Privacy & Complaints Policy

Complaints Policy

Westminster National Pty Ltd
ABN 66 102 212 671

Australian Credit License Number: 391520

(Called ‘Westminster National, ‘we’, ‘us’, ‘our’ in this document)

This Credit Guide is dated 19 October 2021

Version 17.0

How to contact us:

Level 1, 1 Alvan Street
Subiaco 6008 WA

PO Box 681
Wembley WA 6913

T: +61 8 6142 6899
F: +61 8 6142 6877
W: www.westminsternational.com.au

Purpose of the Credit Guide?

This Credit Guide (‘Guide’) is an important document. Please read it carefully and ensure that you understand it.

This Guide is designed to provide you with information about us to assist you in deciding whether to use our services and contains information about:

  • who we are;
  • what services we provide;
  • how we are remunerated for services provided to you; and
  • how complaints against us are dealt with.

Who We Are?

Westminster National has been in business since 1980 and during this time has built up an extensive database of lenders from which to source finance. Through our professionalism we maintain excellent relationships with our lenders, the benefits of which are passed on to our clients.

Westminster National’s mission is to ensure our client service is never compromised by our own growth or profit considerations.

What Credit Services are we authorised to Provide?

Through our Australian Credit License, Westminster National is able to provide credit assistance to you in relation to credit contracts.

We are able to provide credit assistance to you when you:

  • apply for a particular credit contract;
  • increase the credit limit on a particular credit contract,
  • remain in your current credit contract;
  • apply for a particular credit contract or increase the credit limit on a particular credit contract with a particular credit provider.

Our Services?

Westminster National meets client needs across diverse industries in the following areas:

  • Commercial & business finance
  • Equipment finance
  • Home & investment loan finance

How We Provide Services to You?

Our process involves talking to you to understand your needs and objectives in seeking credit, as well as understanding your financial position.

Once we have assessed your requirements and obtained the information and documentation we need, we will provide our credit recommendation to you. We are required by law to ensure that any credit product with which we assist you can be deemed “not unsuitable” for you. In simple terms, this means that the product fits your needs and objectives in seeking credit.

We will then provide you with assistance in obtaining the loan from our Panel of Lenders.

Other Documents You May Receive?

Other than this Credit Guide you may receive any or all of the following documents depending on the loan arranged:

  • Fact Finder (Client Needs Analysis)
  • Preliminary Assessment
  • Credit Quote
  • Credit Proposal Disclosure Document
  • Fact Sheet

What Information Should I Provide to Receive Credit Services?

You should provide us with a list of your personal requirements in relation to the credit contract, details of your current financial situation and any relevant information so that we can offer you the most appropriate information. To assist you prepare this information you should complete a Fact Finder document. We will also request information in order to verify the information contained in the Fact Finder, such as pay slips, bank statements, past tax returns and loan schedules.

Panel of Lenders/Credit Providers

We currently have different Panels of Lenders depending on the type of loan arranged for you.

The names of the Lenders in our Panel include:

Commonwealth Bank, ANZ, Westpac, National Australia Bank, Bankwest, Adelaide and Bendigo Bank, AMP, Citibank, Fastlend, ING Direct, Suncorp, Macquarie, Liberty Financial, Pepper, Bluestone, La Trobe Financial, ME Bank, Latitude Finance, MoneyPlace, Better Choice Home Loans, RAMS, Resimac,
Plenti RE Limited, FAST Edge, FASTCustom, FastExcel, Think Tank, 86 400, Firstmac, Heritage Bank, BOQ, Virgin Money, Judo Bank, P&N Bank, Beyond Bank, Teacher’s Mutual Bank, Oak Capital.

Westminster National’s top six lenders by volume for the financial year ended 30 June 2021 were: ANZ 18.08%, CBA 17.31%, Bankwest 15.00%, Westpac 10.77%, NAB 8.85%, and Macquarie 6.54%.

Westminster National operates and manages its own business and pays FAST for aggregation support services including software and access to a panel of lenders. Westminster has access to a panel of lenders through FAST. FAST is part of National Australia Bank (NAB) Ltd. Westminster National has access to products from lenders including NAB and a branded loan (FASTLend) branded with our aggregator, FAST.

How Will I Pay for the Credit Assistance Services Provided?

In some circumstances a fee may be payable depending on the complexity and nature of your situation.

If fees are payable by you they will be detailed in a Credit Quote and not incurred without your prior written consent.

Can I Request a Copy of the Preliminary Credit Assessment?

We maintain a record of all preliminary credit assessments undertaken that assess whether the loan is not unsuitable for your particular circumstances. You can request a copy of the assessment if the request is made within 7 years of your credit contract. We will give you a written copy of the assessment (at no charge to you):

  • Within 7 business days of receiving the request, if your request is made within 2 years of the Credit assessment; or
  • Otherwise, within 21 business days of receiving the request.

We are not required to give you a copy of the assessment if your request is more than 7 years after the date of the credit contract.

What Commissions, Fees or Other Benefits are received by Westminster National?

We will receive payments called commissions from the Credit Provider/Lender. This can be paid in the following manner:

  • Up-front commission;
  • Ongoing trailing commission.

Equipment and Personal Finance

We will receive an up-front commission of between 1.00% and 4.00% (including GST) of the loan amount.

Property Finance

We will receive an upfront commission of between 0.50% and 1.10% (including GST) of the loan balance less the credit balance in a linked offset account and a trail commission of between 0.00% and 0.50% p.a. (including GST) paid on the outstanding monthly balance of the credit contract at the end of each month.

For example, on a credit contract of $100,000 (with nil credit balance in a linked offset), the upfront commission at 0.75% would be $750 and the annual trailing commission at 0.25% would be $250pa (provided that the outstanding monthly balance at the end of each month of the loan remained at $100,000).

Should there be any other rewards proposed (financial or otherwise); this will be disclosed to you in the Credit Proposal Disclosure Document.

We receive services to support the broking services we give you with mortgage aggregation services received from FAST and equipment finance aggregation services provided by IFBA Pty Ltd. Any fees payable to these service providers are deducted from our commissions and are not payable by you.

Referral Fees

In some cases, your business may have been referred to us by non-regulated third parties such as real estate agents, accountants, financial planners etc. Where this is the case we may pay a referral fee to these parties. If we do pay a fee to these parties then we will disclose the actual fee in our Credit Proposal Disclosure Document that we will provide to you.

What if you are not happy with our services?

At Westminster National, we always work hard to build strong and lasting relationships with our customers. By listening to your feedback, not only can we address any immediate concerns you may have, we will also continually improve our services.

If you have a complaint or concern about the service provided to you, please contact our Complaints Officer. Once we receive your complaint, we will investigate the matter and endeavor to address it as quickly as possible.

Please contact:

Complaints Officer
Westminster National
PO Box 681
Wembley WA 6913

Tel: + 61 8 6142 6899
Fax: + 61 8 6142 6877
Email: justinb@wfb.com.au
Website: www.westminsternational.com.au

We expect that we will be able to completely resolve any issues you raise. If, despite our best efforts, you believe your complaint has not been satisfactorily dealt with, or if you have not received a response within 30 days, you may wish to refer your complaint to our External Dispute Resolution Scheme.

You can contact the Australian Financial Complaints Authority at:

GPO Box 3, Melbourne, Victoria, 3001
T 1800 931 678 W: www.afca.org.au

Privacy

Collection and use of your information

Westminster National and its representatives will only seek to collect necessary information from you in order to provide you with the credit assistance you have sought from us. We may also use this information for purposes associated with our services such as follow-up calls to assist you.

In some cases, we may seek to collect credit information about you. If we do this, it will only be from an Australian Credit Reporting Body and only with your consent, which we will ask you to provide by signing an appropriate consent form.

You can learn more about the Privacy Act and your rights at www.privacy.gov.au

Disclosure of personal information

Westminster National and its representatives will never unnecessarily exchange your personal or business information with any third party for any reason, unless compelled by force of law. In order to assist you, we may be required to provide your personal information to certain organisations. If your information is not provided, we may be unable to assist you.

The types of organisations include:

  • Lenders
  • Mortgage insurers
  • Aggregators
  • Other mortgage intermediaries
  • Valuers
  • Overseas organisations in India and Philippines
  • Other organisations that assist us such as printers, mailing houses, lawyers, debt collectors, accountants and auditors.

Access and alterations to your personal information

You can gain access to your personal or company information or advise alterations to that information by contacting our office:

Contact Person: Justin Bird
Address: Level 1, 1 Alvan Street, Subiaco WA 6008
Email: justinb@wfb.com.au

Information which is easily accessible will be provided to you free of charge. However, information which is more difficult to access may have a fee associated with the request. You can also contact us for more detailed information on how we collect, handle and secure your personal information.

Marketing

From time to time, Westminster National may contact you with information about products from either ourselves or our industry affiliates that we believe may interest you. To opt-out of receiving such information, simply let us know by contacting us directly using the office details above.

Security of your personal information

Westminster National takes reasonable steps to ensure the security of your personal or company information from unauthorised access, theft or modification.

Feedback on the handling of your personal information

Should you be unsatisfied in the manner in which Westminster National has handled your personal information please contact us (per details listed above). We will take all necessary steps to investigate and address your concerns. If the issue you have raised is not resolved to your satisfaction you should contact the Office of the Australian Information Commissioner:

Ph: 1300 363 992
E: enquiries@oaic.gov.au
Mail: GPO Box 5218
SYDNEY NSW 2001

AML/CTF Act 2006

In accordance with the Anti-Money Laundering and Counter Terrorism Financing Act 2006 you are required to provide such documents as the lender requires to confirm your identification at the time of becoming a customer. Westminster National will collect and provide this information to the lender.

Authorisation

Westminster National seeks to gain credit information about you from a Credit Reporting Body (CRB). We may use this information in the course of providing credit assistance to you. By signing the form below, you appoint us as your agent to act as an “access seeker” and obtain your credit information on your behalf.

If you do not consent to us doing this, do not sign the form below. However, if you do not sign the consent, we may be unable to provide credit assistance or other services to you.

This consent form is intended to be read in conjunction with our Privacy Policy available on our website.

I hereby appoint Westminster National as my Agent for the purpose of obtaining my credit information from a CRB.

Privacy Policy

About this Privacy Policy

This Privacy Policy has been published to provide a clear and concise outline of how and when personal information is collected, disclosed, used, stored and otherwise handled by Westminster National Pty Ltd ACN 102 212 671 and its related entities (‘the Group’). The Policy relates to personal information collected by any means and by any technology.

By using the Group’s website, products or services, you consent to the Groupusing your personal information as set out in this Privacy Policy.

The Grouptreats the handling of your personal information very seriously. To that end, it has systems and procedures in place to protect your privacy in relation to the handling of your personal information.

The Group’s objective is to handle information responsibly and provide you with some control over the way information about you is handled and stored.

Our Commitment to Protect Your Privacy

We recognise that any personal information we collect about you will only be used for the purposes we have collected it or as allowed under the law. It is important to us that you are confident that any information we hold about you will be treated in a way which ensures protection of that information.

Our commitment in respect of your information is to abide by the Australian Privacy Principles,as set out in the Privacy Act 1988 (Cth) and other relevant law.

Personal Information

When we refer to personal information we mean information from which your identity is reasonably apparent. This information may include information or an opinion about you. The personal information we hold about you will also include credit information.

Credit information is information which is used to assess your eligibility to be provided with finance and may include any finance that you have outstanding, your repayment history in respect of those loans, and any defaults. Usually, credit information is exchanged between credit and finance providers and credit reporting bodies.

The kinds of personal information we collect about you includes your name, date of birth, address, occupation, and any other information we made need to identify you.

If you are applying for finance we may also collect the ages and number of your dependants and cohabitants, the length of time at your current address, your employment details and proof of earnings and expenses.

Why We Collect Your Personal Information

We collect personal information for the purposes of assessing your application for finance and managing that finance. We may also collect your personal information for the purposes of direct marketing and managing our relationship with you. From time to time we may offer you other products and services.

To enable us to maintain a business relationship with you, we will disclose your personal information to other organisations that provide products or services used by us.

How Do We Collect Your Personal Information?

Where reasonable and practical we will collect your personal information directly from you. We may also collect your personal information from other financial institutions, your employer, accountant, real estate agent and lawyer.

Website

As well as collecting information such as contact and address details, our website also records traffic statistics such as the number of visitors to our site, the date and the time of the visits, the numbers of pages viewed, etc. These details are primarily used for optimising our site and its performance. Any details recorded are anonymous and we cannot link your identity to these statistics.

Do We Disclose Your Personal Information?

We may disclose your personal information:

  • to prospective financiers or other intermediaries in relation to your finance requirements;
  • to other organisations that are involved in managing or administering your finance such as third party suppliers, printing and postal services;
  • to companies that provide infrastructure systems to us;
  • to anybody who represents you, such as financial institutions, real estate agents, lawyers and accountants;
  • to anyone, where you have provided us consent;
  • where we are required to do so by law, such as under the Anti-Money or Laundering and Courter Terrorism Financing Act 2006 (Cth); or
  • to your employer, referees or identity verification services.

Prior to disclosing any of your personal information to another person or organisation, we will take all reasonable steps to satisfy ourselves that:

(a) the person or organisation has a commitment to protecting your personal information at least equal to our commitment, or

(b)you have consented to us making the disclosure.

Direct Marketing

From time to time we may use your personal information to provide you with current information about finance, offers you may find of interest, changes to our organisation, or new products or services being offered by us.

If you do not wish to receive marketing information, you may at any time decline to receive such information by emailing us at justinb@wfb.com.au. If the direct marketing is by email you may also use the unsubscribe function. We will not charge you for giving effect to your request and will take all reasonable steps to meet your request at the earliest possible opportunity.

Updating Your Personal Information

It is important to us that the personal information we hold about you is accurate and up to date. During the course of our relationship with you we may ask you to inform us if any of your personal information has changed. If you wish to make any changes to your personal information, please contact us. We will generally rely on you to ensure the information we hold about you is accurate or complete.

Access and Correction to Your Personal Information

We will provide you with access to the personal information we hold about you. You may request access to any of the personal information we hold about you at any time. We may charge a fee for our costs of retrieving and supplying the information to you, depending on its location and volume.

Depending on the type of request that you make we will usually respond to you within 14 days of receiving your request. We may need to contact other entities to properly investigate your request.

There may be situations where we are not required to provide you with access to your personal information, for example, if the information relates to existing or anticipated legal proceedings, or if your request is vexatious. An explanation will be provided to you if we deny you access to the personal information we hold about you.

If any of the personal information we hold about you is incorrect, inaccurate or out of date you may request that we correct the information. If appropriate we will correct the information. At the time of the request, otherwise, we will provide an initial response to you within 7 days of receiving your request. Where reasonable, and after our investigation, we will provide you with details about whether we have corrected the personal information within 30 days. If we refuse to correct personal information we will provide you with our reasons.

Using Government Identifiers

If we collect government identifiers, such as your tax file number, we do not use or disclose this information other than required by law. We will never use a government identifier in order to identify you.

Business Without Identifying You

In most circumstances it will be necessary for us to identify you in order to successfully do business with you, however, where it is lawful and practicable to do so, we will offer you the opportunity of doing business with us without providing us with personal information, for example, if you make general inquiries about interest rates.

Sensitive Information

Sensitive information is personal information that includes information relating to your racial or ethnic origin, political persuasion, memberships in trade or professional associations or trade unions, sexual preferences, criminal record, or health. At this time we do not collect any sensitive information.

How Safe and Secure is Your Personal Information that We Hold?

We will take reasonable steps to protect your personal information by storing it in a secure environment. We may store your personal information in paper and / or electronic form. We will also take reasonable steps to protect any personal information from misuse, loss and unauthorised access, modification or disclosure.

Complaints

If you are dissatisfied with how we have dealt with your personal information, or you have a complaint about our compliance with the Privacy Act, you may contact our Dispute Resolution Officer:

Address: PO Box 681, Wembley WA 6913
T: + 61 8 6142 6899
F: + 61 8 6142 6877
Email: justinb@wfb.com.au

We will acknowledge your complaint within 7 days. We will provide you with a decision on your complaint within 30 days.

Where we are unable to resolve your complaint or 45 days have elapsed, you may contact theCredit and Investments Ombudsman Service (‘CIO’).

Westminster National is a member of CIO and their services are available free of charge at:

Address: PO Box A252, ydney South NSW 1235
T: 1800 138 422
W: www.cio.org.au

If you believe the Group has not adequately dealt with your complaint and you are not satisfied with IO, you may also complain to the Officer of the Australian Information Commissioner (OAIC) whose contact details are as follows:

Address: GPO Box 5218, Sydney NSW 2001
T: 1300 363 992
Email: enquiries@oaic.gov.au

Links to Other Websites

When you access a link from the Group website to the website of a third party, those sites are not subject to the Group’s Privacy Policy. Those third parties are responsible for informing you of their own privacy standards.

Privacy Officer’s Contact Details

You may request further information about the way we manage your personal information by contacting us. Please address all written correspondence to:

Address: Privacy Officer, PO Box 681, Wembley WA 6913
T: + 61 8 6142 6899
F: + 61 8 6142 6877
Email: justinb@wfb.com.au

Changes to Our Privacy Policy

We may, without notice, amend this Policy from time to time for any reason and will update the Policy accordingly. We ask that you visit our website periodically in order to remain up to date with such changes. We are constantly reviewing all of our policies and attempt to keep up to date with market expectations. Technology is constantly changing, as is the law and market place practices. As a consequence we may change this privacy policy from time to time or as the need arises.

You may request a copy of this Privacy Policy in an alternative form.