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Financial Services Guide Financial Services Guide You have the right to ask us about our charges, the type of advice we will give you, and what you can do if you have a complaint about our services. Everforex is a leading foreign exchange and money transfer services providers ofering on-site and online currency exchanging and trading. Small Business Hub Sharing tips, ideas and advice to help grow your small business. Binary options providers make it easier for traders to receive more on your investment making call and put options. The following list shows you to spelling mistakes possible of the internet users for the website searched superforex. Furthermore, this broker provides PAMM system for customer who prefer their accounts to be managed by experienced traders managers. However, there is no choice of trading platforms, and what is most important — forex broker regulation in Belize is quite loose.

Super Forex Financial Pty Ltd (ABN 42 ) (‘Superforex’) is regulated in Australia by ASIC. Australian Financial Services Licence Member of the Financial Ombudsman Service.

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NIBA has not identified any concerns with this proposal. Proposal 8 Exclude disputes about rating factors and weightings used to determine excess or policy conditions as well as the base premium. Proposal 9 Require Applicants being assisted by a fee-for-service agent to provide any required information at the time they lodge a dispute. Proposal 11 Give FOS the discretion to allow an FSP to sell an asset the subject of a dispute as well as or instead of other action to preserve it.

Proposal 13 Index the current compensation caps in accordance with the current paragraph 9. This is a format change, rather than a change to the content of the TOR.

The format change will make clearer which compensation caps will apply to disputes lodged at different times. NIBA supports this proposal. Proposal 14 Consider increasing and indexing the jurisdictional limit as recommended by the Senate Committee Recommendation 6. NIBA makes no comment on this proposal. If you would like to discuss any aspect of this matter further do not hesitate to contact us. Although Adjudicators will share similar powers to that of an Ombudsman, their authority will be limited to issuing Determinations and Jurisdictional Decisions on simpler, lower value disputes that will be considered under the proposed streamlined process.

The Chief Ombudsman will set limits on the scope of Adjudicators powers based on FOS s experience with the streamlined process over time. This is intended to expedite the complaint resolution process and NIBA supports such a process subject to the persons appointed as Adjudicators having the requisite experience to appropriately make binding determinations.

In effect industry is left to trust the decision of the Chief Ombudsman and has no say in any changes that may be made from time to time. This may create some inconsistency in decision making and the low value threshold of disputes to be determined by Adjudicators should be set out in the TOR document with an ability to amend after appropriate consultation with relevant stakeholders. We note that FOS has stated that it will provide clear guidance on specific timeframes 7. FOS has not yet provided any details of the proposed timeframes for resolving the dispute, these should be provided and included in the consultation pack before these changes are agreed to so that an informed decision about the impact of the changes can be made.

Amendments to clause 5. The amendments to clause 7. FOS should provide details of when it will consider it appropriate to reduce timeframes in these circumstances so an informed decision can be made in relation to the proposed changes. FOS applies has a different jurisdiction for General Insurance Brokers than it does for insurers and intermediaries that are not General Insurance Brokers. A General Insurance Broker is effectively defined as an Australian Financial Services Licensee that has the insurance broker condition in relation to general insurance.

For brokers it is defined to cover the Corporations Act retail client products and any other covers built into a product containing retail cover other than Excluded Products. A Small Business Insurance Product means one thing for General Insurance Broker disputes and another for non-general insurance broker disputes ie those with insurers 9.

It catches such brokers whether acting for the client or for the insurer. For General Insurance Brokers a Small Business Insurance Product is currently limited to small business disputes relating to Retail General Insurance Policies for brokers this is defined to cover the Corporations Act retail client products and any other covers built into a product containing retail cover other than Excluded Products.

FOS is extending its terms to all products ie it will now include all wholesale types not only if part of a package, including a retail type which is broader than the coverage applicable to insurers and non-general insurance broker intermediaries. Excluded Product means a product that is not a financial product for the purposes of Part 7. The above creates significant unfair playing field between Insurance Broker licensees and non-insurance broker licensees which is inappropriate.

This is clearly inappropriate and has not been identified or considered by FOS. In addition to the above, we are not aware of FOS having directly consulted with professional indemnity insurers or NIBA about the impact of such an expansion of jurisdiction. For example, any policy with a FOS aggregate limit will be affected by the change exposing the insurance broker to an unexpected exposure.

In addition, the change may also have an impact on whether the professional indemnity insurance of an insurance broker continues to meet the ASIC compensation requirements and the ultimate cost of such insurance given the increased coverage.

The proposed changes are as a result of the recommendations made in the Independent Review of FOS. FOS will engage with stakeholders with the view to amending its Terms of Reference and expanding its jurisdiction to deal with these disputes.

The review ignored the fact that the IBD jurisdiction was not followed for a number of reasons: NIBA notes that there is no evidence or reasoning provided in support of the proposed change beyond the fact it is different to the old IBD scheme. NIBA opposes the changes and requests that FOS provide evidence for the need for such an extension, especially where the FOS jurisdiction is principally intended to focus on retail client business the reason insurance brokers must belong to FOS in the first place.

For example, what evidence does FOS have of any consumer detriment that has arisen by reason of the current scope of coverage and the number of complaints refused within this range to support its reasoning for seeking an increase in this scope and limit. Is there a reason FOS is adopting a process which is inconsistent with the good regulation practices the current Government is seeking to follow?

Technically the obligation is to join an EDR scheme that covers complaints against the licensee made by For insurers and their non-insurance broker agents a change will be made from 1 January and is: FOS propose that exceptional circumstances may exist in the following circumstances: The issues in dispute are analogous to those FOS normally deals with, and The Applicant would be disadvantaged by pursuing the Dispute in a more traditional forum, such as the Courts.

Accordingly, a claim being denied on one of these bases should be dealt with by FOS if the Applicant is disadvantaged pursuing the Dispute in a more traditional forum.

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