The Australian Securities and Investments Commission (ASIC) has issued a set of benchmarks and disclosure principles, contained in ASIC Regulatory Guide 45 – Mortgage schemes: Improving disclosure for retail investors (RG 45), to help investors understand and access unlisted mortgage schemes, such as the Premium Income Fund (Fund)

This document is the Rhodes Asset Management Ltd Premium Income Fund RG 45 Report as referred to in the Product Disclosure Statement dated 8 May 2026 (PDS) issued by Rhodes Asset Management Ltd (ACN 165 917 813 / AFSL 464772) (Rhodes Asset Management) as the responsible entity of the Rhodes Credit Fund ARSN 606 834 011(RCF Fund). This Premium Income Fund RG 45 Report is taken to be included in the PDS. A copy of this report may be obtained from Rhodes Asset Management on request, at no charge.

Please note that all financial data is current as of 30 April 2026 (unless stated otherwise).

 

Benchmark 1: Liquidity  

This benchmark is met by the Fund

This benchmark is met by Rhodes Finance.

Disclosure Principle 1: Liquidity

45.69

Disclose information about:

1. the current and future prospects of liquidity of the scheme;
2. any significant risk factors that may affect the liquidity of the scheme; and
3. the policy of the scheme on balancing the maturity of its assets with the maturity of its liabilities.

Rhodes Asset Management disclosure

1. We maintain rolling 12 month cash flow estimates for the Fund and Rhodes Finance with the aim of ensuring there is sufficient cash to meet obligations which may arise.
   These estimates are updated at least every three months and reflect any material changes and approved by the directors of the related entity, Rhodes Finance cash flow is also reviewed and ratified by the Rhodes Asset Management board and then adopted in preparing the Fund cash flow.
   Rhodes Finance continues to write new loans. Rhodes Finance and Rhodes Asset Management are committed to achieving returns to investors in line with market conditions.
2. Some significant risks that may affect the liquidity of the Trust could be:
   • a large number of redemptions of an amount more than the available liquidity of the Trust;
   • delays in settlements from Borrowers to repay the loan; and/or
   • borrower defaults.
3. The policy of the Fund is to aim to balance the maturity of assets and the maturity of liabilities to the extent feasible. Rhodes Finance makes short term loans of typically less than 12 months (although sometimes as long as 24 months) and the Minimum Investment Term for Unitholders is 12 months.  This alignment in maturity of timeframes eases the process of matching availability of cash from maturing loans with the obligations to redeem investor capital.  Additionally, for both Rhodes Finance and the Fund we produce rolling 12-month cash flow forecasts managed and monitored by the Rhodes Asset Management board.

 

Benchmark 2: Scheme Borrowing

This benchmark is met by the Premium Income Fund.
The Fund does not and will not undertake any borrowings for the Fund.

This benchmark is not met by Rhodes Finance.
Rhodes Finance is expected to borrow from other parties. Such borrowings are either subordinate to the interests of the Fund or do not encumber the interests of the Fund.

Disclosure Principle 2: Scheme Borrowing

45.72

Disclose:

1. for borrowings due in less than two years – the total debts due and their maturity profile, undrawn credit facility and whether refinancing or sale of assets is likely during this period;
2. for borrowings due in between two and five years – the total debts due and their maturity profile for each 12 month period and undrawn credit facility;
3. for borrowings due after five years – the total debts due;
4. why the responsible entity has borrowed the money, including whether the borrowed funds will be used to fund distributions or withdrawal requests;
5. any material loan covenant breaches;
6. the fact that amounts owing to lenders and other creditors of the scheme rank before an investor’s interests in the scheme; and
7. the risks associated with the scheme’s borrowing and credit facility maturity profile.

45.73

Disclose:

1. the existence and details of any current interest rate and foreign exchange hedging policies of the responsible entity;
2. whether the scheme’s variable interest rate and / or foreign exchange exposure conforms with these policies.

Rhodes Asset Management disclosure

45.75

1. The Fund does not and will not undertake any borrowings for the Fund.
   Rhodes Finance is expected to borrow from other parties. Such borrowings are either subordinate to the interests of the Fund or do not encumber the interests of the Fund.
   Rhodes Finance had two loan notes – $859,950 (revolving facility) and $500,000 (maturing 14 .3.2027) – totalling $1,359,950.
2. No loans
3. No loans
4. Rhodes Finance uses the loan money to fund additional loans.
5. No loan covenant breaches
6. The loan notes were either subordinate to the interests of the Fund or do not encumber the interests of the Fund.
7. There is no risk to the Fund as described above.

45.76

There is no interest rate or foreign exchange hedging.

 

Benchmark 3: Loan Portfolio and Diversification

This benchmark is not met by the Fund.

This benchmark is not met by Rhodes Finance.

Disclosure Principle 3: Loan Portfolio and Diversification

45.77

For pooled mortgage schemes, disclose:

• by number and value:
  1. loans by class of activity (e.g. development or construction projects, industrial, commercial, retail, residential, specialised property and reverse mortgages);
  2. loans by geographic region;
  3. the proportion of loans that are in default or arrears for more than 30 days, by number and value;
  4. the nature of the security for loans (e.g. first or second ranking);
  5. loans that have been approved but have funds that have yet to be advanced and the funding arrangements in place for any of these undrawn loan commitments.
  6. the maturity profile of all loans in increments of not more than 12 months;
  7. loan-to-valuation ratios (LVR) for loans, in percentage ranges;
  8. interest rates on loans, in percentage ranges; and
  9. loans where interest has been capitalized;
• the proportion of the total loan money that has been lent to the largest borrower and the 10 largest borrowers;
• the percentage of loans (by value) that are secured by second-ranking mortgages;
• the use of derivatives (if any);
• a clear description of the non-mortgage assets of the scheme, including the value of such assets; and
• the scheme’s diversification policy and how the assets correlate with that policy. 

45.78

The responsible entity should disclose its policy on the above matters and on how the scheme will lend funds generally. For example, such disclosure should cover:

1. the maximum loan amount for any one borrower;
2. the method of assessing borrowers’ capacity to service loans;
3. the responsible entity’s policy on revaluing security properties when a loan is rolled over or renewed; and
4. the responsible entity’s approach to taking security on lending by the scheme (e.g. the types of security it takes and in what circumstances, and whether the security must be income producing).

45.79

If an unlisted pooled mortgage scheme invests in, or may invest in, other unlisted mortgage schemes (whether registered or unregistered), the responsible entity must disclose its policy on investing in those schemes, including the extent to which the responsible entity requires those schemes to meet the benchmarks and apply the disclosure principles in RG 45.

 

Rhodes Asset Management disclosure

45.77

Unless otherwise stated, the total value of the loan portfolio referred to in this Disclosure Principle is based on the drawn pooled mortgage loans held by Rhodes Financing. The total drawn pooled mortgage balance was $31,137,009.03.

1. • A chart showing loans by sector is set out below.

Sector	Amount	% of Portfolio
Residential	$22,073,037.59	70.89%
Commercial	$4,091,188.66	13.14%
Vacant Land	$4,972,782.78	15.97%

1. • A chart showing loans by geographic region is set out below

State	Amount	% of Portfolio
NSW	$6,286,929.83	20.19%
QLD	$14,627,000.33	46.98%
VIC	$6,154,734.77	19.77%
SA	$4,068,344.10	13.07%
WA	$0.00	0.00%
NT	$0.00	0.00%
TAS	$0.00	0.00%

• • There were three loans in default with a drawn balance of $4,011,493 representing approximately 12.08% of the total amount made available to Rhodes Financing under the Loan Facility Agreement and x9% of the total number of active loans.
    A loan is deemed to be in default if the borrower fails to meet its financial obligations, including the payment of interest or principal, within 30 days of the amount falling due. Any such loan will be classified as Non-Performing by RFS.
    The following procedures is adopted by RFS for all late payments of interest during the term of a Loan:
    • Issue reminder notices to the borrower seven (7) days after the due date of payment
    • Issue default notices to the borrower fourteen (14) days after due date of payment
    • Aim to work with the borrower to reach a satisfactory resolution for repayment of the loan and or outstanding interest.
      If no resolution can be reached with the borrower, RFS will commence recovery proceedings by engaging the solicitors who prepared the security documents, or another suitably qualified law firm at the discretion of the Credit Committee.

• • The nature of the security taken by Rhodes Financing Solutions Pty Ltd (RFS) is that all loans, including first ranking and second ranking mortgages, are secured by registered mortgages and may also be supported by additional security, including Personal Property Securities (PPSR) and General Security Agreements (GSA), and director guarantees where applicable.
  • There were no approved loans for which funds had not yet been advanced. Any future undrawn loan commitments are intended to be funded through a combination of borrower loan repayments (in full or in part) and cash available from other sources, including new investor funds received.
  • No loans within the portfolio have a maturity profile exceeding 12 months.

• • A chart showing loan-to-valuation ratios (LVR) for loans, in percentage ranges, is set out below:

LVR Range	Count of Loans
0-60%	12
60.01-65%	3
65.01-70%	3
70.01-75%	5
75.01-80%	10

• • The current interest rates on loans in percentages is set out below:

Interest Rate Range	Number of Loans
10-12%	16
12.01-14%	9
14.01-16%	1
16.01-18%	5
18.01 – 24%	2

• • Of the total of 33 loans in the portfolio which have been advanced, there were 28 loans in which interest has been capitalised (draw down value of $25,803,305) and 5 loans in which interest is not capitalised (draw down value of $5,333,703).

Rank	Balance
1	$4,080,000.00
2	$2,924,675.96
3	$2,450,000.00
4	$2,260,000.00
5	$2,229,056.04
6	$1,902,935.35
7	$1,327,715.16
8	$1,256,000.00
9	$1,158,180.65
10	$910,888.54

• A chart showing the proportion of the total loan money that was lent to the largest borrower and the 10 largest borrowers are set out below:
• The percentage of loans (by value) that were secured by second-ranking mortgages is 9.91%.
• There are no derivatives used in the Fund.
• Total non-mortgage assets were ($3,440,205), comprised of cash and cash equivalents, representing 10.36% of total assets under Rhodes Financing.
• The Fund’s diversification policy and how the assets correlate with that policy.

Liquidity The Fund’s liquidity level is monitored continuously and reviewed regularly by the Credit Committee and the Board.

Geographic Spread Rhodes Asset Management policy is that the proposed security is located in the states and territories in Australia. There were 33 loans in the loan portfolio. The indicative spread percentages noted in section a ii. above are a guide only. The geographical spread is reviewed by the Credit Committee on an ongoing basis.

45.78

1. The Lending and Investment Policy provides that the maximum loan amount for any one borrower is $5million.
2. As our loans are short term commercial loans, interest is mostly capitalised, and where considered necessary, we obtain a statement from the borrower’s Accountant to confirm serviceability of the loan.
3. We have procedures in relation to loan renewals. The Credit Committee will make a determination if a new valuation is required prior to a renewal. The Credit Committee bases its determination on a number of factors including the borrower’s loan history, the amount of the loan outstanding and the duration of the extension.
4. The primary security for each loan made by the Fund is a registered mortgage (first or second) over real property situated within the states and territories in Australia. Additional types of security may be taken including company charges and personal guarantees to support the first or second mortgage security. The security does not need to be income producing. 

45.79

As part of its short-term excess liquidity management strategy, the Fund may invest in other unlisted managed investment schemes which invest directly or indirectly in mortgage loans secured by registered mortgages. Such investments are intended to assist with liquidity management and are not a core component of RFS’ lending strategy. Before making any such investment, Rhodes Asset Management Ltd assesses the underlying scheme, including its investment mandate, liquidity profile, governance framework, and overall suitability for the Fund.

While regard may be had to the whether the unlisted mortgage scheme meets and applies the benchmarks and disclosures principles in RG45, Rhodes Asset Management does not have a policy that requires the unlisted mortgage scheme to do so. The Fund had one investment in an unlisted mortgage scheme totalling $2.125m.

 

Benchmark 4: Related Party Transactions

This benchmark is not met by the Fund

This benchmark is not met by Rhodes Finance.

 Disclosure Principle 4: Related Party Transactions

45.85

Disclose details of any related party transactions including:

1. the value of the financial benefit;
2. the nature of the relationship (i.e. the identity of the related party, and the nature of the arrangements between the parties, in addition to how the parties are related for the purposes of the Corporations Act – for group structures, the nature of these relationships should be disclosed for all group entities);
3. whether the arrangement is on arm’s length terms and is reasonable remuneration;
4. whether member approval for the transaction has been sought and, if so, when;
5. the risks associated with the related party arrangements; and
6. the policies and procedures that the responsible entity has in place for entering into related party transactions, including how compliance with these policies and procedures is monitored. 

Rhodes Asset Management’s disclosure

45.85

1. The amount advanced by the Fund to Rhodes Finance under the Loan Facility will vary in line with the capital invested in the Fund by Unitholders and may change almost daily.
2. The single investment made under the Fund is to Rhodes Finance, a related party of Rhodes Asset Management.
3. We consider the Loan Facility is on arm’s length terms and therefore approval of the Fund’s members was not required to enter into the Loan Facility.
4. Related party risk exists when the Fund or Rhodes Finance lends to, invests in or transacts with a person or body corporate who is a related party to us and due to the nature of the related party, enforcement of their obligations may be more difficult than for transactions with third parties. We aim to ensure that any related party transaction will be conducted on an arm’s length basis and will be monitored as robustly as those involving unrelated parties.
   Currently, there are no loans extended by Rhodes Finance to related parties.
5. Rhodes Asset Management has policies and procedures in place for entering into related party transactions and compliance is monitored in respect of these by quarterly reporting to the Board and the Compliance Committee.
   In addition, directors and employees of Rhodes Asset Management and other related parties may hold units in the Fund from time to time. These units will be acquired and held on the same terms as any other Investor in the Fund.

  

Benchmark 5: Valuation Policy

This benchmark is not applicable to the Fund – the benchmark is not applicable as the Fund does not hold mortgage assets.

This benchmark is not met by Rhodes Finance.

Disclosure Principle 5: Valuation Policy

45.88

Disclose:

1. where investors may access the scheme’s valuation policy;
2. the processes that the directors employ to form a view on the value of the security property;
3. the frequency of valuations of security property; and
4. any material inconsistencies between any current valuation over the security property and the scheme’s valuation policy.

 

Rhodes Asset Management disclosure

45.88

The Fund does not hold mortgage assets, so references here relate to Rhodes Finance.

• The Valuation Policy is available by emailing us at admin@rhodesam.com.au Please also refer to Section 6.2 of the PDS.
• Rhodes Finance directors rely on independent valuations from qualified and experienced valuers to form a view on the value of the security property.
• We will value an asset on an “as is” basis before it is acquired or disposed (as applicable to price the sale); where an asset is held for more than 12months, we may obtain a revaluation if there is significant change in the macroeconomic environment or any other material change that may adversely affect the value of the asset; where information leads us to believe that there may be a variation in the security value.
• No material inconsistencies exist as at the date of this report.

 

 

Benchmark 6: Lending Principles – Loan-to-valuation ratios

This benchmark is not applicable to the Fund – the benchmark is not applicable as the Fund does not hold mortgage assets.

This benchmark is met by Rhodes Finance.

Disclosure Principle 6: Lending Principles – Loan-to-Valuation Ratios

45.91

Disclose:

1. the maximum and weighted average loan-to-valuation ratios for the scheme as at the date of reporting; and
2. where funds are lent for property development:
3. the criteria against which the funds are drawn down;
4. the percentage (by value) of the completion of any property that is under development as at the date of reporting; and

• the loan-to-cost ratio of each property development loan as at the date of reporting.

45.92

Disclose:

1. the percentage of the scheme’s assets (including cash assets) that are property development loans;
2. if property development loans exceed 20% of the scheme’s assets, the responsible entity should identify the scheme as one that invests a significant component of funds in property development loans;
3. if the loan-to-cost ratio of any property development loan exceeds 75%; and
4. if (c) above exceeds 75%, disclose how and when funds are provided to developers.

Rhodes Asset Management disclosure

45.91

The Fund does not hold mortgage assets, so references here relate to Rhodes Finance.

1. The maximum LVR for loans is 80%. The weighted average LVR for all loans is currently 85% on an ‘as is’ basis.
2. We do not have any loans for property development.

Rhodes Finance does not apply Fund capital to finance property development projects with security based on ‘as if complete’ valuations. Whilst it is not the core business of Rhodes Finance, it is open to applications for construction loans providing the risks are assessed as acceptable, “as is” security is available, and the LVR will be limited to 70% if the security taken is over a property being developed.  If security is available over a different complete property Rhodes Finance will consider a loan to 80% of the security value.

45.92

We do not have any loans for property development.

 

Benchmark 7: Distribution Practices

This benchmark is met by the Fund.

This benchmark is not applicable to Rhodes Finance.

Disclosure Principle 7: Distribution Practices

45.96

Disclose:

1. the source of the current and forecast distributions (e.g. from income earned in the relevant distribution period, operating cash flow, financing facility, capital, application money);
2. if the distribution is not solely sourced from income received in the relevant distribution period, the reasons for making those distributions and the risks associated with such distributions;
3. if the distribution is sourced other than from income, whether this is sustainable over the next 12 months; and
4. when the responsible entity will pay distributions and the frequency of payment of distributions.

45.97

If the scheme promotes a particular return on investments, disclose details of the circumstances in which a lower return may be payable, together with details of how that lower return will be determined.

45.98

1. Include a table identifying up to five main factors that would have the most material impact on forecast distributions, the risks of changes to those factors on distributions and a sensitivity analysis based on changes to those factors.
2. Also explain how any excess returns actually earned by the scheme will be applied. 

Rhodes Asset Management disclosure

45.96

This disclosure is not applicable to Rhodes Finance as it does not pay distributions.

1. Rhodes Asset Management makes distributions out of the interest income received from Rhodes Finance under the Loan Facility net of fees and other costs attributable to the Fund.
2. Not applicable – as above
3. Not applicable – as above
4. Distributions are calculated and payable on a monthly basis. We aim to pay distributions by the 15th day of each month but usually pay within the first week of each month.

45.97 Explanation – (RG 45.99 )

Some mortgage schemes seek to give investors an assurance about income stability by disclosing that a fixed return is generally payable. We consider that such disclosures will be misleading unless the responsible entity also makes prominent disclosure of: (a) the mechanism by which it will seek to achieve a fixed return, together with any limitations of relying on that mechanism; and (b) the circumstances in which it may pay investors a lower return and how it will determine that lower return.

Units issued in the fixed rate Sub-Classes are intended to provide fixed Distribution Rates for 12months from the date of issue, and from each rollover date (if rolled over for further 12month fixed-rate period/s). Distribution Rates are published on our website and are updated on a monthly basis.  Distribution Rates are set by the Rhodes Asset Management board each month after considering various factors, including the current composition of the Rhodes Finance loan book, current lending rates achievable in the market, and the likely lending opportunities available to Rhodes Finance over coming months.  The interest payable by Rhodes Finance to the Fund is set each month by the Rhodes Asset Management board to satisfy all accrued Distributions payable to Unitholders, plus any costs attributable to the Fund.  Since Rhodes Finance makes short term loans of typically less than 12 months (although sometimes as long as 24 months) at fixed interest rates payable by Borrowers, there is a reasonable alignment between the income of Rhodes Finance and its obligations to pay interest to the Fund which includes a fixed component.

Distributions are not guaranteed, and it is possible that the Fund will not achieve its intended Distribution Rates if adverse circumstances arise.  As an example of adverse circumstances, this may occur if Rhodes Finance is unable to meet its obligations under the Loan Facility because Loan(s) that represent a substantial component of the Loan Portfolio default or a number of Borrowers are unable to make interest payments.  In this situation the actual Distribution Rates paid to Unitholders in both fixed-rate Sub-Classes and variable-rate Sub-Classes may need to be adjusted downward in line with lower Fund income.

The Fund will always distribute all its income after expenses to Unitholders.  Rhodes Finance aims to generate a profit by charging an interest margin and other fees to Borrowers, which it retains.

45.98

Distribution Risk	Change Risk	Sensitivity Analysis
Interest rate change	Changes in market interest rates for mortgages and cash rate for cash.	A negative change in commercial lending interest rates may have a negative impact on the ability of Rhodes Finance to source profitable loans, and its ability to meet interest payments to the Fund, which is likely to affect Fund distributions. The impact is dependent on the scale and suddenness of market rate changes.
Borrower risk	A Borrower fails to meet payment obligations or otherwise meet the terms of a Loan or has other financial difficulties. A more significant risk may be realised if a significant number of Borrowers default on their obligations.	This may have an impact on the Fund’s returns. While every effort is made to pre-vet the credit worthiness of a Borrower prior to the loan being offered, it is beyond the control of Rhodes Finance if a Borrower defaults on a loan.
Enforcement risk	Where Rhodes Finance takes enforcement action in respect of a defaulting loan, the cost incurred by Rhodes Finance in doing so could be substantial and could significantly erode any monies recovered from the Borrower.	The risk is subject to the total cost of the enforcement action taken and also the time taken to complete the enforcement and therefore is difficult to determine.
General Economy	Economic downturn in Australia or globally.	This may adversely affect Borrowers’ capacity to meet payment obligations.
Idle Cash	A downturn in quality lending opportunities may result in Rhodes Finance being unable to make sufficient loans to deploy the Fund’s capital.	If Rhodes Finance cannot identify enough quality profitable lending opportunities its Loan Portfolio may not earn sufficient income to support Distribution Rates, which may then fall as a result.
Taxation risk	Changes in tax laws affecting the Fund, could result in lower returns than anticipated.	The degree to which this might affect Distribution Rates is difficult to determine because it is dependent on legislation and regulatory policy and therefore it is hard to determine the impact on the Fund until any tax change is announced.

2. The Fund will always distribute all its income after expenses to Unitholders, therefore there are no excess returns.

 

 

 

Benchmark 8: Withdrawal Arrangements

This benchmark is met by the Fund.

This benchmark is not applicable to Rhodes Finance.

Disclosure Principle 8: Withdrawal Arrangements

45.101

Disclose:

1. the scheme’s withdrawal policy and any rights that the responsible entity has to change the policy;
2. the ability of investors to withdraw from the scheme when it is liquid;
3. the ability of investors to withdraw from the scheme when it is non-liquid;
4. any significant risk factors or limitations that may affect the ability of investors to withdraw from the scheme;
5. how investors can exercise their withdrawal rights, including any conditions on exercising these rights;
6. the approach to rollovers and renewals, including whether the ‘default’ is that investments in the scheme are automatically rolled over or renewed;
7. if the withdrawals from the scheme are to be funded from an external liquidity facility, the material terms of this facility, including any rights the provider has to suspend or cancel the facility;
8. the maximum withdrawal period that applies to the payment of withdrawal requests when the scheme is liquid;
9. any rights the responsible entity has to refuse or suspend withdrawal requests; and
10. the policy of the scheme on balancing the maturity of its assets with the maturity of its liabilities and the ability of its members to withdraw (e.g. if a scheme has a policy of ensuring that sufficient assets are held in readily realisable investments to meet future withdrawal requests, the responsible entity should state this in the PDS, provide details of the source of the realisable investment and report against this in its ongoing disclosure).

 45.102

If the responsible entity makes representations to investors that they can withdraw from the scheme, disclose:

1. the grounds (which must be verifiable) for the statement;
2. the supporting assumptions (which must not be hypothetical only) for the statement;
3. the basis for the statement (which must not be based only on an opinion of the directors of the responsible entity if there are no objective grounds to support that opinion); and
4. any specific risk factors that mean that withdrawal requests might not be satisfied within the expected period.

45.103

If the PDS contains a statement to the effect that, historically, withdrawal requests have been satisfied within a particular period, this may suggest a link between historical withdrawal periods and withdrawal periods that are likely to apply in the future, the responsible entity should ensure the statement clarifies that investors should not conclude that there is such a link between the historical availability of withdrawals and their future availability.

45.104

If the scheme promotes a fixed redemption unit price for investments (e.g. $1 per unit), the responsible entity must clearly disclose details of the circumstances in which a lower amount may be payable, details of how that amount will be determined and the impact of a default under the scheme’s mortgage assets on investors (e.g. on investor distributions and the unit price).

Rhodes Asset Management disclosure

45.101

This disclosure is not applicable to Rhodes Finance as it does not make withdrawal offers.

1. The following is the Withdrawal Policy for the Fund, which is subject to the liquidity position of the Fund and Rhodes Finance, and the discretion of Rhodes Asset Management Asset Management.
   • The Fund is illiquid, as the Fund’s principal asset is the Loan Facility advanced to Rhodes Finance. The Loan Portfolio of Rhodes Finance is in turn illiquid, because there is no readily accessible market to sell short term commercial loan assets, and Rhodes Finance must balance its obligations against loans which are maturing and due to be repaid.
   • We intend to make Withdrawal Offers to Unitholders monthly.
   • Unitholders wishing to make a withdrawal after satisfying the Minimum Investment Term will need to lodge a Withdrawal Participation Notice with us.
   • Withdrawal Participation Notices must be submitted by Midday on the last working day of each month to participate in the following withdrawal offer.
   • The minimum balance of a Unitholder’s Units remaining in the Fund after a part withdrawal must be at least $5,000;
   • Withdrawal Offers will be made within the 1st -7th day of next month (except January – Withdrawal requests made in December and January will be included in Withdrawal Offers in February).
   • If we do not have sufficient liquidity to cover all Withdrawal Participation Notices, we may make a pro-rata offer.
   • The Withdrawal Offer will remain open for 21 days.
   • Payment of redemptions will be within 21 days after the Withdrawal Offer closes.
   • We are not obliged to make a Withdrawal Offer.
   • The Manager may redeem all or some of the Units held by a Member, without the need for a Withdrawal Participation Notice, in certain circumstances.
2. A registered scheme is liquid if liquid assets account for at least 80% of the value of scheme property. A liquid asset is one which can be realised for cash within 21 days. Withdrawal requests are allowed from the scheme when it is a liquid, subject to any conditions at that time.  A scheme would be an illiquid scheme if less than 80% of the assets of the scheme were liquid.  The Fund is illiquid for the reasons given earlier.  This is the case because the Loan Facility extended to Rhodes Finance, and the Rhodes Finance Loan Portfolio, are illiquid.
3. All redemptions would be on the basis provided in section 601KB of the Corporations Act 2001 (Cth). Under this, Rhodes Asset Management Asset Management may (but is not obliged to) offer all Investors in a Class or Sub-Class to withdraw, wholly or partly, their units from the Fund to the extent that particular Fund assets are available to be able to be converted by Rhodes Asset Management Asset Management in time to satisfy the withdrawal requests made by the Investors in response to the offer. If the amount made available is insufficient to meet all requests, then the requests will be satisfied on a pro rata basis.
4. The ability for an investor to redeem their units from the Fund is dependent upon its liquidity. The Fund’s liquidity is influenced by additional investments into the Fund, redemptions and drawdowns required on approved loans.
5. Redemption requests submitted by investors must be in writing and signed by the investor. For further detail, refer to paragraph (a).
6. There is a Minimum Investment Term, but no fixed term.
7. Not applicable as there is no external funding facility.
8. Pursuant to the Constitution, there is no maximum period to meet redemptions if the Fund is a liquid scheme.
9. As this Fund is not liquid, Rhodes Asset Management is not at any time obliged to make a Withdrawal Offer.
10. This is done as part of the process of producing a rolling 12-month cash flow and is managed and monitored by the Rhodes Asset Management board.

45.102

1. Liquidity in the Fund is managed by the Rhodes Asset Management board as described in Disclosure Principle 1: Liquidity
2. See paragraph (a).
3. See paragraph (a).
4. Specific risk factors are referred to in Sections 9.1 of the PDS.

45.103

Not applicable as there is no such statement in the PDS.

45.104

The Fund’s Unit Price has remained at $1 per Unit since inception, and it is intended to remain at $1.  However, if Rhodes Finance were unable to repay the Loan Facility or meet its obligations under the Loan Facility due to significant defaults by Borrowers in its Loan Portfolio, the capital value of the Fund may be impaired resulting in a loss in the Unit Price.

Date of issue: 30 April 2026

 

 

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Start a conversation with us today.

Call 1300 425 594 or

email investors@rhodesam.com.au or

visit us at:

‘The Hub’, Suite 1,

2 Loraine St,

Capalaba QLD 4157

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