Provider Commission Provider Initial % of fund value. Fund based start month % % % % 0.5% % 0.
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1 COBS 6 Annex 5 G Calculation of a maximum rate of commission 1. The net present value of each commission (or equivalent) rate may be calculated by adopting the method set out in the worked example below, used in conjunction with tables of sample net present value factors issued by the FSA. These factors will be calculated using the assumptions set out in paragraphs 8 to 12 of COBS 6 Annex 4G. Worked Example of Disclosure in a menu 2. For the purposes of the following worked example four variations of commission (or equivalent) are shown for an investment bond. The market averages and NPV factors are purely illustrative. A firm has commission arrangements for the sale of investment bonds with five product providers involving all four variations. The firm retains all commissions from each provider. The arrangements are: Provider Provider Initial % of fund value Fund based start month % % % % 0.5% % 0.25% 1 Stage 1 - Comparison of net present value The firm has to decide which provider pays "our maximum". The test is to calculate the net present value of the different commissions using the assumptions prescribed by the FSA. To do this, the method in form 1b below is used. The firm needs to look up the table of NPV factors which shall be made available by the FSA. Looking these up, and completing the form as follows gives: Product group Investment Bonds Rate A Initial NPV B Value = Rate x C = A x B Fund Based Renewal / Trail Rate (& Start Month) J NPV K Value= Rate x L = J x K Total NPV M = C + L % % % 2 4.5% % % % % 0.75% from month % from month % 2.98% % 5.47%
2 5 3.5% % 0.25% from month % 4.74% So commission shape 4 has the highest net present value and is thus "our maximum". Stage 2 Worked example An example is calculated by applying "our maximum" rates to the prescribed lump sum or monthly amounts in this case gives " 300 immediately plus 50 each year from year 1". Stage 3 Market Average "The market average" is the market average rate published by the FSA expressed in the shape that most corresponds to the shape of "our maximum". To do this, the method used in form 2 below is used. The firm needs to look up the table of NPV factors and the table of market average NPVs prescribed by the FSA. Looking these up, and completing the form as follows gives:
3 Form 1 (Worked Example) Product group Investment Bond Market Average NPV 5.0% Shape of your maximum Fund Based Renewal / Trail Premium Based Renewal Spread initial / Non-Indemnified Initial / Indemnified rate Start month rate Start month rate Spread period rate A 0.5% Month % NPV B Value of Shape average - Fund Based average Premium Based average - Spread Initial average - Initial Market Average Shape C = A x B D1 D2 D3 D4 E = D B 2.47% % 2.47% 2.47% / = 0.5% from month % % = 2.53% % / = 2.5% Therefore the market average, expressed in the shape that most closely resembles "our maximum" is 2.5% of the lump sum plus 0.5% of the fund from month 1
4 Stage 4 Enter the appropriate figures in the menu as shown below. Lump sum products Example term or age Comparison of costs Example based on 10,000 lump sum Our maximum Market average This shows the maximum costs of our sales and advice for a lump sum investment of 10,000 ignoring any changes to fund value Savings and investments Investment bond Any 3.0% of the amount you invest plus 0.5% of your fund value each year from year 1 2.5% of the amount you invest plus 0.5% of your fund value each year from year in year 1 plus 50 each year from year 1 (The actual amount will vary in line with your fund
5 Form 1a Calculation of Maximum Amounts (Monthly Premium Products) This form should be used to help decide which of the commission options received for a product group in the "monthly products" table should appear as "our maximum" on the menu. Product group Initial / Indemnified Spread Initial Premium Based Renewal Fund Based Renewal / Trail Value = Value= Value= Value= NPV Rate NPV Rate NPV NPV Rate x Rate x Rate x Rate Rate x Rate (& Spread (& Start Month) (& Start Month) Period) A B C = A x B D E F = D x E G H I = G x H J K L = J x K Total NPV M = C + F + I + L The maximum rate of commission for this product group is the shape with the highest Total NPV (column M). This maximum rate of commission should be included in the menu for this product group
6 Notes for completion of Form 1a 1. A separate form should be completed for all monthly product groupings appearing on the menu. 2. Complete a separate row for each potential maximum commission shape that you receive in the chosen product group. 3. shapes that are clearly lower in value than others of the same shape should be omitted for example, 15% initial + 0.5% fund based paid from month 12 is clearly lower than 20% initial + 0.5% fund based paid from month 12, and so only the latter needs to be included in the calculations. 4. rates used should be the highest rates of the total commission payable that you may retain; 5. rates should be entered for each commission type as follows: Column A (Initial/Indemnified) - a percentage of the first 12 months' premiums; Column D (Spread Initial/Non-Indemnified Initial) a percentage of each premium paid in the initial commission period; Column I (Premium based renewal) a percentage of each premium paid in the renewal period; Column L (Fund Based renewal/trail) a percentage of the fund value each year. 6. Level commissions, payable as a percentage of all monthly premiums, should be treated as premium-based renewal commissions. 7. The relevant NPV s in columns B, E, H & K should be inserted for the relevant Product Group, Type, Spread Period and Start Month. They can be obtained from the document "Published NPV s". 8. Columns C, F, I, L & M should be calculated based on the figures inserted in the previous columns. 9. The commission shape which has the highest total NPV in column M should be used in the "Our Maximum" section of the menu.
7 Form 1b Calculation of Maximum Amounts (Lump Sum Products) This form should be used to help decide which of the commission options received for a product group in the "lump sum products" table should appear as "our maximum" on the menu. Product group Initial Rate NPV Value = Rate x A B C = A x B Rate (& Start Month) J Fund Based Renewal / Trail NPV K Value= Rate x L = J x K Total NPV M = C + L The maximum rate of commission for this product group is the shape with the highest Total NPV (column M). This maximum rate of commission should be included in the menu for this product group
8 Notes for completion of Form 1b 1. A separate form should be completed for all lump sum products appearing on the menu. 2. Complete a separate row for each potential maximum commission shape that you receive in the chosen product group. 3. shapes that are clearly lower in value than others of the same shape should be omitted for example, 15% initial + 0.5% fund based paid from month 12 is clearly lower than 20% initial + 0.5% fund based paid from month 12, and so only the latter needs to be included in the calculations. 4. rates used should be the highest rates of the total commission payable that you may retain. 5. rates should be entered for each commission type as follows: Column A (Initial) - a percentage of the lump sum payment; Column J (Fund Based renewal/trail) a percentage of the fund value each year. 6. The relevant NPV s in columns B & K should be inserted for the relevant Product Group, Type and Start Month. They can be viewed in the document "Published NPV s". 7. Columns C, L & M should be calculated based on the figures inserted in the previous columns. 8. The commission shape which has the highest total NPV in column M should be used in the "Our Maximum" section of the menu.
9 Form 2 Re-expression of market average commission This form should be used to re-express the market average NPV into the relevant shape, for use in the menu. Product group Market Average NPV Shape of your maximum A Fund Based Renewal / Trail Premium Based Renewal Spread initial / Non-Indemnified Initial / Indemnified rate Start month rate Start month rate Spread period rate NPV B Value of Shape average - Fund Based average Premium Based average - Spread Initial average - Initial Market Average Shape C = A x B D1 D2 D3 D4 E = D B
10 Notes for completion of Form 2 1. A separate form should be completed for each product group appearing on your menu; 2. The Market Average NPV should be obtained from the FSA's most recent published list of market averages, choosing the appropriate rate for the relevant product group. 3. In row A, enter the details of the commission shape that the market average is to be expressed in. This should be the commission shape shown as "your maximum" for the relevant product group in your menu. 4. rates should be entered for each commission type as follows: Fund Based renewal/trail a percentage of the fund value each year; Premium based renewal a percentage of each premium paid in the renewal period; Spread Initial/Non-Indemnified Initial a percentage of each premium paid in the initial commission period; Initial/Indemnified - a percentage of the first 12 months' premiums, or a percentage of the lump sum, as appropriate. 5. Level commissions, payable as a percentage of all monthly premiums, should be treated as premium-based renewal commissions. 6. Where "your maximum" commission does not contain a commission type (e.g. your maximum has no spread initial commission), the column relating to that commission type should be left blank. 7. The relevant NPV s in row B should be inserted for the relevant Product Group, Type, Spread Period and Start Month. They can be obtained from the document "Published NPV s". 8. Row C should be calculated as the product of the relevant commission rate in row A and the NPV factor in row B. 9. Row D1 should be calculated as the lower of: the Market Average NPV, and Row C - The Value of Shape for the fund based commission type (but the note below)
11 Note: If the commission shape in row A contains no premium-based, spread initial or initial/indemnified commission (i.e. if fund based commission is the final commission type being considered) then the calculation in row C should be ignored when calculating D1. In this instance, the value in D1 should be equal to: the Market Average NPV 10. Row D2 should be calculated as the lower of: The Market Average NPV minus the value calculated for row D1; and Row C The Value of Shape for the premium based commission type (but note below). If this calculation gives a negative value, D2 should be set to zero. Note: If the commission shape in row A contains no spread initial or initial/indemnified commission (i.e. if premium-based commission is the final commission type being considered) then the calculation in row C should be ignored when calculating D2. In this instance, the value in D2 should be equal to: The Market Average NPV minus the value calculated for row D Row D3 should be calculated as the lower of: The Market Average NPV minus the value calculated for row D1, minus the value calculated for row D2, and Row C The Value of Shape for the spread initial / non-indemnified commission type (but note below). If this calculation gives a negative value, D2 should be set to zero. Note: If the commission shape in row A contains no initial/indemnified commission (i.e. if premium-based commission is the final commission type being considered) then the calculation in row C should be ignored when calculating D3. In this instance, the value in D3 should be equal to: The Market Average NPV minus the value calculated for row D1, minus the value calculated for row D2.
12 12. Row D4 should be calculated as: The Market Average NPV minus the value calculated for row D1, minus the value calculated for row D2, minus the value calculated for row D3. If this calculation gives a negative value, D4 should be set to zero. 13. Row E should be calculated as the value in the relevant row D (for that commission type, e.g. row D2 for premium based renewal commission) divided by the relevant NPV factor in row B. For presentation in the menu, this result should be rounded to the nearest 0.1% (or the nearest 0.25%, if fund-based commission is paid as an exact multiple of this).
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