Daniel Reid of Emanate Finance is licensed under the National Consumer Credit Protection Act 2009.
The details of our licence are as follows:
|Business Name||Emanate Finance|
|Address||2 Powell Street
CLOVERDALE WA 6105
|Telephone||0415 297 154|
|Australian Credit Licence Number||498922|
|Customer First Charter|
Our priority is to you, our customer. We place your finance needs above those of any lender, our company or our aggregator, Connective.
Our duty is to ensure you obtain a loan which is appropriate (in terms of loan amount and structure), affordable, suitable for your needs and requirements and delivered in a responsible manner which provides you with a good outcome.
We will be transparent about products and options and applicable fees and charges. We will communicate in simple to understand language and act with the highest standards of integrity. We are committed to ensuring the product selected will meet your needs and requirements at the time of providing credit assistance.
This Credit Guide contains important information about us, the services we provide and the activities of the credit representative operating under our credit licence. It also contains:
- information about fees and charges that may be payable by you to us
- commissions that we may receive when we are acting as a credit representative
- commissions that we may pay to third parties for introduction of business, and information about what you should do if you have a complaint or dispute in connection with our services and activities.
We are required to provide this document to you as soon as practicable after it becomes apparent that we are likely to provide credit assistance to you. We provide “credit assistance” when we:
- Suggest or assist you in applying for:
- a particular loan with a particular lender
- an increase to an existing loan with a particular lender, or
- Recommend that you remain in an existing loan contract.
Prior to providing credit assistance to you, we must assess whether the particular loan is “unsuitable”. A loan will be “unsuitable” based on the information you provided to us if:
- You will be unable to repay the proposed loan or will only be able to repay the proposed loan with substantial hardship, or
- The proposed loan does not meet your requirements and objectives.
We are required to document our findings that the proposed loan is not unsuitable by way of completing a Preliminary Assessment. The Preliminary Assessment will set out your:
- requirements and objectives
- financial and relevant personal situation, and
- ability to repay the proposed loan.
We are also required to take reasonable steps to verify information provided by you to us.
This verification may include:
- requesting you for copies of documents that demonstrate your financial situation – in some cases we may also need to sight original documents, and
- contacting third parties to assist in verifying the information that you provide.
Obtaining a copy of the Preliminary Assessment
If we provide you with credit assistance, you may request a copy of our Preliminary Assessment anytime for up to 7 years and we must provide you with a copy of the assessment within the following timeframes:
|Your request is made:||We will give you your assessment:|
|Before the Credit Day*||As soon as possible after we receive your request|
|Up to 2 years after the Credit Day||Within 7 business days after we receive your request|
|Between 2 to 7 years after the Credit Day||Within 21 business days after we receive your request|
*The Credit Day is the date the credit contract is settled or the credit limit is increased.
There is no charge for requesting or receiving a copy of the Preliminary Assessment.
|FEES AND CHARGES THAT ARE PAYABLE BY YOU IN RELATION TO OUR CREDIT ASSISTANCE|
We may charge a fee for providing credit assistance to you. If applicable, details about those fees payable by you will be set out in a Credit Quote which we will give you prior to submitting your loan application.
Other fees and charges
You may have to pay other fees and charges (such as application fees, valuation costs and other applicable fees) to the lender or other parties. You should review the particular loan contract documentation for further details of any such fees and charges.
|HOW DO I GET PAID?|
Our aggregator receives commission from the lenders and then pays us commission in relation to loan contracts (such as home and investment property loans, asset finance and personal loans) for providing credit assistance.
In most instances an upfront commission is payable by lenders in relation to settled (drawn-down) loans and is calculated as a percentage of the loan amount. It is usually paid after settlement of the loan.
Trail commission is payable in most instances by mortgage lenders in relation to settled (drawn-down) loans. If applicable, trail commission is generally calculated monthly on the outstanding loan balance and is paid in arrears.
The upfront and trail commissions that we are paid by lenders are not payable by you. Details of commission to be received will be included in the Credit Proposal Disclosure document that we will provide you with when credit assistance is provided.
In some instances we may also receive a volume bonus for some types of finance ranging from a minimum 0% to a maximum of 1% depending on the type of credit contract, the total volume of introduced business including GST.
From time to time, I may receive a non-commission benefit by way of training, professional development, entertainment, gift, conference attendance, sponsorship, or entry into a competition run by a lender or my aggregator, at no extra cost to you. The nature of such arrangements are temporary, and the occurrence and amounts are often not readily ascertainable, however if they are apparent as a result of assisting you with credit assistance, this will be disclosed to you.
|OUR LENDER PANEL – CREDIT PROVIDERS|
We are authorised to engage in credit activities and therefore provide assistance to obtain loans for you from a panel of credit providers. The following are the credit providers through which we generally conduct the most business, however we do have access to many other lenders and may use lender outside our panel from time to time:
|Mortgage Lenders||Adelaide Bank||AFM||ANZ|
|Auswide Bank||Bank of Queensland||Bankwest||Better Choice Home Loans|
|Better Mortgage Management||Bluebay Home Loans||Bluestone||Citibank|
|CBA||Connective Home Loans||Firstmac||Gateway Bank|
|Heritage Bank||Homeloans||ING||Keystart Home Loans|
|La Trobe||Liberty||Loan Ave||Macquarie Bank|
|ME Bank||MyState||NAB||P&N Bank|
|Pepper Money||St George||Suncorp||Teachers Mutual|
|Asset & Personal Lenders||ANZ||Bank of Queensland||Capital Finance|
|CBA||Connective Asset Finance||Firstmac||Flexigroup|
|Get Capital||Latitude Financial Services||Macquarie Leasing||Medfin|
|Prospa||RateSetter||Selfco Leasing||St George|
|OTHER PEOPLE WE DEAL WITH|
We have approval to utilise credit providers and their loan products through the services of our aggregator ‘Connective Broker Services Pty Ltd ABN 77 161 731 111, Credit Representative 437202 is authorised under Australian Credit Licence 389328’. The aggregator charges us a fee depending on our contract arrangements, consisting of:
- a share of commission that is paid by the particular credit provider
- a membership fee for our business
- a monthly fee for each of our accredited loan writers.
Macquarie Bank Limited has a minority, non-controlling interest in Connective Broker Services Pty Ltd. Commissions paid by Connective’s lender panel are transparent and do not influence the broker or consumer choice. Connective is committed to quality consumer outcomes in all circumstances.
Referrers and referral fees
We obtain referrals from a range of sources, including accountants, financial planners, real estate agents and other people. If you were introduced or referred to us, we may pay the referrer a commission or a fee.
Details of any commission or fees being paid to the referrer will be included in the Credit Proposal Disclosure document.
|DISPUTE RESOLUTION AND COMPLAINTS|
We are committed to providing you with the best possible service, however we understand there may be times where you are not satisfied. If this occurs please inform us verbally or in writing with the exact details of your complaint, so we can work towards a prompt and fair resolution.
We are mindful of the need to ensure that consumers are treated fairly and with respect during the complaints handling process. Any dissatisfaction will be handled in an efficient, timely and effective manner in accordance with ASIC regulations of Internal Dispute Resolution (IDR).
We hope that you will be satisfied with how we deal with your complaint. However, if your concerns remain unresolved, or you have not heard from us within 45 days, then you can have your complaint heard by an independent party. The complaint can be lodged with the Australian Financial Complaints Authority (AFCA):
Phone: 1800 931 678 (free call)
Mail: Australian Financial Complaints Authority
GPO Box 3, Melbourne VIC 3001
Time limits may apply to complain to AFCA and so you should act promptly or otherwise consult the AFCA website to find out if or when the time limit relevant to your circumstances expires.
|THINGS YOU SHOULD KNOW|
We don’t provide accounting, legal or financial planning advice. It is important you understand your legal obligations under the loan, and the financial consequences. If you have any doubts, you should obtain independent accounting, legal and financial planning advice before you enter any loan contract.
This policy explains how we respect your right to privacy in accordance with the Australian Privacy Principles contained in the Privacy Act (Cth).
We provide a range of broker services in the credit and financial services industry. This includes products and services such as home loans and car finance and supporting services.
Your personal information
When we refer to personal information, we mean information or an opinion from which your identity is apparent or can reasonably be ascertained. The personal information we hold about you may also include credit information. Credit information is a sub-set of personal information and is information, which is used to assess your eligibility to be provided with finance. It may include any finance that you have outstanding, your repayment history in respect of those loans, and any defaults. Usually, credit information is exchanged between credit and finance providers and credit reporting bodies (CRBs).
What information do we collect?
Your personal information and its protection are of utmost importance to us. We will collect personal information when we do business with you. Personal information held by us may include your name, age or date of birth, current and previous addresses, telephone or mobile phone number, email address, bank details, professional job title or occupation, driver’s licence number and financial details. We may hold details of products and services you have acquired from us or have enquired about (including their status), together with any additional information necessary to deliver those products and services and to respond to your enquiries.
If you choose not to provide certain personal information, our ability to assist you may be limited.
(i) we may not be able to provide you with the services you require or the level of service on which we aim to offer; (ii) we may be unable to tailor our offering to your preferences; and/or (iii) your experience of our offering may not be as enjoyable or as useful.
You may need to provide personal information about other individuals to us (e.g. about your authorised representatives, co-borrowers, spouses and other related parties). If so, we rely on you to inform those individuals that you are providing their personal information to us and to advise them that we can be contacted for further information.
How do we use your information?
We will use your personal information:
- to conduct our business
- to manage our business relationships with you and with others, including our Credit Providers
- to complete a transaction on your behalf
- to provide you with information about our products and services.
From time to time, we will use your contact details to send you direct marketing communications including offers, updates and newsletters that are relevant to the services we provide. We may do so by mail or electronically unless you tell us that you do not wish to receive electronic communications.
You can unsubscribe by notifying us or following the unsubscribe links in our electronic marketing and we will no longer send information to you.
How do we hold and protect your information?
We strive to maintain the relevance, accuracy, completeness and currency of the personal information we hold and to protect its privacy and security. We keep personal information only for as long as is reasonably necessary for the purpose for which it was collected or to comply with any applicable legal or ethical reporting or document retention requirements.
We hold the information we collect from you on our secure database. In some cases, your file is archived and sent to an external data storage provider for a period of time. In some instances, we may use the offshore or overseas services to assist with our business, this includes but is not limited to data processing, document collection and management, data storage centres, administration and back office processing units. We take all reasonable steps to protect your personal information from misuse, interference, loss, unauthorised access, modification or exposure. Access to your information is restricted to those employees whose job requires that information. Access to our premises and computer systems is restricted through locks, password protection, internet firewalls and routers.
We will take reasonable steps to destroy or de-identify your personal information when your personal information is no longer required for our business functions.
Will we disclose the information we collect to anyone?
We do not sell, trade or rent client lists or personal information to any third party. We will disclose personal information about you to our credit providers and agents where it relates to our credit assistance.
In all cases we will only disclose that information that is strictly required and take all reasonable steps to ensure that your personal information is handled in accordance with the Australian Privacy Principles.
Otherwise, we will not disclose personal information unless you consent, we are required to do so by law or under some unusual other circumstances which the Privacy Act permits.
We may use external organisations for customer enquiries; mailing operations; billing and debt-recovery functions; information technology services; marketing and telemarketing; market research; and website usage analysis. This means we disclose your personal information (such as name and address) to them. We take reasonable steps to ensure that these organisations are bound by confidentiality and privacy obligations in relation to the protection of your personal information.
In addition, we may disclose your personal information to:
your authorised representatives or legal advisers (e.g. when requested by you to do so); our related companies; our professional advisers, including our accountants, auditors, and lawyers; organisations who manage our business, marketing and corporate strategies and/or sponsors or promoters of any competition that we conduct to promote our services; credit-reporting bodies and fraud-checking agencies; credit providers (for credit related purposes such as credit-worthiness, credit rating, credit provision and financing); funders and agents (to assist us to provide services to you); Australian Banks, non-bank lenders, and providers of credit, financial, or insurance services; mortgage insurers and title insurers; other comparison sites, mortgage brokers or providers of investment finance, or credit (where legal for us to do so); the police or other relevant authorities or enforcement bodies; government and regulatory authorities or organisations (such as our External Dispute Resolution Scheme or ASIC, as required or authorised by law).
Sharing with Credit Report Bodies (CBRs)
We may disclose information about you to a CRB when you are applying for credit, you have obtained credit from us, or if you guarantee or are considering guaranteeing the obligations of another person to us. When we give your information to a CRB, it may be included in reports that the CRB gives other organisations (such as other lenders) to help them assess your credit worthiness. Some of that information may reflect adversely on your credit worthiness, for example, if you fail to make payments or if you commit a serious credit infringement (like obtaining credit by fraud). That sort of information may affect your ability to get credit from other lenders.
Transfer of information overseas
In order to supply you with an efficient service and pursuant to the Australian Privacy Principles, we may transfer personal information we have collected about you to someone in a foreign country only if permitted to do so under the Australian Privacy Principles. You should note that while they will often be subject to confidentiality or privacy obligations, they may not always follow the particular requirements of Australian privacy laws. Overseas organisations may be required to disclose information we share with them under a foreign law. In those instances, we will not be responsible for that disclosure.
We will not share any of your credit information with a credit reporting body, unless it has a business operation in Australia.
How can you access, update or correct the information we are holding?
If you believe that we are holding inaccurate, incomplete, irrelevant or out of date data about you, you may ask us to correct it. You can make a request for access to or correction of your personal information by contacting us anytime.
In some limited circumstances we may need to refuse access to your information or refuse a request for correction. If this is the case, we will advise you as soon as possible after your request and provide you with our reasons for the refusal.
What happens if you are not happy with how your information is handled?
By asking us to assist you, you consent to the collection and use of the information you have provided to us for the purposes described above.
By providing your email address or by clicking submit on any online application, calculator, tool, or query, you consent to receiving notices and other documents from us by email to the email address provided, and understand that if you provide this consent: we may no longer send you paper copies of notices and other documents; and you should regularly check your email address for documents. You also confirm that you have the facilities to print any notice or document that we send you by email, if desired.
For more information on your privacy rights please visit www.privacy.gov.au
For more information regarding this document or anything else about our services, just contact us at any time. We’re here to assist you.