Our Remuneration Policy- CP116

 

Our Remuneration

We, Eamonn J Moore Limited trading as Moore Financial Consultants, act as an intermediary 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/commission?

For the purposes of this document, remuneration/commission is the payment earned by the intermediary 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.

Some commonly used terms in relation to remuneration/commission are as follows:

Initial commission: this is where payment is made to the intermediary shortly after the business is transacted and is based on a percentage of the premium paid/amount invested/amount borrowed.

Trail/renewal commission model: this is where further payments at intervals are paid throughout the life span of the product. ‘Bullet commission’, ‘fund-based commission’ and ‘flat commission’ are other terms which can sometimes be used interchangeably with trail/renewal commission.

Indemnity commission: this 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.

Life Assurance and Pension products

For these products, commission is generally comprised of initial commission and trail/renewal commission. The initial commission in relation to a single contribution product is generally based on the amount of the single contribution. The initial commission in relation to a regular contribution product is generally based on the amount of the regular contribution for the first 12 months. The trail commission in relation to pension products is generally related to the fund value. The trail commission in relation to life assurance products is generally related to the ongoing premium.

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 (otherwise referred to as a Mortgage Broker). This generally involves the intermediary receiving a payment from the lender amounting to a percentage of the loan/mortgage amount, with no further remuneration arising thereafter.

Clawback

The term Clawback in this context refers to an obligation on the intermediary to repay what is deemed to be unearned commission. Commission can be paid directly after business is transacted 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 may be required to return the commission to the product producer.

Fees

The firm may also be remunerated by charging a fee to the client.

Preferred Providers

We do not have any preferred provider arrangements.

Important Note

The following commission guidance section gives indicative values across every product provider with whom we have an agency and every product in relation to which we can potentially earn a commission. We are obliged by regulation to advise you of the maximum amount that we could receive in commission, but this does not mean that we will receive the maximum amount in all cases. Often, we will receive a lower commission/remuneration than the maximum possible amount – the actual commission/remuneration receivable by us will be disclosed to each client in advance of business being transacted, in line with the Central Bank Consumer Protection Code, on a client-by-client basis.

 

Single Contribution Products Maximum initial commission Clawback Period Maximum trail commission
       
Single Contribution Pension      
Aviva 5% n/a 1% p.a.
Irish Life 5% n/a 0.75% p.a.
New Ireland 5% n/a 1% p.a.
Standard Life 5% n/a 1% p.a.
Zurich Life 5.5% n/a 1% p.a.
       
Single Contribution PRSA      
Aviva 4% n/a 0.5% p.a.
Irish Life 5% n/a 0.75% p.a.
New Ireland 5% 5 Years 0.5% p.a.
Standard Life 3% n/a 0.5% p.a.
Zurich Life 5.5% n/a 0.5% p.a.
       
ARF / AMRF      
Aviva 5% n/a 1% p.a.
Irish Life 5% n/a 1% p.a.
New Ireland 5% n/a 1% p.a.
Standard Life 4% n/a 1% p.a.
Zurich Life 5% n/a 0.5% p.a.
       
Annuity      
Aviva 3% n/a n/a
Irish Life 3% n/a n/a
New Ireland 3% n/a n/a
Zurich Life 3% n/a n/a
       
Investment Bond      
Aviva 5% n/a 1% p.a.
BCP 2.1% n/a n/a
Cantor Fitzgerald Ireland Ltd. 2.25% n/a 0.5%
Davy 1.5% n/a 0.5%
Investec Europe Limited 2.25% n/a n/a
Irish Life 3% n/a 0.5% p.a.
New Ireland 4% 3 Years 1% p.a.
Standard life 4% n/a 1% p.a.
Zurich Life 5% n/a 0.5%p.a.

 

Mortgages Commission Clawback Period
Haven Mortgages Limited 1% 3 years
Finance Ireland 1% 3 years
All mortgage partners via Brokers

Ireland

1% 3 years

 

 

Regular Contribution Products

Initial commission Clawback Period Renewa/

Flat Commission

 

Trail commission

 

 

       
Regular Contribution Pension        
Aviva 20% 5 Years n/a 1% p.a.
Aviva (Heritage Friends) 25% 5 Years n/a 0.75% p.a.
Irish Life 17.5% 5 Years 5% 0.5% p.a.
New Ireland 25% 5 Years 8% 1% p.a.
Standard Life 20% 5 Years 5% 1% p.a.
Zurich Life 20% 5 Years 3% 0.5% p.a.
         
Regular Contribution PRSA        
Aviva 20% 5 Years n/a 0.5% p.a.
Irish Life 17.5% 5 Years 5% 0.5% p.a.
New Ireland 20% 5 Years 6% 0.5% p.a.
Standard Life 20% 5 Years 5% 0.5% p.a.
Zurich Life 20% 5 Years 5% 0.5% p.a.
         
Savings        
Aviva 15% n/a n/a 1% p.a.
Aviva (Heritage Friends) 10% n/a n/a 0.75% p.a.
Irish Life 5.5% n/a 5.5% 0.5% p.a.
New Ireland 10% 5 Years 2.5% 0.5% p.a.
Standard Life 15% 5 Years n/a 1% p.a.
Zurich Life 20% 4 Years 1% 0.5% p.a.

 

Individual Protection Yr1 2 3 4 5 6 7 8 9+ Clawback Period
Aviva 200% 30% 30% 30% 30% 30% 30% 30% 30% 2 Years
Irish Life 120% 28% 30% 28% 28% 30% 28% 28% 28% n/a
New Ireland 225% 50% 20% 20% 20% 12.5

%

12.5

%

12.5

%

12.5

%

5 Years
Royal London 225% 0% 0% 0% 0% 3% 3% 3% 3% 5 Years
Zurich Life 150% 12% 12% 12% 12% 12% 12% 12% 12% 1 Year

 

Group Protection Death In Service Clawback Period Permanent Health Insurance Clawback Period
Aviva 6% n/a 12.5% n/a
Irish Life 6% n/a 12.5% n/a
New Ireland 15% 1 Year 20% 1 Year
Zurich Life 6% n/a 12.5% n/a