EFFECTIVE FROM SEPTEMBER 2016
‘Windsor Wealth Management’ trading as ‘EarlyRetirement.ie’
These Terms of Business set out the general terms under which our firm will provide business services to you and the respective duties and responsibilities of both the firm and you in relation to such services. Please ensure that you read these terms thoroughly and if you have any queries we will be happy to clarify them. If any material changes are made to these terms we will notify you.
‘Windsor Wealth Management’ trading as ‘EarlyRetirement.ie’ is registered in the Companies Registration Office under Company No 429910 with registered office at 29 Windsor Place, Dublin 2
Authorisation with the Central Bank of Ireland
‘Windsor Wealth Management’ trading as ‘EarlyRetirement.ie’ is regulated by the Central Bank of Ireland as an Insurance Intermediary registered under the European Communities (Insurance Mediation) Regulations, 2005 and as a Multi-Agency Intermediary authorised under the Investment Intermediaries Act, 1995. Copies of our regulatory authorisations are available on request. The Central Bank of Ireland holds registers of regulated firms. You may contact the Central Bank of Ireland on 1890 777 777 or alternatively visit their website at www.centralbank.ie to verify our credentials.
Codes of Conduct
‘Windsor Wealth Management’ trading as ‘EarlyRetirement.ie’ is subject to the Consumer Protection Code, Minimum Competency Code and Fitness & Probity Standards which offer protection to consumers. These Codes can be found on the Central Bank’s website www.centralbank.ie
‘Windsor Wealth Management’ trading as ‘EarlyRetirement.ie’ is a member of the Professional Insurance Brokers Association (PIBA). As a member of PIBA we must be in a position to place insurance with at least five Life Assurance Companies and therefore can generally give consumers greater choice than agents and tied agents.
Our principal business is to provide advice and arrange transactions on behalf of clients in relation to life, pensions, serious illness, income protection, deposits, savings and investment insurance products, collective investment schemes and tracker bonds. Our services include:
- Advising our clients on their insurance, pension and financial needs
- Arranging insurance or pension cover in accordance with our clients requirements
- Helping our clients with any changes to such pensions or insurance cover that they may wish to make
- In order to provide these services we hold agency agreements with a number of Product Producers. A list of these is available on request.
Our Commitment to You
‘Windsor Wealth Management’ trading as ‘EarlyRetirement.ie’ will endeavour in all transactions to:-
- Act honestly and fairly in conducting our business activities in the best interests of our clients and the integrity of the market.
- Act with due skill, care and diligence in the best interests of our clients.
- Act with utmost good faith and integrity in our dealings with clients, product producers, fellow employees and members of the public.
- Have and employ effectively the resources and procedures that are necessary for the proper performance of our business activities.
- Seek from our clients, information regarding their financial situations, investment experience and objectives where investment services are requested or where we have identified a financial need.
- Make adequate disclosure of relevant material information in our dealings with our clients.
- Ensure that errors are corrected and complaints handled speedily, efficiently and fairly.
- Meet our client’s needs without exerting undue pressure or undue influence on them.
- Comply with the letter and spirit of all regulatory requirements applicable to the conduct of our business activities so as to promote the best interests of our clients.
The concept of fair analysis is derived from the Insurance Mediation Directive. It describes the extent of the choice of products and providers offered by an intermediary within a particular category of life assurance, general insurance, mortgages, and/ or a specialist area. The number of contracts and providers considered must be sufficiently large to enable an intermediary to recommend a product that would be adequate to meet a client’s needs.
The number of providers that constitutes ‘sufficiently large’ will vary depending on the number of providers operating in the market for a particular product or service and their relative importance in and share of that market. The extent of fair analysis must be such that could be reasonably expected of a professional conducting business, taking into account the accessibility of information and product placement to intermediaries and the cost of the search.
In order to ensure that the number of contracts and providers is sufficiently large to constitute a fair analysis of the market, we will consider the following criteria:
- the needs of the customer,
- the size of the customer order,
- the number of providers in the market that deal with brokers,
- the market share of each of those providers,
- the number of relevant products available from each provider,
- the availability of information about the products,
- the quality of the product and service provided by the provider,
- cost, and
- any other relevant consideration.
Life & Pensions
‘Windsor Wealth Management’ trading as ‘EarlyRetirement.ie’ provides life assurance and pensions on a fair analysis basis i.e. providing services on the basis of a sufficiently large number of contracts and product producers available on the market to enable us to make a recommendation, in accordance with professional criteria, regarding which contract would be adequate to meet the your needs.
We will provide assistance to you for any queries you may have in relation to the policies or in the event of a claim during the life of the policies and we will explain to you the various restrictions, conditions and exclusions attached to your policy. However, it is your responsibility to read the policy documents, literature and brochures to ensure that you understand the nature of the policy cover; particularly in relation to PHI and serious illness policies.
Specifically on the subject of permanent health insurance policies it is our policy to explain to you a) the meaning of disability as defined in the policy; b) the benefits available under the policy; c) the general exclusions that apply to the policy; and d) the reductions applied to the benefit where there are disability payments from other sources.
For a serious illness policy, we will explain clearly to you the restrictions, conditions and general exclusions that attach to that policy.
Duty of Disclosure to Insurers and Duty of “Utmost Good Faith”
Any failure to disclose material information may invalidate your claim and render your policy void.
‘Windsor Wealth Management’ trading as ‘EarlyRetirement.ie’ is remunerated by commission and other payments from product producers on the completion of business. Where we receive recurring commission, this forms part of the remuneration for initial advice provided. In certain circumstances, it will be necessary to charge a fee for these services. Circumstances where fees are chargeable, we will notify you in writing in advance and agree the scale of fees to be charged.
Our remuneration will be either fee and/or commission based which we will agree with you in advance of all transactions. If remuneration is fee based out standard hourly rate is €300.
It is in your best interests that you review, on a regular basis, the products which we have arranged for you. As your circumstances change, your needs will change. You must advise us of those changes and request a review of the relevant policy so that we can ensure that you are provided with up to date advice and products best suited to your needs. Failure to contact us in relation to changes in your circumstances or failure to request a review, may result in you having insufficient insurance cover and/or inappropriate investments.
Conflicts of interest
It is the policy of our firm to avoid conflicts of interest in providing services to you. However, where an unavoidable conflict of interest arises we will advise you of this in writing before providing you with any service.
Cooling Off Period
As a client acting outside any trade, business or profession you have the right to withdraw from any insurance policy within 14 days of the inception date of cover, or the date which you receive your Policy Schedule. With life insurance and pensions the right of withdrawal is 30 days.
Failure to Pay or Default
We reserve the right to instigate cancellation proceedings in the event of the following:
- Your non payment of the premium due at inception, renewal or following a mid term adjustment
- Your bank returns your cheque due to insufficient funds or any other reason
- Non disclosure of relevant information
- Insurer imposed cancellation
Your insurer may cancel your policy in certain circumstances. These conditions are clearly outlined on all policy documents. Our firm will exercise its legal rights to receive payments due to it from clients (fees and insurance premiums) for services provided.
We have a written procedure in place for the effective consideration and handling of complaints. We ask that you make any complaint against our firm, relating to services provided by us, in writing. We will acknowledge your complaint within 5 business days and we will fully investigate it. On completion of our investigation, we will provide you with a written report of the outcome. In the event that you are still dissatisfied with our handling of or response to your complaint, you are entitled to refer the matter to the Financial Services Ombudsman or the Pensions Ombudsman. A full copy of our complaints procedure is available on request.
‘Windsor Wealth Management’ trading as ‘EarlyRetirement.ie’ complies with the requirements of the Data Protection Acts, 1988 and 2003.
The data which you provide to us will be held on a computer database and paper files for the purpose of arranging transactions on your behalf. The data will be processed only in ways compatible with the purposes for which it was given. We would also like to keep you informed of insurance, investment and any other services provided by us or associated companies with which we have a formal business arrangement and which we think may be of interest to you. We would like to contact you by way of letter, email or telephone call. If you do not wish to receive such marketing information please tick the box in the Terms of Business acknowledgement letter. We may receive referrals from such firms and may advise them of any transactions arranged for you.
We are members of the Investor Compensation Scheme operated by the Investor Compensation Company Ltd. See below for details.
‘Windsor Wealth Management’ trading as ‘EarlyRetirement.ie’ is a member of the Investor Compensation Company Limited (ICCL) established under the Investor Compensation Act 1998. This legislation provides for the establishment of a Compensation Scheme and for the payment in certain circumstances of compensation to clients of firms covered by the Act. In the event that a right to compensation is established, the amount payable is the lesser of 90% of the loss which is recognised as being eligible for compensation or €20,000. Further information on this Scheme is available from the Investor Compensation Company Limited, Dame Street, Dublin 2.
As a member of the Irish Brokers Association (IBA) we are also a member of the IBA Compensation Fund Limited. Subject to the rules of the scheme, the liabilities of its member firms up to a maximum €100,000 per client (€250,000 in aggregate) may be discharged by the Fund on its behalf if the member firm is unable to do so or the above detailed ICCL has failed to adequately compensate any client of the member firm.
Our terms of business shall be governed by and construed in all respects according to the laws of the Republic of Ireland.
‘Windsor Wealth Management’ trading as ‘EarlyRetirement.ie’ (‘the Company’) is regulated by the Central Bank of Ireland.
Terms of Business
Attached are the Company’s Terms of Business, which outline the basis on which we provide services to our clients. Please ensure that you read this document. These Terms of Business apply to all business transactions undertaken for you or services provided to you and will remain in force until further notice. Should we make any material changes to our Terms, we will advise you in advance of providing any further services to you.
‘Windsor Wealth Management’ trading as ‘EarlyRetirement.ie’ complies with the Data Protection Acts 1988 and 2003. The data which you provide to us will be held on a computer database and paper files for the purpose of arranging transactions on your behalf. We would also like to keep you informed of various insurance, investment, and any other services provided by us or associated companies with which we have a formal business arrangement, and which we think may be of interest to you. We may receive referrals from associated companies and may advise them of any transactions arranged for you.