Product Disclosure Statement
Last updated: 21 March 2024
This Product Disclosure Statement (“PDS“) has been prepared and issued by Paynow Technology Pty Ltd trading as Finmo Tech ACN 642 442 215 (“Finmo”, “us” “we” or “our”). Paynow Technology Pty Ltd trading as Finmo Tech is a subsidiary of Finmo Tech Pte Ltd, which (together with its subsidiaries globally) operates the “Finmo” brand.
Please note that the information contained in this PDS does not constitute a recommendation, advice or opinion, and does not take into account your individual objectives, financial situation, needs or circumstances.
This is an important document and should be read in its entirety (along with the Finmo Terms and Conditions – available at https://finmo.net/terms-conditions, or an electronic copy can be provided by us free of charge upon request). Before acquiring any product offered under this PDS, you should ensure this is appropriate for your particular financial objectives, needs and circumstances.
If you acquire any of the products described in this PDS, you will be bound by the contents of this PDS and the Terms and Conditions.
The information in this PDS is current as at the date set forth on the cover page, and may be updated from time to time where that information is not materially adverse to clients. Updated information shall be provided on our website – accessible at https://finmo.net/. Finmo may issue a supplementary or replacement PDS as a result of certain changes, which shall be available on our website or shall be distributed in electronic form as required.
This PDS does not constitute an offer or invitation in any place outside Australia where or to any person to whom it would be unlawful to make such an offer or invitation. The distribution of this PDS (electronically or otherwise) in any jurisdiction outside Australia may be restricted by law and persons who come into possession of this PDS should seek advice on and observe any such restrictions. Any failure to comply with such restrictions may constitute a violation of applicable law.
If you received this PDS electronically, we can provide a paper copy free of charge upon request.
Purpose and contents of this PDS
This PDS is an important legal document and is designed to provide you with important information regarding our products and services, including the following information:who we are
how you can contact us
which products we are authorised to offer or utilise
key features/risk/benefits of these products
applicable fees and charges for these products
any (potential) conflicts of interest we may have, and
our internal and external dispute resolution process
Informed Choices
The information in this PDS should assist you to:decide if the product meets your needs, and
compare the product with similar products
Essential Reading
If you intend to apply to use any of the products and services described in this PDS, please read and make sure you understand this PDS, our Terms and Conditions, Privacy Notice, and Financial Services Guide (“FSG”), which are accessible via our website. These documents contain important information regarding the features, benefits, risks and fees applicable, and are designed to assist you in making an informed decision about whether to use our products and services. If you have any questions or need more information, please contact us.All financial amounts mentioned in this PDS are expressed in Australian dollars unless otherwise stated. Unless defined herein, capitalised words used in this PDS have defined meanings which appear in the Glossary at the back of this PDS.
About Finmo
Finmo holds an Australian Financial Services Licence Number 535371 and is authorised to provide financial services relating to its non-cash payment product (NCP) to both retail and wholesale clients.You can contact us at:
Address: 162, 202 Victoria Road, Drummoyne NSW 2047
Email: compliance@finmo.net
Website: www.finmo.net
General product description
The financial products provided by Finmo include facilities for businesses to send (i.e. Payout) and receive (i.e. Payin) money (collectively, the “Services”).
Services
Key Features
Payouts
Payout lets you send money in any Supported Currency to beneficiaries in Australia or any other jurisdiction approved by Finmo. The transaction can be funded from your Available Balance or any other supported payment methods from time to time.
To payout money to a beneficiary, you will need to provide an instruction in accordance with the process described in the Terms and Conditions.
Payin
Payin lets you:
Top up the Available Balance in a Supported Currency through a bank transfer from your own bank account to the Finmo Account, or any other supported payment methods from time to time. The money received will be added to your Available Balance and held in the Account in the Supported Currency.
Payin funds in a Supported Currency into the Account from a third party payer in Australia or any other jurisdiction approved by Finmo. You will need to provide the third party payer with the Account details. The money received will be added to your Available Balance and held in the Account in the Supported Currency.
Hold money in any Supported Currencies.
Multiple Supported Currencies
Multiple Supported Currencies can be held in the Account and form your Available Balance. You can convert any currency forming part of your Available Balance for another Supported Currency by providing an instruction to Finmo via the Finmo Platform.
The Available Balance can be accessed or withdrawn in accordance with the process described in the Terms and Conditions.
It is important for you to understand that the Account is not a bank account, and is instead a non-cash payment (NCP) facility.
Account Interest Details
When Finmo receives funds that are credited to the Available Balance you acquire an interest in (or an increased interest in) a non-cash payment facility (being the Account). Those funds are therefore not monies which are subject to the client money protections in the Corporations Act 2001 (Cth).
Accessing and using our products and services
To access and use our Services, you must first register for an Account via the Finmo Platform, which is accessible via our website. By registering for an Account, you agree to the terms in our Terms and Conditions, Privacy Notice, the FSG, and this PDS. Your application for an Account must be approved by Finmo. Finmo reserves the right to refuse to open an Account for any person.
Eligibility
To be eligible for the Services you must meet the eligibility criteria Finmo sets out in the Terms and Conditions. Your application for a Service must be approved by Finmo. Finmo reserves the right to refuse to provide a Service to any person.
Significant benefits
The significant benefits of the Services are as follows:You can use Payin to load (or reload) value onto your Available Balance, in any Supported Currency, by initiating a transfer from your bank account or through any other means notified described in the Terms and Conditions. You can also use Payin to collect and hold money in any Supported Currency from a third party payer in Australia or any other jurisdiction approved by Finmo, into your Account. This reduces the need for you to open bank accounts in multiple jurisdictions.
You can use Payout to transfer money in any Supported Currency to beneficiaries in Australia or any other jurisdictions approved by Finmo.
Finmo bases all of its FX quotes on the live interbank FX rate and adds a transparent mutually agreed-upon FX markup.
Significant risks
In deciding whether or not to use the Services you should be aware of the significant risks set out below. However, this section does not purport to disclose all of the risks associated with the Services.A Payout or Payin transaction will not be processed if the transaction is not in a Supported Currency and the beneficiary or payer (as the case may be) is not located in a jurisdiction approved by Finmo.
There may be circumstances beyond our reasonable control preventing a transaction from being processed.
You might not be able to get your money back if Unauthorised Transactions or unintended transactions occur.
No interest is earned on the Available Balance and it is not a savings or checking account.
There is a risk that Finmo may become unable to fulfil its obligations to you as they fall due, for example, if our banking partners fail to meet their contractual obligations to us or in the event Finmo experiences insolvency. This is known as counterparty (or credit) risk. If this happens, you may not be able to use the Services as designed and this could result in a loss.
There is a risk of loss resulting from failures, delays, or inadequacies of technological systems, internal processes or external events. This is known as operational risk. While Finmo uses reasonable efforts to ensure uninterrupted access to the Services, it cannot guarantee that such access will never be interrupted as a result of technical or other unforeseen problems that are outside its control. There are also risks associated with the use of an online platform to process transactions, such as network connectivity issues, system or software errors and bugs, and security or data breaches.
Finmo relies on arrangements with banking partners to deliver the Services. Finmo banking partners may make errors or experience unscheduled delays in crediting funds to the Account or transferring them to another account.
Advice
We are obliged to warn you that we will only provide you with general advice, which does not take account of your objectives, financial situation or needs.
Fees and Charges
The following fees apply in connection with the use of the Services. You agree that whenever any of these fees are incurred or become payable, Finmo may deduct it from your Available Balance.
Transaction fees: Transaction fees are payable on each Payout end and Payin transaction. The fees you pay will vary based on the source and destination currencies and countries of the transaction, the size and frequency of your transaction, and the payment method used in the transaction. The exact fee applicable for each transaction will be disclosed to you on the Finmo Platform as well as in the Merchant Services Agreement (MSA) signed with us at onboarding.
Foreign exchange charges: Where currency conversion is required in respect of any transaction, Finmo will apply the prevailing exchange rate disclosed to you on the Finmo Platform which includes a percentage earned by Finmo.
Other fees and charges: You may also incur fees or bank charges on failed transactions, or interest charges on outstanding amounts due to Finmo or creation of Virtual Accounts.
The financial claims scheme
The Financial Claims Scheme is a scheme administered by the Australian Prudential Regulation Authority (“APRA”) to protect depositors of authorised deposit-taking institutions from potential loss due to the failure of these institutions. It provides depositors with a guaranteed protection, up to a cap. As at the date of this PDS, the Financial Claims Scheme applies to deposits only, and does not protect any Available Balance.
For more information, see APRA’s website at https://www.fcs.gov.au.
Privacy policy
Your privacy is important to us and we are committed to compliance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles. Information collected from you at registration or in subsequent communications is used to establish and administer your Account, comply with our regulatory obligations and for us to determine your suitability as a client. We may disclose your personal information to external parties who act on our behalf in the operation of our business or in connection with the transactions to be undertaken. Such external parties are required and committed to protecting your privacy and where they are offshore, we take reasonable steps to ensure that to the maximum extent reasonably possible any information sent has the same level of privacy protection as we provide here in Australia.
Finmo will not otherwise disclose your personal information without your consent, except as authorised or required by privacy laws. Please contact us by writing to compliance@finmo.net if you have any concern.
We will retain information obtained from you only as long as required by our regulatory obligations. This includes information required in order for us to comply with applicable laws and regulations for the prevention of money-laundering and counter-terrorism financing.
The law allows you (subject to permitted exceptions) to access your personal information. You can do this by contacting us using our contact details set out in this PDS.
Where necessary, we will correct personal information where that information is found to be inaccurate, incomplete or out of date. We will not charge an individual for reasonable access and correction requests.
AML/CTF
By accepting the terms and conditions in the PDS and at registration you undertake that activity related to your Account is in no way associated with unlawful or illegal activity. Finmo is compliant with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and associated laws. By registering with Finmo, you undertake to notify us of anything that may put us in breach of this legislation and associated regulations.
You must supply personal details to us and where necessary documentation to assist us verify your identity. This may also be necessary for additional authorised signatories and directors and beneficial owners of corporate entities. From time to time we may be required to obtain further information to assist with ongoing obligations.
We may be required to provide the relevant authorities with information we have collected from you or any transaction records we hold. We will be unable to notify you of any such requests. We may also be required to suspend or cancel your Account or delay, block or freeze the processing of transactions. If this occurs, we are not liable to you for any consequences or losses whatsoever and you agree to indemnify us if we are found liable to a third party in connection with the freezing or blocking of a transaction in connection with your Account.
Tax implications
You should get your own independent tax advice in relation to the impact your use of the Services may have on your personal tax liability as Finmo has not taken into account your individual circumstances or needs.
Disclosure of interest
Subject to disclosures in any other transaction documents, Finmo does not have any relationships or associations which might influence us in providing you with our Service.
Dispute resolution
Finmo has an internal dispute resolution process in place to resolve any complaints or concerns you may have, as quickly and fairly as possible in the circumstances. Any complaints or concerns should be directed to us via compliance@finmo.net. We will seek to resolve your complaint within 30 calendar days or such further time period that may reasonably be required given the nature of the complaint. We will investigate your complaint, and provide you with our decision, and the reasons on which it is based, in writing. If you are dissatisfied with the outcome, you have the right to lodge a complaint with the Australian Financial Complaints Authority, an approved external dispute resolution scheme, of which Finmo is a member.
Australian Financial Complaints Authority
Phone: 1800 931 678 Post: GPO Box 3, Melbourne, Victoria 3001
Website: www.afca.org.au
Glossary of terms
Account
The account by which you access the Finmo Platform.
Available
Balance
Refers to the balance contained in the Account.
Finmo Platform
The proprietary online system(s) and the components thereof, developed, owned and maintained by Finmo, that enables You to obtain the Services from Finmo, including any replacement thereof and any related software, websites, URLs, software programs and deliverable ancillary to the Finno Platform such as reports, compilations or databases
Unauthorised Transaction
A transaction not authorised by you, but not including transactions made by another person who you have permitted to use the Account.
