Terms of Business
Authorised Status:
Drumgoole Financial Services Limited t/a Drumgoole Financial Services is authorised by the Central Bank of Ireland as a Multi-Agency Intermediary. A copy of the company Statement of Authorised Status can be requested if required.
Services:
Drumgoole Financial Services Limited offers advice in relation to life assurance products (term cover, serious illness, mortgage protection, business protection) along with income protection, pensions, savings and investments. It transmits orders on client’s behalf to any of the insurance undertakings from whom letters of appointment are held. A list of all such entities is contained elsewhere in these Terms of Business. Drumgoole Financial Services Limited has an Execution-only service which offers premium rebates on selected products.
Remuneration / Clawback Policy:
Drumgoole Financial Services Limited receives a commission payable by the provider for cases of life assurance, pension, saving and investment contracts. Where the firm is not in receipt of commission, a service fee will be charged. The fee will be agreed with the client in advance of the provision of service, depending on the complexity of the transaction, time spent, the nature and extent of the transaction. Our commission charging structure can be viewed on the ‘Charges’ section, which is viewable at the footer of each page on our website.
If we receive commission from a product provider [and off-set the commission against the fee which we would otherwise have charged you] but the commission is subsequently clawed-back by the provider because of early encashment by you or because of the transferring of the assets or business to another provider or in any circumstances consequent on your actions or omissions, we will charge a fee to you that is equal to [100% of] the clawed-back commission. That fee will be owing in simple contract upon the claw-back of the commission.
Conflict of Interest:
It is the policy of Drumgoole Financial Services Limited to avoid conflict of interest when providing services to clients. Where an unavoidable conflict arises we will advise you of this in writing before providing any business service. If you have not been notified of any such conflict you may assume that none arises.
Complaints Procedure:
Drumgoole Financial Services Limited has in place a written procedure for the handling of complaints. This procedure ensures that all complaints are recorded and acknowledged within 5 days. All complaints are fully investigated and the complainant updated (if relevant) at 4 weekly intervals. All complaints should be directed to Oran Drumgoole, Drumgoole Financial Services Limited, 88 Northlands, Bettystown, Co Meath.
If a client remains dissatisfied with the handling of and / or response to a complaint they may refer the matter to the Financial Services Ombudsman’s Bureau, 32 Merrion Street Upper, Dublin 2. Telephone Number 1890 88 20 90 or www.financialombudsman.ie.
Consumer Protection:
Drumgoole Financial Services Limited is a member of the Investor Compensation Scheme established under the Investor Compensation Act 1998. The legislation provides for the establishment of a compensation scheme and to the payment in certain circumstances, of compensation to clients of firms covered by the Act. However you should also be aware that a right to compensation would only arise where money or investment instruments held by this Company on your behalf cannot be returned either for the time being or for the foreseeable future and where the client falls within the definition of eligible investor as contained in the Act. In the event that a right to compensation is established, the amount payable is the lesser of 90% of the clients loss, which is recognised as being eligible for compensation or €20,000. We are subject to the Consumer Protection Code, Minimum Competency Code and Fitness & Probity Standards which offer protection to consumers. These Codes can be found on the Central Bank’s website www.centralbank.ie Drumgoole Financial Services Limited holds professional indemnity insurance as required by the Central Bank of Ireland.
Money Laundering:
Client Identification
As with other professional services firms, we are under stringent requirements to identify our clients for the purposes of the anti-money laundering legislation. We are likely to request from you, and retain, some information and documentation for these purposes and/or to make searches of appropriate databases. If satisfactory evidence of your identity is not provided within a reasonable time, there may be circumstances in which we are not able to proceed with your business transaction.
Client’s Money:
Drumgoole Financial Services Limited will not accept direct payments in respect of any classes of insurance in the circumstances permitted under Section 25G of the Investment Intermediaries Act 1995. All payments must be addressed to the insurer.
Credit Policy:
We regret that credit cannot be extended to clients in any circumstance. Failure to pay your premium will lead to cancellation of your policy. Your individual policy document will contain details of default remedies and actions of the particular insurance undertaking in the event of your non-payment. On receiving your policy document you should read the terms and conditions of your policy in detail.
Default On Payment By Clients:
Drumgoole Financial Services Limited will exercise its legal rights to pursue and obtain payments due to it from clients for business services provided. We will seek reimbursement of all payments made on behalf of clients where it has acted in good faith.
The insurance undertaking or product producer may withdraw cover benefits in the event of default of payment due under policies of insurance arranged on behalf of clients. Please refer to policy documents and insurance terms and conditions for details of provisions in this regard.
Receipts:
Drumgoole Financial Services Limited will issue receipts for each payment received pursuant to Section 30 of the Investment Intermediaries Act 1995 and should be retained in a safe place.
Data Protection:
Drumgoole Financial Services Limited is registered as a Data Processor under the Data Protection Act 2018 (GDPR).
You have entitlements under the Data Protection Act to inspect all personal information held on file by Drumgoole Financial Services Limited upon request and to require Drumgoole Financial Services Limited to correct any errors of fact that may exist. Any requests should be forwarded to the Data Protection Officer. You may view the company Privacy Notice for further GDPR information on www.drumgoolebrokerage.ie.
Insurance Undertakings & Product Providers:
The following are a list of insurance undertakings and product producers from which letters of appointment are held:
Life Assurance & Pension Product Providers
Aviva / Friends First Zurich Life Assurance Royal London
Irish Life Assurance New Ireland Assurance Standard Life Assurance
Investment Product Providers
Wealth Options Ltd BCP Asset Management Broker Solutions
Sustainability Factors – Investment/IBIPs/Pension Advice
In accordance with the Sustainable Finance Disclosure Regulations (‘SFDR’) 2019, when providing advice on insurance-based investment products/Investments (IBIP), we do not currently consider sustainability risks. This means that we do not assess environmental, social or governance events/conditions that, if they occur, could have a material negative impact on the value of the investment. We will review this position on an annual basis and update our Terms of Business accordingly. The IBIP providers documentation will set out whether and how they consider such sustainability risks, and this documentation should be read carefully.