Our Remuneration 

We, Greenway Financial Advisors Ltd act as intermediary between you, the consumer, and the product provider with whom we place your business. 

The Background 

Pursuant to provision 4.58A of the Central Bank of Ireland’s September 2019 Addendum to the Consumer Protection Code, all intermediaries, must make available in their public offices, or on their website if they have one, a summary of the details of all arrangements for any fee, commission, other reward or remuneration provided to the intermediary which it has agreed with its product producers.

What is Remuneration?

Remuneration is the payment earned by the intermediary for work undertaken on behalf of both the provider and the consumer. The amount of remuneration is generally directly related to the value of the products sold. 

What is commission? 

For the purpose of this document, remuneration is the payment earned by the intermediary for work undertaken on behalf of both the provider and the consumer. The amount of remuneration is generally directly related to the value of the products sold. 

There are different types of remuneration/commission models: 

Single commission model: where payment is made to the intermediary shortly after the sale is completed and is based on a percentage of the premium paid/amount invested/amount borrowed. 

Trail/Renewal commission model: Further payments at intervals are paid throughout the life span of the product. 

Indemnity commission 

Indemnity commission is the term used to describe a commission payment made before the commission is deemed to be ‘earned’. Indemnity commission may be subject to a clawback (see below) if the consumer lapses or cancels the product before the commission is deemed to be earned. 

Other forms of indemnity commission are advances of commission for future sales granted to intermediaries in order to assist with set up costs or business development. 

Sustainability Factors – Investments / IBIPs / Pension Advice

When assessing products, we will consider the different approach taken by product providers in terms of them integrating sustainability risks into their product offering. This will form part of our analysis for choosing a product provider.

Profit Share arrangements 

In some cases, the intermediary may be a party to a profit-share arrangement with a product provider and will earn additional commission. Any business arranged with these product providers on a client’s behalf will be placed with the product provider because that product provider is at the time of placement, the most suitable to meet the client’s requirements, taking all the client’s relevant information, demands and needs into account. 

Life Assurance/Investments/Pension products 

For Life Assurance products commission is divided into initial commission and renewal commission (related to premium), fund based or trail (relating to accumulated fund). 

Trail commission, bullet commission, fund based, flat commission or renewal commission are all terms used for ongoing payments. Where an investment fund is being built up though an insurance-based investment product or a pension product, the increments may be based on a percentage of the value of the fund or the annual premium. For a single premium/lump sum product, the increment is generally based on the value of the fund. 

Life Assurance products fall into either individual or group protection policies and Investment/Pension products would be either single or regular contribution policies. Examples of products include Life Protection, Regular Premium Life Assurance Investments, Single Premium (lump sum) Insurance-based Investments, and Single Premium Pensions


Investment firms, which fall within the scope of the European Communities (Markets in Financial Instruments) Regulations 2007 (the MiFID Regulations), offer both standard commission and commission models involving initial and trail commission. Increments may be based on a percentage of the investment management fees, or on the value of the fund. 

Credit Products/Mortgages 

Commission may be earned by intermediaries for arranging credit for consumers, such as mortgages. The single, or standard, commission model is the most common commission model applied to the sale of mortgage products by mortgage credit intermediaries (Mortgage Broker). 


Clawback is an obligation on the intermediary to repay unearned commission. Commission can be paid directly after a contract is concluded but is not deemed to be ‘earned’ until after a specified period of time. If the consumer cancels or withdraws from the financial product within the specified time, the intermediary must return commission to the product producer. 


The firm may also be remunerated by fee by the product producer such as policy fee, admin fee, or in the case of investment firms, advisory fees. 

Preferred Provider Rate

Other Fees, Administrative Costs/ Non-Monetary Benefits 

The firm may also be in receipt of other fees, administrative costs, or non-monetary benefits such as: 

  • Attendance at product provider educational seminars 
  • Assistance with Advertising/Branding

Greenway Financial Advisors Ltd’s commission options are displayed as a range, showing the maximum amount which can be received. The level of commission depends on individual circumstances, based on the following factors:

  • Intermediary discretion
  • Whether the level of commission is negotiable
  • Client relationship
  • Length of time of the policy
  • Amount of investment
  • Length of investment
  • Commercial decision
  • Complexity of the case
  • Product constraints by the product provider

Single Contribution Products Initial commission Clawback Period Trail commission 
Single Contribution Pension 
Irish Life 5% 0.75% p.a.
New Ireland 5% 5 Years 1% p.a.
Zurich Life 5.5% 0.5% p.a.
Single Contribution PRSA 
Irish Life 5% 0.75% p.a.
New Ireland 7% 5 Years 0.5% p.a.
Zurich Life 5.5% 0% p.a.
Irish Life 5% 0.75% p.a.
New Ireland 5% n/a 1% p.a.
Zurich Life 5% 0.5% p.a.
Irish Life 3% n/a
New Ireland 3% n/a n/a
Zurich Life 3% n/a
Investment Bond 
Irish Life 3% 0.5% p.a.
New Ireland 4% 3 Years 1% p.a.
Zurich Life 5% 0.5% p.a.


Regular Contribution Products  Initial commission  Clawback Period  Renewal / Flat Commission Trail commission
Regular Contribution Pension 
Irish Life 17.5% 5% 0.5% p.a.
New Ireland 25% 5 Years 8% 1% p.a. 
Zurich Life 20% 4 Years 3% 0.5% p.a. 
Regular Contribution PRSA 
Irish Life 17.5% 5% 0.5% p.a.
New Ireland 25% 5 Years 6% 0.5% p.a.
Zurich Life 5% 4 Years 5% 0% p.a. 
Irish Life 5.5% 5.5% 0.5% p.a.
New Ireland 10% 5 Years 2.5% 0.5% p.a.
Zurich Life 10% 4 Years 1% 0.5% p.a.


Individual Protection Yr1 2 3 4 5 6 7 8 9+ Clawback Period
Irish Life 120% 28% 30% 28% 28% 30% 28% 28% 28%
New Ireland 225% 50% 20% 20% 20% 12.5% 12.5% 12.5% 12.5% 5 Years
Royal London 225% 0% 0% 0% 0% 3% 3% 3% 3% 5 Years
Royal London (Average Greenway Remuneration) 151% 7% 7% 7% 7% 3% 3% 3% 3% 5 Years
Zurich Life 100% 12% 12% 12% 12% 12% 12% 12% 12% 1 Year


Group Protection Death in Service  Clawback Period  Permanent Health Insurance  Clawback Period
Irish Life 6% p.a. 12.5% p.a.
New Ireland 15% 1 Year 20% 1 Year
Zurich Life 6% n/a 12.5% n/a


Mortgages Commission Clawback Period
Finance Ireland 1% 3 Years
Haven 1% 3 Years
ICS 1% 3 Years
KBC Bank 1% 3 Years
Permanent TSB 1% 3 Years

Greenway Financial Advisors Limited is regulated by the Central Bank of Ireland. Registered No. C168372











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