Our mission is to balance your portfolios to reflect your moral compass, and our aspiration is to have them perform well in a rising market, with a high level of protection if indices fall.
We are open, straightforward and accountable in our dealings, and determined to empower you to understand where your money is invested, how that is arranged and how you can monitor its performance.
Please read this document carefully.
This agreement is between Ruth Whitehead Associates and yourself. If you have any queries about the agreement or require clarification on a particular matter, please don’t hesitate to contact the office.
Our company
Ruth Whitehead Associates is a financial and business planning consultancy that offers objective, independent financial planning to private individuals and smaller companies or partnerships. Ruth started the company in 1993.
We are authorised and regulated by the Financial Conduct Authority (FCA).
We offer a range of services, from fully comprehensive overviews providing advice on every aspect of your situation, to targeted advice focusing on specific issues. We will make a recommendation after assessing your needs.
We offer financial advice and a transactional execution only service where we act as an agent for providers and managers.
Our services
We are independent and therefore able to offer products, instruments and structured deposits from the whole market to give you the widest possible choice. The products we assess shall be sufficiently diverse with regards to their type, and provider, to make sure your investment and protection objectives can be suitably met. In addition, and secondary to your general investment objectives, we shall assess your Environmental, Social, Governance (ESG) and Sustainability preferences.
We also advise on non-investment protection. We offer products based on a fair and personal analysis for all types of life cover / insurance contracts.
Some examples include Term Assurance, Mortgage Protection Assurance, Critical Illness Insurance, Private Medical Insurance, Permanent Health Insurance, Accident, Sickness and Unemployment Insurance from a whole market range of insurers.
Our advice is based on the information you give us which should be up to date, accurate and complete. If you do not give us the relevant information we need to provide advice, we may refuse to proceed.
Where we agree to provide you with an ongoing review service, we will carry this out at least annually. This service will continually assess the ongoing suitability of previous recommendations. To do this, part of the annual review will require you to confirm that the information we hold about you remains accurate and up to date.
Any subsequent advice or recommendation will be based upon your stated financial objectives, acceptable level of risk and any restrictions you wish to place on the type of investments or policies you are willing to consider.
All our recommendations are justified and confirmed in writing. Unless confirmed we will not place any restrictions on our recommendations.
We are not limited in the range of lifetime mortgages we will consider for you and will look at a comprehensive range of products from across the market, but not deals that you can only obtain by going directly to a lender – unless you specifically request this.
Environmental, Social, Governance (ESG) and Sustainable investing
We hope you’ve chosen RWA because we are passionate about ethical investing, and you are too.
Current regulations say we must assess your preferences regarding ESG and Sustainability in addition and secondary to your general investment objectives, to prevent any excess portfolio risks.
We believe the consideration of ESG factors is an integral part of investment and risk management. By fully integrating and choosing to work with fund groups and companies who disclose and report clearly on these factors, we are able to fully assess the resilience and understanding of your portfolio to withstand risks or allocate capital for opportunities.
- What are Environmental factors? Natural world factors, the biosphere. This includes the interaction and use of renewable and non-renewable resources (ecosystems, biodiversity, water, minerals). Considering climate change, waste, pollution, deforestation, resource depletion.
- What are Social factors? Factors that affect lives of humans, communities, trends, management of human resources. Considering employee relations, work conditions, human rights, child labour, human rights.
- What are Governance factors? Factors involving the issues within business models, industry practices, of interest to broader stakeholder groups Considering executive pay, bribery and corruption, board diversity.
How will my preferences be assessed and how do I know if I want this applied to my portfolio?
- We will assess your general investment objectives first.
- We will provide you with ESG triage. This is factual, balanced, unbiased information on Sustainability and ESG to ensure you have the correct knowledge to determine if you wish to consider these factors in your financial planning. ESG triage is not advice, it is your decision and is about your own Sustainability preferences – and we will record your choice.
- Where you decide to implement your ESG and Sustainability preferences we will then fully explore your views and values via a more detailed Fact Find. From this information we will be able to align your overall investment objectives and your ESG and Sustainability preferences with a suitable portfolio model.
What will this cost?
At RWA we believe the consideration of Environmental, Social and Governance factors are an integral part of investment management, it is part of our Fact Finding and getting to know our clients process, so the cost is included and not an additional cost. The ongoing management costs of your recommended portfolio may vary, as it will depend on portfolio construction and fund group with or without the ESG factors considered.
Client classification
Each client with whom the firm does business is categorised to help us identify the level of regulatory protection available. We shall categorise you as a retail client from the outset as this offers you the highest level of regulatory protection. Under certain conditions your circumstances might require us to offer you Professional Client status. In this case you will lose certain protections under the Financial Services and Markets Act 2000 enforced by the FCA. This means we will not need to adhere to all of the rules as set out by the regulator in respect of financial promotions and we will not have to ensure that you understand all the risks associated with the transactions and services we provide.
In meeting your investment needs and objectives as a retail client, RWA will consider the wide range of retail investment products available, while taking into consideration various factors such as risks, including any associated with Environmental, Social and Governance (ESG) plus any Sustainability preferences you hold, costs, and the complexity of the available financial instruments.
Communications
We will communicate with you in English, both verbally and in writing. We will also meet with you face to face or on zoom, communicate verbally with you by phone or email, but not via social media. We take all instructions in writing to avoid all doubt or possible disputes. Therefore, any verbal instruction you make should be confirmed in writing thereafter.
In addition to making calls at your express invitation, we may contact you at intervals to review your investment requirements. This may involve writing, phoning or emailing you to outline possible changes in legislation or to advise you on services or investments that might be of particular interest.
Please note that we will email you from reviews@rwafinance.co.uk as well as info@rwafinance.co.uk to arrange your review meeting.
General standards
It is your responsibility to provide complete and accurate information to us and insurers when you effect your policy, throughout the life of your policy, and when you renew your insurance.
It is important that you ensure all statements you make on proposal forms, claim forms and other documents are complete and accurate. We cannot be held responsible for incorrect or incomplete data held in the event of inaccurate or non-disclosure.
If you fail to disclose any material information to us or your insurers, this could invalidate your insurance cover and could mean that part or all of a claim may not be paid.
Any advice that we give will thus be based solely on your stated objectives, acceptable level of risk, and any restrictions you may wish to place on the type of investments you are willing to consider.
It may on occasion be necessary to amend this agreement. Unless we obtain your consent, we will give you at least fourteen days’ notice of our intention to do so before conducting investment business with or for you, unless it is impracticable in the circumstances.
Conflicts of interest
In our dealings with you we consider it unlikely that we will have a conflict of interest, or material interest in the transaction, other than the receipt of fees or commission described below. If this does happen, or where we are aware that one of our other customers has such an interest, we will disclose full details to you in writing or orally before we advise you about the transaction and give you the opportunity to object.
If we make a recommendation likely to involve a transaction with or through another person with whom we have an agreement to receive goods or services (soft commission agreement) we will let you know at the time of the recommendation of any such agreement and our policy regarding them. At present we have no soft commission agreements in place.
Registration and documents
Where we arrange a life policy, pension or investment for you, the provider will produce documentation as evidence of the transaction. All investments will be registered in your name, unless you first instruct us otherwise in writing.
We will forward to you all documents of title and documents showing ownership of your investments, including policy documents and share certificates, as soon as practicable after we receive them.
Where a number of documents relating to a series of transactions are involved, we will normally hold each document until the series is complete and then forward them to you. If you prefer, we will send them one at a time. We cannot retain such title documents for whatever reason including holding them as security.
Data Protection
As you may be aware, the UK is one of the most highly regulated financial centres in the world. This legislation safeguards the interests of consumers and other persons purchasing and being advised about investments, insurance and other financial products and in use of their personal data. Against this backdrop, we are required to make certain regulatory and statutory declarations to you.
If instructed by you, we collect data during our initial and other meetings about you and your family. We will also be collecting data about you from other persons. We collect the data through notetaking and filling in of questionnaires about you and your family’s circumstances.
We may make checks with credit rating agencies to authenticate and verify your identity and credit status. We also make checks with institutions with whom you have policies of insurance and investments, and with your mortgage provider. These checks are to help us with our obligations at law and generally to ensure that we provide you with advice that suits your circumstances. The scope and extent of the gathering of information from third parties depends on what type of service you are taking from us.
Your personal information is very important to us. We will endeavour to take all due care to protect this information. We would like to highlight information that you should be aware of:
- Some services are provided to us by third parties such as processing business or obtaining compliance or regulatory advice, which warrant the disclosure of more than just your basic contact details. You agree that personal information held by us may be disclosed on a confidential basis, and in accordance with the General Data Protection Regulation, to any such third parties. You also agree that this information may be transferred electronically, and that ourselves, or any such third party, may contact you in future by any means of communication we consider appropriate at the time.
- Product providers, lenders, investment managers and administrators may administer your policy, any existing policies you may have with them, or provide other services, from centres in countries outside Europe (such as India and the USA) that do not always have the same standard of data protection laws as the UK. However, they are required to put a contract in place to ensure that your information is adequately protected, and they will remain bound by their obligations under the data protection laws even when your personal information is processed outside Europe.
How is your information used?
Primarily, we use data about you and your family’s circumstances to provide advice to you and complete transactions on your behalf. We analyse and assess your data to maintain and develop our relationships with you.
Depending on the instructions we receive from you, we may pass your data to other professional advisers to enable us to provide advice most suited to your circumstances.
Usually, this would be referrals to local accountants, solicitors, tax advisers and sometimes to specialist advisers in the financial and insurance industry where you may benefit from their expertise. We, and any specialist advisers to whom we introduce you, will pass your data to institutions if you agree to purchase or amend policies and products as part of the sales and advice process.
We will retain your data according to the statutory requirements for regulated products. For instance, if you are given specialist pension advice, the data will be retained indefinitely. If you would like details of the statutory retention periods for various product types, contact us and we will obtain the latest legal position on your behalf.
We may be required to share your data with our regulator, the FCA and other third parties including our auditors. Your data is held securely in our offices in computer-based and paper-based filing systems. We also employ a database in the Cloud which meets stringent FCA data protection regulations.
Your right to a copy of your personal data
Under current data protection laws, you have a right to obtain a copy of the personal information that we hold about you. If you believe that any information held is incorrect or incomplete, you should contact the Data Protection Officer at our usual address. Any information that is found to be incorrect or incomplete will be amended promptly.
Rights to cancel
You will be informed of your statutory right to cancel. This is normally 30 days for life and pension contracts. In some circumstances no statutory rights are granted. If this circumstance arises you will be informed in writing before any contract is concluded.
Termination requirements
You, or we, may terminate our authority to act on your behalf under these terms of business at any time, without penalty. Notice of this termination must be given in writing and will take effect immediately upon receipt of the notice. Termination will not prejudice the completion of work already initiated on your behalf or any rights or obligations already arising. A due proportion of any charges for the service provided and any disbursement shall be settled to that date.
It may on occasion be necessary to amend the Engagement Letter (where we both agree what we will do for you and what fees will be charged). Unless we obtain your consent, we will give you at least fourteen days’ notice of our intention to do so, before conducting investment business with or for you, unless it is impractical in the circumstances to do so.
Clients’ money
We do not hold clients’ money and we never own the investments that you buy through us. We never accept cheques payable to us except in settlement of charges or costs for which we have sent you an invoice. We do not handle cash.
How we take instructions and give advice
Any recommendations given to you by us shall be in writing. This aids clarification and avoids future misunderstandings. We may, at our discretion, refuse to accept instructions although such discretion shall not be exercised unreasonably.
We will record all transactions on our files which, along with copies of relevant documentation, will be retained by us for a period of not less than six years. You have a right to inspect copies of contract notes, vouchers and entries in our books or computerised records relating to your transactions. We reserve the right to withhold copies of these records if information to other parties would be disclosed.
We will never contact you or pass your details to other companies associated with us to contact you (including by telephone) with details of any other similar products or promotions without getting your express agreement first.
Later in this document you will need to give us your consent to the transfer of personal information as outlined above. While you are entitled not to do so, the practical implication is that we will find it very difficult to work together efficiently if you don’t, as all requests for information will need to go via you, and responses will need to come to us via you too.
How do we manage your instructions to trade your investments?
We do not execute any trades for you. Instead, we place trades with third parties (investment managers) who execute the trades for you. The third parties are required to have a best execution policy. This means they must take all reasonable steps to ensure that they obtain the best possible result for you. Our procedures adhere to their policies and we monitor their adherence to those policies.
Fees
We appreciate that this might look complex, but we want to be as clear and as upfront as possible about our charging structure.
Ruth Whitehead Associates does it differently; our administrative staff ratio is considerably higher than many other IFA firms. This means the telephone is answered promptly and the bespoke level of service we offer enables us to spend more time working with you.
In addition, our ongoing adviser fee provides the following service to all our clients:
- A qualified Independent Financial Adviser (IFA)
- An appointed Paraplanner who will look after you
- Whole of Market advice – this means we aren’t restricted to certain products/companies
- A review of your investments at least annually, either in person, by phone or online, which will include a meeting with your financial adviser
We offer an initial 30-minute meeting at our cost, so this is free of charge to you. However, we require at least 24 hours’ notice of any initial meeting cancellation. We reserve the right to charge pro rata at our hourly rate of £600 if less than 24 hours’ notice is given. Whether you buy a product or not, you will pay a fee for our advice and services. If we also receive commission from the product provider when you buy a product, we will pass on the full value of that commission to you in one or more ways. For example, we could reduce our fee, or reduce your product charges, or increase your investment amount, or refund the commission to you.
We will discuss your payment options with you and answer any questions you have. We will not charge you anything until you have agreed how we are to be paid. We will set out our charges separately and we will tell you if you have to pay VAT when you engage us. The Engagement Letter and these Terms of Business will form your contractual relationship with us.
Our charging structure is flexible, to best suit the work you have asked us to carry out. It is not possible to set out the many and various circumstances and services that may attach to different charging structures here, but we will agree that specifically with you in writing before we start work.
Our indicative rates for initial or discrete work
- ISA investments (including ISA top ups)– 3% initial or £600 minimum e.g. 3% of £20,000 is £600, or £600 if less than £20,000,
- Bed and ISA – 3% initial or £600 minimum e.g. 3% of £20,000 is £600, or £600 if less than £20,000,
- Investment (non-ISA) – 5% initial e.g. 5% of £250,000 is £12,500,
- Pension Switches – 5% initial e.g. 5% of £100,000 is £5,000,
- Pension top ups – 5% initial e.g. 5% of £100,000 is £5,000,
- Annuity Purchase – 3% initial e.g. 3% of £300,000 is £9,000,
- Regular Premium Investment Contract – up to nine months’ premiums/contributions e.g. 9x £150 is £1350,
- Regular Premium Pension Contract – £600 minimum per contract. The total amount will be quoted to you prior to your agreement and will reflect the complexity of the case,
- Regular Premium Insurance/Protection Contract – £600 minimum per contract. The total amount will be quoted to you prior to your agreement and will reflect the complexity of the case,
- Retirement Planning – from £1,200,
- Company Pension Reporting – from £2,500,
- Inheritance Tax (IHT) Planning – from £1,000,
- Investment written in Trust – from £1,000,
- Lifetime Mortgages (Equity Release) – from £1,000. This fee will be payable at outset. We may also be paid commission from the chosen provider which is disclosed to you from the outset.
The minimum charge for organising any product is £ 600.
Should the agreed work not proceed for any reason, you will still be liable proportionally for the work we have done, charged at our hourly rate. Figures of which can be found under this section of our Terms of Business.
Hourly rate
It is rare for us to charge an hourly rate, but we do so where clients specifically request it and it is the best value for money option for them. As a result, we are not able to give an example costing. However, we can confirm that our rates are as follows:
- Principal/Adviser £600 per hour
- Paraplanner/Administrator £300 per hour
This is charged in five-minute intervals. You may ask us for an estimate of how much in total we might charge. You may also ask us not to exceed a given amount without checking with you first. With protection contracts, the commission will be used to offset any fees due. All renewal commission will be retained as a servicing fee.
Ongoing services
Where we agree to provide an agreed service for an indefinite period, we will agree the extent, frequency and level of that service with you.
We charge 1% of the fund or a minimum of £1,500 per annum on an ongoing basis for this service. For example, 1% of £200,000 is £2,000 per annum. Anything below £150,000 will be a flat rate of £1,500 per annum, reviewed annually.
For Regular Premium Insurance/Protection Contract this is 2.5% of the ongoing premium or commission e.g. 2.5% of £90x 12(months) is £27 per annum.
We will agree charges before beginning work. Our Engagement Letter discloses all costs prior to work being completed. Charges are also outlined in an illustration from the provider, and again in the Financial Report we prepare for you.
Alternatively, you can choose one of the following:
- Fixed Price. We will agree a fixed price in advance of any work being started. This may either be payable separately or via the funds product provider.
- Hourly rate. Our hourly rate of £600 per hour is charged in 5-minute intervals.
You may ask us for an estimate of how much in total we might charge. You may also ask us not to exceed a given amount without checking with you first. With protection contracts, the commission will be used to offset any fees due. All renewal commission will be retained as a servicing fee.
Financial planning costs depend on complexity and size. We estimate that a typical case cost would be £3,750.
If you cancel a scheduled appointment with less than 48 hours’ notice, we reserve the right to charge our hourly rate.
Aggregated costs and charges
If you enter into a transaction where third parties are involved, they will charge for their services.
Typically, there will be three or four third parties involved. For example, if we placed a £250,000 investment for you the annual charges might look like this:
Third party | Percentage | Value |
Platform | 0.8% | £2,000 |
Product | N/A | |
Fund | 0.9% | £2,250 |
TOTAL | 1.7% | £4,250 |
To this you will need to add our ongoing charges, which are set out earlier. We haven’t added them here because of the flexibility in how you pay us.
At this point, this is just an example. We will confirm the aggregated costs and charges based on our recommendations in our Engagement Letter or Financial Report, which is before you sign any commitment documents. By using our services, you are making life brighter and better for the pupils of St Matthias School, refugee families at Akwaaba social centre and funding Young Dissenters’ community choir. Our Ethics in Action regularly sponsors learning and culture in our community, creating opportunities for everyone.
Complaints
It is our intention to always provide the highest quality level of advice and service.
However, if you feel you need to make a complaint, we are committed to dealing with it effectively and fairly in accordance with the FCA’s complaint handling rules and guidance. A copy of our Complaints Policy is available on our website, or you can request a copy to be emailed to you.
In the first instance, please contact us:
In writing Ruth Whitehead Associates, St Matthias Hall, Wordsworth Road, London N16 8DD
By phone 020 7254 8262
By email info@rwafinance.co.uk
If you cannot settle your complaint with us, you have the right to refer it to the Financial Ombudsman Service, free of charge, at The Financial Ombudsman Service, Exchange Tower, London E14 9SR, or by going to their website www.financial-ombudsman.org.uk.
Financial Services Compensation Scheme (FSCS)
If the FSCS judges that a firm is in default it must pay compensation to all claimants affected by the default. The limits of compensation for each complainant are as follows:
Deposits
Deposits: 100% of the first £85,000.
Home finance limits
The maximum level of compensation for claims against firms declared in default on or after 1 April 2019 is £85,000 per person per firm.
Investment limits
The maximum level of compensation for claims against firms declared in default on or after 1 April 2019 is £85,000 per person per firm.
Insurance limits
Long-term insurance (e.g. pensions and life assurance)
The maximum level of compensation for claims against firms declared in default on or after 1 April 2019 is 100% of the claim with no upper limit.
General insurance advice and arranging
- Compulsory insurance (e.g. third party motor)
The maximum level of compensation for claims against firms declared in default on or after the 1 April 2019 is 100% of the claim - Non-compulsory insurance (e.g. home and general)
The maximum level of compensation for claims against firms declared in default on or after 1 April 2019 is 90% of the claim with no upper limit.
Third party rights
This Terms of Business excludes any rights which may be conferred upon third parties by the Contracts (Third Party Rights) Act 1999. To advise you properly, we must obtain certain information from you about your financial and personal circumstances, to assess your suitability for particular products and services.
This Terms of Business is governed by and shall be construed in accordance with English Law and the parties shall submit to the exclusive jurisdiction of the English Courts.
This is our standard client agreement upon which we intend to rely. For your own benefit and protection you should read these terms carefully before signing them. If you do not understand any point please ask for further information.