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Financial Services and Credit Guide

Financial Services and Credit Guide

Updated as of 24 February 2021

The Financial Services and Credit Guide outlines the following information about Modoras Pty Ltd:

  • the financial services available;
  • fees that are charged; and
  • how complaints are managed should they arise.

About Modoras

Modoras was founded in 1984 from a passionate belief that still guides us today: that achieving more is possible for our clients, team members and those yet to join the Modoras financial family. Recognised as market leaders, Modoras has a presence in Queensland, New South Wales and Victoria. Our vision is to continue to extend our reach, empowering us to make the difference to even more lives, so more people experience the confidence and joy that comes from being financially secure.

When a team of professionals work together as one, applying laser focus on turning your dreams into reality, financial security is just the beginning. At Modoras, it isn’t only about investing wisely. It’s about truly understanding each and every client, obtaining considerable insight, so that our team of professionals are confident to deliver the tailored recommendations that span every facet of a client’s financial life. From asset protection and superannuation advice, to investments, personal cash flow, retirement planning and much more, Modoras advice professionals remain by a client’s side throughout their financial journey, sharing financial intelligence to enable them to make well-informed financial decisions, every step of the way.

So, if you are yet to join the Modoras family, invite us along on your financial journey, we are confident of just how far our expert guidance can take you. If you are already a member, we thank you for the trust placed in us, and look forward to continuing to manage, protect and grow what’s important to you.

Information about this Financial Services and Credit Guide

Modoras Pty Ltd ABN 86 068 034 908 (‘Modoras Group’) is providing you with this Financial Services and Credit Guide (FSCG) to assist you in making an informed decision about the financial services and products on offer.

Modoras Group (‘we,’ ‘us’ or ‘our’) provides financial services through its Australian Financial Services Licence (AFSL No. 233209).

This FSCG is divided into two parts and both parts must be read together to form the FSCG.

Part A of this FSCG outlines the Modoras Financial Advice Process, the financial services and products we provide and Part B outlines the financial services and products provided specifically by your Financial Planner. Your adviser will provide this to you as required or upon earlier request.

Your ‘Financial Planner’ is an authorised representative of Modoras and they provide services on our behalf as described in this FSCG. We are responsible for the financial services or product advice provided to you, as well as the content and distribution of this FSCG.

Modoras is also responsible for the credit assistance services provided to you as described in this FSCG. These credit assistance services are provided through Modoras’ Credit Representatives.

Modoras are authorised to provide advice in the below areas. For more specific information about the individual authorisation of your planner, please refer to Part B of the FSCG. Some areas of advice will require specialised and technical knowledge, these areas may include but are not limited to, Margin Lending, Self-Managed Super Funds, Direct Equities, Credit Assistance and Social Security needs. Modoras takes the competency of our Authorised and Credit Representatives seriously. Representatives are required to have current skills and knowledge, operating only within the limits of their authorisation. This limitation is detailed in Part B of the FSCG.

Your planner typically only recommends products which are listed on the Modoras Approved Product List (APL). Where circumstances may require it; your financial planner may recommend a product outside of the APL.

Financial Services Guide |  Credit Guide | General Information

Financial Services Guide

Six Steps to Advice the Modoras Way

Understanding you

Goal Setting

Understand your current financial position and financial potential

Design tailored solutions and preparation of written recommendations

Implementation of your financial journey

Keeping you on track

Financial Services and Products

We may provide you advice in the below areas:

– Financial planning

– Wealth accumulation

– Superannuation, including self-managed superannuation funds

– Investments

– Redundancy payments

– Retirement planning

– Gearing

– Cash flow

– Social security benefits

– Debt management

– Life and disability insurance

– Estate planning services (financial planning)

We may deal in the following financial products:

– Deposit and payments

– Government debentures, stocks or bonds

– Life investment and life risk

– Managed investment schemes including investor directed portfolio services

– Leveraged investments

– Standard margin lending facilities

– Retirement savings accounts

– Securities (e.g. shares)

– Superannuation

Your Privacy

The privacy of your personal information is important to us. We collect your personal information to ensure we are able to provide you with the services most appropriate to your needs. For further information, you can access the Modoras Privacy Policy at or we can provide you a copy at any of our locations.

Documents you will receive

You may receive one or more important document such as a Statement of Advice, Record of Advice or a Product Disclosure Statement.

Statement of Advice (SoA)

In the event that personal advice is provided which takes into account your individual needs, objectives and financial circumstances, you may be provided with a Statement of Advice (SoA). The SoA is an important document which details the recommendations from your financial planner, your personal information, the cost of advice and fees payable to your planner and the licensee and associations between Modoras and its Authorised Representative and other related entities.

An SoA should contain enough information for you to make an informed decision on whether to act on the advice.

Record of Advice (RoA)

If we provide you with further personal financial advice, whereby your circumstances, needs and objectives are not significantly different to when the previous advice was provided to you, and the basis of the advice provided to you is not significantly different to the advice previously provided to you, we may provide you with a Record of Advice (RoA) instead of a SoA.

You may request a copy of the RoA, if you have not already obtained such a copy, at any time up to 7 years after the relevant further advice is provided. In these circumstances a copy of the RoA will be provided to you without charge.

Product Disclosure Statements (PDS)

If we recommend a specific financial product, you may also receive a Product Disclosure Statement or similar document provided by the product issuer. The PDS document or similar document contains important information designed to assist you in deciding whether or not to acquire the product, such as the product’s features and benefits, fees and charges and the risks associated with it. The PDS allows for you to make an informed decision about a particular product.

Instructing your Planner

You can give instructions both verbally and in writing to Modoras. For your protection and Modoras’ protection, Modoras reserves the right at Modoras’ sole discretion to request your prior written confirmation of any instructions prior to those instructions being acted on.

Fees and Costs

Modoras is principally a fee for advice business; you can partner with us in two ways, either by having an ongoing relationship or by seeking advice for specific needs. You can elect to attend one of our many locations or you may find video conferencing more convenient

The fees charged:

– will be dependent on the nature and complexity of the advice and the services we provide;

– will vary based on whether the advice is ongoing or for a specific piece of work;

– are received from you and either paid directly or from your product;

– will vary based on whether specialist advice areas are required such as Margin Lending, Self-Managed Super Funds, Gearing, Direct Equities, Credit Assistance; and

– can be charged as a flat dollar fee, a percentage-based fee or a combination of both.

INITIAL ADVICE Initial Consultations — You may be charged for an initial consultation with your planner at an hourly rate, with prior agreement.

Plan Fees — may include costs associated with:

  • Collecting data
  • Defining your current financial position
  • Assisting you to establish your goals
  • Research and analysis of relevant strategies and products to achieve your goals and objectives
  • Appropriate risk profiling
  • Appropriate risk needs analysis (where required)
  • Strategy research and selection
  • Investment selection
  • Initial advice documentation
  • Consultation appointments up to and including your initial advice presentation.

The indicative fee range for initial advice is $2,200 to $11,000 (including GST).

All Initial Advice fees will be discussed and agreed prior to the commencement of any work. If the plan fee looks likely to exceed the usual range, we will inform you and seek your consent on a revised estimate.


IMPLEMENTATION Advice & Implementation Fees — may include costs associated with:

  • Consultation appointments post initial advice presentation
  • Variations to advice
  • Liaising and project managing advice implementation, including (where specified) with other service providers
  • Preparing all necessary documentation to commence initial advice implementation
  • Preparing, lodging and following up service and/or product providers in order to carefully implement recommended and accepted strategies
  • Other administration required, specific to the initial advice implementation
  • Post Implementation appointment (as required)
  • Regular communication with you during the implementation process, including additional meetings with you or your other service providers (if required)

All Advice and Implementation fees will be discussed in the initial advice stage and will be disclosed in your advice document. An indicative fee range is $5,500 to $27,500 (including GST).

These fees vary based on complexity of strategy to be implemented and are in addition to initial advice fees.


ONGOING SERVICE An ongoing service agreement may be appropriate to help you reach your goals. Ongoing fees will be clearly stated both within your Client Service Agreement and in your advice document.

Ongoing Service fees may be charged:

  1. As a flat dollar fee ranging from approximately $2,200 to $11,000 p.a.* (including GST); or
  2. As a percentage of the assets under management ranging from 1.1%to 3.3% p.a (including GST) of funds under management. For example, where an ongoing service fee is charged at 1.1% p.a. for a portfolio of $100,000, Modoras will charge $1,100 p.a (including GST); or
  3. A combination of options 1 and 2 above

Fees are charged depending on the level of service you prefer or need, which will be outlined in your Client Service Agreement. If, based on complexity or circumstances and services required, the likely ongoing service fee will exceed the usual range, we will inform you and seek your consent on a revised estimate prior to proceeding.

AD HOC ADVICE Ad hoc services may be provided on an as needs basis. Fees will be quoted and agreed before any work commences.

We may charge by the hour, where appropriate for more specific bodies of work. Above and beyond this amount it is likely that an ongoing service package may be more appropriate for you.

PositionHourly rate (including GST)
Senior/Specialist Planner$550
Financial Planner$440
Planning Associate$220
Personal Service Associate$220
Business Associate$110

Facilitation/Project Management Fee

Where more complex project management is required, you may engage us on an hourly rate to facilitate or advocate on your behalf in a project management capacity only.

A fee may be charged, but not limited to, all professional time for drafting, reviewing and completing documents, correspondence, advices, conferences, reading materials, travelling (where related to the work), telephone calls, research and providing letters where requested by you.


INSURANCE COMMISSIONS Insurance Commissions are received on both an upfront and ongoing basis, paid directly to us by product providers and is not an additional cost to you.

From 01/01/2020

Upfront Commissions payable by Life Insurance providers to planners range from 0 to 66% (including GST) of the premium in the first year. Based on a premium of $2,000, this would equate to $1,320 (including GST).

Ongoing Commissions payable by Life Insurance providers to planners range from 0 to 22% p.a. (including GST) for the time you hold the policy, based on renewal.

Commissions are paid once all relevant discounts or rebates are applied, before the 15% premium tax rebate is applied and on all applied loadings. Commissions are not paid on policy fees or stamp duty (where separately charged).

Where level premiums are charged, commission claw backs may be applicable in the first 12 months if the policy is cancelled, a claim is paid, or the insured reaches benefit expiry age.

Policies in place prior to the Life Insurance Framework being introduced on 01/01/2018 are what is known as grandfathered, in which the terms of a policy (including commission rates) written prior to this date will continue to be valid at this time.


INVESTMENT COMMISSIONS In the past where we have placed or increased a margin loan for you, we may have received payments in the form of ongoing commissions from the margin loan provider. Commissions on margin lending products may only be payable in certain circumstances where an arrangement exists as at 1 July 2013.

These commissions range between 0% and 0.5% p.a. of your loan balance.


OTHER Referral Fees

On occasion, as part of conducting a holistic review of your financial situation, we may identify other services which may be of benefit to you, in which case we may provide you with a referral. In turn, other professionals with which we have a relationship with, may identify a need for financial advice in which case they may direct you to us. If any referral fee arrangement applies, it will be clearly disclosed to you, however, in most cases Modoras will only charge for the service they provide to you directly.


GST The percentage rates and dollar amounts shown in the tables contained within this FSCG are inclusive of Goods and Services Tax (GST).

Other Benefits you should be aware of

On occasion, your Financial Planner may be entitled to receive benefits, which are at no cost to you and often provided in the form of ‘sponsorship’, this may include:

  • Inhouse training and educational offerings, formal education, catering at these events or other acceptable items which allow your financial planner to provide a higher quality of service to you.

There may also be invitations to lunches or other functions, promotional material or goods or other minor benefits to Modoras.

Any benefits that Modoras or its Representatives may receive will only be accepted to a value of less than $300 per provider per year. Any benefits received exceeding this limit will not be allowable. While many of our valued clients like to express their gratitude with a gift to their planner, please be reminded that seeing you achieve your goals is all the thanks that we need. Modoras and its Representatives maintain a register for any alternative remuneration received. Registers can be made available upon request if required.

Further details of how a Modoras Authorised Representative is remunerated are contained in the FSCG Part B.

Credit Guide

Six Steps to Credit Assistance


Understanding you

Research and compare lender options for you

Assist and provide proposal

Implement the selected lending option

Keeping you on track

What is Credit Assistance?

Modoras provides credit assistance in relation to credit products regulated by the National Consumer Credit Protection Act.

Credit assistance occurs where a credit representative:

  • Suggests that a consumer apply for a loan, an increase to a loan, or a lease
  • Suggests that a consumer stay with an existing credit provider or lessor
  • Assists the consumer to apply for a loan, an increase to a loan or a lease

Credit Assistance Process Explained

Credit assistance is provided by a “Credit Representative” who, after meeting adequate qualification and skills requirements, is authorised to engage in specified credit activities on behalf of the licensee namely, Modoras Pty Ltd, Australian Credit Licensee Number 233209.

Our obligation when providing credit assistance is to undertake a preliminary assessment, to ensure that the credit contract or ‘loan’ is not considered ‘unsuitable’ but only after making reasonable inquiries into your goals, objectives and current financial situation. We may provide you with a comparison summary of certain lender options which may be available to you.

We will not suggest that you apply, or assist you to apply, for a credit contract or for an increase to the credit limit of a credit contract or suggest that you remain in a credit contract if we assess that the credit contract is unsuitable for you.

When will a credit contract be unsuitable?

A credit contract will be unsuitable if we reasonably believe:

  • the credit contract does not meet your requirements or objectives;
  • it is likely that you will be unable to comply with your financial obligations under the credit contract; or
  • it is likely that you could only comply with your financial obligations under the credit contract with substantial hardship.

Obtaining a copy of the Preliminary Assessment

We will give you a written copy of the applicable Preliminary Assessment, if you request a copy of this from us during the period of 7 years from the date of the quotation for credit assistance we have provided to you (the ‘Quotation Date’). We will provide you a copy of the Preliminary Assessment as per required timeframes set out below:

Period of time elapsed from the Quotation date Period in which we will give you the Assessment
Up to 2 years7 business days after we receive your request
Between 2 and 7 years21 business days after we receive your request

However, we are not required to provide a copy of the Preliminary Assessment if your request is made more than 7 years after entering into a credit contract or a credit limit increase, or if the credit contract is not entered into or the credit limit is not increased.

Credit Providers

The main credit providers that we recommend as a result of our research and analysis are:

WestpacMacquarieSt George

Our Aggregator

Modoras uses the services of Australian Finance Group (AFG) ABN 11 066 385 822 ACL 389087, to enable you to enter into credit contracts with a large range of credit providers, in addition to the credit providers listed above. Not all of Modoras’ Credit Representatives are authorised to use these services. The aggregator charges us a fee depending on our contract arrangements and may include: a share of commission paid by a credit provider, a membership fee or a monthly fee for each of our accredited loan writers.

Part B of the FSCG will indicate if the Authorised Representative providing you with financial services is also a Credit Representative, and what credit assistance and services they can provide. When providing any credit assistance, Credit Representatives of Modoras will not act as your agent and will not act as an agent of any credit provider, except to the extent necessary as part of the application process. If the Authorised Representative providing you with financial services is not also a Credit Representative, they will need to refer you to a Modoras Credit Representative or a suitably qualified third party associated with Modoras.

Credit Disclosure Document

At the same time as providing the credit assistance, Modoras will provide you with a proposal called a Credit Disclosure Document. This document will contain details about the fee amount payable by you to Modoras, a reasonable estimate of the total amount of commission to be received by Modoras, any Credit Representative or an associated entity of Modoras or any referrer, and if applicable, a reasonable estimate of the total amount of fees and charges payable to the lender in relation to applying for the credit.

Also, if the credit is to be used to pay any of the above amounts, a reasonable estimate of the amount of credit left after paying for these amounts will be included.

How is the Licensee Paid?

If you take out a credit product through us, Modoras may receive payments in the form of initial commissions and/or ongoing commissions from the credit provider.

The lender may pay a fee or commission to Modoras for assisting in establishment of the loan between 0.45% 0.77%. The lender may also pay an ongoing commission of 0.1% p.a. to 0.35% p.a.


CREDIT We may charge fees for the preparation, presentation and implementation of our credit assistance. These fees will be based on your individual circumstances and the complexity of the credit assistance required. We will discuss and agree to these and any other fees with you before we provide you with credit assistance. If a fee is to be charged by Modoras, we will provide you with a Credit Quote before providing any credit assistance.

Credit Assistance costs may be charged as an hourly fee of no more than $440 per hour, estimated indicative range $880-$6,600 (including GST).

General Information

Who is providing the services?

The ‘Modoras Group’ includes:

Modoras Pty Ltd (ABN 86 068 034 908)

Australian Financial Service License and Australian Credit License Number 233209.

It also includes Corporate Authorised Representatives and Authorised Representatives which are either partially, wholly-owned or directly affiliated Australia Financial Services Licensees (AFSLs), Australian Financial Services Credit Licensees (ACLs) and Registered Tax Agents and Accountants, as per below:

  • Modoras Asset Management ABN 86 068 034 908
  • Modoras Accounting (QLD) Pty Ltd ABN 81 601 145 215 (accounting services)
  • Modoras Accounting (Gold Coast) Pty Ltd ABN 62 601 145 199 (accounting services)
  • Modoras Wealth Management (QLD) Pty Ltd ABN 66 623 115 668 (financial advising services)
  • Modoras Wealth Management (VIC) Pty Ltd ACN 145 368 869 the Trustee for Modoras Wealth Management (VIC) Unit Trust ABN 27 236 614 176 (financial advising services)
  • Modoras Accounting (VIC) Pty Ltd ACN 145 368 850 the Trustee for Modoras Accounting (VIC) Unit Trust ABN 37 460 720 728 (accounting services)
  • Modoras Wealth Management (SYD) Pty Ltd ABN 82 622 475 478 (financial advising services)
  • Modoras Accounting (SYD) Pty Ltd ABN 18 622 475 521 (accounting services)
  • RJS Wealth Management Pty Ltd ABN 24 156 207 126 (financial advising services)
  • RJ Sanderson & Associates Pty Ltd ABN 71 060 299 783 (accounting services)
  • RJS Loan Solutions Pty Ltd ABN 25 123 033 116 (loan services)
  • RJS Legal Group Pty Ltd ABN 18 636 518 566
  • FinancialLine UMG Pty Ltd ATF The Trustee for the Pyramid Unit Trust ABN 24 741 319 784 (financial advising services)
  • FinancialLine Finance Pty Ltd ATF FinancialLine Finance Trust ABN 11 644 724 780, Australian Credit Licence Number 392126 (credit services)
  • FinancialLine Pty Ltd ABN 28 104 193 857 (technology services)
  • Actocue Pty Ltd ABN 32 128 604 419 Australian Financial Service Licence and Credit Licence Number 323729
  • Enevita Pty Ltd ABN 40 128 973 464 Australian Financial Service Licence Number 321254 (Licensee)
  • Enevita Corporate Services Pty Ltd ABN 73 606 822 566 (accounting administration services)
  • BG Private Clients Pty Ltd ABN 72 621 816 466 trading as BG Wealth Management Pty Ltd ABN 14 127 520 558, AFSL 496348.

Nature of our relationships

Modoras declares an interest in the products and services recommended and commissions, brokerage, fees and other payments received by the companies listed here in this FSCG. Peter Sarai is a shareholder and/or director of all entities either wholly or partially.

Modoras Pty Ltd ABN 86 068 034 908 AFSL 233209 (‘Modoras’), trading as Modoras Asset Management, is the sponsor of the Modoras Asset Management Investment Series. Modoras Asset Management is the specialist investment management division of Modoras that provides financial, capital market and investment analysis, portfolio design and construction as well as portfolio management services to Modoras.

Modoras Pty Ltd is also associated with Enevita Pty Ltd (Enevita) ABN 40 128 973 464, Australian Financial Service Licence Number 321254, which has been established as an Australian Financial Services licensee for the sponsorship of a badged “White Label” Investor Directed Portfolio Services (IDPS). These services are the Enevita Platinum Portfolio Investment Solution and a Superannuation WRAP account platform, which is the Enevita Platinum Retirement Management Solution.

Modoras’ Representatives are authorised to provide advice in relation to and deal in the Enevita (IDPS) and WRAP Account Platforms. Modoras declares an interest in the products and services recommended and commissions, brokerage, fees and other payments received by the above-named companies.

How do you resolve an issue?

We encourage you to speak directly to our staff and they will do their best to resolve your issue. Alternatively, you may contact us using the details below.

When contacting us, you can assist your query or complaint by providing us all the relevant supporting information you have and by setting out your desired outcome. You will receive a prompt acknowledgement of your complaint and, if possible, it will be resolved immediately. If this is not the case, we will commence investigation of the matter and respond with a view to resolve within 45 days. More complex matters may require an extension of time to thoroughly investigate and respond, however, should this be the case; this will be communicated to you.

If your issue is related to Financial Planning or Credit services and after having raised the issue with us, you are still dissatisfied with the outcome, you are entitled to escalate the complaint to an external dispute resolution scheme. We have provided contact details of these below:

Australian Financial Complaints Authority

GPO Box 3,
Melbourne VIC 3001
Phone: 1800 931 678

If your issue relates to privacy, please contact:

Office of the Australian Information Commissioner (OAIC)

GPO Box 5218
Sydney NSW 2001
Phone: 1300 363 992

How do you get in touch with us?

If you seek any further information from the Modoras Group about this policy, please contact our Privacy Officer:

Registered Address: Level 3, 50 – 56 Sanders Street, Upper Mt Gravatt QLD 4122
Postal Address: PO Box 6530, Upper Mt Gravatt QLD 4122
Phone: (07) 3219 2555

Our professional indemnity insurance

Our professional indemnity insurance satisfies the compensation arrangements required under Australian law, being section 912B of the Corporations Act. Modoras maintains appropriate cover for claims in relation to services provided by Modoras‘ Authorised Representatives, Credit Representatives and employees, whether or not those Authorised Representatives Credit Representatives or employees are still working for Modoras.


Issued by:

Modoras Pty Ltd

ABN 86 068 034 908

Australian Financial Services Licensee & Australian Credit Licence No: 233209

1300 888 803 |
Registered Address – Level 3, 50-56 Sanders Street, Upper Mount Gravatt QLD 4122
Postal Address – PO Box 6530, Upper Mount Gravatt QLD 4122