Lender Comparison Statement

Lender Comparison Statement

1. About the FundsConnect Comparison Service

1.1 What We Do

FundsConnect Platform Pty Ltd operates a proprietary technology platform that matches commercial and business/investment purpose loan requirements with private credit lenders. Our lender matching technology compares loan parameters against the criteria of lenders on our panel and presents anonymised comparison results to brokers registered on our platform. All transactions facilitated through the Platform are private credit transactions with terms of 1 to 60 months, entered into by companies or corporate trustees.

1.2 What We Do Not Do

FundsConnect does NOT:

• Provide credit advice or financial product advice
• Recommend any particular lender or loan product
• Guarantee that any lender will approve a loan application
• Make representations about the suitability of any loan product for any borrower
• Act as a lender, credit provider, or mortgage broker
• Assess borrower creditworthiness or capacity to repay
• Facilitate loans regulated under the National Consumer Credit Protection Act 2009 (Cth) or the National Credit Code

1.3 Regulatory Status

The FundsConnect comparison service is a technology matching service. It is not a credit service within the meaning of the National Consumer Credit Protection Act 2009 (Cth). FundsConnect does not hold and is not required to hold an Australian Credit Licence or Australian Financial Services Licence.
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FundsConnect's operations are governed by the ASIC Act 2001 (Cth), in particular ss 12DA, 12DB, and 12CB. All credit activities arising from the use of the Platform are conducted by the relevant lenders under their own regulatory obligations.

All borrowers on the Platform are companies or corporate trustees. All lending is business or investment purpose private credit with loan terms of 1 to 60 months, secured by real property.

2. How the Comparison Works

2.1 Panel Lenders

The comparison is limited to private credit lenders that are approved members of the FundsConnect lender panel. The panel does not represent all lenders available in the Australian market. Lenders are admitted to the panel based on their track record, product suitability, and due diligence outcomes.

2.2 Matching Methodology

The FundsConnect matching technology operates as follows:

1. The broker enters the loan parameters (amount, LVR, term, purpose, property type, location, borrower profile) into the Platform.
2. The Platform matches these parameters against the published lending criteria of each panel lender.
3. Lenders whose criteria match the loan parameters are returned as comparison results.
4. Results are sorted by the criterion selected by the broker (e.g., interest rate, maximum LVR, maximum loan amount).

2.3 Sort Order

The sort order is determined solely by the criterion selected by the broker. The sort order is NOT influenced by any commission arrangement, lender relationship, commercial preference, or any other factor. The broker may change the sort criterion at any time.

2.4 Anonymisation

At the comparison stage, lender results are presented anonymously (e.g., Lender 1, Lender 2, Lender 3). Lender identity is not disclosed until the broker elects to proceed with a specific lender and an indicative funding proposal is issued. This anonymisation is applied uniformly to all panel lenders.

Rationale: Anonymisation ensures that broker selection is based on objective loan parameters (rate, fees, LVR, speed) rather than brand recognition or pre-existing lender relationships. This promotes a merit-based comparison.

3. Fee and Remuneration Disclosure

FEE NEUTRALITY STATEMENT

FundsConnect Platform Pty Ltd does NOT receive any commission, trail fee, volume bonus, soft dollar benefit, or any other form of remuneration from any panel lender. The platform's sole remuneration is a brokerage fee of 1.10% (GST inclusive) of the loan amount, payable on settlement. This fee is identical regardless of which lender is selected. There is no financial incentive for FundsConnect to favour any particular lender.

3.1 Platform Brokerage Fee

3.2 Commission Distribution

From the 1.10% (GST inclusive) brokerage fee, FundsConnect distributes commissions to the broker or introducer who submitted the loan application, in accordance with the applicable Remuneration Agreement. The commission structure is separate from the comparison service and does not influence comparison results.

3.3 Independence Statement

Based on the fee structure described above, FundsConnect has no conflicted remuneration within the meaning of ASIC Regulatory Guide 246 (Conflicted Remuneration). The platform receives the same fee regardless of lender selection. There is no financial incentive for FundsConnect to rank, promote, or favour any particular lender over another.

This independence claim is valid only for so long as FundsConnect receives no remuneration from any panel lender. Any future change to this arrangement will be disclosed to all platform users and reflected in an updated version of this Statement.

4. Information Disclosure Journey

Information is disclosed progressively through three stages to ensure the broker receives all material information before making a selection:

Stage 1: Anonymous Comparison

Disclosed at this stage:

• Indicative interest rate and type (fixed/variable)
• Maximum LVR available
• Indicative loan term range (1 to 60 months)
• Existence and rate of the 1.10% platform brokerage fee
• Number of panel lenders displayed out of total panel

Not disclosed: Lender identity

Stage 2: Indicative Funding Proposal

Disclosed upon broker request for a proposal from a specific anonymous lender:

• Full lender identity and contact details
• Detailed fee schedule (establishment fee, legal fees, valuation fees, exit fees)
• Itemised funding table showing all costs including the platform brokerage fee as a separate line item
• Loan conditions and security requirements
• Lender-specific terms and conditions

Stage 3: Formal Loan Offer

Issued by the lender:

• Binding loan terms and conditions
• All legal documentation
• Settlement requirements

5. Comparison Limitations

Users of the comparison service should be aware of the following limitations:

• Panel only: The comparison only includes lenders on the FundsConnect panel and does not include all lenders available in the Australian market.
• Indicative only: All comparison results are indicative and subject to change. Actual loan terms will be confirmed only in a formal loan offer from the lender.
• Not credit advice: The comparison does not constitute credit advice. The broker is responsible for assessing suitability of any loan product for their client.
• Data currency: Lender criteria and rates are updated periodically. There may be a delay between a lender changing its criteria and the Platform reflecting that change.
• No guarantee: A lender appearing in comparison results does not guarantee that the lender will approve the loan application.
• Borrower eligibility: The Platform is available only for loans to companies or corporate trustees for business or investment purposes. Consumer credit is not facilitated.

6. ASIC Act Compliance

FundsConnect operates the comparison service in compliance with the following provisions of the ASIC Act 2001 (Cth):

• Section 12DA (Misleading or deceptive conduct): The comparison displays all material information known to FundsConnect at the time of comparison. Sort order is transparent and user-controlled.
• Section 12DB (False or misleading representations): No representations are made about the suitability of any loan product. The comparison is presented as a matching service, not as advice or a recommendation.
• Section 12CB (Unconscionable conduct): The comparison methodology and fee structure are transparent and apply equally to all platform users and panel lenders.

7. Contact