Terms of Business – Version 15 Effective as of 15/08/2025

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Conleith M. Quigley Financial Services Limited trading as Quigley Financial Brokers

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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

Conleith M. Quigley Financial Services Limited trading as Quigley Financial Brokers (C44087) is regulated by the Central Bank of Ireland as an insurance intermediary registered under; the European Union (Insurance Distribution) Regulations 2018 as an Investment Intermediary authorised under the Investment Intermediaries Act, 1995 and as a Mortgage Intermediary authorised under the Consumer Credit Act, 1995 and as a Mortgage Credit Intermediary under the European Union (Consumer Mortgage Credit Agreements) Regulations 2016. Copies of our regulatory authorisations are available on request. The Central Bank of Ireland holds registers of regulated firms. You may contact the Central Bank of Ireland on 1890 777 777 or alternatively visit their website at www.centralbank.ie to verify our credentials Ref. No. C44087.

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Codes of Conduct

Conleith M. Quigley Financial Services Limited is subject to the Consumer Protection Code, Minimum Competency Code and Fitness & Probity Standards which offer protection to consumers. These Codes can be found on the Central Bank’s website www.centralbank.ie.

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Our Services

Conleith M. Quigley Financial Services Limited is a member of Brokers Ireland.

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Our principal business is to provide advice and arrange transactions on behalf of clients in relation to Investment, life, pensions, mortgages and general insurance products.

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We are also authorised as deposit brokers. A full list of insurers, product producers and lending agencies with which we deal is available on request.

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Conleith M. Quigley Financial Services Limited acts as a Financial Broker which means that:

​​a) the principal regulated activities of the firm are provided on the basis of a fair analysis of the market; and

​​b) you have the option to pay in full for our services by means of a fee.

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Fair and Personal Analysis

The concept of fair and personal analysis describes the extent of the choice of products and providers offered by an intermediary within a particular category of life assurance, general insurance, mortgages, and/ or a specialist area. The number of contracts and providers considered must be sufficiently large to enable an intermediary to recommend a product that would be adequate to meet a client’s needs.

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The number of providers that constitutes ‘sufficiently large’ will vary depending on the number of providers operating in the market for a particular product or service and their relative importance in and share of that market. The extent of fair analysis must be such that could be reasonably expected of a professional conducting business, taking into account the accessibility of information and product placement to intermediaries and the cost of the search. 

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In order to ensure that the number of contracts and providers is sufficiently large to constitute a fair analysis of the market, we will consider the following criteria:

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• the needs of the customer

• the size of the customer order

• the number of providers in the market that deal with brokers

• the market share of each of those providers

• the number of relevant products available from each provider

• the availability of information about the products

• the quality of the product and service provided by the provider

• cost and any other relevant consideration

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Investment, Life & Pensions

Conleith M. Quigley Financial Services Limited provides investments, life and pensions on a fair analysis basis i.e. providing services on the basis of a sufficiently large number of contracts and product producers available on the market to enable us to make a recommendation, in accordance with professional criteria, regarding which contract would be adequate to meet your needs.

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We will provide assistance to you for any queries you may have in relation to the policies or in the event of a claim during the life of the policies and we will explain to you the various restrictions, conditions and exclusions attached to your policy.

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However, it is your responsibility to read the policy documents, literature and brochures to ensure that you understand the nature of the policy cover, particularly in relation to IPI (income protection Insurance) and serious illness policies.

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Specifically on the subject of income protection insurance policies it is our policy to explain to you a) the meaning of disability as defined in the policy; b) the benefits available under the policy; c) the general exclusions that apply to the policy; and d) the reductions applied to the benefit where there are disability payments from other sources.

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For a serious illness policy, we will explain clearly to you the restrictions, conditions and general exclusions that attach to that policy.

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Deposits

Conleith M. Quigley Financial Services Limited provides deposits on a limited analysis basis i.e. providing services on the basis of a limited number of contracts and product producers available on the market.

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Non-Life

Conleith M. Quigley Financial Services Limited holds an appointment in respect of home insurance with AVIVA (B-Live) scheme on a limited analysis basis. We will also offer assistance to you in relation to processing claims on policies taken out with us and in seeking renewal terms on your cover. To ensure continuity of cover, where you have an existing policy which is due to expire and where we have been unable to contact you, we may put continuing cover in force whilst awaiting your instruction. You will be liable for any premiums payable to the relevant insurer for the period of time between renewal and when we receive your instruction. You have the right not to avail of this service.

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We also hold an appointment with Zurich as its non-exclusive intermediary for the purpose of introducing clients directly in relation to Home, Private Motor and Light Commercial Vehicle Insurance.

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Mortgages

Through the lenders or other undertakings with which we hold an agency, Conleith M. Quigley Financial Services Limited can provide advice on and arrange mortgage products from the following range: fixed-rate loans, variable rate mortgages, capital & interest mortgages, interest only mortgages, endowment mortgages, pension mortgages and residential investment property.

 

Conleith M. Quigley Financial Services Limited provides mortgage advice on a fair analysis basis (providing services on the basis of a sufficiently large number of contracts and product producers available on the market to enable the firm to make a recommendation, in accordance with professional criteria, regarding which contract would be adequate to meet your needs).

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We will need to collect sufficient information from you before we can offer any advice on housing loans. This is due to the fact that a key issue in relation to mortgage advice is affordability and your credit report. Such information should be produced promptly upon our request.

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Disclosure Information

Any failure to disclose material information may invalidate your claim and render your policy void.

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Commission and Charges

Conleith M. Quigley Financial Services Limited is remunerated by commission and other payments from product producers or lenders on the completion of business. You may choose to pay in full for our services by means of a fee. Where we receive recurring commission, this may form part of the remuneration for initial and ongoing advice provided.

 

We reserve the right to charge additional fees if the number of hours relating to on-going advice/assistance exceeds 1 hr.

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In certain circumstances, it will be necessary to charge a fee for services provided. These are listed below for Investment, Life, Pensions and PRSAs. In other circumstances where fees are chargeable or where you choose to pay in full for our service by fee, we will notify you in advance and agree the scale of fees to be charged if different from fees outlined below.

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If we receive commission from a product provider, this may be offset against the fee which we will charge you. Where the commission is greater than the fee due, the commission will become the amount payable to the firm unless an arrangement to the contrary is made.

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Claw-Back of Commission

Where our remuneration is paid by way of commission from a product provider or lender upon completion of business on your behalf, for professional work undertaken, including but not limited to research, analysis, preparation of compliant records, and provision of tailored recommendations, such commission is payable to us on the condition that the product remains in force for a minimum period (the “claw-back period”). This period varies depending on the product type.

 

If the product is cancelled, redeemed, replaced, or otherwise terminated within the claw-back period and this results in the product provider or lender reclaiming (“clawing back”) all or part of the commission paid to us, you agree to reimburse us for the amount of commission reclaimed. Such reimbursement will be payable by you within 30 days of our written request.

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Fee for Professional Services Rendered Without Subsequent Engagement

Where we meet with you—whether in person or via video conference—for the purposes of providing professional advice, quotations, recommendations, preparing compliant documentation, or arranging transactions in relation to mortgages, investments, insurance, pensions, general insurance products, or any other service we offer, our time and expertise are chargeable irrespective of whether you subsequently proceed with a product or service.

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If you decide not to proceed, an hourly fee will be charged in accordance with our prevailing fee rates, as set out in these Terms of Business. This fee reflects the professional work undertaken, including but not limited to research, analysis, preparation of compliant records, and provision of tailored recommendations, and is payable within 30 days of invoicing​.

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Investment, Life & Pensions

You may elect to deal with us on a fee basis.

Directors: €250 per hour

Financial Advisors: €150 per hour

Support Staff: €50 per hour

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Additional fees may be payable for complex cases or to reflect value, specialist skills or urgency. We will give an estimate of this rate in advance of providing you with services.

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Personal Retirement Savings Accounts (PRSAs) – Fees

Where advice is requested for PRSAs, the following hourly fees will apply:

Directors: €250 per hour

Financial Advisors: €150 per hour

Support Staff: €50 per hour

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Additional fees may be payable for complex cases or to reflect value, specialist skills or urgency. We will give an estimate of this rate in advance of providing you with services.

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Mortgages

Submitting Application to a Lender: €350

At Loan Offer: €650

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Additional fees may be payable for complex cases or to reflect value, specialist skills or urgency. We will give an estimate of this rate in advance of providing you with services.

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We may receive up to 1% (or whatever maximum is applicable) of the loan for arranging mortgage finance. This commission is paid by the mortgage lender and will not be offset against the fee, either in part or in full. The actual amount of commission will be disclosed at a later stage in the ESIS (European Standardised Information Sheet) in the Loan Offer.  Information on the variation in levels of commission payable by the different creditors providing credit agreements being offered are available on our website www.quigley.ie under remuneration.

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Please note that lenders may charge specific fees in certain circumstances and if this applies, these fees will be specified in your Loan Offer. You have the right to pay a fee separately and not include it in the loan. Typically, this situation arises in relation to specialist lending.

 

Our fees will be agreed with you in advance of any business being conducted, we can receive mortgage fees on your authority from your solicitor out of the drawdown of the loan cheque.

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Sustainable Factors - Investment/IBIPs/Pension Advice

In accordance with the Sustainable Finance Disclosure Regulation (‘SFDR’), we inform you that when providing advice on 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.

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We integrate these risks in our advice in the following way: 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.

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When providing advice on insurance-based investment products (‘IBIPs’) or investment advice we do not consider the impacts of our advice that result in negative effects on sustainability factors (namely environmental, social and employee matters, respect for human rights, anti-corruption and anti-bribery matters), as currently there is limited relevant products on the market which meet these criteria. The area of sustainable is relatively new and as the issue progresses, we will review our position. The firm will review this approach on an annual basis.

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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. You must advise us of those changes and request a review of the relevant policy so that we can ensure that you are provided with up to date advice and products best suited to your needs. Failure to contact us in relation to changes in your circumstances or failure to request a review, may result in you having insufficient insurance cover and/or inappropriate investments pensions.

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Conflicts 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.

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Default on payments by clients

My firm will exercise its legal rights to receive payments due to it from clients (fees and insurance premiums) for services provided. In particular, without limitation of the generality of the foregoing, the firm will seek reimbursement for all payments made to insurers on behalf of clients where the firm has acted in good faith in renewing a policy of insurance for the client.

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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.

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Mortgage lenders may seek early repayment of a loan and interest if you default on your repayments. Your home is at risk if you do not maintain your agreed repayments.

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Complaints

We ask that you make any complaints in writing. We will acknowledge your complaint within five business days and we will fully investigate it.

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On completion of our investigation, we will provide you with a written report of the outcome.

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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 Ombudsman or the Pensions Ombudsman. A full copy of our complaints procedure is available on request.

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Data Protection

Conleith M. Quigley Financial Services Limited complies with the requirements of the General Data Protection Regulation 2018 and the Irish Data Protection Act 2018. Conleith M. Quigley Financial Services Limited is committed to protecting and respecting your privacy. We wish to be transparent on how we process your data and show you that we are accountable with the GDPR in relation to not only processing your data but ensuring you understand your rights as a client. 

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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, this will be given to all our clients at the time of data collection.

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We will ensure that this Privacy Notice is easily assessable. Please refer to our website http://www.quigley.ie/privacy-statement.html if this medium is not suitable we will ensure you can easily receive a copy by; hard copy or via email.

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Please contact us at info@quigley.ie if you have any concerns about your personal data.

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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 – the test will be that of the ‘average consumer’ 1 .
 

Before renewal of the contract of insurance, specific questions will be asked. Again, you will be required to answer honestly and with reasonable care. Where you do not provide additional information (after being requested to do so) it can be presumed that the information previously provided remains unchanged.

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/statement of fact
Completed proposal forms or Statements of Facts will be provided to you. These are important documents as they form the basis of insurance contract between the insurer and you the consumer. You should review and confirm that the answers contained within are true and accurate. 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. A court of competent jurisdiction can reduce the pay-out to you if you are in breach of your duties under the Act, in proportion to the breach involved.

1 Average consumer as per Directive No. 2005/29/EC of the European Parliament and of the Council of 11 May 2005 is reasonably well informed and reasonably observant and circumspect, taking into account social, cultural and linguistic factors.

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Cancellation of a Contract of Insurance

You may cancel a contract of insurance, by giving notice in writing to the insurer, within 14 working days after the date you were informed that the contract is concluded. This does not affect the notice periods already provided under European Union (Insurance and Reinsurance) Regulations 2015 (  S.I. No. 485 of 2015  ) or the European Communities (Distance Marketing of Consumer Financial Services) Regulations 2004 (  S.I. No. 853 of 2004  ) which is 30 days in respect of life policies, irrespective of whether the sale took place on a non-face to face basis, and 14 days in respect of general policies and only on sales that took place on a non-face to face basis (distance sales).

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The giving of notice of cancellation by you will have the effect of releasing you from any further obligation arising from the contract of insurance. The insurer cannot impose any costs on you other than the cost of the premium for the period of cover.

This right to cancel does not apply where, in respect of life insurance the contract is for a duration of six months or less, or in respect of general insurance, the duration of the contract is less than one month.
 

Post-Contract Stage and Claims
 

If, in respect of the insurance contract the insurer is not obliged to pay the full claim settlement amount until any repair, replacement or reinstatement work has been completed and specified documents for the work have been furnished to the insurer, the claim settlement deferment amount cannot exceed

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o 5% of the claim settlement amount where the claim settlement amount is less than €40,000, or
o 10% of the claim settlement amount where the claim settlement amount is more than €40,000.

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An insurer may refuse a claim made by you under a contract of insurance where there is a change in the risk insured, including as described in an “alteration of risk” clause, and the circumstances have so changed that it has effectively changed the risk to one which the insurer has not agreed to cover.

Any clause in a contract of insurance that refers to a “material change” will be interpreted as being a change that takes the risk outside what was in the reasonable contemplation of both you and the insurer when the contract was concluded. You must cooperate with the insurer in an investigation of insured events including responding to reasonable requests for
information in an honest and reasonably careful manner and must notify the insurer of the occurrence of an insured event in a reasonable time.

You must notify the insurer of a claim within a reasonable time, or otherwise in accordance with the terms of the contract of insurance. If you become aware after a claim is made of information that would either support or prejudice the claim, you are under a duty to disclose it. (The insurer is under the same duty).

If you make a false or misleading claim in any material respect (and know 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 may notify the consumer advising that they are voiding the contract of insurance, and 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.

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.

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Compensation Scheme

We are members of the Investor Compensation Scheme operated by the Investor Compensation Company Ltd. See below for details.

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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.

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A right to compensation will arise only:

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• 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; an

• 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:

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• 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.