Whose Products Do We Offer?

Mortgages

 We offer products in the following ‘relevant market: 

• Regulated mortgage contracts that are used for a non-business purpose

We offer a comprehensive range of first charge mortgages (including deals you can only obtain by going direct to a lender). We do not offer advice on second charge mortgages

Please note that, where you are increasing your mortgage borrowing although we do not advise on the following finance options these may be available to you and be more appropriate: 

• A second charge mortgage

• An unsecured loan

Insurance

We are an insurance intermediary that is acting on your behalf when delivering our services to you.  

We offer products from a range of insurers for Life Insurance, Critical Illness, and Income Protection products.

We only offer products from Payment Shield for Buildings and Contents Insurance.

Which Service(s) Will We Provide To You?

Mortgages

We offer an ‘advised’ sales service. This means we will provide advice and make a recommendation for you after we have assessed your specific needs and circumstances.

Insurance

We will advise and make a recommendation for you after we have assessed your needs for all non-investment insurance products listed above.

What Will You Have To Pay Us For Our Services?

Please see our How We Are Paid page for details

Who Regulates Us?

We are authorised and regulated by the Financial Conduct Authority (FCA).  Our Financial Services Register number is 450155.

Our permitted business is: ‘advising on and arranging investments, non-investment insurance contracts and mortgages’. 

You can check this on the Financial Services Register by visiting the FCA’s website https://www.fca.org.uk/register or by contacting the FCA on 0800 111 6768 (freephone) from 8am and 6pm, Monday to Friday (except public holidays) and 9am to 1pm, Saturdays.

What To Do If You Have a Complaint

If you wish to register a complaint, please contact us:

In writing: Write to:  

The Compliance Officer

Goodwill Financial Services Ltd,

98 Hollway Road,

Bristol,

BS14 8PG

By phone: Telephone 01275 892136.

If you cannot settle your complaint with us, you may be entitled to refer it to the Financial Ombudsman Service.

Are We Covered By The Financial Services Compensation Scheme (FSCS)?

We are covered by the FSCS.  You may be entitled to compensation from the scheme if we cannot meet our obligations.  This will depend on the type of business and the circumstances of the claim.

Mortgages

Mortgage advising and arranging is covered up to a maximum limit of £85,000.

Insurance

Long term insurance benefits (e.g. Life Assurance). The maximum level of compensation for claims against firms declared in default is 100% of the claim with no upper limit.

General Insurance

General insurance advice and arranging is covered for 90% of the claim with no upper limit.

Protection is at 100% where claims arise in respect of compulsory insurance (e.g. employer’s liability insurance), professional indemnity insurance and certain claims for injury, sickness or infirmity of the policyholder.

Protection is at 90% where claims arise under other types of policy with no upper limit.

Further information about compensation scheme arrangements is available from the FSCS (www.fscs.org.uk)

Investment Services

Goodwill Financial Services Ltd (hereinafter referred to as ‘the firm’) is permitted to advise on and arrange (bring about) deals in investments.

We are an intermediary that is acting on your behalf when delivering our services to you.

With regard to investments which we have arranged for you, these will not be kept under review unless we agree that this is a service we have agreed to provide, but we will advise you upon your request. However, we may contact you in the future by means of an unsolicited promotion (i.e. where you had not expressly requested it) should we wish to contact you to discuss the relative merits of an investment or service which we feel may be of interest to you. 

The firm does not handle clients’ money.  We never accept a cheque made payable to us or handle cash (unless it is payment in settlement of adviser charges or disbursements for which we have sent you an invoice).  If you do send us money, this may delay your transaction as we may have to return this money to you.

Regulatory Status

The firm is authorised and regulated by the Financial Conduct Authority.  Our Financial Services Register number is 450155. 

You can check this on the Financial Services Register by visiting the FCA’s website – https://www.fca.org.uk/register or by contacting the FCA on 0800 111 6768.

Client Categorisation

Unless you receive confirmation in writing to the contrary, in all our dealings on investment matters you will be treated as a Retail Client. This means that you are afforded the highest level of protection under the regulatory system and should have the right to take any complaint to the Financial Ombudsman Service (FOS).

Where we have categorised you other than as a ‘retail client’ you may request re-categorisation under a client category which benefits from a higher degree of protection.  However, we reserve the right to agree to such a re-categorisation on a case-by-case basis, and where we agree to do so it does not necessarily mean that you will have a right of access to the Financial Ombudsman Service.

Further information in respect of the Financial Ombudsman Service is available on their website at the address below

http://www.financial-ombudsman.org.uk/

Which Service(s) Will We Provide To You?

We will advise and make a recommendation for you after we have assessed your needs.  We only offer advice on limited types of products.  You may ask us for a list of the products we offer.

Conflicts of Interest

The firm offers advice in accordance with that described herein.  Occasions may arise where we or one of our other clients have some form of interest in business being transacted for you.  If this happens or we become aware that our interests, or those of one of our other clients, conflict with your interests, we will write to you and obtain your consent before we carry out your instructions, and detail the steps we will take to ensure fair treatment.

Termination of Authority

You or we may terminate our authority to act on your behalf at any time, without penalty.  Notice of this termination must be given in writing and will take effect from the date of receipt.  Termination is without prejudice to any services already provided/transactions already initiated, which will be completed according to the Client Agreement unless otherwise agreed in writing.  You will be liable to pay for any transactions made or carried out prior to termination and any adviser charges or other fees which may be outstanding.

Right To Withdraw

In the case of many retail investment products – such as life assurance contracts, personal pension schemes, investment bonds, and collective investment arrangements (e.g. unit trusts), a right to withdraw or cancel the contract within a specified period is normally provided.  Details of such rights are ordinarily contained in the product literature (e.g. Key Features Document) and/or we may provide details of such rights in a separate communication. 

In the case of any non-retail investment products e.g. an ISA wrapper, we will inform you in writing of any right to withdraw or cancel you may have or, if it is the case, we will inform you in writing that no such rights will apply.

Client Risk

You are advised that, because investments can fall as well as rise, you may not get back the full amount invested.  Past performance is not a guide to future performance.

What Will You Have To Pay Us For Our Services?

You will pay for our services on the basis of an adviser charge, a fee, commission, or a combination of these

We will discuss your payment options with you and answer any questions you have.  We will not charge you until we have agreed with you how we are to be paid.

We will discuss with you the basis of our charges, based on the types(s) of work we are asked to undertake for you when you will have to pay our fees, both initial and ongoing.

All fee amounts quoted below are exclusive of VAT, expenses and disbursements; these will be added to the invoice if applicable. 

Advised services

For our advised services, you will pay us via an adviser charge.

Initial advice service

Our initial advice will be appropriate for you, based on your requirements and circumstances at that time.  We will not ensure that any initial advice remains suitable for you at a later date, unless you select to receive ongoing services from us.

Ongoing services

In addition to our initial advice services, you could ask us to undertake further services on an ongoing basis.  Details of any ongoing services that we offer are detailed later within this document. 

You may at any time cancel an ongoing service by serving your notification of cancellation to us in writing. Upon receipt of your cancellation notice for an ongoing advice service we will arrange for any future payment of any associated charges to cease.

Our typical adviser charges are noted below.  The exact amount may be more or less than this, but will be specifically agreed with you based on the work you ask us to do for you. 

If we do not agree a fixed adviser charge with you at outset, you may ask us for an estimate of how much in total we might charge for any service(s) provided.  You may also ask us not to exceed a given amount without checking with you first.

The Cost of Our Services

Payment for initial advice services

Before we provide any services to you, we will gather information about your circumstances and needs. 

We will not make a charge for this.

Once you have agreed to act upon our recommendation:

For a lump sum investment (OEIC, ISA, Pension, Bond), we make no initial charge. We derive our income from the fees you pay us for the ongoing services we provide and these are explained in the next section below.

Payment for ongoing services

There will be a charge for any ongoing work, such as periodic or ongoing reviews we carry out on your behalf. We will confirm the rate, frequency and length of any ongoing service(s) before commencing that ongoing service.       

Ongoing services offered:

• Ongoing meetings

• Reporting

• Investment monitoring and review

• Contact

• Administration

• Professional services

More details on the services we offer will be provided separately.

Example:

How much our ongoing charges might cost if based on a percentage of fund value:

Based on a fund value of £100,000, an ongoing charge of 0.50 % of this amount would mean that it would cost £500 per annum to provide an ongoing service (£100,000 x 0.50 % = £500).  If the fund value increases over time, the ongoing charge then increases accordingly. Conversely, if the fund value decreases over time, then the ongoing charge will reduce.

Your payment options

Payment by Fee

You will be required to settle the payment of your adviser charge on completion of our work within 30 business days.  We accept cheques.  We do not accept payment by cash.  You will be provided with a receipt upon payment.

OR

If you buy a financial product, you can choose to have your adviser charge deducted from the product through instalments.  Although you pay nothing to us up front, that does not mean that our service is free.  You still pay us indirectly through a deduction from the amount you pay into your product. This deduction will reduce the amount left for investment.      

How your regular payment plan could work:

Total monthly premium payable £300.00Total cost of advice over a year (approx.)  £1.50Amount invested£298.50

Aggregated Costs and Charges

We will provide you with an Aggregated Costs document in relation to certain investment types. This will provide you with information on the total costs to you of the financial products and services that have been recommended for these investment types and illustrate the impact of those costs on your investment returns.  This will include all third party product and service costs as well as our firm's own adviser charges. This will be provided to you before any investment transactions take place and on an ongoing basis where you have selected to take ongoing services.

Information about other costs and associated charges

There may be other costs, including taxes, that are payable through other parties (such as the product provider) that we may not be party to. Such charges are normally disclosed in relevant third party documentation, for example a Key Features Document.

Accounting To You

We will confirm to you in writing the basis or our reason for recommending the transaction executed on your behalf.

We will also make arrangements for all your investments to be registered in your name unless you first instruct us otherwise in writing. We will forward to you all documents showing ownership of your investments as soon as practicable after we receive them; where a number of documents relating to a series of transactions is involved, we will normally hold each document until the series is complete and then forward them to you.

Investment Objectives & Restrictions

Any subsequent advice or recommendation offered to you will be based on your stated investment objectives, agreed level of risk you are prepared/able to take and any restrictions you wish to place on the type of investments or policies you are willing to consider. Details of your stated investment objectives will be identified during our discussions with you and confirmed within the suitability report that we will issue to you to confirm our recommendation(s). Unless confirmed in writing, to the contrary, we will assume that you do not wish to place any restrictions on the advice we give you.

Nominee & Safe Custody Services

We do not safeguard or administer client assets but we may arrange business through the Transact platform in line with our business model. Transact will provide custody services for your assets. Where this is the case, the legal title of investments will be registered in the name of the third party’s nominee.

Transactions will be transmitted to the investment wrap platform, for them to execute.  Money or transferred assets will be placed immediately with that third party for investment – we will never hold the assets for you. We will provide you with the relevant account opening details for the identified third party such as their Terms & Conditions, Nominee and Safe Custody Service, and on request their Best Execution Policy, Execution Venues and Conflicts of Interest Policy (or equivalent documents). The legal title of investments will be in the name of the third party’s nominee.

For non-platform business we will make arrangements for your investments to be registered in your name unless you first instruct us otherwise in writing.

Best Execution Policy

It is in the interests of our clients and the firm that we obtain the best possible result when placing orders with other firms (e.g. third party brokers) for the execution of client orders or when transmitting orders on behalf of clients for particular investments – e.g. shares.  We are required under the Rules of the Financial Conduct Authority to take all reasonable steps to provide ‘best execution’ when carrying out such transactions. 

Where we place or transmit orders for such investments on behalf of our clients, we may utilise the services of a third party broker and base our decision to place or transmit an order on the price and cost of execution of the order.  For orders in collective investment schemes (e.g. unit trust), however, the price of units or shares in the scheme is normally set by the scheme operator or manager and as such we have little influence over the price available. 

Full details of our best execution arrangements are provided in our Best Execution Policy, a copy of which can be provided on request.

Mode Of Communication

We will enter into communication with you through whatever means are convenient to you including face-to-face, telephone, paper, e-mail and other acceptable electronic communication methods. This information will be provided free of charge.

Our communications will ordinarily be in English both in respect of oral and written communications.

You may, at any time, choose to request information that has previously been provided to you by means other than paper, in paper form and free of charge. For example, where a communication was originally sent by email.

You may at any time choose to change your preferences as to how we communicate with you. However, where you choose to do this, we will require you to confirm this change in writing to us.

What To Do If You Have a Complaint

If you wish to register a complaint, please contact us:

In writing: Write to:   

The Compliance Officer

Goodwill Financial Services Ltd,

98 Hollway Road,

Bristol,

BS14 8PG

By phone: Telephone 01275 892136.

If you cannot settle your complaint with us, you may be entitled to refer it to the Financial Ombudsman Service.

Are We Covered By The Financial Services Compensation Scheme (FSCS)?

We are covered by the FSCS. You may be entitled to compensation from the scheme if we cannot meet our obligations.  This depends on the type of business and the circumstances of the claim. 

Investments

Most types of investment business is covered up to a maximum of £85,000.

Investment based insurance/Long term insurance provision e.g. pensions and investment bonds

The maximum level of compensation for claims against provider firms declared in default on or after the 3rd July 2015 is 100% of the claim with no upper limit. Further information about compensation scheme arrangements is available from the FSCS (www.fscs.org.uk).

Data Protection

Please refer to the separate Privacy Notice that that sets out how we collect and use data about you. 

Whose 'Buy-to-Let' Mortgages Do We Offer?

We offer a comprehensive range of buy-to-let mortgages from across the market 

Which Service Will We Provide To You?

We will advise and make a recommendation for you after we have assessed your needs.

Alternatively, you will not receive advice or a recommendation from us. However, we may ask some questions to narrow down the selection of products that we will provide details on. You will then need to make your own choice about how to proceed.

Please note that our ’Buy to Let’ service is restricted to helping you arrange a suitable mortgage. We will not advise you about whether or not the property you plan to buy and let out to tenants, will turn out to be a sound investment.

Regulatory Position

In most cases, advising on and arranging buy-to-let mortgages is not regulated by the Financial Conduct Authority. 

If either yourself or a close relative intend to occupy the property being mortgaged, either now or in the future please advise us immediately as the mortgage is likely to be regulated by the Financial Conduct Authority and we will need to provide you with a different initial disclosure document regarding our mortgage services.

Following our initial discussions regarding your circumstance we will have identified that either:

• You are looking to arrange a buy-to-let mortgage in respect of a property you have previously resided in, and that you do not own any other rental properties. We will therefore treat you as a Consumer Buy-to-Let mortgage (CBTL) customer

A consumer buy-to-let mortgage is defined as a buy-to-let mortgage which is not entered into ‘by way of business’

A buy-to-let mortgage will usually be treated as a consumer buy-to-let mortgage if you (or a close relative) have, at any point, lived in the property (unless you already own other rental properties).

Buy-to-let mortgages are not regulated by the Financial Conduct Authority (FCA), however there are some additional protections for consumer buy-to-let mortgages customers.

We are supervised by the Financial Conduct Authority (FCA) in respect of any Consumer Buy-to-Let mortgage activities we conduct and are required to comply with the conduct of business requirements set out in the Mortgage Credit Directive Order [2015]. Our FCA registration number is 450155. 

You can check this on the Financial Services Register by visiting the FCA’s website https://www.fca.org.uk/register or by contacting the FCA on 0800 111 6768 (freephone) from 8am and 6pm, Monday to Friday (except public holidays) and 9am to 1pm, Saturdays.

Please note that we offer independent advisory services in respect of consumer buy-to-let mortgages

Or,

• You are looking to arrange a buy-to-let mortgage in respect of either:

• A new property being purchased for the sole purpose of being let, or

• An existing property that neither yourself (or a close relative) have previously resided in, or

• An existing property which either yourself (or a close relative) have previously resided, but you own another property let subject to a rental agreement and/or on which there is an existing buy-to-let mortgage

In these circumstances you will deemed to be taking out a buy-to-let mortgage ‘by way of business’.

What Will You Have To Pay Us For Our Services?

Please see our How We Are Paid page for details.

What To Do If You Have a Complaint

If you wish to register a complaint, please contact us:

In writing: Write to:  

The Compliance Officer

Goodwill Financial Services Ltd,

98 Hollway Road,

Bristol,

BS14 8PG

By phone: Telephone 01275 892136.

If you cannot settle your complaint with us, you may be entitled to refer it to the Financial Ombudsman Service.

The Financial Ombudsman Service will not consider complaints in respect of Buy-to-Let mortgages entered into ‘by way of business’

Are We Covered By The Financial Services Compensation Scheme?

Our ’Buy-to-Let’ mortgage services are not covered by the Financial Services Compensation Scheme, except if they are regulated by the Financial Conduct Authority (as explained in Section 3 of this document).

Where the business is regulated by the FCA mortgage advising and arranging activity is covered up to a maximum limit of £85,000.

Further information about compensation scheme arrangements is available from the FSCS (www.fscs.org.uk).