflict of interest by:

  • Not directing or influencing Adviser Businesses or Financial Advisers to recommend products from particular Product Providers.

  • Requiring Financial Advisers to recommend products by following an advice process that ensures the Financial Adviser understands the needs and goals of their clients and that their recommendations meet those needs and goals.

  • Carrying out regular assurance in relation to the advice provided by a Financial Adviser which assesses, amongst other matters, how conflicts of interest have been managed.

An Authorised Body and/or Financial Adviser will disclose to you any other interests they have in the Adviser Disclosures.

Complaints and Dispute Resolution

If you have a complaint about the financial advice or the service you’ve received from an Authorised Body and/or a Financial Adviser please lodge a complaint with them. Information about an Authorised Body’s internal complaints service and their dispute resolution scheme can be found in the Adviser Disclosures.

If you have a complaint that relates to NZFSG, or if you are unhappy with how a complaint against your Adviser Business or your Financial Adviser has been dealt with, you can contact NZFSG’s internal complaints service by emailing us at compliance@nzfsg.co.nz with the heading Complaint - (Your Name).

Please set out the nature of your complaint, and the resolution you are seeking. We aim to acknowledge receipt of this within 24 hours. We will then record your complaint in our Complaints Register and investigate your complaint. We may want to meet with you to better understand your issues.

We will then investigate your complaint and aim to provide a response to you within 7 working days of receiving your complaint. If we need more time to investigate your complaint, we’ll let you know.

If we cannot agree on a resolution you can refer your complaint to our external dispute resolution service. This service is independent and will cost you nothing and will assist us to resolve things with you.

Details of this service are:

Financial Services Complaints Limited - (FSCL) - A Financial Ombudsman Service.

Phone: 0800 347 257

Email: complaints@fscl.org.nz

Our Duties

Anyone giving financial advice under NZFSG’s licence from the FMA is bound by and supports the duties set out in the Financial Markets Conduct Act 2013. These duties are:

• Meet the standards of competence, knowledge, and skill and the standards of ethical behaviour, conduct, and client care set out in the Code of Professional Conduct for Financial Advice Providers.

• Give priority to client’s interests.

• Exercise care, diligence, and skill.