Terms of Business
Information about our services and costs
Version 3 · September 2026
1. About Us
At Trevor Downing Financial Management (IFA) Limited, we take immense pride in making a positive and lasting impact on our clients’ financial lives. Our approach is built upon a profound understanding of each client’s unique circumstances combined with our extensive expertise in the financial advisory domain.
With over 35 years of providing independent financial advice, our team collectively holds more than 160 years of experience spanning a comprehensive range of financial services for both individuals and business owners.
What distinguishes us is our unwavering commitment to delivering exceptional service and value. As an independent firm, we have access to the entire market, enabling us to craft bespoke solutions tailored precisely to your personal needs, objectives and circumstances.
We are dedicated to helping you achieve your financial goals and aspirations in the most effective and personalised manner possible.
2. Our Regulatory Status
Trevor Downing Financial Management (IFA) Limited is authorised and regulated by the Financial Conduct Authority (FCA). The FCA is the independent regulator of financial services in the United Kingdom.
Our firm is entered on the Financial Services Register under reference number 118176. You can verify our registration by visiting the FCA Register at www.fca.org.uk/register or by contacting the FCA directly on 0800 111 6768.
Our Company Registration Number is 01829773.
As an independent financial adviser, we provide advice based on a comprehensive and fair analysis of the relevant market. We are not restricted to recommending products from any particular provider, which means we can search the whole market to find solutions that best meet your needs.
3. Our Services
We provide independent financial advice to individuals and businesses on all aspects of financial planning. Our mainstream services include arranging and advising on:
- Investments and Pensions – including ISAs, Personal Pension Plans, Self-Invested Personal Pensions (SIPPs), and workplace pension schemes
- Personal and Family Protection – including Life Assurance, Critical Illness Cover, and Income Protection Insurance
- Mortgages – including residential, Buy-to-Let, and remortgages
- Equity Release – releasing equity from your home
- General Insurance – including Buildings and Contents, Private Medical Insurance, and Accident, Sickness and Unemployment cover
- Estate Planning – including Inheritance Tax planning, Wills, and Powers of Attorney
For all services, we conduct a thorough fact-find to understand your circumstances, needs, and objectives. We then undertake research to provide personal recommendations relevant to your individual situation. Should you wish to proceed, we will implement our recommendations and arrange any products or services on your behalf.
Once your financial plans are in place, it is essential to keep them under review to ensure they remain suitable. We offer both ongoing advisory services and ad-hoc transactional services to suit your preferences.
4. Our Charges
We believe in transparent, fair pricing that reflects the value of our advice and the work involved. Below is a summary of our standard charges. The actual cost will depend on the services you choose and your individual circumstances, and will always be confirmed to you in writing before any advice is implemented.
Initial Advice Fees
For new plans and products that we recommend and arrange for you, our initial advice fees are structured as follows:
| Investment Amount | Initial Advice Fee |
|---|---|
| £1 to £500,000 | 1.50% |
| Above £500,000 | 1.00% (subject to decency cap) |
Minimum Initial Advice Fee £1,500
Where the percentage-based calculation would result in a fee below £1,500, the minimum fee of £1,500 will apply. This minimum reflects the regulatory, operational, and professional costs we incur in delivering comprehensive financial advice, regardless of the amount invested.
Decency Cap
For larger investments, we apply what we term a ‘decency cap’ – an upper limit on our fees that ensures charges remain fair and proportionate to the work involved. This cap is determined on a case-by-case basis, taking into account the complexity of your requirements and the time needed to deliver our advice. We will always discuss and agree this with you before proceeding.
Fixed Fee Option
As an alternative to percentage-based fees, we can agree a fixed fee for our services. This may be particularly suitable where the scope of work is clearly defined or where you prefer certainty over costs. Any fixed fee will be agreed in writing before we commence work on your behalf. Please note that our minimum fees still apply: £1,500 for initial advice and £750 per annum for ongoing advice.
Our Commitment to Transparency
Regardless of the fee structure, we are committed to charging fairly for the work involved. Our fees cover the cost of our research, analysis, advice, and implementation of recommendations. We will always provide you with a clear breakdown of costs before any advice is implemented, and you will never be charged more than the amount agreed.
Ongoing Advice and Review Services
It is important to review your financial plans regularly to ensure they remain on track and suitable for your evolving circumstances and objectives. Our ongoing advice service provides you with:
- Continuous access to your dedicated adviser throughout the year
- An annual review meeting as a minimum, with additional meetings as often as your circumstances require
- Proactive monitoring of your investments and financial arrangements
- Timely advice on changes that may affect your financial position
- Assistance with any queries or concerns you may have
| Portfolio Value | Ongoing Advice Fee (per annum) |
|---|---|
| £1 to £1,000,000 | 0.75% |
| Above £1,000,000 | Subject to decency cap |
Minimum Ongoing Advice Fee £750 per annum
Where the percentage-based calculation would result in a fee below £750 per annum, the minimum fee of £750 will apply. This minimum reflects the baseline level of service we commit to providing all ongoing clients, as well as the underlying regulatory, operational, and professional costs we incur as a financial advisory practice.
For portfolios exceeding £1,000,000, we will apply a decency cap to ensure fees remain proportionate. A fixed annual fee may also be considered where appropriate. All ongoing fees will be detailed in writing and agreed with you before any service commences.
You may cancel our ongoing services at any time.
5. Payment Options
We offer flexibility in how you pay for our services:
- In most circumstances, fees are paid through a deduction from your investment or pension, which is facilitated by the product provider.
- If you prefer to pay fees separately from your investment, the fee will normally be added on top of the amount invested.
- For investments funded by regular contributions, fees may be collected as instalments deducted from your regular payments.
- We do not accept payment by cash or credit card.
Please note that if you cancel an investment or pension product before our fee has been settled in full, including during any statutory cooling-off period, you may need to make alternative arrangements to pay any outstanding fees.
We will let you know if VAT applies to any of our services.
Other Costs
It is possible that other costs, including taxes related to transactions or products we arrange for you, may arise. These costs are not paid by our firm but are borne by you. We will make you aware of any such costs before you proceed.
6. Insurance Services
Personal and Family Protection
We are insurance intermediaries who offer products based on a fair and personal analysis of the market for Life Assurance, Critical Illness Cover, and Income Protection Insurance.
General Insurance
We are insurance intermediaries who offer products based on a fair and personal analysis of the market for Buildings and Contents Insurance, Accident, Sickness and Unemployment Insurance, and Private Medical Insurance.
How We Are Paid for Insurance Services
We do not usually charge a fee for advice on or arranging an insurance product. Instead, we receive commission from the insurer, which is reflected in the premium you pay. The amount of commission varies depending on the type of contract, term of cover, and premium amount.
We will disclose the commission we expect to receive before we arrange any insurance on your behalf. You will also receive a quotation detailing any other fees relating to any insurance policy we arrange for you.
We are not permitted to receive or retain any financial inducements, significant gifts, or hospitality from insurance product providers for arranging insurance contracts on your behalf.
Referral to Third Parties
We may, on occasion, refer you to third parties to provide specialist services such as wills, probate, or powers of attorney. We do not normally charge a fee for such referrals, though the provider will charge you directly. If we receive a commission from any such provider, we will notify you accordingly.
7. Client Classification
Under FCA regulations, we will classify you as a ‘retail client’ for investment and pensions business. This classification affords you the highest level of regulatory protection.
As a retail client, you have the right to request reclassification as an ‘elective professional client’. This may apply generally or in respect of a particular service, type of transaction, or product. Please note:
- All requests for reclassification must be made in writing.
- We will consider such requests on a case-by-case basis against the criteria set out in FCA rules.
- We will confirm the scope of any reclassification along with the consumer protections you would lose as a result.
- You must keep us informed of any changes to your circumstances that could affect your classification.
Debt Management
We will not advise you if you are experiencing difficulties managing your debts. Free help and advice about managing debts is available from the Money and Pensions Service at www.moneyandpensionsservice.org.uk.
8. How We Use Your Personal Data (Customer Privacy Notice)
Why you should read this section
During the course of dealing with us, we will ask you to provide detailed personal information relating to your existing circumstances, your financial situation and, in some cases, your health and family health history (Your Personal Data). This section is important as it explains what we will need to do with Your Personal Data and the various rights you have in relation to it.
What we mean by “Your Personal Data”
Your Personal Data means any information that describes or relates to your personal circumstances. It may identify you directly, for example your name, address, date of birth or National Insurance number. It may also identify you indirectly, for example your employment situation, your physical and mental health history, or any other information that could be associated with your cultural or social identity.
In the context of providing you with advice on your investment, pension, mortgage, equity release, protection and insurance requirements, Your Personal Data may include:
- Title, name, date of birth, gender, nationality, civil or marital status, contact details, addresses and documents that are necessary to verify your identity
- Employment and remuneration information (including salary, bonus schemes, overtime, sick pay and other benefits) and employment history
- Bank account details, tax information, loans and credit commitments, personal credit history, sources of income and expenditure, family circumstances and details of dependants
- Health status and history, details of treatment and prognosis and medical reports (further details are provided below regarding the processing we may undertake in relation to this type of information)
- Any pre-existing investment, pension, mortgage, protection or insurance products and the terms and conditions relating to these
The basis upon which we will deal with Your Personal Data
When we speak with you about your financial planning requirements we do so on the basis that both parties are entering a contract for the supply of services. In order to perform that contract, and to arrange the products you require, we have the right to use Your Personal Data for the purposes detailed in this section.
Alternatively, either in the course of initial discussions with you or when the contract between us has come to an end for whatever reason, we have the right to use Your Personal Data provided it is in our legitimate business interest to do so and your rights are not affected. For example, we may need to respond to requests from product providers, mortgage lenders, insurance providers and our compliance service provider relating to the advice we have given you, or to contact you to seek feedback on the service you received.
On occasion, we will use Your Personal Data to meet responsibilities we owe to our regulator, the Financial Conduct Authority, or for wider compliance with any legal or regulatory obligation to which we are subject.
Special category data and criminal disclosures
Where you ask us to assist you with protection or insurance (in particular life assurance, critical illness cover, income protection and private medical insurance), or with ethical or values-based investments, we will ask you for information about your health and medical history and, where relevant, your ethnic origin (Your Special Data). We will record and use Your Special Data in order to make enquiries of insurance and investment providers in relation to products that may meet your needs and to advise you on the suitability of any product that may be available to you.
If you have parental responsibility for children under the age of 13, it is very likely that we will record information on our systems that relates to those children and potentially to their Special Data.
The arrangement of certain types of insurance may involve you disclosing to us information relating to historic or current criminal convictions or offences (Criminal Disclosures). This is relevant to insurance activities such as underwriting, claims and fraud management. We will use Your Special Data and any Criminal Disclosures in the same way as Your Personal Data generally, as set out in this section. Information of this kind must be capable of being exchanged freely between insurance intermediaries such as our firm and insurance providers, to enable you to secure the protection your needs require.
How we collect Your Personal Data
We will collect and record Your Personal Data from a variety of sources, but mainly directly from you. You will usually provide information during our initial meetings or conversations to establish your circumstances, needs and preferences. You will provide information to us verbally and in writing, including by email and through any secure client portal we make available to you.
We may also obtain some information from third parties, for example credit checks, information from your employer, your existing product providers (with your authority) and searches of information in the public domain such as the electoral roll. If we use technology solutions to assist in the collection of Your Personal Data, for example software that is able to verify your credit status, we will only do so with your consent. With regard to electronic identity checks we do not require your consent, but we will inform you of how such software operates and the purpose for which it is used.
What happens to Your Personal Data when it is disclosed to us
In the course of handling Your Personal Data, we will:
- Record and store Your Personal Data in our paper files, on mobile devices and on our computer systems (including email, hard drives and cloud facilities). This information can only be accessed by employees and consultants within our firm, and only when it is necessary to provide our service to you and to perform any administration tasks associated with or incidental to that service.
- Submit Your Personal Data to product providers, mortgage lenders and insurance providers, both in paper form and online via secure portals. Providing this information to a third party is essential in allowing us to progress any enquiry or application made on your behalf and to deal with any additional questions or administrative issues that lenders and providers may raise. Where you are making an application for credit, such as a mortgage, the lender may refer to a credit reference agency who will process your data. This may impact your credit rating.
- Use Your Personal Data for the purposes of responding to any queries you may have in relation to any product or policy you take out, or to inform you of any developments in relation to those products and policies of which we become aware.
Our use of Artificial Intelligence (AI)
AI is the development of computer systems that can perform tasks typically requiring human intelligence, often by processing large amounts of data. To enhance the quality, efficiency and accuracy of our services, we use AI tools to assist with:
- Recording and transcribing client meetings (you can opt out of being recorded at any time, in which case we will take written notes instead)
- Generating meeting notes and summaries
- Drafting correspondence, financial planning reports and other client documentation
- Conducting checks for compliance with our internal procedures
The AI tools we use are business-grade services operated under contracts that prohibit the provider from using our clients’ information to train their models. Any output produced with the assistance of AI is reviewed and approved by your adviser before it is relied upon or sent to you; AI does not make advice decisions. We are committed to protecting your privacy and ensuring that any information processed in this way is handled securely. If you have any questions or concerns about the AI we use in relation to your personal information, please contact us using the details below.
Sharing Your Personal Data
From time to time Your Personal Data will be shared with:
- Investment and pension providers, mortgage and equity release lenders, and insurance providers
- Third parties who we believe will be able to assist us with your enquiry or application, or who are able to support your needs as identified. These may include, but are not limited to, our compliance advisers, product and technical specialists, discretionary investment managers, providers of legal services such as solicitors, estate planners and conveyancers, accountants, surveyors and valuers (in each case where we believe this to be required due to your particular circumstances).
In each case, Your Personal Data will only be shared for the purposes set out in this section, that is, to progress your enquiry and to provide you with our professional services. This sharing of Your Personal Data does not entitle such third parties to send you marketing or promotional messages; it is shared to ensure we can adequately fulfil our responsibilities to you.
Some of the cloud-based systems we use to store and process Your Personal Data (for example email, document storage and the AI tools described above) may be hosted outside the United Kingdom. Where Your Personal Data is transferred outside the UK, we will only do so where the destination country has been recognised by the UK as providing an adequate level of data protection, or where appropriate safeguards are in place, such as the UK International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses, in accordance with UK data protection law.
Security and retention of Your Personal Data
Your privacy is important to us and we will keep Your Personal Data secure in accordance with our legal responsibilities. We will take reasonable steps to safeguard Your Personal Data against it being accessed unlawfully or maliciously by a third party.
We also expect you to take reasonable steps to safeguard your own privacy when transferring information to us, such as not sending confidential information over unprotected email, ensuring email attachments are password protected or encrypted, and only using secure methods of postage when original documentation is being sent to us.
Your Personal Data will be retained by us, either electronically or in paper form, for a minimum period of six years following the advice or service you receive from us. Your data may be held for a longer period where this is needed to meet the requirements of our regulator; for example, records relating to pension transfer advice must be retained indefinitely.
Your rights in relation to Your Personal Data
You can:
- Request copies of Your Personal Data that is under our control
- Ask us to further explain how we use Your Personal Data
- Ask us to correct, delete, restrict or stop using Your Personal Data (details as to the extent to which we can do this will be provided at the time of any such request)
- Ask us to send an electronic copy of Your Personal Data to another organisation should you wish
- Change the basis of any consent you have provided to enable us to market to you in the future, including withdrawing that consent entirely
Collection of data from a third party to support you
Where identifiable data is collected from a third party, such as a family member or a trusted friend, this information will only be used for the purpose of supporting the contract for the supply of services as outlined in this section and not for any other reason.
How to contact us about the use of Your Personal Data
If you have any questions or comments about this section, or wish to exercise any of the rights set out within it, please contact our data protection contact, Trevor Downing, at Trevor Downing Financial Management (IFA) Limited, Market Square House, 22 Market Square, Westerham, Kent TN16 1SR, by telephone on 01959 547077 or by email at enquiries@downingfm.co.uk.
If we feel we have a legal right not to deal with your request, or to action it in a different way to how you have requested, we will inform you of this at the time.
You should also contact us as soon as possible on becoming aware of any unauthorised disclosure of Your Personal Data, so that we may investigate and fulfil our own regulatory obligations.
If you have a complaint about how we have handled Your Personal Data, please contact us using the details above. We will carry out an investigation and respond to you with the outcome. If you remain dissatisfied after receiving our response, you may lodge a complaint with the UK’s data protection regulator, the Information Commissioner’s Office (ICO), through their website at ico.org.uk/global/contact-us or by writing to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
Client Agreement
Before we provide advice, you will be asked to sign a copy of these terms. By signing, you confirm that you agree to the terms set out in this document, that you understand our charges and how they are to be paid, that you have read and understood Section 8 (How We Use Your Personal Data) which explains how we will collect, use, share and retain Your Personal Data, and that if you have provided information relating to another person (such as a partner or a dependant), you have shown them these terms and obtained their permission to do so.
Marketing Consent (optional)
We would like to keep you informed about products, services and topical financial planning matters that we think may be of interest to you. You do not have to agree to this to receive our advice, and you can withdraw your consent at any time by contacting us. When you sign our terms, you can choose whether you are happy for us to contact you for marketing purposes by email, telephone or post.