Financial Services Guide
This Guide has been authorised for distribution by Trading Levels Pty Ltd ACN 126 495 609 AFSL 317817 and for its Authorised Representative Mirabile Vincere Pty Ltd (ARep No 321187) TA TradingLounge
V1.92 Dated 1 December 2019
Content
01. About this Financial Services Guide
02. Who is providing the service?
03. Who is my Trading Levels Pty Ltd Representative?
04. Who ultimately is responsible for the advice given to you?
05. What type of financial services is TradingLounge™ authorised to provide?
06. What specific services are offered by TradingLounge™?
07. Are there risks involved?
08. How does Trading Levels Pty Ltd and Trading Lounge get paid?
09. What Commission is received?
10. How are employees and other representatives of TradingLounge™ remunerated?
11. Conflicts of Interest
12. Inquiries, Complaints Handling and Dispute Resolution
13. PI Insurance arrangements
14. Privacy Policy
15. Is there anything else I need to read before I become a subscriber?
01. About this Financial Services Guide
This FSG is an important document required to be provided by law in the provision of financial product advice1. It answers the question: “what service am I getting? The Guide contains information about the financial services provided by Trading Levels Pty Ltd through its authorised representative, Mirabile Vincere Pty Ltd as trustee for the Mathers Grace Trading Trust trading as Trading Lounge (“Trading Lounge”, “we”, “us”, “our”), the providing entity, to help you decide whether to use the financial services we offer. It explains:
- who we are
- the services and types of products we offer
- what remuneration and other financial benefits may be paid to us
- potential conflict of interest that may exist
- details of our internal and external complaints handling procedures and how you can access these systems, and
- how you can contact us.
Please take the time to read this Guide carefully, along with our Terms and Conditions, prior to considering using our services.
NOTE: Because Trading Levels Pty Ltd nor its authorised representative, Mirabile Vincere Pty Ltd as trustee for the Mathers Grace Trading Trust trading as Trading Lounge does NOT provide “Personal Advice” as defined by [Sec. 766B(3) of the Corporations Act (2001) we are not required to provide you with a Product Disclosure Statement (PDS) or a Statement of Advice (SOA).
02. Who is providing the service?
This FSG provides information about the financial services and products provided by Trading Lounge, a trading name of Mirabile Vincere Pty Ltd (ACN: 122 054 371) (AR No: 321187). Trading Lounge is acting as an authorised representative of the Australian Financial Services License holder, Trading Levels Pty Ltd (AFSL No: 317817); pursuant to section 913B of the Corporations Act 2001). We do not act on behalf of any issuers or owners of the securities or derivatives that we provide opinions on.
03. Who is my Trading Levels Pty Ltd representative?
When you speak with us, you are dealing with a Trading Lounge employee or contractor who is authorised to represent Trading Levels Pty Ltd. All our representatives are experienced and qualified to provide the general financial product advice contained in this FSG. Authorised Representative business address:
Mirabile Vincere Pty Ltd (ABN 49122054371)
as trustee for the Mathers Grace Trading Trust trading as
TRADING LOUNGE
Telephone: 61 2 4787 6020
PO BOX 331 Blackheath NSW 2785 Australia
Email: admin@tradinglounge.com
Website: tradinglounge.com
04. Who ultimately is responsible for the advice given to you?
Trading Levels Pty Ltd, the AFS licensee, is authorised to provide General Financial Product Advice to retail and wholesale clients and is regulated by ASIC. Trading Levels Pty Ltd as the AFS Licensee, closely supervises its authorised representative as it is ultimately responsibility for the general advice provided to you by TradingLounge™.
AFS Licensee business address: Trading Levels Pty Ltd
PO BOX 331 Blackheath NSW 2785 Australia
Telephone: 61 2 4787 6020
Email: admin at tradinglounge.com
Website: tradinglounge.com
05. What type of financial services is Trading Lounge authorised to provide?
Trading Levels Pty Ltd (AFSL: 317817) has appointed TradingLounge™ as an authorised representative to provide General Financial Product Advice (including opinions and recommendations) with respect to securities and derivatives and their underlying markets.
PLEASE NOTE As with any investment opportunity there is a risk of making losses on investments that Trading Lounge expresses opinions on. Historical results are no guarantee of future returns. Some investments are inherently more risky than others. At worst, you could lose your entire investment. TradingLounge™ uses a range of technical analysis tools, software and basic fundamental analysis as well as economic forecasts aimed at minimising the potential for loss. The advice we provide through our TradingLounge™ website and our TradingLounge™ Membership has been prepared without taking into account your particular objectives, financial situation or needs. Reliance on such advice, information or data is at your own risk. The decision to trade and the method of trading is for the subscriber alone to decide. This information is of a general nature only, so you should, before acting upon any of the information or advice provided by us, consider the appropriateness of the advice in light of your own objectives, financial situation or needs. You should consult your personal financial adviser before making any investment decision. If you do not have a personal financial adviser, you should contact a financial adviser or stockbroker who is licensed to provide you with personal financial product advice. Your financial adviser is required to provide you with a Statement of Advice (SoA).
06. What specific services are offered by Trading Lounge?
Primarily Trading Lounge is a financial services business providing research and educational sharemarket and derivative comment. Several times a week we publish our opinions/advice on securities and derivatives, such as CFDs, to Members through the TradingLevels® Members Area on our website. Additionally, we may also provide opinions and advice during our presentations to the general public and to the financial press. Trading Lounge strives to deliver high quality securities and derivatives financial markets research using predominantly technical analysis (also known as “charting”) or other like tools and fundamental analysis. TradingLounge™ Members will receive regular (likely to be daily) charts (with accompanying commentaries) of watched stocks and derivatives. From time to time the service may provide additional information about the financial markets both in Australia and overseas. An ‘invitation to join’ email maybe sent out to potential clients who have given us permission to hold their email on our database. The email introduces the Member services and invites the recipient to join. The TradingLounge Member fee is paid in advance.
07. Are there risks involved?
As with any investment opportunity there is a risk of making losses on investments that TradingLounge™ expresses opinions on. Historical results are no guarantee of future returns. Some investments are inherently more risky than others. At worst, you could lose your entire investment. Trading Lounge uses a range of technical analysis tools, software and basic fundamental analysis as well as economic forecasts aimed at minimizing the potential for loss. This information is of a general nature only so you should seek advice from your broker or other investment advisors as appropriate before taking any action. The decision to trade and the method of trading is for the reader alone to decide. As such you should not act on any advice, information or data without first obtaining specific advice from your own personal advisor to ensure it is appropriate to your particular circumstances. Reliance on such advice, information or data is at your own risk.
08. How does Trading Levels Pty Ltd and TradingLounge™ get paid?
Trading Levels Pty Ltd is paid a licence fee by its authorised represenative (Mirabile Vincere Pty Ltd as trustee for the Mathers Grace Trading Trust trading as) TradingLounge™. TradingLounge™’s primary service, TradingLounge™ Membership is a web site published report and Members pay an Annual (USD$670 plus GST), 3Monthly fee (US$200 inc GST) or 20 Day Trial fee (USD$1 inc GST) active from the date of payment cleared. Members have password-cleared access to our Member pages to see our technical analysis, commentary and trading recommendations on a daily basis The fee includes up to 4 weeks annual leave when some reports, charts and signals may not be updated. Wholesale client’s fees for any TradingLounge™ technical analysis reports are negotiated between TradingLounge™ and each client. Fees may include access to our online Members pages and may include more detailed commentary. The fees include up to 4 weeks annual leave when some reports, charts and signals may not be updated. Non-members and Members seminars are occasionally held and the fees for these range from $90 to $3300 depending on the type of seminar. We sell trading and investment books and software. We sell trading education services and these fees vary depending on the service required.
09. What commission is received?
Neither Trading Levels Pty Ltd nor its authorised representative (Mirabile Vincere Pty Ltd as trustee for the Mathers Grace Trading Trust trading as) TradingLounge™, receive any commission, or other fees and benefits in relation to the general advice, services or products as outlined in this FSG; nor from any of the companies whose stocks are recommended as suitable for investors or traders.
10. How are employees and other representatives of TradingLounge™ remunerated?
All employees of TradingLounge™ receive a salary (hourly rates for contractors). They may also receive performance-based bonuses which are based on profitability, the number of subscribers and subscription renewal rates. Employees (including contractors and other representatives of TradingLounge™) are not entitled to any other fees, commissions or benefits from TradingLounge™ or any other person in relation to the financial services provided. TradingLounge™ and related body corporates may from time to time, have associations and relationships with other financial service providers and as a result may be entitled to remuneration.
11. Conflicts of interest
TradingLounge™ directors, employees or contractors, may from time to time have interests in securities and derivatives that appear within our articles and reports. We recognise that this may create conflict of interest and to manage this potential conflict, while we are not prohibited from commenting on financial products in which we have an interest, such interests are disclosed through the web site, emails, seminars, reports and so on.
12. Complaints handling and dispute resolution
We aim to adhere to the highest standards of professional conduct at all times both through our internal policies as well as our associations with professional bodies. Nevertheless, we understand there may be times when you might want to make a complaint about our services. We have established procedures to ensure that all enquiries and complaints are properly considered and dealt with fairly. The following steps provide instructions for any escalating unresolved complaint:
Step 1. If you have an inquiry or complaint, please send in your complaint to Trading Levels Pty Ltd Compliance Officer Peter Stephan (preferably by email: peter@tradinglounge.com). Alternatively you can mail it to the business address in this Guide. We will try and resolve it quickly and in an equitable way.
Step 2. However, If an issue has not been resolved to your satisfaction, you can lodge a complaint with the Australian Financial Complaints Authority, or AFCA. AFCA provides fair and independent financial services complaint resolution that is free to consumers.
• With the Australian Financial Complaints Authority:
Website: www.afca.org.au
Email: info@afca.org.au
Telephone: 1800 931 678 (free call)
In writing to: Australian Financial Complaints Authority, GPO Box 3, Melbourne VIC 3001
Please note that before AFCA deals with your complaint you must have first lodged a formal complaint with us, Trading Levels Pty Ltd; in addition to giving each party adequate and reasonable time to resolve the complaint internally. In addition, ASIC has an info line to make a complaint or obtain information about your rights: 1300 300 630.
Step 3. If the dispute or difference does not fall within the rules of AFCA, you may request Trading Levels Pty Ltd to agree to submit the dispute or difference for arbitration. If Trading Levels Pty Ltd agrees to your request, the arbitration will be conducted in accordance with and subject to the Institute of Arbitrators and Mediators of Australia Expedited Commercial Arbitration Rules, and to the extent permitted under those rules the Arbitrator will be a person recommended by the Sydney chapter of the Institute of Arbitrators and Mediators in Australia. If Trading Levels Pty Ltd does not agree to your request, you may not submit the dispute or difference for arbitration, although you may commence legal proceedings against Trading Levels Pty Ltd, in which case you agree to submit the dispute or difference to the courts of Sydney, Australia. To the maximum extent permitted by law, any dispute or difference whatsoever raised by you in connection with Trading Levels Pty Ltd must be dealt with in Australia as described above.
Step 4. What is the effect of a determination by AFCA or the arbitrator? You agree to accept the determination of AFCA or the arbitrator as final and binding and submit to the non-exclusive jurisdiction of the Courts in Sydney for the enforcement of any such determination.
13. PI insurance arrangements
Trading Levels Pty Ltd and its Authorised Representaives has professional indemnity (“PI”) insurance arrangements in place as required under s912B of the Corporations Act 2001. Our PI insurance takes into account the nature and volume of our business, the number of clients and kind of clients we have, our employees and the maximum potential extent of liability.
14. Privacy policy
We collect personal information from our members / subscribers such as name, address, telephone and email and other pertinent information relating to the products and services we provide you. We keep your details on our database to facilitate the dissemination of our products and services. This information is held in accordance with our privacy policy, which can be found online at www.tradinglounge.com. We may also keep a record of any correspondence between you and us, including, but not limited to emails and letters. All personal information is kept confidential and secure. If you have any queries regarding your personal information please email us at the above URL link. We will not share your personal information with any third party without your express permission. The information will only be disclosed to Trading Levels PL related companies and affiliates. If at any time you wish to change any of your details, please contact us. We may, from time to time, inform you of special offers or ask your opinion of our services. You may opt out of receiving these correspondences, by contacting us.
15. Is there anything else I need to read before I become a subscriber?
This FSG should be read in conjunction with our Terms & Conditions. You can print a copy of the FSG (Click the print icon at the bottom of this text) or we can email or mail you a copy.
(Footnotes) 1 RG175.20 (ASIC): “A recommendation or a statement of opinion, or a report of either of those things, constitutes financial product advice, if… ‘ it is aimed at influencing a decision. 2 Subscribers are defined as both wholesale and retail clients and other professional investors.
FINANCIAL SERVICES GUIDE
V1.92 Dated 1 December 2019
Mirabile Vincere Pty Ltd (ABN 49122054371)
as trustee for the Mathers Grace Trading Trust
trading as TradingLounge™ is an Authorised Representative (No 321187)
of Trading Levels Pty Ltd AFSL 317817
PO Box 331 BLACKHEATH NSW 2785 AUSTRALIA
Email: admin at tradinglounge.com.
Telephone: +61 2 4787 6020