We, Avoca Financial Services Ltd act as an intermediary between you, the consumer, and the product provider with whom we place your business.
The background
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 product.
Indemnity commission
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
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
insurance product.
Profit Share arrangements
In some cases, the intermediary may be a party to a profit-share arrangement with a product provider and
will earn additional commission. Any business arranged with these product providers on a client’s behalf will
be placed with the product provider because that product provider is at the time of placement, the most
suitable to meet the client’s requirements, taking all the client’s relevant information, demands and needs
into account.
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
the fund.
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.
Investments
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 the value of the fund.
Clawback
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. If
the consumer cancels or withdraws from the financial product within the specified time, the intermediary must return the commission to the product producer.
Fees
The firm may also receive other fees, administrative costs, or non-monetary benefits such as:
Product providers may provide training to our staff from time to time, which we attend to comply
with our annual continuous professional development requirements, and to keep us completely up to date
with the market for our clients.
Preferred Provider Rate
We only accept commissions when it is in our clients best interest, and our clients have been made aware of
The same. We can operate as a fee-only financial advisor in the vast majority of cases. We have no preferred
provider arrangements with any product providers.
Other Fees, Administrative Costs/ Non-Monetary Benefits
The firm may also receive other fees, administrative costs, or non-monetary benefits such as:
-Attendance at product provider educational seminars
-Assistance with Advertising/Branding
Maximum Commission Rates
Single Contribution Products Initial Commission Clawback Period Trail Commission Pension
Aviva 5% 1%
Friends First 5% 0.75%
Irish Life 5% 0.75%
New Ireland 5% 5 Years 1%
Standard Life 5% 1%
Zurich Life 5.5% 0.5%
PRSA Initial Commission Clawback Period Trail Commission
Aviva 4% 0.5%
Friends First 7.5% 0.25%
Irish Life 5% 0.75%
New Ireland 7% 5 Years 0.5%
Standard Life 5% 0.5%
Zurich Life 5.5% 0%
ARF / AMRF Initial Commission Clawback Period Trail Commission
Aviva 5% 1%
Friends First 5% 0.75%
Irish Life 5% 0.75%
New Ireland 5% 1%
Standard Life 4% 1%
Zurich Life 5% 0.5%
Annuity Initial Commission Clawback Period Trail Commission
Aviva 3%
Friends First 3%
Irish Life 3%
New Ireland 3%
Zurich Life 3%
Investment Bond Initial Commission Clawback Period Trail Commission
Aviva 5% 1%
BCP 2.1%
BlackBee Investments 3%
Broker Solutions 2.5%
Cantor Fitzgerald Ireland Ltd. 2.25%
Friends First 4% 0.75%
Investec Europe Limited 2.25%
Irish Life 3% 0.5%
New Ireland 4% 3 Years 1%
Standard Life 4% 1%
Zurich Life 5% 0.5%
R
egular Contribution Initial commission Clawback Period Renewal commission Trail commission
Pension
Aviva 15% 1%
Friends First 25% .75%
Irish Life 17.5% 5% .5%
New Ireland 25% 5 Years 8% 1%
Standard Life 25% 5% 1%
Zurich Life 20% 4 Years 3% .5%
PRSA
Aviva 22.5% .5%
Friends First 17.5% .25%
Irish Life 17.5% 5% .5%
New Ireland 25% 5 Years 6% .5%
Standard Life 5% 5% .5%
Zurich Life 5% 4 Years 5% 0% Savings
Aviva 15% 1%
Friends First 10% 0.75%
Irish Life 5.5% 5.5% 0.5%
New Ireland 10% 5 Years 2.5% 0.5%
Standard Life 15% 5 Years 1%
Zurich Life 10% 4 Years 1% 0.5%
Individual Protection Yr 1 2 3 4 5 6 7 8 9+ Clawback Period
Aviva 200% 30% 30% 30% 30% 30% 30% 30% 30% 2 Years
Irish Life 120% 28% 30% 28% 28% 30% 28% 28% 28%
New Ireland 225% 50% 20% 20% 20% 12.5% 12.5% 12.5% 12.5% 5 Years
Royal London 225% 0% 0% 0% 0% 3% 3% 3% 3% 5 Years
Zurich Life 100% 12% 12% 12% 12% 12% 12% 12% 12% 1 Year
Group Protection Death in Service Clawback Period Permanent Health Insurance Clawback Period
Aviva 6% 12.5%
Irish Life 6% 12.5%
New Ireland 15% 1 Year 20% 1 Year
Zurich Life 6% 12.5%
Seatown Financial Services T/A Avoca Financial Services is Regulated by The Central Bank of Ireland