Q&A RELATING TO CHANGES TO ADVISER CHARGING ON OFFSHORE BONDS IN THE UK FOR FINANCIAL ADVISERS ONLY Please note this document is based on our interpretation of current law and taxation practice in the UK, Ireland and the Isle of Man as at 30 January 2015, which could change in the future and is subject to individual circumstances.
CONTENTS Background information 3 Types of advice 3 What is the process for requesting the appointment of a discretionary asset manager? 6 Pipeline applications 7 Charges taken for advice pre and post 1 September 2014 8 Changing existing charging agreements 8 VAT and charges for advice 8 Platforms 9 Old Mutual International Trust Company Limited 9 Old Mutual Wealth s Onshore Bonds 9 Illustrations 9 Literature 10 Contact us 10 All references in this document to Old Mutual International refer to Old Mutual International Isle of Man Limited and all references to Old Mutual International Ireland refer to Old Mutual International Ireland dac. References to Old Mutual Wealth refer to Old Mutual Wealth Life & Pensions Limited. 2
BACKGROUND INFORMATION On 3 July 2014 HM Revenue & Customs (HMRC) confirmed that, providing certain conditions are met, all advice relating to investments linked to onshore or offshore bonds held by UK residents with a UK financial adviser can be considered as advice to the life company and not the policyholder. We have received confirmation from HMRC that our new model for investment advisers meets the conditions and their fees for investment advice will not be treated as part surrenders which affect the policyholder s 5% annual tax deferred allowance. From 1 September 2014, any charges for investment advice can be facilitated by our Old Mutual International and Old Mutual International Ireland bonds held by UK residents with a UK financial adviser without it affecting the policyholder s 5% annual tax deferred allowance providing they are set up in a specific way. The tax position created by facilitating these charges will depend on who provides the advice and what the advice relates to. The 5% annual tax deferred allowance does not apply to UK companies or UK trust companies holding bonds as they are subject to the loan relationship rules so these changes have no impact on their tax position. The changes apply to the following Old Mutual International and Old Mutual International Ireland bonds: OLD MUTUAL INTERNATIONAL International Portfolio Bond Life International Portfolio Bond Redemption OLD MUTUAL INTERNATIONAL IRELAND European Portfolio Bond Life PRE 31 DECEMBER 2012 BONDS The changes also apply to the following Old Mutual International and Old Mutual International Ireland Bonds that were closed to new business in the UK on 31 December 2012: OLD MUTUAL INTERNATIONAL Collective Investment Bond Executive Investment Bond* Collective Redemption Bond Executive Redemption Bond* OLD MUTUAL INTERNATIONAL IRELAND European Collective Investment Bond.* Please note: the European Executive Investment Bond is not listed because it is not possible to appoint a Discretionary Asset Manager to this bond as the Irish VAT exemption does not apply. * These bonds are only sold outside of the UK so this only applies where the policyholder becomes UK resident. There is an annual artificial investment gain of 15% of the premium(s) invested on a cumulative basis, which result in an annual tax charge for UK residents holding one of these bonds until the policyholder requests to restrict the range of assets for the bond. TYPES OF ADVICE Please find below a table that outlines the terms we are using in this document to describe the different types of advice related charges. Adviser charges Discretionary asset manager Discretionary asset manager charges This term applies to charges taken by a financial adviser on any matter not relating to the underlying assets linked to the bond. This is a person or firm appointed by Old Mutual International or Old Mutual International Ireland to either manage assets (Discretionary basis) or advise on assets (Advisory basis) held by Old Mutual International or Old Mutual International Ireland. This term applies to a portfolio fund charge taken from an Old Mutual International or Old Mutual International Ireland policy to reflect fees paid to a discretionary asset manager. 3
WHAT IS THE DIFFERENCE BETWEEN A DISCRETIONARY ASSET MANAGER WHO IS APPOINTED ON A DISCRETIONARY BASIS AND A DISCRETIONARY ASSET MANAGER WHO IS APPOINTED ON AN ADVISORY BASIS? The difference between discretionary and advisory is: Discretionary means the adviser holds regulatory authority to carry out discretionary investment management activities based on an agreed investment mandate and does not need to agree any changes to the assets with Old Mutual International/Old Mutual International Ireland before they submit the asset dealing instructions. Advisory means the adviser holds the regulatory authority to advise on investments and can only submit asset dealing instructions following agreement with Old Mutual International/Old Mutual International Ireland. For the advisory model, all investment decisions will be made by Old Mutual International or Old Mutual International Ireland. However, Old Mutual International/Old Mutual International Ireland requests under the advisory model that any investment recommendations are also agreed with the policyholder before they are submitted to Old Mutual International/Old Mutual International Ireland. DISCRETIONARY ASSET MANAGER OPTIONS Type of authority held Discretionary Basis Advisory Basis Who appoints them? What does the appointment relate to? Old Mutual International/ Old Mutual International Ireland Old Mutual International s/ Old Mutual International Ireland s assets which are linked to the policyholder s bond Old Mutual International/ Old Mutual International Ireland Old Mutual International s/ Old Mutual International Ireland s assets which are linked to the policyholder s bond Services they provide to us? Discretionary investment management Advising on investments Who makes the investment decisions? The discretionary asset manager based on a discretionary investment mandate Old Mutual International/Old Mutual International Ireland make investment decisions based on the discretionary asset manager s recommendations WHAT IS THE DIFFERENCE BETWEEN A DISCRETIONARY ASSET MANAGER AND A FUND ADVISER? A discretionary asset manager is appointed by Old Mutual International or Old Mutual International Ireland to provide investment services and the fees paid to them by Old Mutual International or Old Mutual International Ireland are reflected as a policy charge on the policyholder s bond. A fund adviser is appointed by the policyholder to provide investment services and the fees paid to them are treated as taxable withdrawals which will reduce the policyholder s 5% tax deferred allowance. WHAT TYPE OF ADVICE COUNTS TOWARDS THE POLICYHOLDER S 5% ANNUAL TAX DEFERRED ALLOWANCE? Type of charge Forms part of the policyholder s 5% annual tax deferred allowance Adviser charges Discretionary asset manager charges appointed on an advisory basis Discretionary asset manager charges appointed on a discretionary basis Yes No* No* * These charges reflect the fees Old Mutual International or Old Mutual International Ireland pay to the discretionary asset manager. The fees are not treated as part of the policyholder s annual 5% tax deferred entitlement. This is because the service provided by the discretionary asset manager on the bond s assets is provided to either Old Mutual International or Old Mutual International Ireland. Old Mutual International or Old Mutual International Ireland are therefore able to make a portfolio fund charge to reflect the fees they are paying and it is this charge that is deducted from the bond. CAN AN ADVISER PROVIDE PERSONAL RECOMMENDATIONS ALONGSIDE INVESTMENT ADVICE? If the adviser has the correct regulatory permissions, they can act as a financial adviser and a discretionary asset manager. For the fees to be facilitated as a discretionary asset manager charge, the financial adviser must prove that they have the appropriate permissions and be appointed as a discretionary asset manager by Old Mutual International or Old Mutual International Ireland. A client can request for an adviser to be appointed as a discretionary asset manager by completing the Request for Old Mutual International Isle of Man Limited ( Old Mutual International )/Old Mutual International Ireland dac ( Old Mutual International Ireland ) to appoint a discretionary asset manager form. The following flow chart explains the processes that must be followed for an adviser to take a charge either for investment advice or carrying out discretionary investment management that does not form part of the policyholder s 5% tax deferred allowance. 4
DISCRETIONARY BASIS An adviser must have the correct regulatory permissions to provide investment advice or discretionary investment management ADVISORY BASIS The first step to offering this service is to sign the Investment Management Agreement with Old Mutual International and/or Old Mutual International Ireland. This is required as you will be making investment decisions on behalf of Old Mutual International or Old Mutual International Ireland. The Investment Management Agreement details your responsibilities to Old Mutual International and/or Old Mutual International Ireland and our general investment mandate. When obtaining an illustration, the adviser must provide details of the split between the financial advice and the investment advice provided. This information that the adviser provides is displayed on the illustration so the client can clearly see how much they are paying for the financial advice and the investment advice. When obtaining an illustration, the adviser must provide details of the split between the financial advice and the discretionary investment management charges. This information is displayed on the illustration so the client can clearly see how much they are paying for the financial advice and the discretionary investment management service. When the client (or you on behalf of the client) submits their application, they also need to complete the Request for Old Mutual International Isle of Man Limited ( Old Mutual International )/Old Mutual International Ireland dac ( Old Mutual International Ireland ) to appoint a discretionary asset manager form. When the client (or you on behalf of the client) submits their application, they also need to complete the Request for Old Mutual International Isle of Man Limited ( Old Mutual International )/Old Mutual International Ireland dac ( Old Mutual International Ireland ) to appoint a discretionary asset manager form. Along with the Request for Old Mutual International or Old Mutual International Ireland to appoint authorised custodians form and a Letter of Authority. Subject to our approval, the adviser will be appointed as the discretionary asset manager to offer investment recommendations in respect of Old Mutual International s or Old Mutual International Ireland s assets which are linked to the portfolio fund for the client s bond. Subject to our approval, the adviser will be appointed as the discretionary asset manager to offer discretionary investment management in respect of Old Mutual International s or Old Mutual International Ireland s assets which are linked to the portfolio fund for the client s bond. Once the above agreement is in place, the adviser will then receive the: Adviser charges (Initial fee or ongoing service fee in respect of the financial advice) this charge is taxable and does form part of the client s 5% annual tax deferred allowance. Discretionary asset manager charge this charge is only for the investment advice and is not taxable and does not form part of the policyholder s 5% annual tax deferred allowance. 5
HOW AND WHEN WILL THE DISCRETIONARY ASSET MANAGER CHARGE BE PAID? The charge can be either: (a) a percentage each year of the value of the portfolio fund to be taken quarterly or (b) a monetary amount to paid quarterly. Quarterly relates to each calendar quarter. WHICH CHARGES ARE STILL TREATED AS TAXABLE WITHDRAWALS? Any advice that is not related to investment advice in respect of the assets linked to the value of the bond will still be taken as a taxable withdrawal. Only investment advice that is given by a suitably qualified adviser and nominated using the Request for Old Mutual International Isle of Man Limited ( Old Mutual International )/Old Mutual International Ireland dac ( Old Mutual International Ireland ) to appoint a discretionary asset manager form will be treated as non-taxable. Advice relating to any other matter will be treated as advice to the policyholder and therefore will form part of the policyholder s annual 5% tax deferred entitlement. WHAT IS THE DIFFERENCE IN PROCESS BETWEEN A DISCRETIONARY ASSET MANAGER ON AN ADVISORY BASIS OR ON A DISCRETIONARY BASIS? ADVISORY Where the discretionary asset manager (DAM) is appointed on an advisory basis, the legal agreement between them and Old Mutual International/Old Mutual International Ireland is included in the request form and therefore is required each time a client wishes to request Old Mutual International/Old Mutual International Ireland to consider this service. The discretionary asset manager cannot make investment decisions and must ensure they provide investment recommendations to Old Mutual International/Old Mutual International Ireland as appropriate. Old Mutual International/Old Mutual International Ireland insist as part of the agreement that the policyholder agrees to the advisory DAM s investment recommendations and that the advisory DAM keeps copies of these records. Old Mutual International/Old Mutual International Ireland may request sight of the written records and failure to provide these may result in termination of the advisory DAM s appointment. Please note: The Financial Conduct Authority released a press announcement on 21 August 2014 that they are currently investigating whether appointing the policyholder as an agent for the insurer will deem the policyholder to be a professional client and therefore unable to complain to the UK Financial Ombudsman Service (FOS). This is not yet certain. Also, this announcement and any subsequent loss of the right to complain to FOS does not affect the policyholder s right to complain to Old Mutual International or Old Mutual International Ireland, nor their respective Financial Services Ombudsman. DISCRETIONARY Where the discretionary asset manager is appointed on a discretionary basis, the legal agreement between them and Old Mutual International/ Old Mutual International Ireland is drawn up as a one off agreement which is separate to the policyholder request form. The legal agreement is signed following due diligence being completed by Old Mutual International/Old Mutual International Ireland and includes a generic investment mandate. The policyholder request form provides additional conditions/ restrictions to the investment mandate that the discretionary asset manager must follow. The discretionary asset manager makes investment decisions based on the investment mandate and is responsible for those decisions. Old Mutual International/Old Mutual International Ireland will monitor the investment dealing being carried out to ensure that the discretionary asset manager is acting within the investment mandate and any breach could result in termination of the appointment of the discretionary asset manager. WHAT IS THE PROCESS FOR REQUESTING THE APPOINTMENT OF A DISCRETIONARY ASSET MANAGER? ONLINE APPLICATIONS The easiest, fastest and most convenient way of applying for a bond is by submitting an application online through Wealth Interactive. If you have not registered for Wealth Interactive, please visit www.oldmutualinternational.com/wealthinteractive to find out how you and your clients can benefit from our online wealth management service. The following section explains the process for requesting that a discretionary asset manager is appointed either to manage the assets held with our default custodian or an authorised custodian: APPOINTING A DISCRETIONARY ASSET MANAGER TO MANAGE ASSETS HELD WITH OUR DEFAULT CUSTODIAN (OLD MUTUAL INTERNATIONAL OR OLD MUTUAL INTERNATIONAL IRELAND) You or your client do not need to select online that they wish to appoint a discretionary asset manager to manage the assets held by our default custodian as part of the client s bond application that is being submitted. They just need to complete a Request for Old Mutual International Isle of Man Limited ( Old Mutual International )/Old Mutual International Ireland dac ( Old Mutual International Ireland ) to appoint a discretionary asset manager form and either email it to PBMAINTENANCE@ominternational.com or post it to us. If you want to illustrate the discretionary asset manager charge up front, you will need to contact our sales support centre who can provide an illustration for you. (See Contact us on page 10) 6
APPOINTING A DISCRETIONARY ASSET MANAGER FOR ASSETS HELD BY AN AUTHORISED CUSTODIAN When you submit your client s application online, you can select the option to appoint a discretionary asset manager on screen. You need to click on the link to the Request for Old Mutual International Isle of Man Limited ( Old Mutual International )/Old Mutual International Ireland dac ( Old Mutual International Ireland ) to appoint a discretionary asset manager form. On this screen there is also the option to upload the form to Wealth Interactive as part of the application process. OFFLINE APPLICATIONS AND EXISTING BUSINESS Your client needs to complete a Request for Old Mutual International Isle of Man Limited ( Old Mutual International )/Old Mutual International Ireland dac ( Old Mutual International Ireland ) to appoint a discretionary asset manager form and either email it to PBMAINTENANCE@ominternational.com or post it to us. USING THE DISCRETIONARY ASSET MANAGER PAPERWORK AND SETTING UP TRUSTS As with all of our Fund Adviser, Ongoing Service Fee and Discretionary Asset Manager agreements, these agreements will terminate if the policyholder changes. Therefore, if you or your client intend to apply for a new bond and then make that bond subject to a trust, the Request for Old Mutual International Isle of Man Limited ( Old Mutual International )/Old Mutual International Ireland dac ( Old Mutual International Ireland ) to appoint a discretionary asset manager form should be completed by the trustees (not the client as original policyholder) once the trust has been created. 7
CHARGES TAKEN FOR ADVICE PRE AND POST 1 SEPTEMBER 2014 WHAT IS THE TAX POSITION OF CHARGES TAKEN PRE AND POST 1 SEPTEMBER 2014 The following table details the tax position for adviser charges and discretionary asset manager charges: Charge forms part of the policyholder s 5% annual tax deferred entitlement? Charge Pre 1 September 2014 Post 1 September 2014 Adviser Charges Yes Yes Assets held by an authorised custodian Discretionary asset manager charges appointed on an advisory basis Discretionary asset manager charges appointed on a discretionary basis Option not available No No No Fund Adviser Yes Yes Assets held by our default custodian (Old Mutual International or Old Mutual International Ireland) Discretionary asset manager charges appointed on an advisory basis Discretionary asset manager charges appointed on a discretionary basis Option not available Option not available No No Fund Adviser Yes Yes VAT AND CHARGES FOR ADVICE DO ALL TYPES OF CHARGES FOR ADVICE STILL ATTRACT VAT AND CAN THIS BE ADDED TO THE CHARGE? Whether VAT is applicable or not will depend on the service provided and a detailed explanation is beyond the scope of this document. Broadly, intermediation services to policyholders do not attract VAT whilst other types of advice will be subject to VAT at the standard rate. More information on this can be found on the following website http://www.hmrc.gov.uk/manuals/vatfinmanual/vatfin7600.htm In the Request for Old Mutual International Isle of Man Limited ( Old Mutual International )/Old Mutual International Ireland dac ( Old Mutual International Ireland ) to appoint a discretionary asset manager form, we require the discretionary asset manager charge to be expressed inclusive of any VAT. If the VAT rate changes in the future, a new request form will need to be completed. Please note that where VAT is applied on charges for financial advice and not investment advice these charges will be treated as a withdrawal and will form part of the 5% annual tax deferred entitlement. 8
PLATFORMS If your client wishes to appoint a discretionary asset manager for assets held on a third party platform through an Old Mutual International or Old Mutual International Ireland bond, they will need to complete the relevant paperwork for the platform and the Request for Old Mutual International Isle of Man Limited ( Old Mutual International )/Old Mutual International Ireland dac ( Old Mutual International Ireland ) to appoint a discretionary asset manager form. INVESTING INTO THE COLLECTIVE INVESTMENT ACCOUNT (CIA) If your client wishes to appoint a discretionary asset manager on an advisory basis and invest in the Collective Investment Account on Old Mutual Wealth s platform through an Old Mutual International or Old Mutual International Ireland bond, they will need to complete the Request for Old Mutual International Isle of Man Limited ( Old Mutual International )/Old Mutual International Ireland dac ( Old Mutual International Ireland ) to appoint a discretionary asset manager form and the CIA appointment for discretionary asset managers form. The financial adviser will set up the Collective Investment Account in the name of Old Mutual International or Old Mutual International Ireland as per the current process. WHERE A CLIENT INVESTS INTO A COLLECTIVE INVESTMENT ACCOUNT (CIA) VIA AN OLD MUTUAL INTERNATIONAL OR OLD MUTUAL INTERNATIONAL IRELAND BOND WILL THE FEES PAID TO THE ADVISORY DISCRETIONARY ASSET MANAGER BE TAKEN FROM THE CIA? No, Old Mutual International and Old Mutual International Ireland will not pay the fees from the Collective Investment Account under any circumstances. The fees paid by Old Mutual International or Old Mutual International Ireland will be reflected as the Discretionary Asset Manager Charge deducted from the bond. WHERE THE OLD MUTUAL INTERNATIONAL PORTFOLIO BOND INVESTS INTO A COLLECTIVE INVESTMENT ACCOUNT AND THE WEALTHSELECT MANAGED PORTFOLIO SERVICE HAS BEEN SELECTED, CAN AN ADVISORY DAM FEE BE TAKEN? Yes, however, this is only possible where the advisory DAM is providing Old Mutual International with advice regarding the ongoing suitability of the WealthSelect Managed Portfolio Service and is in relation to the Investment Mandate specified in the original Request for Old Mutual International/Old Mutual International Ireland to appoint a Discretionary Asset Manager form. Please note that both the policyholder and Old Mutual International will need to agree to the advisory Discretionary Asset Manager fee. OLD MUTUAL INTERNATIONAL TRUST COMPANY LIMITED We currently do not offer the adviser charging options (other than fund adviser fees which are taxable withdrawals) for Old Mutual International bonds that use our professional trustee service. However this is being reviewed and an update will follow in due course. OLD MUTUAL WEALTH S ONSHORE BOND ARE OLD MUTUAL WEALTH GOING TO OFFER THIS ADVISORY DISCRETIONARY ASSET MANAGER OPTION FOR ITS COLLECTIVE INVESTMENT BONDS? Old Mutual Wealth is reviewing its options in relation to offering this model on its Collective Investment Bond. This model is aimed at clients who want to be very actively involved in the management of the funds linked to their bond. For clients who are looking for a discretionary fund management service based on their investment risk profile, they can currently use the Wealth Select Managed Portfolio Service (MPS) or the adviser s bespoke Discretionary Fund Manager (DFM) service. However, if either discretionary fund management service is used, any adviser fees will still form part of the clients annual 5% allowance because the investment service is provided to the client for the WealthSelect MPS or DFM service and fees for advice other than for investment services (such as recommending the bond with the MPS) will always form part of the client s annual 5% tax deferred allowance. ILLUSTRATIONS Please find below the details of how you obtain an illustration: ASSETS HELD BY OUR DEFAULT CUSTODIAN (OLD MUTUAL INTERNATIONAL OR OLD MUTUAL INTERNATIONAL IRELAND) Discretionary asset manager appointed on a discretionary basis you can obtain an illustration online from Wealth Interactive or alternatively you can call our Sales Support Centre. You will need to complete the appropriate Addendum that can be obtained from the Adviser Charging section of the Old Mutual International literature library. The completed Addendum must be given to your client at the same time they are given their illustration. Discretionary asset manager appointed on an advisory basis you can obtain an illustration online from Wealth Interactive or alternatively you can call our Sales Support Centre. You will need to complete the appropriate Addendum that can be obtained from the Adviser Charging section of the Old Mutual International literature library. The completed Addendum must be given to your client at the same time they are given their illustration. ASSETS HELD BY AN AUTHORISED CUSTODIAN Discretionary asset manager appointed on a discretionary basis - you can obtain an illustration online from Wealth Interactive or alternatively you can call our Sales Support Centre. Discretionary asset manager appointed on an advisory basis - you can obtain an illustration by contacting our Sales Support Centre. Please see the Contact us section on the following page for Sales Support s contact details. 9
LITERATURE WHAT LITERATURE IS REQUIRED TO FACILITATE CHARGES FOR ADVICE UNDER THE NEW HMRC GUIDANCE? The following literature had been updated and needs to be completed for Old Mutual International and Old Mutual International Ireland bonds. OLD MUTUAL INTERNATIONAL NEW BUSINESS Request for Old Mutual International Isle of Man Limited ( Old Mutual International )/Old Mutual International Ireland dac ( Old Mutual International Ireland ) to appoint a discretionary asset manager form Bond application form (if offline) Old Mutual International Portfolio Bond Key Features Document Key Features Illustration Policy Terms If the underlying asset is to be a CIA, you will need: Request for Old Mutual International Isle of Man Limited ( Old Mutual International )/Old Mutual International Ireland dac ( Old Mutual International Ireland ) to appoint a discretionary asset manager form Bond application form (if offline) Key Features of investing in a Collective Investment Account via an Old Mutual International Portfolio Bond Key Features Illustration Policy Terms CIA appointment form OLD MUTUAL INTERNATIONAL IRELAND NEW BUSINESS Request for Old Mutual International Isle of Man Limited ( Old Mutual International )/Old Mutual International Ireland dac ( Old Mutual International Ireland ) to appoint a discretionary asset manager form Bond application form (if offline) Old Mutual International Ireland European Portfolio Bond Life Key Features Document Key Features Illustration Policy Terms If the underlying asset is to be a CIA, you will need: Request for Old Mutual International Isle of Man Limited ( Old Mutual International )/Old Mutual International Ireland dac ( Old Mutual International Ireland ) to appoint a discretionary asset manager form Bond application form (if offline) Key Features of investing in a Collective Investment Account via an Old Mutual International Ireland European Portfolio Bond Life Key Features Illustration Policy Terms CIA appointment form. OLD MUTUAL INTERNATIONAL EXISTING ISLE OF MAN AND IRELAND BUSINESS Request for Old Mutual International Isle of Man Limited ( Old Mutual International )/Old Mutual International Ireland dac ( Old Mutual International Ireland ) to appoint a discretionary asset manager form. CONTACT US If you have any questions or require further information please contact your Old Mutual Wealth Consultant. If you require an illustration from the Sales Support Centre, please call +44 (01624) 655010. 10
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www.oldmutualwealth.co.uk www.oldmutualinternational.com Calls may be monitored and recorded for training purposes and to avoid misunderstandings. Old Mutual Wealth is the trading name of Old Mutual Wealth Limited which provides an Individual Savings Account (ISA) and Collective Investment Account (CIA) and Old Mutual Wealth Life & Pensions Limited which provides a Collective Retirement Account (CRA) and Collective Investment Bond (CIB). Old Mutual Wealth Life Assurance Limited, Old Mutual Wealth Limited and Old Mutual Wealth Life & Pensions Limited are registered in England & Wales under numbers 1363932, 1680071 and 4163431 respectively. Registered Office at Old Mutual House, Portland Terrace, Southampton SO14 7EJ, United Kingdom. Old Mutual Wealth Life Assurance Limited and Old Mutual Wealth Life & Pensions Limited are authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority. Their Financial Services register numbers are 110462 and 207977 respectively. Old Mutual Wealth Limited is authorised and regulated by the Financial Conduct Authority with register number 165359. VAT number for all above companies is 386 1301 59 Old Mutual International Isle of Man Limited is registered in the Isle of Man under number 24916C. Registered and Head Office: King Edward Bay House, King Edward Road, Onchan, Isle of Man, IM99 1NU, British Isles. Phone: +44 (0)1624 655 555 Fax: +44 (0)1624 611 715. Licensed by the Isle of Man Financial Services Authority. All promotional material is approved by Old Mutual Wealth Limited. Old Mutual Wealth Limited is authorised and regulated by the Financial Conduct Authority. Financial Services register number 165359. The rules made under the Financial Services and Markets Act 2000 (as amended) for the protection of retail clients in the UK do not apply. Old Mutual International Isle of Man Limited is a member of the Association of International Life Offices. Old Mutual International is registered in the Isle of Man as a business name of Old Mutual International Isle of Man Limited. Old Mutual International Ireland dac is regulated by the Central Bank of Ireland. Registered No 309649 Administration Centre for correspondence: King Edward Bay House, King Edward Road, Onchan, Isle of Man, IM99 1NU Tel: +353(0)1 479 3900 Fax: +353(0)1 475 1020 Head Office Address: Hambleden House, 19-26 Lower Pembroke Street, Dublin 2, Ireland. VAT number for Old Mutual International Ireland dac is 6329649S Registered Office: Arthur Cox Building, Earlsfort Terrace, Dublin 2, Ireland. Old Mutual International is registered in Ireland as a business name of Old Mutual International Ireland dac. When printed by Old Mutual this item is produced on a mixed grade material, which uses a combination of recycled wood or paper fibre from controlled sources and virgin fibre sourced from well managed, sustainable forests. PDF10069/INT16-0944/November 2016