Consumer Protection Code 2012 (CPC). Commission Disclosure 4.58A

Summary of the details of all arrangements for any fee, commission, other reward or remuneration paid or provided to the firm and paid of provided to the policyholders appointed broker.
Pursuant to the addendum to the CPC provision 4.58A. As at March 2020.

 

INTRODUCTION:

The Central Bank has amended the Consumer Protection Code 2012 (CPC). New provisions are amending certain existing provisions of the CPC. The Addendum will be effective 31 March 2020.
The addendum to the CPC has created a new provision 4.58A (a copy of wording of this provision is shown below) which require all intermediaries to make available on its website, a summary of the details of all arrangements for any fee, commission, other reward or remuneration paid or provided to the intermediary which it has agreed with product producers.
To enable us to fulfil our obligations under the CPC and make available in a manner which seeks to inform consumers, we are introducing onto the website this summary of the arrangements for fees, commission and if relevant other rewards or remuneration which is receivable and which Blackrock pays to our brokers, per product.
This Document is intended to allow the brokers with which we engage to comply with their own obligations in relation to dealings with Blackrock Insurance Solutions Ltd (The Firm).

 

COMMISSIONS/REMUNERATION PAYABLE TO THE PRODUCING BROKER: (CPC AMENDMENT 4.58 DISCLOSURE)

The income of the Firm is commission allowed from the GWP by the regulated Insurer on behalf of which we underwrite and distribute. That commission is split between the Firm and the clients appointed broker.
The agreed rate of commission to the producing broker shall average not more than 10% in 2020.
This has been assessed as appropriate against market norms and shall not create any conflict of interest for the producing broker.

 

FEES:

The Firm charges a nominal administration fee (typically less than 0.01% of the premium payable or €100) from Policyholders.
Risk Survey fees may be collected on behalf of third-party survey service providers and the Firm derives no income in that regard.

 

COMMISSION/REMUNERATION TO THE FIRM

The Insurer product producer (appointments held with Ironshore Europe DAC and/or  Generali (UK Branch) and/or Everest Syndicate 2786 at Lloyd’s) will allow commission on Gross Written Premium (GWP). The commission on a transaction or policy is variable. We share the commission with the Policyholders appointed broker (the Producing broker). Ordinarily, it is 10%.
Leisure Liability can be challenging on expected claims to Gross Premium ratios (Expected Loss Ratios). On pubs, bars and hotels, fitness facilities such as Gyms or leisure risks, the commission that the Firm retains can be as low as 5%.  
As we assess and price risks on behalf of the Insurer, we may earn a conditional profit share commission retrospectively, several years after the close of the business year.

 

PROFIT COMMISSION (PAYABLE RETROSPECTIVELY ON SUCCESSFUL UNDERWRITING RESULTS)

Blackrock Insurance Solutions may also earn an additional payment known as profit share. This is payable retrospectively by the Insurer, several years after the close of the business year (allowing for development of claims after the Period of Insurance), in the event that the Underwriting performance is better than agreed triggers.
This will not be shared with producing brokers and no conflict of interest shall so arise. This profit commission when payable may adjust Blackrock earnings on a sliding scale to a maximum upside of an additional 1-2% of commission on GWP. This income is highly conditional and is typically payable 24-36 months after the close of the Underwriting Year, and subject to repayment on subsequent deterioration of results on the Underwriting Year on which it is payable.

 

NON-MONETARY BENEFITS

These are deemed to be any benefits, which are not related to the intermediary’s individual sales. The Firm may provide training and host meetings for information transfer with producing brokers. For the avoidance of doubt such meetings may include hospitality of a nominal and proportional value which shall not create any conflict of interest or particular incentive for the producing broker. 

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