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Financial Services Guide

1 March 2022

Important details

The purpose of this Financial Services Guide (‘FSG’) is to provide you with details of the financial services provided by Spotee Pty Ltd ABN 55 637 623 940, (CARN 001283189) (‘Spotee’) or its directors/employees and to provide relevant information to help you decide whether to use the financial services offered.

This FSG provides details about remuneration or benefits that we (or others) may receive, attributable to the financial services we provide. It also details how complaints about the financial services we provide will be dealt with.

Most financial products, other than listed securities, will have a Product Disclosure Statement (PDS). A PDS is a disclosure document which assists you to make an informed investment decision, including helping you to compare it with other products. It sets out significant features of a financial product, including its risks, benefits and costs. Where applicable, when we offer to arrange for the issue of a financial product to you, we will provide you with a PDS.

The content and distribution of this FSG have been authorised by Spotee and Daylight Financial Group Pty Ltd, ABN 77 633 984 773. You can contact us by email at

Unless specified otherwise, a reference to ‘we’, ‘our’ of ‘us’ in this FSG is a reference to Spotee also any financial services provided by Spotee’s employees or directors, Daylight Financial Group Pty Ltd.


What services we may provide to you

Spotee offers:

  • A Q&A service (Spotee Connect) for investors who wish to have their share market related questions answered by an expert.
  • Education services (SpoteeED) where a fee is charged for the delivery of education (either face-to-face or online) to attendees.
  • Consulting services (Spotee Consulting) to private investors and corporate advisers on the topic of securities and investing principles.

Spotee Connect

Spotee Connect offers a service online where an investor can ask a share market question about any stock listed on the Australian securities exchange and authorised Spotee staff will deliver insights on those businesses asked about via the portal.

These responses are then also visible by other users of the software. There is not a forum where there is interaction with other users. Rather it’s a Q&A service where all responses are curated and provided by trained Spotee staff members. This is a pay-by-the-month service and a user can cancel at any time with their access continuing until the end of the subscription period.

All responses are prepared without considering your personal objectives, situation or needs. Therefore, should you wish to discuss any response in light of your personal circumstances then you need to speak to an advisor licenced to have that discussion with you.


SpoteeED facilitates paid for education events (either face-to-face or online) on the topic of share investing. These are presented either by staff of Spotee, or with the assistance of an appropriately approved expert. The topic of the education as well as the cost varies based on time, resources and content.

Spotee Consulting

Spotee’s consulting services is our premium investing support offering that encompass a range of different components based on the need of the client. These tasks can range from a portfolio diagnostic, through to share market education, and/or mentorship services.

Spotee directors and/or staff may provide general financial product advice through the delivery of these services. What we do NOT provide as part of any of these services is any personal advice, be it trading or similar, nor do we act as a broker. For further information on Spotee’s services, please visit the website

We may also provide general financial product advice to you on securities indirectly via another financial services provider (e.g. an adviser), who has an existing arrangement with us and utilises our services. General advice you receive from us under this arrangement will be sourced by your other financial service provider and provided to you in a written report form, which will include our details.

Where we provide general financial product advice through a third party, we act for the clients to whom these services are provided. (In the above example, the services are provided by us to an adviser – so, we act for the adviser, not for you.)


Who will be providing financial services to you?

Financial services will either be provided to you by Spotee’s directors and/or Spotee’s employees.

Spotee is a corporate authorised representative (CARN 001283189) of Daylight Financial Group Pty Ltd ABN 77 633 984 773. Daylight Financial Group Pty Ltd is the holder of an Australian Financial Services Licence number 521404 and has authorised Spotee to provide financial services on its behalf.

To the extent Spotee’s directors or employees provide financial services, the directors or employees act as representatives of Daylight Financial Group Pty Ltd.

Neither Spotee nor Daylight Financial Group Pty Ltd is responsible to you for the actions of its representatives. Neither is Spotee nor Daylight Financial Group Pty Ltd responsible to you for services provided to you by any other third party, including other financial service providers (e.g. advisers). You should refer to the FSG of your other financial services provider for further information about the services they offer.


What kinds of financial services are we authorised to provide you and what kinds of products do those services relate to?

  • deposit and payment products
  • debentures, stocks or bonds issued or proposed to be issued by a government
  • interests in managed investment schemes (including IDPSs)
  • retirement savings accounts
  • securities (such as shares)
  • superannuation

Though currently not undertaking such services, Spotee can also deal in a financial product by applying for, acquiring, varying or disposing of a financial product on behalf of another person, in respect of the following classes of financial products:

  • interests in managed investment schemes (including IDPSs)
  • securities (such as shares)
  • superannuation


Will I be provided with advice that is suitable to my investment needs and financial circumstances?


Where we provide you with advice, it will be general financial product advice only.

Our advice will be prepared without taking into account your individual objectives, financial situation or needs; and because of this, before acting on the advice you should consider the appropriateness of the advice having regard to your objectives, financial situation and needs; and if the advice relates to the acquisition or possible acquisition of a particular financial product, you should obtain a copy of, and consider, the PDS before making any decision.


What charges will you incur?


Spotee Connect

Spotee Connect is a pay-by-the-month arrangement where the fee is $99.95 per month (inc GST) and it is automatically renewed each month until you decide to cancel your subscription.

Spotee has the right to change this rate at any time.

As the membership is on auto renewal, you will be charged the monthly fee on the anniversary date.

You can cancel your subscription at any time.

If you do cancel your subscription before the anniversary date, you will still have access to the program until the end of the period. After that you will no longer be charged and therefore will not have access the program.

There are strictly no refunds with this service.

SpoteeED education sessions

Spotee will run special group education sessions (delivered either online or face-to-face).

Depending on the nature of the content and duration of the sessions, Spotee may charge a fee for that training. Fees will depend on the specific training undertaken and will be advertised at the time it is offered.

All training and education will be general of nature and will not take into account your personal objectives, situation or needs. Any refunds are subject to our cancellation policy 

Spotee’s consulting services

If you choose to utilise Spotee’s consulting services you will be charged an hourly rate for any work completed.

Hourly charge.

The charge is $750 per hour (inc GST). This is also the minimum charge for any work completed.

Spotee has the right to change this rate at any time, however the rate you initially subscribe to will be the rate that applies to you moving forward.

The billing cycle includes both any preparation work and time for the consultation. You will be told what that amount will be before any work commences and payment must be made before the session is held. If you can’t make the scheduled meeting for any reason, we will look to reschedule.

No refunds are available.

Annual charge

An annual subscription to Spotee’s consulting and education services for retail investors is $7,995 p.a. (inclusive of GST)

This rate includes all preparation work, reviews, consultations and subsequent contacts. It will remain at this rate for the tenure of our relationship, irrespective of any price rises in the future.

Annual Rates for Financial Advisers will need to be negotiated based on the number of clients and your current offering (direct holdings, SMA/IMA etc). The base level rate is $7,995 p.a. (inclusive of GST).

A base schedule of sessions will be arranged, with subsequent contact available on an ‘as requested’ basis.

Payment must be made in full prior to any work commencing. And given the significant price discount and resource commitment required to support a full year offering, there are no refunds available.

However, should you wish to suspend your service for a time, then we are happy to extend the service period for the time you will be offline to a maximum of 6 months where the billing cycle will recommence.

First 30 minute consultation is free

The first consultation is complimentary and is for a maximum 30 mins on the phone.

It is a fact-finding mission to discuss what you are seeking from a service such as this. This includes a brief questionnaire that you will need to complete in order to help maintain focus on the things that matter most to you.

There will be no answers to your problems provided in this session.

After the meeting, a plan and future schedule will outline what services will be delivered as part of the consultation process. At this point you have the option not to proceed with any sessions if you feel our program would not be able to assist you.

Consider carefully if this service is cost effective for you

To give you an idea of the time required and potential outlay – A full and thorough review of your existing portfolio, strategy development and education could take 3 hours to complete – $2,250.

If all you require is a discussion on recent decisions and learnings, that time will likely be 1hr – $750 (30 mins research + 30min discussion).

Obviously the larger the portfolio and/or more question, the more time required. If your portfolio is very small, then this service may not be cost-efficient. Only you can determine if this is the case or not.

With the annual charge, no such time constraint exists. A base schedule of meetings will be arranged, created around your preferences and needs. These will be agreed upon prior to you making any payment.

Cost examples

These are just examples of potential costs and should be taken as any indication as to what services you may require.

Hourly charge 

  • An investor with little to no market knowledge has an existing portfolio or lump sum of $250k. Allowing for education, training and mentorship over say 5 hours conducted over a number of weeks, then the outlay equals 1.5% of the portfolio (ie $3,750 to get the knowledge you need to start investing.)
  • An existing $1m portfolio run by an investor with sound knowledge of the market, then a full diagnostic and consultation could take between 3-4 hours ($2250 – $3000) to initially complete meaning an investment of 0.23 – 0.3% of the portfolio. Ongoing reviews would be shorter based on the complexity and number of changes you have made since our last meeting.

Annual charge

  • Based on the same portfolio values described above, should you subscribe to the annual subscription then the time to complete any review is irrelevant, however the outlay does increase to 3.2% of a $250k portfolio or 0.8% of a $1m portfolio.


Other referral payments

Spotee may make referral payments to third parties that distribute promotional material about Spotee Connect, consultation services and/or education offerings. At present, no such deals are in place.


What other remuneration or other benefits we may receive in relation to the financial services we provide?

Spotee may receive revenue from referring and / or advertising a third-party service to investors. At present, no such deals are in place.


Staff representatives-remuneration

Spotee’s staff are remunerated on a fixed salary basis. Elio D’Amato, Founder of Spotee, and other owners and/or staff representatives of Spotee may benefit from a share in any profits of Spotee Pty Ltd.


Do any relationships or associations exist that might influence us in providing you with financial services?

Spotee is a subsidiary of Daylight Financial Group Pty Ltd, its authorising licensee. Together, Spotee and Daylight Financial Group Pty Ltd, form the Daylight Financial Group of companies. When employees or directors of Spotee provide financial services, they do so as representatives of Daylight Financial Group Pty Ltd, on the basis that they are employees and directors of an entity that is a related entity of the holder of an Australian Financial Services Licence.

Daylight Financial Group Pty Ltd receives a royalty from Spotee in relation to Spotee’s appointment as a corporate authorised representative of Daylight Financial Group Pty Ltd. Daylight Financial Group Pty Ltd does not receive any remuneration or benefit for the financial services provided by Spotee, or Spotee’s directors or employees.

Where a company in the Daylight Group of companies, its directors, employees or associates hold an interest in a particular company which is the subject of our general advice, this will be noted in our content, as appropriate.


Who can you complain to if you have a complaint about the services that we provide?

If you have any complaints about the service that we provide, please take the following steps:

Contact the team at Spotee by email at We will endeavour to resolve any client complaint or query as soon as possible.

If you prefer, you can lodge your complaint in writing to: Managing Director, Spotee Pty Ltd, PO Box 333 Avondale Heights, VIC 3034.

If you do not receive a satisfactory outcome, you have the right to complain to the Australian Financial Complaints Authority. The contact details for the Australian Financial Complaints Authority are GPO Box 3, Melbourne, Victoria, 3001 by phone 1800 931 678 (free call), by email at or fax (03) 9613 6399.

The Australian Securities and Investments Commission (ASIC) also has an Info line number 1300 300 630 which you may use to make a complaint and obtain information about your rights.


Professional Indemnity insurance.

We have Professional Indemnity insurance in place that covers claims in respect of current and former representatives for financial services provided by or on behalf of Daylight Financial Group Pty Ltd. In our view, this insurance satisfies the requirements for compensation arrangements under the Corporations Act and Regulations 2001.


General investment warnings.

The value of an investment may go down as well as up. Past performance of an investment is not a reliable indicator of future performance. We do not guarantee the return of capital. Neither Spotee nor Daylight Financial Group Pty Ltd is responsible to you for the actions of its representatives. The information in this Financial Services Guide (FSG) is of a general nature only and does not take into account any individual’s objectives, financial situation or needs. Therefore, before acting on any advice contained in this FSG, you should consider the appropriateness of the advice, having regard to your objectives, financial situation and needs.

All figures quoted in this FSG are as at 01 March 2022(GST inclusive except where explicitly stated).


Privacy policy

We are committed to preserving and respecting your privacy and complying with the Privacy Act 1988. For full details about our privacy practices and your rights, see the Daylight Group’s Privacy policy and collection notice at or .