Disclosure
This is the publicly available disclosure for SIMPLER Financial Limited (trading as Simpler Mortgages). It tells you who we are, what we advise on, how we get paid, and what to do if something goes wrong.
We're required to give you this information under the Financial Markets Conduct Regulations 2014. A copy is also available on request, free of charge. Just email adviser@simpler.co.nz.
1. Important information about our business
SIMPLER Financial Limited (FSP761131) (trading as Simpler Mortgages) holds a Financial Advice Provider (FAP) licence issued by the Financial Markets Authority to provide financial advice services in New Zealand.
- Legal name: SIMPLER Financial Limited
- Trading name: Simpler Mortgages
- Financial Services Provider Number: FSP761131
You can verify our registration on the Financial Service Providers Register at fsp-register.companiesoffice.govt.nz.
Our office contact details:
2. Nature and scope of our advice
Our services
We provide regulated financial advice on debt management, including borrowing for personal and investment property purposes. We also provide advice on personal insurance, specifically life cover, health insurance, trauma cover, mortgage protection, and income protection.
Products we can provide financial advice about
- Home loans, including for first home buyers, refinancing, property investment, moving house, new builds, top-ups, bridging finance and development finance
- Investment property loans
- Reverse mortgages
- Life cover
- Health insurance
- Trauma cover
- Mortgage protection
- Income protection
We do not provide advice on KiwiSaver, managed investments or retirement planning, or on general insurance such as house, contents and car. If you need advice on any of those, we'll refer you to a specialist who can help.
3. Product providers we work with
We can arrange home loans with more than 25 banks and non-bank lenders in New Zealand through our membership of the Kiwi Adviser Network adviser group. The current lender panel is published and kept up to date by KAN at kiwiadvisernetwork.co.nz/PrivacyPolicy. We can also email you a current copy on request.
If we ever recommend a lender that isn't on the standard panel, we'll tell you in writing and explain why before you proceed.
For personal insurance, we provide advice on products from AIA and Partners Life.
4. Our fees and charges
Our fees
We do not charge you a fee for the financial advice we provide, for preparing and submitting your application, or for taking your loan through to settlement. We are paid by commission from the lender on settlement.
This applies to standard residential lending, regardless of the loan amount.
When a charge may apply
There are two circumstances in which a charge may apply. The first is quoted to you in writing before you commit to proceeding. The second arises only after settlement, and only where a lender reclaims commission already paid to us.
1. Complex lending, 0.5% to 1% of the loan amount. Where the work required goes substantially beyond a standard application. This includes lending affected by credit impairment such as defaults, investor lending arranged outside the CCCFA (for example through a trust or company), and development finance.
2. Commission clawback recovery, $280 per hour, subject to the maximums below. Applies only where a lender reclaims commission paid to us because your loan was repaid, refinanced or restructured within that lender's clawback period.
Complex lending charges
- All charges are quoted to you in writing when your approval is issued
- Charges apply only if you choose to proceed with that approval. If you do not proceed, no charge is payable
- Charges are invoiced when your loan structure is confirmed, and are payable on settlement
Commission clawback recovery
When your loan settles, the lender pays us a commission. That commission remains subject to recovery by the lender for a period after settlement. If you repay, refinance or restructure your loan within the lender's clawback period, the lender reclaims some or all of the commission paid to us, even though the advice and application work have already been completed. Where this occurs, we may invoice you to recover it.
- This is not a fee for our advice. Our advice remains free of charge.
- It applies only where a lender has reclaimed commission from us. If no clawback occurs, no charge is payable.
- The amount is capped as set out below, and may be reduced or waived at our discretion.
- The basis of calculation is provided with any invoice.
| Properties or entities | Maximum hours | Maximum charge |
|---|---|---|
| 1 | 13 | $3,640 |
| 2 | 21 | $5,880 |
| 3 | 29 | $8,120 |
| 4 or more | 37 | $10,360 |
Charged at $280 per hour. Invoiced on notification of the clawback and payable within 7 days.
5. Other costs
There are no other costs payable to us in the process of providing our advice and services to you.
If a third party charges you for something connected with your loan application (for example, a property valuation, a builder's report, or a lawyer's fee), those costs are between you and that third party. We don't receive any portion of them.
6. Commissions
For arranging home loans, commissions are paid to us by the lender as follows:
Initial commission
A percentage of the loan amount, paid by the lender at settlement: between 0.55% and 0.90% of the loan amount.
Ongoing (trail) commission
A percentage of the outstanding loan balance, calculated at the end of each month in which you hold the loan: between 0.10% and 0.30% per annum on the outstanding balance.
The specific commission we'll receive on the loan you've chosen will be disclosed to you in writing before you sign anything.
If a loan is repaid, refinanced away, or restructured within a clawback period (usually the first 24 to 28 months after settlement), we may have to repay some or all of the initial commission we received. Where that occurs, we may recover it from you. See section 4.
Personal insurance commission
Where you take out a personal insurance policy on our advice, the insurer pays us an upfront commission of between 150% and 220% of the first year's annual premium, and an ongoing commission of between 7.5% and 20% of the policy premium each year. The ongoing commission is paid to us to manage the relationship with you and provide ongoing support.
We will tell you the specific commission payable on any policy we recommend to you at the time we give you that advice.
7. Conflicts of interest and incentives
We're here for our clients and to advise you as best we can. Your interests are our priority, although we do have business relationships with lenders.
The main potential conflict in our business is that we're paid commission by lenders, not by you. Different lenders pay slightly different commission rates.
From time to time our lenders may assist with funding so advisers can attend conferences and professional development training, or may provide non-monetary benefits such as discounted access to industry tools.
We do not have any volume targets, set sales quotas, or volume-based bonus agreements with any lender.
8. How we manage conflicts of interest
To ensure our advisers prioritise our clients' interests:
- We follow an advice process that ensures our recommendations are made appropriately, based on each client's goals and circumstances.
- All our advisers undergo annual training on how to identify and manage conflicts of interest.
- We maintain registers of conflicts of interest and the gifts and incentives we receive. These registers are monitored regularly, and additional training is provided where required.
- We undertake an annual independent Compliance Assurance Review through Kiwi Adviser Network.
- The specific commission we'll receive on any loan we recommend is disclosed to you in writing before you decide.
9. Our duties and obligations to you
We are bound by the duties of the Financial Markets Conduct Act 2013 (sections 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 client's interests
- Exercise care, diligence and skill
- Meet the standards of ethical behaviour, conduct, and client care set out in the Code of Conduct
These duties apply to every adviser at Simpler, every time we give you advice.
10. Internal complaints process
If you have a problem, concern, or complaint about any part of our advice or service, please tell us so we can try to fix it.
Our internal complaints manager is Sebastian Pierce, who can be reached:
You'll receive an initial response within 24 hours, with a written acknowledgement within 2 business days.
Our internal complaints handling process:
- We acknowledge your complaint in writing within 2 business days of receiving it.
- We investigate the issue and gather any relevant information from you and our records.
- We respond with our findings and any proposed resolution within 10 business days. If we need longer, we'll let you know why and how long we expect it to take.
- If you're satisfied with the resolution, we'll close the complaint and record the outcome in our complaints register. If you're not satisfied, we'll refer you to our external dispute resolution scheme (see below).
11. External complaints process
If we cannot agree on how to fix the issue, or if you decide not to use our internal complaints process, you can contact our external dispute resolution scheme. This service will cost you nothing, and they'll help us resolve the complaint.
FSCL is approved by the Ministry of Business, Innovation and Employment. Their decisions are binding on us.
12. Contact us
For information about how we handle your personal information, see our privacy policy.