Rising to the CPC-116 Challenge

The provision requires that you make available an exact list of all your highest upfront and recurring commissions across all providers you deal with. This should be made available to your customers in your office and on your website. These information provided must include all upfront, recurring and claw-back and non monetary benefits.

The Central Bank has advised that it envisages a webpage, with links to the products available from each provider and maximum and clawback commission rates for each product. This is to be a combination of all factors of commission including any upfront, recurring, clawback and non-monetary benefit as well as any specific terms. The Central Bank does not wish to see ranges. The Central Bank also notes it is what you take at a maximum level, not what you mostly take or take on average.

You must have an accessible file online or on a drive to be readily available for inspection or digestion for any party. This should be in a format that is ready for circulation and kept up to date as new products come on stream, or existing products are edited or removed from the market. For example one Life Office has 4 savings contracts with differing commission options and one other Life Office has 6 different Buyout bond commission options.

Yes, they are aware.

They can simply survey a Brokerage website remotely as part of their desk based themed inspection process. This process would not need to be on site, with staff capable of reviewing a number of sites quite quickly. Consistency from industry perspective is key, particularly if there are varying levels of consistency, information and quality of presentation.

The Central Bank have made it clear that they want to see detailed remuneration information presented on brokers websites. We all know that this will be a significant amount of information (even for brokerages with only a handful of agencies). That’s why our solution will allow you to set out a plain English description of your charging ethos and the key charges that apply to individual products that you sell.

The intent is that this approach will present a more customer friendly and digestible up-front summary. Naturally, if customers wish to do so, they will be able to explore down to the detail level of all of the maximum charging options per product per provider. Our expectation is that most customers will not actually do this. For the time being Brokers Ireland have advised ClearChoice/Brokerages not to display every breakdown or matrix of each product and the linked commissions, allocations, AMC’s etc.

No, their obligations around CPC 116 predominantly relate to corporate entertainment etc. This is a Brokerage/intermediary obligation within the CPC.

Of course you can. However, we recognise the volume of work that is required up-front to assemble all of the charging information that needs to be placed on a your website. Furthermore, we also recognise the burden that will be placed on brokers as they endeavour to keep this information constantly up-to-date.

We are proposing to create an automated solution that does all of this work for you and therefore allows you to focus your energy on your business, not spending administrative time on collation of pricing information and constantly checking if it is correct and up-to-date.

ClearChoice, with a tight deadline, have to build a centralised solution for many Brokerages, with different requirements, options, types of websites.

The ongoing maintenance fee is for updating, maintaining, deleting and editing all arrangements, such as a new product launch or new agency. The importance of a centralised solution are;

1. Consistency of information for inspection and presentation for the industry
2. Accuracy
3. Ongoing maintenance, difficult for a Brokerage to control and maintain information of this density on their own website(s)
4. Lowers the cost for all

Yes, existing ClearChoice and TAG customers get a discount on both the up-front and on-going cost of the solution. Please refer to the pricing section above.

Earlier this year, ClearChoice issued a survey to over 1,500 brokers to seek feedback on the type of solution that brokers would value. Overwhelmingly, the feedback was that people wanted something automated that they could setup and effectively ‘forget about’. We did propose and consider slightly less complex solutions that would require more on-going administration by brokers themselves, but the sentiment was clear – fully automated and integrated was what you wanted.

The only risk to this solution not working is that an insufficient number of brokerages signup to the solution. If the volume of sign-ups is insufficient, we will not be proceeding.

If there is sufficient interest and sign-up’s, ClearChoice is committed to creating a CPC-116 solution for our industry.