Fears protection commission disclosure will turn clients off advisers

As new disclosure rules bring the full extent of protection commissions into the spotlight, experts are asking if this will see clients ditch their advisers in favour of execution-only services.

Under the Insurance Distribution Directive, from 1 October advisers have had to provide clients with information before a product sale about any commission received, which should include up-front and ongoing costs. Where necessary, this must also be done when a policy is either renewed or updated.

While protection remained the one area of advice immune from the RDR’s commission ban, the IDD effectively mandates charges for protection are split out in a clearer way between all types of remuneration in line with what the RDR enforced on investment and pensions advice.

The IDD gives EU members the flexibility, if they want, to go further on the commission rules and restrict any commissions or fees from third parties for insurance advice, meaning the FCA could, if it chooses, tighten the rules further.

A senior protection industry source says: “The fact you have to visibly disclose could cause advisers trouble. Clients might notice that they are now being charged hundreds of pounds for a phone call.

“If the IDD makes disclosure obvious, what is the value of the advice and the commission?”

The source adds that unearned indemnity commission is a topic that has arisen in meetings with the FCA.

Some would see this as a negative development in the market.

One protection expert tells Money Marketing that while they may look cheaper, some execution-only sites actually take more commission than advisers do.

Chapters Financial director Keith Churchouse believes there is unlikely to be a significant drop-off in advised sales, however.

He says: “Many clients do not identify the need for protection or quantify it. It is those two elements where the adviser normally creates an opportunity for a protection plan.

“I would think it would be very rare for a client, say a director of a company, to protect themselves or their business, working out a sum assured and then handling the market. They have got better things to do than that.

“For someone who is green, researching the market for the first time, they may find that quite difficult and time-consuming.”

Churchouse adds: “I can see a price-point argument but that would be very limited. I don’t see a flood away from advisers at all.

“Many online services do offer good value, no doubt about that, but many people do not buy protection or identify it as a need. You don’t normally get clients taking advice then heading off to a third party to execute the deal.”

Bridging the gap

If there is a shift to self-service, referral to execution-only sites may not necessarily leave the adviser worse off.

Protection Review’s Kevin Carr notes that execution-only does not necessarily mean no commission, and that most execution-only sites do facilitate payments.

He says: “Advisers can of course reduce the commission by any amount down to zero and charge a fee instead, and some advisers already partner with execution-only firms if that is what the client prefers.”

In a letter to members of Kent-based adviser network Julian Harris, seen by Money Marketing, the firm advertises a new referral service to an execution-only protection site for advised clients.

It says it is targeted at advisers “who would rather not advise clients on protection but would still like to receive the commission”.

Advisers direct clients to the site where they can get a quote from a range of eight different providers, listing the adviser as their introducer, who would then receive their commission.

The letter says that the introductory commission rate would be between 118 and 132 per cent of annual premium depending on the insurance company.

Commission is subject to an up-front cap of £350 per plan, with the balance held until the end of the indemnity period.

Advisers are provided with a template letter they can show clients when referring them to the self-directed service, notifying them that it “selects from a limited number of providers, and hence you may be able to obtain a more competitive quote elsewhere”.

The suggested letter adds: “I am not giving you any advice in respect of your protection needs or possible solutions, hence if you want advice in connection with your protection needs and possible solutions, you should contact an authorised adviser who is willing to advise you in this area.”

Churchouse says advisers should be clear about where advice starts and ends.

He adds: “It can still be advice if the adviser is making a recommendation to a third party or a recommendation which the third party then uses.

“It might be execution-only with a small ‘e’, as it were, because advisers are still probably providing advice on what they should be looking at.”



Nic Cicutti: Adviser anger at FOS is misplaced

The number of upheld complaints outside the 15-year liability period demanded is tiny and falling Do you ever get that kind of uneasy feeling where you do a piece of work for a client but have a niggle at the back of your mind about something you might have missed? I had that sensation a […]

Tapering of annual allowance – adjusted and threshold income

The definitions of adjusted income and threshold income used to determine whether, and to what extent, someone’s annual allowance will be reduced can be confusing.  Here we try to make sense of it all. The annual allowance will be reduced for high income individuals from 6 April 2016.  Our previous article Tapering of annual allowance […]


FCA confirms ban for jailed Norfolk IFAs

The FCA has confirmed that financial adviser pair Alan and Russell Taylor will not be allowed to work in any regulated position again after being jailed for 11 years on fraud charges. The brothers, who ran Norfolk IFA Taylor and Taylor Associates, plead guilty to conspiracy to defraud earlier this year, after defrauding nearly 200 […]


Nest trials sidecar savings concept

The National Employment Savings Trust has launched a trial with retailer Timpsons to test how its sidecar savings model works. In a sidecar structure, contributions over and above the auto enrolment minimum are designed to create an optimal level of liquid savings while also maximising long-term savings. The trial will explore whether the sidecar savings […]

Natixis video: Making smarter use of asset classes

Content supplied by Natixis Global Asset Management This video from Natixis Global Asset Management focuses on Active Share. One strategy for the smarter use of equity investments is ensuring you get what you pay for. According to the company, looking at Active Share can give you a better perspective on where performance comes from. Active […]


News and expert analysis straight to your inbox

Sign up


There are 6 comments at the moment, we would love to hear your opinion too.

  1. Surely the worry about turning clients off is admission itself that, more often then not, commissions have been gratuitous and totally disproportionate.

    As pointed out above, a rebate should take care of any concerns.

    This change is long long overdue.

  2. Why the relentless drive to remove remuneration for advisers for products consumers need help with, that need to be sold and advised on! Yes, sold, I don’t know of a time someone woke up with the thought, “I’m going to buy critical illness cover today” without the concept ever being introduced by an adviser!

  3. Problem is that customers want advice, just do not want to pay for it.

    Problem with Execution Only is that they convince themselves that they were given advice, or that information was confusing or misleading and run off to the FOS.

  4. Touche…. why can’t the FCA get it through their thick skulls that protection (in the initial stages)has to be sold and is rarely if ever bought. Life Insurance is singly the hardest product to advise anyone, so don’t make it even more difficult No-on goes out on a Saturday with the family and thinks “As well as visiting Burger King and John Lewis we ought to sit down and discuss buying some critical illness cover too” If you turn IFA’s away from advising then the public will only be left to the likes of Gofundme.co. and charities to resource money in their times of financial need. Just take a look at some of the hard luck stories on Gofundme regarding situations that could have been resolved by putting appropriate protection in place and you will see what I mean.

  5. Many advisers have been disclosing commission pre-sale for many years. Me thinks this topic has been over-egged somewhat.

    • Agreed, Mr Hurdman! I have been disclosing commission on protection policies for at least 12-15 years, and doing so has never caused a problem. Furthermore, I stopped taking ‘indemnity’ commission at the same time and the resultant (modest) monthly payments from the likes of AEGON, Aviva, L&G, etc. has been very helpful, with few worries about ‘clawback’ – few policies go off the books, so to speak, if they are set up correctly at outset.

Leave a comment


Why register with Money Marketing ?

Providing trusted insight for professional advisers. Since 1985 Money Marketing has helped promote and analyse the financial adviser community in the UK and continues to be the trusted industry brand for independent insight and thought leadership.

News & analysis delivered directly to your inbox
Register today to receive our range of news alerts including daily and weekly briefings

Money Marketing Events
Be the first to hear about our industry leading conferences, awards, roundtables and more.

Research and insight
Take part in and see the results of Money Marketing's flagship investigations into industry trends.

Have your say
Only registered users can post comments. As the voice of the adviser community, our content generates robust debate. Sign up today and make your voice heard.

Register now

Having problems?

Contact us on +44 (0)20 7292 3712

Lines are open Monday to Friday 9:00am -5.00pm

Email: customerservices@moneymarketing.com