Terms of Business

(These terms of business are effective from 24th March 2026 and remains up to date until amended)

McGeough Financial Consultants Ltd. of Market Square, Letterkenny, Co. Donegal specialises in the provision of Life Insurance, Investment and Pension services to consumers.

These Terms of Business set out the general terms under which our firm will provide business services to you and the respective duties and responsibilities of both the firm and you in relation to such services. Please ensure that you read these terms thoroughly and if you have any queries, we will be happy to clarify them. If any material changes are made to these terms, we will notify you.

Authorisation with the Central Bank of Ireland

McGeough Financial Consultants Ltd.C44617 is regulated by the Central Bank of Ireland as an Insurance Intermediary under the Insurance Distribution Regulations and Investment Intermediary under the Investment Intermediaries Act, and is subject to various regulatory requirements including the Consumer Protection Code/Regulations, Minimum Competency Code, Fitness & Probity Standards and the Individual Accountability Framework, which are designed primarily to inform and protect you, our client. These codes can be found on the Central Bank’s website www.centralbank.ie The Central Bank holds registers of authorised firms- our authorisations can be verified by contacting the Central Bank of Ireland at: New Wapping Street, North Wall Quay, Dublin 1 – Tel. 0818 681 681 or on the Central Bank’s website http://www.centralbank.ie

Services

McGeough Financial Consultants Ltd is a member of Brokers Ireland. Our principal business is to provide advice and arrange transactions on behalf of clients in relation to life & pensions/ products. A full list of product producers with which we deal is available on request.

We do not offer any opinion or advice (professional or otherwise) on any product provider or products offered by any provider unless McGeough Financial Consultants Ltd holds an agency to place business with such providers. Should you engage with such providers or invest with them McGeough Financial Consultants Ltd will take no responsibility for any engagement or the soundness of any investment you may make.

Fair and Personal Analysis

Distinction between Fair Analysis and Limited Analysis of the Market.

When we provide advice we may provide services on the basis of fair analysis of the market or limited analysis of the market depending on the particular service/product to be provided.

Fair analysis of the market means that a sufficiently large number of product providers available in the market are considered when identifying suitable providers/products for clients.

Limited analysis of the market means providing services on the basis of a limited number of contracts and product producers on the market, that is to say, while not tied to one product producer the services are not provided on the basis of a fair analysis of the market.

In relation to insurance based products, we provide advice on a fair and personal analysis basis. We are not under any contractual obligation to conduct insurance business exclusively with any insurance undertaking, do not have a holding, direct or indirect, representing 10% or more of the voting rights or of the capital in any insurance undertaking, and equally no insurance undertaking holds any such voting rights or capital in our firm. We represent our customers when dealing with insurers.

In relation to non-insurance based investment products, other than bank deposit accounts, we provide advice on a limited analysis and nonindependent basis, as we may receive remuneration from the product providers of such products. These products include structured products which may typically be listed bonds and shares, collective instruments, unit trusts and tracker bonds. The type of firms we may engage with for limited analysis are BCP, Quest Retirement Solutions, Davy, Cantor, Goodbody, and Newcourt.

Renumeration Policy

McGeough Financial Consultants Ltd. is remunerated by commission from the product providers we deal with, details of which are available on our website. We may receive renewal commissions on an ongoing basis – these contribute to our administration costs in providing you with services.

Fees:

You may elect to pay for our services by way of fees. If so, we will agree a fee basis with you. Commissions which we may receive for business placed will not be offset against fees unless agreed with you in writing.

Ongoing Remuneration:

We wish to inform you that we receive ongoing remuneration from Product Providers in respect of the financial service provided to you. This remuneration is based on a percentage of the value of your investment, or annual premiums, and is intended to cover the ongoing service that we provide to you in relation to this product.

Sustainable Finance Disclosure (‘SFRD’)

In accordance with the Sustainable Finance Disclosure Regulation (‘SFDR’), we inform you that when providing advice on insurance-based and non-insurance based investment products/Investments, we assess, in addition to relevant financial risks, relevant sustainability risks as far as this information is available in relation the products proposed/advised on. This means that we assess environmental, social or governance events/conditions that, if they occur, could have a material negative impact on the value of the investment.

We integrate these risks in our advice. We review product provider literature in relation to sustainability risks, we liaise with the providers in relation to any queries in relation to the funds. This information is reviewed by the firm on an ongoing basis.

Conflict of Interest

It is the policy of our firm to avoid conflicts of interest in providing services to you. However, where an unavoidable conflict of interest arises, we will advise you of this in writing before providing you with any service and the firm will take all steps within its control to appropriately manage the conflict and minimise the impact of the conflict on the consumer. David McGeough is responsible for managing potential conflicts of interest.

In some cases, we may be a party to a profit-share arrangement with product producers where we provide extra services for the provider. Any business arranged with these providers on your behalf is placed with them as they are at the time of placement the most suitable to meet your requirements taking all relevant information, demands and needs into account

Default on payments by clients

We will exercise our legal rights to receive payments due to us from clients (fees and insurance premiums) for services provided. Product producers may withdraw benefits or cover in the event of default on payments due under policies of insurance or other products arranged for you. We would refer you to policy documents or product terms for the details of such provisions.

Complaints Procedure

Upon receipt of an oral complaint, we will provide the option to have the complaint addressed through the firms established complaints procedure. We will permit and facilitate submission of complaints in writing by post and by electronic means. We will acknowledge your complaint in writing within 5 working days and we will fully investigate it. We shall investigate the complaint as swiftly as possible, and the complainant will receive an update on the complaint at intervals of not greater than 20 working days starting from the date on which the complaint is made. On completion of our investigation, we will provide you with a written report of the outcome. In the event that you are still dissatisfied with our handling of or response to your complaint, you are entitled to refer the matter to the Financial Services and Pensions Ombudsman (FSPO). A full copy of our complaint’s procedure is on our website and available on request.

Ongoing Sustainability of Products

The firm’s services do not include ongoing suitability assessments of insurance, pensions and investment products unless this has been agreed with you in writing. The rationale for this decision will be provided to you, the client, through a separate communication.

Regular Reviews

It is in your best interests that you review, on a regular basis, the products which we have arranged for you. As your circumstances change, your needs will change which may result in you having insufficient insurance cover and/or inappropriate investments. We would therefore advise that you contact us to ensure that you are provided with upto-date advice and products best suited to your needs.

Consumer Insurance Contracts Act 2019

The Consumer Insurance Contracts Act is aimed at enhancing consumer protection. Set out below are some specific points arising from the new legislation.

Consumers: Duty of Disclosure when completing documentation for new business/renewals and midterm adjustments:

You are required to answer all questions posed by us or the insurer honestly and with reasonable care. Failure to answer all questions honestly and with reasonable care can result in the Insurer being able to rely on proportionate remedies for misrepresentation, which include but are not limited to the insurer voiding the contract of insurance. If a policy is cancelled by an insurer for any reason including payment default you may encounter difficulty in purchasing insurance in the future.

Completed proposal forms

A copy of an application form or proposal form, will be provided to you showing the insurers specific questions and information required for underwriting purposes. You must review the document(s) provided and check that the answers you provided to insurers, or to us when assisting you to complete the application form or proposal form, are accurate. If any information or answer provided is incorrect you must notify us immediately.

New Business

You may cancel a contract of insurance on receipt of your policy documents. The cancellation timescales and process will be outlined in these documents.

You are under a duty to pay your premium within a reasonable time, or otherwise in accordance with the terms of the contract of insurance.

Post-Contract Stage and Claims

The consumer must notify the insurer of a claim within a reasonable time, or otherwise in accordance with the terms of the contract of insurance.

If, when making a claim, a consumer provides information that is false or misleading in any material respect (and knows it to be false or misleading or consciously disregards whether it is) the insurer is entitled to refuse to pay and to terminate the contract.

Where an insurer becomes aware that a consumer has made a fraudulent claim, they must notify the consumer on paper or on another durable means advising that they are avoiding the contract of insurance. It will be treated as being terminated from the date of the submission of the fraudulent claim. The insurer may refuse all liability in respect of any claim made after the date of the fraudulent act, and the insurer is under no obligation to return any of the premiums paid under the contract.

An insurer may repudiate liability or limit the claim payment if it establishes that there has been non-disclosure of material information and that the insurer would not have issued a policy or issued a policy on the terms on which it did if that information had been known to the insurer. Likewise, where there has been misrepresentation by a consumer, an insurer may, depending on the type of misrepresentation, reduce the amount of a claim or refuse to pay a claim.

Data Protection

McGeough Financial Consultants Ltd. complies with the requirements of the General Data Protection Regulation 2018 and the Irish Data Protection Act 2018. We are committed to protecting and respecting your privacy. We wish to be transparent on how we are accountable with the GDPR in relation to not only processing your date but ensuring your understand your rights as a client. The data will be processed only in ways compatible with the purposes for which it was given and as outlined in our Data Privacy Notice which will be given to all our clients at the time of data collection. We will ensure that this Privacy Notice is easily assessable. Please refer to our website www.mcgeoughfinancial.ie. If this medium is not suitable we can easily provide you with a copy of post or email.

If you have any concerns about your personal data you may contact us by post, phone or email info@mcgfinance.ie.

Investor Compensation Scheme

The Investor Compensation Act, 1998 provides for the establishment of a compensation scheme and the payment, in certain circumstances, of compensation to certain clients (known as eligible investors) of authorised investment firms, as defined in that Act.

The Investor Compensation Company Ltd. (ICCL) was established under the 1998 Act to operate such a compensation scheme, and our firm is a member of this scheme.

Compensation may be payable where money or investment instruments owed or belonging to clients and held, administered or managed by the firm cannot be returned to those clients for the time being and where there is no reasonably foreseeable opportunity of the firm being able to do so.

A right to compensation will arise only:

If the client is an eligible investor as defined in the Act; and

If it transpires that the firm is not in a position to return client money or investment instruments owned or belonging to the clients of the firm; and

To the extent that the client’s loss is recognised for the purposes of the Act.

Where an entitlement to compensation is established, the compensation payable will be the lesser of:

90% of the amount of the client’s loss which is recognised for the purposes of the Investor Compensation Act, 1998; or

Compensation of up to €20,000.

For further information, contact the Investor Compensation Company Ltd. at (01) 224 4955.

Brokers Ireland Clients’ Compensation and Membership Benefits Scheme (BIC)

We are also members of the Brokers Ireland Clients’ Compensation and Membership Benefits Scheme (BIC). Subject to the rules of the scheme the liabilities of its members firms up to a maximum of €100,000 per client (or €250,000 in aggregate) may be discharged by the fund on its behalf if the member firm is unable to do so, where the above detailed Investor Compensation Scheme has failed to adequately compensate any client of the member. Further details are available on request.

Client acknowledgement & Consent

I/We acknowledge and confirm that I/we have been provided with a copy of the Terms of Business for McGeough Financial Consultants Ltd. and that I/we have read through and understand these terms.

I/We consent to McGeough Financial Consultants Ltd. and its associated forms contacting me/us by letter, email, SMS text or telephone regarding any products which may be of interest. Where a third party has introduced me to McGeough Financial Consultants Ltd., I/we also consent to the disclosure to that third party of information.

Where you have given us your email address, we take that as consent as an agreed method for forwarding to you any relevant documents in relation to providing you with our services.

Agreed Method of contact:

Email: Yes/ No

Phone: Yes/ No

SMS: Yes/ No

Post: Yes/ No

Please do not contact me. Yes/ No

Even if you do subscribe now you can always unsubscribe at any time

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