Last Updated: 3rd October, 2022
TTSP Ltd. trading as Top Insure.
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
TTSP Ltd. Trading as Top Insure (henceforth ‘Top Insure’) (C141040) is regulated by the Central Bank of Ireland as an insurance intermediary registered under the European Union (Insurance Distribution) Regulations 2018 . 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.
Codes of Conduct
Top Insure 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
Top Insure is a member of Brokers Ireland.
Our principal business is to provide advice and arrange transactions on behalf of clients in relation to general insurance products. A full list of insurers, product producers and lending agencies with which we deal is available on request.
Insurance Intermediary Services
Top Insure acts as an Independent Broker which means that:
- The principal regulated activities of the firm are provided on the basis of a fair and personal analysis of the market
- You have the option to pay in full for our services by means of a fee
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.
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 and personal analysis must be such that could reasonably be expected of a professional conducting business, taking into account the accessibility of information and product placement to intermediaries and the cost of the search.
In order to ensure that the number of contracts and providers is sufficiently large to constitute a fair and personal analysis of the market, we will consider the following criteria:
- 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.
Top Insure can provide advice on and arrange products from the following range: household, motor, commercial, public liability, employer liability, and travel insurance. Top Insure provides general insurance on a fair and personal 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).
In some cases we may be granted authority from an insurance undertaking to conduct tasks on their behalf, for which we will be remunerated. Where we place your business with this insurance undertaking under this authority you will be notified in advance of the placement.
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.
Disclosure of Information
Any failure to disclose material information may invalidate your claim and render your policy void. Any failure to disclose a material fact or misrepresentation of a material fact in order to obtain insurance may be considered fraud and we are obliged to hand over any documentation / call recordings or video footage, in our possession, to the relevant authorities, which may result in prosecution.
Commission Payments Structure
A full list of our commission rates can be viewed by clicking the PDF icon below to download our most up to date rates in PDF form.
Top Insure is remunerated by commission from insurers on completion of business (either new business, renewal or mid-term alterations). Details of this remuneration are available on request. Where an override commission is received, this will be disclosed to you in general terms.
- New Business / Renewal Brokerage fee: Maximum €250
- Cancellation fee: Maximum €250
- Mid Term Alteration fee: Maximum €250
- Duplicate Documentation: Maximum €50
- Finance Arrangement Fee: Maximum €50
- Finance Reinstatement Fee: Maximum €100
- Direct Debit Default Fee: Maximum €15
- Maximum fee applied to Return Premiums: Maximum €250
- Claims handling: Depending on case.
Where separate premium finance agreements are arranged for you via a premium finance provider we may earn additional commission of up to 6% of the annual premium.
We will inform you of the amount of fee to be charged. Where it is not possible to provide the exact amount, we will provide you the method of calculation of the fee.
Central Credit Register Notification
The Central Credit Register is the new database for credit and personal information for loans of €500 or more. This information will be held on the Central Credit Register and may be used by other lenders when making decisions on your credit applications and credit agreements. It has been set up by the Central Bank of Ireland under the Credit Reporting Act 2013.
If you choose to pay for your insurance by monthly instalments, your finance will be provided by Close Brothers Limited trading as Close Brothers Premium Finance Ireland. As part of the new regulations TTSP Ltd T/A Top Insure is now required to capture Identification and Verification documents (ID&V), such as PPS number, for all customers availing of the premium finance payment option, on behalf of Close Brothers Premium Finance Ireland.
Further information on the Central Credit Register can be found on the official CCR and Central Bank websites:
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 or it may null and void your insurance policy.
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. A full copy of our conflicts of interest policy is available on request.
Default on payments by clients
Our 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. We hold the right to withhold annual documents such as an insurance certificate or proof of no claims discount until any outstanding debt has been cleared from a client’s account.
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.
Whilst we are happy to receive verbal complaints, it is necessary to receive any complaint in writing (Email or Post). We will acknowledge your complaint within 5 business days and we will fully investigate it. We shall investigate the complaint as swiftly as possible, and, the complainant will receive an update on the complaint at intervals of not greater than 20 business days starting from the date on which the complaint is made. On completion of our investigation, we will provide you with a written report of the outcome. 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 and Pensions Ombudsman (FSPO). A full copy of our complaints procedure is available on request.
How and When We May Contact You / Authorised Person Acting on Your Behalf
We may contact you by phone/email/sms/post for the following purposes:
- Administration of your insurance policy
- To provide you with renewal terms on an existing policy
- To offer you assistance when you have requested a quote from us either over the phone or through our website; for example by providing you with details to retrieve your quote online and issuing you with a reminder before your quote expires.
- Handling customer service queries and complaints
- Marketing Top Insure products and services (unless you have opted out of receiving marketing communications)
- Provision of customer loyalty programme
- Conducting market research
Top Insure is subject to the requirements of the General Data Protection Regulation 2018 and the Irish Data Protection Act 2018.
Top Insure 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.
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.
We will ensure that this Privacy Notice is easily accessible. Please refer to our website www.topinsure.ie if this medium is not suitable we will ensure you can easily receive a hard copy.
Please contact us at email@example.com if you have any concerns about your personal data.
We are members of the Investor Compensation Scheme operated by the Investor Compensation Company Ltd. See below for details.
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.
A right to compensation will arise only:
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; and
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:
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.
Brokers Ireland Compensation Fund
We are also members of the Brokers Ireland Compensation Fund. 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.