Welcome to Sutton McGrath Hartley Financial Services LLP
Who are we and what do we do?
We are a firm of independent financial advisers who believe in establishing and maintaining long term relationships in order to assist our clients with structuring their financial future. We are committed to providing our clients with a professional and efficient service and in order to do this it is important that we agree, in advance, our relationship with you.
We are authorised and regulated by the Financial Conduct Authority (FCA). The FCA regulates financial services in the UK, our authorisation and permitted activities are detailed on the Financial Services Register and can be checked by visiting the FCA’s website www.fca.org.uk/firms/systems-reporting/register or by contacting the FCA on 0800 111 6768. Our registration number is 740490.
What can we do for you?
Our mainstream service is to act on your behalf for the purpose of advising on the following:
- Investments & Pensions, for example an ISA or Personal Pension Plan;
- Personal & Family Protection, for example a Life Assurance or Critical Illness Plan;
For all the services described above we will undertake an initial meeting so we can understand your circumstances, specific needs and objectives. Following our research we will provide a personal recommendation for you to consider. With your agreement we will then implement our recommendation and arrange any financial solutions on your behalf.
Once your financial plans are in place it is important to keep them under review. Subject to the type of service you require from us, we can continue to act on your behalf. Alternatively, for those who prefer a more transactional or ad-hoc ‘pay as you go’ service, we are also happy to provide our services as and when you need them. Ultimately, whichever type or level of service you require from us we will act in your best interests at all times.
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.
Further details about these and other related services we provide are contained in the pages below. This also confirms the typical cost of our services and how we get paid for them.
Unless we notify you in writing to the contrary, we will be treating you as a “retail client” for investment business and a “consumer” for insurance 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.
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.
INFORMATION ABOUT OUR INVESTMENT & PENSION SERVICES
We offer a range of services to help you meet your investment and retirement objectives. We provide independent advice, which means that our recommendations to you will be unbiased, unrestricted and based on a comprehensive and fair analysis of the market. The amount we charge and the basis of the payment will depend on the service you choose and your individual circumstances.
Any advice or recommendation that we offer to you will only be given after we have assessed your needs and considered your financial objectives and attitude to any risks that may be involved. We will also take into account any restrictions that you wish to place on the type of products you would be willing to consider.
With very few exceptions, we will confirm to you in writing the basis of our recommendations along with details of any special risks associated with the products recommended.
Full details of the products we recommend to you including, for example, the minimum duration of the product, information on your right to cancel or whether no right to cancel exists, and any other early termination rights and penalties, will be covered in the relevant product disclosure information you will receive before conclusion of any contract.
We may also, on occasion, advise on other financial products which are not regulated by the FCA under the Financial Services and Markets Act 2000. The Financial Services Compensation Scheme does not apply to any of these products.
Under the terms of this agreement, we may, if appropriate, advise you on investments which are not readily realisable. We would draw your attention to the risks associated with these investments as there is a restricted market for them. In some circumstances it may therefore not be possible to deal in the investment or obtain reliable information about its value.
What can you expect to pay for our investment and pension advice?
We provide you with an initial consultation free of charge. This helps us to understand your financial objectives and will confirm how we can support you in working towards these. We will also discuss the cost, and levels of our services both initially and throughout our relationship with you.
Our fees are then based on either, hourly rates, fixed fee, percentage of the amount you invest or a combination of these dependent on the advice that you require. The amount that we charge will be dependent on the on your individual circumstances, the amount and complexity of the work we undertake on your behalf.
Where hourly rates are stated, these are the actual hourly rates that will apply. There is an additional charge should you engage for an on-going service. The typical cost of our ongoing service is also set out below. You can cancel our on-going services at any time.
It is possible that other costs, including taxes related to the business we conduct and products we arrange for you, may arise. These costs will not be paid by our firm but borne by you.
Examples of our typical fees for advice and arranging an investment or pension on your behalf are set out below.
Initial Advice Services
For all new clients we offer a first meeting of up to 1 hour free of charge. The purpose of this meeting is to discuss your needs and our services. We usually conduct this meeting at our offices but are happy to discuss matters with you over the phone or Skype, at a mutually convenient time.
Ongoing charge for periodic reviews and servicing work
On-Going Advice and Review Service
We strongly believe that regular reviews are essential to ensure your financial plans remain on course to achieve your goals, aspirations and financial objectives.
We will ask you whether you want us to provide you with an ongoing service. As part of our ongoing service we will issue valuations of your arrangements and invite you to planning meetings. Our ongoing service can include the following;
- ongoing assessment of your personal financial circumstances, ensuring ongoing suitability
- provide written recommendations, as appropriate
- implement any of our written recommendations
- provide written confirmation of all actions undertaken on your behalf
- issue any additional documentation in line with your expectations
- Access to your adviser and administrator by phone and email
- Annual or Half yearly valuation of your investments
- Up to 2 Face to Face portfolio reviews per annum
- manage all policy administration
Our ongoing fees will be dependent on your specific requirements and costed accordingly. Typically, we charge an annual servicing fee (an adviser charge) of up to 1% pa of the assets we look after. However, our ongoing fees could be more than this dependent on the amount of assets that you have under advice.
If agreed the fee will be deducted monthly from your investment and paid by the product provider. The amount of the fee will increase (or decrease) with the underlying value of your investments. Alternatively you can pay by cheque in accordance with our fee agreement
INFORMATION ABOUT OUR INSURANCE SERVICES
Personal and Family Protection
We offer products from a range of insurers for Life Assurance, Critical Illness Cover, and Income Protection Insurance.
How much do we charge for our insurance services?
Typically, we will receive commission from the insurer and this is reflected in the premium amount you pay to them. The amount of commission we receive will vary depending on the type of contract, term of the cover and the premium amount. Alternatively, we will charge you a fee for advice and arranging an insurance product and rebate any commission thereby reducing the premium.
In any event we will normally charge a small fee to cover the work undertaken should the policy no proceed.
We will tell you the fee and how much commission we expect to receive before we transact business for you. You will receive a quotation, which will tell you about any other fees relating to any particular insurance policy we arrange for you.
If we arrange an insurance contract and are remunerated via commission, if you subsequently cease to pay your premiums and commission has to be refunded to the provider, we reserve the right to invoice your for this amount without the need for a a separate fee agreement.
VAT- Under current legislation our services are not subject to VAT but should this change in future, and where VAT becomes due, we will notify you before conducting any further work.
Anti Money Laundering - 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 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.
Cancellation Rights - 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 pure protection policies the start of the cancellation period 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. In other cases, the cancellation period will begin on the day the contract is concluded or, if later, the day on which you receive the contractual terms and conditions.
Instructions for exercising the right to cancel, if applicable, will be contained in the relevant product disclosure information which will be issued to you. If you cancel a single premium contract, you may be required to pay for any loss you might reasonably incur in cancelling it which is caused by market movements. This means that, in certain circumstances, you might not get back the full amount you invested if you cancel the policy.
Client Money - Sutton McGrath Hartley Financial Services LLP is 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.
Communication - We will issue any documentation/recommendations and any other communication to you in English (unless agreed otherwise).
Data Protection - The information you have provided is subject to the Data Protection Act 1998 (the “Act”). By signing this document 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.
“Processing” includes obtaining, recording or holding information or data, transferring it to other companies associated with us, product providers, the FCA or any other statutory, governmental or regulatory body for legitimate purposes including, where relevant, to solicitors and/or other debt collection agencies for debt collection purposes and carrying out operations on the information or data.
In order to provide services to you we may be required to pass your personal information to parties located outside of the European Economic Area (EEA) in countries that do not have Data Protection Laws equivalent to those in the UK. Where this is the case we will take reasonable steps to ensure the privacy of your information.
We may also contact you or pass your details to other companies associated with us to contact you (including by telephone) with details of any other similar products, promotions, or for related marketing purposes in which we think you may be interested.
The information provided may also contain sensitive personal data for the purposes of the Act, being information as to your physical or mental health or condition; the committing or alleged committing of any offence by you; any proceedings for an offence committed or alleged to have been committed by you, including the outcome or sentence in such proceedings; your political opinions; religious or similar beliefs; sexual life; or your membership of a Trade Union.
If at any time you wish us or any company associated with us to cease processing your personal data or sensitive personal data, or contacting you for marketing purposes, please contact The Data Protection Officer in writing at Sutton McGrath Hartley Financial Services LLP, 5 Westbrook Court, Sharrowvale Road, Sheffield, S11 8YZ
Documentation - 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 as soon as practicable after we receive 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.
Force Majeure - Sutton McGrath Hartley Financial Services LLP 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.
Instructions - We prefer our clients to give us instructions in writing, to aid clarification and avoid future misunderstandings. We will, however, accept oral instructions provided they are confirmed in writing.
Law - 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.
Material Interest - 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.
In accordance with the rules of our regulator, The FCA, we are prohibited from accepting any payment (commission or other non-monetary benefits) which is likely to conflict with the duty of the firm to its clients.
Termination - 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 and a due proportion of any period charges for services shall be settled to that date.
Complaints - If you are unhappy with the service you have received or a product we have arranged on your behalf, a copy of our complaints procedure, which sets out how we will handle your complaint, is available upon request.
If you would like to make a complaint please contact us either in writing to: Complaints, Simon Turner, Sutton McGrath Hartley Financial Services LLP, 5 Westbrook Court, Sharrowvale Road, Sheffield, S11 8YZ .
If we are unable to settle your complaint or you are unhappy with our response, you may be able to refer it to the Financial Ombudsman Service (FOS).
Further information about the FOS is available from their website: www.financial-ombudsman.org.uk or by calling them on 0800 0234567.
Compensation Scheme - 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.
Investment business will normally be covered up to a maximum of £50,000.
Further information about these amounts and limits for all other product types are available from the FSCS at http://www.fscs.org.uk/what-we-cover/products