GDD

GENERAL
DISCLOSURE
DOCUMENT
ABOUT US
AND WHAT WE DO
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Table of contents
Purpose of this document .................................................................................. 3
Who are we? ........................................................................................................ 4
Where are we based? .......................................................................................... 5
Who owns and controls us? ............................................................................... 8
Our approach to advice ...................................................................................... 9
How big are we? ................................................................................................10
What financial matters do we advise on? ........................................................11
Our advice process ...........................................................................................12
What if something goes wrong?.......................................................................14
Your personal data and privacy .......................................................................16
How we are paid ...............................................................................................19
How much do our services cost? .....................................................................20
Our customer propositions ..............................................................................21
Types of ‘Immediate services’ customer propositions ...................................22
Types of ‘Recurring services’ customer propositions .....................................23
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Purpose of this document
Financial advice is complicated. Regretfully, there is no getting away from this fact of
life. The decisions you make regarding financial matters will also be some of the most
important in your life, both to you and others. Our role as financial advisers is to ensure
you are placed in a position to make informed and objective decisions about these
important matters. The purpose of this document is to explain what matters we advise on
and how we carry this out.
Choosing a financial adviser is an exercise in trust. We recognise that to establish that
trust, it is necessary for customers to understand more about us as people and as an
organisation. The purpose of this document is to set out the essential elements of that
information.
Disclosure is a regulatory requirement. The Financial Conduct Authority set out strict
requirements for the information financial advisers must disclose to customers at outset of
any engagement. The purpose of this document is not just to meet those requirements but
to try to go further in providing you with comprehensive background information.
Couldn’t you have made this document shorter? Making a document shorter doesn’t
necessarily make it easier to read. Neither will it convey required information more readily.
We’ve spent a lot of care and attention producing a document that we feel conveys our
commitment to provide a quality service to our customers.
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Who are we?
We are a firm of financial advisers based in South Wales. We started in 2004 and serve
customers across the UK.
We are authorised and regulated by the Financial
Conduct Authority (FCA). You can check our
registration at https://register.fca.org.uk/ under the
Firms Register Number: 402291.
We are directly regulated by FCA Financial advice firms can be regulated directly by the
FCA, or an appointed representative of another directly regulated firm.
We are independent. Financial advisers as either ‘independent’, or ‘restricted’. FCA rules
set out that a firm describing itself as independent must:
'assess a sufficient range of relevant products available on the market which must be sufficiently diverse with
regard to their type; and issuers or product providers, to ensure that the client’s investment objectives can be
suitably met; and not be limited to relevant products issued or provided by the firm itself or by entities having
close links with the firm; or other entities with which the firm has such close legal or economic relationships,
including contractual relationships, as to present a risk of impairing the independent basis of the advice
provided.' (See FCA Handbook COBS 6.2B.11)
These are the key differences between independent and restricted financial advisers:
Will consider all retail investment
products
Independent
Yes
Restricted
Can focus only on a particular market No Yes
Can consider products only from certain
product providers
Has to explain to you the type of advice
they offer
Can use ‘independent’ to describe the
advice they offer
Incentivised to recommend one product
over another
No
Yes
Yes
No
No
Yes
Yes
No
No
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Where are we based?
Our offices are located at:
Valleys Innovation Centre
Navigation Park
Abercynon
CF45 4SN
Our offices have free customer parking and are easily accessible to wheelchair users.
Our offices can be contact at:
Phone: 01443 749991
Email:
info@leabold.co.uk
Website: www.leabold.co.uk
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To reach us by road – from Cardiff
‣ Head north on A470 towards Pontypridd.
‣ Continue along the A470, for roughly two miles.
‣ Leave the A470 on the slip road signposted B4275 ‘Abercynon’.
‣ At the roundabout, take the 1 st left.
‣ The Valleys Innovation Centre is the first building on your left.
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To reach us by rail
‣ Arriva Trains Wales from Cardiff Central - both Aberdare and Merthyr Tydfil trains
will stop at Abercynon Station.
‣ Our offices are 0.4 miles, or about a nine-minute walk from the station.
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Who owns and controls us?
Leabold Financial Management Limited is a wholly owned subsidiary of Leabold
Financial Management Holdings Limited, a non-trading holding company that is majority
owned by its founding directors.
You can find out more about the ownership and control of our companies at Companies
House website on https://beta.companieshouse.gov.uk/search/companies by searching
on the following registration numbers:
‣ Leabold Financial Management Limited: 05173817
‣ Leabold Financial Management Holdings Limited: 08296996
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Our approach to advice
We believe in giving clear professional opinions to our customers setting out exactly how
and why they should act. While we respect customers may not always wish to follow our
advice, we believe it important they be placed in position to evaluate the risks and
consequences of not doing so.
We do not believe in undertaking transactions that we reasonably believe may be
imprudent and against our customer’s interests. We do not, therefore, provide execution
only services, ie where clients instruct us to carry out transactions without advice.
We believe that fairness to our customers is key. This means ensuring they get fair value
and are aware of our costs before committing to proceed. Our charging tariffs are intended
to provide a quality service at a highly competitive rate.
We do not believe financial advisers should decide for their clients but place the client in
a position to decide themselves. That includes recommending products, or strategies, that
clients are not capable of fully understanding or confident in managing.
We believe that basic financial products, ie those with the least complexity and greatest
transparency, usually provide best value for clients. We are therefore cautious in
considering anything offering unusual guarantees, low costs, high returns, or tax
advantages.
We do not believe in encouraging clients to undertake transactions for which there is no
immediate tangible benefit. Neither do we recommend transactions where the practical
benefits are likely to be outweighed by the cost.
We believe in quality and technical excellence. All research and preparation of advice is
carried out in-house and subject to a rigorous peer review. We invest significantly in the
ongoing training and competence of our staff with each individual having a supervised
development plan.
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How big are we?
It depends what you mean by ‘big’ but the following may help you decide. Currently:
‣ We employ a qualified financial adviser and three technical support staff that undertake
our administration, research, and preparation of advice. These staff are overseen by a
Chartered Financial Planner who also oversees the day-to-day running of the company.
‣ We do not outsource technical services, compliance, or investment oversight. We take
pride in managing this internally.
‣ We advise on over £70 million of customer investments.
‣ We service over 240 active clients including private individuals and businesses across the
UK.
‣ Combined, our staff have over 150 years of relevant industry experience.
‣ We apply the same principles of prudence and thrift to the financial management of our
business as when advising our customers. We retain a significant amount of our balance
sheet assets as cash, which gives us a superior capability to deal with risks, adapt to
changes in the marketplace, and focus on long-term goals and objectives.
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What financial matters do we advise on?
We provide advice to customers who are defined by the Financial Conduct Authority as
‘retail’ or ‘consumer’. This means ordinary people acting outside their trade or profession.
We also advise ‘professional’ and ‘commercial’ customers. These are typically larger
organisations and businesses who have a greater understanding of the products on which
they require advice.
The permissions we hold from the Financial Conduct Authority enable us to advise on
a wide range of financial products and transactions. These include:
‣ Investing capital to create a regular income or protect against erosion in value from
future inflation. This is typically for retired customers, or those who have amassed
significant funds they wish to pass on to the next generation.
‣ Planning to meet income needs in retirement. This is typically for customers who have
not yet retired but wish to plan for a retirement income to support a particular lifestyle.
‣ Advising on the transfer of entitlements held under occupational pension schemes.
‣ Protection for families against the financial effect of death or incapacity.
‣ Reducing exposure to inheritance tax through use of insurance and investment
products.
We also advise businesses, ranging from small to large, on business planning issues
including.
• Employee workplace pension arrangements and death in service schemes.
• Shareholder protection arrangements.
• Key-person cover.
• Self-invested and director pension arrangements.
• Corporate Investments.
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Our advice process
We start with an informal discussion in which we get to know you and establish whether
we can help you. This is without charge or obligation to proceed.
We offer a number of services, which we refer to as ‘customer propositions'. The fee you
pay is dependent upon the proposition you select. If more than one of our propositions is
appropriate for you, we will advise you of this.
Following our first meeting, if you decide you want us to act on your behalf, we will ask
you to complete a formal customer agreement. This document sets out what we will deliver
and provide you with our best estimate of the cost.
We then collect the details from you needed to prepare our advice. Where you hold
existing financial products, we will ask you to sign authorities allowing us to approach the
providers and obtain details.
Once we have received all necessary information, we will then prepare our advice and
provide this to you in a formal written report setting out the following:
‣ Our understanding of your objectives.
‣ The information used to prepare our advice. Where we are advising on investments,
we will ask you to complete a ‘risk tolerance’ questionnaire so we can establish how
comfortable you are with investing. Our report will set out the results of our assessment
and explain how this has affected our recommendations.
‣ Clear recommendations covering each decision you will need to make, together with
an explanation of why we consider this to be the most appropriate course of action.
‣ Where we are giving advice on investments, we will set out details of the strategy you
should follow as well as the asset types and geographical sectors in which you should
invest. We will also set out both the potential for future returns on your investments
and the potential for you to incur losses if the value of investments fall.
‣ The future steps you will need to take in the future to ensure our advice remains
consistent with your requirements.
‣ Recommendations for product providers with whom you should purchase investments
and other financial products. This will include an assessment of the financial strength
of the provider; cost of the product in relation to others available in the market; and
the servicing record.
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‣ The risks of either following, or not following, our advice.
‣ The costs and charges you will be required to meet both for our services and those of
any recommended product providers.
‣ A list of supplementary documents to help you understand the background to our
advice and place you in the best position to make an informed decision.
When preparing our advice, we apply extensive ‘peer review’ and other internal checks
to ensure accuracy, consistency and to ensure the language used is clear and understandable.
Once a report has passed these checks, we then issue it to you by post, giving you the
opportunity to review and consider at your own pace.
After issuing our advice, we will contact you to hold another meeting to answer any
queries and establish how you wish to proceed. After taking your instructions, we will then
arrange for the transactions you specify to be executed.
If you require, we will then periodically review and meet with you to determine any
changes in your circumstances which might impact on our previous advice. We will also
review the position of your investments and forward to you any critical communications
from providers with whom they have been arranged.
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What if something goes wrong?
Where a customer is unhappy with the service we have provided, it is important to us to
try and resolve the matter as quickly and fairly as possible. Part of the role of our
compliance department is to investigate and manage the resolution of any customer
complaints or expressions of dissatisfaction.
If you have a complaint, you can contact a member of our compliance department at our
main office address. However, all our staff are trained to deal with customer complaints
and ensure these are passed on the compliance department. Please be aware that you do
not have to make a complaint in writing. A verbal complaint is sufficient for us to act.
When we receive a complaint, we will try to acknowledge it, in writing, within 5 working
days. Our acknowledgement will set out our understanding of the matter that has caused
concern or dissatisfaction and will request any further information that we require in order
to proceed with an investigation.
We will try to complete our investigation as soon as possible, at which point we will write
back to you proposing how we intend to resolve matters. Typically, we will do this within
a period of eight weeks. However, in the event that this is not possible, we will write to you
explaining the reason for the delay.
If you are not satisfied with our proposal to resolve your complaint, or we are unable to
finish our investigation within eight weeks, we will invite you to refer the matter to the
Financial Ombudsman Service. The Ombudsman will act on your behalf, without charge,
and their decision is binding on the firm.
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Where we provide services to you as a retail client acting outside their normal trade or
profession, our advice and services are covered by the Financial Ombudsman Service
(FOS) and Financial Services Compensation Scheme (FSCS).
The FOS was set up by Government to resolve
individual complaints between financial
businesses and their customers. They can look
into problems involving most types of money
matters - from payday loans to pensions, pet
insurance to PPI. If they decide someone has
been treated unfairly, they have legal powers to
put things right.
From 1 st April 2022, the maximum claim you can make if you bring a complaint to the
FOS is £375,000. This amount will increase each year in line with inflation
If you have a complaint about a financial product or service and you're not sure how
to get started, you can contact them at:
‣ Financial Ombudsman Service, Exchange Tower, London 14 9SR
‣ Phone: 0800 023 4567
‣ Email: complaint.info@financial-ombudsman.org.uk
You can find out further details about the FOS at: http://www.financialombudsman.org.uk
The FSCS is an arrangement established by
Parliament to protect consumers if a regulated firm
has stopped trading or does not have enough assets to
pay claims made against it.
The amount of compensation you receive will
depend on the basis of your claim. The FSCS only pays compensation for financial
loss. Compensation limits are per person per firm, and per claim category:
‣ Deposits: £85,000 per person per firm
‣ Investments: £85,000 per person per firm
‣ Insurance Business: there is no upper limit on the amount of protection.
You can find further details about the FSCS at: https://www.fscs.org.uk
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Your personal data and privacy
New laws protecting the personal privacy of UK citizens came into force in May 2018.
These increase the existing duties on businesses and organisations to ensure your personal
information is protected and fairly processed.
When you first approach us to become a client, we will obtain information about you
directly and from other sources. Typically, these sources will include those financial services
providers with whom you have existing arrangements, and those services necessary to
determine your identity for the purposes of complying with our statutory obligations.
The information we collect will include details of your personal circumstances, financial
affairs, and your goals and objectives. Where relevant, we may also collect sensitive
information such as details of your health, medical history, religious considerations and
ethical preferences.
We hold your information in both paper and electronic
formats. Typically, we will maintain a paper file with your
most recent information, which is used for day-to-day
servicing of your affairs. These files are periodically
updated and electronically archived to our computer
server.
Unless we receive your consent, we process your
information only in relation to those services we have
agreed to provide to you, and which are set out in the
Customer Agreement you have signed and agreed to.
Where you have given your consent, we will use your
contact information to provide you with regular copies
of our newsletter, birthday and Christmas cards, or to
contact you from time to time on matters we reasonably believe will be of relevance and
interest to you.
We will not, at any time, release your information to any other source for the purposes of
marketing to you.
We will only share your information with another party where necessary to fulfil the
contractual obligations set out in our Customer Agreement, or where subject to a statutory
obligation.
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Those sources with whom we will share data will usually be your existing and potential new
financial service providers, as well as:
https://www.smartsearchuk.co
m
https://www.intelliflo.com/fin
ancial-adviser-software
https://www.xero.com/uk/
Our identity verification
service provider
Our back office
administration and
investment valuation
provider
Our online accounting
system provider
https://products.office.com/e
n-us/sharepoint/collaboration
https://www.financialexpress.
net/analytics
https://www.ev.uk/
https://www.thegooditcompa
ny.co.uk/
Our online data sharing
platform
Our investment data
provider.
Our client risk tolerance
profiling system provider
Our IT management
provider
https://asana.com/
https://doc-safe.co.uk/
https://www.thecabinetoffice
wales.co.uk/
https://www.csgdms.co.uk/
Our online project
management provider
Our secure online
customer portal provider
Our data capture
contractor
Our data storage manager
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Before using an external provider, we always take steps to determine their security and
data handling arrangements are appropriate.
We will hold your information and keep it up to date during the period during which
your Customer Agreement is in force. We may continue to hold such information after this
agreement has terminated where necessary to comply with relevant regulations, or for
indemnification against any future claim.
You are welcome to request to inspect
our records or ask for details of the
information we hold on you, provided that
reasonable notice is given, and such access
does not affect the confidentiality of other
clients. If you request, we will provide details
of any personal data we hold on you in
accordance with the requirements of the
Data Protection Act 2018.
It is important to us to keep your data up-to-date and as accurate as possible. It is also
a legal obligation that we make a reasonable effort to do so. With this in mind, if you make
us aware of any error or omission in the data we hold on you, we will correct this
immediately.
You have the right to request that data we hold on you is deleted. Unless there are
good reasons to prevent this, ie regulatory requirements or the need to indemnify ourselves
against legal action, we will be happy to comply with such requests.
All organisations retaining and handling
personal data are required to register
with the Information Commissioner’s
Office (ICO), The UK’s independent
authority set up to uphold information rights
in the public interest, promoting openness by
public bodies and data privacy for
individuals. Our license number is Z8721312
and details of our registration can be found
on https://ico.org.uk/esdwebpages/search
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How we are paid
Before we agree to provide a service to you, we will provide details of the basis on which
we will be paid, together with an estimate of the actual cost. This is set out in a ‘Customer
Agreement’ document that sets out the scope and nature of the services you will receive,
as well as when and how you will need to pay us.
Before we commence to provide a service, it will be necessary for you to sign the
Customer Agreement and return it to us. It will then be countersigned by a director of the
Company and a copy returned to you.
You have the option to pay for our services directly, or for the providers of your
financial products to deduct our charges from your financial products and pass these on to
us (known as ‘Adviser Charging’). Where you choose to pay us directly, we will invoice you
for the agreed amount on completion for payment within 30 days.
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How much do our services cost?
Our services are based around advice and focus on how financial products can be used
efficiently and effectively to meet customer needs. Our propositions to customers are
therefore built around providing a service consisting of initial advice followed by ongoing
oversight to ensure that advice remains consistent with changes in the customer’s
circumstances and needs.
Each service proposition is fully defined and documented so that our customers are
aware of precisely what we will deliver and the standard to which this will be carried out.
We are similarly rigorous in ensuring our charges are fully transparent and disclosed in a
manner that enables customers, not just to be aware of the cost, but also to make a
reasonable judgement about the value to them.
The amount you pay will depend on the type of service you require. This may be a
flat amount, percentage of the amount you are investing, or an agreed hourly rate. To help
you understand how much our services would cost, we have outlined these in further detail
within this brochure, together with monetary examples.
You will not be charged VAT. This is because services provided by financial advisers are
exempt from VAT where they involve the arrangement of financial products, or where
advice is given with a view to such arrangements. Where we provide services outside of
this exemption our turnover for this type of activity is currently below the level required
for VAT registration. Hence, we are not required to pass this additional cost on to you.
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Our customer propositions
We offer two types of customer propositions:
‣ ‘Immediate services’ – This service proposition is for customers that require us to
carry out an immediate provision of advice. It contains the following elements:
◦ Establish objectives
◦ Collect supporting information
◦ Research and assessment
◦ Provision of advice
◦ Taking instructions
◦ Undertaking transactions
‣ ‘Recurring services’ – This proposition is for customers that require us to carry out
an ongoing service. This service does not include immediate advice, but instead contains
the following periodic elements:
◦ Continuous concession
◦ Continuous monitoring
◦ Continuous forwarding
◦ Recurring advice review
◦ Recurring investment review
◦ Recurring valuations
Further details of the above elements can be found within each customer
propositions, which we recommend that you read thoroughly prior to signing.
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‘Immediate services’ customer propositions
We offer two types of ‘Immediate services’ customer propositions:
‣ ‘Retirement planning’ – This proposition is for customers that require us to carry out
an immediate provision of advice that sets out a financial plan specifically for retirement.
How much does this service cost?
Value reviewed for advice
Charge rate
£0 - £249,999 £2,400.00
£250,000 - £499,999 £2,900.00
£500,000 - £749,999 £3,400.00
£750,000 - £999,999 £3,900.00
£1,000,000+ By arrangement
‣ ‘Investment planning – This proposition is for customers that require us to carry out
an immediate provision of advice that sets out an investment plan for a given purpose.
How much does this service cost?
Value reviewed for advice
£0 - £50,000 £600
£50,001 - £100,000 £825
Charge rate
£100,001 - £150,000 £1,050
£150,001 - £200,000 £1,275
£200,001 - £250,000 £1,500
£250,001 - £300,000 £1,725
£300,001 - £350,000 £1,950
£350,001 - £400,000 £2,175
£400,001 - £450,000 £2,400
£450,001 - £500,000 £2,625
£500,001 - £550,000 £2,850
£550,001 - £600,000 £3,075
£600,001 - £650,000 £3,300
£650,001 - £700,000 £3,525
£700,001 - £750,000 £3,750
£750,001+ 0.50% of investment
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‘Recurring services’ customer propositions
We offer three types of ‘Recurring services’ customer propositions:
‣ ‘Multiple Investment Funds’ – This proposition is for customers that, within their
financial product(s) administered by Leabold, have adopted an investment strategy that
utilises multiple investment funds.
How much does this service cost?
The charge rate is 1.0% per annum is subject to a minimum charge of £850 per annum.
As an example, where the value of your invested assets was £200,000, the annual cost
would be £2,000. However:
• If the value of your investments grew by 5% to £210,000 over the year: £2,100
• If the value of your investments fell by 5% to £190,000 over the year: £1,900
‣ ‘Discretionary Investment Management’ – This proposition is for customers that,
within their financial product(s) administered by Leabold, have adopted an investment
strategy that utilises the services of a Discretionary Investment Manager.
How much does this service cost?
The charge rate is 1.0% per annum is subject to a minimum charge of £850 per annum.
As an example, where the value of your invested assets was £500,000, the annual cost
would be £5,000. However:
• If the value of your investments grew by 5% to £525,000 over the year: £5,250
• If the value of your investments fell by 5% to £475,000 over the year: £4,750
‣ ‘Single Investment Fund’ – This proposition is for customers that, within their
financial product(s) administered by Leabold, have adopted an investment strategy that
utilises a single investment fund.
How much does this service cost?
The charge rate is 0.5% per annum is subject to a minimum charge of £300 per annum.
As an example, where the value of your invested assets was £100,000, the annual cost
would be £500. However:
• If the value of your investments grew by 5% to £105,000 over the year: £525
• If the value of your investments fell by 5% to £95,000 over the year: £475
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