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Disclosure

This disclosure explains our role, how we work, what it may cost, and how we manage any conflicts of interest. It also sets out our duties to you and how you can make a complaint if you are not satisfied.

Important information about our business

 

Key & Compass Limited holds a Financial Advice Provider licence issued by the FMA to provide financial advice services. Key & Compass Limited’s Financial Services Provider Number is FSP1010983. Shane Passfield-Bagley is a financial adviser operating under this licence.

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Our office contact details:

Address:       By appointment, based in Christchurch
Phone:           02108663523
Email:            support@keyandcompass.co.nz
Website:       www.keyandcompass.co.nz​
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We work primarily with clients across New Zealand using online meetings, phone, and email, with face-to-face meetings by appointment.

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Nature and Scope of financial advice services

 
​Our Services
We provide financial advice mainly about home lending. This includes:

  • First home buyer lending

  • Next-home and upgrade lending

  • Investment property lending

  • Refinancing and restructuring existing loans

  • Construction and renovation lending

  • Debt consolidation where lending is secured against residential property
     

We do not currently provide full investment planning, personal insurance advice, or broader retirement planning advice. If you need advice in those areas, we can refer you to a specialist adviser.

 

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Products we can provide financial advice about
We can provide advice on the following products:

  • Residential home loans

  • Investment property loans

  • Construction and top-up loans

  • Refinancing and debt consolidation loans secured by residential property

 

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Product providers we might recommend

Through our membership with Kiwi Adviser Network, we have access to a range of banks and non-bank lenders.

 

A current list of lenders we may recommend includes:

  • AIA Go Home Loans

  • ANZ Bank New Zealand Limited

  • ASB Bank Limited

  • Bank of New Zealand (BNZ)

  • Kiwibank Limited

  • SBS Bank

  • TSB Bank Limited

  • The Co-operative Bank Limited

  • Westpac New Zealand Limited

 

Non-bank and specialist lenders we may recommend include:

  • Avanti Finance Limited

  • Basecorp

  • Conrad Funds Management Limited (CFML)

  • First Mortgage Trust

  • Funding Partners

  • Heartland Bank Limited

  • Liberty Financial

  • Pepper Money

  • Prospa NZ

  • Southern Cross Partners
     

We will confirm which lender or lenders we are considering for you, and why, as part of the advice process. You can request a current list of all product providers we may use at any time.​

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Our fees

For most standard New Zealand residential home loans, we are paid by the lender and do not usually charge you a separate fee for our advice and implementation services.

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There are some situations where a fee may be charged. For example:

  • Where we arrange lending with a provider that does not pay commission

  • Where your situation is particularly complex and requires significant additional work

  • Where you ask us to undertake substantial work and then choose not to proceed with any lending

  • Where you repay or refinance your loan very soon after settlement and the lender claws back the commission paid to us

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If a fee is payable, we will:

  • Explain why a fee is appropriate in your situation

  • Tell you the amount or the way it will be calculated

  • Agree the fee with you in writing before any fee is charged

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Any agreed fee may be:

  • A fixed dollar amount, or

  • A percentage of the lending amount, or

  • A combination of both

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You will not be charged a fee unless you have agreed to it in advance.

 

Other costs

We do not charge our clients any additional costs such as administration, courier, or travel fees for the financial advice we provide. If an unusual cost arises as part of your transaction, we will discuss this with you and obtain your agreement before it is incurred.

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Commissions

For services in relation to loan products, commissions may be paid by the product provider as follows:

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Initial Commission

Upon agreeing to take out new lending under our recommendation, lenders may pay us an up-front commission of 0.55-1.0% of the new lending amount, depending on the lender and nature of the lending product.

 

Ongoing Commission

Lenders may also pay us an ongoing ‘Trail’ commission, which is usually based on the outstanding loan amount. In most cases, this is between 0.15-0.2% of the outstanding loan balance, as is paid on a monthly basis.

We will tell you the actual commission amounts (or ranges) that apply to the products we recommend for you when we give you our advice, so you understand how we are being paid.

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Conflicts of interest or other incentives

We are here for our clients and to advise you as best we can. Your interests are our priority, although we do have business relationships with product providers and an adviser network.

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The main potential conflicts of interest are:

  • We are paid by the lender through commissions when you take out a loan following our advice

  • Different lenders may pay different commission amounts

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From time to time, product providers or our adviser network may provide non-monetary benefits such as training, professional development, or contributions towards conferences or events

Examples of non-monetary benefits we may receive include:

  • Training courses, webinars, and workshops

  • Invites to lender or network events

  • Access to subsidised or discounted software or customer relationship management (CRM) tools

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We also have professional relationships with other service providers such as lawyers, accountants, insurance advisers and real estate agents. Where we refer you to one of these partners, we do so because we believe they may be a good fit for your needs.

 

We do not accept any referral fees, commissions or other “kickbacks” from these professional partners for sending them business. Likewise, if they refer clients to us, they do not receive any payment or other benefit from Key & Compass.

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We do not have set sales targets with lenders that require us to place a certain amount of business with any one provider. We choose lenders based on what we believe is most suitable for your situation, considering your goals, needs and overall circumstances.

 

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How we manage any conflicts of interest

To help ensure we always put your interests first:

  • We follow a documented advice process that requires us to base our recommendations on your goals, needs, and circumstances

  • We compare appropriate options across our panel of lenders, and we will explain why we are recommending a particular lender or structure

  • All advisers associated with Key & Compass receive regular training on managing conflicts of interest and understanding their legal and ethical duties

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We maintain registers of:

  • Conflicts of interest

  • Gifts and hospitality received

  • Incentives from product providers

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These registers are reviewed regularly and additional training or changes to our processes are implemented if needed.

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We undertake periodic independent compliance reviews to check that our policies and processes are being followed in practice.

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If you would like more detail about how we manage conflicts, you can ask us for a copy of our Conflicts of Interest policy.

 

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Our duties and obligations to you

We are bound by the duties of the Financial Markets Conduct Act (431I, 431K, 431L and 431M) to:

  • Meet the standards of competence, knowledge, and skill set out in the Code of Conduct      

  • Give priority to the clients’ interest, and           

  • Exercise care, diligence and skill, and

  • Meet the standards of ethical behaviour, conduct, and client care set out           in the Code of Conduct.

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If you would like more detail about these duties, we can provide you with a copy of the relevant legislation and Code or direct you to where this information is available online.

 

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Our Internal complaints process

If you have a problem, concern, or complaint about any part of our advice or service, please tell us so that we can try to fix the problem.

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Our internal complaints manager is Shane Passfield-Bagley who can be reached at:

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We will:

  • Acknowledge your complaint within 24 hours of receiving it

  • Record your complaint in our complaints register

  • Work with you to understand what has happened and what outcome you are seeking

  • Investigate the complaint, which may include reviewing file notes, communications, and speaking with any staff involved

  • Provide you with our written response and our decision, including the reasons for that decision

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We aim to resolve complaints within 20 days. If we need more time, we will let you know and explain why.

 

Our external complaints process

If we cannot agree on how to fix the issue, or if you decide not to use the internal complaints scheme, you can contact our external disputes resolution scheme: Financial Services Complaints Limited (FSCL). This service will cost you nothing and will help us resolve any complaints.
 

You can contact FSCL at:

Call: 0800-347257

Email: info@fscl.org.nz

Visit: www.fscl.org.nz

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