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Financial Services Disclosure Statement

Introduction

This disclosure document outlines the services I provide, including timeframes, obligations, fees, and other important information you should be aware of before deciding to engage my services or proceed with my financial advice.

 

If you have any questions about the information in this document or would like further clarification on my services, please don’t hesitate to contact me by phone or email.

 

In providing advice to you, I am duty bound to:

  • Give priority to your interests.

  • Exercise care, diligence, and skill.

  • Meet standards of competence, knowledge, and skill set by the Code of Professional Conduct.

  • Meet ethical behaviour, conduct, and client care standards set by the Code of Professional Conduct.

 

Disclosure Information

I, Cody Subritzky am the principal financial adviser for Cody Subritzky Mortgage Brokers Limited, which holds a Financial Advice Provider Licence issued by the Financial Markets Authority. This licence permits me to provide financial advice services to retail clients. The licence is subject to conditions imposed by the FMA, which include maintaining appropriate competence, managing conflicts of interest, and handling complaints fairly.

 

Unless detailed in the Scope of Service, I personalise my advice and recommendations to your specific situation, goals, and needs.

 

Financial Advice Provider (FAP)
Cody Subritzky Mortgage Brokers Ltd

FSP #1005528
Office: The Hub Mall T7, 94 Kerikeri Road, Kerikeri Northland, 0230. 
Website: www.codysubritzky.co.nz
Email: cody@codysubritzky.co.nz

 

Financial Adviser
Cody Subritzky

FSP #1002755
Phone: +64 27 733 2782
Email: cody@codysubritzky.co.nz

 

Services I Provide

  • Life and Health Insurance Advice

    • I provide advice to protect you against financial hardship caused by health events such as premature death, illness or disability.

  • Mortgage Brokering

    • I provide mortgage brokering services to help you purchase NZ residential property and, where applicable, investment property or business lending that is secured by residential property.

  • Investment Advisory

    • I provide advisory services related to complex lending solutions and property investment.

 

Services I Do Not Provide

  • Asset Protection & Estate Planning

  • Tax

  • Legal Advice & Conveyance

  • General Insurance

  • Real estate transactions

 

Suppliers I am Accredited With

  • Life & Health Insurance Providers

    • Fidelity Life

    • Partners Life

    • Asteron Life

    • Nib

  • Lending / Mortgage Providers

    • ASB

    • BNZ

    • ANZ

    • Westpac

    • Kiwi Bank

    • SBS

    • Bank Of China (BOC)

    • Co Op

    • Pepper Money

    • Liberty Finance

    • FinBase

    • Basecorp

 

How I Am Remunerated

  • Insurance Commissions

    • I receive a commission from the insurance provider when a policy arranged by me is issued. Upfront commissions range from 0% to 240%, and ongoing (trail) commissions range from 0% to 30%, depending on the provider. Commissions are based on the net annual premium (excluding GST). No commission or fee is earned on the GST component.

  • Mortgage Commissions

    • I receive a commission from the lender when a loan arranged by me settles. Upfront commissions range from 0.5% to 1%, and trail commissions range from 0% to 0.2%, depending on the lender.

  • Insurance Fees

    • I reserve the right to charge a fee if the insurance policy is cancelled within two years of issuance, triggering a commission clawback. This fee will be up to the value of the clawback, capped at $5,000.

    • I reserve the right to charge a minimum service fee of $1,500 if you request our assistance with an insurance claim on a policy not arranged through me.

  • Mortgage Fees

    • Some non-bank or second-tier lenders do not pay commission. In such cases, I may charge a broker fee of up to 2% of the loan amount.

    • I reserve the right to charge a minimum service fee of $1,500 if I obtain a loan approval aligned with your objectives and you choose not to proceed.

    • I reserve the right to charge a minimum service fee of $1,500 if I arrange a new loan approval with a lender you already have a mortgage with, and no commission is payable to me.

    • I reserve the right to charge a fee if your loan is repaid within three years of settlement, triggering a commission clawback. This fee will be up to the value of the clawback, capped at $5,000.

    • I reserve the right to charge a minimum fee of $500 for top-up loans or restructures on mortgages I have previously arranged.

  • Advisory Fees

    • For investment-related advice, including property investment strategies or complex lending solutions, a service fee may apply.

    • This fee will be quoted based on the specific scope and nature of advice required, and will be outlined at the Scope of Service stage. Work will not commence until the fee is confirmed, accepted and paid by you.

 

Conflicts of Interest

As a financial adviser, I am legally and ethically required to prioritise your best interests when providing advice. In some cases, I may receive commissions or other payments from product providers (such as insurers or lenders) when you proceed with a product I recommend. These commissions are paid by the provider and are not an additional cost to you.

This creates a potential conflict of interest, as I may benefit financially when you choose one product over another. To manage this risk, I take the following steps:

  • I follow a structured advice process based entirely on your needs and goals.

  • I disclose all commissions, fees, and any other incentives upfront before you make a decision.

  • I do not accept soft-dollar incentives such as gifts, events, or travel rewards.

  • I regularly review my advice process to ensure full compliance with the Code of Professional Conduct.

  • I do not share commissions or receive referral fees from any other financial advisers, legal professionals, or external service providers.

  • I charge a fee for service in situations where commission is not payable.

  • If any specific conflict arises during the advice process, I will disclose it immediately and explain how it will be managed.

 

My Advice Process

I am required to follow best practices when providing an advice service. The advice I follow is the internationally accepted Six-Step Advice process:

  1. Establish a client-adviser relationship.

  2. Gather client data and determine goals and expectations.

  3. Analyse and evaluate the client's financial position.

  4. Develop and present advice.

  5. Oversee the implementation of the plan.

  6. Monitor and review the plan.

 

Complaints

If you are not satisfied with the financial advice service received, you can make a complaint using the adviser contact details I provided. When I receive a complaint, I am obliged to consider it following my complaints process. This includes:

  • Letting you know how I intend to resolve your complaint. I may contact you to obtain further information about your complaint.

  • I aim to resolve your complaint within ten working days of receiving it. If that is not possible, I will contact you within that time to let you know I need more time to consider your complaint.

  • I will contact you by phone or email to let you know whether I can resolve your complaint and how I propose to do so.

  • If your complaint cannot be resolved, or you are not satisfied with the proposed resolution, you can contact my independent dispute resolution provider, Financial Services Complaints Limited:

  • www.fscl.org.nz, 0800 347 257, or complaints@fscl.org.nz.

  • FSCL is an independent dispute resolution scheme approved by the Ministry of Consumer Affairs.

 

Your Obligations

To ensure I can provide you with high-quality, tailored advice that is in your best interests, your full cooperation is required throughout the advice process. As my client (or prospective client), you agree to:

  • Provide true, complete, and accurate information about your personal circumstances, including but not limited to:

    • Financial position, income, and liabilities

    • Personal goals, needs, and aspirations

    • Existing insurance policies and benefits

    • Current investments and assets

    • Mortgages, lending arrangements, and other financial commitments

    • Estate planning structures (e.g. wills, trusts, enduring powers of attorney)

    • Criminal history or material legal matters

    • Your health and medical history

    • Lifestyle and pastimes (including any high-risk activities)

    • Any other information reasonably requested to support the advice process

  • Notify me promptly if any of the above information changes or becomes inaccurate during our engagement.

  • Respond to communication and provide requested information in a timely manner. Many aspects of the advice process are time-sensitive and may be affected by delays or inaction.

  • Acknowledge that failure to provide accurate or timely information may limit my ability to provide appropriate advice and may affect the quality and effectiveness of the services delivered.

 

Timeframes

  • Mortgage or insurance reviews typically take several weeks to several months, depending on third-party processing times (e.g. lender approvals or underwriting).

  • If the proposed timing is unsuitable, I can delay your review by mutual agreement.

  • I will highlight any risks associated with delays.

  • If you become unresponsive after reasonable attempts to contact you, I may assume the timing is no longer suitable and close the review by email. You may re-engage with me at any time.

 

Termination of Service

  • If I am partway through a review and you become non-responsive after a reasonable number of follow-ups, we will assume the timing is no longer appropriate and may close the review by email.

  • If you wish to terminate this engagement, you must notify me in writing.

  • I also reserve the right to terminate this agreement at any stage of the review process by providing written notice.

  • Any fees or obligations incurred up to the date of termination will remain payable.

 

Disclaimer & Limitations of Liability

The following limitations of liability apply to the advice and services we provide, to ensure clear expectations.

  • I only provide advice within the agreed scope, as outlined in your Scope of Service document. If you require advice outside of this scope (e.g. legal, tax, or general insurance advice), I may refer you to an appropriate professional.

  • If my services are terminated by either party during the advice or review process, you agree to indemnify us for any actual or potential financial loss or liability resulting from that termination, where such loss was reasonably foreseeable and directly related to the termination.

  • If you fail to provide accurate or timely information, and this results in delays, errors, or financial loss, you agree to indemnify us for any costs reasonably incurred as a result.

  • While I take every reasonable step to explain the potential costs and implications of any advice or product recommended, I am not liable for any unexpected or indirect costs that arise from implementing that advice, including costs charged by third parties.

  • You acknowledge that any decisions made as a result of the financial advice provided are ultimately your responsibility. I do not guarantee the performance or suitability of any product, provider, property, or third-party service.

  • I am not responsible for any delays, errors, or losses caused by third parties (including lenders, insurers, solicitors, valuers, or government agencies), or due to incomplete, inaccurate, or outdated information provided by you.

  • My advice is based on the information you provide at the time of the engagement. If this information is incomplete, materially incorrect, or changes significantly, the advice may no longer be appropriate, and I recommend a review in such circumstances.

  • Any estimates, forecasts, or projections provided are illustrative only and do not constitute a guarantee of financial performance or outcomes.

  • This document, and any advice or documentation provided to you, should not be considered legal, accounting, or tax advice. You are encouraged to seek independent professional advice where appropriate.

 

Privacy Statement

  • I collect personal information about you to provide tailored financial advice and to implement financial solutions. This may include your name, contact details, financial position, health information, and other relevant personal data.

  • Your data is stored securely using a cloud-based CRM protected by two-factor authentication. Only authorised staff can access it.

  • Your information will be retained for seven years from the end of our engagement, in accordance with regulatory obligations.

  • You may request a copy of the information we hold about you or ask for corrections at any time by contacting us.

 

Acceptance

By continuing to engage the services of Cody Subritzky, or by accepting the Scope of Service provided, we agree to the terms outlined in this Disclosure Statement.

  • I/We acknowledge that we have read and understood this Disclosure Statement in full.

  • I/We confirm that we understand and accept the fee structures outlined in this Disclosure Statement, including any applicable fees relating to mortgage approvals, insurance services, clawbacks, and advisory engagements. I/We acknowledge that these fees may be payable in certain circumstances, even if we choose not to proceed or if a commission clawback is incurred.

  • I/We further acknowledge that Cody Subritzky reserves the right to update this Disclosure Statement from time to time. Any updates will be provided to us in writing for our review and acceptance.

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