Remuneration Document & Information – HC Financial

Our Remuneration

We, HC Financial Advisors Ltd (Trading as HC Financial) act as intermediary (Broker) between you, the consumer, and the product provider with whom we place your business.

The Background

Pursuant to provision 4.58A of the Central Bank of Ireland’s September 2019 Addendum to the Consumer Protection Code, all intermediaries, must make available in their public offices, or on their website if they have one, a summary of the details of all arrangements for any fee, commission, other reward or remuneration provided to the intermediary which it has agreed with its product producers.

What is Remuneration?

Remuneration is the payment earned by HC Financial for work undertaken on behalf of both the provider and the consumer. The amount of remuneration is generally directly related to the value of the products sold

What is Commission?

For the purpose of this document, commission is the payment earned by the Broker for work undertaken on behalf of both the provider and the consumer. The amount of commission is generally directly related to the quantity or value of the products sold.

We are remunerated by commission and other payments from product producers. When assessing products, we will consider the different approach taken by product providers in terms of them integrating sustainability risks into their product offering. This will form part of our analysis for choosing a product provider.

Our Brokerage commission options are displayed as a range, showing the maximum amount which can be received. The level of commission depends on individual circumstances, based on the following factors:

The factors that may impact a variation in charges include;

Client segmentation
Adviser discretion
Competitive pressures
Investment/pensions/saving size
Schemes size
Term/timeline of a policy or service
Complexity of advice
Preferential terms in the market, available to a Brokerage & client at the time

There are different types of commission models:

Single commission model: where payment is made to HC Financial shortly after the sale is completed and is based on a percentage of the premium paid/amount invested/amount borrowed.

Trail/Renewal commission model: Further payments at intervals are paid throughout the life span of the product.

Indemnity Commission

Indemnity commission is the term used to describe a commission payment made before the commission is deemed to be ‘earned’. Indemnity commission may be subject to a clawback (see below) if the consumer lapses or cancels the product before the commission is deemed to be earned.

Other forms of indemnity commission are advances of commission for future sales granted to intermediaries in order to assist with set up costs or business development.

General Insurance Products

General insurance products, such as motor, home, travel, health, retail or liability insurance, are typically subject to a single or standard commission model, based on the amount of premium charged for the insurance product.

Profit Share Arrangements

In some cases, the intermediary may be a party to a profit-share arrangement with a product provider and will earn additional commission. Any business arranged with these product providers on a client’s behalf will be placed with the product provider because that product provider is at the time of placement, the most suitable to meet the client’s requirements, taking all the client’s relevant information, demands and needs into account.

Life Assurance/Investments/Pension Products

For Life Assurance products commission is divided into initial commission and renewal commission (related to premium), fund based or trail (relating to accumulated fund).

Trail commission, bullet commission, fund based, flat commission or renewal commission are all terms used for ongoing payments. Where an investment fund is being built up though an insurance-based investment product or a pension product, the increments may be based on a percentage of the value of the fund or the annual premium. For a single premium/lump sum product, the increment is generally based on the value of the fund.

Life Assurance products fall into either individual or group protection policies and Investment/Pension products would be either single or regular contribution policies. Examples of products include Life Protection, Regular Premium Life Assurance Investments, Single Premium (lump sum) Insurance-based Investments, and Single Premium Pensions.

Sustainability:

This commission payment will not influence our decision to recommend a particular product. We consider how the Product Producers and Insurers have integrated sustainability risks into their investment product offerings prior to making our recommendations to our clients

Investments

Investment firms, which fall within the scope of the European Communities (Markets in Financial Instruments) Regulations 2007 (the MiFID Regulations), offer both standard commission and commission models involving initial and trail commission. Increments may be based on a percentage of the investment management fees, or on the value of the fund.

Bespoke Investments

On occasions, HC will assist clients in arranging bespoke investment solutions. For this type of investment, the commission percentage and/or fee structure varies from product to product. Commissions and/or fees are fixed by product provider at the outset of each investment and these are fully disclosed in investor documents and brochures and HC’s Statement of Suitability.

Credit Products/Mortgages

Commission may be earned by intermediaries for arranging credit for consumers, such as mortgages. The single, or standard, commission model is the most common commission model applied to the sale of mortgage products by mortgage credit intermediaries (Mortgage Broker).

Clawback

Clawback is an obligation on the intermediary to repay unearned commission. Commission can be paid directly after a contract is concluded but is not deemed to be ‘earned’ until after a specified period of time. If the consumer cancels or withdraws from the financial product within the specified time, the intermediary must return commission to the product producer.

Fees

The firm may also be remunerated by fees by the product producer such as policy fee, administration fee, or in the case of investment firms, advisory fees.

Other Fees, Administrative Costs/ Non-Monetary Benefits

The firm may also be in receipt of other fees, administrative costs, or non-monetary benefits such as:

Attendance at product provider seminars
Assistance with Advertising/Branding

Please Note

The commission guidance section gives indicative values across every product provider and every product advised whereby a commission or fee is received within our business. This is generally the maximum HC Financial will take and is subject to change. In certain cases HC Financial may take a different remuneration. Where this happens, this will be disclosed to each client as per the Central Bank Consumer Protection Code regulations, on a client by client basis.

Unregulated Activities

On occasions, HC will assist clients in arranging bespoke investment solutions in Unregulated Activities. For this type of investment, the commission percentage and/or fee structure varies from product to product. Commissions and/or fees are fixed by product provider at the outset of each investment. HC Financial will clearly disclose to clients when regulatory protections do not apply to the product or service provided. Please note that unregulated investments are not regulated by the Central Bank and therefore investor protections are lost/not applicable when investing in a product deemed to be out of scope of regulation, including: compensation schemes, client assets protections, and recourse to the financial services ombudsman.

Click on the links below to access details from the list of the providers that our firm deals with, the products we sell and the maximum commissions available to us, which for ease of reference is in alphabetical order.

Life Companies (Fair Analysis)

HC Financial currently holds letters of Appointment from the following Agencies and Product Producers.

Mortgage (Fair Analysis)

We are authorised by the following Financial Institutions in relation to mortgages.

Deposits (Fair Analysis)

We are authorised by the following Financial Institutions in relation to Deposits

*Permanent TSB plc

*(HC Financial do not get any commission from Permanent tsb plc on deposit accounts. We do however, hold an active agency with Permanent tsb plc.)

General Insurance (Limited Analysis)

We are authorised by the following Financial Institutions in relation to General Insurance

Irish Life Health DAC

Note:
HC Financial Advisers Limited can also provide advice on products by companies with whom we do not hold an appointment.

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Quest Retirement Solutions Ltd

Quest Retirement Solutions Ltd : 5% with 0.5% per annum ongoing.

Broker Assist

We use Broker Assist to streamline and funnel the submission of our business to lenders and this eliminates the need to utilize several portals for doing same. They act in the capacity of a processor on our behalf. The only information we provide them with is the information provided to meet business and legal requirements. For more information about Broker Assist, please visit www.brokerassist.ie The cost of this service is covered by HC Financial and there is no cost charged to the individual client.

Cantor Fitzgerald:
Cantor Fitzgerald:

Cantor Fitzgerald:- Commission of 3% with Nil Trail.

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Conexim Advisers Ltd.

Conexim Advisers Ltd:- Commission Ongoing 0.75% per annum

Merrion Solutions Ltd.

Merrion Solutions Ltd.:- Commission of 3% with Nil Trail.

Newcourt Pensioneer Trustees Limited

HC hold an agency with Newcourt Pensioneer Trustees Limited, however we are currently not receiving any commission.

Newcourt Retirement Fund Managers Limited

Personal Retirement Bonds
Commission 0.25%

Approved Retirement Funds
Commission 0.25%

Personal Retirement Savings Accounts
Commission 0.25%

Self-Administered Pension Scheme
Variable. Commission is case dependent and agreed with the client at the outset

HC hold an agency with Rentflow, Commission of 3% with Nil Trail. *(Rentflow is not regulated by the Central Bank of Ireland).

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Please note:

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Altvest Alternative Investments.

HC hold an agency with Altvest Alternative Investments, Commission of 3% with Nil Trail. *(Altvest Alternative Investments are not regulated by the Central Bank of Ireland).

Distribution Fees will be payable by the Alternative Investment Product Manufacturer or Provider directly to the HC Financial. AltVest will arrange an Agency Appointment between the Alternative Investment Product Manufacturer or Provider and HC Financial for this purpose. The fees payable to HC Financial in relation to each Alternative Product or Service will differ and will be confirmed by AltVest in writing on a case by case basis. Any fees of charges will be declared in writing to the client in advance of any business being transacted.

Quest Capital Trustees Ltd.

We can not currently receiving any commission from Quest Capital Trustee Ltd and any potential future business will be assessed on a case by case basis.