Terms of Business
This document sets out the terms under which we agree to act for you and contains our regulatory and statutory responsibilities. It also sets out some of your responsibilities.
Commencement/Termination
The provisions of these Terms of Business will take effect immediately that they are provided to you and will continue in force until they are cancelled by you or us, or they are replaced by updated Terms of Business.
Investor Profile Ltd
Our registered address is: 230 Acre Lane, Northampton, NN2 8DX.
We are authorised and regulated by the Financial Services Authority (FSA). We are listed on the FSA register and our Registration Number is 481396. You can check this, and our address, on the FSA’s Register by visiting the FSA’s website www.fsa.gov.uk/register or by contacting the FSA on 0845 606 1234.
We are permitted to advise on and arrange financial products on a whole of market basis.
Client Classification
We have classified you as a “retail client”. This means that you are afforded the greatest level of protection available under the Financial Services and Markets Act (FSMA).
You have the right to request a different categorisation, however this may result in the loss of some of the protections available under the FSMA.
The FSA may not regulate all investments referred to on our website, which means the protection available under the Financial Services and Markets Act may not apply when dealing with non-regulated investments.
Communicating with you
We will normally communicate with you by post or e-mail, or where necessary by telephone. This may include proactive communication.
We may communicate with you by e-mail, which may include electronic data. By consenting to this method of communication we and you accept the risks involved regarding unauthorised access, interception, corruption, and the risk of viruses or other harmful devices although we and you will be responsible for taking all reasonable steps to mitigate such circumstances.
Please note that you cannot assume instructions sent to us by e-mail have been processed until you receive our confirmation.
We may retain details of communications with you for our records and regulatory purposes. In the case of any dispute we may rely on such records.
Our Services – Investment Broking
We act as your agent in arranging investments on an execution only basis.
Our website aims to provide you with the information and tools to help you make the best decision for your circumstances. In providing this we are not making a personal recommendation, offering advice or exercising judgement on your behalf as to the merits or suitability of a particular transaction. We will not advise on the suitability of particular funds, investment strategies or individual products unless you ask us to do so in an official capacity through our advisory services.
If you are unsure as to the suitability of any particular investment you may contact us to book an appointment for a financial adviser to discuss your options with you.
We offer products available through Cofunds and Transact. Where we do arrange investments on your behalf through our service we will not aim to review the suitability of these in the future unless you request us to do so.
Investor Profile accepts no liability to clients who do not comply with ISA, pension or other product related rules and regulations.
You will be asked to agree to our Terms of Business prior to placing investment instructions online. Submitting paper applications to us for processing confirms your agreement to our Terms of Business where these have been made clearly available at the time of accessing your application.
Our Services – Advisory
We offer a ‘simplified’ and ‘affordable’ advice service that aims to assess your needs, identify your financial goals and to make recommendations accordingly. These may be specific to an area of financial planning or general.
Our advice sessions will focus on arriving at a solution that best meets your needs and circumstances. This may or may not involve a generic or specific product recommendation. We will agree a course of action together during the meeting.
As a simplified advice service any recommendations made are based purely on the information discussed with you and disclosed by you.
We will not provide a written report of the advice we provide you with during the meeting. Instead a copy of our notes including your personal details, relevant considerations and specific needs, as well as our recommendations/agreed actions will be sent to you via e-mail in a simplified document form that is easy and convenient for you to read and understand.
If during the course of our discussion we agree that a more formal and comprehensive report is required then we shall produce this for you at the agreed fee level.
If we agree that a referral is necessary for specialist advice or a product recommendation as a result of our discussions then this will be confirmed in writing, usually via e-mail.
We may ask you to return any requested information prior to the meeting so that we may concentrate on delivering you full value for money during the advice session. You should be aware that if you do not provide the requested information before the meeting for any reason we will need to acquire this during your session and this may impact on the time we have to consider advisory solutions.
Where more specialist advice is required in a specific area or a product recommendation is required we may refer you to a partner organisation that specialises in that particular area of financial, or other e.g. legal, services.
The ‘pay as you go’ nature of our advisory service means that we will not aim to review the suitability of our advice, or your circumstances, in the future unless you ask us to do so.
Conflicts of Interest
Occasions can arise where we, or one of our other clients, will have some form of interest in the business that we are transacting for you. If this happens, or we become aware that our interests conflict with your interests, we will inform you in writing and ask for your consent before we carry out your instructions.
We maintain a Conflict of Interest Policy which enables us to identify and manage conflicts and potential conflicts of interest. The policy is designed to ensure that you are provided with an appropriately independent level of service by putting in place appropriate procedures, supervision and monitoring techniques. Further details of the policy are available upon request.
Remuneration – Investment Broking
Investor Profile will take no initial commission on any new investments, whether lump sum or regular, or subsequent switches made through its service, unless we agree with you prior to you placing your investment that an initial commission is to be taken. In such circumstances the level of commission taken will be disclosed to you before any investment is made.
We will take an annual commission of up to 0.5% of the funds under administration. We will disclose to you the basis of commission prior to you placing your investment instructions. Details of these Fees and Charges are always made openly available on our website.
You should be aware of the possibility that other costs or taxes relating to the services that we provide for you may exist even though they are not paid through us or imposed by us.
Remuneration – Advisory
We want to be as up front as possible and provide you with value for money. For this reason we set out in plain terms what we charge. Our advice will be charged at £40 +VAT per session regardless of how complex your affairs might be.
This fee is payable at the time of booking an appointment. Appointment times will only be confirmed once payment has been received. This is to ensure we minimise cancellations and absences. Each session will last for 30 minutes and we aim to spend that time analysing the information you have provided us with and identifying solutions that best meet your needs.
We charge a standard report fee of £250 +VAT for any recommendations that we agree with you are more complex and therefore warrant more specific and complex recommendations and rationales.
Refunds Policy
The Financial Surgery Session fee, once paid, is non-refundable. Every effort will be made to contact you on the number(s) you provide us with at the time of your appointment. If we are unable to reach you, or your appointment runs short of 30 minutes, we will not refund any of the fee paid for the Financial Surgery Session.
The standard report fee of £250 +VAT, once paid, is also non-refundable. If you wish to discuss the outcomes or contents of your report then please feel free to call us on 01604 211234 and we would be happy to discuss this with you.
If you wish to cancel an appointment prior to your allotted time and date you may do so and receive a full refund if your request is received more than 24 hours before the appointment was due to begin. Alternatively we can re-schedule an appointment for a time that is more convenient for you.
If you decide against purchasing a written report of personalised recommendations then a full refund may be made to you only if work has not yet begun on compiling the report.
Client Money
Investor Profile does not handle client money. We will not handle cash or accept cheques made payable to us for money that is intended for investment by you.
Quality of Service
If you have any complaint about the service you receive from us please write to: Compliance Oversight Officer, Investor Profile Ltd, 230 Acre Lane, Northampton, NN2 8DX. If, after we have reviewed your complaint you remain dissatisfied, you have the right to refer your complaint to the Financial Ombudsman Service. Copies of our complaints procedures are available on request.
Investor Profile maintains a professional indemnity insurance policy for the protection of clients in the event of any negligence by any member or employee of Investor Profile. Details of this, including the current limits of indemnity, are available on request.
Investor Profile accepts no liability for products or investments made or purchased via any other company or broker and does not provide advice as to the suitability of new investments unless you specifically ask us to do so during an advisory session.
Are we covered by the FSCS?
Yes we are which means you may be entitled to compensation from the Financial Services Compensation Scheme if we are unable to meet our obligations. This depends on the type of business and the circumstances of the claim. Most types of investment business are covered for 100% of the first £30,000 and 90% of the next £20,000 so the maximum compensation is £48,000. Further information about the compensation scheme arrangements is available from the FSCS website at www.fscs.org.uk.
Risk factors
We will write to you separately regarding any specific risk factors that apply to the service we provide for you. You should be aware that the past performance of investments is no indicator of future performance and that the value of investments can go up or down, which means you may not get back the full amount invested.
Money Laundering
Where we are required to verify your identity in accordance with the FSA rules, no investment will be made until such verification has been obtained. If the required verification is not forthcoming within a reasonable period we will not arrange any investment for you.
We may use and search the records of credit reference or fraud prevention agencies to check your identity to satisfy the requirements of the UK Money Laundering Regulations 2007, the Proceeds of Crime Act 2002 (as amended), the Terrorism Act 2000, the Anti-terrorism, Crime and Security Act 2001 and FSA rules. Such searches will not affect your credit rating. Where such searches prove unsatisfactory for this purpose, we may ask you to supply at least one document to verify your identity and/or address.
Documentation
All investments will be registered in your name unless otherwise agreed in writing. Unless you instruct us in writing to the contrary, we will forward to you all contract notes and documents showing ownership of your investments as soon as practicable after we receive them.
Personal Information
Personal information provided by you may be maintained on computer and paper records, where you consent to us or any company associated with us for processing, both manually and by electronic means, your personal data for the purposes of providing advice, administration and management.
The information Investor Profile holds will not be disclosed to other parties except representatives of our compliance advisers, our auditors, third party investment providers, third party product providers, or other selected third party organisations under exceptional circumstances, as well as any organisation requiring access to such information for regulatory purposes only, or any person having a legal entitlement to access.
We may from time to time use the information that we hold about you to contact you by post, telephone or e-mail to bring your attention to products, services or information that we feel you may benefit from.
All cheques, documents of title, etc, may be sent by post to your latest known address and shall be sent at your own risk. The Recorded Delivery service will not normally be used.
Future Changes
In accepting these Terms of Business, you agree that we may change the future content without receiving your prior consent to do so, but we will not conduct any investment business for you following any change unless we have given you reasonable notice, unless it is impractical to do so.
Cancellation
These Terms of Business may only be cancelled and our authority to act on your behalf may only be terminated in writing, at any time, without penalty, by either party and with immediate effect without prejudice to the completion of transactions initiated prior to receipt of such notice. Other than as stated in this paragraph, there are no cancellation rights that apply to these Terms of Business.
However specific cancellation rights do apply to certain products available through our service. Clients will be entitled to a 30 days cancellation notice period for all SIPP and ISA contracts whether opening a new account or transferring existing investments to our service. More details regarding the cancellation rights of individual products can be found in the product Key Features document, which is made available prior to investment. Clients will not be entitled to receive cancellation rights in relation to unit trust purchases, whether inside or outside of a product wrapper such as an ISA or SIPP.
Law
English law will be the basis of this contract and the language in which this contract will be interpreted, and in which all communications will be conducted, will be English. The Contracts (Rights of Third Parties) Act 1999 shall not apply to this Client Agreement.
Commencement/Termination
The provisions of these Terms of Business will take effect immediately that they are provided to you and will continue in force until they are cancelled by you or us, or they are replaced by updated Terms of Business.
Investor Profile Ltd
Our registered address is: 230 Acre Lane, Northampton, NN2 8DX.
We are authorised and regulated by the Financial Services Authority (FSA). We are listed on the FSA register and our Registration Number is 481396. You can check this, and our address, on the FSA’s Register by visiting the FSA’s website www.fsa.gov.uk/register or by contacting the FSA on 0845 606 1234.
We are permitted to advise on and arrange financial products on a whole of market basis.
Client Classification
We have classified you as a “retail client”. This means that you are afforded the greatest level of protection available under the Financial Services and Markets Act (FSMA).
You have the right to request a different categorisation, however this may result in the loss of some of the protections available under the FSMA.
The FSA may not regulate all investments referred to on our website, which means the protection available under the Financial Services and Markets Act may not apply when dealing with non-regulated investments.
Communicating with you
We will normally communicate with you by post or e-mail, or where necessary by telephone. This may include proactive communication.
We may communicate with you by e-mail, which may include electronic data. By consenting to this method of communication we and you accept the risks involved regarding unauthorised access, interception, corruption, and the risk of viruses or other harmful devices although we and you will be responsible for taking all reasonable steps to mitigate such circumstances.
Please note that you cannot assume instructions sent to us by e-mail have been processed until you receive our confirmation.
We may retain details of communications with you for our records and regulatory purposes. In the case of any dispute we may rely on such records.
Our Services – Investment Broking
We act as your agent in arranging investments on an execution only basis.
Our website aims to provide you with the information and tools to help you make the best decision for your circumstances. In providing this we are not making a personal recommendation, offering advice or exercising judgement on your behalf as to the merits or suitability of a particular transaction. We will not advise on the suitability of particular funds, investment strategies or individual products unless you ask us to do so in an official capacity through our advisory services.
If you are unsure as to the suitability of any particular investment you may contact us to book an appointment for a financial adviser to discuss your options with you.
We offer products available through Cofunds and Transact. Where we do arrange investments on your behalf through our service we will not aim to review the suitability of these in the future unless you request us to do so.
Investor Profile accepts no liability to clients who do not comply with ISA, pension or other product related rules and regulations.
You will be asked to agree to our Terms of Business prior to placing investment instructions online. Submitting paper applications to us for processing confirms your agreement to our Terms of Business where these have been made clearly available at the time of accessing your application.
Our Services – Advisory
We offer a ‘simplified’ and ‘affordable’ advice service that aims to assess your needs, identify your financial goals and to make recommendations accordingly. These may be specific to an area of financial planning or general.
Our advice sessions will focus on arriving at a solution that best meets your needs and circumstances. This may or may not involve a generic or specific product recommendation. We will agree a course of action together during the meeting.
As a simplified advice service any recommendations made are based purely on the information discussed with you and disclosed by you.
We will not provide a written report of the advice we provide you with during the meeting. Instead a copy of our notes including your personal details, relevant considerations and specific needs, as well as our recommendations/agreed actions will be sent to you via e-mail in a simplified document form that is easy and convenient for you to read and understand.
If during the course of our discussion we agree that a more formal and comprehensive report is required then we shall produce this for you at the agreed fee level.
If we agree that a referral is necessary for specialist advice or a product recommendation as a result of our discussions then this will be confirmed in writing, usually via e-mail.
We may ask you to return any requested information prior to the meeting so that we may concentrate on delivering you full value for money during the advice session. You should be aware that if you do not provide the requested information before the meeting for any reason we will need to acquire this during your session and this may impact on the time we have to consider advisory solutions.
Where more specialist advice is required in a specific area or a product recommendation is required we may refer you to a partner organisation that specialises in that particular area of financial, or other e.g. legal, services.
The ‘pay as you go’ nature of our advisory service means that we will not aim to review the suitability of our advice, or your circumstances, in the future unless you ask us to do so.
Conflicts of Interest
Occasions can arise where we, or one of our other clients, will have some form of interest in the business that we are transacting for you. If this happens, or we become aware that our interests conflict with your interests, we will inform you in writing and ask for your consent before we carry out your instructions.
We maintain a Conflict of Interest Policy which enables us to identify and manage conflicts and potential conflicts of interest. The policy is designed to ensure that you are provided with an appropriately independent level of service by putting in place appropriate procedures, supervision and monitoring techniques. Further details of the policy are available upon request.
Remuneration – Investment Broking
Investor Profile will take no initial commission on any new investments, whether lump sum or regular, or subsequent switches made through its service, unless we agree with you prior to you placing your investment that an initial commission is to be taken. In such circumstances the level of commission taken will be disclosed to you before any investment is made.
We will take an annual commission of up to 0.5% of the funds under administration. We will disclose to you the basis of commission prior to you placing your investment instructions. Details of these Fees and Charges are always made openly available on our website.
You should be aware of the possibility that other costs or taxes relating to the services that we provide for you may exist even though they are not paid through us or imposed by us.
Remuneration – Advisory
We want to be as up front as possible and provide you with value for money. For this reason we set out in plain terms what we charge. Our advice will be charged at £40 +VAT per session regardless of how complex your affairs might be.
This fee is payable at the time of booking an appointment. Appointment times will only be confirmed once payment has been received. This is to ensure we minimise cancellations and absences. Each session will last for 30 minutes and we aim to spend that time analysing the information you have provided us with and identifying solutions that best meet your needs.
We charge a standard report fee of £250 +VAT for any recommendations that we agree with you are more complex and therefore warrant more specific and complex recommendations and rationales.
Refunds Policy
The Financial Surgery Session fee, once paid, is non-refundable. Every effort will be made to contact you on the number(s) you provide us with at the time of your appointment. If we are unable to reach you, or your appointment runs short of 30 minutes, we will not refund any of the fee paid for the Financial Surgery Session.
The standard report fee of £250 +VAT, once paid, is also non-refundable. If you wish to discuss the outcomes or contents of your report then please feel free to call us on 01604 211234 and we would be happy to discuss this with you.
If you wish to cancel an appointment prior to your allotted time and date you may do so and receive a full refund if your request is received more than 24 hours before the appointment was due to begin. Alternatively we can re-schedule an appointment for a time that is more convenient for you.
If you decide against purchasing a written report of personalised recommendations then a full refund may be made to you only if work has not yet begun on compiling the report.
Client Money
Investor Profile does not handle client money. We will not handle cash or accept cheques made payable to us for money that is intended for investment by you.
Quality of Service
If you have any complaint about the service you receive from us please write to: Compliance Oversight Officer, Investor Profile Ltd, 230 Acre Lane, Northampton, NN2 8DX. If, after we have reviewed your complaint you remain dissatisfied, you have the right to refer your complaint to the Financial Ombudsman Service. Copies of our complaints procedures are available on request.
Investor Profile maintains a professional indemnity insurance policy for the protection of clients in the event of any negligence by any member or employee of Investor Profile. Details of this, including the current limits of indemnity, are available on request.
Investor Profile accepts no liability for products or investments made or purchased via any other company or broker and does not provide advice as to the suitability of new investments unless you specifically ask us to do so during an advisory session.
Are we covered by the FSCS?
Yes we are which means you may be entitled to compensation from the Financial Services Compensation Scheme if we are unable to meet our obligations. This depends on the type of business and the circumstances of the claim. Most types of investment business are covered for 100% of the first £30,000 and 90% of the next £20,000 so the maximum compensation is £48,000. Further information about the compensation scheme arrangements is available from the FSCS website at www.fscs.org.uk.
Risk factors
We will write to you separately regarding any specific risk factors that apply to the service we provide for you. You should be aware that the past performance of investments is no indicator of future performance and that the value of investments can go up or down, which means you may not get back the full amount invested.
Money Laundering
Where we are required to verify your identity in accordance with the FSA rules, no investment will be made until such verification has been obtained. If the required verification is not forthcoming within a reasonable period we will not arrange any investment for you.
We may use and search the records of credit reference or fraud prevention agencies to check your identity to satisfy the requirements of the UK Money Laundering Regulations 2007, the Proceeds of Crime Act 2002 (as amended), the Terrorism Act 2000, the Anti-terrorism, Crime and Security Act 2001 and FSA rules. Such searches will not affect your credit rating. Where such searches prove unsatisfactory for this purpose, we may ask you to supply at least one document to verify your identity and/or address.
Documentation
All investments will be registered in your name unless otherwise agreed in writing. Unless you instruct us in writing to the contrary, we will forward to you all contract notes and documents showing ownership of your investments as soon as practicable after we receive them.
Personal Information
Personal information provided by you may be maintained on computer and paper records, where you consent to us or any company associated with us for processing, both manually and by electronic means, your personal data for the purposes of providing advice, administration and management.
The information Investor Profile holds will not be disclosed to other parties except representatives of our compliance advisers, our auditors, third party investment providers, third party product providers, or other selected third party organisations under exceptional circumstances, as well as any organisation requiring access to such information for regulatory purposes only, or any person having a legal entitlement to access.
We may from time to time use the information that we hold about you to contact you by post, telephone or e-mail to bring your attention to products, services or information that we feel you may benefit from.
All cheques, documents of title, etc, may be sent by post to your latest known address and shall be sent at your own risk. The Recorded Delivery service will not normally be used.
Future Changes
In accepting these Terms of Business, you agree that we may change the future content without receiving your prior consent to do so, but we will not conduct any investment business for you following any change unless we have given you reasonable notice, unless it is impractical to do so.
Cancellation
These Terms of Business may only be cancelled and our authority to act on your behalf may only be terminated in writing, at any time, without penalty, by either party and with immediate effect without prejudice to the completion of transactions initiated prior to receipt of such notice. Other than as stated in this paragraph, there are no cancellation rights that apply to these Terms of Business.
However specific cancellation rights do apply to certain products available through our service. Clients will be entitled to a 30 days cancellation notice period for all SIPP and ISA contracts whether opening a new account or transferring existing investments to our service. More details regarding the cancellation rights of individual products can be found in the product Key Features document, which is made available prior to investment. Clients will not be entitled to receive cancellation rights in relation to unit trust purchases, whether inside or outside of a product wrapper such as an ISA or SIPP.
Law
English law will be the basis of this contract and the language in which this contract will be interpreted, and in which all communications will be conducted, will be English. The Contracts (Rights of Third Parties) Act 1999 shall not apply to this Client Agreement.
