Client Agreement
A completely transparent way of working on your behalf
This agreement sets out the terms under which our services are to be provided, including details of the specific services and a summary of our charges for those services.
Harpur Wealth Management Limited is a financial planning business focused on helping you understand and plan for your financial future. We are also able to act on your behalf as the client in advising you on investments, pensions and non-investment insurance contracts. We offer you an initial discussion (at our cost) at which we will describe our services more fully and explain the payment options. Following our initial discussion, should you decide to go ahead there is a cost for our advice and services.
Full details of what is included in each of our services are provided in our Centralised Investment Proposition.
We offer both initial and ongoing services. Any advice we have provided to you will only be kept under review as part of an ongoing service for which you have agreed to pay. Where you do agree to purchase an ongoing service, unless otherwise agreed, it will be provided as a follow up to the initial service.
Any advice or recommendation that we offer to you, will only be given after we have assessed your needs and considered your financial objectives and attitude to any risks that may be involved. We will also take into account any restrictions that you wish to place on the type of products you would be willing to consider.
In some circumstances we may provide you with a non-advised service where you will not receive advice or a recommendation from us. Where this is the case we will provide details of our non-advised services and charges separately.
We take all our regulatory responsibilities very seriously and we ensure that all our staff are required to demonstrate their competence to undertake their role and our business is structured in a manner that is designed to meet in full all the requirements set by our regulator, the Financial Conduct Authority, and under European Securities and Market Authority rules.
This agreement shall commence once it has been signed by all parties and shall remain in force until terminated in accordance with Section 6 – Cancellation below.
For any aspect of our financial planning all charges and fees will be fully disclosed to you. We will not charge you until we have discussed your payment options and agreed with you how we are to be paid. We will also let you know if there are any other costs that might arise in connection with the services we provide to you.
Our charges/fees will be VAT exempt unless the work we provide for you only involves advice and/or preparing a report, in which case VAT may be applicable. We will always tell you if you have to pay VAT before we undertake any work for you. Charges for the ongoing service will not be liable to VAT (unless the initial service was liable to VAT) where both the initial and ongoing services are part of the same package.
Investment & Pension Planning
We provide a restricted advice service. Restricted advice means that we will only consider investments from a limited range of products and/or providers that we have previously researched and found suitable for our clients in most situations.
We restrict our advice because we do not offer advice in the following investment product areas:-
Unregulated Collective Investment Schemes
Structured Capital & Risk Products
Initial charges
Our initial charges relating to new work such as client take-on, new investments and one-off reviews are as follows:
Paying our initial charges
Our charges are payable on completion of our work and must be settled within 28 business days. Payment can be made either by:
1. You may pay our charges via deductions from the financial product(s) that you might invest in, where the product/platform provider allows this. Please note that if you choose to pay by deduction from a financial product this will reduce the amount left for investment and may, depending on your circumstances, have other consequences.
2. If your investments are held on a platform (a platform is an online investment administration service) you may choose to pay our charges out of the funds held within the platform cash account (where the platform provider offers this facility).
3. Cheque or electronic transfer (we do not accept payments by cash).
If you select option 1 or 2 we will discuss how it works and the implications of using this payment method with you prior to putting it in place.
Our ongoing charges
Before recommending a product, we will make suitability checks to ascertain your relevant knowledge, experience, objectives, financial situation and your ability to bear losses.
Prior to any transaction we will provide you with a suitability report outlining any recommendations we have made including the selling, holding or buying of investments.
Any advice we have provided will only be kept under review as part of an agreed ongoing chargeable service. This service will be agreed with you and confirmed in our service agreement. The charge for this service will be taken monthly, quarterly, half yearly or yearly (depending on the provider) as a % of funds under management.
Our ongoing service option incorporates a periodic suitability review of the investments we have recommended, this is to ensure the original recommendation remains suitable. This periodic assessment will be completed at least annually, however, the frequency may be increased when taking into account your risk profile and the types of financial products that have been recommended.
We offer an ongoing Wealth Management Service. Full details of what is included in this service are available in our Centralised Investment Proposition.
All figures quoted are purely for example, the actual fee paid will depend on the complexity of the work undertaken and will be confirmed to you in our client engagement letter prior to any work being undertaken.
We will provide you with information regarding the costs at least annually to help you understand the overall cost and the cumulative effect on the return of the investment.
Termination of Our Services (On-going Advice)
You have the right to cancel payment for our on-going services giving a notice period of 14 days. Where you hold assets within a WRAP, you need to be aware that there will be terms and conditions applicable, such as your agreement with the wrap provider in respect to facilitating our fees, which means you may need to instruct the wrap provider directly and arrange for the removal of assets from the WRAP or appoint another adviser who will be able to access your assets and provide further on-going advice to you. We will be pleased to assist you at this time in cancelling our service to you, making sure that any WRAP provider is informed of this cancellation.
Protection Planning
Our advised protection planning services are suitable if you are looking for the best way to protect you, your family or your business through products such as critical illness cover, health insurance and life cover. We advise on non-investment protection products e.g. term assurance, income protection and critical illness from a range of insurers.
We research the market based on a “fair analysis” and make a personal recommendation.
You can pay for our advised protection services by:
- Commission (where this is available)
- A combination of fee and commission
- A fee
Paying by commission
Where we are paid by commission we will tell you the amount before we carry out any business for you. Although you may pay nothing to us up front that does not mean that our service is free. You still pay us indirectly through deductions from the amount you pay into your product.
In respect of any regular premium policy which we have arranged for you, should you subsequently cease to pay premiums on the policy and in consequence we are obliged to refund the commission that has been paid to us, we reserve the right to charge you a fee representing the amount we have to repay, for a period of up to four years after commencement of the policy.
We will confirm the exact amount that will need to be repaid by you and the timescale over which it will need to be repaid in the suitability report we will send you when a recommendation is made. We will not charge any such fee if you exercise your right to cancel in accordance with any cancellation notice sent to you by the life insurance company.
Paying by fee/a combination of fee and commission
Our fee will be based on an hourly rate basis subject to a minimum fee of £300.
Any commission we receive from the product provider can be used to offset this fee. Any surplus will be refunded to you. We will always present you with a personalised quote before undertaking any work that might be charged for. The following example shows what our typical costs would be:
Recommendations
We will confirm to you in writing the basis of our recommendations along with details of any special risks associated.
Best execution
It is our policy to transact your business in order to achieve the best possible results in terms of the:
- Price of products, providers and services
- Cost of advice
- Speed
- Size and Nature of the transaction
- Effectiveness of the Platform, Provider or Service Provider
Protecting your personal information
Your personal information is important to us. We will endeavour to take all due care to protect this information. We highlight below matters relating to your information that you should be aware of.
Some services are provided to our firm by third parties such as processing business or obtaining compliance or regulatory advice, which warrant the disclosure of more than just your basic contact details.
Personal information held by ourselves may be disclosed on a confidential basis, and in accordance with the Data Protection Act 1998, to any such third parties. This information may be transferred electronically (e.g. e-mail) and we, or any such third party, may contact you in future by any means of communication which we consider appropriate at the time.
Product providers and investment managers may administer your policy, any existing policies you may have with them and provide other services from centres in countries outside Europe (such as India and the USA) that do not always have the same standard of Data Protection laws as the UK. However, they are required to put a contract in place to ensure that your information is adequately protected, and they will remain bound by their obligations under the Data Protection Act even when your personal information is processed outside Europe.
Anti-money laundering
We are required by anti-money laundering regulations to verify the identity of our clients, to obtain information as to the purpose and nature of the business which we conduct on their behalf, and to ensure that the information we hold is up-to-date. For this purpose we may use electronic identity verification systems and we may conduct these checks from time to time throughout our relationship.
Conflict of interests
We have a legal and regulatory obligation to take all appropriate steps to identify and to prevent or manage conflicts of interest from arising. In the event of any of our business interests or activities creating a potential conflict of interest we will ensure that we take all appropriate steps to manage the potential conflict by maintaining robust systems, controls and staff training. In the unlikely event that we are unable to prevent the potential conflict, we will fully disclose to you, the general nature and/or sources of conflicts of interest and the steps taken to mitigate those risks.
Other benefits we may receive
From time to time we may attend training events funded and /or delivered by product providers, fund managers and platforms. These events are designed to enhance our knowledge and ultimately therefore enhance the quality of service we provide to our clients. Further details are available on request.
We will not receive any financial inducement or gift that will in any way compromise our ability to provide you with suitable advice.
Communicating with you
We may communicate with you by telephone, post, e-mail or in person. In certain circumstances, we may ask you to confirm any instructions in writing prior to implementation. All our communications with you will be in English.
Product cancellation rights
Full details of the products we recommend to you including, for example, the minimum duration of the product, information on your right to cancel or whether no right to cancel exists, and any other early termination rights and penalties, will be covered in the relevant product disclosure information you will receive before the conclusion of any contract.
In most cases you can exercise a right to cancel by withdrawing from the contract. In general terms you will normally have a 30 day cancellation period for a life, protection, payment protection or pension policy and a 14 day cancellation period for all other policies. Instructions for exercising the right to cancel, if applicable, will be contained in the relevant product disclosure information which will be provided to you.
If you cancel a single premium contract, you may be required to pay for any loss you might reasonably incur in cancelling it which is caused by market movements. This means that, in certain circumstances, you might not get back the full amount you invested if you cancel the policy.
Harpur Wealth Management Limited is authorised and regulated by the Financial Conduct Authority (FCA), 12 Endeavour Square, London, E20 1JN.
Our Financial Services Register number is 738074. Our permitted business is advising on and arranging pensions, savings and investment products and non-investment insurance contracts.
You can check this on the Financial Services Register by visiting the FCA’s website www.fca.org.uk/firms/systems-reporting/register or by contacting the FCA on 0800 111 6768.
Unless we notify you in writing to the contrary, we will be treating you as a retail client. This means that you are afforded the highest level of protection under the regulatory system and should have the right to take any complaint to the Financial Ombudsman Service.
Complaints
If you are dissatisfied with a recommendation we have made you are entitled to make a complaint. We have a complaints procedure that is available on request. If you wish to register a complaint, please contact us:
- In writing: Paul Simmonds, Harpur Wealth Management Limited, 19 Goldington Road, Bedford, MK40 3JY.
- By phone: +44 (0)1234 924620
- By e-mail: ray@harpurwm.com
Please be assured we treat complaints seriously. For your further protection if you cannot settle your complaint with us, you may be entitled to refer it to the Financial Ombudsman Service (‘FOS’). Full details of the FOS can be found on its website at www.financial-ombudsman.org.uk.
Financial Services Compensation Scheme
We are also covered by the Financial Services Compensation Scheme (‘FSCS’). You may be entitled to compensation from the scheme if we cannot meet our obligations. This depends on the type of business and the circumstances of the claim.
Investment
Most types of investment business are covered for 100% of the first £85,000 per person per firm, so the maximum compensation is £85,000 per person per firm.
Protection, non-Investment Insurance mediation
Protection is at 100%, where:
(1) The claim is in respect of a liability subject to compulsory insurance.
(2) The claim is in respect of:
- A relevant omission; and
- A professional indemnity insurance contract, or would be in respect of a professional indemnity insurance contract if the insurance contract had been effected.
(3) The claim is:
- In respect of a relevant omission;
- In respect of a relevant general insurance contract or would be in respect of a relevant general insurance contract if the insurance contract had been effected; and
- Arises from the death or incapacity of the policyholder owing to injury, sickness or infirmity.
(4) The claim is in respect of:
- A relevant omission; and
- A pure protection contract, or would be in respect of a pure protection contract if the insurance contract had been effected.
(5) In all other cases: 90% of claim
We may also, on occasion, advise on other financial products which are not regulated by the Financial Conduct Authority (FCA). The Financial Services Compensation Scheme does not apply to any of these products. Further information about compensation scheme arrangements is available from the FSCS at www.fscs.org.uk/consumer.
Client money
We are not permitted to handle client money and we cannot accept a cheque made out to us (unless it is in respect of a service for which we have sent you an invoice) or handle cash.
Jurisdiction
This agreement is governed by and should be interpreted in accordance with English law and you agree to submit to the non-exclusive jurisdiction of the English Courts.
Legal and accounting advice
Neither our firm nor our employees are qualified to render legal or accounting advice or to prepare any legal or accounting documents. It is hereby understood and agreed that the onus is on you, the client, to refer to a solicitor or accountant any point of law or accountancy that may arise during the course of discussions with us.
Disclaimer: The Financial Conduct Authority does not regulate Legal and Accountancy advice.
Investment related
Documentation
We will endeavour to make arrangements for all your investments to be registered in your name unless you first instruct us otherwise in writing. All policy documents will be forwarded to you as soon as practicable after we receive them. If there are a number of documents relating to a series of transactions, we will normally hold each document until the series is complete and then forward them to you.
Investment Performance & Risks
Please be aware that investments can fall, as well as rise, and that you may not get back the full amount invested. The price of investments we may recommend may depend on fluctuations in the financial markets, or other economic factors, which are outside our control. Past performance is not necessarily a guide to future performance.
Specific warnings relevant to the investments, investment strategies or other products we recommend will be confirmed to you in your suitability report. Under the terms of this agreement, we may, if appropriate, advise you on investments which are not readily realisable. We would draw your attention to the risks associated with these investments as there is a restricted market for them. In some circumstances it may therefore not be possible to deal in the investment or obtain reliable information about its value.
Providing information to your insurer
Your cover is based upon the information you provide to the insurance company. Where you are buying insurance as an individual, this means that you must take ‘reasonable care’ to answer all questions asked by the insurer fully and accurately. Failure to provide accurate and up to date information may invalidate your insurance cover and mean that a claim may not be paid.
I/We acknowledge that the client agreement will come into effect once it has been signed by all parties.
