Terms of Business
Menu of Services, Terms of Business and Client Agreement
Introduction and Firm Background
This document is aimed at providing you with a brief overview of Coole Bevis Wealth Management (CBWM) and to introduce our services to you in more detail. We will discuss this with you so that you fully understand what is offered and how it will benefit you. If you would like this document in larger print or in another format, please contact us.
- Incorporating our Terms of Business and Client Agreement it explains in more detail the services that we provide and the associated costs.
- This document also aims to give you a good idea of how much you can expect to pay for our services, however we treat all of our clients as individuals and we will therefore calculate the cost of our advice based on your specific requirements.
- This means that the charges outlined in this document should only be used as an indicative guide and we will provide you with a more accurate breakdown of the service and costs that will apply to you once we have fully assessed your personal circumstances and the services that you require.
- Should you have any questions on any element of this please do not hesitate to ask us.
CBWM is a financial services business which provides independent financial advice to a range of retail personal and business clients.
- We provide holistic financial advice for individuals, businesses, trusts and charities on investments, savings, retirement planning, and non investment insurance (for example Life Assurance, Private Medical Insurance, Critical Illness cover).
CBWM is a joint venture between Coole Bevis solicitors (a merger of Woolley Bevis Diplock LLP and Coole & Haddock LLP), a leading law firm based in Sussex with a long established reputation and extensive expertise across a range of legal services, and Carpenter Box Wealth Management LLP, in order to provide a comprehensive independent financial planning service for the clients of CBWM.
What do we offer?
Unless we notify you in writing to the contrary, we will be treating you as a “retail client”. This means that you are afforded the highest level of protection under the regulatory system and you may have the right to take a complaint to the Financial Ombudsman Service.
Coole Bevis Wealth Management is able to act on your behalf in advising you on investments and non-investment insurance contracts as detailed in our services below.
We offer a variety of advice services including:
- Full Financial Review
- Limited Advice
- Introducer for Lending Services
- Introducer for General Insurance Services
- Ongoing Review Services
Any advice or recommendation that we provide 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. All advice and recommendations will be provided in the format of a suitability report or a letter.
As we offer independent investment advice we will consider a wide range of financial strategies and products. We are constantly reviewing the market to ensure that the services and products we offer are appropriate for our clients.
Where we recommend particular investment strategies and products to you, these will be selected based on your personal circumstances, financial goals and objectives. We will consider a number of factors, including the services you need, the cost of investing, how much risk you are prepared to accept in an investment product and how much of a drop in its value you could withstand.
The areas we can advise on include:
- Open ended investment companies
- Unit trusts
- Investment bonds
- Exchange traded funds
- Investment trusts
- Enterprise investment schemes
- Structured products, incl. structured deposits
- Venture capital trusts
- Phased retirement and income drawdown
- Term assurance
- Critical illness cover
- Income protection
- Long term care
- Whole of Life
We do not provide advice in relation to individual share holdings. If this is something you need assistance with, we can refer you to a stockbroker.
We do not provide advice on options, futures and other derivative contracts as we believe that these are unlikely to be suitable for the majority of our clients.
Where we provide protection planning services we are an insurance intermediary and will provide advice which is based on a fair and personal analysis of the market.
Providing information about your circumstances
Our advice will be based on the information that you give so it is important that you provide us with accurate and up to date information when we request details about your circumstances and objectives. This will allow us to provide you with suitable advice. If the information you provide is inaccurate or if you limit the information provided this could affect the suitability of the advice we give.
Aggregated costs and charges
To help you understand the overall costs of our services and recommendations we will add together all the costs and charges payable. This is referred to as aggregated costs and charges information.
We will confirm the actual aggregated costs and charges based on our recommendations within our suitability report or letter.
Full Financial Review
We will provide a suitability report or letter which is intended as a discussion document to help assist you in making decisions in terms of your priorities and objectives.
If you specifically instruct CBWM that you do not wish to discuss a particular area of financial advice, and that area should not form part of the advice given, this will be considered to be ‘limited advice’.
- In which case, the standard advice process stages will still be followed, but specifically in relation to the requested area.
- You must be aware that if you limit the information provided, this may affect the completeness of the advice given, and that any information not disclosed could affect how appropriate that advice is to your circumstances.
Introducer for Lending Services
Coole Bevis Wealth Management does not provide advice on lending based services, such as Mortgages, Equity Release loans or commercial credit of any type.
In some instances however, we may refer you to third party institutions who offer solutions for lending based services. Where Coole Bevis Wealth Management make a referral to a third party institution for lending services we are acting in the capacity as an introducer and are not making a recommendation or providing advice as to the suitability of an underlying product or service. We are a credit broker and not a lender.
In addition, where we introduce you to a third party for lending services we may receive an introducer fee. We will disclose details of any fees, commissions, or other benefits received in connection with any introduction and keep relevant records of such transactions. These introduction fees will be payable on completion of application for lending. Assuming £100,000 is borrowed over 5 years on a traditional capital replacement business loan, the commission Coole Bevis Wealth Management expect to receive would be 0.75% of the initial loan capital which is £750.
Introducer for General Insurance Services
In some instances we may refer you to a third party institution for insurance. Where Coole Bevis Wealth Management make a referral to a third party institution for lending services, we are acting in the capacity of an introducer. As such, we are not making a recommendation or providing advice as to the suitability of an underlying product or service. We may receive an introducer fee for said referral.
Once your financial plan is in place it is recommended to ensure that it remains in line with your objectives and is on track to meet your goals, while adapting to any changes in your circumstances. We recognise that our clients have differing needs and we offer core services as follows:
Optional services which can be added, ensuring that we can tailor our work to your specific requirements.
Where we send investment applications on your behalf to third parties (e.g. to put an investment into force), we will take all sufficient steps to ensure that we obtain the best possible result for you. This is referred to as ‘best execution’.
We have a best execution policy. If you wish to see a copy it is available on request.
Financial Crime – Anti Money Laundering
We are required by the anti-money laundering regulations to verify your identity before undertaking any business with you, to obtain information as to the purpose and nature of the business which we conduct on your behalf, and to ensure that the information we hold is up-to-date.
- Personal data will be processed to assist our obligations to prevent money laundering and terrorist financing. This would normally include requesting a copy of either your passport or driving licence and a recent (dated within 2 months) utility bill or bank statement in your name.
- 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. The check may leave a ‘footprint’ on your credit file but it will not affect your credit rating.
- If we have not met in person we will need to contact you via videocall to verify your ID as a true likeness.
Conflict of interest
Although we will always try to act in your best interests there may be situations where we or one of our other clients has some form of interest in the business being transacted for you. If this happens, or we become aware that our interests or those of one of our other clients conflict with your own, we will write to you and ask for your consent to proceed before we carry out any business for you. We will also let you know the steps we will take to make sure you are treated fairly.
We have a conflicts of interest policy. If you wish to see a copy it is available on request.
- From time to time we may attend training events delivered by product providers, fund managers and platforms. Some of the cost of providing this training may be passed to you as part of the total charges you pay.
- Under the rules of our regulator, the FCA, as a firm providing independent advice we are unable to accept or retain payments or benefits from other firms (e.g. product providers) as this would conflict with our independent status.
Coole Bevis Wealth Management 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.
We will endeavour to make arrangements for all your investments to be registered in your name (except where a nominee is used in which case it will be held by the nominee with you as the beneficial owner) unless you instruct us otherwise in writing. Our normal ways of communicating with you are by telephone, post, e-mail or in person.
- All policy documents will be forwarded to you as soon as practicable after we receive them.
- We will issue any documentation/recommendations and any other communication to you in English (unless agreed otherwise).
- We may ask you to confirm your instructions in writing as this helps to avoid any future misunderstandings.
- Should application forms not be returned within six months after the advice, having been pro-actively chased we reserve the right to review the advice as it may no longer be appropriate which will be at an additional cost.
In most cases with the products we recommend, 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. All terms and conditions and will be clearly listed and provided to you with our suitability and recommendation report. All reports will have the provider terms and conditions attached which will provide the relevant cancellation rights to the product(s) that we have recommended.
Where there is a material change to the document we will provide an updated agreement to you.
From time to time it may be necessary to amend the terms set out in this agreement where it is not necessary to issue a new agreement. If this is the case we will update our terms of business which are available online with details of the changes at least 28 business days prior. Any significant changes that will affect existing clients will be notified in advance.
Coole Bevis Wealth Management is authorised and regulated by the Financial Conduct Authority (FCA), 12 Endeavour Square, Stratford, London, E20 1JN. www.fca.org.uk. Our firm reference number is 515456.
Our permitted business is advising on and arranging pensions, savings and investment products and non-investment insurance contracts.
You can check our details on the Financial Advisers Register by visiting the FCA’s website www.fca.org.uk/firms/systems-reporting/register or by contacting the FCA on 0800 111 6768.
In the event that you are dissatisfied with a recommendation we have made you may be entitled to make a complaint. We have a complaints procedure that is available on request. Please be assured we treat complaints very seriously.
If you complain, please contact us:
- In writing: Write to The Compliance Officer, Coole Bevis Wealth Management, Amelia House, Crescent Road, Worthing, BN11 1RL.
- By phone: Telephone +44 (0)1903 534587
- By e-mail: firstname.lastname@example.org
For your further protection if you cannot settle your complaint with us, you may be entitled to refer it to the Financial Ombudsman Service (‘FOS’). Full details of the FOS can be found on its website at www.financial-ombudsman.org.uk.
We are covered by the Financial Services Compensation Scheme (‘FSCS’). You may be entitled to compensation from the scheme if we cannot meet our obligations. This depends on the type of business and the circumstances of the claim.
- Investments – eligible claims related to most types of investment business are covered for up to 100% of a claim up to a maximum of £85,000 per person per firm.
- Non Investment Insurance – in the majority of cases, eligible claims related to advising and arranging of protection products are covered for either 90% or 100% of the claim, without any upper limit.
- Long Term Insurance – includes investment bonds, pensions, whole of life contracts and endowments. Advising and arranging 100% of a claim to a maximum of £85,000 per person per firm or 100% if due to failure of firm providing the contract with no upper limit.
Further information about compensation scheme arrangements is available from the FSCS at www.fscs.org.uk/consumer
Legal and Accounting
We are not qualified to provide legal or accounting advice or to prepare any legal or accounting documents. This means the onus is on you to refer any point of law or accountancy that may arise during the course of discussions with us to a solicitor or accountant.
Ending this agreement
We may terminate this agreement by giving you at least 20 business days’ written notice.
You may terminate this agreement at any time, without penalty. Notice of termination must be given in writing and will take effect within 5 business days.
Any transactions already initiated will be completed according to this agreement unless otherwise agreed in writing.
You will be liable to pay for any services we have provided before cancellation and any outstanding fees, if applicable.
If you are an individual, then this agreement will terminate automatically upon your death or mental incapacity.
Paying for our services
We will discuss your payment options and agree with you how we will be paid.
- We will provide you with a Fee and Service Agreement for you prior to commencement of any work for each activity we undertake. This is for you to review and will fully detail all our initial and ongoing charges.
- Our initial charges are payable once we have completed our agreed work. You can pay our charges by cheque, BACS or standing order. We do not accept payments by cash. Our charges will become payable on completion of our work and should be settled within 30 business days.
- You may also pay our charges via deductions from the financial product/s that you invest in, where the product provider allows this.
- Please note that if you choose to pay by deduction from a financial product this will reduce the amount left for investment and may, depending on your circumstances, have other consequences. The amount of ongoing charges may increase as the size of your fund grows.
- If you select this option, we will discuss the implications of using this payment method with you prior to putting it in place. For investments held on a platform (an online investment administration service) you may choose to pay our charges out of the funds held in the platform cash account, although it’s important to maintain sufficient funds in the account to cover our charges as they become payable.
- In some limited circumstances (for protection) we may receive a commission payment. Further details are provided under protection business later in this document. The amount of commission is a percentage of the total annual premium and we’ll tell you the amount before we carry out business for you. Where relevant we will provide details of the maximum amount that we could reclaim from you and the timescale in which we could do so within our suitability report.
- Any products we have arranged for you will only be kept under review as part of an ongoing service for which you have agreed to pay.
- Our charges for ongoing services will start alongside the initial charge.
- Ongoing charges can be cancelled at any time by informing us in writing, but please note that we do reserve the right to charge you for services we have provided before cancellation.
- We may ask for a deposit for initial fees this will be deducted from the final invoice.
When is VAT payable?
We will always endeavour to provide you with guidance in advance, currently we are not VAT registered so no VAT will be charged. We reserve the right to pursue VAT at a later date if it becomes due.
Appendix 1: Services and Fee StructureRead Appendix 1: Services and Fee Structure
This document is our terms of business upon which we intend to rely. For your own benefit and protection, you should read these terms carefully. If you do not understand at any point, please ask for further information. This agreement is governed, and shall be interpreted in accordance with English law and both parties shall submit to the exclusive jurisdiction of the English Courts.
Please be aware that investments can fall, as well as rise, and that you may not get back the full amount invested. The price of investments we may recommend may depend on fluctuations in the financial markets, or other economic factors, which are outside our control. Past performance is not necessarily a guide to future performance.
We may occasionally recommend investments that are not readily realisable. We’ll only do this where appropriate but, if we do, we’ll draw your attention to the risks associated with the investments in our suitability report. There is a restricted market for such investments and in some circumstances, it may not be possible to deal in the investment or obtain reliable information about its value.
We will undertake the transfer of information on a confidential basis when warranted between any such third parties, such as your accountant, solicitor or existing financial adviser. I acknowledge that this agreement will come into effect from the date of issue, and signature of our fee & service agreement.
Please note that we will issue you with a separate service agreement outlining the exact cost of our services following out initial meeting and investigations into your circumstances and objectives. This document will require your signature which will be agreeing to the service and fee agreement, and specifically confirms that you have read and are aware of this document.
These Terms of Business were last updated on 01/04/2023.