7 September 2020

Important details

The purpose of this Financial Services Guide (‘FSG’) is to provide you with details of the financial services provided by Spotee Pty ABN 55 637 623 940, (CARN 001283189) (‘Spotee’) or its directors/employees and to provide relevant information to help you decide whether to use the financial services offered.

This FSG provides details about remuneration or benefits that we (or others) may receive, attributable to the financial services we provide. It also details how complaints about the financial services we provide will be dealt with.

Most financial products, other than listed securities, will have a Product Disclosure Statement (PDS). A PDS is a disclosure document which assists you to make an informed investment decision, including helping you to compare it with other products. It sets out significant features of a financial product, including its risks, benefits and costs. Where applicable, when we offer to arrange for the issue of a financial product to you, we will provide you with a PDS.

The content and distribution of this FSG have been authorised by Spotee and Daylight Financial Group Pty Ltd, ABN 77 633 984 773 AFSL 521404. You can contact us by email at question@spotee.com.au or mail PO Box 333, Avondale Heights, VIC 3034.

Unless specified otherwise, a reference to ‘we’, ‘our’ of ‘us’ in this FSG is a reference to Spotee or, in the case of financial services provided by Spotee’s employees or directors, Daylight Financial Group Pty Ltd.


What services we may provide to you

Spotee offers consulting services to private investors and corporate advisers on the topic of securities and investing principles. Spotee’s directors and/or staff may provide general financial product advice through the delivery of this service. Spotee’s consulting services are available on a limited basis, relative to capacity.

We may also provide general financial product advice to you on securities via another financial services provider (e.g. an adviser), who has an existing arrangement with us and utilises our services. General advice you receive from us under this arrangement will be sourced by your other financial service provider and provided to you in a written report form, which will include our details.

Where we provide general financial product advice through our consulting services, we act for the clients to whom these services are provided. (In the above example, the services are provided by us to an adviser – so, we act for the adviser, not for you.)

Spotee’s consulting services encompass are range of different functions based on the need of the client. These tasks can range from a portfolio diagnostic, through to share market education, and/or mentorship services.

What it does NOT entail is any personal advise be it trading or similar, nor do we act as a broker. For further information on Spotee’s consulting services, please visit www.spotee.com.au/consulting-services .


Who will be providing financial services to you?

Financial services will either be provided to you by Spotee’s directors and/or Spotee’s employees.

Spotee is a corporate authorised representative (CARN 001283189) of Daylight Financial Group Pty Ltd ABN 77 633 984 773. Daylight Financial Group Pty Ltd is the holder of an Australian Financial Services Licence number 521404 and has authorised Spotee to provide financial services on its behalf.

To the extent Spotee’s directors or employees provide financial services, the directors or employees act as representatives of Daylight Financial Group Pty Ltd.

Neither Spotee nor Daylight Financial Group Pty Ltd is responsible to you for the actions of its representatives (including Spotee). Neither Spotee nor Daylight Financial Group Pty Ltd is responsible to you for services provided to you by any other third party, including other financial service providers (e.g. advisers). You should refer to the FSG of your other financial services provider for further information about the services they offer.


What kinds of financial services are we authorised to provide you and what kinds of products do those services relate to?

  • deposit and payment products
  • debentures, stocks or bonds issued or proposed to be issued by a government
  • interests in managed investment schemes (including IDPSs)
  • retirement savings accounts
  • securities (such as shares)
  • superannuation

Though currently not undertaking such services, Spotee can also deal in a financial product by applying for, acquiring, varying or disposing of a financial product on behalf of another person, in respect of the following classes of financial products:

  • interests in managed investment schemes (including IDPSs)
  • securities (such as shares)
  • superannuation


Will you be provided with advice that is suitable to your investment needs and financial circumstances?


Where we provide you with advice, it will be general financial product advice only. Our advice will be prepared without taking into account your individual objectives, financial situation or needs; and because of this, before acting on the advice you should consider the appropriateness of the advice having regard to your objectives, financial situation and needs; and if the advice relates to the acquisition or possible acquisition of a particular financial product, you should obtain a copy of, and consider, the PDS before making any decision.


What charges will you incur?

Spotee’s consulting services

If you choose to utilise Spotee’s consulting services you will be charged either an hourly rate for any work completed, or alternatively you can subscribe to a full year at a discounted rate.


Hourly charge.

The charge is $500 per hour (inc GST). This is also the minimum charge for any work completed.

Spotee has the right to change this rate at any time, however the rate you initially subscribe to will be the rate that applies to you moving forward.

The billing cycle includes both any preparation work and time for the consultation. You will be told what that amount will be before any work commences and payment must be made before the session is held. If you can’t make the scheduled meeting for any reason, we will look to reschedule.


Annual charge

An annual subscription to Spotee’s consulting and education services for retail investors is $5,995 p.a. (inclusive of GST)

This rate includes all preparation work, reviews, consultations and subsequent contacts. It will remain at this rate for the tenure of our relationship, irrespective of any price rises in the future.

Annual Rates for Financial Advisers will need to be negotiated based on the number of clients and your current offering (direct holdings, SMA/IMA etc). The base level rate is $5,995 p.a. (inclusive of GST).

A base schedule of sessions will be arranged, with subsequent contact available on an ‘as requested’ basis.

Payment must be made in full prior to any work commencing. And given the significant price discount and resource commitment required to support a full year offering, there are no refunds available.

However should you be unavailable and not monitoring your portfolio for a period of time, then we are happy to extend the service period for the time you will be offline.


First 30 minute consultation is free

The first consultation is complimentary and is for a maximum 30 mins on the phone.

It is a fact-finding mission to discuss what you are seeking from a service such as this. This includes a brief questionnaire that you will need to complete in order to help maintain focus on the things that matter most to you. There will be no coaching or answers to your questions provided.

After the meeting, a plan and future schedule will outline what services will be delivered as part of the consultation process. At this point you have the option not to proceed with any sessions if you feel our program would not be able to assist you.


Rescheduling and refunds

Hourly charge

You can reschedule your appointment at any time.

Refunds are only available should you cancel your session at least 48 hours before the agreed time. Refunds will not be paid should the cut-off time not be met. The only other alternative is to reschedule to another day and time.

Annual charge

Given the significant price discount and resource commitment required to support a full year offering, there are no refunds available.

However should you be unavailable and not monitoring your portfolio for a period of time, then we are happy to extend the service period for the time you will be offline.


Consider carefully if this service is cost effective for you

To give you an idea of the time required and potential outlay – A full and thorough review of your existing portfolio, strategy development and education could take 3 hours to complete – $1,500.

If all you require is a discussion on recent decisions and learnings, that time will likely be 1hr – $500 (30 mins research + 30min discussion).

With the annual charge, no such time constraint exists. A base schedule of meetings will be arranged, created around your preferences and needs. These will be agreed upon prior to you making any payment.

If your portfolio is very small, then this service may not be cost-efficient. Only you can determine if this is the case or not.

There is a lot of free information/education available, including via the “Spotee on Shares” program www.spotee.com.au that runs Monday – Wednesday 12pm AEST on tickertv.com.au . In this program we invite market experts to provide their views on stocks, whilst answering questions live on air. Other sources such as www.ASX.com.au , as well as not-for-profit organisations such as the Australian Shareholders Association and the Australian Investors Association provide good share market education.


Cost examples

These are just examples of potential costs and should be taken as any indication as to what services you may require.

Hourly charge 

  • An investor with little to no market knowledge has an existing portfolio or lump sum of $250k. Allowing for education, training and mentorship over say 5 hours conducted over a number of weeks, then the outlay equals 1% of the portfolio (ie $2,500 to get the knowledge you need to start investing.)


  • An existing $1m portfolio run by an investor with sound knowledge of the market, then a full diagnostic and consultation could take between 3-4 hours ($1500 – $2000) to initially complete meaning an investment of 0.15 – 0.2% of the portfolio. Ongoing reviews would be shorter based on the complexity and number of changes you have made since our last meeting.

Annual charge

  • Based on the same portfolio values described above, should you subscribe to the annual subscription then the time to complete any review is irrelevant, however the outlay does increase to 2.4% of a $250k portfolio or 0.6% of a $1m portfolio.
Spotee education sessions

Spotee will run special group education sessions (delivered either online or face-to-face).

Depending on the nature of the content and duration of the sessions, Spotee may charge a fee for that training. Fees will depend on the specific training undertaken and will be advertised at the time it is offered.

All training and education will be general of nature and will not take into account your personal objective, situation or needs.


Other referral payments

Spotee may make referral payments to third parties that distribute promotional material about Spotee’s consultation services and/or education offerings. At present, no such deals are in place.


What other remuneration or other benefits we may receive in relation to the financial services we provide?

Spotee may receive revenue from referring and / or advertising a third-party service to investors on either SpoteeTV, Spotee consulting services or via Spotee education. At present, no such deals are in place.


Staff representatives-remuneration

Spotee’s staff are remunerated on a fixed salary basis. Elio D’Amato, Managing Director of Spotee, and other staff representatives of Spotee may benefit from a share in any profits of Spotee.


Do any relationships or associations exist that might influence us in providing you with financial services?

Spotee is a subsidiary of Daylight Financial Group Pty Ltd, its authorising licensee. Together, Spotee and Daylight Financial Group Pty Ltd, form the Daylight Group of companies. When employees or directors of Spotee provide financial services, they do so as representatives of Daylight Financial Group Pty Ltd, on the basis that they are employees and/or directors of an entity that is a related entity of the holder of an Australian Financial Services Licence.

Daylight Financial Group Pty Ltd receives a service fee from Spotee in relation Spotee’s appointment as a corporate authorised representative of Daylight Financial Group Pty Ltd. Daylight Financial Group Pty Ltd does not receive any remuneration or benefit for the financial services provided by Spotee, or Spotee’s directors or employees.

Where a company in the Daylight Group of companies, its directors, employees or associates hold an interest in a particular company which is the subject of our general advice, this will be noted in our content, as appropriate.


Who can you complain to if you have a complaint about the services that we provide?

If you have any complaints about the service that we provide, please take the following steps:

Contact the team at Spotee by email at question@spotee.com.au. We will endeavour to resolve any client complaint or query as soon as possible.

If you prefer, you can lodge your complaint in writing to: Managing Director, Spotee Pty Ltd, PO Box 333 Avondale Heights, VIC 3034.


If you do not receive a satisfactory outcome, you have the right to complain to the Australian Financial Complaints Authority. The contact details for the Australian Financial Complaints Authority are GPO Box 3, Melbourne, Victoria, 3001 or phone 1800 931 678 (free call).

Alternatively email the Australian Financial Complaints Authority at info@afca.org.au  or fax (03) 9613 6399.


The Australian Securities and Investments Commission (ASIC) also has an Info line number 1300 300 630 which you may use to make a complaint and obtain information about your rights.


Professional Indemnity insurance.

We have Professional Indemnity insurance in place that covers claims in respect of current and former representatives for financial services provided by or on behalf of Daylight Financial Group Pty Ltd. In our view, this insurance satisfies the requirements for compensation arrangements under the Corporations Act and Regulations 2001.


General investment warnings.

The value of an investment may go down as well as up. Past performance of an investment is not a reliable indicator of future performance. We do not guarantee the return of capital. The information in this Financial Services Guide (FSG) is of a general nature only and does not take into account any individual’s objectives, financial situation or needs. Therefore, before acting on any advice contained in this FSG, you should consider the appropriateness of the advice, having regard to your objectives, financial situation and needs.

All figures quoted in this FSG are as at 22 August 2020 (GST inclusive except where explicitly stated).


Privacy policy

We are committed to preserving and respecting your privacy and complying with the Privacy Act 1988. For full details about our privacy practices and your rights, see the Daylight Group’s Privacy policy and collection notice at www.daylightfinancial.com.au or www.spotee.com.au .