Client Agreement for Investments & Insurances
This agreement is issued on behalf of MLP Wealth Management Ltd of 36 High Street, Banstead, Surrey, SM7 2LS who can be contacted on 020 8296 1799. Registered Office: Copthorne Business Suite, Copthorne Hotel London Gatwick, Copthorne Way, West Sussex, England, RH10 3PG
The purpose of this agreement is to set out the basis on which we will act for you and to clarify our respective responsibilities. It sets out the detailed terms of a legal contract between us. Please do not hesitate to contact us if anything is unclear, or you would like further explanation of any of the terms used.
MLP Wealth Management Ltd is Authorised and Regulated by the Financial Conduct Authority (FCA). The FCA regulates financial services in the UK and you can check our authorisation and permitted activities on the Financial Services Register by visiting the FCA’s website www.fca.org.uk/firms/systems-reporting/register. Our Financial Services Register number is 413308
We provide independent investment advice. We will consider a range of regulated products from the available market that can meet the investment objectives of a retail client but we will only provide a recommendation to you when we know the product is suitable for your personal circumstances.
You should be aware that investments carry varying degrees of risk and as their underlying value can fall as well as rise you may not get back the full amount invested.
For Non-investment protection contracts we are an intermediary and will act on your behalf when providing advice and making our personal recommendation(s) to you. We will do this based on a fair and personal analysis of insurers for term assurance, income protection, critical illness.
Full details of the products we recommend will be confirmed in the product literature you will receive before it is arranged. We will inform you if any investment we recommend restricts future access to your capital.
Please note we do not offer tax advice other than in respect of the products and services we recommend to you. We do not offer Legal advice. Where you have been advised previously by another Firm, we will not review the suitability of their financial advice to you.
Your Aims and Objectives
Unless we notify you in writing to the contrary, we will be treating you as a “retail client” for investment business. 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. V.20190307
Any advice or recommendation(s) we offer to you will only be given after we have assessed your needs and considered your financial objectives, attitude to risk and capacity to bear any losses. We will also take into account any restrictions that you wish to place on the types of products or investment strategy you would be willing to consider.
Our Ethical Policy
We are committed to providing the highest standard of financial advice and service possible. The interest of our clients is paramount to us and to achieve this we have designed our systems and procedures to place you at the heart of our business. In doing so, we will:
- be open, honest and transparent in the way we deal with you;
- not place our interests above yours;
- communicate clearly, promptly and without jargon;
- seek your views and perception of our dealings with you to ensure it meets your expectations or to identify any improvements required.
We only accept instructions in writing (paper or electronic means) to aid clarification and avoid future misunderstandings. Please note we will not act on oral instructions to avoid any possible misunderstandings.
Investment Services and Costs (including structured deposits)
We provide you with an initial consultation free of charge. This helps us to understand your financial objectives and we will confirm how we can support you in working towards these goals. We will also discuss the cost, and levels, of our services both initially and throughout our relationship with you. We charge for our services by way of a fee of £250 per hour. For investment advice we charge an implementation fee based on a percentage of the amount you invest, subject to a minimum fee. The 2 steps of this process are explained here:
Financial Review and Recommendation
This can be a continuation from the initial discussion, where agreed, or further appointments. This process covers the:
- gathering of information about your existing financial arrangements and full personal circumstances;
- understanding of your investment knowledge and attitude and tolerance towards investment risk;
- recommendation of an asset allocation model that matches your risk profile and the subsequent assessment and suitability of any existing holdings;
- preparation of our recommendations to you for implementation;
- arranging further appointments to explain and discuss our recommendations in detail.
We charge £250 per hour, payable upfront where applicable, and/or £1,000 on provision and acceptance of the report containing our recommendation(s) to you. This fee will be waived wholly or in part should you decide to implement any of our recommendations.
Policy Arrangement & Implementation – Lump Sum Investments, Transfers & Switches
Should you instruct us to proceed with (any of) our recommendation(s) we will act for you in the following ways:
- Handle all fund and policy administration on your behalf;
- Ensure all your documents are issued in line with your expectations;
- Provide confirmation of all actions taken on your behalf in writing.
Our initial charge for this service is based on a percentage of the amount you invest and/or transfer. These charges are typically applied as follows:
- 3% on amounts up to £250,000 with a minimum fee of £1,000 we may agree to reduce or waive our minimum fee where annual allowance restrictions apply e.g. Individual Savings Accounts (ISAs), or where you make an additional investment to a product or service we have previously arranged for you.
- 2% of the total where the amount is between 250,001 and £500,000.
- Above £500,001 individually agreed.
This payment can often be facilitated by the product provider(s) from your investments/policy(ies) when they receive your funds. Alternatively, we can invoice you and you can pay us directly.
Example 1; if we arrange an investment on your behalf for £100,000 our Policy Arrangement & Implementation fee would be £3,000 (3% x £100,000)
Example 2; if we arrange investments on your behalf totalling £300,000 our Policy Arrangement & Implementation fee would be £6,000 (2% x £300,000)
Example 3; if we arrange investments on your behalf totalling £500,000 our Policy Arrangement & Implementation fee would be £10,000 (2% x £500,000)
These are only example charges. Specific charges and cash amounts will be agreed with you before work is undertaken and these amounts will be reconfirmed in our report recommendations.
When we arrange the sale of a protection or insurance contract, we will not typically charge you a fee, as we will receive a commission from the provider/insurer. Where the commission paid to us is lower than £1,000, we may charge a fee, which will be agreed with you before proceeding. The amount of this will be disclosed to you in the product literature.
It is important to review every investment you hold and at regular intervals. At the time of, or prior to, our recommendation to you we will discuss our on-going service proposition. This is confirmed in our ‘service proposition and engagement’ document which will be sent to you separately from this agreement.
Under current legislation our intermediary services are not subject to VAT but should this change in future and VAT becomes payable, we will notify you before conducting any further work.
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, pure protection, payment protection or pension policy and a 14 day cancellation period for all other policies. For investments this will typically start when funds are invested and for pure protection policies this will normally begin when you are informed that the contract has been concluded or, if later, when you have received the contractual terms and conditions. Instructions for exercising the right to cancel, if applicable, will be contained in the relevant product information issued to you.
If you cancel a single premium contract, you may incur a loss due to market movements. This means that, in certain circumstances, you might not get back the full amount you invested if you cancel the policy.
We are not permitted to handle client money and we cannot accept a cheque made out to us (unless it is in respect of an item for which we have sent you an invoice) or handle cash.
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 immediately after we have received 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. We will issue all communications in English, unless agreed otherwise.
We will act honestly, fairly and professionally known as conducting business in ‘Client’s best interest’ regulations. Occasionally situations may arise where we or one of our other clients have some form of interest in business transacted for you. If this happens or we become aware that our interests or those of one of our other clients conflict with your interest, we will write to you and obtain your consent before we carry out your instructions, and detail the steps we will take to ensure fair treatment. Where this cannot be achieved, we will not conduct the business.
A summary of our internal complaints handling procedures for the reasonable and prompt handling of complaints is available on request and if you cannot settle your complaint with us, you may be entitled to refer it to the Financial Ombudsman Service at www.financial-ombudsman.org.uk or by contacting them on 0800 023 4567.
If you make a complaint and we are unable to meet our liabilities, you may be entitled to compensation from the Financial Services Compensation Scheme. For information on the amounts covered for various products please visit their website: https://www.fscs.org.uk/what-we-cover/ .
The Proceeds of Crime Act 2002 and the Money Laundering Regulations 2007
In common with all financial businesses, we are required by the Proceeds of Crime Act 2002 and the Money Laundering Regulations 2007 to:
- Maintain identification procedures for clients and some beneficiaries/trustees
- Maintain records of identification evidence and the work undertaken for the client
- Report, in accordance with the relevant legislation and regulations
We have a duty under section 330 of the Proceeds of Crime Act 2002 to report to the National Crime Agency if we know, or have reasonable cause to suspect, that another person is involved in money laundering. Failure on our part to make a report where we have knowledge or reasonable grounds for suspicion would constitute a criminal offence.
The offence of money laundering is defined by section 340(11) of the Proceeds of Crime Act 2002 and includes concealing, converting, using or possessing the benefit of any activity that constitutes a criminal offence in the UK.
It also includes involvement in any arrangement that facilitates the acquisition, retention, use or control of such a benefit.
We are obliged by law to report any instances of money laundering to the National Crime Agency without your knowledge or consent. In consequence, the firm’s directors or staff will not enter into any correspondence or discussions with you regarding such matters.
We are not required to undertake work for the sole purpose of identifying suspicions of money laundering. We shall fulfil our obligations under the Proceeds of Crime Act 2002 in accordance with the principles, rules and guidance published by the Financial Conduct Authority.
We are required by the 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 to 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, not just at the beginning.
This client agreement is governed and shall be construed in accordance with English Law and the parties shall submit to the exclusive jurisdiction of the English Courts.
MLP Wealth Management Ltd shall not be in breach of this Agreement and shall not incur any liability to you if there is any failure to perform its duties due to any circumstances reasonably beyond its control.
The authority to act on your behalf may be terminated at any time without penalty by either party giving seven days notice in writing to that effect to the other, but without prejudice to the completion of transactions already initiated. Any transactions effected before termination a due proportion of any period charges for services shall be settled to that date.
Consent for MLP Wealth Management Ltd and associated companies to process data has been given in the privacy notice, a copy of which is displayed on our website. Privacy Notice