A shared approach                toAdviser and Consultancy Charging                Technology, Media & Telecommunications ...
ContentsIntroduction	                                         2Generic principles	                                   3Faci...
“ e know extremely well in our industry about the devil being in the detail. And so W it is with Adviser Charging and Cons...
IntroductionThe regulatory changes arising from the Retail                Clarity will continue to emerge in the coming mo...
Generic principlesHere we provide an overview of the generic principles that we believe will underpin Adviser Charging and...
Facilitating Adviser ChargingS tarting, stopping and amending AC are the core activities that will be involved in facilita...
Stopping and reducing Adviser ChargesThis process applies when providers are instructed to stop or reduce AC. It does not ...
Increasing an Adviser Charge or applying an ad-hoc Adviser Charge                                                         ...
Facilitating Consultancy ChargingStarting, stopping and amending CC are the core activities that will be involved in facil...
Starting a Consultancy Charge (continued)                          7. Scheme              8. Policy set up and      9. Adm...
Stopping and reducing Consultancy ChargesThis process applies when providers are instructed to stop or reduce CC. It does ...
Increasing a Consultancy Charge or applying an ad-hoc Consultancy ChargeThis process assumes individual consent is not req...
Core Adviser and ConsultancyCharging structuresHere we set out the core AC and CC charging structures, which we believe ar...
Collective investments (e.g. Equity ISAs) and investment bonds                    Initial                                 ...
Cooling-off and opt-outOn cancellation within the cooling-off period, the FSA will allow refunds to the client to be eithe...
High-level options for opt-out from automatic enrolmentRefunds must be gross of AC or CC. Providers will either:	   (a)  e...
Changes to an adviser firmThere are a range of scenarios under which there could be a change to an adviser firm and a numb...
Continued from previous pageQuestion                         Answer5. 	 hat if the adviser    W                           ...
Value Added Tax (VAT)When there are changes to the applicable rate of VAT this could lead to a significant volume of work ...
GlossaryTerm                                   DefinitionAd-hoc Adviser Charge                  A single adviser charge fo...
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Transcript of "Rdr charges brochure"

  1. 1. A shared approach toAdviser and Consultancy Charging Technology, Media & Telecommunications Predictions 2011 a
  2. 2. ContentsIntroduction 2Generic principles 3Facilitating Adviser Charging 4Facilitating Consultancy Charging 7Core Adviser and Consultancy Charging structures 11Cooling-off and opt-out 13Changes to an adviser firm 15Value Added Tax (VAT) 17Glossary 1918
  3. 3. “ e know extremely well in our industry about the devil being in the detail. And so W it is with Adviser Charging and Consultancy Charging. Simple in concept but not without some practical challenges in their application. We therefore very much welcome the initiative taken by this group, comprising of experienced advisers and product providers, in taking the time to work through in detail these important matters. For advisers thinking about how Adviser Charging and Consultancy Charging might work for them in practice, we believe this document should prove to be a very helpful starting point.”Stephen Gay, Director General, AIFA“ he ABI supports the RDR which will introduce massive changes for the financial T services industry and consumers, including the ban on commission payments for advice and the introduction of Adviser and Consultancy Charging. So we welcome this new guidance as it will help advisers, insurers and others to understand ways in which Adviser and Consultancy Charging can work in practice.”Maggie Craig, Director of Financial Conduct Regulation, ABI“ eloitte is particularly pleased to have facilitated the creation of A shared approach to D Adviser and Consultancy Charging. We very much want to see a smooth transition to a post-RDR world and believe the outputs of the project will go a long way to helping both advisers and the wider provider community prepare for the practicalities of the RDR. We hope the publication will act as a framework to underpin core AC and CC facilitation across the industry, without restricting in any way what advisers and providers might wish to offer in addition.”Gavin Norwod, Partner, Deloitte A shared approach to Adviser and Consultancy Charging 1
  4. 4. IntroductionThe regulatory changes arising from the Retail Clarity will continue to emerge in the coming months.Distribution Review (RDR) take effect on 31st December However we believe the publication of this document2012. Although many of the regulatory rules and will help the adviser community to move forwardguidance are in place, the industry needs to develop a towards implementation of AC and CC with increasedview as to how certain processes and activities around confidence. We hope all readers will find this documentAdviser Charging (AC) and Consultancy Charging (CC) useful in supporting as smooth as possible a transitionwill operate in practice. to RDR.We (AEGON, Friends Life, Legal General, Prudential If you have any questions or would like to discussand Scottish Life) believe A shared approach to the content of this guide, please contact yourAdviser and Consultancy Charging represents one of representative from any of the product providersthe first concrete deliverables around the RDR from listed above.the industry, helping to clarify practical issues andcore AC and CC functionality. Through a series of The contents of the pack are owned by the productworkshops and meetings facilitated by Deloitte, we providers listed above and not Deloitte. The viewshave developed a common approach to facilitating AC contained within the document are the views ofand CC through the product by creating a series of high these providers. Whilst this document has beenlevel principles and processes detailed in this document. created in good faith based on our understanding ofWe have also expressed our views on the core AC the regulations as at 16th December, we cannot beand CC charging structure options that we think are held responsible for any inaccuracies or changes inlikely to be widely available in the market. It will be for regulations that may render the information containedadvisers to determine when it will benefit their clients in this document incorrect.to facilitate an AC or CC from the product.The guide is not intended to restrict in any way thetypes of AC or CC facilitation providers will offer or howthey choose to operate it. Providers will not necessarilyoffer all the options set out in this document. Insteadit aims to ensure all parties involved in an AC or CCarrangement have a common understanding of theactivities and processes that underpin it.We would like to express our sincere thanks to SesameBankhall Group for their valuable input throughout theproject. A shared approach to Adviser and Consultancy Charging 2
  5. 5. Generic principlesHere we provide an overview of the generic principles that we believe will underpin Adviser Charging andConsultancy Charging.1. The AC agreement is between the client and the adviser firm, not the adviser.2. The CC agreement is between the employer and the adviser firm, not the adviser.3. AC/CC taken from pensions can only pay for advice and services on pensions.4. Providers will communicate to the market the products through which they will facilitate AC and CC, and the AC and CC structures available for these products.5. Before any AC or CC can be facilitated, the adviser firm and the provider need to re-agree terms of business.6. AC/CC instructions will capture any initial, ongoing or ad-hoc AC/CC and stipulate that it will be the gross amount (i.e. including VAT). The CC instruction can be at scheme or at individual level.7. Providers do not require information with regard to AC/CC which they are not facilitating.8. The provider will comply with AC/CC instructions once validated, in a timely manner.9. Advisers or employers will communicate services/changes to services being provided to the client or individual, in a timely manner.10. Advisers will keep their own VAT records for AC/CC. Providers will not keep these records. A shared approach to Adviser and Consultancy Charging 3
  6. 6. Facilitating Adviser ChargingS tarting, stopping and amending AC are the core activities that will be involved in facilitating AC.Here are the core processes that we believe will underpin AC facilitation, and that could be adopted across the industry.The process flows provide the activities in a step-by-step format. Providers and advisers may not necessarily carry out the process steps in exactlythe same order.Starting an Adviser Charge 1. Introduction 2. Needs analysis 3. Research 4. Recommendation 5. Application • dviser meets A • dviser carries A • dviser A • dviser A • dviser/client A client and they out needs researches recommends completes agree services analysis. products and product(s) to product and charging AC facilitation client. application. structure (the AC options. agreement). • C charging A • dviser/client A • dviser requests A structure is completes illustrations, agreed. standard AC including impact instruction. of AC options. • ote: This may N represent a variation to the AC agreement. 7. Policy set up and 8. Administration 9. Payments to 6. Provider validation confirmation of AC of AC adviser firm • rovider validates P • rovider P • rovider P • rovider credits P the instruction. completes new administers the adviser firm. business process AC within the for product. product. • emuneration R statement should • rovider confirms P split commission, AC to client and AC and CC adviser. transactions. A shared approach to Adviser and Consultancy Charging 4
  7. 7. Stopping and reducing Adviser ChargesThis process applies when providers are instructed to stop or reduce AC. It does not cover situations where AC reduces or stops as a result ofcontribution or fund variations. 3. Client/adviser 5. Amendment of 1. Services/AC 2. Illustration request 4. Provider validation instruction charges • dviser and A • llustration I • rovider receives P • rovider validates P • rovider acts on P client discuss of impact of the instruction the instruction. instruction. the changes to amended AC is from either the services and requested by client or the associated AC. the adviser from adviser. the provider (optional). 6. Information to 7. Information to 8. Administration 9. Payments to client adviser of AC adviser firm • rovider informs P • rovider informs P • rovider P • rovider credits P client. adviser. administers adviser firm. any remaining AC within the • emuneration R product. Statement should split commission, AC and CC transactions. A shared approach to Adviser and Consultancy Charging 5
  8. 8. Increasing an Adviser Charge or applying an ad-hoc Adviser Charge 5. Amendment of 1. Services/AC 2. Illustration request 3. Client instruction 4. Provider validation charges • dviser and A • llustration I • he client T • rovider validates P • rovider acts on P client discuss of impact of confirms they the instruction. instruction. the changes to amended AC is agree to the services and requested by the increased/ad-hoc associated AC. adviser from the AC and adviser provider. documents this and sends instruction to provider. • ote: There may N or may not be an associated policy alteration. 6. Information to 7. Information to 8. Administration 9. Payments to client adviser of AC adviser firm • rovider informs P • rovider informs P • rovider P • rovider credits P client. adviser. administers the adviser firm. AC within the product. • emuneration R statement should split commission, AC and CC transactions. A shared approach to Adviser and Consultancy Charging 6
  9. 9. Facilitating Consultancy ChargingStarting, stopping and amending CC are the core activities that will be involved in facilitating CC.Here are the core processes that we believe will underpin CC facilitation, and that could be adopted across the industry.T he process flows provide the activities in a step-by-step format. They also reflect the involvement of individual members who are the legalowners of the policies. Providers and advisers may not necessarily carry out the process steps in exactly the same order.Starting a Consultancy Charge 1. Introduction 2. Needs analysis 3. Research 4. Recommendation 5. Application • dviser meets A • dviser carries A • dviser A • dviser A • dviser A employer and out needs researches recommends completes they agree analysis. products and product to product services and CC facilitation employer. application. charging • dviser and A options. structure (the CC employer agree • dviser A • mployer/adviser E agreement). on approach to • dviser requests A obtains generic completes apportioning of terms for illustrations. standard CC CC across the the scheme instruction. members. and sample • dviser and A illustrations employer agree including impact on scheme set up of CC options (if and CC structure. any). • ote: This N • dviser decides A may require on preferred refinement to product. suit employer needs and a variation to the CC agreement. Continued on the next page A shared approach to Adviser and Consultancy Charging 7
  10. 10. Starting a Consultancy Charge (continued) 7. Scheme 8. Policy set up and 9. Administration 10. Payments to 6. Provider validation communications confirmation of CC of CC adviser firm • rovider validates P • rovider P • rovider P • rovider P • rovider credits P the instruction. provides joining completes new administers the adviser firm. pack including business process CC within the • ote: Member N scheme details, for individual product. • emuneration R specific application and policies. statement should validation may be illustration. split commission, required. • rovider confirms P AC and CC • dviser/ A CC to individuals, transactions. employer/ employer and provider carry out adviser. communications and enrolment as agreed. A shared approach to Adviser and Consultancy Charging 8
  11. 11. Stopping and reducing Consultancy ChargesThis process applies when providers are instructed to stop or reduce CC. It does not cover situations where CC reduces or stops as a result ofcontribution or fund variations. 3. Amendment of 4. Employer/adviser 1. Services/CC 2. Illustration request 5. Provider validation services instruction • dviser and A • llustration I • dviser/employer A • rovider receives P • rovider validates P employer discuss of impact of informs the the instruction the instruction. the changes to amended CC is individual of from either services and requested by changes to employer or associated CC. the adviser from services. adviser. the provider for the employer (optional). 6. Amendment of 7. Information to 8. Information to 9. Information to 10. Administration charges employer individual adviser of CC • rovider acts on P • rovider informs P • rovider informs P • rovider informs P • rovider P instruction. employer. individuals. adviser. administers any remaining CC within the product. 11. Payments to adviser firm • rovider credits P adviser firm. • emuneration R statement should split commission, AC and CC transactions. A shared approach to Adviser and Consultancy Charging 9
  12. 12. Increasing a Consultancy Charge or applying an ad-hoc Consultancy ChargeThis process assumes individual consent is not required. 3. Amendment of 4. Employer 1. Services/CC 2. Illustration request 5. Provider validation services instruction • dviser and A • llustration I • dviser/employer A • mployer E • rovider P employer discuss of impact of informs the provides CC validates the CC the changes to amended CC is individual of instruction to instruction. services and requested by the changes to provider. associated CC. adviser from the services. provider for the employer. 6. Amendment of 7. Information to 8. Information to 9. Information to 10. Administration charges employer individual adviser of CC • rovider acts on P • rovider informs P • rovider informs P • rovider informs P • rovider P instruction. employer. individual. adviser. administers the CC within the product. 11. Payments to adviser firm • rovider credits P adviser firm. • emuneration R statement should split commission, AC and CC transactions. A shared approach to Adviser and Consultancy Charging 10
  13. 13. Core Adviser and ConsultancyCharging structuresHere we set out the core AC and CC charging structures, which we believe are likely to be offered by the provider community. Different providersare likely to offer different options. But when an adviser firm is agreeing on an AC or CC structure with a client, they will want to do so withconfidence that the provider they ultimately select is likely to be able to facilitate that structure.This is not intended to limit the number of structures that can be offered by anyone, but to ensure there is a certain level of consistency betweenprovider and adviser approaches to ensure smooth facilitation of AC/CC to benefit advisers, clients and providers.The options documented are not exhaustive, and providers may offer one or more of these charge types and others as they deem appropriate.Pensions (including drawdown) Initial Ongoing Ad-hoc Gross single 1. £ and/or % of gross single 1. £ and/or % of funds. 1. and/or % of fund (one-off £ contribution contribution or transfer value 2. requency monthly as default. F payment). and (one-off payment). transfer value Gross regular 1. and/or % of gross regular £ 1. and/or % of funds and/or % of £ 1. and/or % of fund (one-off £ contribution contributions. gross regular contributions. payment). 2. eriod: instalments over P 2. requency monthly as default. F 1-24 months (Note: If the term of the product is 12 months for example, the spread would be a maximum of 12 months).*Notes:• urther options for ongoing charges include flexibility of start date, end date, frequency (e.g. quarterly, yearly), in advance or arrears and F escalation of £ amounts. An option for regular contribution Initial charges defined at scheme level is escalation of £ amount.• or CC within a scheme, different categories of member may be subject to different CC structures and levels. F• he following applies to all boxes: With deduction options, the minimum standard is to provide one of the following options: T (a) deduct from contribution before asset purchase; or (b) cancellation of asset.• CC can only be agreed upon and applied for by an employer for their employees.• he option to apply additional AC, with individual member consent, may be offered to members of a scheme with CC. T• When receive instructions, act in a timely manner, i.e. for deduction date.• Providers may offer one or more of each of these type of charges.*Instalments over a period of time greater than 24 months could also be an option. A shared approach to Adviser and Consultancy Charging 11
  14. 14. Collective investments (e.g. Equity ISAs) and investment bonds Initial Ongoing Ad-hoc Single 1. £ and/or % of single contribution 1. £ and/or % of funds. 1. and/or % of fund (one-off £ contribution or transfer value 2. requency monthly as default. F payment). and transfer (one-off payment). value Regular 1. and/or % of regular £ 1. and/or % of funds and/or % of £ 1. and/or % of fund (one-off £ contribution contributions. regular contributions. payment). 2. eriod: instalments over P 2. requency monthly as default. F 1-24 months (Note: If the term of the product is 12 months for example, the spread would be a maximum of 12 months).*Notes:• urther options for ongoing charges include flexibility of start date, end date, frequency (e.g. quarterly, yearly), in advance or arrears and F escalation of £ amounts.• he following applies to all boxes: The minimum standard is to provide one of the following options: T (a) deduct from contribution before asset purchase; (b) cancellation of asset; or (c) facilitation outside of the product.• When receive instructions, act in a timely manner, i.e. for deduction date.• Providers may offer one or more of each of these type of charges.• Regular contributions and transfer value do not apply to investment bonds.*Instalments over a period of time greater than 24 months could also be an option.Annuities Initial Ongoing Ad-hoc 1. £ and/or % of annuity purchase price Default assumption is none.* Default assumption is none.* (one-off payment).Notes:* n investment annuity may offer a chance for ongoing advice in the same style as pensions, with flexibility of start date, frequency A (e.g. quarterly, yearly) and escalation of £ amounts. A shared approach to Adviser and Consultancy Charging 12
  15. 15. Cooling-off and opt-outOn cancellation within the cooling-off period, the FSA will allow refunds to the client to be either net or gross of AC/CC.The FSA also recently made changes to its COBS rules to reflect pension reforms and automatic enrolment. A scheme used for automaticenrolment will offer all members an opt-out facility instead of cancellation rights. But under opt-out, DWP legislation stipulates that the individualmust receive a return of their full contributions – i.e. without any deduction for AC/CC.It is likely that different providers will take different approaches on both cancellation and opt-out. For cancellation, they may also vary theirapproach between products. Here we set out some common principles that providers might follow and explain the implications of differentapproaches.Adviser firms should also make it clear in their AC/CC agreement with clients what will happen to agreed AC/CC on cancellation – in particular,if the client is still liable to pay this and if not, the mechanisms to follow to have it repaid.High-level options for cooling-offRefunds can either be gross or net of AC or CC1. Refund clients investments gross of AC or CC. providers choose to follow this approach, they can either: If (a) elay deducting AC/CC from the policy and paying it to the adviser until the cooling-off period has ended; or d (b) eclaim paid AC/CC from the adviser. r2. Refund clients investments net of AC or CC. Here, it will be for the adviser and client to agree whether the adviser should refund the AC or CC to the client. This should be covered in their AC/CC agreement.Key principlesWhile different providers will adopt different approaches, and possibly vary these between products, the following principles should apply: The right to cancel and how the refund will be calculated will be communicated to individuals in pre-sale documentation such as Key Features.1. 2. Pension transfer payments should be refunded in full to the ceding scheme and any AC/CC reclaimed from the adviser.3. Providers will inform the adviser of all cancellations promptly.4. any ongoing (in addition to initial) AC/CC is paid during the cooling-off period, it will be treated the same as initial. If A shared approach to Adviser and Consultancy Charging 13
  16. 16. High-level options for opt-out from automatic enrolmentRefunds must be gross of AC or CC. Providers will either: (a) elay deducting AC/CC from the policy and paying it to the adviser until the opt-out period has ended; or d (b) eclaim paid AC/CC from the adviser. rKey principlesWhile different providers will adopt different approaches, the following principles should apply:1. The right to opt-out will be communicated by the provider and pre-sale documentation will make it clear that on opt-out, the client will get a refund of their full contributions.2. Providers will inform the adviser of all opt-outs promptly.3. any ongoing (in addition to initial) AC/CC is paid during the opt-out period, it will be treated the same as initial. If A shared approach to Adviser and Consultancy Charging 14
  17. 17. Changes to an adviser firmThere are a range of scenarios under which there could be a change to an adviser firm and a number of these are considered below.This is a complex area which will result in providers adopting different approaches. The approaches taken will depend on their own internal riskand due diligence procedures.Please note: This is for AC and CC only, not commission.Question Answer1. What if the adviser firm sells If the adviser firm (regulated entity) is selling part or all of the client contracts and database (with their client contracts and the same terms and services continuing to apply), the provider may need to check (depending on database to another firm? their own risk/compliance and due diligence processes) the legal sale and purchase agreement to ensure that they could deal with the purchasing firm in relation to the clients documented in the agreement. Once validated the provider should not necessarily need to stop the current AC/CC instructions and start a new one, but simply redirect the current instruction to the new adviser firm. Two communications would be required: one from the ‘new’ and one from the ‘old’ adviser firm to the client (who is the employer when referring to a CC) to explain the change of adviser. The provider would also inform the client once they have validated the agreement (not to seek agreement but to advise of the change). The Provider would also write to individuals to inform then of the change in relation to CC transfers. If a client rejects the change in adviser firm, the charge would be stopped and the provider would inform the client and the adviser firms.2. What if the adviser firm has The provider can continue to facilitate the AC/CC as previously instructed. a change in shareholders or partners?3. What if the adviser firm has Provider’s approach will depend on their own risk/compliance and due diligence processes. a change in legal status (i.e. Limited company to Limited Liability Partnership)? What are the implications of Where the advisers are from the same firm, there are no problems as the client agreement is with4. multiple advisers related to the adviser firm, not the specific individuals. a policy? There will be situations where multiple adviser firms will be receiving AC and CC simultaneously. Providers must exercise caution to ensure they do not breach the Data Protection Act. Continued on the next page A shared approach to Adviser and Consultancy Charging 15
  18. 18. Continued from previous pageQuestion Answer5. hat if the adviser W Where AC is being paid to remunerate the adviser for ongoing services, loss of regulatory firm loses regulatory permission is very likely (but not certain) to mean these agreed ongoing services cannot permissions? What happens be provided and future AC payments should stop. Provider firms will become aware of an to future payments of intermediary firm losing authorisation through data supplied by the FSA. Where this happens, AC and CC?” provider firms will need to contact the adviser firm to confirm whether or not ongoing AC can continue. If ongoing AC is to stop, future deductions from the policy will also stop. AC for initial advice can be spread over a time-period for regular premium policies. If an adviser firm loses authorisation during that time-period, there is no regulatory requirement that future instalments should cease, as these are paying for advice previously given. The AC Instruction given to the provider firm will have made clear if AC is for initial advice or in respect of ongoing services. CC is agreed with the employer for services which are not necessarily subject to regulated activities. It will be for the adviser and employer to decide if agreed services are affected by the loss of regulatory permissions and to instruct the provider accordingly. Where provider firms become aware of an adviser firm losing authorisation through data supplied by the FSA, they should contact the adviser firm to confirm whether or not ongoing CC should continue.6. hat if an adviser moves W The AC agreement is not with the adviser, but between the adviser firm and the client. There between adviser firms? should be no change to the AC unless the client provides an instruction to stop the previous AC and an instruction to start a new AC.7. What happens if the client A new AC/CC instruction will be required from the client. changes their adviser firm?8. What if a new adviser firm The provider should obtain authority from the client to disclose payment information to the new (servicing agent) requests adviser firm. The transaction history could then be provided. detail of payments made from a policy to a previous adviser firm (agent)? A shared approach to Adviser and Consultancy Charging 16
  19. 19. Value Added Tax (VAT)When there are changes to the applicable rate of VAT this could lead to a significant volume of work across the industry and potential clientconfusion. We have sought a practical solution to this in order to ensure fairness to the client, whilst enabling an efficient operational processacross the parties involved.There are three example scenarios where VAT can change:1. VAT itself changes (this will follow the principles stated below).2. VAT status of a service provided changes (this would follow some of the steps in increasing or reducing an AC or CC process).3. AT status of the adviser changes because they go above or drop below VAT threshold (this would follow some of the steps in increasing or V reducing an AC or CC process).Proposed principles:1. nitial provider statements/declarations to clients should include robust wording around VAT changes where the adviser wants to have the I authority to instruct that changes in relation to VAT are to be made by the provider automatically, without having to validate the instruction.2. dvisers should be able to provide information in an industry standard format, to providers on applicable VAT changes for any client affected at A the policy level on which the providers can act to make changes to AC or CC.3. The same principles apply for a decrease in VAT. A shared approach to Adviser and Consultancy Charging 17
  20. 20. GlossaryTerm DefinitionAd-hoc Adviser Charge A single adviser charge for some specific advice or services outside of the initial or ongoing agreement. This may be referred to as an on-demand or one-off charge.Ad-hoc Consultancy Charge A single Consultancy Charge for some specific advice or services outside of the initial or ongoing agreement. This may be referred to as an on-demand or one-off charge.Adviser/Consultancy Charge The methods available of how to facilitate the AC/CC, e.g. a) Outside of productFacilitation Method wrapper; b) Deduction from a contribution before purchasing assets; and c) Selling assets (dis-investment).Adviser Charge (AC) Any form of charge payable by, or on behalf of, a client to an adviser firm in relation to a personal recommendation in respect of a retail investment product.Adviser Charge Agreement The agreement between client and adviser firm regarding the structure and level of charges which will be paid for the advice and services undertaken.Adviser Charge Instruction (ACI) An instruction from the client to the product provider to confirm the adviser charges to be facilitated by the provider and paid to the adviser firm. Instructions can be in whichever format a provider believes is necessary to meet regulations and are acted upon only if proved valid to options supported by the provider.Adviser Charge Type An initial, ongoing or ad-hoc charge.Consultancy Charge (CC) Any form of charge payable by, or on behalf of, an employee to an adviser firm in respect of advice given, or services provided, by the adviser firm to the employer or employees in connection with a group personal pension scheme or group stakeholder pension scheme, where those charges have been agreed between the adviser firm and the employer.Consultancy Charge Agreement The agreement between employer and adviser regarding the structure and level of charges which will be paid for the advice and services undertaken.Consultancy Charge Instruction (CCI) An instruction from the employer to the product provider to confirm the consultancy charges to be facilitated by the provider and paid to the adviser firm. Instructions can be in whichever format a provider believes is necessary to meet regulations and are acted upon only if proved valid to options supported by the provider.Individual Adviser This is the registered individual providing the advice to the client/individual/employer.Initial Adviser Charge Adviser Charges for initial advice or services provided.Initial Consultancy Charge A Consultancy Charge for initial advice or services.Ongoing Adviser Charge An Adviser Charge for advice and services provided on an ongoing basis.Ongoing Consultancy Charge A Consultancy Charge for advice and services provided on an ongoing basis. A shared approach to Adviser and Consultancy Charging 18

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