Remuneration for Financial Adviser GCFS
We, Gwen Clarke Financial Services Ltd. act as intermediary between you, the consumer, and the product
provider with whom we place your business.
Pursuant to provision 4.58A of the Central Bank of Ireland’s September 2019 Addendum to the Consumer
Protection Code, all intermediaries, must make available in their public offices, or on their website if they
have one, a summary of the details of all arrangements for any fee, commission, other reward or
remuneration provided to the intermediary which it has agreed with its product producers.
What is commission?
For the purpose of this document, remuneration is the payment earned by the intermediary for work
undertaken on behalf of both the provider and the consumer. The amount of remuneration is generally
directly related to the value of the products sold.
There are different types of remuneration/commission models:
Single commission model: where payment is made to the intermediary shortly after the sale is completed
and is based on a percentage of the premium paid/amount invested/amount borrowed.
Trail/Renewal commission model: Further payments at intervals are paid throughout the life span of the
Indemnity commission is the term used to describe a commission payment made before the commission is
deemed to be ‘earned’. Indemnity commission may be subject to a clawback (see below) if the consumer
lapses or cancels the product before the commission is deemed to be earned.
Other forms of indemnity commission are advances of commission for future sales granted to intermediaries
in order to assist with set up costs or business development.
General insurance products
General insurance products, such as motor, home, travel, health, retail or liability insurance, are typically
subject to a single or standard commission model, based on the amount of premium charged for the
Life Assurance/Investments/Pension products
For Life Assurance products commission is divided into initial commission and renewal commission (related
to premium), fund based or trail (relating to accumulated fund).
Trail commission, bullet commission, fund based, flat commission or renewal commission are all terms used
for ongoing payments. Where an investment fund is being built up through an insurance-based investment
product or a pension product, the increments may be based on a percentage of the value of the fund or the
annual premium. For a single premium/lump sum product, the increment is generally based on the value of
Life Assurance products fall into either individual or group protection policies and Investment/Pension
products would be either single or regular contribution policies. Examples of products include Life
Protection, Regular Premium Life Assurance Investments, Single Premium (lump sum) Insurance-based
Investments, and Single Premium Pensions.
Investment firms, which fall within the scope of the European Communities (Markets in Financial
Instruments) Regulations 2007 (the MiFID Regulations), offer both standard commission and commission
models involving initial and trail commission. Increments may be based on a percentage of the investment
management fees, or on the value of the fund.
Clawback is an obligation on the intermediary to repay unearned commission. Commission can be paid
directly after a contract is concluded but is not deemed to be ‘earned’ until after a specified period of time. If
the consumer cancels or withdraws from the financial product within the specified time, the intermediary
must return commission to the product producer.
The firm may also be remunerated by fee by the product producer such as policy fee, admin fee, or in the
case of investment firms, advisory fees.
Preferred Provider Rate
We do not have a preferred
Other Fees, Administrative Costs/ Non-Monetary Benefits
The firm may also be in receipt of other fees, administrative costs, or non-monetary benefits such as:
– Attendance at product provider educational seminars
– Assistance with Advertising/Branding