Terms of Business

This Terms of Business sets out the business on which Drumlin Financial Services Ltd t/a Key Financials, (hereinafter referred to as Key Financials), will provide business services to you as an individual private client of the firm. Please take a minute to read through the terms and if you have any questions we will be happy to answer them.

Key Financials is regulated by the Central Bank of Ireland as a Multi-Agency Intermediary under the Investment Intermediaries Act, 1995. The Central Bank of Ireland holds registers of regulated firms.

Key Financials holds a written appointment to act as an agent for the following investment & life assurance companies:

(i) New Ireland

(ii) Zurich Life

(iii) Standard Life

(iv) Aviva, Life & Pensions

(v) Irish Life Assurance Plc.

(vi) Royal London

In relation to products provided by the product producers, the services that the firm is authorised to provide are:

(i) Advising you in relation to the nature of each of the products and advising you as to which product is suitable for your needs.

(ii) Receiving and transmitting orders on your behalf for a product. 

Key Financials receives commission and other payments from the product producer to whom orders are transmitted. Summary details of these payments will be included in a product disclosure document before proceeding with a proposal form is completed. Full details of the payments will be provided at the policy issue stage. In certain circumstances the firm may charge you a fee for the services provided. If we do this we will provide you a written estimate of this in advance of providing any business service. 

Key Financials’ policy is to avoid a conflict of interest when providing business service to its clients. However, should an unavoidable conflict arise we will advise you of this in writing before proceeding to provide any business service. If you have not been advised on any such conflict you are entitled to assume that none arises. Key Financials will, if necessary, exercise its legal rights to receive any payments due to it from clients for business services provided by it and to reimburse for any value obtained by the firm for clients arising from payments by the firm on behalf of clients who subsequently default in payment due to the firm.

Product producers may withdraw benefits or cover on default of payments due under any products arranged for your benefit. Details of these provisions will be included in your product terms and conditions.

If you have any complaint in relation to the business services provided by Key Financials you should outline the nature of your complaint. Any such complaint will be acknowledged within 14 days. The complaint will be fully investigated by Key Financials and a full response will be provided to you. We will aim to provide this response not later than two months from receipt of your complaint. In the event that you remain dissatisfied with the firms handling and response to your complaint you are entitled to refer your complaint to the Central Bank of Ireland.

Key Financials is a member of the Investor Compensation Scheme, which provides certain remedies to eligible clients in the event of default by the company. The main details of the operation and conditions of the scheme are attached – see appendix 1.

Our Code of Practice is outlined in Appendix 2.

APPENDIX 1

Details of the Investor Compensation Act, 1998

1. The Investor Compensation Act 1998 provides for the establishment of a compensation scheme and the payment, in certain circumstances, of compensation to certain clients (known as eligible investors) of authorised investment firms, as defined in that Act.

2. Key Financials is a member of that compensation scheme ICCL 40306.

3. Compensation may be payable where money or investment owed or belonging to clients and held, or in the case of investment instruments, administered or managed by the firm, cannot be returned to those clients for the time being and there is no reasonably foreseeable opportunity of the firm being to do so.

4. A right to compensation will arise only:

a) If the client is an eligible investor as defined in the Act

b) If it transpires that the firm is not in a position to return client money or investment instruments owed or belonging to clients of the firm and;

c) To the extent that the client’s loss is recognised for the purpose of the Act.

5. Where an entitlement to compensation is established, the compensation payable will be the lesser of:

a) 90 per cent of the amount of the client’s loss as recognised for the purpose of themInvestor Compensation Act, 1998, or

b) Compensation of up to €20,000.

APPENDIX 2

KEY FINANCIALS

Code of Practice

Key Financials shall ensure in all transactions that it;

a) Acts honestly and fairly in conducting its business activities in the best interest of its clients and the integrity of the market.

b) Acts with due skill, care and diligence in the best interests of its clients and the integrity of the market.

c) Has and employs effectively the resources and procedures that are necessary for the proper performance of its business activities,

d) Seeks from its clients information regarding their financial situations and their objectives as regards the services requested.

e) Makes adequate disclosure of relevant material information, including charges/commission, in its dealings with its clients.

f) Makes a reasonable effort to avoid conflicts of interests and, when they cannot be avoided, ensures that its clients are fairly treated.

g) Complies with all regulatory requirements applicable to the conduct of its business activities so as to promote the best interests of its clients and the integrity of the market.

APPENDIX 3

We draw your attention to the following warnings;

YOUR HOME IS AT RISK IF YOU DO NOT KEEP UP REPAYMENTS ON A MORTGAGE OR ANY OTHER LOAN SECURED ON IT. THE PAYMENTS RATES ON THIS HOUSING LOAN MAY BE ADJUSTED BY THE LENDER FROM TIME TO TIME.

THERE IS NO GUARANTEE THAT THE PROCEEDS OF THE INSURANCE POLICY WILL BE SUFFICIENT TO REPAY THE LOAN IN FULL WHEN IT BECOMES DUE FOR REPAYMENT