Our Commitment to you

Yes.  The information you pass to us will usually include ‘special category data. UK Data Protection laws require you to obtain your client’s explicit consent to share this type of information with us. A suitable consent form allowing you to transfer data regarding receiving insurance mediation services is provided in the appendix section.

You are responsible for the accuracy of the information you pass to us if relied on to base our recommendations. 

You can only pass a client’s contact details to us if they have provided their consent for us to contact them to offer insurance services. 

You can only pass us the clients fact find information if they have provided their express consent to share with us their data, including special category (Health) information.

As a mortgage advisor, you are in a particular position of trust with your client. Any comments or opinion you offer about the appropriateness or suitability of our insurance recommendations are likely to have the force of advice.  Accordingly, you should only comment if you are licenced under the HLP T&C Scheme to Advise on Protection contracts and are prepared to accept responsibility for that advice.

Helping the customer complete their insurance proposal/application for cover or make a claim are also regulated activities and as subject to high standards of professional conduct.

Suppose you are not Licensed to Advise on Insurance Contracts under HLP's T&C Scheme. In that case, you must not advise your client or say anything that gives the impression of advice regarding our insurance recommendations. Instead, it would be best to tell your client that you cannot advise them and refer them back to their HL Protection Advisor. This restriction does not prevent you from discussing the insurance contracts we recommended and, in factual terms, the impact these have on the client's overall financial situation.

Please refer your client back to us if they require help to complete their insurance application, have questions about our advice or want to make an insurance claim.

Our interpretation of current tax law is that the revenue you receive through this activity is commission for insurance intermediation, and as such, it is likely to be exempt in the UK from Value Added Tax.

There is no need to include the fees received on the RMAR. This will be recorded through our system.

You should record in your suitability letter that the client understood and accepted the risks of the recommended borrowing. For many clients this includes the risk of no longer being able to afford to live in the mortgaged property following unforeseen changes in circumstances including death of a partner, inability to work due to accident, sickness or redundancy and fire, storm, flood.

To demonstrate that you have met this duty please record in your Suitability Letter that you have referred your client to HL Protection for advice about their insurance needs and recommend that they act on that advice prior to committing to take on the recommended mortgage.   For example your Suitability Letter might say the following:

You will be reliant on each other to meet the mortgage repayments and household expenditure and I pointed out the serious financial implication if either of you are unable to work due to illness, redundancy or died.  I pointed out that insurance cover designed to protect against these types of risks is generally available and with that in mind I have passed your details to the specialist HL Protection to advise you further in this regard. I recommend that you act on their advice prior to you becoming committed to purchase at exchange of contracts. 

Referral payments for business received in the month will be paid within the first 2 weeks of the following month. This means that the referral payment for all commission received from providers in the month of January will be paid to you by the middle of February.

Your referral commission will be paid to the same bank account registered against your AR account.

Your Referrals and any resulting insurance business arranged by HLProtection should not be recorded in the Ancillary Business Register.