General Disclosure Document
You also want an ePaper? Increase the reach of your titles
YUMPU automatically turns print PDFs into web optimized ePapers that Google loves.
<strong>General</strong> <strong>Disclosure</strong><br />
<strong>Document</strong><br />
About us and what we do
Contents<br />
Page<br />
Purpose of this document ................................................................................. 3<br />
Who are we? ..................................................................................................... 4<br />
Where are we based? ........................................................................................ 5<br />
Who owns and controls us? .............................................................................. 8<br />
Our approach to advice ..................................................................................... 9<br />
How big are we? .............................................................................................. 10<br />
What financial matters do we advise on? ....................................................... 11<br />
Our advice process .......................................................................................... 12<br />
What if something goes wrong? ...................................................................... 14<br />
Your personal data and privacy ....................................................................... 16<br />
How we are paid .............................................................................................. 19<br />
How much do our services cost? ..................................................................... 20<br />
Our customer proposition for ‘Investment Portfolios’ .................................... 21<br />
Our customer proposition for ‘Single Investments’ ......................................... 23<br />
Our customer proposition for ‘Pension Transfers’ .......................................... 25<br />
Our customer proposition for ‘Pension Planning’ ........................................... 27<br />
Our customer proposition for ‘Personal Protection’ ....................................... 30<br />
Our customer proposition for ‘Estate Planning’ .............................................. 32<br />
Our customer proposition for ‘Hourly Charged Advice’ .................................. 34<br />
Page 2 of 34 <strong>General</strong> <strong>Disclosure</strong> <strong>Document</strong> 20/3/2023
Purpose of this document<br />
Financial advice is complicated. Regretfully, there is no getting away from this fact of life.<br />
The decisions you make regarding financial matters will also be some of the most important<br />
in your life, both to you and others. Our role as financial advisers is to ensure you are placed<br />
in a position to make informed and objective decisions about these important matters. The<br />
purpose of this document is to explain what matters we advise on and how we carry this<br />
out.<br />
Choosing a financial adviser is an exercise in trust. We recognise that to establish that trust,<br />
it is necessary for customers to understand more about us as people and as an organisation.<br />
The purpose of this document is to set out the essential elements of that information.<br />
<strong>Disclosure</strong> is a regulatory requirement. The Financial Conduct Authority set out strict<br />
requirements for the information financial advisers must disclose to customers at outset of<br />
any engagement. The purpose of this document is not just to meet those requirements but<br />
to try to go further in providing you with comprehensive background information.<br />
Couldn’t you have made this document shorter? Making a document shorter doesn’t<br />
necessarily make it easier to read. Neither will it convey required information more readily.<br />
We’ve spent a lot of care and attention producing a document that we feel conveys our<br />
commitment to provide a quality service to our customers.<br />
Page 3 of 34 <strong>General</strong> <strong>Disclosure</strong> <strong>Document</strong> 20/3/2023
Who are we?<br />
We are a firm of financial advisers based in South Wales. We started in 2004 and serve<br />
customers across the UK.<br />
We are authorised and regulated by the Financial Conduct<br />
Authority (FCA). You can check our registration at<br />
https://register.fca.org.uk/ under the Firms Register<br />
Number: 402291.<br />
We are directly regulated by FCA Financial advice firms can be regulated directly by the<br />
FCA, or an appointed representative of another directly regulated firm.<br />
We are independent. Financial advisers as either ‘independent’, or ‘restricted’. FCA rules set<br />
out that a firm describing itself as independent must:<br />
'assess a sufficient range of relevant products available on the market which must be<br />
sufficiently diverse with regard to their type; and issuers or product providers, to ensure that<br />
the client’s investment objectives can be suitably met; and not be limited to relevant<br />
products issued or provided by the firm itself or by entities having close links with the firm; or<br />
other entities with which the firm has such close legal or economic relationships, including<br />
contractual relationships, as to present a risk of impairing the independent basis of the<br />
advice provided.' (See FCA Handbook COBS 6.2B.11)<br />
These are the key differences between independent and restricted financial advisers:<br />
Independent<br />
Restricted<br />
Will consider all retail investment products Yes No<br />
Can focus only on a particular market No Yes<br />
Can consider products only from certain product providers No Yes<br />
Has to explain to you the type of advice they offer Yes Yes<br />
Can use ‘independent’ to describe the advice they offer Yes No<br />
Incentivised to recommend one product over another No No<br />
Page 4 of 34 <strong>General</strong> <strong>Disclosure</strong> <strong>Document</strong> 20/3/2023
Where are we based?<br />
Our offices are at:<br />
Valleys Innovation Centre<br />
Navigation Park<br />
Abercynon<br />
CF45 4SN<br />
Phone: 01443 749991<br />
Email: info@leabold.co.uk<br />
Website: www.leabold.co.uk<br />
Our offices have free customer parking and are easily accessible to wheelchair users.<br />
Page 5 of 34 <strong>General</strong> <strong>Disclosure</strong> <strong>Document</strong> 20/3/2023
To reach us by road – from Cardiff<br />
‣ Head north on A470 towards Pontypridd.<br />
‣ Continue along the A470, for roughly two miles.<br />
‣ Leave the A470 on the slip road signposted B4275 ‘Abercynon’.<br />
‣ At the roundabout, take the 1 st left.<br />
‣ The Valleys Innovation Centre is the first building on your left.<br />
Page 6 of 34 <strong>General</strong> <strong>Disclosure</strong> <strong>Document</strong> 20/3/2023
To reach us by rail<br />
‣ Arriva Trains Wales from Cardiff Central - both Aberdare and Merthyr Tydfil trains will<br />
stop at Abercynon Station.<br />
‣ Our offices are 0.4 miles, or about a nine-minute walk from the station.<br />
Page 7 of 34 <strong>General</strong> <strong>Disclosure</strong> <strong>Document</strong> 20/3/2023
Who owns and controls us?<br />
Leabold Financial Management Limited is a wholly owned subsidiary of Leabold Financial<br />
Management Holdings Limited, a non-trading holding company that is majority owned by its<br />
founding directors.<br />
You can find out more about the ownership and control of our companies at Companies<br />
House website on https://beta.companieshouse.gov.uk/search/companies by searching on<br />
the following registration numbers:<br />
Leabold Financial Management Limited: 05173817<br />
Leabold Financial Management Holdings Limited: 08296996<br />
Page 8 of 34 <strong>General</strong> <strong>Disclosure</strong> <strong>Document</strong> 20/3/2023
Our approach to advice<br />
We believe in giving clear professional opinions to our customers setting out exactly how<br />
and why they should act. While we respect customers may not always wish to follow our<br />
advice, we believe it important they be placed in position to evaluate the risks and<br />
consequences of not doing so.<br />
We do not believe in undertaking transactions that we reasonably believe may be imprudent<br />
and against our customer’s interests. We do not, therefore, provide execution only services,<br />
ie where clients instruct us to carry out transactions without advice.<br />
We believe that fairness to our customers is key. This means ensuring they get fair value<br />
and are aware of our costs before committing to proceed. Our charging tariffs are intended<br />
to provide a quality service at a highly competitive rate.<br />
We do not believe financial advisers should decide for their clients but place the client in a<br />
position to decide themselves. That includes recommending products, or strategies, that<br />
clients are not capable of fully understanding or confident in managing.<br />
We believe that basic financial products, ie those with the least complexity and greatest<br />
transparency, usually provide best value for clients. We are therefore cautious in<br />
considering anything offering unusual guarantees, low costs, high returns, or tax<br />
advantages.<br />
We do not believe in encouraging clients to undertake transactions for which there is no<br />
immediate tangible benefit. Neither do we recommend transactions where the practical<br />
benefits are likely to be outweighed by the cost.<br />
We believe in quality and technical excellence. All research and preparation of advice is<br />
carried out in-house and subject to a rigorous peer review. We invest significantly in the<br />
ongoing training and competence of our staff with each individual having a supervised<br />
development plan.<br />
Page 9 of 34 <strong>General</strong> <strong>Disclosure</strong> <strong>Document</strong> 20/3/2023
How big are we?<br />
It depends what you mean by ‘big’ but the following may help you decide. Currently:<br />
We employ four fully qualified financial advisers. Supporting them are seven technical<br />
staff engaged in administration, research, and preparation of advice, who are overseen<br />
by a Chartered Financial Planner. In addition, we have a full-time compliance officer<br />
assisting us with negotiating the range of complex regulations and laws that financial<br />
services businesses must meet.<br />
We do not outsource technical services, compliance, or investment oversight, but take<br />
pride in managing this internally and to a high standard.<br />
We advise on over £70 million of customer investments.<br />
We service over 340 active clients including private individuals and businesses across the<br />
UK.<br />
Combined, our staff have over 150 years of relevant industry experience.<br />
We apply the same principles of prudence and thrift to the financial management of our<br />
business as when advising our customers. We retain a significant amount of our balance<br />
sheet assets as cash, which gives us a superior capability to deal with risks, adapt to<br />
changes in the marketplace, and focus on long-term goals and objectives.<br />
Page 10 of 34 <strong>General</strong> <strong>Disclosure</strong> <strong>Document</strong> 20/3/2023
What financial matters do we advise on?<br />
We provide advice to customers who are defined by the Financial Conduct Authority as<br />
‘retail’ or ‘consumer’. This means ordinary people acting outside their trade or profession.<br />
We also advise ‘professional’ and ‘commercial’ customers. These are typically larger<br />
organisations and businesses who have a greater understanding of the products on which<br />
they require advice.<br />
The permissions we hold from the Financial Conduct Authority enable us to advise on a<br />
wide range of financial products and transactions. These include:<br />
<br />
<br />
<br />
<br />
<br />
Investing capital to create a regular income or protect against erosion in value from<br />
future inflation. This is typically for retired customers, or those who have amassed<br />
significant funds they wish to pass on to the next generation.<br />
Planning to meet income needs in retirement. This is typically for customers who have<br />
not yet retired but wish to plan for a retirement income to support a particular lifestyle.<br />
Advising on the transfer of entitlements held under occupational pension schemes.<br />
Protection for families against the financial effect of death or incapacity.<br />
Reducing exposure to inheritance tax through use of insurance and investment<br />
products.<br />
We also advise businesses, ranging from small to large, on business planning issues<br />
including.<br />
<br />
<br />
<br />
<br />
<br />
Employee workplace pension arrangements and death in service schemes.<br />
Shareholder protection arrangements.<br />
Key-person cover.<br />
Self-invested and director pension arrangements.<br />
Corporate Investments.<br />
Page 11 of 34 <strong>General</strong> <strong>Disclosure</strong> <strong>Document</strong> 20/3/2023
Our advice process<br />
We start with an informal discussion in which we get to know you and establish whether<br />
we can help you. This is without charge or obligation to proceed.<br />
We offer a number of services, which we refer to as ‘customer propositions'. The fee you<br />
pay is dependent upon the proposition you select. If more than one of our propositions is<br />
appropriate for you, we will advise you of this.<br />
Following our first meeting, if you decide you want us to act on your behalf, we will ask you<br />
to complete a formal customer agreement. This document sets out what we will deliver and<br />
provide you with our best estimate of the cost.<br />
We then collect the details from you needed to prepare our advice. Where you hold<br />
existing financial products, we will ask you to sign authorities allowing us to approach the<br />
providers and obtain details.<br />
Once we have received all necessary information, we will then prepare our advice and<br />
provide this to you in a formal written report setting out the following:<br />
<br />
<br />
<br />
<br />
<br />
<br />
<br />
Our understanding of your objectives.<br />
The information used to prepare our advice. Where we are advising on investments, we<br />
will ask you to complete a ‘risk tolerance’ questionnaire so we can establish how<br />
comfortable you are with investing. Our report will set out the results of our<br />
assessment and explain how this has affected our recommendations.<br />
Clear recommendations covering each decision you will need to make, together with an<br />
explanation of why we consider this to be the most appropriate course of action.<br />
Where we are giving advice on investments, we will set out details of the strategy you<br />
should follow as well as the asset types and geographical sectors in which you should<br />
invest. We will also set out both the potential for future returns on your investments<br />
and the potential for you to incur losses if the value of investments fall.<br />
The future steps you will need to take in the future to ensure our advice remains<br />
consistent with your requirements.<br />
Recommendations for product providers with whom you should purchase investments<br />
and other financial products. This will include an assessment of the financial strength of<br />
the provider; cost of the product in relation to others available in the market; and the<br />
servicing record.<br />
The risks of either following, or not following, our advice.<br />
Page 12 of 34 <strong>General</strong> <strong>Disclosure</strong> <strong>Document</strong> 20/3/2023
The costs and charges you will be required to meet both for our services and those of<br />
any recommended product providers.<br />
A list of supplementary documents to help you understand the background to our<br />
advice and place you in the best position to make an informed decision.<br />
When preparing our advice, we apply extensive ‘peer review’ and other internal checks to<br />
ensure accuracy, consistency and to ensure the language used is clear and understandable.<br />
Once a report has passed these checks, we then issue it to you by post, giving you the<br />
opportunity to review and consider at your own pace.<br />
After issuing our advice, we will contact you to hold another meeting to answer any queries<br />
and establish how you wish to proceed. After taking your instructions, we will then arrange<br />
for the transactions you specify to be executed.<br />
If you require, we will then periodically review and meet with you to determine any changes<br />
in your circumstances which might impact on our previous advice. We will also review the<br />
position of your investments and forward to you any critical communications from providers<br />
with whom they have been arranged.<br />
Page 13 of 34 <strong>General</strong> <strong>Disclosure</strong> <strong>Document</strong> 20/3/2023
What if something goes wrong?<br />
Where a customer is unhappy with the service we have provided, it is important to us to try<br />
and resolve the matter as quickly and fairly as possible. Part of the role of our compliance<br />
department is to investigate and manage the resolution of any customer complaints or<br />
expressions of dissatisfaction.<br />
If you have a complaint, you can contact a member of our compliance department at our<br />
main office address. However, all our staff are trained to deal with customer complaints and<br />
ensure these are passed on the compliance department. Please be aware that you do not<br />
have to make a complaint in writing. A verbal complaint is sufficient for us to act.<br />
When we receive a complaint, we will try to acknowledge it, in writing, within 5 working<br />
days. Our acknowledgement will set out our understanding of the matter that has caused<br />
concern or dissatisfaction and will request any further information that we require in order<br />
to proceed with an investigation.<br />
We will try to complete our investigation as soon as possible, at which point we will write<br />
back to you proposing how we intend to resolve matters. Typically, we will do this within a<br />
period of eight weeks. However, in the event that this is not possible, we will write to you<br />
explaining the reason for the delay.<br />
If you are not satisfied with our proposal to resolve your complaint, or we are unable to<br />
finish our investigation within eight weeks, we will invite you to refer the matter to the<br />
Financial Ombudsman Service. The Ombudsman will act on your behalf, without charge,<br />
and their decision is binding on the firm.<br />
Page 14 of 34 <strong>General</strong> <strong>Disclosure</strong> <strong>Document</strong> 20/3/2023
Where we provide services to you as a retail client acting outside their normal trade or<br />
profession, our advice and services are covered by the Financial Ombudsman Service (FOS)<br />
and Financial Services Compensation Scheme (FSCS).<br />
The FOS was set up by Government to<br />
resolve individual complaints between<br />
financial businesses and their customers. They<br />
can look into problems involving most types of<br />
money matters - from payday loans to<br />
pensions, pet insurance to PPI. If they decide<br />
someone has been treated unfairly, they have<br />
legal powers to put things right.<br />
From 1 st April 2022, the maximum claim you can make if you bring a complaint to the FOS is<br />
£375,000. This amount will increase each year in line with inflation<br />
If you have a complaint about a financial product or service and you're not sure how to get<br />
started, you can contact them at:<br />
<br />
Financial Ombudsman Service, Exchange Tower, London 14 9SR<br />
Phone: 0800 023 4567<br />
<br />
Email: complaint.info@financial-ombudsman.org.uk<br />
You can find out further details about the FOS at: http://www.financial-ombudsman.org.uk<br />
The FSCS is an arrangement established by Parliament to protect consumers if a regulated<br />
firm has stopped trading or does not have enough<br />
assets to pay claims made against it.<br />
The amount of compensation you receive will<br />
depend on the basis of your claim. The FSCS only<br />
pays compensation for financial loss. Compensation<br />
limits are per person per firm, and per claim<br />
category:<br />
<br />
<br />
<br />
Deposits: £85,000 per person per firm<br />
Investments: £50,000 per person per firm<br />
Insurance Business: there is no upper limit on the amount of protection.<br />
You can find further details about the FSCS at: https://www.fscs.org.uk<br />
Page 15 of 34 <strong>General</strong> <strong>Disclosure</strong> <strong>Document</strong> 20/3/2023
Your personal data and privacy<br />
New laws protecting the personal privacy of UK citizens came into force in May 2018.<br />
These increase the existing duties on businesses and organisations to ensure your personal<br />
information is protected and fairly processed.<br />
When you first approach us to become a client, we will obtain information about you directly<br />
and from other sources. Typically, these sources will include those financial services providers<br />
with whom you have existing arrangements, and those services necessary to determine your<br />
identity for the purposes of complying with our statutory obligations.<br />
The information we collect will include details of your personal circumstances, financial<br />
affairs, and your goals and objectives. Where relevant, we may also collect sensitive<br />
information such as details of your health, medical history, religious considerations and<br />
ethical preferences.<br />
We hold your information in both paper and electronic<br />
formats. Typically, we will maintain a paper file with<br />
your most recent information, which is used for day-today<br />
servicing of your affairs. These files are periodically<br />
updated and electronically archived to our computer<br />
server.<br />
Unless we receive your consent, we process your<br />
information only in relation to those services we have<br />
agreed to provide to you, and which are set out in the<br />
Customer Agreement you have signed and agreed to.<br />
Where you have given your consent, we will use your<br />
contact information to provide you with regular copies<br />
of our newsletter, birthday and Christmas cards, or to<br />
contact you from time to time on matters we<br />
reasonably believe will be of relevance and interest to you.<br />
We will not, at any time, release your information to any other source for the purposes of<br />
marketing to you.<br />
We will only share your information with another party where necessary to fulfil the<br />
contractual obligations set out in our Customer Agreement, or where subject to a statutory<br />
obligation.<br />
Page 16 of 34 <strong>General</strong> <strong>Disclosure</strong> <strong>Document</strong> 20/3/2023
Those sources with whom we will share data will usually be your existing and potential new<br />
financial service providers, as well as:<br />
https://www.smartsearchuk.com<br />
https://www.intelliflo.com/financ<br />
ial-adviser-software<br />
https://www.xero.com/uk/<br />
Our identity verification<br />
service provider<br />
Our back office<br />
administration and<br />
investment valuation<br />
provider<br />
Our online accounting<br />
system provider<br />
https://products.office.com/enus/sharepoint/collaboration<br />
Our online data sharing<br />
platform<br />
https://www.financialexpress.net<br />
/analytics<br />
Our investment data<br />
provider.<br />
https://www.ev.uk/<br />
Our client risk tolerance<br />
profiling system provider<br />
https://www.thegooditcompany.<br />
co.uk/<br />
Our IT management<br />
provider<br />
https://asana.com/<br />
Our online project<br />
management provider<br />
https://doc-safe.co.uk/<br />
Our secure online<br />
customer portal provider<br />
https://www.thecabinetofficewale<br />
s.co.uk/<br />
Our data capture<br />
contractor<br />
Page 17 of 34 <strong>General</strong> <strong>Disclosure</strong> <strong>Document</strong> 20/3/2023
https://www.csgdms.co.uk/<br />
Our data storage<br />
manager<br />
Before using an external provider, we always take steps to determine their security and<br />
data handling arrangements are appropriate.<br />
We will hold your information and keep it up to date during the period during which your<br />
Customer Agreement is in force. We may continue to hold such information after this<br />
agreement has terminated where necessary to comply with relevant regulations, or for<br />
indemnification against any future claim.<br />
You are very welcome to request to inspect our records or ask for details of the<br />
information we hold on you, provided that reasonable notice is given, and such access does<br />
not affect the confidentiality of the Company’s other clients. If you request, we will provide<br />
details of any personal data we hold on you in accordance with the requirements of the<br />
Data Protection Act 2018.<br />
It is important to us to keep your data up-to-date and as accurate as possible. It is also a<br />
legal obligation that we make a reasonable effort to do so. With this in mind, if you make us<br />
aware of any error or omission in the data we hold on you, we will correct this immediately.<br />
You have the right to request that data we hold on you is deleted. Unless there are good<br />
reasons to prevent this, ie regulatory requirements or the need to indemnify ourselves<br />
against legal action, we will be happy to comply with such requests.<br />
All organisations retaining and handling personal<br />
data are required to register with the Information<br />
Commissioner’s Office (ICO), The UK’s independent<br />
authority set up to uphold information rights in the<br />
public interest, promoting openness by public bodies<br />
and data privacy for individuals. Our license number is<br />
Z8721312 and details of our registration can be found<br />
on https://ico.org.uk/esdwebpages/search<br />
Page 18 of 34 <strong>General</strong> <strong>Disclosure</strong> <strong>Document</strong> 20/3/2023
How we are paid<br />
Before we agree to provide a service to you, we will provide details of the basis on which<br />
we will be paid, together with an estimate of the actual cost. This is set out in a ‘Customer<br />
Agreement’ document that sets out the scope and nature of the services you will receive, as<br />
well as when and how you will need to pay us.<br />
Before we commence to provide a service, it will be necessary for you to sign the Customer<br />
Agreement and return it to us. It will then be countersigned by a director of the Company<br />
and a copy returned to you.<br />
You have the option to pay for our services directly, or for the providers of your financial<br />
products to deduct our charges from your financial products and pass these on to us (known<br />
as ‘Adviser Charging’). Where you choose to pay us directly, we will invoice you for the<br />
agreed amount on completion for payment within 30 days.<br />
Page 19 of 34 <strong>General</strong> <strong>Disclosure</strong> <strong>Document</strong> 20/3/2023
How much do our services cost?<br />
Our services are based around advice and focus on how financial products can be used<br />
efficiently and effectively to meet customer needs. Our propositions to customers are<br />
therefore built around providing a service consisting of initial advice followed by ongoing<br />
oversight to ensure that advice remains consistent with changes in the customer’s<br />
circumstances and needs.<br />
Each service proposition is fully defined and documented so that our customers are aware<br />
of precisely what we will deliver and the standard to which this will be carried out. We are<br />
similarly rigorous in ensuring our charges are fully transparent and disclosed in a manner<br />
that enables customers, not just to be aware of the cost, but also to make a reasonable<br />
judgement about the value to them.<br />
The amount you pay will depend on the type of service you require. This may be a flat<br />
amount, percentage of the amount you are investing, or an agreed hourly rate. To help you<br />
understand how much our services would cost, we have outlined these in further detail<br />
within this brochure, together with monetary examples.<br />
You will not be charged VAT. This is because services provided by financial advisers are<br />
exempt from VAT where they involve the arrangement of financial products, or where<br />
advice is given with a view to such arrangements. Where we provide services outside of this<br />
exemption our turnover for this type of activity is currently below the level required for VAT<br />
registration. Hence, we are not required to pass this additional cost on to you.<br />
Page 20 of 34 <strong>General</strong> <strong>Disclosure</strong> <strong>Document</strong> 20/3/2023
Our customer proposition for ‘Investment Portfolios’<br />
This service is suitable for customers requiring ongoing advice and oversight of an<br />
investment portfolios, as well as those wishing to make new investments.<br />
This service is not suitable for customers intending to hold investments within a single asset<br />
type or through a discretionary manager. It is also not suitable for customers requiring<br />
limited or one-off advice.<br />
We will take over servicing of an existing portfolio of investments and make necessary<br />
recommendations to ensure it is both tax-efficient and consistent with the customer’s<br />
tolerance to risk and requirement for future returns.<br />
Once we have provided our advice, and we have received instructions on how the customer<br />
wishes to proceed, we will then arrange for the agreed transactions to be carried out.<br />
Where you have asked us to provide continuing oversight, we will also:<br />
<br />
<br />
<br />
<br />
<br />
Forward any relevant communications received from product providers from whom you<br />
have transferred servicing rights responsibilities to us.<br />
Monitor any changes in legislation, tax allowance, product terms and product provider<br />
status and notify you where these impact on those objectives, attitude to risk and<br />
personal circumstances you have notified to us.<br />
Undertake a formal review of our original advice and recommendations at intervals of<br />
twelve months.<br />
Calculate and provide you with a valuation of your investments at quarterly intervals.<br />
Advise you on rebalancing your investments and review the suitability of each investment<br />
in your portfolio at six monthly intervals.<br />
How much does this service cost?<br />
To take over any existing investments, prepare our advice and carry out any initial<br />
transactions:<br />
Value of investments<br />
Charge rate<br />
£1 - £50,000 £600<br />
£50,001 - £100,000 £831<br />
£100,001 - £150,000 £1,063<br />
£150,001 - £200,000 £1,294<br />
Page 21 of 34 <strong>General</strong> <strong>Disclosure</strong> <strong>Document</strong> 20/3/2023
£200,001 - £250,000 £1,526<br />
£250,001 - £300,000 £1,758<br />
£300,001 - £350,000 £1,989<br />
£350,001 - £400,000 £2,221<br />
£400,001 - £450,000 £2,452<br />
£450,001 - £500,000 £2,684<br />
£500,001 - £550,000 £2,916<br />
£550,001 - £600,000 £3,147<br />
£600,001 - £650,000 £3,379<br />
£650,001 - £700,000 £3,610<br />
£700,001 - £750,000 £3,842<br />
£750,001 - £800,000 £4,074<br />
£800,001 - £850,000 £4,305<br />
£850,001 - £900,000 £4,537<br />
£900,001 - £950,000 £4,768<br />
£950,001 - £1,000,000 £5,000<br />
£1,000,000+ 0.50% of investment<br />
Where we are subsequently required to advise on additional investments:<br />
Per amount of additional investment<br />
Charge rate<br />
£50,000 £400<br />
To provide continuing oversight:<br />
Value of investments<br />
Charge Rate<br />
Minimum charge<br />
Charge rate<br />
1.0%pa of investment value<br />
£500pa<br />
As an example - Let us say you were to ask us to establish or takeover investments to the<br />
value of £100,001, the cost of initial advice, including any transactions you required us to<br />
undertake, would be £1063.<br />
The subsequent annual cost would depend on how much your investments increased or<br />
reduced in value, for example:<br />
If the value of your investments remained at £100,000: £1000pa<br />
If the value of your investments grew by 5% to £105,000: £1050pa<br />
If the value of your investments fell by 5% to £95,000: £950pa<br />
Please note - You are able to cease our services at any time, subject to confirming this in<br />
writing to us.<br />
Page 22 of 34 <strong>General</strong> <strong>Disclosure</strong> <strong>Document</strong> 20/3/2023
Our customer proposition for ‘Single Investments’<br />
This service is suitable for customers who wish to invest in a single asset type or investment<br />
manager. It is suited both to smaller investments of less than £100,000, as well as larger<br />
investments where a discretionary fund manager is to be appointed.<br />
This service is not suitable for customers intending to hold investments in multiple asset<br />
types or through more than one investment manager. It is also not suitable for customers<br />
requiring limited or one-off advice.<br />
We will take over servicing of an existing portfolio of investments and make necessary<br />
recommendations to ensure it is both tax-efficient and consistent with the customer’s<br />
tolerance to risk and requirement for future returns.<br />
Once we have provided our advice, and we have received instructions on how the customer<br />
wishes to proceed, we will then arrange for the agreed transactions to be carried out.<br />
Where you have asked us to provide continuing oversight, we will also:<br />
<br />
<br />
<br />
<br />
Forward any relevant communications received from product providers from whom you<br />
have transferred servicing rights responsibilities to us.<br />
Monitor any changes in legislation, tax allowance, product terms and product provider<br />
status and notify you where these impact on those objectives, attitude to risk and<br />
personal circumstances you have notified to us.<br />
Undertake a formal review of our original advice and recommendations at intervals of<br />
twelve months.<br />
Calculate and provide you with a valuation of your investments at quarterly intervals.<br />
How much does it cost?<br />
To take over your existing investments, prepare our advice and carry out transactions:<br />
Value of investments<br />
Charge rate<br />
£1 - £50,000 £600<br />
£50,001 - £100,000 £831<br />
£100,001 - £150,000 £1,063<br />
£150,001 - £200,000 £1,294<br />
£200,001 - £250,000 £1,526<br />
£250,001 - £300,000 £1,758<br />
£300,001 - £350,000 £1,989<br />
Page 23 of 34 <strong>General</strong> <strong>Disclosure</strong> <strong>Document</strong> 20/3/2023
£350,001 - £400,000 £2,221<br />
£400,001 - £450,000 £2,452<br />
£450,001 - £500,000 £2,684<br />
£500,001 - £550,000 £2,916<br />
£550,001 - £600,000 £3,147<br />
£600,001 - £650,000 £3,379<br />
£650,001 - £700,000 £3,610<br />
£700,001 - £750,000 £3,842<br />
£750,001 - £800,000 £4,074<br />
£800,001 - £850,000 £4,305<br />
£850,001 - £900,000 £4,537<br />
£900,001 - £950,000 £4,768<br />
£950.001 - £1,000,000 £5,000<br />
£1,000,000+ 0.50% of investment<br />
Where we are subsequently required to advise on additional investments:<br />
Per amount of additional investment<br />
Charge rate<br />
£50,000 £400<br />
To provide continuing oversight:<br />
Value of investments<br />
Charge Rate<br />
Minimum charge<br />
Charge rate<br />
0.50%pa of investment value<br />
£500pa<br />
As an example - Let us say you were to ask us to establish or takeover investments to the<br />
value of £100,001.<br />
The cost of initial advice, including any transactions you required us to undertake, would be<br />
£1063.<br />
The subsequent annual cost would depend on how much your investments increased or<br />
reduced in value, for example:<br />
If the value of your investments remained at £100,000: £500pa<br />
If the value of your investments grew by 5% to £105,000: £525pa<br />
If the value of your investments fell by 5% to £95,000: £475pa<br />
Please note - You are able to cease further charges at any time, subject to confirming this in<br />
writing to us.<br />
Page 24 of 34 <strong>General</strong> <strong>Disclosure</strong> <strong>Document</strong> 20/3/2023
Our customer proposition for ‘Pension Transfers’<br />
This service is suitable for customers who require advice on whether to transfer the value<br />
of pension benefits built up under an employer’s occupational pension scheme to another<br />
type of pension arrangement.<br />
This service is not suitable for customers who require a transfer to be undertaken<br />
irrespective of the risks and consequences, or who require limited advice.<br />
We operate a fully non-contingent charge for this service. This means that the charge<br />
remains the same whether we advise you to transfer your pension benefits or retain your<br />
existing pension entitlement.<br />
The purpose of the service is to advise you on whether your interests are best met by<br />
transferring or retaining your pension entitlement. Critical considerations will include the<br />
extent to which you are capable and comfortable in understanding the risks and<br />
consequences of what is a complex and potentially risky transaction.<br />
We will establish the value of benefits provided by the scheme and compare this against<br />
the amount of money that the scheme would be prepared to transfer to another pension<br />
arrangement in lieu of those benefits.<br />
We will consider the extent to which a transfer might affect the value of the benefits you<br />
would receive on retirement, as well as those that would be payable to your dependents in<br />
on your death.<br />
We will determine the overall level of income you may require in retirement and how this<br />
is likely to be split between essential domestic and non-essential lifestyle related<br />
expenditure. We then advise the earliest date at which retirement could reasonably be<br />
considered.<br />
Where a transfer is recommended, we will advise on how a portfolio of investments can be<br />
constructed to provide a potential for growth that is consistent with both the target<br />
retirement income, as well as your tolerance to investment risk. We will also consider the<br />
range of personal pension products that could be utilised to hold these investments, taking<br />
account of the cost and requirement for flexibility.<br />
Once our advice has been provided to you, we will meet with you and resolve any further<br />
queries you may have.<br />
Page 25 of 34 <strong>General</strong> <strong>Disclosure</strong> <strong>Document</strong> 20/3/2023
How much does it cost?<br />
The following charge covers the research, preparation and issuing a written report<br />
setting out our advice. In the event that we recommend a transfer, it also covers our<br />
carrying out that transaction on your behalf:<br />
Transferred pension fund<br />
Charge rate<br />
£0 - £249,999 £2,400.00<br />
£250,000 - £499,999 £2,900.00<br />
£500,000 - £749,999 £3,400.00<br />
£750,000 - £999,999 £3,900.00<br />
£1,000,000 - By arrangement<br />
As an example - Let us say you were to ask us to advise on a transfer of £100,001, the cost<br />
of advice and any transactions you required us to undertake, would be £2,400.<br />
Page 26 of 34 <strong>General</strong> <strong>Disclosure</strong> <strong>Document</strong> 20/3/2023
Our customer proposition for ‘Retirement Planning’<br />
This service is suitable for customers requiring ongoing advice and oversight of their<br />
pension fund investments, as well as those wishing to make new pension contributions.<br />
This service is not suitable for customers intending to hold pension fund investments within<br />
a single asset type or through a discretionary manager. It is also not suitable for customers<br />
requiring limited or one-off advice.<br />
We will take over servicing of an existing pension fund and make necessary<br />
recommendations to ensure it is consistent with the customer’s tolerance to risk and<br />
requirement for future returns.<br />
We will forecast the likely value of your pension fund and the benefit this may provide on<br />
your retirement. We will then compare this against your need for income at that point and<br />
identify any risk of shortfall.<br />
We will also examine features, charges and financial strength of the providers with whom<br />
your pension fund is invested to determine the extent to which these meet your needs. We<br />
will also determine whether effectiveness of the investments selected those products to<br />
establish whether they provide the optimum potential for future returns.<br />
Once we have provided our advice, and we have received instructions on how the customer<br />
wishes to proceed, we will then arrange for the agreed transactions to be carried out.<br />
Where you have asked us to provide continuing oversight, we will also:<br />
<br />
<br />
<br />
<br />
<br />
Forward any relevant communications received from product providers from whom you<br />
have transferred servicing rights responsibilities to us.<br />
Monitor any changes in legislation, tax allowance, product terms and product provider<br />
status and notify you where these impact on those objectives, attitude to risk and<br />
personal circumstances you have notified to us.<br />
Undertake a formal review of our original advice and recommendations at intervals of<br />
twelve months.<br />
Calculate and provide you with a valuation of your investments at quarterly intervals.<br />
Advise you on rebalancing your investments and review the suitability of each investment<br />
in your portfolio at six monthly intervals.<br />
Page 27 of 34 <strong>General</strong> <strong>Disclosure</strong> <strong>Document</strong> 20/3/2023
How much does it cost?<br />
To take over your existing pension fund, prepare our advice and carry out transactions:<br />
Value of the pension fund<br />
Charge rate<br />
£1 - £50,000 £600<br />
£50,001 - £100,000 £831<br />
£100,001 - £150,000 £1,063<br />
£150,001 - £200,000 £1,294<br />
£200,001 - £250,000 £1,526<br />
£250,001 - £300,000 £1,758<br />
£300,001 - £350,000 £1,989<br />
£350,001 - £400,000 £2,221<br />
£400,001 - £450,000 £2,452<br />
£450,001 - £500,000 £2,684<br />
£500,001 - £550,000 £2,916<br />
£550,001 - £600,000 £3,147<br />
£600,001 - £650,000 £3,379<br />
£650,001 - £700,000 £3,610<br />
£700,001 - £750,000 £3,842<br />
£750,001 - £800,000 £4,074<br />
£800,001 - £850,000 £4,305<br />
£850,001 - £900,000 £4,537<br />
£900,001 - £950,000 £4,768<br />
£950,001 - £1,000,000 £5,000<br />
£1,000,000+ 0.50% of pension fund<br />
Where we are subsequently required to advise on additional investments:<br />
Per amount of additional pension contribution or Charge rate<br />
transferred pension fund<br />
£50,000 £400<br />
To provide continuing oversight:<br />
Value of pension fund<br />
Charge Rate<br />
Minimum charge<br />
Charge rate<br />
1.0%pa of investment value<br />
£500pa<br />
Page 28 of 34 <strong>General</strong> <strong>Disclosure</strong> <strong>Document</strong> 20/3/2023
As an example - Let us say you have an existing pension fund to the value of £100,001. The<br />
cost of initial advice would £1063.<br />
If you required us to continue overseeing your pension fund, the cost each year would<br />
depend on how much your pension fund increased or reduced in value, for example:<br />
If your pension fund remained at £100,000, the charge would be £1000<br />
If your pension fund grew by 5% to £105,000, the charge would be £1050<br />
If your pension fund fell by 5% to £95,000, the charge would be £950<br />
Please note - You are able to cease further charges at any time, subject to confirming this in<br />
writing to us.<br />
Page 29 of 34 <strong>General</strong> <strong>Disclosure</strong> <strong>Document</strong> 20/3/2023
Our customer proposition for ‘Personal Protection’<br />
This service is suitable for customers requiring advice on planning for the financial<br />
consequences of death or incapacity to their dependents, or who wish to mitigate the<br />
potential effect of inheritance tax on beneficiaries to their estate.<br />
This service is not suitable for customers requiring limited advice or one-off advice.<br />
We will establish the financial effect on your dependants if you were to die or become<br />
incapacitated and the extent to which your financial affairs may be arranged to meet their<br />
needs. Where there is a shortfall, we will examine and identify appropriate means for this to<br />
be covered within your expenditure budget.<br />
Where it is necessary to take out insurance to cover any shortfall, we will examine<br />
features, charges and financial strength of providers and recommend those whom best<br />
meet your needs.<br />
We will also advise on establishing a will and other legal arrangements necessary to care<br />
for children and ensure access to finances are not restricted by probate. Where you do not<br />
already have a solicitor, we will arrange to introduce you to a suitable local practice.<br />
Once we have provided our advice, and we have received instructions on how the customer<br />
wishes to proceed, we will then arrange for the agreed transactions to be carried out.<br />
Where you have asked us to provide continuing oversight, we will also:<br />
<br />
<br />
<br />
Forward any relevant communications received from product providers from whom you<br />
have transferred servicing rights responsibilities to us.<br />
Monitor any changes in legislation, tax allowance, product terms and product provider<br />
status and notify you where these impact on those objectives, attitude to risk and<br />
personal circumstances you have notified to us.<br />
Undertake a formal review of our original advice and recommendations at intervals of<br />
twelve months.<br />
In the event of your death, we will provide your dependents with a comprehensive range of<br />
support and advice services to allow them to manage funeral and other financial<br />
arrangements<br />
Page 30 of 34 <strong>General</strong> <strong>Disclosure</strong> <strong>Document</strong> 20/3/2023
How much does it cost?<br />
Value of estate in the event of death<br />
Charge rate<br />
£0 - £499,999 £750.00<br />
£500,000-£999,999 £1,500.00<br />
£1,000,000 - £2,999,999 £2,500.00<br />
£3,000,000 - £4,999,999 £3,500.00<br />
£5,000,000 + - By arrangement<br />
To provide continuing oversight:<br />
Value of estate in the event of death<br />
Charge rate<br />
£0 - £499,999 £250.00<br />
£500,000-£999,999 £750.00<br />
£1,000,000 - £2,999,999 £1,250.00<br />
£3,000,000 - £4,999,999 £1,750.00<br />
£5,000,000 + - By arrangement<br />
As an example - Let us say the existing value of your estate in the event of your death was<br />
£250,000. The cost of initial advice would £750.<br />
If you required us to continue overseeing your affairs and providing bereavement support,<br />
the cost each year would be £250<br />
Please note - You are able to cease further charges at any time, subject to confirming this in<br />
writing to us.<br />
Page 31 of 34 <strong>General</strong> <strong>Disclosure</strong> <strong>Document</strong> 20/3/2023
Our customer proposition for ‘Estate Planning’<br />
This service is suitable for customers requiring advice on the immediate gifting of assets and<br />
maximising the value of the estate to be passed to beneficiaries following death.<br />
This service is not suitable for customers requiring limited advice or one-off advice.<br />
We will establish that you have adequate Income and capital to meet your needs. Including<br />
provision for long term care, in order to assess the level of any surplus capital that may be<br />
used either to provide immediate gifts or for passing into trusts for the purposes of reducing<br />
exposure to inheritance tax.<br />
Where it is necessary to take out insurance to cover the shortfall in the amount of<br />
Inheritance tax your estate may be liable to pay, we will examine features, charges and<br />
financial strength of providers and recommend those who best meet your needs.<br />
We will also advise you on establishing wills, power of attorney and other legal<br />
arrangements necessary to care for you while alive and reduce delays in settling your estate<br />
after your death. If you do not already have a solicitor, we will arrange to introduce you to a<br />
suitable local practice.<br />
Once we have provided our advice, and we have received instructions on how the customer<br />
wishes to proceed, we will then arrange for the agreed transactions to be carried out.<br />
Where you have asked us to provide continuing oversight, we will also:<br />
<br />
<br />
<br />
Forward any relevant communications received from product providers from whom you<br />
have transferred servicing rights responsibilities to us.<br />
Monitor any changes in legislation, tax allowance, product terms and product provider<br />
status and notify you where these impact on those objectives, attitude to risk and<br />
personal circumstances you have notified to us.<br />
Undertake a formal review of our original advice and recommendations at intervals of<br />
twelve months.<br />
In the event of your death, we will provide your dependents with a comprehensive range of<br />
support and advice services to allow them to manage funeral and other financial<br />
arrangements<br />
Page 32 of 34 <strong>General</strong> <strong>Disclosure</strong> <strong>Document</strong> 20/3/2023
How much does it cost?<br />
Value of estate in the event of death<br />
Charge rate<br />
£0 - £499,999 £750.00<br />
£500,000-£999,999 £1,500.00<br />
£1,000,000 - £2,999,999 £2,500.00<br />
£3,000,000 - £4,999,999 £3,500.00<br />
£5,000,000 + - By arrangement<br />
To provide continuing oversight:<br />
Value of estate in the event of death<br />
Charge rate<br />
£0 - £499,999 £250.00pa<br />
£500,000-£999,999 £750.00pa<br />
£1,000,000 - £2,999,999 £1,250.00pa<br />
£3,000,000 - £4,999,999 £1,750.00pa<br />
£5,000,000 + - By arrangement<br />
As an example - Let us say the existing value of your estate in the event of your death was<br />
£250,000. The cost of initial advice would £750.<br />
If you required us to continue overseeing your affairs and providing bereavement support,<br />
the cost each year would be £250<br />
Please note - You can cease further charges at any time, subject to confirming this in writing<br />
to us.<br />
Page 33 of 34 <strong>General</strong> <strong>Disclosure</strong> <strong>Document</strong> 20/3/2023
Our customer proposition for ‘Hourly Charged Advice’<br />
This service is suitable for customers who require limited, one-off or advice areas not<br />
covered by our other propositions.<br />
This service is not suitable for customers requiring continuing oversight of their affairs.<br />
As with our other propositions, we will review any relevant existing financial products you<br />
hold and ensure they are consistent with your needs and objectives. Once our advice has<br />
been provided to you, and we have received your instructions on how you wish to proceed,<br />
we will then arrange for the agreed transactions to be carried out.<br />
How much does it cost? - The cost of this service is charged at £100 per hour. The total<br />
amount you pay will therefore depends on the complexity and amount of advice involved.<br />
However, we will always provide an estimate, in advance.<br />
Page 34 of 34 <strong>General</strong> <strong>Disclosure</strong> <strong>Document</strong> 20/3/2023