Compliance / Client Confidentiality

A message from the Managing Director 14th December 2006

Following recent disturbing media reports alleging mis-conduct by the auctioneering industry and mortgage broking firms, I feel it is timely to reassure existing and new customers around the area of compliance “best practice”, client confidentiality and
retention of client information.

Frank Lenny Financial Services Ltd is regulated by the Financial Regulator. We believe passionately about the need for strong adherence to compliance codes and professional business standards. The very strong compliance and best Practice culture within the firm influences all of our daily activities and interaction with clients, banks, Insurance companies and of course our Regulatory Authorities. Compliance is an ongoing issue and is the one permanent item on the agenda for team meetings which are held monthly. The Directors and Staff of the company adhere strictly to many regulatory principles that shape how business is conducted and how information is used. Audrey Doyle QFA our Compliance Officer has been authorised by me to implement and oversee all of our regulatory responsibilities and duties to the highest standards. This authority gives her the power to act independently of the directors in the unlikely event of such a need arising.

A very strong culture of obtaining appropriate professional qualifications approved by the Financial Regulator and our industry is promoted within the firm. This assists with the provision of delivering better customer advice, in a structured way to our customers. It also underpins the compliance culture.

Before engaging in any business activity on behalf of a client, a client is fully briefed on our terms of business, a copy of this document is enclosed for reference. The regulatory documents mentioned in Appendix 1, 2 and 3 of this document are also attached. The document is comprehensive and covers 1) the necessary regulatory disclosures 2) conflicts of interest 3) our complaints procedure 4) consumer protection 5) the consumer protection code.

In addition I wish to confirm that the company is registered with the Data Protection Commissioner and our operations are subject to the Data Protection Acts of 1988 and 2003. The company is registered as a Data Controller.

In relation to the specific concerns concerning business relationships between auctioneers and mortgage brokers I wish to confirm the following:

The Financial Regulator permits such relationships in certain circumstances and where full details concerning the relationship are registered with the Financial Regulator.

Personally I believe that such relationships give members of the public cause for concern and are unhealthy generally. Frank Lenny Financial Services has no arrangement whatsoever with any auctioneering firm. We do not intend to have any such relationships into the future and if we receive a request from any outside party to discuss or disclose client information we refer back to our client. If the client decides that it is in their best interest to pass information onto any third party including an auctioneer then this is of course their right and their own business. I would not recommend it. Finally I want to summarise by again reassuring clients of the total independence offered by my firm. At Frank Lenny Financial Services we believe in customer service, professionalism and choice. We value your business.

Frank Lenny QFA (LIAMdip)
Managing Director