New commission disclosure and consent obligations
Following the recent Johnson, Wrench and Hopcraft Court of Appeal judgment, we have decided to put in place new disclosure arrangements to mitigate potential future risks for brokers, and us as a lender. We are taking steps to ensure that customers receive full disclosure of the arrangements, as outlined below.
The new disclosure will ensure customers are informed of the following:
- The relationship between us and you
- The existence of commission
- The nature of the commission
- The amount of commission you’ll receive
- The method we use to calculate the commission amount
We’re developing a new digital solution for checking commission disclosure, that will be delivered by mid-December. This will be a simple, easy and compliant solution, for both personal and commercial lines brokers, which will be applied for bordereau and non-bordereau business.
On this page:
What does this mean for me?
New consent process for non-bordereau business
In the meantime, we are introducing a Commission Disclosure Consent (CDC) form, which will be used for non-bordereau, commercial lines business from Monday, 25 November 2024. The CDC form will need to be used for all UK new business applications and renewals loaded from this date. Any new business or renewal applications without a CDC form, after this date will be automatically rejected.
Let’s look at this journey:
- Client is interested in premium finance, so you complete section 1 of the CDC form (available here to download)
- You email the CDC form to the customer and they complete section 2, including a wet signature, and return the form to you
- You send the form to us at CommercialNewBusiness.Mailbox@closebrothers.com and retain the form as evidence of the informed consent
- You process the premium finance application as usual to CBPF
Download the Commission Disclosure Consent (CDC) Form
Click the button below to download the CDC Form, for non-bordereau business
Download the CDC Form Broker Guide
Click the button below to access the CDC Form Broker Guide.