The Professional Insurance Broker · 2020-01-23 · PRSAs were introduced to help increase pension coverage and were intended to complement company schemes and other Pension arrangements

The Professional Insurance BrokerT h e o f f i c i a l m a g a z i n e o f t h e p r o f e s s i o n a l I n s u r a n c e B r o k e r s A s s o c i a t i o n

Issue No.2 - Summer 2003

Interview with Dr. Liam O’Reilly

T h e P ro f e s s i o n a l I n s u r a n c e B ro ke r

Editoral

Page 1 Chairman’s RemarksTerry Hardiman

Page 2 PRSAs – Challenging Times for the Non- Standard ProductBy Pat Ryan, Pensions Manager, Canada Life

Page 5 IFSRA board Members

Page 6 Level Playing Pitch Favoured by IFSRA ChiefInterview with Dr. Liam O’Reilly

Page 8 Views from across the water - A Perfect Storm Stuart Holah of Fidelity Investments UK

Page 12 Annual Conference 2003

Page 16 Just when you thought it couldn’t get any worse.By Tony Gilhawley

Page 18 The Problem of Under-InsuranceBy Derek Fitzgerald

Page 20 Meet a PIBA Broker in a paperless office!PIBA broker Donald Moloney

Page 22 Death of a Saleman!By Tony Ball

Page 25 Updates for your Diary..

Page 26 Classifieds and Crossword Competition

Contents

The Professional Insurance Broker32 Greenmount Office Park, Harold’s Cross, Dublin 6w ● Tel: 01 4020250 ● Fax: 01 4736920 ● e-mail: [email protected] ● Website: www.piba.ie

Chief Executive: Diarmuid Kelly

Editorial Group: John Hogan, Paul Morris, Rachel Doyle, Tim Ryan Editor: John Hogan, Publisher: Tim Ryan Communications Tel: 01 6624649 Design: The Design Room Tel: 01 6617080

Views expressed by contributors or correspondents are not necessarily those of PIBA or the publisher and neither PIBA nor the publisher accept any responsibility for them.

PRSAs were introduced to help increase pension coverage and were intended tocomplement company schemes and other Pension arrangements. They were to beflexible, simple, a different product to meet differing customer needs.

However, in order to meet this or that objective or concern, conditions andrestrictions were added. Now IFSRA appears to be adding further requirements. Thenet result is that the target of increased pension coverage is unlikely to be achieved.whatever the arguments between Standard PRSAs and Non-Standard PRSAs. The realquestion is how to encourage a higher take up of pensions generally.

The experience of Defined Benefits schemes is worth looking at. The conditions arenow so onerous that virtually no new private sector DB schemes have been set up inrecent years.

Where an employee has never had a pension and where an employer is facilitating aparticular standard PRSA arrangement, then Brokers should be allowed to offer anon-advice Standard PRSA after the arrangement is set up. This is particularlyimportant at lower premium levels. Throughout their lives, customers’ needs willchange and they will require and, can hopefully afford, detailed advice.

In order to achieve the aim of increased pension coverage, consultation with Brokersshould take place to ensure a workable way forward.

Committee MembersTerry Hardiman ChairmanTommy Coyne Vice-ChairmanPeter Cox SecretaryGary Ellison TreasurerTony BallGeorge PorterPaul MorrisDan MurphyJohn HoganDerek FitzgeraldDonal AitkinsLiam Carberry

Sub-Committee ChairmenAgency – Terry HardimanGeneral – Derek FitzgeraldMortgages – Tommy CoyneLegislation – John HoganRegional Co-ordinator – Paul MorrisMagazine Editorial Board – John HoganDevelopment of Service Survey – Peter CoxTechnology – George PorterCompliance Research – Tony BallNetwork Sub-Committee – George Porter

Regional OfficersMid-West – Michael LeydenSouth – Dan MurphySouth-East – George PorterNorth East – Charlie GolloglyMidlands – Niall Lynch

Chief Executive: Diarmuid Kelly

The next issue of The Professional Insurance Broker will be published in October. For Advertising enquiries, please contact: 01-6624649. Yearly subscription (5 Issues) €30.

Growth Opportunities for the Broker MarketAn Irish Life conference for Independent Brokers, 23 June, 2003

Chaired by Willie Holmes and held in the hugely impressive surroundings of Croke Park, over 200 people heard anumber of speakers highlight the opportunities that exist for Brokers to build successful businesses based on experiencesfrom both home and abroad. The successful Broker business will be built on a strong technology strategy, which drivesefficiencies in the business and ensures more face time with the customer. The role and importance of compliance willbe to increase the level of professionalism in our industry.

The conference was rounded off with a popular and lively debate chaired by Economist and Journalist David McWilliamswith the panel comprising established and successful Brokers, Hannah Kiely of HC Group, Bryan Moloney of MMPI andTom Fitzgerald of Revoclife.

Connor O'Hara, Allied Pension TrusteesClive Reynolds, Ernst & Young Stephen McGrath, Mortgage Masters

David McWilliams, Bryan Moloney, Hannah Kiely,Tom Fitzgerald David Went, Willie Holmes

Joe Donnelly, P & C Financial Services, MichaelTynan, Heavey Insurances Ltd,

Tony Hill, P & C Financial Services

John Mellon, John Mellon InsurancesKaren Brown, Irish Life

Willie Holmes, General ManagerIrish Life Broker Services

Richard Morton, Moneywise Financial Planning John Hogan, John Hogan & Associates Tommy Coyne, Thomas Coyne Insurances

Hannah Kiely, H-C FinancialServices Group

David McWilliams chairing the debate

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It gave me great pleasure to be elected as your Chairman at ourAnnual General Meeting in May. At that meeting, I paid special tributeto the outgoing Chairperson, Aileen Cashman, for her immensecontribution during the last two years. I also paid special tribute to thetrojan work of the 2002/2003 Committee members. They all deserveyour special thanks.

We live in fast changing times, times of additional responsibilities as wecome to terms with the new compliance regulations. These newregulations seem to place a huge administrative burden on each andevery broker. Our attitude to these regulations going forward willdetermine our ultimate success. We can try and avoid these changesor we can confront them head–on and use them to our advantage.

My responsibility, together with the new Executive Committee andCEO, will be to ensure that help in understanding these regulations isavailable to every member. It is our intention, as far as possible, toprovide as much compliance help as will be necessary going forward.

Your PIBA Executive Committee has set up a Compliance ResearchSub–Committee and it has already been to the UK to study the modelthey have there.

Our industry in the UK is regulated by the UK Financial ServicesAuthority (FSA). Regulation has existed there in one form or othersince 1988. It is clear that regulation affects every element of thebusiness, the most interesting observation was that the UK FSA is onlynow setting about regulating the general insurance market. Speak toany IFA (Independent Financial Advisor ) and they will tell you howseriously their business has been affected by regulation. They also tellus that ignoring the issues, or hoping the impact of regulation on yourbusiness will be minimal, will not do.

The FSA in the UK is in the process of inviting comments on a newconsultation document aimed at making the market work forconsumers. Based on their research, they do not believe that themarket being polarised as it is in Ireland is delivering sufficientconsumer benefits to justify its continuing intervention in the market.As an example, their research shows that even with effective statusdisclosure as in Ireland, many consumers continue to use the tiedchannel whilst at the same time stating a preference in principle forindependent advice because it offers them an element of choice. Inpractice their choice of advisor is not driven by status but by trust.Regulators and the industry alike must make sense of this reality.

It is also clear in the UK that hand in hand with regulation, theintermediary costs have escalated out of proportion to earnings. Thecosts most affected were license fees, professional indemnity coverand compliance help. These fees are with us here and we should notallow these costs to get out of hand. We must be vigilant. The neteffect of these increased cost would be to drive the small to medium-sized broker out of the business of providing advised policies, thusdepriving the consumer of independent advice and rendering productssold directly without advice as seemingly better value.

We were told that UK society is woefully under-insured against theconsequences of death and long term disability. Maybe this means thatthe industry and regulators in the UK have become so engrossed in

the complexities of the industry that the basics have been overlooked,leaving consumers ill-protected against the risks they face or evenunaware of them. This could happen here in Ireland.

Finally, we will continue to monitor the progress of the UK consultationdocument.

Turning to our own regulatory authority, IFSRA, we recently attended ameeting with Mary O’Dea, Consumer Director and, at that meeting, sheconfirmed that the Authority was embarking on a review of the presentregulations. She will be issuing a discussion document in Septemberand we have agreed to forward our proposals for change before then.We would welcome any comments from our members in this regardby email over the next couple of weeks at [email protected].

Another perceived threat to our business is the huge rise in thedominance of banks and investment houses waiting to muscle in onour traditional role as insurance advisors. We must continuously remindourselves that they will never be able to offer the quality personalservice we do whilst at the same time ensure that they play on a samelevel playing field.

Another challenge for PIBA will be to continue to adapt and embracerapidly improving computer technology that can support us in advisingclients. Our clients now use computers to compare costs andalternatives to the products we sell. We need to stay ahead of them.

Turning to our association, I have identified areas that requireimprovement and my focus will be:

* to continue to professionalise our association by ensuring that wehave the resources to be active and effective on your behalf inrepresenting the various issues that arise.

* to strengthen our regional structures and promote regular regionalmeetings. This helps in two ways. Firstly, it acts as a channel ofinformation from Head Office and more importantly, Head Office getscoal face feedback that is important in formulating future strategies.

* to make PIBA a household name, not just to people in the industrybut to the public at large. It’s time that the public knew that PIBAmembers represent the best of the best and that PIBA membersshould be their primary source of information on insurance.

PIBA will continue to promote standards of excellence amongst ourmembers. Clients are going to want more qualified and not lessqualified advisors. I say to our young people: ‘Don’t put off qualificationuntil they are forced on you. Let’s gain qualifications in our own time.’

PIBA have endorsed the QFA Programme for Life Assurance and havebeen asked to endorse the Insurance Foundation Training course. It isour intention to promote a CPD programme for experienced long termpractitioners.

Finally, I challenge you to think and feel better about what you do daily.In return, I promise I will work to enhance PIBA as a worthy gatheringplace for all our members

Terry Hardiman, Chairman

Chairman’s RemarksTerry Hardiman

PRSAs are now with us for a few months and the majorProviders have brought suites of products to the market. SomeProviders have introduced only Standard PRSAs, one provideris offering only a Non – Standard product but the majority areoffering both Standard and Non-Standard PRSAs.So, as we advise employer clients on the pension accessobligations of 15 September 2003 and employees/selfemployed clients on the implications for pension planning inthe new PRSA environment – there are many new pensionproducts to evaluate, in addition to the existing product rangecovering occupational and personal pension options.

Additional Compliance

Furthermore, pension brokers are now regulated by the IrishFinancial Services Regulatory Authority (IFSRA) and this newregulatory body has now introduced additional presalerequirements, firstly in relation to all PRSAs and, secondly, inrelation to non- standard PRSAs.The IFSRA requirements may be summarised as follows:

1. Complete a client specific fact-find for each client. TheAuthority expects that the sale of a Non–Standard PRSA willrequire a more comprehensive fact-find than the sale of astandard PRSA.

2. Provide client with a copy of IFSRA’s two page PRSAexplanatory leaflet.

3. Provide client with a written statement of why relevant PRSAis considered to be in best interest of client (genericstatement may not be used). Where a Non-Standard PRSAis recommended, this statement must demonstrate why thenon- standard PRSA is more appropriate than a relevantstandard PRSA. Broker must retain copy of this statement.

Where a non-standard PRSA is recommended, both client andBroker must complete the Declaration below. Original of thisDeclaration must be retained on the client file.

For Pension Brokers, the IFSRA requirements clarify twoimportant issues.

Firstly, the concept of execution-only PRSAs is knocked on thehead. Therefore, when advising employer clients aboutPRSA/Occupational Scheme options, we need to consider thedemands of servicing occupational scheme business versusPRSAs in terms of employer/member meetings and we needto complete individual member fact finds and remunerationissues. The costs of providing services/advice need to befactored into the employer decision-making process.Secondly, Non-Standard PRSAs now effectively carry a ‘healthwarning’. As such, it may be useful to recap on the differencesbetween Standard and Non-Standard PRSAs and the reasonswhy most Providers have brought both product types to themarket place.

Standard and Non-Standard – The differences

The differences between the product types arise primarilyunder the following headings:

Employer Obligations/Employee Rights

* An employer who does not make occupational pensionscheme membership available to ‘excluded employees’must make at least one standard PRSA available via salarydeduction facilities and arrange for PRSAprovider/intermediary access to be made available.

* Employer must make a Standard PRSA available even if allemployees already have Non-Standard PRSAs in place.

* Employees have no access /salary deduction rights inrelation to any Non-Standard PRSA or any other standardPRSA other than that made available by Employer.

* For PAYE employees, paying PRSAs by payroll deduction willalways be more advantageous than paying by directdebit from a bank account due to at source PAYEand PRSI relief.

Investment Options

* A Standard PRSA can invest only in pooled fundsas prescribed by legislation.* A Non-Standard PRSA is not restricted to offeringpooled funds only and may therefore offer a widerinvestment choice.

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PRSAs – Challenging Times for the Non- Standard Product

By Pat Ryan,

Pensions Manager, Canada Life

Non Standard Personal Retirement Savings AccountDECLARATION SECTION A TO BE COMPLETED BY THE CONSUMER

* I declare that I understand that the charges payable on a non-standard PRSA may be higher than those for a standard PRSA.* I declare that I understand that the investment risks associated with non- standard PRSA may be higher than those for a standard PRSA* I declare that I understand that the Irish Financial Services Regulatory Authority recommends that consumers should seek independent

financial advice, before buying a non-standard PRSA.* I declare that I am satisfied that I require a pension product and that, having reviewed the differences between standard and non-

standard PRSAs, a non –standard PRSA is the most appropriate pension product for me.

Signed:_________________________________________________________________ Date:______________________________

SECTION B - TO BE COMPLETED BY THE VENDOR (WHETHER PRODUCT PRODUCER OR INTERMEDIARY)

* I declare that in my opinion it is in the best interests of the above named to purchase a non-standard PRSA rather than a standard PRSA.* I declare that in my opinion the non-standard PRSA I propose to sell to the above named is the product most suited to this consumer

from among all those I am able to advise on.* I declare that I have fully explained to this consumer the differences between this non- standard PRSA and Standard PRSA’s and, where

this is the case, focused on the fact that the charges are higher and the investment risks are greater for this non- standard PRSA.

Signed:_________________________________________________________________ Date:______________________________

Name of Firm:_______________________________________________ Position Held:____________________________________

Charges* All PRSAs can incorporate only two types of charges, a

charge on contributions and/or a charge per annum onPRSA assets.

* For Standard PRSAs, these charges are capped at 5% oncontributions and 1% p.a. on assets.

* For Non-Standard PRSAs, charges are not capped andtherefore, may exceed those applicable on Standard PRSAs.

Why Market Non Standard PRSAs?

Employer obligations/employer rights

* An Employer’s only interest in Non-Standard PRSAs is toallow employees a choice of standard or non standardoptions via salary deduction. If the same provider is used,there is no additional work for the employer and if the non-standard option acts to increase employee PRSA take-up,there are increased PRSI savings to be made.

Investment Options

As the IFSRA leaflet states: “The size of your fund at retirementwill depend on your contributions and the investmentperformance less the charges deducted. Investmentperformance cannot be predicted”. This is a very importantstatement. Unlike charges which can be clearly measured and,in a competitive market will be closely monitored, investmentperformance is usually the largest determining factor asregards overall pension performance. For example, the MercerGroup Pensions Managed Fund update at 31st May 2003shows the top fund over 10 years as producing an annualisedreturn of 10.7% per annum. The bottom fund in the 12 fundsurvey produced a return of 7.4% p.a. This means that€1,000 invested 10 years ago in the top fund producedinvestment growth of €1,764 over the period compared to again of only €1042 if invested in the bottom fund. The extragain here is 69% within the same category of funds. Whenone crosses investment categories, the differential increases.Hindsight is great and, as IFSRA points out, “investmentperformance cannot be predicted”. Also, clients have differentrisk tolerance levels. Some have a need for guarantees, othersrequire progressive investment outlets. Standard PRSAs only allowaccess to prescribed pooled investment funds. Non-StandardPRSAs are necessary to cater for wider investment options.

ChargesMost media focus on PRSA products is around the area ofcharges. In a perfect world, there would be no charges onPRSAs or on other pension products. However, in a perfectworld there would be no need for pensions or any investmentin the first place as all life’s requirements would be freely andreadily available to all. So, PRSAs contain charges to covercosts of investment, product maintenance, compliance,marketing, distribution and profit.

Because Standard PRSAs cap the charges a Provider can makeat any point in time and the manner in which the charges canbe designed, the Provider is restricted in the manner in whichcharges may be recouped to meet the product costs as theyarise. As such, the uncapped cost structure of the Non-Standard PRSA allows a product Provider greater flexibility inthe manner of recouping product costs. This enables greaterproduct innovation opportunities such as catering for morecapital intensive investment solutions and/or higherpersistency/long term value products, hence the marketing ofNon–Standard PRSA Products by the majority of PRSA Providers.

Non–Standard PRSAs – Best Advice issuesLet’s look at a potential situation where we are talking to aself-employed client or an employee whose employer ismaking both Standard and Non-Standard PRSAs available viasalary deduction.

The IFSRA Declaration above requires that both client andBroker address issues surrounding charges, investment risksand standard/non standard differences when a Non-StandardPRSA is recommended.

For example, in relation to Canada Life PRSA products, theissues could be addressed with regard to the following threeproduct types are marketed:

Standard PRSA – offering six investment funds, charges 5% oncontributions and 1% p.a. on assets

Advance PRSA – (Non-Standard) – offering same sixinvestment funds as a Standard PRSA plus five additionalfunds including Unitised With Profit Fund. Charges same asStandard PRSA except for additional charge on assets in respectof investments held in any of the five additional funds whichare not available on the Standard PRSA.

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Pensions Board Office

Premium PRSA (Non- Standard) offering the same 11 funds asthe advance PRSA. Charges – 50% on first year’s contributionand 3% on contributions thereafter. Annual Managementcharge of 1% on assets reducing to 0.5% p.a. after year eleven.Impact of charging structure is lower illustrative values forregular premiums than Standard PRSA for investment terms upto 15 years and higher illustrative values than Standard PRSAfor terms to retirement in excess of 15 years.

Issues to be addressed via IFSRARequirements

ChargesAdvance (Non-Standard) v. Standard PRSACharges are identical where Standard PRSA funds are selected.Charges are higher on Non-Standard product only if, and when,additional fund choices are selected.

Premium (Non-Standard) v. Standard PRSACharges are higher (additional charge of 45% of first year’scontribution) initially on Non Standard and cheaper thereafter,compared to Standard. Cheaper long term charges on Non-Standard work to clients benefit as fund increases and producehigher values where contributions are continued for at least 15years. Non-Standard funds are again available at a highermanagement charge where used.

Investment RiskNon-Standard v. Standard PRSAThe six funds including the Default Investment Strategy whichare available on the Standard PRSA are also available on bothNon–Standard products at the same price.

Both Non-Standard products also provide access to fiveadditional funds carrying additional annual managementcharges giving access to guarantees, additional fund managerchoice and specialist investment options.

If client remains within six standard funds, the investment risk issimilar on all products. However, higher or lower investmentrisk profile may be catered for on the non-standard products.

Differences between Standard and NonStandard PRSA Products

The differences are highlighted above under the headings ofCharges and Investment Risk.

The additional investment options available on both non-standard products provide client with greater investment choice.Client may control investment risk to same degree as standardproduct by staying within standard fund choice parameters butis empowered to reassess investment risk/reward in a widersphere, as required.

A choice of charging structures is available on the non-standard products. It is not available on Standard PRSA due tolegislative constraints. Factfind can identify preference for shortterm/long term value for money charging structures. Short-termcontract will provide identical values to Standard PRSA on samefunds. Long term, if selected, will provide better values on samefunds for terms of 15 years or more.

Conclusion

Non-Standard PRSA (either version) is recommendeddepending on value for money preference.The IFSRA leaflet describes higher charges as “just like a weighthandicap in a horse race – creating a need to produce a betterinvestment performance just to remain level with productscarrying lower charges”. The choice of Non-Standard chargingstructures allows you pick the course and distance of the horserace and pick the horse best weighted to suit those conditions.However, the added bonus in this horse race is that you canassess performance in running and switch horses throughoutthe race. The extra investment choices on the Non Standardproducts mean that you have 11 horses in the race running foryou rather than six. You may still not pick the winner but youare certainly shortening the odds in your favour!

Best Advice

The IFSRA requirements clarify the fact that PRSAs are advice-based products similar to other personal investment products.The additional compliance in respect of Non-Standard PRSA’s isindeed burdensome. However, it is important that as advisors,we do not fall into the trap of assuming that Standard PRSAsare always the best fit. Experience to date demonstrates thatthis is often not the case.

For most clients, the race to retirement is a long one. Clientslook to us, as professional advisers, to help them find the besthorses and the best horses are seldom found at the bottom ofthe handicap!

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IFSRA Board MembersThe Irish Financial Services Regulatory Authority (IFSRA) was established on 1 May. It is the new regulatorof all financial services firms in Ireland. The following were appointed Board members.

Brian Patterson

Brian Patterson is the Chairman of IFSRA. He isformer Chief Executive of Wedgwood (division ofWaterford Wedgwood plc) and former DirectorGeneral of the Irish Management Institute. He wasrecently appointed Chairman of The Irish Times Trust.

Alan Ashe

Alan Ashe was Managing Director of Standard LifeAssurance Company from 1998 – 2000. Previously hewas General Manager Finance of TSB Dublin. He is aFellow of the Chartered Institute of ManagementAccountants, a member of the Institute of Taxation anda former Chairman of the Irish Insurance Federation. Heis a former President of the Insurance Institute and aformer member of the Insurance Ombudsman’s Board.

Gerard Danaher

Gerard Danaher is a well-known Senior Counsel. Anative of West Limerick, he is a former member of theIndependent Radio & Television Commission (IRTC).He is the Honorary Consul for Croatia and is also aDirector of the Central Bank.

Friedhelm Danz

The German-born businessman is aformer Chairman and Chief Executive ofthe meat company, Agra Trading. He isalso a Director of the Central Bank.

John Dunne

John Dunne is Chairman of IDA Ireland, theinvestment agency responsible for the promotion ofForeign Direct Investment into Ireland since July 2000.He was formerly Director General of the Irish Businessand Employers Confederation (IBEC). He is a FulbrightScholar and was awarded an honorary Degree ofDoctor of Laws by the National University of Ireland.He is also a Director of the Central Bank.

Jim Farrell

Jim Farrell is Chief Executive of the NationalDevelopment Finance Agency (NDFA) whosefunction is to provide financial advice andfunding to State authorities for infrastructureprojects. He joined the National TreasuryManagement Agency (NTMA) as Director ofOperations in May 1991, having previouslyworked with Citibank.

Dermot Quigley

Dermot Quigley is the former Chairman ofthe Revenue Commissioners. During hiscareer with the Revenue Commissioners hewas responsible for spearheading theintroduction of a major computerisationprogramme.

Deirdre Purcell

Deirdre Purcell is a well-known novelist andjournalist. She is a member of the Councilof Credit Institutions' Ombudsman. She is aformer Newscaster with RTE. She is also aDirector of the Central Bank.

Dr. Liam O'Reilly

Dr. Liam O’Reilly is Chief Executive of IFSRA. He is also Director of the Central Bank. He was Assistant Director General of the Central Bank ofIreland since 1998, with responsibility for all of the Central Bank’s financial supervision functions. In that period, he oversaw significant changesin the supervision regime. Outside of this supervisory role, he has previously held the positions of Manager of the Central Bank’s FinancialControl & Settlements Department, Markets Department and International Relations Department. He is a member of the ECB BankingSupervision Committee, the EU Banking Advisory Committee, the Committee of European Securities Regulators and the InternationalOrganisation for Securities Commissioners. He was a member of the Review Group on Auditing, set up by the Tánaiste in 2000 and whichsubsequently led to the establishment of the Interim Board of the Irish Accountancy and Auditing Supervisory Authority, the regulatory boardfor auditors, of which he is a member. He holds an M.Sc. in Economics and Statistics and a Ph.D. in Econometrics from Trinity College Dublin.

Mary O'Dea

Mary O’Dea is Consumer Director with IFSRA. Most recently, she was Head of the Regulatory Enforcement and Development Department ofthe Central Bank where she was responsible for the coordination of policy across all of the Bank’s supervision departments. This included theintroduction of codes of conduct for banks and investment firms focussing on their dealings with their customers. Prior to this, she held anumber of positions in financial regulation areas including those as deputy head of the Banking Supervision Department and deputy head ofthe Securities and Exchanges Supervision Department. She started her career in the Central Bank as an Economist. Prior to joining the Bank in1987 she worked in the Department of Political Economy, UCD and in Bord Fáilte. Mary holds an MA in Economics and an MSc in Investmentand Treasury Management.

How do you see the future role for small brokers underthe new regulatory regime?

What we are finding in IFSRA is that yes, some people areleaving and moving out of the business but others are movingin. So, by and large, we have not seen any diminution at all inthe number of intermediaries. If they are doing the job and Ithink they have an important intermediary role to play and ifthey are doing it properly, I don’t see why they shouldn’t havea healthy future.

All PIBA members have to have at least five agencies.Do you think that brokers should generally have arange of products rather than be tied agents?

We have basically broken down the category of intermediaryinto two broad areas – Multi Agency Intermediaries andAuthorised Advisers. They key is that the customerunderstands whom he/she is dealing with and is fully aware ofthe status of the intermediary. To that extent, it is notimportant to us whether a broker has a range of agencies or istied to one single product producer as long as the customerunderstands that and it is clearly spelt out. In general, we thinkit is good that there are a range of service providers in themarketplace because this creates competition and gives theconsumer choice.

Under the new regulatory regime, MAIs are required togive professional advice to clients on products acrossall their agencies. Yet recently IFSRA described MAIs,who account for the vast majority of brokers as,product salesmen and if clients needed investmentadvice they should go to an AA? Is this not somethingof a contradiction?

I’d like to think that we would not use the phrase “productsalesmen” as their role is somewhat broader than that andthey are, of course, expected to give the best advice even ifthe advice is limited. However, their job is to sell insuranceproducts to the consumer and in that sense they are selling.But they are dealing with financial products so there is extraresponsibility, much more so than in the shop where you areselling, let’s say, electrical goods. They have to be professionalenough to understand the product and to sell it to theconsumer. What I would say is there is a specific differencebetween the Multi-agency Intermediary and the AuthorisedAdviser. In terms of their job, I would say it is to ensure thatthe customer is looked after, that the customer knows withwhom he/she is dealing. They are also responsible for makingsure the product fits the customer’s needs.

It is generally known that the sale of PRSAs has been

very slow to date. Do you believe that the IFSRAregulations are acting as a roadblock to sales and haveyou any plans to ease the requirements?

I would hope the regulations have not been a roadblock. Webelieve PRSAs are an important extra element and an extraservice for consumers. All new products are, by definition, anaddition to consumer choice. What we are worried about inrelation to PRSAs is not necessarily the standard ones where itis very clear what they are promising but we want to makesure that the non-standard products are explained properly. Wehave had an example over the past few years of endowmentmortgages where customers did not know what they weregetting into. They are finding that the amount of money theyare expecting to be there will not in fact be realised. I think it isvery important that they explain fully to the consumer, in theconsumer’s interest and in the interest of the intermediariesthemselves, what to expect so that it is not a surprise at theend. What was wrong with endowment mortgages was notthat they were sold but that the consumer might have beenmisled as to what they were buying. What we want to do isavoid a repeat situation with the more complex PRSAs. Wehave less problems with the standard ones. I think theregulations are reasonable.

Solicitors and accountants are exempt from IFSRAregulations, including an audit, if less than 20% of theirturnover comes from insurance business, yet 20% of anaccountant’s turnover is likely to be much larger thanthat of many brokers. Is this fair?

We are currently building up a profile of the industry as awhole. We are carrying out a complete review across the entirefinancial services industry to try and ensure that we put inplace a system that will lead to a level playing field for allthose involved. However, one of the things we have to take onboard is what the legislation says and in this regard there is alarge amount of self-regulation within sectors such as solicitorsand accountants and they are excluded from our regulation inso far as their investment business is incidental to their mainbusiness. Within the limits of the law and, in so far as possible,we do want to ensure that there is a level playing field and wewill pursue that.

At present, all brokers are required to have an audit,even if they are sole traders and do not handle clientcash. Would you support in principle exempting lowerincome brokers or do you think everybody should havean audit?

If you are a financial institution then I think you have to havean audit of some kind but I would be very cognisant of the

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Level Playing Pitch Favoured by IFSRA ChiefIFSRA Chief Executive Dr. Liam O’Reilly wants to see a level playing pitch inthe selling of financial products by intermediaries, financial institutions andother professionals. He spoke to Tim Ryan.

Dr. Liam O’Reilly

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fact that the level of the audit and what’s being asked for mustbe commensurate with the size of the business. Certainly,within the bounds of control, I would be very sympathetic tobigger firms having far more comprehensive audits than smallfirms. It would be unreasonable to ask one or two personoperations to have a very comprehensive audit carried out. Italso depends on whether you carry or don’t carry cash. That isan important distinction. If you are carrying cash on behalf ofcustomers, then I think it’s very important to ensure it ishandled properly. Client money audits are a very sensibleprocess to ensure full accountability.

Do you think the publication by IFSRA of a notice ofcessation of trading by a broker in one business canhave an adverse effect on his or her other business?Some brokers claim it has affected their business.

Again there are regulations here that require that we arenotified when a firm becomes authorised or de-authorised. Wehave to keep a register to be able to tell the public out there ifsomebody is authorised or not. But I would be very flexible inensuring it’s quite clear in the advertisement what it is aboutso that we don’t damage anybody. If the industry has anyideas as to how we might do that, then we are open to them.If we can come up with a proposal that keeps them in theremainder of their business and gets across that they are notin the intermediary business, I would be happy to look at it.

Many insurance companies are ending agreements withbrokers who do not write a set level of business withthem even though the company may have dramaticallyraised its premiums. Isn’t that inconsistent with brokersbeing obliged to offer the best and most cost effectiveproduct to clients?

I will make a general comment. Anything that wouldundermine the Intermediary’s role in giving proper advicewould be a worry to me. I would have the same problem withcommissions. If commissions are such that they are forcingintermediaries to provide products to customers that might notnecessarily suit them, then I would be worried about it. Whatyou are saying could be construed as a disincentive to dealwith customers in a fair way.

Do you have the power to intervene in such asituation?

Let’s put it this way. If PIBA or the industry came to us andsaid there was a disincentive here to deal with customersproperly, I would be prepared to listen to it. If I felt theinsurance companies were dealing with intermediaries in amanner that would force them to oversell to the consumer orto provide “unsuitable” products, I would want to know about

it. However, I would like to see the case first. The broker wouldhave to prove to me that he or she lost the agency becausethey were being forced to sell unsuitable products. I wouldhave to have chapter and verse to confirm that there was adirect connection between not reaching the target and if theyhad reached the target they would have been forced to sellunsuitable products to consumers while there were morecompetitive products in the marketplace. To date, I have notseen any firsthand complaint of this nature.

PIBA has expressed some concerns about inspectorsand their methods of inspection. What qualifications orexperience of the insurance industry do inspectorshave?

As regards the inspectors, first of all, while they are not obligedto give notice of inspections, they generally do. Not alone that,but the Codes were introduced last year and we gave theindustry a long period to settle down. Rome was not built in aday and what we are all trying to do is to set standards so thatcustomers can get a better deal. We think that is the long-termbest interest of both intermediaries and the public.Our inspectors like a good night’s sleep as well so I don’t thinkthere is much danger of a midnight inspection!Generally the people on the inspection teams have two levelsof background. Firstly, they are generally accountants. They arehighly qualified and, on top of that, over the last few years wehave encouraged staff to undertake the insuranceexaminations so that they are familiar with the industry. Notalone that, but we have been doing a lot of work ourselves,going around the country hosting seminars in which we triedto tell the industry what we are about.If we look at a file, one of the things we check is to ensure thecustomer has signed off to the effect that the product issuitable for them and that the whole thing has been explainedproperly to them by the intermediary. If the customer has notsigned off, the whole thing is invalid. That sort of paperworkneeds to be checked. It might have been an issue in the pastthat the paperwork was not absolutely right. But we are alllearning here and we are giving time for the industry to pickup, as we learn ourselves. Nobody has the final corner ofwisdom in all of this. We are reasonable people and if thereare reasonable explanations for a problem, we are willing tolisten. We are not a closed institution! Finally, could I say wehave been going through a period of change within theindustry. We understand the anxiety that intermediaries mightfeel as a result of this change, as a result of higher standardsbeing introduced but I think we will get there if we all worktogether. At the end of the day, all we are trying to do is toensure that the customer gets the best deal. That’s ourobjective and it should be the intermediaries’ objective too.

In the movie of the same name, a meteorologist tracks theconvergence of a hurricane, an extreme low-pressure front andthe jet stream, and chillingly predicts “This could be a disaster,this is the perfect storm”. Our industry is about to be rocked byits own perfect storm. We face three powerful and converginginfluences. It’s an unprecedented combination and the impactwill be destabilising and difficult to predict. The first of theseinfluences is N2*, which although it is already upon us, is yetto make its full impact felt as the advice sector accommodateschange. The second force is the FSA’s* CP121* consultationand the certain end to the current polarised market structure.And the third powerful factor is the coming slew of furtherindustry reviews including Sandler, with-profits, pensions anddisclosure.Of these tumultuous forces, depolarisation is the one thatshould demand immediate continued attention from all of us.We know many advisers see CP121 as old news and there’s asense of depolarisation fatigue. However, there are very realchoices to be made.

Choose your direction

Depolarisation* represents the most fundamental industry shiftin 15 years. Welcome or not, the proposals within CP121herald a sudden transformation. We are faced by a profoundshake-up in the market for advice. And if this soundscataclysmic, we don’t believe it will necessarily lead to disaster.Change also brings opportunity. The fact that there are stillcomplex and unresolved issues means it is impossible toreliably predict a single outcome, so the temptation can be notto think about it. However, we think it is not only possible, butessential, for advisers to plan their strategy now. Even fromcurrent outline proposals, it is possible to anticipate a range ofoutcomes and consider what an adviser might do under eachpotential scenario. In the remainder of this article, we aim toexplore some of the factors affecting this choice. I mustchoose my words carefully; firstly because it is not my place totell any adviser what to do with their business, and secondlybecause Fidelity doesn’t have an axe to grind. We don’t regardany one option as superior and it’s a classic case of ‘horses forcourses’. However you look at it, it seems to boil down tothree main choices: tie, become fee-based, or stay as you are.

1. Multi-tiesThe question of whether to multi-tie is a divisive issueamongst IFAs*. The decision represents a trade-off between

likely commercial benefits and any potential compromises inthe practice business model. The primary commercial appeal isthe prospect of capital investment, ‘soft’ loans, and the widelyexpected volume-override commissions, assuming of coursethat the Best Advice principle is modified -which is not certain.Cash is not the only advantage to a multi-tied adviser andfurther benefits may come from simplification of businessprocesses across fewer providers. For some advisers theserewards will be compelling and research suggests 5%-15% ofadvisers are considering this option. Amongst IFAs opposed tomulti-ties, a recurring theme we hear is that multi-ties wouldentail a loss of autonomy and business control. One adviserput it very succinctly by saying: “I considered how I would feelwhen my multi-tie firm inevitably appointed a regionaldevelopment manager to ‘help’ me manage my practice. Iwoke up from a pleasant dream“. There are other issues toconsider and many seem less clear cut. We’ve heard itsaid by some advisers that a multi-tie is little different to aproduct ‘panel’, especially since provider consolidation andother commercial pressures are narrowing panels anyway. Thisview could be quite misleading since it is relatively easy tomove providers on and off panel, but it will prove moredifficult to change multi-ties when these are contractuallyformalised with notice periods and financial issues to consider.More fundamentally, CP121 does not clarify whether a multi-tied adviser is an ‘agent’ of a Provider or, as for IFAs, an ‘agent’of the client. Some advisers believe they can only trulyrepresent clients’ best interests if they retain this legal basis ofagency. This brings us to the crux of the debate: how wouldclients respond to the change? There are challenges toovercome in convincing customers to accept multi-tie status,particularly amongst older and more affluent clients. IFAs maybe victims of their own success, since they spent 15 yearsdemonstrating the virtues of independence to clients who maynot now accept an alternative.

2. Fee-based adviceIn deciding whether a fee-based strategy is right for theirpractice, many IFAs will already be familiar with the arguments.Advantages include a generally higher revenue, more flexibleproduct selection and, increasingly in the future, a moresupportive media backdrop. In addition, US evidence showsfee-based firms consistently achieve higher valuation multipleswhen they are sold. However, this must be weighed againstthe transitional cash flow challenge, since it takes time for

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Views from across the waterA Perfect Storm

Financial intermediaries in the UK have experienced major reform of theregulatory environment. Here Stuart Holah of Fidelity Investments UK,looks at some challenges facing UK brokers. (Please refer to the explanatory notes at the end of the article-ed.).

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accrued fees to offset the loss of commission. Typical adviserexperience shows this takes from two to three years, though itcan be done more quickly depending on a firm’s starting point.In addition, some clients have an aversion to paying fees, sothere will be an inevitable customer loss. There’s also evidencefrom the UK and US that transition accelerates when adviserscreate a new overall package of services, as well as changingthe practice payment method. This isn’t a negative, but it addsto the challenge. The established fee-based financial planningmarket in the US may hold some instructive lessons. The shifttowards fees in the US was commercially, not legislatively,driven and reflected growing adviser emphasis on complexholistic planning. Today, over $1.7 trillion of assets are underfee-based management and it’s not feasible to be an adviserwithout a fee-based offering. However, such services haven’teliminated commission, which is still the majority paymentmethod. Consequently, most advisers have parallelcommission propositions, especially for smaller clients whodon’t fit the fees model.

Fee models

As in the UK, there are four main fee types in the US: assetbased fees, annual retainers, hourly rates and ‘service-based’fees. Asset based fees are typically 1% p.a., reducing in tiersfor larger portfolios. Retainers are another common model andtake account of a client’s income and total net worth. A typicalretainer might be $6,000 in year one, dropping down to$1,500 from year two once the relationship is established. Foradvisers charging hourly fees, $150 an hour is not atypical butthis rises to $400 for sophisticated tax and trust work. Lesscommon are firms with an activity-based menu where clientspay to establish their financial plan (say $2,500) and payseparately for subsequent reviews (at, say, $750 each) as theyrequire them. Finally, with all models, it’s common forcommission to be offset against fees. Research from USresearcher Cerulli Associates suggests advisers move to fees inthree distinct phases. The first phase is called “latency“ whenfee-based work simply reflects natural client demand. This iswhere most UK firms are today generating less than 20% oftheir income from fees. Phase two is “revival“ and typicallyoccurs when the share of revenues from fees reaches 20%and advisers recognise that commission-based businessbecause clients are wealthier, more loyal and provide betterreferrals. Not surprisingly, this sparks a further pursuit of fee-based business. The third “epidemic“ phase starts whenaround 40% of adviser revenues come from fees and advisersstart to find it easier to convert almost completely to a fee-based practice.

Migrating to feesIn the US, as in the UK, advisers migrating to fees share somerecurring themes. Most advisers target their wealthier clientsand ‘downscale’ their business, ending up with fewer clients ofhigher average net worth -around 80-150 clients is typical inthe US. Many firms also evolve their overall proposition,becoming more specialised in areas such as wealthmanagement or estate planning. Naturally, this transitiondemands a great deal of effort and commitment.Implementation may involve new adviser compensationmodels, billing systems, staff training and possibly a newcorporate identity. Many fee-based advisers tell us the momentof truth comes when they communicate their changed statusto clients. Many customers feel they received this level ofservice “free“ for many years and for some it is not astraightforward discussion. This isn’t to say clients thought theirIFA was a charity worker, they simply paid less attentionbecause they didn’t write a separate cheque. As you mightexpect, client willingness to pay fees increases with clientincome, but decreases with age. A common experience for alladvisers who become fee-based is that some clients leavethem but, both in the UK and US, most advisers are pleasantlysurprised by the number that don’t.

3. *AFA: stay as you are

Of the proposed CP121 options, many IFAs think the *AFAroute is the easiest and in the near term, this seems true.Besides some stationary changes and explaining your revisedstatus to customers, the biggest challenge may be what to callyourself if “Independent“ is off limits. Our research, forinstance, found investors preferred functional alternatives suchas “Registered” or “Chartered” to the FSA’s proposed“Authorised Financial Adviser” description.

But there’s more to staying commission-based than a simplechange of name. Retaining a completely unchanged businessmodel is seldom a sustainable long-term option in any sector.Our industry isn’t standing still and all markets evolve. CP121will unleash what economists call a “market shock“ and manyindustry participants will seize new ideas and abandon oldones. It will unquestionably bring new competitive dynamicsinto play, aided by technological change and shifting consumerpreference. Don’t assume there’s a ‘business as usual’ option -there are advantages in looking for new ideas andopportunities. remains highly popular with investors and forthis reason we anticipate that the commission-based sectorwill thrive. One factor that will further help advisers is the likelychanges to relationships between advisers and product

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providers. A positive aspect of CP121 is the bold stance theFSA seems prepared to take on the nature ofadviser/provider ‘partnerships’. The most widely discussed ofthese is whether providers might buy stakes in adviser firms,but both sides seem unclear about what benefits wouldaccrue to providers when an adviser retained unfetteredproduct choice across the market. Such stakes may makesense as a pure ‘investment’ but the illiquidity of the advisersector could make this particularly challenging given the sizeof a typical adviser firm.

Provider support

We believe there is more immediate promise in the CP121proposal to overhaul the ‘indirect benefit’ rules limitingProvider support for advisers. To illustrate what mightbecome possible under a different UK regime, Fidelityalready provides a ‘Practice Advantage’ service to USadvisers, though we have no immediate plans to launch thisin the UK. This IFA support programme includes marketingconsultancy, lead generation, compliance support,preferential PI rates and technology support. Services aredesigned to assist advisers in growing and managing theirbusiness and are provided at discounted rates or free ofcharge. The ‘catch’ - if it can be described as such - is thatIFAs must use our trading and custody services such asFundsNetwork. There’s no requirement to invest in Fidelity’sfunds. We benefit from IFA success by growing assets underour custody, and advisers benefit in exactly the same way.None of this is currently feasible in the UK. But if IndirectBenefit rules are relaxed, we’d be able to conceive a middleground where we can match some of the commercialupsides on offer in the tied sector, but without the loss ofadviser autonomy that may come with a multi-tie. In short, itwould be possible to think far more creatively aboutpartnerships with advisers.

In conclusion

Whilst CP121 still has very obvious flaws where the IFAsector is concerned, we believe it is possible for advisers tostart to consider their future choices. Despite the industryrumours that will no doubt emerge in coming months, webelieve no one business option is dominant, or doomed. Asin other markets, different adviser business models will co-exist successfully. The important decision for advisers will beto make the choice that’s most appropriate to them, theirpractice, and their clients.

Notes: *FSA: Financial Services Authority ( www.fsa.gov.uk)*IFA: Independent Financial Adviser

Independent Financial Advisers (IFAs) are able torecommend products from the whole range available.

*N2: Financial Regulatory Reform date November 2001*CP121:Consultation Paper 121

The FSA's Consultation paper 121 is entitled 'ReformingPolarisation: Making the market work for consumers'. Itwas published in January 2002 and the period forconsultation responses closed on 19 April 2002.

*AFA: Authorised Financial Adviser Authorised Financial Advisers (AFAs) are able torecommend products from one or a group of productprovider(s).

*Depolarisation:The abolition of polarisation (i.e. being a "tied agent"). Theproposal to abolish polarisation: D2 Polarisation restricts product and provider choice in thetied sector. CP121 suggested that the abolition ofpolarisation might have four major beneficial effects, so faras this sector is concerned:

A. Consumers in the tied sector will get an increased choiceif providers fill the gaps in their product ranges withdifferent types of products they do not manufacture,making it more likely that consumers will get suitableproducts.

B. They will also benefit from a wider choice if providersintroduce several choices of the same type of product.This makes it more likely that consumers will get suitableproducts (no longer one-size fits all) and will introduce anelement of provider competition within the tied sector.

C. They will get better value products if providers substituteor include better value products of other providers insteadof, or alongside, their own brands.

D. In the longer term, there may be cost efficiency savingsthrough increased specialisation and through increasedcompetition between providers in a multi-tied sectorcompared to a tied sector (potentially offset by anyreduced competition through consolidation). There mayalso be increased competitive pressure on theindependent sector.

The editor wishes to sincerely thank Geoffrey Tait andAndrew Berwick of Fidelity Investments UK for theirhelp with the above article.

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Tom Shanley and Mary Brennan.

Aeveen Kiernan and John Millett, PIBA Committee

Charlie Gollogly, Pauline Callaghan, Ollie Callaghan and Bartley Landy.

Rachel Doyle and Triona Clancy, PIBA Head Office

2003 Agm And Annual Conference A Major Success!There was a large turnout of PIBA members and guests at this year’sAGM and Annual Conference in the Ardilaun Hotel, Galway on Friday,May 9. The efforts of a hard-working committee were evident in thesmooth running of the event which it was agreed was a major success

Speaking on behalf of Friends First who sponsored the Conference,General Manager - Retail, Tom McCormack said the company hadrecognised for some time the success of PIBA in representingbrokers in this competitive market.

Friends First used the occasion of the Annual Conference to sign anew Agency Agreement with PIBA.

“This agreement is a prerequisite to doing business with PIBAmembers and will be an essential ingredient in any futurepartnership with PIBA,” he said. “We very much welcome the newera between PIBA and Friends First and I am confident that brokerswill be well placed to provide best advice to clients with the supportof Friends First.”

The Conference was officially opened by the Minister of State at theDepartment of Enterprise, Trade and Employment, Frank Fahey TD.Speakers included PIBA Chairman, Terry Hardiman, Jim Power, ChiefEconomist, Friends First, John O’Dwyer, Chief Executive, Friends First,Tony Gilhawley, Insurance Expert and solicitor Kevin Brophy.

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Adrian Daly, Advisor Plus, Councillor Terry O'Flaherty, Mayor of Galway and John Hogan, Chairman PIBA Legislation Committee.

Terry Hardiman, PIBA Chairmanaddressing the Conference.

Breffni May and Anita May.

George Porter, PIBA Committe, Olive Porter and Vincent Clavey.

Kevin Brophy, PIBA Solicitor, John O’Dwyer, Friends First and Tony Gilhawey, Technical Guidance Ltd.Michael Fleming, Tony Ball PIBA Committe and

Derek Fitzgerald PIBA Committe.

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Annual Conference 2003

Terry Hardiman, PIBA Chairman and John O’Dwyer CEO Friends First.

Jarlath Jordan, Galway City,John O’Dwyer, CEO Friends

First, Anne Hession, Oranmoreand Tom Campbell, Ballinasloe

John Carew, Clonmel,Jim Power,

Chief Economist, Friends First and

Richard Crowe, Tipperary

Gary Ellison, PIBA Treasurer, Minister of State Frank Fahey TD, Anne Hession, Oranmore and Paul Morris, PIBA Regional Co-ordinator

PIBA Committee(Back L to R) George Porter, Paul Morris, Dan Murphy (Middle) John Hogan, Liam Carberry, Derek

Fitzgerald, Donal Atkins, Tony Ball (Front) Gary Ellison (Treasurer), Terry Hardiman (Chairman), Peter Cox (Secretary), Tommy Coyne (Vice Chairman), Diarmuid Kelly (CEO)

Bill Murphy, New Ross, Jim Power, Friends First and Patsy Callaghan, Wexford.

Pat O’Sullivan, Salthill,Brendan James, Galway,

Ted Cleary, Loughrea andNoel O’Brien, Mountbellow

Photographs: by Stan Shields and Michael Dillon

I’m sure you feel at this stage that you have all the regulationyou can handle. Well, I’m sorry to be the one to break the badnews ...there’s lot more on the way!

One provision, in particular, related to auditing, could have asignificant regulatory impact on intermediaries.

Auditing

Currently all intermediaries regulated under the InvestmentIntermediaries Act, 1995 must be audited and provide annualaudited accounts to IFSRA.This seems somewhat harsh as :* the vast majority of intermediaries, being MAIs and AAs, are

not authorised to handle client monies in any event, exceptfor insurance premiums in circumstances where the insureris responsible for the money.

* the auditing requirement applies to sole traders andunincorporated intermediaries who would not otherwise berequired to be audited.

* intermediaries who are trading as companies cannot avail ofthe audit exemption afforded to small companies generally.Small companies with a turnover less than €317k pa can,under the Companies’ (Amendment) Act, (No 2), 1999,avail of an exemption from the requirement to be audited.However, this exemption is specifically denied tointermediary firms regulated under the InvestmentIntermediaries Act, 1995.

Companies (Auditing & Accounting)Bill 2003

This Bill is currently going through the Dail. It deals with a lotof issues related to auditing and corporate compliance.The Bill proposes that directors of companies subject to auditwould be required to prepare a Director’s ComplianceStatement in writing which must set out :

(a) its policy in relation to compliance with company and taxlaw and other relevant legislation;

(b) the procedures which it has put in place within thecompany to ensure compliance with these obligations and

(c) the arrangements for implementing and reviewing theeffectiveness of these policies and procedures.

The Directors in their annual accounts must include a director’sstatement to :* acknowledge that they are responsible for the company

complying with company and tax law, etc.* confirm that the company has internal procedures in place

to ensure compliance with company and tax law, etc, and ifnot why not,

* confirm that the directors have reviewed the ‘effectiveness’of internal procedures to ensure compliance with companyand tax law, etc.,

* confirm that the directors have used ‘all reasonableendeavours’ to ensure the company complied withcompany and tax law in the financial year in question, and

* confirm that the company has complied with all companyand tax law in the financial year in question, and if not whynot.

The Directors of the company have to review and revise, ifnecessary, the Directors Compliance Statement at least everythree years.

The company’s auditor must conduct an annual review of theDirectors’ Compliance Statement and the associated director’sstatement and report in their audit their view as to whether ornot the company and the directors have complied. The auditormust report to the Director of Corporate Enforcement if, inhis/her opinion, the company and the directors have failed tocomply with company and tax law and with their Directors’Compliance Statement.

The Directors’ Compliance Statement and all that goes with itwill not apply to small private companies which can currentlyavail of the exemption to be audited, i.e. with a turnover lessthan €317k pa. However, as pointed out already, intermediarycompanies regulated under the Investment Intermediaries Actcan not avail of the audit exemption and so will be required tocomply with the Directors’ Compliance Statement.

But as the Bill stands currently, the Directors ComplianceStatement wouldn’t apply to sole traders and unincorporatedintermediaries, as they are not companies.

Central Bank and Financial ServicesAuthority of Ireland (No 2) Bill, 2003

This Bill is expected to be published in the autumn but the‘heads’ of the Bill have already been published.The draft Bill proposes to :* extend the Directors’ Compliance Statement to all

intermediaries regulated under the InvestmentIntermediaries Act, i.e. to include sole traders andpartnerships.

* extend the scope of the Directors Compliance Statement for

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Just when you thought it couldn’t get any worse...

By Tony Gilhawley

intermediaries to include compliance with all IFSRAlegislation, Codes of Conduct, regulations, guidance etc.

* require a copy of the Directors Compliance Statement to besent to IFSRA

* require the intermediary’s auditor to submit a copy ofhis/her report in relation to compliance with the Directors’Compliance Statement to IFSRA.

What does all of this mean?

If the two Bills go through as currently drafted :* all intermediaries, be they companies or unincorporated

entities, will be required to be audited annually.* all intermediaries including sole traders and partnerships,

unless specifically exempted by IFSRA, will have to prepare aCompliance Statement setting out policies and procedures,in relation to compliance with company law, tax law, andIFSRA related legislation, guidance, codes of conduct andregulations. In addition, the Directors will have to reportannually on their compliance procedures etc, during thatfinancial year.

For example, the Compliance Statement may have to dealwith the procedures the intermediary has in place to ensurecompliance with the ‘suitability’ requirement of the Code ofConduct for any product recommended to a client.* the intermediary’s auditor will be required to report annually

on the Compliance Statement and associated directors’statement, both in the company’s account and to IFSRA.

The auditor may therefore have to review productrecommendations made by the intermediary during the

financial year to see if such recommendations fit in with theintermediary’s Compliance Statement and stated procedures. The intermediary’s auditor will therefore be reviewing allaspects of the intermediary’s compliance with IFSRA legislationand Codes of Conduct etc, in addition to compliance withcompany and tax law generally.

In this respect the annual audit will become akin to a site visitby IFSRA; anything untoward the auditor finds will find its wayback to the Director of Corporate Enforcement (forcompanies) and to IFSRA.

A sledgehammer

Clearly the Director’s Compliance Statement and auditor’sreport on same is a sledgehammer to crack a nut whenapplied to small non cash handling intermediaries.What would make sense would be:* allow intermediary firms who are non cash handlers to

benefit from the same exemption from audit as currentlyapplies to all other companies if they meet the samerequirements, i.e. current turnover less then €317k.

* exempt sole traders and partnership intermediaries who arenon cash handlers from the requirement to be audited,provided they meet the same requirements as apply tocompanies exempted from audit.

* any intermediary exempted from audit should also, as aconsequence, be exempted from the Director’s ComplianceStatement requirement.

But what makes sense and what gets put into legislation arefrequently two different things!

Tony Gilhawley F.I.A. is Director of Technical Guidance Ltd

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The past five years have seen a huge rise in house prices,most notably in the Dublin region. The Celtic Tiger economybrought an overnight unexpected windfall for most peoplewho were lucky to own their own home and today they havea major asset behind them which can be used, if necessary, toget them over a lean period.

However, one of the downsides of the rapid growth in houseprices is the severe shortfall in keeping pace with insurancepremiums. As a result, there is now a degree of under-insurance of homes throughout the country, with consequentmajor implications for the unlucky few who will have to makea claim due to fire or other cause of major structural damage.

I am a partner in a Dublin centre mixed brokerage. Five yearsago, the average cost of house insurance was somewherebetween £80 and £150 (€101 - €190), depending on thesize. Today, the same premiums range from €250 to €550, a250% increase.

Understandably, many householders find the reasons for therise difficult to understand. In my view 9/11, even thoughgenerally cited as the reason for almost everything, includingthe rain, had nothing to do with it. The reason is largely due tokeeping pace with the rate of house inflation.

What people do not realise is that there is a finite amount ofmoney available in the event of fire and when this isexceeded, the “average clause” kicks in. The customer getscompensated to the value of the amount insured and paysthe remainder himself.

What brokers need to point out to clients when explaining thereasons for a relatively high premium is that the insurancedoes not cover just the cost of replacing the building. It alsoprovides for fire brigade charges, demolition (with skips costing€300 each in Dublin, this can be a substantial cost),alternative accommodation for a period of time, architect’s

fees, loss adjustor’s fees, planning permission and so on.When added together, these items can come to a substantialfigure and have to be borne in the overall figure. Theaftermath of a fire is an expensive time for householders apartfrom the major trauma suffered. Bills just pile up!

As a rule of thumb, I urge clients to find out the squarefootage of their house and multiply by €190. Thus, an averagefamily home measuring 1200 square feet will cost €228,000to rebuild. The cost might be a little less for a terraced houseand a bit more for a large detached house. Of course, thecosts in Dublin are higher than elsewhere and allowances aremade for this.

Then there is the question of house contents. Here, again themajority of householders are under-insured. The simplemethod I use is to ask the householder to take a pen andpaper and go round the house noting the replacement cost ofeach item. Computers and their accessories alone can cometo thousands of euro not to mention the housewife’swardrobe and jewellery! As households are usually collectedover a period of years, most people are completely unaware

of the cost of replacement when it comes to insurance.

In an ideal broker’s world, everybody would have an averagehouse insurance to the value of €228,000 and contents tothe value of €50,000. However, the premium to cover thatamount is around €600 and very often people do notmake provision for that sort of figure. Mortgages and othermore immediate demands take precedence.

Insurance is not, by its nature, an exact science. But asresponsible brokers, we must urge our clients at all timesto take inflation into account. Most companies todayprovide for payment over a six month or longer period oftime. This costs more but is often the only course opento a client..

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The Problem of Under-Insurance By Derek Fitzgerald

Personal Experience!

Personal experience counts for a lot in this matter as recently we a had a

fire in an adjoining office to ourselves in central Dublin. That all our staff

got out safely is thanks to the Almighty. The damage caused by smoke and

water was considerable. The vast majority of our files in the open plan

office smell like kippers! Even though no flames reached our offices, there

was a lot of damage to equipment and furnishings.

The fire brigade sent the landlord a bill for €2,100 for the use of three

tenders at €500 each and one ‘special’ at €600. Even working closely

with our insurers, it will take weeks before we are back to normal.

Like it or not, insurance brokers have had to cope with a hugeinflux of technology over the past few years. On-lineapplication forms, list checks, background information and soon are just part of the daily diet of a modern-day broker.Increasingly, the successful broker is the one who can grasptechnology successfully and adapt it to make his or her officemore efficient and customer-focused.

Donald Moloney is an MAI operating a busy office atNorthampton, outside Kinvara, Co. Galway. Having worked hisway up through sales in NZI Life, Woodchester and later asSenior Branch Manager in Acorn Life in Galway, he opened hisown office in 1998.

His first office was a room in his home but today he has threeother outlets based in Portumna, New Inn and Moycullen.

Not being particularly fond of the area of administration, hedecided there must be another way. Eamonn Keaney inCanada Life was the first person Donald approached when hewent into brokerage.

“Eamonn gave me very good advice to get myadministration set-up right the first day before I went sellinganything and it would stand to me over time. I took that toheart as I was hoping to expand. How we handledadministration was going to be vital. I looked at what wason the market and nobody seemed to have an adequateadministration product for brokers at the time.”

Eventually, he sat down with the Galway-based TitanConsultancy and asked them could they develop a system thatwould grow and expand with the business. We opted to scaneverything as I was conscious of the Consumers Affairs Actand other legislation that requires information to be heldreadily available for clients.

“My first office was very small,” he recalls, “and I basicallydid not have enough space for files and filing cabinets! Westarted scanning! The procedure is quite simple. When thepostman comes in the morning any relevantdocumentation is scanned into the system and filed in theappropriate place. That information is there and readilyaccessible forever. Anything that should be sent on isscanned and sent on electronically.”

Wherever possible, applications are always sent electronically.He particularly commends Irish Life and Eagle Star for theirelectronic application procedures, which he describes as“absolutely excellent”. The only paper generated is the partwith the client’s signature. That is placed in an envelope andposted. The “Reasons Why” and other relevant informationare all scanned into the system.

Donald also recommends any broker to invest in a good back-up system.

In the office there is a modern computer system which is fullynetworked.

Donald pays tribute to Foresight Computer Solution whoseBoss system is ideal for the broker’s needs. And he has highpraise for Omni view from Assurelink.

“Basically, Boss is a software system whereby when a client

phones, you simply type in the new information and thesystem runs a fact-find and or full report for you. Everything isavailable in seconds, as it is an all-in concise package. Thesystem holds details of all clients, their policies and allcommunications. Because all the data is held in one placeservicing and marketing are only a matter of a few clicks. Ihave been informed that Omni view and Boss have anagreement where Omni view data will be downloadable intoBoss in the near future. I could not recommend anything morestrongly. It is not expensive and keeps all the informationtogether in one place. In addition, there is a built-in diarysystem that is ideal for planning purposes.

Today, Donald and his colleagues, Frank Downey, Niall O’Reilly,Mary O’Toole, Carol Diviney and Mary Moloney all operatepaperless operations and correspond via two ISDN lines mostof the time. (He cannot wait for Broadband to becomeavailable in his area!). Photocopying, faxing and allunnecessary phone calls are all eliminated. Even the fax islinked into the computer. Messages go directly into the systemand are deleted or filed as required.

The cost breakdown is not overwhelming. A good computerwith sufficient storage costs between €1500 and €2,000. Ascanner costs a few hundred euro. A very efficient back-upsystem costs around €2,000.These systems can be designedat the outset to expand with your needs with very littledisruption. The software costs €60 per month, bringing thetotal to under €4,000.

Donald Moloney is more than willing to share his informationwith other brokers and to advise them on what they need. Byworking together, he says brokers can make progress.

“The great thing about this system is that you can get into itvery quickly. You don’t have to close the office for a monthto change over. I don’t know how often I get calls fromcompanies, colleagues and others saying they have mislaidsuch and such a form and would I have a copy. Mail methe name of any client and I can supply his or her entire filein 30 seconds.”

And the busiest machine in his office is the shredder –shredding other people’s paper!

20


Meet a PIBA Broker in a paperless office!

Donald Moloney

Tim Ryan meets PIBA broker Donald Moloney who operates in a virtualpaperless office and strongly recommends the system to his colleagues.


TITANC o n s u l t a n c y

* Business Solutions* Network Design & Implementation.* I.T Consultancy.* Web Design.* E-Mail & Internet Solutions* Wireless WAN and LAN solutions* Telephone Solutions* Maintenance & Support

Galway Office:Salthill, Galway Tel: 091 581817

Clare Office: Corofin, Co Clare. Tel: 065 6827025

Email: [email protected]

One Stop NewsNew Employer Section for www.onestop.ie

Eagle Star is pleased to announce that it has added towww.onestop.ie a new section designed specifically foremployers. This section includes the following:* An employer's guide to PRSAs.* The legal requirements for employers.* How to implement an employee payroll deduction facility. * An explanation of the tax advantages to the employer in

having a PRSA as part of the employee benefit package. * An information flyer for employees explaining the benefits of a

PRSA for them.

There is also a very useful calculator for employers that calculatesthe tax advantages to the employer when they and or theiremployees make contributions to PRSAs.

One Stop Standard PRSAs are distributed exclusively throughPIBA and IBA members. The ‘One Stop’ initiative is an onlineproduct that aims to reinforce the primary role of theIndependent Intermediary in the provision of pensions inIreland while widening the distribution of Standard PRSAsnationwide. For further information, please contact your EagleStar Broker Consultant or your Sales Support Team.

Much has already been written about the Central Bank, IFSRA,the new regulations and the ‘culture shock’ of adjusting to thenew world of intrusive supervision. Little or nothing has beenwritten so far about the stress and worry suffered by the ever-growing number of intermediaries who have been inspected.

Financial Advisers in the UK have been living with this newregime for more years than we have and the anecdotes I havebeen picking up from friends across the water are beginning tohave a familiar ring. I am indebted to a friend over there whorecently sent me a cutting from the Daily Telegraph.

Entitled “Death of Salesman”, it describes what happened to a50-year old Independent Financial Adviser, Emlyn Wynne, afterthree visits from the Personal Investment Authority (PIA) whichregulated the pensions industry. These inspection visits were inthe context of the ongoing pensions review to investigate mis-selling in the UK. Some 12 hours after the last visit by theinspectors Mr Wynne died from a heart attack!

His family claim that the Regulator’s visits were so stressfulthat they played a major part in his death. Mr Wynne’s wife,Pamela, worked for her husband on the administration side ofthe business. She said her husband was in good health andbecause of his hobby as an amateur rally-driver, had regularmedical check-ups. During the previous year, he had won theBritish Rally Driving Championship for the third time in a row.

Said Mrs Wynne: “He had been in the industry for 29 yearsand was very worried about this first visit by the regulators. Youmention these inspection visits to any financial adviser andhe/she automatically starts to panic.”

Mrs Wynne said she began to see her husband’s health startto deteriorate during these visits.

“The whole thing was carried on behind closed doors andhe was summoned in to answer questions throughout thattime. He started to lose all the colour in his face as hebecame more and more agitated. It was just like aninterrogation.”

Mrs Wynne added that their daughters, Hayley (29) and Jo(32) had to be put on a course of anti-depressants, followingtheir father’s sudden death.

The Press Officer for the City watchdog, the FSA, stated thatthe family’s complaint had been immediately referred to theIndependent Complaint’s Commissioner. “These routinemonitoring visits are serious things, they are businesslike andare there for a reason,” he said. “It is not an emergency spotcheck. We send letters out in advance to give people time toget the information together. All visits start with an opening

interview which is not designed to test or trick the financialadviser. It is merely to gain an initial overview of activity andprogress. It is not confrontational. A financial adviser isexpected to have a reasonable grasp of his firms’ activities.”Mike Kent, who works for a firm of financial advisers in the UKwhich specialises in providing valuations – for other firms ofadvisers being put up for sale – has stated that: “…manyfinancial advisers are over 50 years of age and can no longercope with the pressures put on them. Many see theseregulatory visits as the final straw and are getting out.”

Insurance companies in the UK are using tied agents and salesemployees less and less. The number fell by 75% in the 90’s.The biggest IFAs are very attractive to banks and insurancecompanies. The 100 biggest IFA groups write 40% of themarket by volume.

The new word you will be hearing a lot is ‘Polarisation’. This iswhat happened in Britain 13 years ago when the marketdivided into two classes – IFAs and tied agents. The otherword you will hear a lot is ‘multi-tied’.

IFAs tended to use a limited range of companies while peopleon lower incomes bought from tied agents. The FSA alsointends to create a new tier of multi-tied agents selling arestricted range of company products, not completelyindependent but offering better choice than single-tieds. Thethinking behind all of this is, basically, the insurance-buyingpublic are lazy and no matter how strictly you regulate, peoplecould still end up buying from a restricted range of products.The conclusion is that it might be better to spend moremoney on public information and education and spend lesson regulation. Strict monitoring of the advice insuranceintermediaries give has not really worked.

Bank assurers have failed, and banks could become thebiggest users of multi-tieds and/or IFAs. The multi-tieds willneed less qualifications. “Cheap and Cheerful” will be thename of the game. It’s a new kind of industrial branchbusiness. What goes round, comes round.

So where does all of this leave us in Ireland?

I believe we have to monitor these inspection visits a lot moreclosely and build up a body of information about ourmembers’ experiences and the ongoing effect it is having onthem. Our members need feed-back and support where needed. As an Association, we need tolearn from the British experience and make sure our membersare not subjected to undue harassment or interference. Afterall, none of us want to die of a heart attack when theinspector comes knocking!

22


Death of a Saleman!By Tony Ball

PIBA OnLine is a dedicated service available exclusively toPIBA members, through Eagle Star’s Broker Centre @www.eaglestarlife.ie. Launched on 16th September 2002, thisonline facility provided PIBA members with a dedicatedservice, priority policy issue, reduced administrative costs. Froman Eagle Star perspective, we have seen a steadily increasingvolume of Protection business through PIBA OnLine and over40% of PIBA members are now availing of this online facility.

As the first anniversary approaches, Eagle Star and PIBA havediscussed and agreed future developments of PIBA OnLine.The following additional benefits will be available through PIBAOnLine from 16th September 2003:

Pension Products * One Stop Standard PRSA (already available)* Freedom In Retirement - Standard PRSA* Freedom In Retirement - Advice PRSA* Freedom In Retirement - Retirement Advice Plan* Freedom In Retirement - Flexible Retirement Plan

Eagle Star has placed its technology advancements behindPIBA OnLine and in particular the One Stop Standard PRSA.Such technology enables you, the Independent Intermediary,to provide your clients with first class service while dealing withthis business at the level of efficiency necessary to earn areasonable remuneration for your effort.

Protection ProductsEagle Star will continue to offer its range of competitivelypriced Protection products:* Guaranteed Mortgage Protection* Life & Serious Illness - Guaranteed Term Protection

Remember that lower minimum premiums are availableonline and that for specified levels of cover, it may be possibleto complete a shortened proposal form. Through PIBA OnLine,you will get priority policy issue with Immediate Cover - subjectto underwriting limits. Where your client’s application does notqualify for Immediate Cover you will receive a same-dayresponse from Eagle Star, where an application is submittedbefore 2.00 p.m., and a response the next morning before11.00 a.m. if submitted after 2.00 p.m.

Sharing the benefits

The benefits associated with the continued development ofPIBA OnLine will continue to be shared by the members of

PIBA, PIBA and Eagle Star. Increased efficiencies and a widerproduct offering give you an advantage in an increasinglycompetitive and changing market environment. To further buildon these advantages, Eagle Star will also continue to supportPIBA in the roll out of technology and the encouragement ofits use by PIBA members.

Lower Administration OverheadsFor all PIBA OnLine business, both Pension and Protectionbusiness, this business will be completed entirely online.

How to Register for PIBA OnLine

Simply request a PIBA OnLine Access Application Form fromyour Eagle Star Broker Consultant or Sales Support Team.Complete it and return to Eagle Star. You will then be issuedwith a PIBA OnLine Agency and you will be able to completeonline Pension and Protection business and view your PIBAOnLine commission details online.

If you have any queries relating to PIBA OnLine you shouldcontact your Eagle Star Broker Consultant, Sales Support Teamor Helen Lowe. Helen has overall responsibility for PIBAService and she can be contacted on 01 799 2830 or byemail at [email protected].

We at Eagle Star would like to thank you for your ongoingsupport and we look forward to working with you in the futureas we both strive to provide the quality service our mutualclients deserve.

Eagle Star and PIBA – Building a winning partnershipthrough technology

24


PIBA OnLine Goes From Strength to Strength

By Dermot Browne,

Sales & Marketing Director, Eagle Star Life

O N L I N E

FAS Financial Advisors Assistants’ CourseThe joint PIBA/FAS supported Financial Adviser Assistant Traineeship hasbeen successfully running in Navan for the last number of months andtrainees on the Traineeship are now about to head out into theimportant Work Place Training element of this course. Local PIBAmembers have been very supportive of this Traineeship and haveoffered 19 trainees the opportunity to complete the work place trainingelement of this programme in the region.

Due to the success of the initial pilot Traineeship in Navan and theongoing support of PIBA members FAS plan to run out future FinancialAdviser Assistant Traineeships in the Dublin and Cork regions. Indeedthe Traineeship in Cork is due to begin in the coming weeks. A meetingbetween PIBA representatives, the Cork FAS Training Centre andrepresentatives from the National Traineeship Unit to launch the CorkTraineeship took place on Wednesday 16th July. Thanks to the ongoinginterest and support of the PIBA Chairperson, Diarmuid Kelly and PIBAmembers the FAS Traineeship Unit hopes that the Financial AdvisorAssistant Traineeship will continue to act and develop as an example ofbest practice in Traineeship in the coming years.

PIBA EGMPIBA is holding an Extraordinary General Meeting in the Jury’s DublinGreen Isle Hotel on July 29 between 4pm and 6pm. This meeting is toconsider motions to change the Memorandum and Articles ofAssociation of PIBA.

The Insurance Institute of Dublin activitiesLife LectureDate: 4th September 2003, 8amVenue: TBASpeaker: Tom Barry, Canada LifeCPD points apply.

ANNUAL NATIONAL CONFERENCE 2003.11th and 12th September The Marriott, Druids Glen, NewtownmountkennedyTopic: "Connecting with the Customer"

Dublin DebateKindly Sponsored by AccentureDate: Wednesday, October 15, 5:30pmVenue: Albert Theatre, Royal College of SurgeonsTopic: The Legal System - the need for reform?CPD Points apply


Updates for your Diary..

Date Event Venue 4-6 Sept 25th Anniversary Celebrations Kinsale and Cork15 Sept Family Law Limerick Ryan

TBC

16 Sept CPD SeminarKieran Tansey & Nigel Groarke Fairway's Hotel, Dundalk

4.30pm - 7pm

24 Sept Duncan Robertson & Kieran Tansey UCD 4.30 pm 2 hours CPD

14 Oct CPD SeminarEoin Fahy + AN Other Fairway's Hotel, Dundalk

4.30pm - 7pm

18 Oct Understanding Equities-Colin Hunt UCC 10.00am - 12.30pm 2 hours CPD

22 Oct Bob Leahy UCD 4.30 pm 2 hours CPD

LIA Upcoming Events

IMAF Service excellence awardsIMAF's Annual Service Excellence Award survey questionnaire will beissued to all registerd mortgage brokers this month. IMAF hopes to get agood response from all mortgage brokers, including IMAF members, inreturning completed forms.The greater the number of forms returnedmakes the survey more meaningful. The Awards will be presented atFado Restaurant, Dawson Street, on 6th November.

Matthew Fish Financial Services, Unit A3, NutgroveOffice Park, Rathfarnham, Dublin 14 wish to recruit anadministrative/customer services assistantTel: 01 – 2990013 e-mail: [email protected]

Bodley Financial Services, Churchtown, Dublin 14 on theground floor on a high street location is offering to sharespace with a General Insurance Broker or Estate Agent.Contact: Frank Bodley@ [email protected] Tel: 087 – 2314580

Multi-agency insurance brokerage, based in the south-east, seeks the services of a highly motivated, computer andregulations-literate insurance agent. Contact: [email protected]

RJ Crolly & Co. Insurance Brokers, 4 Finsbury Park,Dundrum, Dublin 14 are seeking to purchase a small tomedium southside brokerage with non-life business. Wouldconsider purchase of non-life business from Brokeragewishing to retain their life business. Contact: 01 – 2989166/2960224 e-mail: [email protected]

Broker in Dundalk Area seeks shared office andexpenses with other Broker / Accountant etc. Principalsplease only apply by email to the PIBA office [email protected]. Ref No: 2003001

Brokerage for Sale Ref: 2003002A Life and Pensions Client Bank is for Sale in the SouthDublin area. Renewal and indexation is about €50,000p.a.and the persistency is around 95%. If you are interestedplease contact the PIBA office at [email protected]

26


DUFFY MORTGAGES & INVESTMENT BROKERSDue to continued growth and expansion we Wish to appoint a MORTGAGE CONSULTANTJob Specification:*Sales & development of Mortgage business*Develop and manage new business*Liase with financial institutionsThe PersonCandidates must be able to act independently,problem solve, have good admin. And IT skills.Strong work ethic and communication skills areessential.QualificationsExperience essential within the financial servicessector. Specific experience within mortgage sales isan advantage.The RewardsThe above position offers a very attractiveremuneration package. Apply in writing only withdetailed CV to: Duffy Mortgages & InvestmentBrokers Fitzroy House, Castle Street, Mullingar, Co.Westmeath Tel: 044 – 48772 Fax: 044 – 48231 e-mail: [email protected]

DOWN1. Implement used to murder Trotsky in

1940 (3,4)2. Tirana is the capital of this European

country (7)3. See 7 Across4. Terry Hardiman has succeeded her as

Chairperson of the ProfessionalInsurance Brokers Association (7)

5. Sweets in the USA (5)6. Minister of State who opened the

Professional Insurance BrokersAssociation's Annual Conference (5)

9. And 24 Across. IFSRA intends this groupto sell a restricted range of companyproducts (5-4,6)

14. Ice-cream cake containing fruit and nuts(7)

15. In the future, an _____ may have toconduct an annual review of theDirectors Compliance Statement (7)

16. This country's economy is draggingdown the euro zone area (7)

19. German submarine (1-4)20. South American mountain range (5)21. Chief Economist of Friends First (5)

WIN A WEEKENDIN THE LUXRY FOUR STAR KILLASHEE HOUSE

Killashee House Hotel is set amidst 70 acres of gardens withmagnificent views over the Wicklow mountains and Kildarecountryside. The majestic Victorian house, dating back to 1861, is amagnificent building, complete with intricate and stunning featuressuch as the majestic Bell Tower. Killashee House Hotel also boasts asuperb leisure centre complete with a 25-metre deck swimmingpool and a fully equipped gymnasium, Jacuzzi and steamroom. Tel: 045 - 879277 (Weekend consists of two nightsaccommodation, incl.uding breakfast plus one dinner for two.)Simply complete the crossword puzzle and send your entry alongwith the form to : Cross Word Competition, c/o Tim RyanCommunications, 69 Fitzwilliam Square, Dublin 2.

Entries to arrive no later than August 15. Winner will be notified bypost. Lucky winner: The lucky winner of the last crosswordcompetition was Gerard Sheehy, Webb Insurances, The Square,Cahir, Co. Tipperary.

Name: _______________________________________________________________________

Address :_____________________________________________________________________

_________________________________ Tel No: ____________________________________

CROSS WORD

COMPETITIO

N✂

ACROSS7. And 3 Down. Buoyant era for the Irish

economy (6,5)8. Second-largest country in the world

(6)10. State of little variation after an

increase (7)11. These funds are a minority

investment vehicle but of interest tothe more adventurous investor (5)

12. Murderer of his brother Abel (4)13 Britain's Foreign Secretary (5)17. Massive hit single in 1987 for George

Michael (5)18. Rubik's was a worldwide toy sensation

(4)22. Does 007 invest in these? (5)23. Practice of talking too much about

oneself (7)24. See 9 Down25. High distinction (6)

The lucky winner of the lastcrossword competition.

Mary Daly of the Hibernian Hotel, pulling the winner’s name.Gerard Sheehy won a weekend for two.

ClassifiedsThe following are classified advertisements from PIBA members. To place anadvertisement in this section of The Professional Insurance Broker, simply e-mail it [email protected]. The service is FREE to PIBA members.

Killashee House Hotel

Documents

The Professional Insurance Broker · 2020-01-23 · PRSAs were introduced to help increase pension coverage and were intended to complement company schemes and other Pension arrangements