Disclosure

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.

​

Our office contact details:

Address:       By appointment, based in Christchurch
Phone:           02108663523
Email:            support@keyandcompass.co.nz
Website:       www.keyandcompass.co.nz​

​

We work primarily with clients across New Zealand using online meetings, phone, and email, with face-to-face meetings by appointment.

​

​

​

Nature and Scope of financial advice services

 

​Our Services

 

We provide financial advice about home lending, business lending, and KiwiSaver.

 

Lending advice 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

• Business lending. Where business lending is secured against residential property, we provide full advice on the loan in the same way as our other lending advice. Where business lending is not secured against residential property, our advice is more limited, and in some cases we may refer you to a specialist provider rather than provide advice directly.

 

KiwiSaver advice includes:

• Reviewing your current KiwiSaver fund and provider

• Recommending a KiwiSaver fund type and provider suited to your goals, timeframe and risk tolerance

• Advice on contribution rates and using KiwiSaver toward a first home withdrawal

 

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

 

​

​

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

• Bridging finance and equity release secured by residential property

• Business loans and business finance

• KiwiSaver schemes

 

​

​

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)

• China Construction Bank (New Zealand) Limited

• Kiwibank Limited

• Nelson Building Society

• SBS Bank

• TSB Bank Limited

• The Co-operative Bank Limited

• Westpac New Zealand Limited

​

Non-bank and specialist lenders we may recommend include:

• ASAP Finance

• Avanti Finance Limited

• Basecorp

• Conrad Funds Management Limited (CFML)

• Cressida Capital

• Finbase

• First Mortgage Trust

• Funding Partners

• General Finance

• Go Lend

• Heartland Bank Limited

• Latitude Financial Services

• Lendr

• Liberty Financial

• Line Capital

• Pepper Money

• Plus Finance

• Southern Cross Partners

• Vincent Capital

• Welcome

• Zurix (FIFO Capital)

​

Where a client requires business finance, we may also recommend:

• Bizcap

• Prospa NZ

• ScotPac Business Finance

​

KiwiSaver providers

We currently hold accreditations with the following KiwiSaver providers and can provide advice on their schemes:
 

• Booster

• Generate

• Fisher Funds

• Milford

• SBS Wealth

 

Where a client's KiwiSaver needs would be better met by a provider we are not accredited with, we may refer you to that provider directly or to another appropriately qualified adviser. We currently have a referral arrangement in place with NZ Funds for this purpose. ​​

​

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.

​

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

​

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

​

Any agreed fee may be:

• A fixed dollar amount, or

• A percentage of the lending amount, or

• A combination of both

​

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

​

For KiwiSaver advice, we are paid by the product provider through a fee based on your funds under advice, rather than a fee charged directly to you. We will confirm the applicable rate before providing any recommendation.

 

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.

​​

​

Commissions

 

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

​

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.

​

KiwiSaver Commission

Where you take out or transfer to a KiwiSaver scheme under our recommendation, the relevant provider may pay us:
 

• An upfront commission of up to $300

• An ongoing trail commission of up to 0.50% per annum of your investment balance, deducted from the fund's own management and administration fees rather than charged to you separately

 

Where we refer you to NZ Funds under our referral arrangement, NZ Funds may pay us an ongoing referral commission of 0.4% per annum. This is separate from any commission paid by your KiwiSaver provider and applies only where you are referred to an NZ Funds product.

​

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.

​​​

​

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.

​

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

• We have a referral arrangement with NZ Funds, and receive an ongoing referral commission where a client is referred to an NZ Funds product. This gives us a financial incentive to refer clients to NZ Funds specifically.

• Some providers on our panel are relationships where we refer clients rather than provide advice directly on that provider's product. Where this applies, we will tell you at the time.

 

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

 

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 currently accept any referral fees, commissions or other benefits from these professional partners for sending them business, although this arrangement may change in the future. Likewise, if they refer clients to us, they do not currently receive any payment or other benefit from Key & Compass. Where any such arrangement is introduced with a professional partner, we will disclose this to you at the time advice is given.

​

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.

 

​
 

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

• Where we provide advice on lending or KiwiSaver, we compare appropriate options across our panel of lenders and KiwiSaver providers, and we will explain why we are recommending a particular lender, KiwiSaver provider or structure

• Where we refer you to a provider rather than provide advice directly ourselves, we will tell you this at the time

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

 

We maintain registers of:

​

• Conflicts of interest

• Gifts and hospitality received

• Incentives from product providers

 

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

​

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

​

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

​
 

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.

​

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.

 

​

​

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.

​

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

• Email: complaints@keyandcompass.co.nz

• Phone: 02108663523

​

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

​

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

​

​