Terms and Conditions of Business

The Financial Services Authority requires that we give you Client Agreement Initial Disclosure Document to tell you about our services. This document explains the products we are able to recommend, our status and charging methods.

Our Client Agreement explains the main aspects of the way we operate as a company, and how this affects you, the client. This Client Agreement Letter will be effective from the date of receipt but may be amended by us following any initial contact intended to ascertain your current financial situation, objectives, and attitude to financial risk. Any such amended Client Agreement Letter will be sent to you within 10 working days of that contact. However, irrespective of any amendments arising from such contacts, we reserve the right to amend the terms of this letter without your consent but we will give at least 10 business days notice before conducting relevant business, unless we consider it to be impracticable to do so under the circumstances existent at that time.

Our Client Agreement covers the following subjects, please click on the subheadings below for further specific information.

• Our Status
• Our Services
• Objectives
• Records
• Personal Interests
• Instructions
• Ownership
• Fee & Commissions
• Review
• UK Money Laundering & Regulations
• Data Protection
• What to do if you have a Complaint
• Client Money
• Safeguards
• Compensation & Professional Indemnity
• Law & Language

OUR STATUS

First Place Financial Ltd is authorised and regulated by the Financial Services Authority. Our FSA number is 476381. Our permitted business includes advising on and arranging investments (including pensions), mortgage and general insurance transactions, including life and health insurances. You can check this on the FSA’s Register by visiting the FSA’s website www.fsa.gov.uk/register/ or by contacting the FSA on 0845 606 1234.

OUR SERVICES

As our firm is independent and we offer products from the whole market. When advising on investment, pensions, mortgage and general insurance transactions, including life and health insurances, details of the services that we provide are set out in our Combined Initial disclosure Document.

OBJECTIVES

When making a detailed mortgage or investment recommendation, we will confirm your objectives and any restrictions on the types of product that you wish to buy, and explain why, having assessed your needs and why our recommendations are suitable for your individual circumstances in our suitability letter or report.

When arranging an insurance contract, including life and health insurances, we will confirm your needs and any restrictions on the types of product you wish to buy, and explain the reasons for our recommendations in a “reasons why letter”.

RECORDS

We will, if required by you supply copies of records and computerised records relating to you. We undertake to maintain such records for a period of at least six years from the date of each transaction.

PERSONAL INTERESTS

We undertake not to transact for you, business in which we or one of our other customers or any director/partner/employee has a known interest.

INSTRUCTIONS

We usually ask clients to give instructions in writing by completing the relevant application form and signing the appropriate declaration. Where you have a right to cancel your purchase, the product provider will give you notice of this in writing. You will be informed of any taxes or costs that may exist other than our fees, the period for which any illustrations are valid, and of the minimum duration of the contract. Our authority to act on a client’s behalf in accordance with these Client Agreement can be terminated at any time by either side in writing, without prior notice and without penalty. A mortgage fee is non refundable in the event of a mortgage not being offered or not completing. This will be effective from the date the notification is received. However, if transactions already initiated remain outstanding, the notification will only be effected once these have been completed.

OWNERSHIP

As independent intermediaries we never own any products you buy or transact through us. All purchases will be registered in the name(s) of the client(s). We will forward to you all documents showing ownership of your purchases as soon as it is practical after we receive them. Where a number of documents relating to a series of transactions are involved, we may retain each document until the series is completed and then forward them to you. In some cases the documentation will be sent to you direct from the product provider.

FEES & COMMISSIONS

On some (but not all) transactions, we may receive commission in line with standard industry practice. This is retained to cover administrative and general operating expenses. In accordance with FSA guidelines, where commission disclosure is mandatory, all commission payable to us will be disclosed prior to the transaction.

REVIEW

When we have arranged a contract for which you have given instructions we will not give you any further advice unless you request it. We will contact you shortly before the contract expires to discuss its renewal, if appropriate. Alternatively, we will be glad to advise you, at any time you ask us to.

UK MONEY LAUDERING REGULATIONS

We are obliged to conform to the UK Money Laundering Regulations and also adhere to the guidance notes from the Joint Money Laundering Steering Group. This process may require sight of certain documentation to verify the identity and place of residence of each client. We may also request that you inform us how any monies being invested were obtained or accumulated. If you provide false or inaccurate information and we suspect fraud or money laundering we will record this. We will not forward any applications or money to third parties or product providers until our verification requirements have been met. We take no responsibility for any delay where money laundering verification is outstanding. In circumstances where sufficient verification is not received in a timely manner after we have received completed applications, the application(s) and any monies may be returned to you.

DATA PROTECTION

We are required to demonstrate to the FSA that we "know our client". Through this process we may request "sensitive data" from you e.g. your state of health for life assurance contracts. If you agree to provide this information, we will take this as your explicit consent to the processing of such information. Your "Data" will be put onto the database and manual records of First Place Financial Ltd and held, processed, disclosed and used by us and third party product providers in servicing our / their relationship with you, including identity and money laundering checks, as well as informing you of new opportunities by post, telephone, fax or email. You also agree that for the purposes described above your data may be transferred to countries outside the European Economic Area (EEA). If you do not agree to this storage, use and disclose, please write to the Data Protection Officer at First Place Financial Ltd, Nethercott Barn, Spreyton, Crediton, Devon, EX17 5DZ.

WHAT TO DO IF YOU HAVE A COMPLAINT

If you wish to register a complaint, please contact the Compliance Officer in writing at:-

First Place Financial Ltd, Nethercott Barn, Spreyton, Crediton, Devon, EX17 5DZ. Or by telephone on 01837 849130

We will acknowledge the complaint raised and send you a copy of our internal complaints procedure. The matter will be investigated in line with our procedures and our findings reported to you. If you cannot settle your complaint with us, you may be entitled to refer it to the Financial Ombudsman Service.

CLIENT MONEY

We do not handle clients’ money. We never accept a cheque made out to us (unless it is settlement of charges for which we have sent you a bill). We do not handle cash.

All commission to be rebated to the client, in respect of any transaction arranged, is and will remain the property of this firm, until such time as, if previously agreed, all or part of that commission is refunded to the client. Any interest on any such sums will not be payable.

SAFEGUARDS

For your protection, First Place Financial Ltd is registered under the Data Protection Act, and authorized and regulated by the Financial Services Authority. Please be aware that business mortgages, buy-to-let mortgages and loans for timeshare purchase are not regulated mortgage contracts.

COMPENSATION AND PROFESSIONAL INDEMNITY

We are covered by the Financial Services Compensation Scheme. You may be entitled to compensation from the scheme if we cannot meet our obligations. This all depends on the type of transaction and the circumstances of the claim at the time. Compulsory classes of insurance are covered for 100% of the claim, and most other types of insurance transactions are covered for 100% of the first £2,000 and 90% of the remainder of the claim, without any upper limit. Most types of investment and mortgage business are covered for 100% of the first £30,000 and 90% of the next £20,000, so the maximum compensation is £48,000. Further information about compensation arrangements is available from the Financial Services Compensation Scheme. (Customer Services – 020 7892 7300).

LAW AND LANGUAGE

Where applicable, our dealings with you shall be governed by the law of England. All information, terms and conditions, and communications shall be in English.