Menu
CROSS BORDER PAYMENTS PRODUCT DISCLOSURE STATEMENT
Flexewallet Pty Ltd (“Flexewallet”) (ACN 164 657 032) provides payment services and holds an Australian Financial Services Licence (AFSL No. 448066) authorising it to deal in, and provide general advice regarding non-cash payment products. Novatti Trading FX Pty Ltd (“Novatti”) (ACN 645 493 161) is an online international payment service provider and is an Authorised Representative of Aurora Capital Markets Pty Ltd (“Aurora”) (AFSL No. 490749).
Flexewallet and Novatti are wholly owned subsidiaries of Novatti Group Ltd (ACN 606 556 183), a company listed on the Australian Securities Exchange (ASX Code: NOV). Aurora and Flexewallet have authorised the distribution of this Product Disclosure Statement (PDS).
This PDS applies only to financial services provided in Australia. Financial services offered under this PDS may be restricted by law in certain other jurisdictions.
A copy of this PDS is available for download from our website www.novattixb.com. If you have any questions about any part of this PDS, please contact us by phone at +61 03 9013 0066 or by email at [email protected].
Capitalised words used in the PDS have defined meanings which appear in the Definitions section at the end of this PDS.
Effective Date: 5/01/2022
Version No: 1.1
PURPOSE
This PDS is issued by Novatti and Flexewallet (together, “us”, “we”) pursuant to an intermediary authorisation agreement in place between Novatti and Aurora and under Flexewallet’s AFSL. Under Novatti’s agreement with Aurora, Aurora offers to arrange for Novatti to issue the FX component of the Product under section 911A(2)(b) of the Corporations Act 2001 (Cth). Under Flexewallet’s AFSL, Flexewallet arrages to issue the non-cash payment facility component of the Product.
Novatti is an Authorised Representative of Aurora (AR No. 001289459) who holds AFSL No. 490749.
Under Aurora’s AFSL Novatti is authorised to:
to retail and wholesale clients.
Under Flexewallet’s AFSL, Flexewallet is authorised to:
To retail and wholesale clients.
This PDS is designed to assist you in deciding whether to use Novatti’s online international money transfer service (the “Product”).
The information in this PDS does not take into consideration your individual financial situation, objectives, or needs. Prior to making any decision about the Product or whether to use it, you should consider whether this Product is right for you. Any advice in this PDS is general advice only. You should consider the appropriateness of any general advice to your own circumstances before acting on it. For more information on the Product, please visit www.novattixb.com.
1. UPDATES RELATING TO THIS PDS
Information in this PDS may be subject to change from time to time. Information about changes that are not materially adverse will be available at www.novattixb.com. The information which we will make available by way of these updates may change from time to time.
If the changes are materially adverse to the information provided in this PDS, we will issue a replacement PDS.
2. THE PRODUCT ISSUER
By acquiring this Product, you are entering into a contractual relationship with Novatti and Flexewallet (together, the “Issuer”), not with Aurora or any other parties involved with this Product.
Novatti’s Contact Details
The Product and services referred to in this PDS are provided by:
Novatti Trading FX Pty Ltd (ACN 645 493 161)
Address: Level 3, 461 Bourke Street, Melbourne, VIC, 3000
Telephone: +61 03 9013 0066
Email: [email protected]
Website: www.novattixb.com
Flexewallet Pty Ltd (ACN 164 657 032)
Address: Level 3, 461 Bourke Street, Melbourne, VIC, 3000
Email: [email protected]
Website: www.flexewallet.com
3. OTHER PARTIES
Aurora Capital Markets Pty Limited
Novatti Trading FX Pty Ltd is an Authorised Representative of Aurora Capital Markets Pty Limited (ACN 165 534 958) who hold an Australian Financial Services Licence (AFSL No. 490749).
You can contact Aurora at:
Address: Level 41, 55 Collins Street, Melbourne, Victoria 3000
Telephone: 1300 000 002
Email: [email protected]
Website: www.auroramarkets.com.au
Currencycloud
We use Currencycloud to provide our services to you. We use Currencycloud’s platform to process your Transactions. Currencycloud holds all money in your Wallet, including your available balance, in a separate bank account to their business accounts.
Barclays
Barclays Bank UK PLC. (Registration No: 9740322) (“Barclays”) is authorised by the Prudential Regulation Authority in the UK and is regulated by the Financial Conduct Authority and the Prudential Regulation Authority (Financial Services Register number: 759676). Barclays provides Currencycloud with segregated bank accounts to hold customer funds.
Important Information about the Financial Claims Scheme
The Financial Claims Scheme (“FCS”) is a scheme administered by the Australian Prudential Regulation Authority (“APRA”) to protect depositors from potential loss due to the failure of institutions. It provides depositors with a guaranteed protection, up to a cap. As at the date of this PDS, the FCS applies to deposits only. It does not extend to the Product or any Available Balance held on the Product.
If Barclays fails:
The risks associated with the Product may therefore be increased when you load or hold large amounts of money in the Product
For more information on the FCS, refer to: http://www.fcs.gov.au/
4. THE PRODUCT
The Product is an online international money transfer service (available 24 hours, seven days a week). You can instruct us to send your funds overseas immediately (i.e. within the next 48 hours) by providing us with Instructions via a Spot Contract.
Spot Contract
A Spot Contract is a foreign exchange contract under which we agree to exchange money at an agreed rate within 48 hours of the contract being entered into.
Spot Rate
We will quote you an exchange rate in the form of a spot rate (“Spot Rate”). The Spot Rate will be valid for 48 hours. You must Deliver your funds to us within 48 hours for immediate transfer to your nominated Beneficiary Account.
We calculate the Spot Rate by taking into account the Interbank Spot Rate and the Margin. If you choose to compare the Spot Rate we quote you with another exchange rate, you must compare a Spot Rate with another Spot Rate. Spot Rates are different to a Value Today Rate (today’s rate only) or a Value Tomorrow Rate (valid for 24 hours). Value Today and Value Tomorrow Rates are calculated differently to Spot Rates and are consequently not appropriate comparisons.
Variable Components
In a Spot Contract, there are a number of variable components that need to be agreed, including:
Settlement
A Spot Contract must be settled within 48 hours of the Transaction being entered into. This means you must pay us the money you are exchanging within 48 hours. It may take longer than 48 hours for funds to be received by the Beneficiary Account, as this is dependent on when we receive the funds, the destination of the Beneficiary Account and the intermediary banks involved.
Cancellation
Once a Transaction has become legally binding, you may not cancel the Transaction in any circumstances. You may only take action to correct any of the Transaction details set out in the Deal Confirmation if the Deal Confirmation does not reflect the transaction details that have already been agreed.
No Margin or Speculative Trading
We do not facilitate any type of margin or leveraged foreign exchange transaction (i.e. where you speculate on future exchange rate movements by putting down a deposit and trading a multiple of that deposit). We do not allow you to pay us only the amount of any loss occasioned by exchange movement. In no circumstances will we pay you any profit realised as a result of an exchange rate movement.
Your Global Currency Account
In order to access the Product, you must create an account via our online platform. Once you have created an account, you will be provided with a facility which allows you to hold, send or receive electronic money/payments via the platform (the “Global Currency Account”). The electronic money held in your Global Currency Account does not expire, except when your account is closed. The electronic money held in your Global Currency Account will not earn any interest.
You may only hold electronic money in currencies which we support from time to time. You may convert the money held in one currency into other currencies we support. You can only perform a conversion in respect of funds that you already hold in your Global Currency Account. A conversion fee will apply.
You may withdraw money from your Global Currency Account at any time, however you must always have a zero or positive account balance. If your Global Currency Account goes into a negative balance as a result of a chargeback, reversal of a transaction, deduction of fees or any other action carried out by you, you are obliged to repay the negative balance immediately without any notice from us.
You can load funds into your Global Currency Account through local network routes or using SWIFT. Funds can also be collected on your behalf and credited to your Global Currency Account. We may permit additional methods of receiving or loading money into the Wallet from time to time.
It is important to understand, the Global Currency Account is not a bank account or deposit product, it is a non-cash payment facility. The acquisition of the Product does not represent a deposit with, or an investment in any of the parties involved in this Product.
5. ACCESSING THE PRODUCT
You can access the Product directly, via our online platform. In order to transact with us you will need to be granted access to the platform. You will need to submit the onboarding form (available on the website) and pass our due diligence before we can grant access to the platform. When you submit the onboarding form to us, you will also be asked to agree to the terms of the Cross Border Payments Terms and Conditions (the “Master Agreement”). Once you have passed our due diligence process and you have read and entered into the Master Agreement, your registration will be complete. However, you will only be able to transact once we have approved your account.
We reserve the right at all times to refuse to accept your Instructions or process Transactions, including after you have agreed to the Client Agreement, and can do so without giving you any reason or incurring any liability. If you book a Transaction prior to your account being reviewed and approved by us, we may refuse to process the Transaction.
6. DELIVERABLE ONLY
In all cases, you must Deliver to us the full amount of the funds you are exchanging. We simply transmit money. We do not facilitate any type of margin or leveraged foreign exchange transaction.
7. GENERAL INFORMATION ONLY
We provide general information in relation to foreign currency Transactions. We can provide you with advice about how deliverable foreign exchange Transactions work. None of the information we provide to you, either on our website, our platform, via email or over the phone, will take into account your personal financial circumstances and needs. You will always need to exercise your own judgement and should obtain independent financial advice as to the amount, type and timing of any Transaction you enter into with us.
8. DOCUMENTS YOU WILL RECEIVE
The following documents are available for you to view and download at www.novattixb.com. It is important that you read and understand the documents listed below before using the Product. If you do not agree to the terms and conditions outlined in the documents, then you must not use the Product.
Product Disclosure Statement
You will have access to this PDS before you are provided with the Product. The PDS is designed to assist you with deciding whether the Product is right for you.
Financial Services Guide
You will also have access to the Financial Services Guide (FSG) before you are provided with the Product. The FSG is designed to tell you about the Issuer and the Financial Services we provide.
Master Agreement – Cross Border Payments Terms and Conditions
We will ask you to agree to the Master Agreement which sets out the terms and conditions relating to the provision of our foreign exchange services generally. You must read and agree to the terms set out in the Master Agreement before entering into any Transactions. The Master Agreement applies to all Transactions that you subsequently enter into with us. Each Transaction you enter into will be a separate contract, which is governed by the terms of the Master Agreement. If you wish to enter into a Transaction, you may do so by giving us Instructions online.
Privacy Policy
You should also read the Issuer’s Privacy Policy before you decide to use the Product.
We may publish updated guidelines and terms and conditions regarding the use of the Product on our website from time to time.
9. SIGNIFICANT BENEFITS
There are some significant benefits to you associated with use of the Product, including:
10. SIGNIFICANT RISKS
There are some significant risks associated with use of the Product that you should be aware of, including:
Credit Risk
Credit risk is the risk that the Issuer or any third party involved in the transactions will become insolvent and as a result we will be unable to perform our contractual obligations to you. When entering into a contract with us, you are taking a risk on our and our third party providers solvency. Any money you place with us is held by Currencycloud in a bank account that is independent from Currencycloud’s business bank accounts. This minimizes the credit risk, as your money is segregated from Currencycloud’s assets.
Operational Risk
We use both internal and third-party systems to provide our service. If our systems or the third-party provider’s fail, we may not be able to provide the Product adequately. This could result in delayed settlement or errors in payment details. We cannot control the third-party systems. The risks involved with using these systems is dependent on measures implemented by the third-party providers.
Technology and Data Security Risk
We have certain security measures and physical risk reduction processes in place. We use all reasonable efforts to ensure uninterrupted access to the Product. However, technical or unforeseen issues that are out of our control, such as errors and bugs in the software, telecommunication failures and security breaches, may prevent you from accessing the Product in the future. We cannot guarantee that your access will never be uninterrupted. We also have the right to suspend or terminate your access to the Product at any time without providing you notice. We will not accept liability for any loss you incur due to lack of access to the Product due to issues with the software or technology.
Discretionary powers of the Issuer
We have a number of discretionary powers which may affect your ability to conduct a Transaction.
We have the power to refuse to enter into a Transaction or terminate any open Transaction without providing you with notice. We may also block or freeze your account and/or funds without providing notice if we suspect your funds may be connected to money laundering, terrorist financing activities or if a regulatory authority requires us to do so. We will not be liable for any indirect or consequential losses connected with your account being blocked or frozen. Please read the Master Agreement for more information about our discretionary powers.
Foreign Exchange Risk
Price and availability of currencies can change quickly as foreign exchange currency markets are subject to a number of unpredictable influences (e.g. natural disasters, political conditions, changes to economies). Once you have entered into a Spot Contract with us, you have locked in the exchange rate, and you will not be affected by any subsequent exchange rate movements. If there is an adverse exchange rate movement, you will not be disadvantaged by it. Alternatively, if there is a more favourable exchange rate movement, you will not be able to take advantage of it.
11. FEES & CHARGES
The following fees and charges will apply when you book a Transaction:
Margin
The Margin will vary from time and from currency to currency. The Margin is not a separate amount you have to pay, it is built into the exchange rate. It effectively represents our gross profit margin on each Transaction. We will not usually be able to tell you what the Margin is. To help you decide if our Margin is reasonable, you can compare the exchange rate we quote with the rates quoted by other providers.
Payment Services Transaction Fees
You will be charged a transaction fee per transaction. The fee varies depending on the currencies you are converting and the method you are using to convert the funds (e.g. SWIFT or local).
The Issuer reserves the right to amend the Payment Services Transaction Fees by giving you no less than thirty (30) days prior written notice. Such amendments to the Payment Services Transaction Fees will become effective on the date specified in the written notice.
Foreign Exchange Service Fees
When a transaction is cancelled or withdrawn due to insufficient funds and we are locked into buying and or selling the currency you requested, you will be charged a foreign exchange service fee at market cost or gain.
Third Party Transaction Fees
We do not charge you an additional amount for third party Transaction fees. They are built into our Margin. However, in some cases, the intermediary banks we use to process payments may deduct Transaction fees that we have not anticipated. For example, in some jurisdictions, the receiving bank charges a receiving bank fee. We will try to notify you of these additional fees if we are aware of them, but we cannot always do so in advance. As a result, you may find, in some cases, the total amount received in the Beneficiary Account is less than expected because such fees have been deducted. You should bear this in mind if you are paying the precise amount of an invoice. You may contact us if you have any questions regarding the likelihood of third-party Transaction fees being levied by intermediary banks for your Transaction.
Payment of Losses
The amount of any loss realised on the Closing Out of a Transaction is a debt payable by you. We may immediately deduct the total amount of any loss (together with any expenses, premiums, commissions or other fees) from any funds we hold in relation to any Transaction. If the amount we are seeking to recover exceeds the amount of any funds held by us, you agree to pay the balance within seven (7) days of being notified by us of the total amount due.
No Payment of Profit
We will not pay you any profit arising from Closing Out a Transaction in any circumstances.
Fee for holding a Euro balance
You will be charged the following fee for holding a Euro balance in your account:
Negative Interest Fee | |||
Type | Balance Band (€) | Rate | |
The Rate: | Banded | 0-20,000,000 | 0.60% per annum |
Banded | >20,000,000 | 0.75% per annum | |
The Negative Interest Fee: | The Rate per day multiplied by the balance on the account at the end of each day, calculated monthly. The Rate per day is determined by dividing the Rate per annum by 360. | ||
Each month, you will pay Novatti in arrears the Negative Interest Fee. | |||
Ancillary Fees
The Issuer reserves the right to charge the following ancillary fees:
(a) Any landing fees for receipt of funds from you;
(b) Any financing charges (including any market
losses and costs) Novatti incurs due to delayed settlement or changes to settlement date; and
(c) Any exceptional transaction charges Novatti is required to charge you for any reason.
Closing Out
When we Close Out any or all of the Transactions that you have entered into, we buy back the currency that we have bought for you when you entered into the Transaction at prevailing market rates chosen by us in good faith. If the value of the currency you have asked us to exchange has strengthened, a loss will be incurred on the Transaction and you will be liable to pay us the amount of that loss, together with any expenses, premiums, commissions or other fees incurred by us.
12. PRODUCT LIMITS
Depending on where you are sending money to, some schemes have their own limits for local payments. Please contact us if you would like more information about limits that may apply.
13. DISPUTES
Internal Disputes Procedure
If you have a complaint, you can contact us at:
Phone: +61 03 9013 0066
Mail: P.O. Box 171, 380 Bourke Street, Melbourne, VIC, Australia, 3001
Email: [email protected]
We will handle all complaints according to our internal dispute resolution procedure.
Our dispute resolution procedure requires that we acknowledge your complaint within 24 hours, provide an initial response to your complaint within 5 days, and provide a final response within 30 days.
The period of 30 days may be extended in exceptional circumstances.
Australian Financial Complaints Authority
After 30 days, if you are not satisfied with the outcome of our internal disputes procedure, you have the right to complain to the Australian Financial Complaints Authority (AFCA). AFCA provides independent financial services complaint resolution which is free for consumers.
You can contact AFCA via:
Mail GPO Box 3, Melbourne VIC 3001
Phone 1800 931 678
Fax 03 9613 6399
Website www.afca.org.au
Email [email protected]
Arbitration
If your dispute does not fall within the rules of the AFCA, you may submit the dispute to arbitration to be determined by the 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 New South Wales Chapter of the Institute of Arbitrators and Mediators of Australia. You agree to accept the determination of the arbitrator.
14. TAX IMPLICATIONS
There may be tax implications associated with Transactions you enter into with us. We encourage you to seek professional tax advice before entering into any Transactions with us.
15. APPLICABLE LAWS
AML/CTF Laws
We are required to collect and verify certain identification information about you. We will collect personal information from third parties to verify your identity. We may be required to disclose certain information to AUSTRAC about you and we may not be able to tell you when this occurs. We may also be required to freeze Transactions or block your account.
Privacy
Our Privacy Policy can be found on the website and sets out how, why and when personal information is used, collected, stored, disclosed or otherwise handled by us.
16. DEFINITIONS
Close Out means any action we may take to close out, cover or reduce our exposure in relation to a Transaction (e.g. cancelling a Transaction) including any action we reasonably consider appropriate in the circumstances.
Beneficiary Account means the bank account nominated by you to which we send your funds.
Deal Confirmation means a written communication, on the platform confirming the details of any Transaction that you have booked online, which shall be an error correction mechanism only.
Deliver or Delivery means payment to us for the full amount of currency you are exchanging.
Interbank Spot Rate means the market Spot Rate that we receive from the foreign exchange wholesale market, being a preferential rate given to the organisations conducting large and frequent Transactions.
Instructions means a request made by you to enter into a Transaction.
Margin means the difference between the exchange rate we pay our provider (which we access through the wholesale foreign exchange market) and the rate we quote you. The Margin will vary from currency to currency and from time to time. We will not be able to tell you what the Margin is, but you can compare the exchange rate we quote you with other providers to ensure that we are offering you a competitive rate.
Master Agreement means the Cross Border Payments Terms and Conditions that we will ask you to enter into before beginning transacting with us.
PDS means this Product Disclosure Statement.
Spot Contract means a foreign exchange contract under which we agree to exchange money at an agreed rate within 48 hours of the contract being entered into.
Spot Rate means the exchange rate for settlement within 2 business days from the date the Transaction was booked.
Transaction means a Spot Contract and shall be taken to refer to a series of Transactions pursuant to standing instructions given by you.
We or Us means Novatti Trading FX Pty Ltd (ACN 645 493 161) and Flexewallet Pty Ltd (ACN 164 657 032).
Copyright © 2023 Novatti Group Limited (ASX:NOV) ABN 98 606 556 183. All Rights Reserved.