Financial Services Guide
Effective date: 1st January, 2023
Table of contents:
- The purpose of this FSG
- What other disclosure documents and statements will I receive?
- Who are we and what services do we provide?
- Details of Associations or Relationships
- What are our responsibilities and what type of advice do we give?
- How you may instruct us
- Opt – in partner offers
- How we are paid
- Referral payments
- Referral fees example
- How do Douugh people and related third parties get paid?
- Platform and transaction fees
- Other Administrative fees - DriveWealth
- Complaints and Disputes
- Compensation Arrangements
This Financial Services Guide (FSG) is provided to you by Douugh Australia Ltd ABN 76 617 000 138, Australian Financial Services Licence (AFSL) number 500063 (Douugh, us, our). You may contact us as email@example.com, or online at https://douugh.com/au.
The purpose of this FSG
The purpose of this FSG is to inform you of the financial services that we are able to provide, and to assist you in deciding whether to use any of our services. It seeks to explain:
who we are;
what financial services we provide and the financial products to which those services relate;
what our responsibilities are and what type of advice we give;
how you can instruct us;
what you can expect to pay for the financial services;
what remuneration and other benefits may be paid to us, our employees or others;
what to do if you have a complaint, and how it will be dealt with;
for what purpose we use your contact data; and
how you can contact us.
This FSG contains only general information about the services we offer. If you still have any questions after reading this FSG, please contact us. Our contact appears above.
What other disclosure documents and statements will I receive?
You will not be provided with any personal financial product advice from Douugh. Any advice or information we provide to you is general advice only and does not take into account your personal objectives, financial situations or needs. It is up to you to decide whether or not you want to use our services, and if you need assistance or advice in this regard, you should consult a suitably qualified financial adviser. You will not receive a Statement of Advice from Douugh.
Generally, where we arrange for the issue of a financial product to you, you will receive a Product Disclosure Statement (PDS) or other relevant disclosure documents that include information about the product so that you can make an informed decision whether to acquire the product. It would include any relevant terms, significant risks and costs associated with the supply of that financial product.
Who are we and what services do we provide?
We are authorised to provide general financial product advice about securities and basic deposit products. We are also authorised to deal in a financial product by arranging for another person to apply for, acquire, vary or dispose of securities, basic deposit products, and foreign exchange contracts. Our authorisation cover both retail and wholesale clients.
We can offer you factual market data and information, including general advice, regarding those products and services our authorisation permits us to provide. The products on which we may provide this information include:
holding deposits in a Client Segregated Account;
securities, funds and trusts traded on the local exchange; and
community data, reviews and third party analyst opinion.
You may be offered opt – in access to third party partner products, such as Bundles, superannuation, banking and other financial and non – financial products and services. Douugh offers no opinion, nor recommendation as to the quality or appropriateness of these products. Selection of partner products and services to offer is made based on the sustainable and responsible nature of that product and its alignment to the Douugh purpose.
Douugh provides Eligible Customers with the ability to research Stocks, Exchange Traded Funds (ETFs) and to purchase selected Stocks and ETFs listed on United States stock exchanges, including parts (fractions) of whole shares through the Investing app.
Details of Associations or Relationships
Douugh has a relationship with each of DriveWealth LLC (Drivewealth), OFX, Zepto and Basiq all of whom provide services directly to you in order for you to access our services. These relationships in no way influence the provision of financial services by Douugh to you.
With Douugh you can invest in US listed securities by way of funding your Trading Account, via direct debit. Funds can be used immediately to place Buy Orders. These orders will be placed using ‘Buying Power’ issued by our broker partner, DriveWealth.
Should you wish to commence trading activities via Douugh, you agree to commence the application process for a:
DriveWealth, US brokerage account; and
OzForex Limited, trading as OFX account.
Douugh has entered into an Introducing Broker Agreement with DriveWealth,. DriveWealth provides execution and clearing services to you, the customer. Your identity will be disclosed to DriveWealth, so that DriveWealth can enter into a broking agreement with you.
What are our responsibilities and what type of advice do we give?
We provide general advice and information regarding financial products and services that can be dealt in through us. This information or advice does not take into account your personal and financial circumstances, needs and objectives and because of that you should, before acting on the advice, consider the appropriateness of the advice having regard to your personal and financial circumstances, needs and objectives.
It should be noted that if you open an account with us you will also be requested to provide some information relating to your financial circumstances. This information is collected so that we can:
receive some reassurance that you will be able to finance any trading that you enter into; and
identify who you are as required by the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AMLCTF Act 2006).
How you may instruct us
You can get in touch with us through the contact details at the top of this FSG.
If you wish to execute a transaction, you can do so through our app. When you do this, you will be subject to our Terms of Service, which are available on our website. An instruction to fund or withdraw from your cash account will require a conversion between AUD and USD based on the FX rate provided in the app by our FX providers OFX.
Opt – in partner offers
From time to time, users of Douugh will be offered access to partner offers and partner products. In some instances, Douugh may receive referral or affiliate fees from these third parties. Opting – in, unless otherwise specified, will authorise Douugh to share personal information with the third-party provider for the sole purpose of that provider being able to provide product and services to you.
Douugh makes no recommendation or statement, and offers no opinion on the fees, performance or quality of third-party products. Douugh does not show offers the market. Please ensure that you read the appropriate product disclosure before deciding to take up any product.
Douugh retains the right to add, change or discontinue any third part offers at any time.
How we are paid
We aim to keep cost simple and transparent and we will update this FSG from time to time to reflect any changes in fees and charges. Please refer to the Platform and Transaction fees below for details.
Douugh may also receive referral and / or affiliate payments from third party providers should you opt – in to a third party offered product or service. These fees will vary dependant on the commercial relationships between parties and the level of service being provided.
Referral fees example
Douugh customer opts – in to a third party superannuation product made available by Douugh via email.
Douugh receives a payment from the third party upon opt – in e.g. via a link click.
Douugh receives an additional payment from the third party on full account creation with third party provider.
Douugh receives an additional payment from the third party on funding of the superannuation account.
Our directors and employees who provide the financial services described in this FSG are remunerated by way of salary and other employee benefits. They may also be eligible for a discretionary bonus, or with other monetary or non-monetary benefits. The value of any such bonus arrangement or benefit is unascertainable, and is structured to minimise potential conflicts of interest. For example, the bonus may be linked to an innovative idea or positive customer compliments management.
We may pay a referral fee or (with your consent) a percentage of your membership fee to third party referrers. The amount of any such payment is unascertainable.
We don’t make payments to other parties, other than service providers for the supply of services to us.
You may request further details of the fees and benefits (including any commissions) that may be payable at any time by contacting us within a reasonable time after you are given (or access) this FSG and before we provide any financial services to you.
Platform and transaction fees
$2.99 per 28 days
Plan fees are charged upon take up of the Portfolio products in the Douugh app. They are charged on a monthly basis on accounts with balances over $50. Fees are charged every 28 days. Plan fees will apply to any account where the balance was above $50 at any point during the 28 day cycle. Plan fees apply to “portfolios” and are charged separately to Single and Autopilot trades.
Trades (inc. AutoPilot trades)
$2.99 per 28 days.
If a customer Buys or Sells any security with Douugh, either as a one off trade or under an AutoInvest instruction established in AutoPilot controls, a single fee of $2.99 will be charged. This fee applies to a single or multiple trades placed within the 28 day trading cycle. Fees are charged every 28 days. This does not include instructions placed on “Portfolios''
Instant funding provides access to USD funds for the purpose of trading immediately after the confirmation of the deposit funding request, or the funds have been received by us, depending on the selected payment method.
US Tax Form Completion
Upon establishing a Trading Account with Douugh, a digital W8-Ben form (US Tax treaty document) is completed on your behalf. The fee is charged to customers on completion of this digital form.
Other trading fees
Buy side fees:
ADRs - $0.01 - $0.03 per share, per trade
American Depository Receipts (ADRs), are basically stocks in non-US companies that trade in the U.S. They are subject to periodic fees that are intended to compensate the agent bank that is providing custodial services on behalf of the ADR. These fees are levied on the holder of the ADR, i.e. you as the investor. Please refer to the prospectus for the ADR for information on the ADR Fee.
Sell Side fees:
SEC Fee, of $0.0000051 per $1 of sales proceeds, rounded to the nearest cent.
TAF Fee, (sell side only): $0.000119
per share, rounded to the nearest cent.
When trading on the US share market there are regulatory fees when selling shares and are levied independent of your brokerage costs.
Foreign Exchange (FX) Margin
A fee of 0.99% is included in the quoted FX rate when converting money between AUD & USD. This is a fee charged by our FX provider, OFX.
Investment platforms commonly charge you a fee called a ‘spread’ when they transfer money from one currency to another. This commonly ranges from 1.0% – 1.5% of the total funds transferred.
Douugh has entered into a revenue share agreement with OFX and receives a percentage of the fee charged by OFX. Douugh will receive a revenue share of 0.4 on a quoted FX rate of 0.99.
Portfolio transfers in from other brokers
ACATS – Free
DTC – Free
Through our broker DriveWealth accepts both ACATS and DTC incoming transfers.
Portfolio transfers out to other brokers
$200 per account on both ACATs or DTC. DTC transfer includes up to 4 positions.
Additional position on DTC will be charged at $50 per position.
Brokers either accept transfers via the ACATS or DTC System.
Please check with your broker to understand what the charges are. A sufficient cash balance is required in your Douugh account to commence the transfer.
$0.01 - $0.03 per share per quarter
This fee is to pass on the costs incurred by Douugh for compensating the agent bank that is providing custodial services on behalf of the ADR.
Direct Debit Failure Fee
$15.00 per failed transaction
You may be charged a Direct Debit dishonor fee should your direct debit fail due to providing incorrect bank details or having insufficient available funds. Or any other issue that causes the direct debit to fail, dishonor or be returned unpaid.
Note that Direct debits will not be accepted from savings or high interest-bearing accounts. If you provide savings account details which results in the direct debit being dishonored, you may be charged a dishonor fee.
There is no interest currently earned on the client trust account but Douugh retains the total interest, if any, earned on its client trust account balance. The interest rates are set by the partner (currently Zepto Payments Pty Ltd c/o Cuscal Payments Pty Ltd) and DriveWealth based on the applied money market provider and rate.
Other Administrative fees - DriveWealth
Other administrative fees may be applied by DriveWealth, our broker partner, on certain events. These events are ad hoc and must be via direct request to Douugh, or to DriveWealth.
Typically, these fees are charged to Douugh, not you as the customer. You will be notified of any fees before the request is complete.
Complaints and Disputes
If you are unhappy with our service and wish to make a complaint, Douugh has a formalised client complaint resolution procedure. All complaints are reviewed and investigated by the Chief Complaints Officer and we advise you of the outcome by phone or in writing.
The Chief Complaints Officer can be contacted by email at enquiries@Douugh.com. If you make a complaint, our first response will be to contact you to discuss the complaint and to register a formal record of such complaint. We will try to resolve your complaint quickly and fairly.
If, despite our best efforts, you believe your complaint has not been satisfactorily dealt with or you are not satisfied with our response after 45 days, you may lodge a dispute with The Australian Financial Complaints Authority (AFCA).
You can contact AFCA by writing to:
The Australian Financial Complaints Authority
GPO Box 3, Melbourne VIC 3001
You may also wish to contact ASIC to discuss your complaint and/or your concerns. You can contact ASIC on its free call Infoline 1300 300 630.
Douugh holds Professional Indemnity Insurance cover for the activities conducted under its AFS Licence and continues to maintain Professional Indemnity Insurance that generally satisfies the requirements of s912B of the Corporations Act 2001 and Regulatory Guide RG126.