Background
McNamara Wealth act as broker between you, the consumer, and the product provider with whom we place your business.
Pursuant to provision 4.58A of the Central Bank of Ireland's Consumer Protection Code, all brokers must make available in their public offices, or on their website if they have one, a summary of the details of all arrangements for any fee, commission, other reward or remuneration agreed with their product producers. This document fulfils that requirement.
How We Are Remunerated
McNamara Wealth may be remunerated in one or more of the following ways: by commission paid by the product provider to whom business is transmitted, based on a percentage of the premium paid or the amount invested; by a fee agreed directly with you in advance of any transaction; or by a combination of commission and fees, as discussed and agreed with you. Where commission is received from a product provider, this will be disclosed to you in your Customer Information Notice before any transaction is completed. Where we receive commission and a fee has also been agreed, we may offset commission received against any fee due.
Types of Commission
Type of Commission | Description |
Single / Initial Commission | Payment made to the firm shortly after the sale is completed, based on a percentage of the premium paid, amount invested, or amount borrowed. |
Recurring / Trail Commission | Further payments at intervals throughout the life of the product, based on a percentage of the fund value or the annual premium. |
Renewal Commission | A payment made at regular intervals throughout the term of a policy, usually based on a percentage of the premium paid. |
Indemnity Commission | Commission paid before it is deemed to be fully earned, effectively an advance. Indemnity commission may be subject to clawback if the client cancels or lapses the product within the specified period. |
Clawback
Clawback is an obligation on the broker to repay unearned commission. Commission may be paid directly after a contract is concluded but is not deemed to be fully earned until after a specified period of time. If you cancel or withdraw from a financial product within the specified clawback period, the broker may be required to return some or all of the commission to the product provider. Clawback periods, where they apply, are set out in the provider tables below.
Our Fees
In addition to or instead of commission, McNamara Wealth may charge a fee for the financial planning and advisory services we provide. The nature and amount of any fee will be agreed with you in writing before any work is carried out. Our fee structure is set out below.
Service | Fee |
Initial consultation | Complimentary, no obligation. |
Financial planning fee | Agreed in advance based on complexity and scope of work. |
Second Opinion review | Fixed fee of €250, agreed with you in advance. Offset in full against implementation fees where changes are subsequently made through the firm. |
Implementation fee (Platform-based investments) | Up to 3% on the first €500,000; up to 1% on €500,001–€2,000,000; up to 0.5% above €2,000,000. Applied on a tiered basis: each rate applies only to the portion of assets within that band. |
Ongoing annual advice fee (Platform-based investments) | Up to 0.75% per annum on the first €1,000,000; up to 0.5% per annum on €1,000,001–€10,000,000; up to 0.3% per annum above €10,000,000. Applied on the same tiered basis. |
The implementation fee and ongoing annual advice fee set out above apply to investment and pension assets held on an investment platform, where we provide portfolio construction, custody arrangements and ongoing review. They do not apply to business placed directly with a product provider, where we are remunerated by commission as set out in the tables below. They do not apply to standalone financial planning work, which is agreed separately and in writing in advance.
Worked examples (at maximum rates)
Implementation fee on an investment of €800,000: 3% on the first €500,000 (€15,000) plus 1% on the remaining €300,000 (€3,000), a total of €18,000.
Ongoing annual advice fee on assets of €5,000,000: 0.75% on the first €1,000,000 (€7,500) plus 0.5% on the remaining €4,000,000 (€20,000), a total of €27,500 per annum, an effective rate of 0.55%.
These examples illustrate the maximum fees that could apply. The actual fee will be agreed with you in writing in advance and may be lower.
Where a fee has been agreed and you subsequently implement recommendations through the firm, any commission we receive from the product provider in connection with that implementation will be offset against the fee, up to the full value of the fee. Where the commission received exceeds the agreed fee, no fee is payable by you and no further amount is refunded. Where the commission received is less than the agreed fee, the balance remains payable. This will be confirmed to you in writing before any transaction is completed.
A Second Opinion review of your existing pensions, investments and policies is carried out for a fixed fee of €250, agreed with you before any work begins. This covers the gathering of information from your existing providers, a full review of costs, performance, structure and tax treatment, and a written assessment presented in plain language. Where you subsequently decide to implement changes through McNamara Wealth, the €250 is offset in full against any implementation fees that would otherwise apply. The fee is not refundable where no further engagement takes place, as it represents payment for the review work carried out.
Non-Monetary Benefits
McNamara Wealth may receive non-monetary benefits from product providers from time to time, including attendance at product seminars and conferences, or IT and administrative support. We will only accept such benefits where they are reasonably designed to enhance the quality of service we provide to clients and where they do not conflict with our duty to act in your best interests.
Sustainability
When providing investment advice and insurance-based investment advice, McNamara Wealth does not currently consider the principal adverse impacts of investment decisions on sustainability factors as a primary consideration in its advice process. This position is reviewed annually.
Remuneration Details
The following tables set out the maximum commission arrangements that McNamara Wealth has agreed with each product producer. These figures represent the maximum our firm may receive. Actual remuneration may be lower and is disclosed to each client individually.