C.R.E. Financial Services

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C.R.E. FINANCIAL SERVICES; TERMS OF BUSINESS, REMUNERATION, PRIVACY & LEGAL, COMPLAINTS



Client classification

Unless we notify you in writing to the contrary, we will be treating you as a "retail client". This means that you are afforded the highest level of protection under the regulatory system and should have the right to take any complaint to the Financial Ombudsman Service. Details of our complaints procedure are available on request.


Our Relationship

Any advice or recommendation that we offer to you, will be based on your stated objectives and circumstances and take into account any restrictions that you wish to place on the type of products you would be willing to consider.

With very few exceptions, we will confirm to you in writing, the basis of our reason for recommending the products arranged on your behalf.

Your stated objectives will be reiterated in a Suitability Report, which we will issue to you following our recommendation, along with details of any special risks associated with the product recommended.

As discussed, we offer products from the whole of the market. This means that we source the recommended mortgage from the range of mortgages available to "Intermediary" Firms. Certain lenders may offer products directly to the public, rather than via an Intermediary Firm, with more favourable terms. Accordingly our recommendation to you will be based on the most suitable mortgage product incorporated within the range available to Intermediary Firms.

Full details of the products we may recommend to you including, for example, the minimum duration of the product, information on the right to cancel or whether no right to cancel arises, and any other early termination rights and penalties, will be covered in the relevant product disclosure information you will receive, before conclusion of any contract.

Any products we arrange for you, will not be kept under review but we will advise you upon your further request, however, we may contact you in the future by means of an unsolicited promotion (by telephone, post or e - mail) should we wish to discuss the relative merits of a particular product or service which we feel may be of interest to you.


Client Money

CRE Financial Services is not permitted to handle client money, neither can we accept a cheque made out to us (unless it is in respect of an item for which we have sent you an invoice), similarly we do not accept or handle cash.


Disclosure of charges / fees

All charges / fees will be fully disclosed to you. These will be disclosed in summary form before we undertake any work for you. The precise charges relating to any recommendations we make, will be confirmed in your Suitability Report or relevant product disclosure information that is provided to you.

In respect of any regular premium policy which we have arranged for you, should you subsequently cease to pay premiums on the policy and in consequence, we are obliged to refund the commission that has been paid to us, we reserve the right to charge you a fee representing the amount we have to repay. This condition applies for a period of up to four years after commencement of the policy. We will not charge any such fee if you exercise your right to cancel in accordance with any cancellation notice sent to you by the life insurance / product provider / company, at the outset.

There is no additional cost to you for using a means of distance communication.

We obtain professional support services from three sixty services LLP, who provide us with regulatory and business advice. Three sixty services LLP are supported by product providers, fund managers and platforms, through the provision of training resources and occasionally through commission payments made direct to them, which can be used to offset our own fees to them. In the event that three sixty is remunerated through commission, this will be disclosed in the literature provided to you, and in no way will it affect the charges you pay.


Conflict of interest

We will always endeavour to act in the best interests of our clients, however, circumstances can arise where we or one of our other customers may have some form of interest in the business being transacted for you. If this happens or we become aware that our interests or those of one of our other customers conflict with your interests, we will write to you and obtain your consent before we carry out your instructions and we will detail the steps we will take to ensure fair treatment.


Best execution

In executing or transmitting orders on your behalf to third parties, we will take all reasonable steps to ensure that we obtain the best possible result for you, in terms of best execution.


Risk warnings

Please be aware that investments can fall as well as rise, and that you may not get back the full amount invested. The price of investments we may recommend, may depend on fluctuations in the financial markets, or other economic factors, which are outside our control. Past performance is not necessarily a guide to future performance. Specific warnings relevant to the investments, or investment strategies, we recommend will be confirmed to you in your Suitability Report.


Cancellation rights

In most cases you can exercise a right to cancel, by withdrawing from the contract recommended to you. In general terms you will normally have a 30 day cancellation period for the majority of policies. In most instances, you will not be able to exercise a right to cancel a mortgage contract, unless the contract is concluded at a distance (i.e. no face to face advice), at which point you may have a 14 day cancellation period.

The start of the cancellation period will normally begin, for pure protection policies, when you are informed that the contract has been concluded or, if later, when you have received the contractual terms and conditions. In other cases, the cancellation period will begin on the day the contract is concluded or, if later, the day on which you receive the contractual terms and conditions. Instructions for exercising the right to cancel, if applicable, will be contained in the relevant product disclosure information which will be issued to you.

If you cancel a single premium contract, we will require you to pay for any loss you might reasonably incur in cancelling it (which is caused by market movements). This means that, in certain circumstances, you might not get back the full amount you invested if you cancel the policy.


Documentation

We will endeavour to make arrangements for all your investments to be registered in your name unless you first instruct us otherwise in writing. All Policy Documents or Lender’s Offer Documents will be forwarded to you as soon as practicable after we receive them. If there are a number of documents relating to a series of transactions, we will normally hold each document until the series is complete and then forward them to you.


Data Protection

Your personal information is very important to us. We will endeavour to take all due to care to protect this information. We would like to highlight below, a few matters relating to your information that you should be aware of.

Some services are provided to C.R.E. Financial Services by third parties, such as processing business or obtaining compliance or regulatory advice, which warrant the disclosure of more than just your basic contact details. You agree that personal information held by C.R.E. Financial Services may be disclosed on a confidential basis, and in accordance with the Data Protection Act 1998, to any such third parties. You also agree that this information may be transferred electronically, e.g. via email and you agree that ourselves, or any such third party, may contact you in future by any means of communication which we consider appropriate at the time.

Product Providers, Lenders and Investment Managers may administer your policy (or any existing policies you have with them) and provide other services, from centres in countries outside Europe (such as India and the USA) that do not always have the same standard of data Protection laws as the UK. However, they are required to put a contract in place to ensure that your information is adequately protected, and they will remain bound by their obligations under the Data Protection Act even when your personal information is processed outside Europe.


Termination

You or we, may terminate our authority to act on your behalf at any time, without penalty. Notice of termination must be given in writing and will take effect from the date of receipt. Termination is without prejudice to any transactions already initiated which will be completed according to these terms of business (unless otherwise agreed in writing). You will also be liable to pay for any transactions made prior to termination and any pending / outstanding fees due (for work in progress) at the time of termination.


Remuneration

C.R.E. Financial Services will accept instructions to act on behalf of the client in return for remuneration based on either one or a combination of the following methods ;-


The client will be given the option to elect how you remunerate us for our services before any work is undertaken on your behalf.

Where C.R.E. Financial Services is remunerated via a commission payment from the product provider on indemnity terms, you the client, agree to unconditionally reimburse C.R.E Financial Services in the sum of the full amount of any commission reclaimed by the product provider, should the policy arranged or product chosen, be cancelled or lapsed (for whatever reason) during the indemnity period.

To clarify, in respect of any regular premium policy which we have arranged for you, should you subsequently cease to pay premiums on the policy and CRE Financial Services have to repay the commission (that has been paid to us) back to the insurer, we reserve the right to charge you a fee equal to the amount of commission that we have to repay. This clause applies for a periods of between one and four years after commencement of the policy (and varies according to the type of policy taken out). We will not, however, charge any such fee if you exercise your right to cancel in accordance with any cancellation notice sent to you, by the insurer / product provider at the outset.


Your consent

In giving C.R.E. Financial Services Instructions to act on your behalf, you the client, agree to these terms of business and hereby authorise C.R.E. Financial Services to transact business on your behalf. These terms of business comprise our standard client agreement, upon which we intend to rely. For your protection you, “the client” should read these terms carefully, before signing them.


Privacy & Legal

C.R.E. Financial services will at all times, act professionally and in accordance with the prevailing legislation applicable to the type and volume of business, that we are permitted to undertake and authorized to transact, on behalf of the client.

In the event of a dispute the governing laws of England & Wales will apply.


Complaints

Should be made in writing to :- The compliance officer, C.R.E. Financial Services Ltd. and sent to the company's registered office, clearly stating the date of the event, the nature of your complaint, the member of staff involved. We will acknowledge receipt of your complaint within fourteen working days from the date of receipt at our registered office. Your complaint will then be investigated and a reply will be made to you within a reasonable timescale (subject to the nature and type of complaint received). Where a complaint involves a third party (other than a directly employed member of staff), we accept no responsibility for delays in processing the complaint (due to third party failure to comply with the investigation process). C.R.E. Financial Services Ltd. will not accept service of documents by fax or e mailed attachments nor will we respond to a third party without the appropriate complainant authority. Should your complaint not be resolved satisfactorily the matter may be referred to the ombudsman or the appropriate regulatory authority.