The Professional Insurance Broker The official magazine of the Professional Insurance Brokers Association Issue No.6 - Autumn 2004

Learning for Life!

Our Commercial Priorities – What You told Us

Money laundering – How does it Affect us? Chairman’s Remarks

Welcome to the autumn issue of The Professional PIBA is delighted to announce that we are nominating Insurance Broker magazine. It has been an extremely John Hogan, PIBA Committee member, as a busy quarter for PIBA and there have been a number of representative on the new statutory Insurance recent regulatory developments that will impact greatly on Ombudsman Scheme. Diarmuid Kelly, PIBA CEO, and the way Brokers conduct their business. Liam Carberry, PIBA Committee member, have been put forward as candidates for the Industry Consultative Panel. PIBA has welcomed the publication of the Joint These appointments have become available under the Oireachtas Committee on Enterprise and Small Business’s above mentioned Act. Second Interim Report on Reforms to the Irish Insurance By Terry Hardiman market. This report supports PIBA’s efforts to bring back You may have noticed the high number of articles that the term ‘Broker’, which is the term most readily refer to pensions. This was set to coincide with National understood by the general public. We hope that this will Pensions Awareness week, which is running from the be reflected in the new codes of conduct currently being 13th – 19th of September. Brokers need to play an active drawn up by IFSRA. role in promoting pensions to ensure their clients have adequate funding at retirement. As our members must now be aware through our system of constant updates, the President signed the CBFSAI Bill I hope by now everyone has had an opportunity to have No. 2 on the 5th of July. Most of the provisions of this a summer break and as the end of the year quickly Act came into force on the 1st of August. Mortgage approaches I wish you every success for the balance of Brokers now have a stricter compliance regime to adhere 2004. to from the 1st of January next year. Contents

Pg. 6 Learning for Life!

Pg. 7 Brokers welcome second interim Oireachtas report on Insurance Reform

Pg. 10 Tax Planning can Save you a Fortune when Purchasing Property

Pg. 12 Approved Retirement Fund

Pg. 14 Self Administered Pension Schemes

Pg. 15 Our Commercial Priorities – What You told Us

Pg. 18 AGM

Pg. 20 Meet Hugh Sheriden

Pg. 22 Football Crazy!

Pg. 23 Professional Indemnity – do Brokers need this cover?

Pg. 25 A Mortgage Client, a Client for Life

Pg. 27 Money laundering – How does it Affect us?

Pg. 30 Designing a website – What you Need to Know

Pg. 31 A Pension built on Sound Foundations

Pg. 33 Stand – alone PRSA AVCs Editorial

The recent inspector’s report into the practices and activities pursued by NIB during the 1990s, together with the ongoing IFSRA investigations into more contemporary practices engaged in by AIB, bring into sharp focus the need for a resolute and independent financial regulator.

Some of our fellow travellers within the industry have persisted in the myth that the bigger the institution the more compliant they were in the practices that they engaged in. This was alleged to be supported by the sophisticated (according to them) internal audit and compliance controls that they had in place. The publication of the reports exposes this position as at best misleading and self-centered in its pursuit of maintaining the status quo.

The practice of allowing a significant lead-in time in the notification of regulatory inspections to large financial institutions appears at odds with the potential regulatory risk that they pose. This is in direct contrast to the minimal notification generally advised to the smaller regulated firms. It is also inconsistent with the conclusion that can be legitimately drawn from the reports: that is, the previous regulatory system, as operated, simply did not work.

Similarly, the self-regulatory environment that operated in certain quarters prior to the Investment Intermediaries Act, 1995, was shown to be totally inadequate in protecting the consumer. The exposure of activities in both MMI and Morrogh merely reinforces the view held by a large number of persons engaged in the business that the more money is involved, the greater is the likelihood of wrongdoing. Opportunities to flout regulations have always been availed of by unscrupulous persons in positions of authority, particularly where a large financial incentive is available.

The position as consistently espoused by PIBA has always been that the cost of regulation should be directly proportionate to the risk posed across the industry. PIBA has always put forward the argument that those who present the higher risk should pay pro rata for the cost of that risk.

IFSRA has shown itself to be capable of rising above the old historic practices that have dogged the industry in the past. It has also shown itself to be more than capable of both acting as well as talking tough when required.

I fully expect that going forward IFSRA will prove to be above the vested interests that currently prevail. The real necessity required to restore consumer confidence in financial services is complete transparency in the regulatory process. The consumer expects that regulation and its enforcers should strike an appropriate balance between the larger institutions on the one hand and the body of retail intermediaries on the other.

I wait with interest to see what actions both IFSRA and the Office of the Director of Corporate Enforcement propose to take with regard to the individuals and activities exposed in recent reports.

Committee Members Sub-Committee Chairmen Terry Hardiman Chairman Tommy Coyne Vice-Chairman Life/Business Development Liam Carberry John Hogan Secretary General Derek Fitzgerald Gary Ellison Treasurer Mortgage Tommy Coyne Derek Fitzgerald Legislation John Hogan Donal Aitkins Liam Carberry Niall Lynch John Millett Chief Executive: Diarmuid Kelly

The Professional Insurance Broker

32 Greenmount Office Park, Harold’s Cross, Dublin 6w ● Tel: 01 4020250 ● Fax: 01 4736920 ● e-mail: [email protected] ● Website: www.piba.ie Chief Executive: Diarmuid Kelly Editorial Group: John Millett, Derek Fitzgerald, Liam Carberry, Lisa Gillett and Tim Ryan Editor: John Millett Publisher: Tim Ryan Communications, 69 Fitzwilliam Square, Dublin 2 Tel: 01 6624649 Design: Design Room Tel: 01 497 9022 Views expressed by contributors or correspondents are not necessarily those of PIBA or the publisher and neither PIBA nor the publisher accept any responsibility for them.

The Professional Insurance Broker 5 Learning for Life!

By Bryan Johnston, a consultant and trainer in the Financial Services Industry, and ex- director of the LIA. Bryan also designed the PIBA Financial Advisors Assistant course.

As an enthusiastic young newly-appointed sales inspector in the consumers becoming better and better educated, we need to early 1980s, I spotted a new Brokerage on the Rathfarnham Road make sure our knowledge and skills are up to scratch. It certainly one afternoon. Keen to boost my panel, I decided to drop in and looks like the QFA qualification will play a key role for all involved introduce myself and my company. in financial services.

I was well received and delighted to see that there were three It may well also be the case that if you have a given number of Brokers available to see me. years experience, you will not be expected to fulfil whatever the final mandatory educational requirements are for all new entrants. The meeting started off well until I started to wax lyrical about our fantastic new life and savings plan. I was quizzed about various However, there are huge benefits for you to consider taking the technical aspects of the product and it very quickly became clear QFA course. I have helped many sit and pass these exams, that I lacked a lot of basic knowledge. I was asked to leave and including members of PIBA. If you are keen to take this course come back when I had a proper understanding of what I was but worried for any reason, please contact me and I will be selling. I left with my tail between my legs and my ego delighted to chat through your concerns. considerably bruised. It was a very painful experience! Some of the main benefits of the QFA course Consultation Papers include: IFSRA are busy on the education and competency front. They ➤ It’s practical - all four books relate to day-to-day business. Every currently have two consultation papers on education. The first Broker that has studied the course has found that it has helped paper is on mandatory competency requirements for people develop his/her business and confidence. Many also use the working in financial services. They are examining what books as an invaluable reference source. qualifications people entering and those already in the business ➤ It’s up to date. Courses are updated after the Finance Act each should have. In addition, part of the Insurance Mediation Directive, year and any other changes in legislation or trends are included. which must be enacted by the 15th of January next year, For example, there will be a new chapter on consumer credit addresses the area of knowledge and competence. added this year. You can check out the consultation paper on the web at ➤ It’s accessible. From October this year, five tutorials per book www.ifsra.ie and the responses from various interested bodies, will be included. Tutorials will be held in Dublin, Cork, Galway, including the joint submission made by LIA Ireland, the Institute of Waterford and Letterkenny in the evenings and on Saturdays. Bankers of Ireland and the Insurance Institute of Ireland. I was ➤ There will also be full day refresher courses and options for delighted to see that this joint submission also included input and personal coaching and distance learning in the comfort of support from PIBA, the IBA and IMAF. your own home. The second and more recent consultation paper IFSRA has is ➤ Exams are also held at regular intervals. ‘Financial Planning Education for Consumers’ (CP5). A major part ➤ It gives personal satisfaction. One of the highlights in November of IFSRA’s strategy is “to help consumers make informed choices every year is the Graduation ceremony. Pass the QFA and you through education and codes of practice in a fair financial services will be invited along with your family to a very elegant market”. IFSRA has already started this process with ‘It’s Your ceremony in UCD, Belfield. Money’, an initiative that gives consumers free advice on financial ➤ It meets regulation and consumer demands. Consumers may services. want to know that they are dealing with a qualified Broker. ➤ Structured Approach It’s a step to further qualifications. The QFA can now lead to a degree in the form of Bachelor of Financial Services awarded by IFSRA is now looking to develop a more detailed and structured UCD. approach to financial planning, starting in primary school and running all the way through to 3rd level education. Continuous Professional Development

However, IFSRA is not the only one advocating education for Those who have the QFA qualification, along with those who consumers and investors. might be excused sitting the QFA by way of experience in the business (grandfathering), are expected to undertake a minimum The Motley Fool has been educating consumers for some time number of study hours each year to keep up to date. There are through its website, www.motleyfool.com, and its many many formal CPD events organised each year and informally there publications. are lots of ways to keep your knowledge and skills honed. Many other books, including one of this year’s bestsellers, ‘The New Investor’s Toolbox’, puts education as its number one The benefits of lifelong learning are many. foundation for successful investing. But back to my experience on the Rathfarnham Road. One of the So whether it is mandatory competency requirements or Brokers there that fateful day for me was your Chairman, Terry Hardiman! I still owe him!

6 The Professional Insurance Broker Terry Hardiman, Donie Cassidy TD, Chairman of the Joint Oireachtas Committee on Enterprise and Small Business and Diarmuid Kelly at Leinster House for the launch of the report Brokers welcome second interim Oireachtas report on Insurance Reform

The Joint Oireachtas Committee on Enterprise and Small draw attention publicly to the emerging difficulty. Business launched their second interim report on Reforms to ➤ Insurance companies should be required to remind policy the Irish Insurance Market on the 17th of July 2004. holders of the renewal date two months prior to renewal and to submit a quotation to the policy holder one month prior to PIBA has continuously lobbied for the return of the term the renewal date. ‘Broker’, which is easily and readily understood by all members ➤ of the public as someone who can offer choice in the IFSRA should make regulations to permit Insurance Brokers, marketplace. We warmly welcome the suggested return. subject to a competency test, to deal on behalf of their clients with any insurance company and the term "authorised advisor" should be discontinued. Firms that presently call The key recommendations are themselves "Insurance Brokers" and who do not qualify Through a wide ranging series of recommendations, the report under the competency test should be required to call proposes that the following twelve key recommendations be themselves "Multi Agency Intermediaries". implemented - ➤ IFSRA should carry out a fundamental review of the insurance Broker market with a view to substantially improving the ➤ The Departments of Finance and Justice, Equality and Law operation of that market, particularly in relation to Reform should remove any impediment to the impounding transparency for the consumer. of uninsured vehicles by An Garda Siochána. ➤ Random breath tests for drink driving should be introduced. Commission vs. Fees ➤ The National Curriculum Council should introduce road safety instruction to the second level school curriculum as a matter The Committee proposed that IFSRA should consider the issue of urgency. of whether Brokers should operate on a fee only basis. IFSRA ➤ The Government should give priority to the speedy told the Committee that it wanted to make sure that enactment of the Road Traffic Bill and the Driver Testing and commissions are structured in such a way that products are Standards Authority Bill. sold appropriately and that the incentive structure works in ➤ The new Safety, Health and Welfare at Work Bill should be favour of consumers. passed by the Oireachtas as soon as possible. The Committee examined evidence that showed that Broker ➤ The Competition Authority should publish its final report on commission levels in Ireland are substantially lower than in the insurance market as soon as possible and not later than other European countries. It also argued for keeping the end of October 2004. commission as it is not subject to VAT (an extra expense which ➤ The Irish solvency requirements for new entrants should be is inevitably passed to the consumer), whereas VAT is payable exactly the same as for existing market participants. on fees charged by Brokers.

The report states that “provided the policyholder is fully aware And those which will impact the most on of the levels of commission paid by insurance companies to Brokers are Intermediaries, there would seem to be no fundamental ➤ Irish solvency requirements should be no higher than the reasons for the elimination of the commission system”. PIBA norm required by EU regulation. members already disclose commissions and fees on the life ➤ IFSRA should monitor the level of insurance capacity in the side so disclosure on the general side should not cause too Irish market and, where there is a lack of capacity, should much confusion.

The Professional Insurance Broker 7 MAI and AA Brokers in making renewal information available. ➤ Where there are competing Brokers, insurers must satisfy PIBA are delighted with the progress made so far with the themselves that the new Broker has authority from the client to reintroduction of the term Broker. In line with IFSRA’s plain English obtain confidential information about the policy. campaign, bringing back an easily understood term will enable the consumer to understand financial services better and therefore choose a service best suited to their needs. The AA and MAI What comes next? categorisations have caused widespread confusion not only with the The Joint Committee is to review the Competition Authority report in public in general but it has also manifested itself in research projects relation to Brokers and consider this issue further when the final undertaken by government departments. report is published by the end of October.

Other Recommendations Finally, the report noted that in the Irish market, there is only a small number of significant insurance companies. Insurance Brokers, they ➤ There should be no production quotas established by any noted, are therefore an important positive force for competition. insurance company that might inhibit or prevent Brokers from Brokers can also access insurance companies in other giving independent advice to their clients. jurisdictions/states and provide an attractive, low cost entry vehicle for ➤ Insurance companies should not discriminate against competing insurers registered outside Ireland.

At the launch of the Oireachtas report on insurance reform were (l - r): Donie Cassidy TD, Chairman of the Joint Oireachtas Committee John Hogan, Derek Fitzgerald, Donie Cassidy TD, Conor Lenihan TD, speaking at the launch of the report Terry Hardiman and Diarmuid Kelly

The Chairman of the Joint Oireachtas Committee on Enterprise and Joint Oireachtas Committee member Brendan Howlin TD Small Business, Deputy Donie Cassidy discusses the report with answers a question at the launch Committee member, Deputy Conor Lenihan.

Pictured at the gates of Leinster House were (l - r): John Hogan, Deputy Kathleen Lynch, Diarmuid Kelly, Deputy Phil Hogan, Terry Hardiman, PIBA Chairman Terry Hardiman and Cork North-Central Deputy Katleen Derek Fitzgerald and Deputy Gerard Murphy. Lynch (Lab) at the launch of the Insurance report.

8 The Professional Insurance Broker Tax Planning can Save you a Fortune when Purchasing Property

Financing property deals in a tax efficient manner can save owner-managers considerable amounts of money, writes Alan Brennan, Senior Wealth Manager, ACCBank

What do you do when you are considering new or reviewing to take personal benefit from the property (and you will at existing property finance? some point) you will face a staggering double tax hit on the proceeds which will decimate the real value of your ➤ Shop around for the best interest rate in the market? investment. ➤ Source the highest level of value / debt ratio appropriate to your needs? This is because when you come to retire and access funds, ➤ Negotiate bank arrangement fees? the company will sell the property and suffer a 20 per cent ➤ Negotiate legal fees? CGT/CT hit. The company will then have net funds on its balance sheet and for the individual to access this he/she While these are not only common, but very important, will either pay marginal rate income tax and PRSI and levies steps, it is equally important for business owners to make OR, in the context of the liquidation of the company, a the structure and method of loan repayment efficient. In further 20 per cent CGT hit. other words, optimise your personal cash flow and the all important personal tax position. Interest Only Finance Personal Ownership Regardless of how good a deal you strike with a bank the common method of loan repayment is by making a regular Unless you are a trading property developer, it is generally installment, which is made up of a combination of interest understood that the most sensible way of owning property charged and loan capital. In the early years, the installment is in your own name. However, many business owners have is mostly interest (tax efficient) and, in the later years, loan put property into a company name, generally for short-term capital (not tax efficient). In real terms, you are throwing reasons such as reduced stamp duty, personal cash flow away valuable tax breaks with every year that passes. And considerations and short-term personal tax issues. you can never get them back. But, in the long term, this method carries a heavy price and Setting up your loan on an interest only basis will have the it is possible to achieve many of these benefits under effect of keeping tax deductable interest constant personal ownership with the right planning. throughout the term (albeit that you will pay a higher When a company owns property and you eventually come amount of interest). With capital and interest mortgages, the interest is front-loaded and, as the loan matures, the

10 The Professional Insurance Broker interest (tax deductable) portion decreases and takes with it that the allowances can be offset against all other income the tax break. (besides rental income) up to a maximum of ¤31,750 per annum. Investors should ensure that they have sufficient Therefore, an interest only loan will allow you to maximise and income taxable at the marginal rate of tax to obtain the keep constant the tax efficiency throughout the term and maximum tax relief. make the most of one of the few tax breaks left. In addition there are also Section 23 properties still available Loan Capital Repayment for investment. As was just mentioned, reducing the capital sum outstanding As with all property investment, each project should be looked to the bank is not tax efficient. However, for business owners at from a commercial point of view. Investment should not be there is a way to make it so. You should have guessed it by made purely for tax purposes. now as it is one of the few ways left to take money from your company without the tax heartache of losing 47 per cent in Commercial Property Syndicates the process. One of the most common ways for private Irish investors to Pension payments made by your company immediately participate in the commercial property market is by way of become personal assets and, as such, pension contributions syndication. are one of the few ways to obtain company money for The idea and the structure of a property owning syndicate is personal benefit without having to pay income tax. Using quite straightforward. A number of individual investors group pension contributions to provide for repayment of capital together and with their combined buying power are able to effectively gives you a tax break on loan capital repayments. purchase property in lot sizes that would be beyond their This basic principle is the key to a personal tax and personal individual means. Typically, 75-80 per cent of the purchase cash flow solution that you would be crazy not to investigate if price is frequently funded by bank debt, with the rent from the you are a business owner with property investments. property being used to pay the interest, and any surplus being applied to the outstanding loan.

The Results The ownership and control of the property is typically ➤ Your property investments are in your personal name. governed by a co-ownership agreement. Each investor will ➤ Rent from property will cover interest only payments and own a proportion of the property, pro rata to his or her equity other expenses (no personal cash flow cost or tax cost if stake, and the agreement will usually provide that the action of they match). one co-owner will not bind the others. The agreement will ➤ Your trading company looks after the loan repayment (no cover decision-making (on rent reviews, sub-lettings, personal tax or cash flow cost). appointment of managing agents and so on) and will also set ➤ Your company saves money as it can keep its rental out an exit strategy. There should be provision for individual payments to you down compared to the common capital investors to exit early by offering their stake to their co-owners, and interest method. This saving is quite significant and or alternatively selling it in the market. equates to between 50 per cent and 100 per cent of the The attraction of property investment syndicates is the amount borrowed over the loan term. opportunity to participate in the ownership of prime, institutional quality property for an affordable entry cost, whilst Property Investment Tax Breaks retaining an involvement in the control of the important Tax breaks are still available on certain property investments. decisions of the ownership of the property. With the ability to Most notably, these include investments in nursing homes, invest pension money bringing an added dimension, property hotels and holiday cottages. syndicates are likely to form an increasingly important part of investors' portfolios in the years to come In terms of hotels and nursing homes, there is a 15 per cent tax break on your capital allowance in the first six years and 10 per cent in the seventh, while it is 10 per cent per annum Pamela O’Donoghue, Tax Manager, Anne Brady & Associates, over 10 years for holiday cottages. and Andrew Watt, Director, Finnegan Menton also contributed Investments in nursing homes also offer additional benefit in to this article.

The Professional Insurance Broker 11 Approved Retirement Fund

James Skehan is Pensions Sales Manager of New Ireland Assurance.

Approved Retirement Funds - ARFs 1. They can follow the traditional route, taking a tax-free lump sum of up to 1.5 times their final salary. If they decide to Prior to 1999 and the introduction of ARFs, life was take this tax-free lump sum, they must use the balance of straightforward for individuals who reached retirement age and the fund to purchase an annuity and the ARF route is not for their advisors. The vast bulk of retirees came from defined an option. benefit schemes and frequently the only choice they had to 2. Alternatively, they can decide to take up to 25% of the make was whether to take their benefits in full as a pension or accumulated fund tax-free and with the remainder then to take the tax-free lump sum and a reduced pension. follow the ARF route. The Broker’s role was to inform the individual of the options Individuals can also follow the ARF route in relation to any AVC and once these had been decided, to arrange for the purchase funds they have built up. Again it is important to bear in mind of the annuity on behalf of the Trustees and/or individual. that for employees, the tax-free lump sum they can take at Having secured the most appropriate annuity rate in the retirement (in total between all the schemes they are market and set up the pension, the Broker’s work was finished. contributing to) is 1.5 times their final salary subject to 20 years service being completed. The Pensions Explosion In advising employees, care is needed particularly where the Since the period 1999-2002 a significant amount of pension main scheme benefits are on a defined benefit basis. One of legislation change has taken place in our industry. One of the the exercises which needs to be completed is a comparison as most important of these changes was in the treatment of to the amount of pension which needs to be exchanged in retirement benefits resulting from the 1999 and 2000 Finance receipt for a tax-free lump sum and whether it would be better Acts. to maximise the tax-free lump sum from the AVC fund. This resulted in transforming the approach that Brokers should take to retirement planning advice. Brokers need to take stock Are Annuities Dead? of their position in the “advice chain” and review their With the ability to transfer your ARF retirement fund to your approach to both the advice they give, and its duration. dependants after you die there has been a lot of focus on this Before the new ARF options became available the relationship option. However it is critical not to lose sight of the valuable with the client and the extent of the advice given terminated role that annuities still have to play in the whole area of once the pension had been purchased and set up. With the retirement planning. new ARF options, the retirement date will in many cases be Annuities for years catered adequately for the retirement simply a stop along the journey rather than the final needs of people, however in the last few years they have destination. suffered in the shape of falling interest rates, as well as improved life expectancy. Options at Retirement Nevertheless the underlying fundamental principles of the The options available at retirement depend on a number of annuity should not be overlooked: factors and in giving advice, it is clearly important to understand what exactly can and cannot be done. Since the 1. an annuity guarantees an income, and Pensions Act, 2002, the availability of the ARF option has been 2. guarantees that income for life. further expanded to include PRSAs. No matter how attractive an ARF may be, it cannot provide a The categories of individuals who can avail of the ARF options similar level of comfort to a retiree. Even though an annuity are as follows: dies with a person, a guarantee period can be built in thereby 1. The self-employed offering a continuation of income to the individual’s spouse until their death. 2. Company directors owning 5% or more of a company shareholding The certainty of an annuity will remain its biggest attraction, 3. Individual employees in relation to their AVC funds only however with many clients now favouring the ARF route, it is 4. PRSA policyholders not only important but also essential for advisors to explore each approach with their clients. For the self-employed and PRSA policyholders the situation is straightforward. At retirement, they can take up to 25% of the The first piece of ARF advice to give a client is for them to accumulated fund tax-free and with the balance of the fund consider an annuity instead! It is only by comparing and they are free to follow the ARF route. contrasting the relative merits of annuities with the new ARF options that your client can evaluate the retirement route best In the case of company directors, they have two choices at suited to their needs. retirement:

12 The Professional Insurance Broker Self Administered Pension Schemes Kevin Coughlan, The Independent Trustee Company

Self Administered Pension Schemes are known by a variety of guarantees. So a bank lending to a trust for the purpose of names: among them, Self Directed Trusts, Small Self acquiring an asset must be satisfied that the asset can Administered Schemes and SAPs. But don’t be confused by generate the income required to repay the loan. However, the terminology, they deserve less of the mystique attached to further pension contributions can also make loan repayments them than they enjoy. Quite simply, they are employer or indeed can reduce outstanding capital. There is already sponsored pension schemes that provide the scheme significant evidence that this option is proving to be an member with control over the direction of investment. They attractive proposition to clients but it is important to remember are framed by the same legislation that underpins more widely that it is the pension trust that is borrowing and not the client known insurance company contracts; however the client isn’t per se, so it is a requirement to consult the pension trustee limited to the investment options provided within the contract. before becoming involved in negotiation with lenders. Instead, he can invest in a range of products from a wide So what is involved? Similar to a traditional occupational range of providers as well as direct equity investment, scheme, a trust deed is set up. Revenue approval is sought investments in private companies otherwise known as private and a bank account is set up in the name of the trust, which is equity investment, and of course direct property investment by available to take fund transfers from the company and from purchasing in individual property or through syndicates. other insurance company executive pension contracts if the The trend towards this type of pension arrangement is client so desires. The client becomes a co-trustee with the relentless and is fuelled by a number of factors. There is a pension trustee whose function is to ensure that the scheme large swathe of investors in Ireland who have been successful operates in accordance with Revenue regulations. The throughout the Celtic Tiger years and who want more than the pension trustee undertakes not to authorise investments or to traditional fund offerings currently available. These people are terminate the trust except in accordance with the approved frequently unhappy with fund performance, the lack of provisions. In effect the pension trustee ensures the client transparency and, most of all, the lack of direct involvement cannot “take the money and run”. with their investments. Hence the significant increase in direct Investments must be for the sole purpose of providing property investment and the evolution of a diverse range of pension benefits and so there are two primary restrictions that investment products available from specialist providers such as clients should be aware of. The first is called “Self Dealing”. stockbrokers and banks. The introduction of Approved This is perhaps best explained by saying “If it’s not an arm’s Retirement Funds in 1999 further changed the pensions length investment, it’s likely to be self dealing!” Principally, the landscape. With the obligation to purchase annuities confined trust cannot sell, lease to or buy from the company, the to the past, investors could plan to accumulate a pension beneficiary or his immediate family. In the case of a property investment fund and look forward to managing it throughout for example, neither he nor his family can occupy a property retirement. Not everyone will want to take the ARF option, but even by paying market value rent! Secondly, there is a now shareholding directors, personal pension policyholders prohibition against what are known as Pride in Possession and PRSA holders have the choice: a development which articles, examples of which are fine wines, vintage cars and reflects the maturing nature of the Irish investor. works of art. The initial motivation for setting up a self administered pension Finally, this is a growing area of pension investment that gives scheme is often property and this has received further impetus many clients the structural investment solutions they are with the introduction of borrowing within occupational pension seeking and as the range of investments that can be schemes in this year’s Finance Act. Revenue Retirement incorporated in these schemes is wide, it is my experience that Benefits District has confirmed that borrowing must be on a many investors rely on regulated financial advice. non-recourse basis and that there can be no personal

14 The Professional Insurance Broker Our Commercial Priorities – What You told Us…

By Liam Carberry, Chairman of Life/Business Development Sub-Committee

We recently conducted a survey of our members to establish Of the 68% of Brokers who transact mortgage business, only what our priorities should be in respect of commercial 5% of them get 80% or more of their income from this developments on behalf of Brokers. Over 150 firms returned activity. the questionnaire and had their say on what they would like Of the 93% of members who derive income from life broking, PIBA to deliver for them. The research has also identified a third of these generate 80% or more of their business from major issues facing Brokers that will affect their performance this source. and profitability into the future. We will be addressing these issues in our representations to those authorities we believe We asked our members to indicate their annual turnover and are best positioned to assist us. the results are as follows:

One of the objectives of the survey was to get a better < €50,000; 6% understanding of who our members are and what their €50,001 - €100,000; 26% business focus is. The average member company has been € € running for 11 years, however, 32% of members have been 100,001 - 200,000; 30% established for five years or less. A quarter of members have €200,001 - €300,000; 15% been in business for over 15 years. There are a significant €300,001 - €400,000; 13% number of relatively young companies amongst our €400,001 - €500,000; 3% membership but some of those businesses are run by Brokers € who have been in the industry for a much longer period. The > 500,000; 7% average member employs three people and over 76% of 65% of our members’ annual income is generated from new administration staff are employed full time. One of the major business. 56% of it comes from sales to existing clients. This issues that respondents said they face is the sourcing and perhaps reflects the fact that a lot of members are young training of new staff. 15% of Brokerages are one-person businesses. There is still a significant proportion of new practices where the selling Broker employs no administrative business to be sourced from new clients and our members support. From the figures provided in our research sample, we achieve this largely through referrals from existing clients. estimate that PIBA member Brokerages employ over 2,500 people in Ireland. We asked members to tell us where they saw the greatest opportunities to write more business over the next 12 months. We were also keen to establish what the business focus of our Term Assurance was ranked as the best life opportunity for members is and what they perceive their core activity to be. new business – Brokers expect a 29% increase in this class of The survey showed that whilst 93% of Brokers transact life business over the next year. PHI was seen as the product area business, only 39% describe it as their core activity. Similarly, that offered the greatest increase in income – members 68% of members transact mortgage business yet only 23% forecast a 39% increase in their income from the sale of this see it as their main business. 9% of our members described product. Regular premium pension business and critical illness general broking as their key activity. Although the majority of also came high up the list of opportunities. members transact life and mortgage business, it would appear that life broking is the main income stream even for some of The majority of innovation that our members would like to see those who stated that mortgage broking is their core business. in the life and pensions sector revolves around product

The Professional Insurance Broker 15 development and service and support. In particular, the need Brokers to structure their business planning. Only a few for new investment products and new private medical respondents mentioned budgeting as an important part of the insurance products were identified. Brokers want us to planning process, yet many pointed out that rising costs negotiate more schemes with insurers on their behalf and associated with regulation were a concern. 50% of the encourage more product availability generally. respondents to our survey have an action plan for sales and marketing. On the issue of service and support, members would like to see an improvement in service from providers, particularly in Overall, our members are upbeat about future business relation to mortgage business - faster turnaround times and performance and expect their income to increase by an the streamlining of documentation were suggested as areas to average of 23% this year and 21% next year. 87% will be addressed. achieve this growth through cross sales to existing clients and by attracting more new clients through the referral process. In the general insurance sector, home insurance was identified Only 12% plan to expand by acquisition – 24% plan to do it as the product area with the greatest opportunity to write by recruiting new advisors. 97% of members’ leads are more business. 80% of respondents indicated that they would generated through referrals from existing clients. However, be interested in a home scheme run by PIBA. The potential 38% of respondents use direct mail and advertising to get premium value of a PIBA scheme was indicated by 60 Brokers business. The average spend on marketing is 6% of annual who provided an indication that the amount of business they budget. would contribute was €2.7 million. The real potential is much greater than this when the total PIBA membership is 44% of members derive business from introducer agreements considered. We are already in the final stages of sourcing an where the other party is paid for a productive lead. 49% of underwriter for this home insurance scheme and plan to meet Brokers said they would definitely use PIBA branded material to promote themselves and 57% said they would definitely the regulator to discuss the provision of it to our members. use articles for newspapers provided by PIBA for local PR. Overall, members expect to increase their home business by 80% would be prepared to pay for PIBA marketing support. 32% over the next 12 months. Commercial Combined The two main issues identified by members as affecting the insurances followed closely as another good opportunity. future development of their businesses are regulation (time Our members submit an average of 31% of their business and cost involved) and sourcing qualified and experienced online. 21% of Brokers submit more than 50% of their administration and advisory staff. Increased competition, business in this way. 92% see themselves submitting a higher retention of existing clients, low commissions and poor proportion of their business online in the future. Clearly the margins were also identified as potential threats. use of technology in the life sector is seen as an important Members have also highlighted the need for greater PR for part of the service to clients. However, the level of online Brokers, in particular making consumers aware of what Brokers technology available in the general and mortgage broking can offer. Business support was also identified as an area that markets appears to be limited. members would like PIBA to become more actively involved Better technology support in the form of better quotation in. 54% of PIBA Brokers feel that the business development systems, mid term adjustments enabled electronically, and support provided by insurers helps them create more greater use of online technology to amend policies from business. 10% felt the same way about general insurers and 29% felt lenders were supportive. Those companies scoring providers were identified as the key innovations that general highest in terms of good support were Eagle Star, New Ireland, Brokers would like to see, followed closely by greater Irish Life, Hibernian, and Friends First in that order. availability of agencies and a level playing field on rates. Competition and market access were identified as the areas There are a number of areas that PIBA will focus on holding back the growth of general insurance Brokerages. developing for members as a result of this research and other feedback from members. These are: Brokers would also like to have more online technology available from lenders to enable them to operate more ➤ the launch of a home insurance scheme efficiently. Service and product flexibility were identified as ➤ the launch of a mortgage repayment protection plan areas for more development. Some of the improvements that ➤ Brokers mentioned they would like to see were guaranteed sourcing of investment products from UK providers to turnaround times, faster service, a reduction in paperwork, increase the variety available here standardised compliance documentation, and more flexibility ➤ commitment to agency agreements from lenders and from underwriters. They would like access to a stand-alone general insurers mortgage repayment protection plan and a home insurance ➤ business planning support in the form of business planning product. Mortgage Brokers see poor service from lenders as tools and workshops one of the main issues holding back the growth of their ➤ continued promotion of the use of online technology businesses. ➤ the agreement to minimum service standards for Brokers 47% of Brokers who replied to our survey have a formal from lenders and life and general insurers business plan – most of them plan ahead by reviewing last ➤ assistance with the sourcing and training of staff year’s performance and restating their financial targets ➤ provision of marketing material that enables members to accordingly. Many also implement client contact plans. promote themselves locally as members of a professional Generally speaking, there would appear to be a need for body and financial articles for placement in local press.

16 The Professional Insurance Broker AGM

PIBA’s AGM took place on the 26th of May 2004. Terry Hardiman was re-elected Chairman for a second term. Peter Cox and Tony Ball retired from the committee after several years of excellent service. PIBA is delighted to announce that John Millett and Niall Lynch were elected to the committee and we look forward to their contribution.

Conor Riordan, John White, Hugh Sheridan and John Meade

John Millett, Derek Fitzgerald and Jerry McSweeney

Tommy Coyne, Peter Cox, Gary Ellison and Terry Hardiman

Niall Lynch, Tommy Coyne, John Hogan and John Millett

Lisa Gillett, Gary Ellison and Geraldine Layden

18 The Professional Insurance Broker AGM

Pat O Connell, former Chairman, Terry Hardiman, Chairman and Liam Flynn, MOP solicitors.

Richard Crowe, Mary Crowe, Nessa Kelly and Michael Leyden

Patrick Glynn, Patricia Glynn and Liam Carberry

Gary Ellison, Treasurer and Terry Hardiman, Chairman

Donal Atkins, Rachel Doyle and Tommy Coyne

The Professional Insurance Broker 19 Meet Hugh Sheridan A Broker who stresses enthusiasm and a positive attitude

Dundalk Broker Hugh Sheridan started his career in the life worries about robberies either. Trust played a large part in assurance business 30 years ago as a sales representative the process!” with Irish Life in his native town. Like any other sales rep., he The first policy Hugh sold was an educational savings plan to serviced existing clients and sold new business. a young couple for their new baby daughter over a 15-year “My business was in two sections, Home Service and term. Personal Finance,” he recalls. “That baby then grew up and I sold her Life Assurance for “Home Service was originally known as IB or Industrial herself and later an educational savings plan for her first Branch, which was mostly with - profit policies. The child!” premium would be collected weekly from clients’ homes Some time later Hugh moved, on promotion, to District but later the pattern changed to monthly payments.” Inspector and later to Area Sales Manager for the North Hugh’s allocated area, or debit, geographically covered part West of Ireland, a position that was based in Sligo. His area of Dundalk town and a rural area which brought him close covered counties Sligo, Roscommon, Mayo, Leitrim, Donegal to Hackballscross in North Louth and Forkhill in South and Cavan. Armagh.

“I covered the highways and byways of this area in all Paddy Kavanagh Country types of weather, firstly on a bike, and later on a Hugh Sheridan was born and educated near Carrickmacross, motorcycle. Later again, I bought a new car and was able South Monaghan, a few miles from Co. Cavan and not a to travel further afield in order to write new business. great distance from ‘Paddy Kavanagh country’. Married to Maureen, the couple have three children, twin daughters, Key in the door Breda and Ciara, and son John. As an Irish Life employee, he was elected National Secretary of the trade union MSF, One aspect of the job and society then, compared to now, representing 400 members, and took part in negotiations is reflected in the following situation which he recalls. seeking better terms and conditions. “Home Service premiums were normally due on Friday Hugh had enjoyed his career in direct sales with Irish Life. mornings. Nevertheless, clients would usually go up town He featured in the company’s honours list for sales service shopping often simply leaving the key in the door for me and administration for many years. With many changes to go in! The premium receipt book for my company, Irish taking place in the company and having considered going Life, would be sitting on the table in the kitchen with the into brokerage, he felt that it was time to move on. He money on top of it! Possibly alongside it would be the discussed the idea of self-employment with his family who premium receipt book for New Ireland. I would conduct were enthusiastic about the idea. my business and then pull the front door after me. Each other agent would do the same. Nobody would interfere “I felt that the pros outweighed the cons and so I decided to with the other’s business or money. There were no big leave Irish Life,” he recalls,

20 The Professional Insurance Broker “So two years ago, I set up in the brokerage business as a return to my office to check any urgent administration for Multi Agency Intermediary. I operate my business, Hugh posting and make appointments for future days.” Sheridan Insurances, from my home near Dundalk, to which we returned. I specialise in the life and pensions end of the Continuous Professional Development business. Hugh is aware of the need for ongoing education in his “Being your own boss means that you have more control of profession. Having studied and passed the LIA examinations (he the job. I am still doing the same type of job, except that I am holds the QFA FLIA designation), he joined the North-East able to quote a number of company products. That means Committee, which organises Continuous Professional that, as a Broker, I have a very competitive advantage. It took a Development seminars. Just over two years ago, he joined PIBA. while getting to know the other companies’ products but I was determined to have a good knowledge of them which I could “It is good to be in an industry-recognised association. There is confidently offer clients.” an old saying: ‘United we stand, divided we fall’ and it’s very true in our profession. There are many areas to be explored In Hugh’s opinion, a good independent insurance Broker is worth and negotiated and, hopefully, PIBA will help secure and his or her weight in gold. enhance our future in the industry.”

He got to know the Account Managers with the various companies and found them very helpful. He uses the Bagpipes opportunities provided by product launches and conferences to For leisure, Hugh enjoys music, motor sport and walking. meet intermediaries from other areas and to compare notes. “I play an unusual instrument, the bagpipes, in a local pipe Regulation band! We won the All-Ireland Fleadh Cheoil Na hÉireann on two occasions in Listowel, County Kerry, and enjoyed many Regulation was not something new to Hugh Sheridan - he was outings and competitions. We also played at the St. Patrick’s already used to most of it in direct sales. Day Parade in London and at a St. Patrick’s Day concert in the Royal Albert Hall to an audience of three thousand people.” “When I started as a Broker, many intermediaries were concerned about all the new regulations. And, indeed, there For Hugh Sheridan, life as a Broker is interesting and no two days are times when I am very concerned about them myself, and are the same. As a result, time goes quickly. how time-consuming it all is! But, long term, it should be good for the industry, the consumer and us, the Brokers. But I “Intermediaries provide a very valuable service to the strongly believe that all intermediaries, regardless of their community and many families would not have Life Assurance status, occupation or financial institution membership, should but for advice from the local Broker. be bound by the same rules. In other words, there should be a I have been involved in Life Assurance claims paid out on the level playing pitch for all. death of young and old. In all cases, the spouse and parents, as The new regulations should ensure that the intermediaries now beneficiaries, were pleased to at least have the Life Assurance to in the business are there for the long haul.” help pay their funeral expenses bill, clear their mortgage or help educate young members of the family.”

Back-up Similarly, others among Hugh’s clients were glad to have a pension income on retirement or to have savings to educate their Like many fellow Brokers, Hugh Sheridan is lucky in that his children. In his view, the service of the Broker to the community family provides a good back-up service. is undervalued and not fully appreciated. “They help with the administration end of things such as the “Clients and the media may talk at times about fund computer work and accounts. I use the computer for performance, underinsurance and so on but nobody has ever quotations mostly, and e-mail of course. Omniquote, for refused a cheque in a time of need or change of example, is very good in that I can compare quotes from circumstances in their life. In fact, they are usually delighted to various companies and then print off the one I have selected. get it.” Omniview is also helpful in that a client’s information can be downloaded when required.” He readily admits that selling and advising on financial services is not an easy job due to the intangible nature of the products. It is However, he points out that even in this era of computers, mostly based on trust and, in the case of Life Assurance, the Brokers seem to have more paper to contend with than ever! benefit will be paid to someone else and not the life assured. When the post arrives, he normally tries to do one of these three things (a) deal with it there and then, (b) file it or (c) shred it. “Physically it is not too demanding, but mentally it can be very much so. There are ups and downs in our business as This helps to keep the paper mountain down - a constant happens in every walk of life. However, enthusiasm and a struggle in the office. positive attitude help keep us going. After all, it is a great Planning and preparation are vital to Hugh’s routine. career offering the sort of variety not experienced in other businesses.” “I try to make as many appointments as possible for the daytime. However, many appointments must, of necessity, be Hugh quotes one very successful salesman, who, on retiring from in the evening. I try to get the administration and any phone the business, was asked to write a book on the secret of his calls to Life offices made in the early morning. Then perhaps a success. He replied that the secret of his success was contained coffee break if I am lucky. Then, it is usually time for mid- in one simple three-letter word: ‘ASK!’ morning appointments or ‘prospecting’. In the late afternoon, I

The Professional Insurance Broker 21 Football Crazy!

Niall Lynch is Director of Niall G. Lynch Insurance Brokers in Athlone. Outside of work, his passion is Gaelic Football. He spoke to Tim Ryan.

Athlone Broker Niall Lynch is a new member of PIBA’s “Athlone is very lucky to have a fine Regional Sports Centre National Council. A former Gaelic footballer for his native offering a tremendous facility to the local community. Taken Westmeath, he is well known throughout the lake together with Athlone and Garrycastle GAA Clubs and county for his love of the sport. Ericsson Park – home to Buccaneers Rugby Club – this area is well endowed with sporting facilities. There is great, Niall was for ten years manager of the Canada Life positive interaction between all the clubs and we all get on office in Athlone before he set up his own business, very well together. ” Niall G. Lynch Insurance Brokers on Castlemaine St., in 1998. The firm specialises in all areas of life and pensions Niall Lynch is very conscious of the loyalty and friendship that and mortgages. Another former employee at Canada Life, the GAA provides and which stands to benefit all. In his Seán Hannon, joined him to take care of the administration. younger days, he also played League of Ireland soccer with Athlone Town. Niall inherited his love of football and sport in general from both parents. His mother came from strong hurling country in And the interest in sport has already taken root in the next Adare, Co. Limerick while his father, Des Lynch, played football generation of the Lynch family. Married to Valerie Duncan, the himself and had a lifelong interest in the game, winning six couple have two children, Néil and Dylan. Both are already senior championship medals with Athlone. He also served as committed underage players. Niall hopes they get the same Lord Mayor of the town. enjoyment and satisfaction from playing the game as he did. Valerie’s father, the late Harry Duncan was a very well-known As a student in the local Marist College, the young Niall Lynch figure in the local Boat Club. quickly immersed himself in football and played the game at all levels, beginning with underage. He captained various High profile Manager Páidí O’Shea has attracted a lot of media College teams and later moved on to Athlone GAA Club attention to the current Westmeath team. Niall is where he played at minor, under-21 and senior levels. There complimentary of Páidí and his efforts. He also singles out he won many honours including five senior championship another Kerryman, Tomás O Flaherty, as well as Jack Cooney, medals. Paddy Collins; and player co-ordinator Michael Duffy for his painstaking, behind-the-scenes work. Growing up, his football heroes included Brian Mullins, Jack O’Shea and Dessie Dolan Snr. But much of his success and “Together, they are an extremely professional group of enjoyment was due to local man Martin Flynn who first people. A key to their success is the Supporters Club, which introduced him to Athlone GAA Club at the age of ten. Martin provides the necessary capital to run a truly modern-day is the current Chairman of the club. professional operation. The team has retained its place in the first division of the League and that augurs well for next “Men like Martin – and there are many others – have given year. I think this team is well capable of a Leinster generously of their time to the development of the games Championship while an All-Ireland title might yet be just a and to helping the youth,” he says. “They are owed a great little way off. But that is the ultimate target. I am keenly deal of gratitude for the work they do. They were a great aware that the county has not qualified for the Leinster Final help to me and to many of my colleagues growing up in since 1949 and this year is a major step forward. The Athlone in the ‘70s and ‘80s.” atmosphere has been tremendous all summer as the team But it was as a player at underage and at senior county level gradually won its way to qualify for the key game against for Westmeath in the ‘80s that Niall became known to the Laois.” wider sporting world. In 1988 his team achieved a major Athlone GAA Club has a number of players on the panel: Joe breakthrough for the county when they won the O’Byrne Cup. Fallon, Fergal Murray, Tom Traynor and Westmeath’s first ever But, like many of his team mates, his retirement from senior football All-Star Rory O’Connell. county level did not mean retirement from the game. He Recently Niall has taken up golf and is making progress. continued to play for Athlone for a number of years and began to take a more active role in the running of the club. “There is only one direction I can go with my golf! I often feel you need to get in some practice at the sport when you “The club is well organised and structured and has a very are young as it takes a long time to perfect it in later life.” good record. There were many very good players there and between them they have clocked up 20 senior titles.” Though running a busy insurance brokerage, Niall still finds himself spending an average of three to four nights per week The club has also benefited from grants from the National – not to mention weekends - involved with Athlone GAA Club Lottery, money which Niall says was put to very good use. in one form or another. It’s a passion he intends to indulge Extra dressing rooms were built and the pitch was floodlit. for some time to come.

Local politicians, including former Minister and now Leader of Westmeath won their first Leinster title at Senior Level on the Seanad, Mary O’Rourke, are very supportive of the club Saturday, 24th of July 2004 beating Laois after a replay on a and of sporting facilities in general in the town. score line of 0-12 to 0-10. What are the odds on Westmeath winning their first All Ireland at Senior Level?.

22 The Professional Insurance Broker Professional Indemnity – do Brokers need this cover? By Derek Fitzgerald, PIBA Committee

From time to time we read about a surgeon leaving a medical So now you are convinced that you need a P.I. policy, you set instrument inside a patient and we think, how on earth could about getting quotations for your brokerage and you find that anybody make such a mistake! there are only two players in the market. You then discover that the premium is linked to the limit of indemnity and the Consider, however, the thousands and thousands of only way to reduce this premium is to accept a higher excess. operations carried out each day. Consider the thousands and The final outcome is a policy with a premium of €5,000 and thousands of medical personnel involved in these operations an excess of €5,000 (each and every claim), so unless you and consider how prone we all are to making mistakes and have an Armageddon you will not need this policy. In 30 then you might expect such mistakes to happen more often. years of paying for P.I. insurance, I had to use my policy once The fact is that professional people working in their professions and that was to pay the insurers up front the excess of £2,000 have through years of experience learnt not to make such to investigate a claim that never materialised. Still I would basic mistakes. prefer that to happen than be remembered as a surgeon who left an instrument inside a patient! A Broker today carries out numerous business transactions on behalf of his clients, from arranging new business policies and Simple Rules renewals to midterm adjustments, settling claims, collecting premiums, paying insurers, and employing staff. All of these To avoid the possibility of a mistake in dealing with clients, and more are prone to human error and yet it is seldom that there are a few simple rules that will ensure errors and we hear of a mistake causing harm or loss to a client. omissions are kept to a minimum. I find that taking notes of all telephone conversations and face-to-face meetings with In essence, a Broker, like all other professionals, has his work clients is useful and, in particular, any agreements or governed by ‘best practice’; and by adhering to regulations and instructions should be noted carefully. observing a strict Code of Conduct, the chances of a serious mistake occurring are all but eliminated. In dealing with insurance companies all instructions, even if agreed verbally, should be followed with a written submission Professional Indemnity Insurance and a request to the company for confirmation of those instructions. Even a simple matter like a change of address So you may ask do Brokers need professional indemnity could be left unaltered until something happens to bring it to insurance? The answer to that question is a definite ‘yes’ and notice. To be fair to insurance companies, simple errors of this for two important reasons, which can enhance their business nature are corrected by them but it is an example of how dealings with the public. The present P.I. policy ensures that claims can arise against a Broker. any acts of error or omission by the Broker or his employees that cause a loss to a client will be indemnified by the insurer. Professional Indemnity insurance is there to protect the client This gives a client a ‘feel good factor’ in that the Broker, good against mistakes made by a Broker that result in a loss to the and all as he is, has the backing of an insurance company client. Conversely, a Broker has the protection to his business should he make a serious mistake. That a client can be should a successful claim be judged against him. In that both reimbursed financially for any loss caused by his Broker’s parties are protected, the need for P.I. is self-evident and, negligence should give the client extra confidence in his although expensive, I believe that no Broker should be without dealings with that Broker. The second reason a Broker’s needs this protection. The EU agrees and from January of next year P.I. cover is for his own personal peace of mind in that he P.I. cover will become compulsory. PIBA have negotiated a knows that, should the unthinkable happen, then his business, scheme which offers competitive market rates for our his home and his livelihood will not be placed in jeopardy. members.

The Professional Insurance Broker 23 A Mortgage Client, a Client for Life

By Tommy Coyne, Chairman, PIBA Mortgage Sub-Committee

The biggest decision that most people make in their life is to A Mortgage Intermediary should: purchase a house. It’s a very traumatic time for most people, 1. Act honestly and fairly in conducting its business activities particularly for young couples making their first and possibly in the best interests of its clients and the integrity of the only purchase. market. So, a mortgage client is somebody who depends on the 2. Act with due skill, care and diligence in the best interests of Broker for the best advice suited to his/her individual its clients and the integrity of the market. circumstances. They need somebody in whom they can trust 3. Employ effectively the resources and procedures that are and whose expertise will find them a mortgage tailored necessary for the proper performance of its business exactly to their individual requirements. activities. There was a time when a mortgage client was somebody you 4. Seek from clients information regarding their financial saw maybe once or twice in their lifetime. Once the loan was situations and their objectives as regards the services drawn down, it was generally the case that the mortgage requested. intermediary had fulfilled his job and the client subsequently 5. Make adequate disclosure of relevant material information, became the client of the lending institution and not of the including charges and commissions in dealings with clients. Broker. That has all now changed. 6. Make a reasonable effort to avoid conflicts of interest and, Today, the average lifespan of a mortgage is at most seven when they cannot be avoided, ensure that clients are fairly years and is predicted to drop to five over the next few years. treated. Today’s mortgage client will probably change house, renovate 7. Comply with all regulatory requirements applicable to the or invest in a second property at least once and maybe conduct of business activities so as to promote the best several times and so will need expert advice time and time interests of clients and the integrity of the market. again. These requirements can be summarised in three basic points: In recent years, the role of the mortgage Broker has also ➤ Firstly, you should disclose your commission and charges changed dramatically in the area of regulation. Shaping up in relation to your mortgage business. This can be done your business to incorporate compliance procedures has in your ‘Terms of Business’ letter. been an onerous process but most Brokers feel they are now ➤ Secondly, you should also be including your regulatory finally getting to grips with the new regulations. status in a disclosure statement on all stationery, e-mails and any other correspondence. IFSRA has taken over the role of regulating all Mortgage ➤ Finally, there is also an obligation on the Broker to seek Intermediaries from the Director of Consumer Affairs. In June relevant details on the clients. This can be achieved by of last year, an Interim Code of Conduct for Mortgage filling out an application form, although this must be prior Intermediaries was issued. The general principles of the to giving advice. In other words, using a generic code are: application form would eliminate the need for a factfind.

The Professional Insurance Broker 25 In addition to offering mortgage advice, Brokers now offer Agency Agreement which spells out the basic rights of their many additional products to clients. These include: appointments to financial institutions.

➤ Home insurance The key aspects that such an Agency Agreement should cover ➤ Mortgage repayment protection include: ➤ Serious illness and unemployment protection ➤ Non-cancellation for non-production of business All this means that the Broker must be aware of all the ➤ Defined procedures for cancellation financial needs of a client and not just the mortgage ➤ Right of sale/transfer/bequest requirement. This all raises the very critical issue of access to ➤ information relating to clients. How many times have you tried Arbitration/dispute resolution to request information on a client from a lending institution ➤ Client bank protection. only to reach a dead end? Is the fact that a client has elected These are basic requirements, which will ensure that you, as you to act on their behalf as their Broker not enough to entitle mortgage Broker, can service your client to the best of your you to access this information? ability as well as protecting your own business.

Access to client information It is now almost two years since PIBA first began lobbying financial institutions on behalf of members seeking formal In order to provide the best service to meet a client’s needs, Agency Agreements. Since then we have received some you need access to client information. That is a bottom line positive feedback and we hope in the near future to be in a for PIBA. In this regard, the cancellation of a Broker’s position to sign the first Agency Agreement. The operation of appointment to a financial institution is not acceptable as how such Agreements have proved highly successful on the Life can a Broker service a client if he/she does not have an and Pensions side and are working to the benefit of both appointment from the institution that provided the mortgage in institutions and Brokers. the first place? That is why PIBA believes the fundamental rights of a Broker should be upheld through an Agency It is very important that Brokers acknowledge the fact that a Agreement. In these days of regulation and compliance, it mortgage client is a client for life! However, to date there is seems to me that the least Brokers are entitled to is a formal some doubt as to whom the client belongs!

UPDATE ON PIBA MORTGAGE SUB-COMMITTEE

Agency Agreements Generic Documentation ➤ The Mortgage sub-committee has met various lenders ➤ PIBA now has a generic mortgage application form and regarding Agency Agreements. salary certificate.

Business Development Professional Indemnity ➤ PIBA is currently looking at a mortgage repayment and a ➤ All PIBA members have access to a PIBA Professional home insurance product. Indemnity scheme

If you are an insurance Broker as defined by the Insurance Act, 1995, and a mortgage Broker and you would like to join PIBA to benefit both your mortgages and insurance business please contact Rachel Doyle at the PIBA Office on 01 - 4020250

FINANCIAL ADVISORS ASSISTANCE COURSE LAUNCHED IN DUBLIN The Professional Insurance Brokers FÁS are currently looking to recruit employers for the trainees for a period Association is delighted to announce the enthusiastic candidates for this course of 15 weeks after they have completed Dublin launch of the Financial Advisors who are keen to develop a career within their 24 weeks’ training in FÁS. Assistance Course. the financial services sector. To register your interest, please e-mail This programme has been designed by For information on eligibility and how to [email protected]. FÁS in conjunction with PIBA to provide apply for a place on the course please trainees with the skills, knowledge and e-mail [email protected] qualifications necessary to work PIBA are also looking to enlist Brokers effectively in the life, pensions and who will be willing to act as host mortgage business.

26 The Professional Insurance Broker Money laundering - How does it Affect us?

By Eleanor Fitzgerald

In February of this year the Financial Services Regulator, IFSRA, an individual or a corporate identity and address; issued, with the approval of The Money Laundering Steering Report suspicions of money laundering to An Garda Síochána Committee, Guidance Notes for Insurance and Retail AND the Revenue Commissioners. Investment Products for use by Life Assurance Companies and Insurance Intermediaries. These guidelines replace the earlier If you think this topic has nothing to do with how your firm version dated April 1995 and should provide assistance for the operates, you should be aware that the penalties applicable to insurance sector on the practical implications of complying this piece of legislation are up to 14 years imprisonment with the Criminal Justice Act, 1994, as amended. and/or an unlimited fine as well as negative publicity.

The focus is on the life industry. However, all Brokers, be they Insurance intermediaries are specifically named as being a mortgage or non-life practitioners, have obligations to report Designated Body under the Criminal Justice Act, 1994, and suspicions in the event they are aroused by a particular must therefore take measures to prevent money laundering. transaction or action of a client. Other designated bodies are life assurance companies, banks, building societies, credit unions, stockbrokers, solicitors, Know Your Client accountants, auctioneers, to name but a few. Typically, the life Broker knows more about their client’s financial standing than most, as during the factfind process a Vulnerable lengthy discussion will have taken place with the client Life assurance companies and intermediaries are singled out establishing their financial and personal circumstances. But as being particularly vulnerable to money laundering because increasingly, this knowledge carries with it high risks, and now retail investment products such as unit linked bonds and unit the burden has just got heavier. In effect, KYC or ‘Know Your trusts may attract money launderers since these products allow Client’ has become a part of everyone’s life in this industry. the criminal to quickly and easily move their money from one product to another, mixing lawful and illicit proceeds and The new regulations and Guidance Notes require the Broker to thereby integrating them into the legitimate economy. Lump establish certain procedures and impose on the Broker sum investments in liquid products are clearly the most reporting obligations in respect of suspicious transactions vulnerable, particularly where payment is received in cash. regarding offences under money laundering legislation. So the big question is: “What should I be doing?” In summary the Broker must: KYC – Know Your Client; KYC – Know Your Client Retain identification records for at least six years from the date The requirement for intermediaries and life assurance of last doing business; companies is to keep comprehensive and clear transaction records as an audit trail. These records can provide the Establish internal controls and procedures to prevent and authorities with assistance when investigating individuals and detect money laundering, including undertaking appropriate organisations involved in money laundering schemes. training for all staff and the nomination of a Money Laundering Reporting Officer (MLRO); As already stated, factfinding is core to the life business and an integral part of the whole Broker/client relationship. From a Establish robust identification procedures for the verification of

27 The Professional Insurance Broker money laundering perspective, it is important to understand has responsibilities in the event of suspicions being aroused. the source of a client’s assets, details of the payment methods So when Joe Public goes to buy a house and a mortgage being used, e.g., a cheque drawn on the client’s personal bank protection policy, his auctioneer, accountant, solicitor, mortgage account with a designated body within the State, a policy Broker, life Broker and lending institution will all have to satisfy maturing with another institution etc. And you should always themselves as to his or her identity. Now there are ways that ask yourself: designated bodies can certify to each other that the client has Is the client or referral source for the client known to me? been ‘ID’ed but it is still a vast process. Is the transaction in keeping with the client’s normal investment activity? Identification Procedures Am I being asked to do anything unusual? Those readers who are mortgage practitioners have been Is the transaction being settled in a normal manner? establishing clients’ IDs since 1995 and this is already Are there any other transactions linked to the transaction in incorporated into their day-to-day practices. Insurance question which could be designed to disguise money? intermediaries have had this obligation since May 2, 1995 and although not expected to retrospectively establish the identity Record retention of persons who were already clients on that date, where an existing client enters into a new policy after that date, the new Although the legislation states that records should be retained ID rules apply. ID is required when ownership of a policy for five years, the Financial Services Regulator requires changes or when the proceeds of a policy are being paid to intermediaries to retain identification records for at least six someone other than the policyholder. years from the date of last doing business and the intermediary must be able to retrieve these documents Another obvious point is that evidence of ID should be without delay. obtained prior to the policy being put into force. And when dealing with a Corporate, a firm should seek a copy of the The types of documents that should be retained include: document (board resolution/partnership agreement) giving the The factfind individual the necessary authority to act on the company’s (i.e. your client’s) behalf. Copies of documents used to verify ID and address Details of method(s) of payment for the transaction The Notes give guidance on the types of items permissible Details of the transaction, including all policy information and when establishing identity and the types of items required the illustration of benefits during face-to-face contact versus non-face-to-face contact. You should familiarise yourself with these and include them as All post-sales records associated with the maintenance of the a Standard Operating Procedure (SOP) going forward. contract up to and including the maturity of the contract Details of the maturity processing and/or claim settlement Reporting Internal Controls All suspicious transactions should be reported to the Garda Bureau of Fraud Investigation AND the Office of the Revenue Each firm should by now have appointed an MLRO who is a Commissioners. Exact details of how to do this, together with senior figure within the firm with the necessary knowledge and the necessary forms, are contained in the Guidance Notes. Tax powers required for this role. The MLRO acts as the contact offences receive special attention. Where there is suspicion point for the authorities in the event of an investigation into a that a transaction involves the proceeds of tax evasion this particular transaction or client of the firm. The MLRO must must be reported. This may present particular challenges to keep written records of any matter reported to him/her, practitioners in the mortgage industry. whether or not the suggestion was negated or reported, and the reasons for this decision. This is a huge issue for everyone in the financial services sector, no matter what your role, and I hope to have gone The firm must ensure that there are clear internal policies so some of the way to answering the question poised at the that all staff are aware of how they can discharge their beginning of this article. It’s not the most exciting topic to read obligations when reporting a suspicion. Matrix reporting will about, but it is vital to establish standards for your business as not work here as their obligation under the legislation can only the penalties on both a personal and business level are be fully satisfied when they inform the MLRO, not a supervisor severe. or manager. If you do not have a copy of the Guidance Notes you can print The Principals of the firm must ensure that all staff are them off from IFSRA’s website, www.ifsra.ie, Industry section, adequately trained. Training must occur for all new entrants Anti-Money Laundering sub-section. and there must be refresher training on an annual basis thereafter. Training should be appropriate to the staff And then, going forward, it is all about Knowing That Client member’s role in the organisation, i.e. sales staff versus and Having That Procedure….. processing staff. Eleanor Fitzgerald, Director, FBS Compliance can be contacted The firm is always required to verify the identity and address of on (01) 4949386 or at www.compliance.ie. the individual or company they are dealing with and all staff The contents of this article should be used for information must be trained in this area. There are some exceptions to purposes only and should not be relied upon as advice. obtaining these documents, which are identified in the Guidance Notes. However, always, always, the intermediary

The Professional Insurance Broker 29 Designing a website – What you Need to Know Alan Cochrane, Managing Director of float.ie examines some of the issues involved.

What is the Internet? service you wish to provide. In essence you must conduct a factfind on your own business needs. This can affect decisions The Internet is a worldwide network of computers joined on your final choice of design company. together by telecommunication lines. It is a communications medium that allows us to send electronic information between A small business has varied needs ranging from (in order of computers linked to this network. price): The World Wide Web is a particular way of transporting text, ➤ Brochure images and other multimedia content over the Internet. Web A brochure site is essentially a digital business card. Its function servers respond to particular requests by sending documents to is to advertise your company and the products or services you the user. The user needs a browser to receive this data. supply. It also functions as a first point of contact for potential Often the terms ‘Internet’ and ‘Web’ are used synonymously. An customers. Internet user has access to a wide variety of services: electronic ➤ Information mail, file transfer, vast information resources, interest group The purpose of these sites is to provide information. This membership, interactive groups, multimedia displays, real-time information is supplied to the user as a service and the provider broadcasting, shopping opportunities, breaking news, etc. generally allows free access. No one is in charge of the Internet. There are organisations that develop technical aspects of the network and set standards for ➤ Intranet creating applications on it, however no governing body controls An Intranet is a network within a business, whereas the Internet the Internet. is a worldwide network. An Intranet has access to the Internet Increasingly the Internet has become a sales channel for many but not vice-versa. It can function just like a website. different types of goods and services. It has been estimated that ➤ e-Commerce transactions worth €6 trillion will take place over the Internet by An e-commerce site gives you the ability to display and sell your the year 2041. products or services to a global market.

What is a Website? Website Management A website is a location on the Web owned and controlled by a Good management is crucial to a website’s value and efficiency. single person or organisation. It is a set of coded pages linked to each other. Some company websites simply reflect their A successful management strategy will: corporate brochures while others are using websites to transact ➤ Consider the website a vehicle for customer service as well as business, allow customers access to their account information, a potential source of direct revenue allow suppliers access to company systems, etc. ➤ Develop a structured plan for training staff ➤ Set up a formal technical support plan What is e-Business? ➤ Recognise and address the changing needs of the target audience e-Business refers to all business processes that take place across ➤ Provide an effective follow-up procedure electronic networks. This includes everything from buying and ➤ Put systems in place to ensure the above strategy is selling goods and services through the Internet, to interactive implemented television and a whole host of other emerging technologies. It integrates current communication technologies with traditional Cost Benefit Analysis business processes, whilst also introducing efficiencies that cut costs and increase profits. Lower transaction expenses are a reality and the labour costs associated with management can be slashed. Supply costs can e-Business can give your company a significant competitive be reduced. The extensive availability of Internet-based advantage. Online transactions have been identified as the most information means that companies have a wider choice of important sector in this new marketplace. Businesses often use suppliers. This by extension leads to more competitive pricing. technologies like the Web to source new partners and materials, to open up new markets and to provide better support for In short, there are many advantages to creating an online existing customers. presence. Remember, a website can provide valuable information to clients and the general public. You have a Developing a website worldwide audience; use that to your advantage. For any business, getting a website requires an investment of Contact Alan at e-mail: [email protected] Website: www.float.ie time and money. You must first be sure of what kind of online Tel: +353 (01) 4516850

30 The Professional Insurance Broker A Pension built on Sound Foundations

By Jennifer Richards, Investment Director, Ireland, Standard Life Investments

Introduction pronounced economic cycles, then this bodes well for property given the relative inefficiencies of the demand and supply Many pension funds are in a difficult position after the setbacks relationship. they have endured in recent years. The spectacular collapse of the technology bubble, over-concentrated portfolios, sharp declines in discount rates as bond yields have fallen and Volatility onerous legislative requirements have all heaped pressure onto Another attractive feature of property is the lower volatility trustees and sponsors of pension schemes. With the increased shown by the asset class relative to others. As property values attention on the volatility of returns, we strongly believe that the are based on prices of comparable transactions, they tend to best approach for pension funds is to adopt a more robust smooth underlying movements. In a well-diversified property approach to diversification of their asset mix, utilising alternative portfolio, the change in rental income will be smoother than the investments, most particularly property. pattern of changes in the current level of market rent, as rent reviews in the portfolio will be spread over time and, in the UK With the introduction of FRS 17, publicly traded companies must and Ireland, will tend to be upward only. This will also reduce disclose the assets and liabilities of their defined benefit pension the volatility in the asset class. plans. Subsequently, the industry has spent a great deal of time re-assessing the rationale behind pension funds and their Property’s historically stable income yield is a key attraction for matching requirements and this has acted as a catalyst for a pension funds seeking certainty from income streams. In a movement away from equities and into fixed interest securities. continued low inflationary and low interest rate environment, However, we maintain that this move alone is not enough to property’s yield, currently at around 6.5% p.a., will represent a ensure the efficient diversification of pension assets. greater proportion of investor returns compared to the more volatile capital growth element, which over the last 30 years has Added to this dilemma is the accounted for 45% of nominal property market returns (see strong recent performance of Chart 2). Property is a real asset and provides strong inflation equities. Many trustees, not hedging characteristics over the medium to long term - an surprisingly, are finding it difficult to important consideration for pension funds looking to match long buy bonds in the current term liabilities. environment. This highlights the need for alternative investments. A number of studies have shown that returns from property do We believe commercial property not correlate closely with returns from traditional bond and acts as a complement for bond equity asset classes. This means that property can help to portfolios as it can reduce risk and smooth out the return of an equity and bond portfolio. enhance returns. In this article, we outline the long term drivers of UK A good time to invest in the UK market? commercial property and state the strong case for their inclusion in a Over the six months we have become increasingly confident well-diversified investment regarding the outlook for the UK commercial property market in portfolio. 2004. Against a backdrop of strengthening economic fundamentals, the divergence of performance in the UK What drives the property property market will narrow further over the year. The appetite of UK institutional investors and the volume of funds from market? overseas (including Ireland) will maintain upward pressure on When the economy is growing, capital values. We believe that 2004 will be another year of property returns are positive. respectable double digit returns for UK property investors. Property cycles are closely linked with economic cycles, as is shown in chart 1 for the UK. When Conclusion economic conditions are positive and finance is relatively It has long been recognised that there are important benefits in abundant, developers are enticed into the market to capitalise diversifying within a pension fund. Based on long term on what they see as an attractive balance between supply and fundamentals and the current economic environment, we demand. If the economic climate then deteriorates, the believe that asset allocations can be complemented by the expected tenant demand falls away but the property supply introduction of a UK property component, which provides pipeline cannot be turned off as quickly because of lengthy efficient diversification whilst potentially enhancing returns. construction periods. If we are in an age of shorter and less

The Professional Insurance Broker 31 Stand-alone PRSA AVCs By Brendan Johnston, Pensions Director, Eagle Star Life.

I am somewhat surprised at the controversy that has arisen over by The Pensions Board in November 2003; so began the the introduction of Stand-alone PRSA AVCs. Some competitors are possibility of writing PRSA AVCs on a stand-alone basis. It was reportedly saying that they could not be done; some are saying logical that the Revenue transferred the responsibility of policing that they should not be done, and others want clarification. Revenue Maximum from the trustee's shoulders to the provider's. Stand-alone PRSA AVCs are good news for clients and for Brokers. PRSAs have been a mixed bag until now, requiring greater compliance and having lower average rates of Key Benefit to You remuneration. The Broker share of the PRSA market is lower The key benefit to Brokers is that you can now sell PRSAs to the than its natural share of the pensions market. Stand-alone PRSA vast majority of pension scheme members including public AVCs are a positive development because they allow Brokers service employees. The only complication is that you will need access to a much bigger market. to source the member's pension details to allow the provider to The table below shows that there are about three-quarters of a perform a Revenue Maximum check. In the vast majority of million people who are members of occupational pension cases, members will be able to pay in their chosen amounts. schemes. These people had little choice about how AVC contributions could be invested and no opportunity to use their Key Benefits to Your Clients own financial advisors. The key benefits are confidentiality, choice, and continuity. Current Schemes Defined Benefit and Defined Contribution An employer should not have access to an employee's private financial affairs. For example, it may weaken an employee's case No. of Schemes No. of Members for a pay rise if he or she is paying substantial amounts into Scheme Size 31 Dec 2002 31 Dec 2001 31 Dec 2002 31 Dec 2001 AVCs. Stand-alone contracts will offer much greater privacy. Non-Group 87,776 79,792 87,776 79,792 1 – 50 19,014 17,189 98,883 92,541 Stand-alone PRSAs offer greater choice both in terms of 51 – 99 429 421 30,530 29,693 investment and advisor. Trustees will tend to limit the member's 100 – 500 422 407 89,716 85,630 options on investment, since they will minimise their risk. It is 501 – 1000 62 64 41,666 42,758 unlikely that the trustees will co-operate with the member's 1001+ 61 58 360,761 340,084 Total 107,764 97,931 709,332 670,498 chosen advisor. Continuity and flexibility are also important. Stand-alone PRSAs Source: The Pensions Board Annual Report and Accounts 2002 can be carried throughout a client’s career. There are too many little pots of money hanging around in the form of paid-up Background — What is a Trustee's Role in pensions or old retirement annuity contracts. Stand-alone PRSA PRSA AVCs? AVCs are a major step forward in flexibility and simplification and should encourage longer-term involvement and ownership. The initial rules on PRSA AVCs meant that they could only be allowed if the trustees of the main occupational scheme agreed to a change in the rules of the scheme. Best Advice Issues

This troubled us from an early stage. First of all, it is difficult to Clients will probably have an alternative form of AVC provision get trustees to change the rules of a scheme and this normally and this will need to be factored in when formulating advice. If involves a long gestation period and input from lawyers. The the company AVC is a DC arrangement, the matter is relatively Revenue did allow PRSA AVCs if the trustees indicated a straightforward and is a comparison of the relative merits of the willingness to change the rules at a future date. Although helpful two alternatives in terms of cost, choice, flexibility, etc. to the sales process, this leads to administration burdens: what happens if the trustees never make the change? If the alternative AVC is added years of benefit, direct financial comparison should be avoided, for these are two very different Secondly, the trustee’s role is not well defined. Unlike a forms of provision. It would be like comparing apples and traditional AVC, the trustees do not "own" the PRSA AVC. They oranges. Clients should be advised that PRSA AVCs are very have no control over the investment strategy. Asking the good at providing lump sums suitable for investing in an ARF, trustee's permission is similar to seeking the trustee's permission while added years are suitable for additional guaranteed to invest in an SSIA or even to buy a fridge in Power City! The pension. In some cases, the terms for buying back missing years only role for the trustees in these arrangements is to police are so generous that these should be seriously considered. Revenue Maximum. To conclude, Stand-alone PRSA AVCs are now available, don’t let We made a submission to the Revenue to effectively take the your clients miss out on an opportunity that will definitely trustees out of the loop, and there was a favourable response. benefit them. The notification to the industry was contained in an e-mail sent

The Professional Insurance Broker 33 Updates LIA Update Date Event TIME Speaker/Venue Wed. 8 Sept. ‘04 LIA CPD Seminar (2.5 hours CPD) 8.30 am -11.30 am Brendan Johnson - Approved Retirement Opportunities. Harry Cassidy- Alternative Investment Opportunities. Ardilaun Hotel, Galway.

Seminar (2 hours CPD) 4.30 pm - 7.00 pm James Skehan - Pensions Update Industry Ctr., UCD.

Mon. 13 Sept. ‘04 CPD Seminar (2 hours CPD) 9.30 am - 12.00 noon IFSRA Update. Dara Smyth - Reading and Interpreting Accounts. Clarion Hotel, Dublin.

Sat. 25 Sept. ‘04 CPD Seminar (2 hours CPD) 10.00 am - 12.30 pm Trish Nolan - Policy Ownership. Boole Library, UCC. Mon. 11 Oct. ‘04 CPD Seminar (2 hours CPD) 9.30 am - 12.00 noon David Boyle - Family Law. Harry Cassidy - Property Investments through Pensions. Clarion Hotel, Dublin.

CPD Seminar (2 hours CPD) 12.30 pm - 3.00 pm IFSRA Update. Ardilaun Hotel, Galway.

Tues. 19 Oct. ‘04 CPD Seminar (2 hours CPD) 5.00 pm - 7.30pm Des Kelly - Financial Planning Structure and Investment. IFSRA Update. Ard Rí Hotel.

Sat. 6 Nov. ‘04 CPD Seminar (2 hours CPD) 10.00 am - 12.30 pm Brendan McGinn - Retirement Planning. Boole Library, UCC.

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➤ Terms and conditions: the prize is available between 1st October and 23rd December 2004, Tel No: ______(open weekends in December only) excluding bank holidays, and reservations are subject to availability at the time of booking. Lucky winner: The lucky winner of our Summer ‘04 competition was Simply complete the crossword puzzle and send your entry along with the form to: Crossword Competition, c/o Tim Ryan Communications, 69 Fitzwilliam Square, Dublin 2. Entries to arrive not later than Sept 20th. Bernadette Walsh, Templegue, Dublin 16 34 The Professional Insurance Broker