Protection Advice Standards Manual 3.9 (PASM) - Connells, Sequence and Regional Brands (Inc. GMC)

PROTECTION
ADVICE
STANDARDS
MANUAL e
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Connells Group – Protection Advice Standards Manual Version 3.9

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VERSION CONTROL SHEET
Version No Amendment Amendment Date Reason

No.
1 1.1 24/10/2016 Amendment of Provider from Friends Life to Aviva
1 1.2 18/01/2017 Q4 2016 December review conducted by MS Sub Committee
1 1.3 23/02/2017 Removal of signed AMRA as not required by Aviva
1 1.4 07/03/2017 Amendment of Run-Down rate to 6% as authorised by Adrian Scott
1 1.5 09/03/2017 Amendment of Standard Critical Illness Cover to Core Critical Illness
Cover
1 1.6 16/03/2017 Amendment to IPB deferred period recommendations.
1 1.7 18/04/2017 Amendments following Project Sand final decisions
1 1.8 11/05/2017 Final Version approved by MS Sub Committee (11/05/2017) amendment
made as error on page 14 (19/05/2017)
1 1.9 06/06/2017 Admin error regarding wording around Upgraded CIC
2 2.0 19/06/2017 Amendment to IPB Term (agreed at MS Sub 14/06/2017)
2 2.1 26/07/2017 Post pilot amends (agreed at MS Sub via email 26/07/2017)
2 2.2 22/08/2017 IPB Review and amendments from MS Sub meeting (09/08/2017)
2 2.3 16/01/2018 Annual review, Agreed at MS Sub Committee (11/01/2018)
2 2.4 20/04/2018 Amendments to Maternity Leave, Call ML, Protection only cover and
Income Protection Term
2 2.5 23/04/2018 GDPR updates
2 2.6 20/06/2018 Deferred period for NHS staff, unknown occupation, rationale for a
shortfall in existing cover and review of existing protection
2 2.7 08/08/2018 Further guidance with regards to shortfalls in existing cover, further
guidance with regards to reviewing existing protection and clarity on
Income Protection Term
2 2.8 08/10/2018 Further clarify on the deferred period for NHS fixed term contracted staff
2 2.9 01/04/2019 Annual Review amendments and updates
3 3.0 27/02/2020 Updated to include clarity on Scope of Advice, clarity on evidence of
existing cover, clarity on affordability after a policy has been rated, minor
amendments to Income Protection relating to 2nd income, removal of
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glossary of changes, minor amendments to appendices and updated
Protection Guidance Notes added
3 3.1 25/03/2020 Introduction of Credas
3 3.2 13/08/2020 Further Protection advice clarity regarding policy replacement, limited benefit
and additional benefits
3 3.3 25/11/2020 Updated following Customer Vulnerability system changes
3 3.4 17/12/2020 Updated following Brexit Considerations
3 3.5 12/05/2021 Updated to confirm approach regarding Dual Benefit calculator & Limited
Benefit IP Recommendation
3 3.6 15/11/2021 Dynamo referral
3 3.7 19/01/2022 Clarity regarding policy replacement
3 3.8 16/03/2022 Updated clarity on what is required re Will & credas update
3 3.9 07/06/2023 Updated regarding Government & Private Sector Schemes.
Updated regarding editing application (as per GRASP issue 22 - 2022)
Annual Review incl. Consumer Duty
Please note that, if printed, this document is only valid at the date/time as shown in the bottom left hand corner of each
page.
CONNELLS GROUP MORTGAGE SERVICES
PROTECTION ADVICE STANDARDS MANUAL
Introduction
This document details the regulatory and Compliance Advice Standards to be applied throughout the Connells Group
Mortgage Services protection sales process.
The document is in 6 sections with 7 appendices as follows:
 Section 1 - General Standards

 Section 2 - Know Your Customer
 Section 3 - Advice

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 Section 4 - Preparing Solutions
 Section 5 - Presentation of Advice
 Section 6 - Post Sale Activities
 Appendix 1 - Life Cover (Verbal Disclosure)
 Appendix 2 - Life with added CIC cover (Verbal Disclosure)
 Appendix 3 - Critical Illness Cover ( Verbal Disclosure
 Appendix 4 - Income Protection (Verbal Disclosure
 Appendix 5 - Buildings & Contents (Verbal Disclosure)
 Appendix 6 - Protection Recommendation - Guidance Notes
SECTION 1 – GENERAL STANDARDS
1.1 General
The Protection Advice Standards Manual (PASM) reflects the FCA requirements for advising on insurance contracts as
set out in the Insurance Conduct of Business Sourcebook (ICOB) and the principles of treating customers fairly (TCF).
These standards also reflect Consumer Duty and the Conduct Rules
You have a regulatory responsibility to adhere to these standards when advising on insurance. They provide minimum
standards and guidance on what Connells Group expects from mortgage services staff when dealing with clients but they
are not exhaustive and should be tailored to your client taking into account their individual circumstances. In
particular, you should bear in mind that protection sales linked to a mortgage could be associated with a stressful life event
(such as marriage, divorce or bereavement) for many customers, who, as a result, will be in a vulnerable position. Others
may be vulnerable due to factors such as disability, low mental capacity, restricted English language skills or financial
difficulties. You should always make allowances for customers’ vulnerability, adapting your approach according to their
particular requirements.
If, for example, you are asked to provide mortgage and/or protection advice to customers who do not speak good English,
you should recommend that they arrange for a qualified translator to attend meetings. If a translator is present at meetings
with non-English speaking customers, the file must record the name and address of the translator, details of the translator’s
qualifications and any relationship with the customer (for example if they are a family member or friend). If you remain

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concerned that your customers have not understood the advice they have been given, you must take action to address
this. If you need further assistance you should refer to the Vulnerable Customer guidance on Engage.
Approved Persons (APER) have a regulatory responsibility to ensure that advisers are adhering to these standards.
Where no specific ruling or guidance exists within these standards, we expect that an individual will take an intelligent view
that is in the best interest of the customer, and not seek to exploit any apparent omissions.
If you have any queries you should, in the first instance, refer to your line manager/field trainer. Should you require further
guidance on dealing with vulnerable customers, you can refer to the Vulnerable Customer guidance on Engage.
For guidance on all matters relating to mortgage advice, you must refer to the Mortgage Advice Standards Manual (MASM).
Guidance/standards with regards to the following, general, areas is also contained within that document:
 Financial Promotions
 Communications with Customers
 General Data Protection Regulation
 Non-advised and Execution-Only sales
 Selling to yourself or other staff members
 Retention of Original Client Documentation
 Introducer Referrals
 Inducements
 Prospecting
 Regulated Complaints
 Financial Crime
1.2 Scope of Advice
The scope of the service that we provide to our customers is currently focussed on advising them on their protection needs
in connection with their new/existing mortgage needs. Income protection may be arranged for up to the clients selected
retirement age & for their full salary.
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It is beyond our scope of advice to arrange Protection for:
 Inheritance Tax planning purposes

 Business Protection.
 Whole of Life Policy
 Whole of Life Conversion Option
 Renewal Option
 Family Income Benefit
 Family Protection
 Bridging
 Commercial
 Later life lending e.g. retirement interest only
 Second charge
In any event, you should take time to ensure that your customer has fully understood the content of your recommendation.
For standalone protection cases, you must also make the following declarations:
 That we have selected individual insurance companies for each area of protection. For Life, Critical Illness and Income
Protection we have chosen Aviva and for buildings and contents cover we have chosen Ageas.
 That we will receive commission from insurance providers and that details are available on request at application.
Parties not on Mortgage Application
It is appropriate to make recommendations to all members of the household regardless of if they are on the mortgage
application providing they are contributing to the household (either financially or through housekeeping/childcare).

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Advice to ex-pats in relation to their UK properties
From 1 January 2021, business carried on by a UK firm in the EU may be subject to the local laws and regulations of the
individual member state.
This means that advice provided to customers based outside of the UK will be subject to the additional laws and
regulations of that country, even if the advice relates to a UK property. This does not apply if the customer has travelled
back to the UK to receive the advice.
If you identify a situation whereby the customer is based outside of the UK, or you are unsure as to whether or not the
customer circumstances constitute cross border advice, you must step away from the advice process and escalate this
to your line manager and/or Risk and Compliance.
Vulnerable customers
The FCA have stated that “we consider a vulnerable consumer to be someone who, due to the personal circumstances,
is especially susceptible to harm ”.
The FCA expects us to ensure that a regulated contract is suitable for that customer. It is therefore important to identify
if a customer has vulnerabilities and take account of these in the advisory process.
Where relevant, you should record details of the customer’s vulnerability, whether there is a need for a change in service
and confirmation that the customer explicitly consents to this information being recorded and shared within the business.
This should be recorded on HUB.
You are not expected to ask questions of your client in regard to all of the above, however we would expect you to be
sensitive to the possibility of this and proceed accordingly.
Further guidance on the identification of vulnerable customers, the handling of customer disclosures and how to proceed
is available on the Intranet.

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1.3 Record Keeping
In order to comply with current regulations, we are required to maintain a record of the details of the customer information,
including the customer’s needs and circumstances, for the purpose of assessing the suitability of the advice given. This
requirement is covered by the Hub fact find and throughout this document you will find details of specific information to be
recorded. In addition, you must ensure that the notes section of the Hub contains any additional information that is relevant
to the customer’s circumstances, the recommendations made or the advice given.
There is also a requirement for us to provide the customer with an explanation of the reasons why we believe the personal
recommendations made comply with suitability requirements and an explanation of why a personal recommendation has
been made on a basis other than the least expensive. This is covered by the Statement of Demands and Needs (SDN)
and an accurate, fully completed, copy of that document is to be saved to the Hub in all cases and further versions must
be provided to the customer and saved in the event of a subsequent change to the advice given (e.g. term, sum assured
etc.).
At all times you should remain alert to the possibility that your customers’ needs may be influenced by vulnerable
characteristics (e.g. limited mental capacity or restricted English language skills), or that they may find themselves in
vulnerable circumstances, which will require sensitive handling. You must obtain your customer’s explicit consent before
recording any sensitive personal data, such as details of physical or mental health, and should only record factual
information, using the customer’s own words.
Details of customer’s vulnerability, and that they have given their explicit consent for us to record this information, must be
recorded in the notes section of the Hub.
Copies of any documentation provided by the customer(s) must be scanned and saved to the case.
The following documents must be saved to the case for all mortgage protection cases:
 Key information about our Mortgage and Protection services document *

 Proof of ID and Address – (see Section 1.3)
 Where a recommendation is being made to cancel/replace a policy, copies of the relevant policies must be saved on
all cases

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 All relevant protection Illustrations (see Section 2.2)
 Ageas application
 Fully completed accurate Statement of Demands and Needs (SDN)*
 Detailed Budget Planner* (with the exception of buildings and contents for a BTL applicant where the customer has
declined to complete a DBP)
 HomeGuard Acceptance Form, Proposal Form, Declaration (where applicable)
 Other relevant documents should be saved and labelled appropriately.
 Call Validate Report * if Call Validate has been used rather than Credas
You must attempt to obtain copies of all existing protection policies and every effort should be made to obtain these.
Where provided, these must be saved to the case.
Where a recommendation is being made to cancel/replace copies of relevant policies must be saved.
If any of the documents marked with an asterisk (*) are not present (where required) this will automatically result in the
case being graded Unclear.
1.4 Credas & Call Validate – SEE MASM
SECTION 2 – KNOW YOUR CUSTOMER
2.1 In order to achieve this it is crucial that you fully complete the mortgage/protection fact find in all mortgage and protection
cases and the protection-only fact find where appropriate. N.B. For protection-only cases you must still establish
affordability and complete a Detailed Budget Planner and save to the Hub [with the exception of buildings and contents
for a BTL applicant where the customer has declined to complete a DBP]. Protection-only sales must remain within the
scope of our advice and the customer must have or be arranging a mortgage.
IMPORTANT – You must ensure that you complete a comprehensive and detailed Budget Planner tailored to the individual
circumstances of the customer(s) in all cases. This includes residential mortgages, buy-to-let mortgages with protection
and protection only cases. This will help the customer(s) to understand and quantify their need(s) for protection and you
to confirm affordability.
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In all cases, you must establish whether the customer has any existing cover (including employer benefits such as Death
in Service, Pension Term Assurance, Sick Pay etc.) and document these on the fact find, taking care to record the correct
purpose of this cover (e.g. the customer may have existing life cover to protect dependants and you will not, therefore,
need to take this into account when making recommendations to protect the mortgage - but this must be recorded
accurately). You should ask the customer to provide copies of policies but if the customer is unwilling or unable to provide
evidence but has provided sufficient detail, you must still take relevant existing mortgage and family protection into account.
Where the customer has an existing buildings-only or contents-only policy the buildings/contents drop down must be
selected.
Having completed this you should now identify the customers protection needs and generally speaking the order will be
as follows:
N.B. At this stage you are identifying the customer’s needs so it is not necessary to take into account existing cover (you
will do this when preparing your solutions).
Married/co-habiting/single with dependants
 Death – to protect the full amount of the mortgage (including any fees added) (it is not permitted to arrange cover
for Business, Whole of life or IHT Planning needs) for each party to the mortgage in the event of death during the
term of the mortgage.
 Critical Illness – to protect the full amount of the mortgage (including any fees added) (it is not permitted to
arrange cover for Business or IHT Planning needs) for each party to the mortgage in the event of a critical illness
during the term of the mortgage for each party to the mortgage in the event of a critical illness during the term of
the mortgage.
 Ill Health/Injury (Income Protection) – to protect earned income for each party to the mortgage in the event of
them being unable to work due to ill health or in the event of an injury up to Selected Retirement Age or, if not
known, State Pension Age. Aviva do not offer house persons or unemployed persons cover.
 Will - to ensure that the estate is disposed of in accordance with the customer(s) wishes in the event of death.
 Buildings – to cover the rebuild cost of the property due to an insurable event. N.B. Buildings insurance is a
lender requirement.
 Contents – to cover the full cost of reinstatement due to losses resulting from an insurable event.

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Single no dependants
 Critical Illness – to protect the full amount of the mortgage (including any fees added) in the event of a critical
illness during the term of the mortgage.
 Ill Health/Injury (Income Protection) – to protect earned income for each party/insurable interest to the mortgage
in the event of them being unable to work due to ill health or in the event of an injury up to Selected Retirement
Age or, if not known, State Pension Age. Aviva do not offer house persons or unemployed persons cover.
 Death – to protect the full amount of the mortgage (including any fees added) in the event of death during the term
of the mortgage.
 Will - to ensure that the estate is disposed of in accordance with the customer’s wishes in the event of death.
 Buildings – to cover the rebuild cost of the property due to an insurable event. N.B. Buildings insurance is a
lender requirement.
 Contents – to cover the full cost of reinstatement due to losses resulting from an insurable event.
You should explain to the customer that the order of priority outlined above is for guidance and is based on potential impact
in a given event.
The actual order of priority must be established with the customer taking into account their individual circumstances and
needs, (including any areas of vulnerability), any existing levels of cover, amount of NDI available to address, and their
views on what is important to them.
Having explained this, you should establish the customer’s aims and views in ALL areas, and agree their priorities with
them. You must ask appropriate questions in respect of each need in order to help the customer (and you) understand
the potential impact and how the customer would be able to afford to maintain repayments in any event and record details
in the fact find. Consider arranging for an appropriate third party to attend where you judge that your customer’s ability to
comprehend is impaired by limited language skills, reduced mental capacity, etc. You must be prepared to provide
appropriate challenge as to why, for instance, a customer may feel that a specific area of cover is not important or why
they feel that one area may be more important than another. You should, however, bear in mind that your customer’s
transaction may be associated with stressful life events, and you should not look to exploit their vulnerability.
It is important not to discuss premiums at this stage as you want the customer to consider the need and the consequences
of not having sufficient cover in place rather than simply being driven by cost.

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You should continuously check that your customer has understood what you have explained, and revisit any areas if
required.
It is important that the Budget Planner contains sufficient detail to enable you to identify what is affordable and should
contain details of weekly expenditure to fund lifestyle and any future plans (e.g. savings). Where it appears that the
customer’s NDI is unlikely to be sufficient to completely satisfy the needs to be pursued you must discuss and agree with
the customer whether they would prefer to cascade (e.g. address priority 1 completely before addressing priority 2 etc.) or
whether the customer would prefer to spread the amount available across more than one area. It is likely that the most
suitable solution will be to cascade as care should be taken not to spread the amount available too thinly so that the
customer has a number of relatively worthless policies. This should certainly never be done to maximise ‘policy count’
and must only be done where there is a justifiable reason (e.g. topping up existing cover)
2.2 Illustrations.
Where your advice/recommendation is based on the principles outlined in this document for example joint policies for joint
applicants, combined policies where customer wishes to pursue life and CIC (and joint where applicable) etc. and the
customer has accepted the recommendation the requirement is simply to add those illustrations.
Where, however, the advice/recommendation differs from the principles outlined or the customer has a preference for a
reduced level of cover then any comparison illustrations must also be saved to the Hub. For example where single policies
have been recommended for joint applicants you must produce and save comparison joint illustrations or where separate
rather than combined life/CIC policies have been recommended you must produce comparison combined illustrations.
2.3 There should be a separation between Fact Finding and Presenting Advice in order to allow sufficient time to prepare and
discuss suitable solutions and possible alternatives. This is especially important where the customer has existing cover
that you may need to take into account or where it may be appropriate to recommend that an existing policy be replaced
or cancelled.

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SECTION 3 – ADVICE
3.1 General
You must ensure that any protection recommendation(s) that you make result in the right outcome for the customer and
that any product/recommendation is both suitable and affordable. You must also ensure that the customer is eligible to
claim policy benefits and that the policy(s) recommended meet the demands and needs of the customer taking into
account level of cover and cost. You must always consider the least expensive solution that meets the customer’s full
mortgage protection need.
Your protection term for Life and Critical illness cover should match your mortgage term and if this is not in whole years
e.g. Product Transfer, you should round this up to the nearest whole year and not down to ensure there is no shortfall
Where the customer agrees to a protection need but is not happy for you to make a recommendation, you must document
in the HUB the customers reasons for wanting to leave the shortfall unaddressed .
3.2 Affordability
Any protection recommendations that you make must be affordable and within the customer’s net disposable income
taking into account the new monthly mortgage payment where applicable.
It is imperative that you complete a comprehensive and detailed Budget Planner to include all committed, essential and
quality of living costs, monthly expenditure to fund lifestyle and any future plans (e.g. savings) as affordability will be
established within the remaining net disposable income.
Where the customer/s does not accept your recommendation and the budget planner shows affordability, the Hub and
SDN should include the customer/s detailed reasons for not taking your full protection recommendation.
When a policy that you recommend is subsequently rated at point of sale you must review affordability and check NDI is
appropriate, update the SDN in accordance with the ‘How to Edit’ SDN Guide. You must not amend your
recommendation. If still affordable no further action is required in this respect but where the policy is now not affordable

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you must revisit this with the customer and make revised recommendations as required, ensuring that an accurate SDN
is completed.
If the policy is rated after submission, you must review affordability and check NDI is available. If there is insufficient NDI
you must amend your recommendation so it is affordable.
If the customer does not wish to pursue Buildings cover with you and they do not have an existing policy in place that is
included in the detailed Budget Planner you must ensure that, following your recommendations, the customer can still
afford to address this need elsewhere.
3.3 Joint Policies
You must always recommend the least expensive solution that meets the customer’s demands and needs and where the
new mortgage is to be on a joint basis it is likely that this will be to arrange cover on a joint life, first death basis. This is
inclusive of parties not named on the mortgage (insurable interest). There may be circumstances where it is more
appropriate to recommend separate policies, for example:
o Friends or siblings buying together

o One applicant is a smoker
o Customers have needs for differing levels of cover
o Pre Existing Medical Conditions
o Age Restrictions
Where there is a justifiable reason and an identified need for separate policies, this must be explained in the SDN. It
should be noted that this should not simply be on the basis of a marginal increase in cost and must explain why you felt
that separate policies were the most suitable recommendation. It is not appropriate to provide your customer with a
range of alternatives that include unnecessary/unjustified additional levels of cover in excess of the mortgage amount.

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It must be remembered where the only need being addressed is to repay the mortgage It is highly unlikely therefore, that
joint applicants will have a need for separate policies, each protecting the full mortgage amount, as this will exceed the
scope of our protection advice and provide the customer with cover in excess of the mortgage. – In any other
circumstances gain the approval of Insurance Desk before proceeding.
3.4 Combined CIC/Life Policies
In the event of the client(s) suffering a critical illness or death, the need that you have identified is to repay the mortgage.
Clearly, it is not possible to repay the mortgage twice so where the customer wants to pursue both needs, the least
expensive solution is a Life policy with CIC added. There may, of course, be times where the customer prefers to take
separate policies or this is more appropriate, for example:
 The need or preference for level of critical illness cover is less than that for life cover (for example where one or
both customers have an existing critical illness policy to protect part of the mortgage but no life cover)
 In the case of a joint mortgage, one party may not be eligible for one of the policies (e.g. CIC due to pre-existing
medical condition).
 If the term of the mortgage extends past the maximum age for one type of cover (e.g. If the term of the mortgage
extends past the maximum age for one or both parties of the CIC policy would be exceeded whereas the life policy
could continue. Please refer to your Aviva Product Guides for max ages on Critical Illness Cover and Upgraded
Critical Illness Cover with additional options selected.
Aviva offer two forms of Critical Illness Cover, Core Critical Illness and Upgraded Critical Illness.
Our standard recommendation is to recommend Upgraded Critical Illness cover, however where NDI does not
permit, you should recommend Upgraded CIC within available NDI but allow the customer to vary to Core Critical
Illness cover (having discussed both options), you need to produce illustrations for both Core and Upgraded Critical
Illness and save to the case. Discussions with the customer should take place with regards to their preference to
a lower level of Upgraded cover or a higher level or Core cover and documented on the case.
N.B. Where a Life Policy with CIC attached is recommended and the customer has decided not to proceed with CIC,
this must be documented in the variation section of the appropriate recommendation in the SDN.

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3.5 Repayment Types:
Throughout this section, reference to DTA and LTA applies to both life cover and critical illness cover.
Whether you recommend DTA or LTA will, therefore, depend on the repayment method of the mortgage that you are
protecting and the following rules must be applied:
Repayment Mortgage:
The recommendation must be for DTA (life, life & CIC option or standalone CIC as appropriate) but see LTA for repayment
mortgages below
Interest Only:
The recommendation must be for LTA (life, life & CIC option or standalone CIC as appropriate) and this cannot be varied
to DTA as this will leave the customer with a shortfall in cover.
Part Repayment/Part Interest Only:
The recommendation (life, life & CIC option or standalone CIC as appropriate) must be DTA for the Repayment amount
and LTA for the Interest Only amount. An LTA illustration for the full mortgage amount must be prepared for a cost
comparison, particularly where the DTA is for the minimum premium.
The least expensive option must be recommended; where both DTA and LTA are at minimum premium to cover the full
mortgage amount, you may recommend LTA as it provides more comprehensive cover for no additional cost. The best
fit of the two options is to be discussed with the clients and a recommendation to be based on their preference.
LTA for Repayment mortgages
There may be circumstances when consideration should be given to recommending a LTA policy for a Repayment
mortgage and an example of this is detailed below. Any such recommendations must be based on the customer’s current

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circumstances and must not be made to “future-proof” protection (i.e. because the customer may move house in the
future).
Shared Equity/HTB & Shared Ownership:
Where the mortgage is on a Shared Equity/HTB or Shared Ownership scheme and the mortgage loan is arranged on a
Repayment basis the recommendation must be for DTA for the repayment mortgage and Indexed LTA for the Shared
Equity/HTB or ownership amount.
 You must recommend increasing cover (indexation) at RPI, though the customer can choose to vary this to a fixed
rate of increase.
 Your recommendation to protect the HTB/Shared Equity element must be to the remaining term of the Scheme
(which should be detailed in Existing Commitments). If you have any queries from your customers about previous
recommendations of this type, please refer to the Quality Assurance Director or Case Checking.
Forces HTB –
There is no requirement to protect the Forces HTB loan however if being used in conjunction with the HTB Shared Equity
scheme the Shared Equity element should be protected as above. Refer to Insurance Helpdesk if the guidance above is
not appropriate for your customer(s).
Minimum Premium
For a repayment mortgage, where the illustration for DTA (life, life & CIC or standalone CIC as appropriate) to cover the
full repayment mortgage amount results in minimum premium and this provides an excessive amount of cover, you should
consider whether LTA (for the full mortgage amount) provides the required cover for the same price (as it provides more
comprehensive cover for no additional cost). For example:
Mortgage amount = £100,000
 DTA illustration results in min premium and cover of £163,000

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 LTA comparable illustration results in min premium and cover of £107,000
In such circumstances (where LTA at minimum premium covers the full mortgage) you may recommend LTA without
increasing cover. You must, in such cases, save copies of quotes illustrating both options.
Under no circumstances should you recommend the LTA min premium option where this option does not provide
sufficient cover to protect the entire mortgage. If DTA at minimum premium is recommended due to affordability and this
does not provide sufficient cover to protect the whole mortgage you must not recommend LTA as this would reduce the
amount of cover at the outset.
See Appendix 6 for further information and Insurance Helpdesk for further guidance.
3.6 Single Applicant.
Where the applicant is single and has no financial dependants, it is unlikely that life cover will be the most pressing need
and in such cases Critical Illness cover or Income Protection is likely to be a higher priority. As the person has no
dependants the most important cover is likely to be one that enables them to continue to make their mortgage payments
and maintain other financial commitments if unable to work, or repay some/all of the mortgage in the event of a critical
illness. Life cover to protect the mortgage for single applicants with no dependants should only be arranged ahead of
Critical Illness Cover and/or Income Protection where the customer has identified this as a higher priority (the reasons
for this must be recorded on the HUB and on the SDN). If this is the case you must discuss with the client their reason
for the preference for life cover and ;
 Specify in the Hub and in the Statement of Demands and Needs (SDN) Important Information section, the detailed
reasons why the client has a need and a preference for life cover.
 You must document in Hub why the customer does not have a priority/ need for IP and CIC.
 Ensure that you are able to justify the recommendation for Life Cover, as it will be considered to be your own
recommendation because we do not write business on an execution only basis.

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3.7 Income Protection - Refer to Insurance Helpdesk for further guidance
The recommendation for Income Protection should be to protect all earned income (up to the maximum amount permitted
by Aviva and subject to affordability) for each party to the mortgage in the event of them being unable to work due to ill
health or in the event of an injury.
Income should be inclusive of all gross earned income including additional income e.g. regular/guaranteed overtime,
commission, London weighting, and second job.
The level of benefit should be determined using the Maximum Benefit Calculator available from the MS Portal or Hub.
Do not include the following:

 State Benefits (Child Benefit)
 Maintenance
 Rental Income
 Pension Income
 Other Income that will continue to be received during a claim
In the event of a claim, Aviva will base the claim on the last 12 months earnings.
It is not permitted to arrange stand-alone Income Protection and advice can only be provided where a mortgage is
being arranged or is already in place in line with our scope of advice (protection).
Income Protection Term - Refer to Insurance Helpdesk for further guidance.
Income Protection must always be recommended to take the customer to their stated retirement age (or State Pension
Age if not known) as documented in HUB and the FMA, unless Aviva Occupation restrictions apply refer to the AVIVA
Occupation Guide
If your customer wants to work beyond the maximum age permitted by Aviva you should recommend one year beyond
that stated in the Occupation Guide;

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Example; Customer is a bus driver and wants to retire at 68, Aviva restriction is 65. Recommendation should be to age
66 as this will provide cover up to the point the customer turns 65 and 364 days.
Example; Customer is a bus driver and wants to retire on his 65th birthday, Aviva restriction is 65. Recommendation
should be to age 65 as this will provide cover up to the point the customer retires on their 65th birthday.
Example; Customer is a bus driver and wants to retire during the year he is 65, Aviva restriction is 65.
Recommendation should be to age 66 as this will provide cover up to the point the customer turns 65 and 364 days.
You need to document any shortfall in term due to Aviva age restriction in the Important Information section of the SDN.
Your customer is still able to vary your initial recommendation to take a policy for a set term or a lower age than that
which was recommended.
Deferred Period(s)
You must discuss deferred periods with the customer and recommend a suitable period to match the customers’ needs
(e.g. taking into account sick pay, any other cover). Where the customer declines your recommendation and chooses to
vary your advice and opts for a longer deferred period, you must record the reasons for this in the SDN.
For customers who are a registered doctor, surgeon, nurse or midwife on a permanent employee contract for the NHS,
you should recommend a policy on a 52 week deferred period in respect of their NHS earnings. Non NHS earnings
should be covered by the standard recommendations. For customers on a temporary fixed term contract working for
the NHS, your recommendation must be based on their current sick pay arrangements.
Only the above occupations within the NHS can be considered
Example 1 – The customer has no sick pay and no benefits from any other policy – recommended deferred period should
be the shortest possible depending on the customer’s occupation and provide maximum cover permitted by Aviva. The
customer can choose to vary this advice and accept a longer deferred period but the reasons must be recorded in the
SDN.

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Example 2 – The customer gets 13 weeks full pay followed by 13 weeks half pay – In this scenario the recommendation
will be for a dual deferred period. There is no need for IP during the first 13 weeks so the first cover should have a 13
week deferred period and should provide maximum cover permitted whilst customer is in receipt of sick pay benefits. The
second cover should have a deferred period of 26 weeks and provide the remaining benefit in line with Aviva maximum.
The customer can choose to vary this advice and accept a longer deferred period but the reasons must be recorded in
the SDN.
Example 3 – The customer gets 26 weeks full pay followed by 26 weeks half pay – In this scenario the recommendation
will be for split cover. There is no need for IP during the first 26 weeks so the first cover should have a 26 week deferred
period and should provide maximum cover permitted whilst customer is in receipt of sick pay benefits. The second cover
should have a deferred period of 52 weeks and provide the remaining benefit in line with Aviva maximum. The customer
can choose to vary this advice and accept a longer deferred period but the reasons must be recorded in the SDN.
There may be occasions where the deferred periods offered by Aviva do not exactly match the customer’s sick pay
arrangements (e.g. the customer gets 16 weeks sick pay but Aviva only offer deferred periods of 13 or 26 weeks). In
such cases your recommendation must ensure that the customer is fully covered and it is accepted that this will result in
excess cover but it is felt that this is a better outcome for the customer (the customer can of course vary this if they wish).
Please see the following example:
Example 4 –– The customer gets 16 weeks full pay. In this scenario the recommendation must be for full benefit with a
deferred period of 13 weeks. It must be explained to the customer that any benefit payable during the first month after
the deferred period will be reduced by the amount of benefit payable in the final month of the employer’s sick pay scheme.
If the customer accepts this recommendation a note must be included in the Important Information section explaining
this. The customer can choose to vary this advice and accept a longer deferred period but the reasons must be recorded
in the SDN.
For self-employed customers without formal sick pay arrangements, consideration should be given to the level of income
and period over which an income would be drawn by the customer from the business in the event of their incapacity. The
most appropriate deferment period should then be recommended providing for an overlap where an exact match cannot
be made. A record of the discussion including the level of income and the period over which this would be drawn should
be noted in the Fact Find.

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Please Note: The Dual Benefit Calculator should only be used to calculate the benefit split. It cannot be relied upon to
show the correct deferred periods, so you should ignore the deferred periods shown on the Dual Benefit Calculator and
base your recommendations on the above guidance.
Covering a Second Income
Where the customer has more than one source of earned income, your recommendation should cover all sources of a
customer’s earned income, including any second job. For a second job there is no minimum income required or minimum
number of hours to be worked, for earned income to be included in your recommendation.
Increasing Cover (Indexation)
In order to ensure that your customer’s income protection policy keeps pace with inflation, you must discuss the benefits
of including increasing cover.
 Where the customer requires increasing cover, you must recommend at RPI, not the fixed increase option, though
the client can opt to choose a fixed rate option.
 Where the customer does not wish to include increasing cover or chooses a fixed rate option, this should be
highlighted as a shortfall in the important information section of the SDN.
Affordability:
Where due to insufficient NDI the full recommendation for the full term cannot be made you should consider the following
options accordance with the customers preferences documenting the discussion in the Important Information sections
of the SDN
 Reduce the term

 Increase the deferred period
 Reduce the benefit amount

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If the policy is rated after submission, you must review affordability and check NDI is available. If there is insufficient NDI
you must amend your recommendation so it is affordable.
Limited Benefit Cover
Limited Benefit cover must never be initially recommended;
Customers can choose to vary to this but this must not form part your initial recommendation.
Where Limited Benefit IP is recommended as part of a variation of advice, you must include full details on the case to
explain why the 2 year Limited Benefit period is suitable. Affordability alone will not be a sufficient justification.
Where Limited Benefit is varied to, the MSC must make the customer aware of the of the limitations and restrictions on
the benefit claim periods and why this is still deemed to be in the customer’s best interests, based on their needs and
circumstances.
Where Limited Benefit IP is varied to, the MSC must record the following in the SDN:
a) They have advised the customer that Limited Benefit has restrictions on claim duration and is therefore only a temporary
solution
b) Confirmation that the customer has been made aware of the claim limitations.
Maternity Leave
Where you have identified a need for Income Protection for a client who is currently on maternity leave a recommendation
should be made if the customer has indicated their intention to return to work in accordance with Aviva policy.
Existing ASU Cover
You should not make a recommendation to cancel/replace an existing ASU policy and where the customer chooses to
retain this you must take into account when making recommendations for Income Protection.

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3.8 BTL Ltd Company Protection Recommendations
BTL Limited Companies require specialist protection policies which are beyond our scope of advice.
The Ageas system does not cater for policies written for limited companies so under NO circumstances should
buildings/contents cover be recommended.
Under NO circumstances should any Aviva Individual Protection Polices be recommended.
You may not recommend Ageas Homeguard Let Buildings & Contents policies. Instead, you should request your
customers consent to make a referral to Dynamo for buildings and contents insurance, please follow the relevant referral
process on Engage.
You cannot refer life business in respect of Limited companies to Dynamo.
3.9 Existing Cover
Where the customer has existing cover (including employer benefits) you should establish the details (e.g. benefit
amount, term, etc.) and the intended purpose of this cover and record accurately in the fact find the purpose of the cover.
If the intended purpose is to protect the mortgage and the customer has been able to provide sufficient details of the
policy (e.g. you can fully complete all sections of the Existing Policies area of Hub), you must take this into account when
preparing your solutions whether or not you have seen evidence of the cover. If the customer is not able to provide
sufficient details of existing policies, you cannot include them in your advice/recommendation and must make the
customer aware of this and record this in the Hub. You must also confirm in notes that you have recommended to the
customer that they make every effort to ascertain/establish and provide you with any missing details. You should
establish whether the existing cover is suitable (e.g. term, sum assured etc.) and where there is a shortfall you should
discuss this with the customer and explain their options e.g:
o Use existing cover to protect all/part of the mortgage and recommend cover to make up shortfall where
possible
o Use existing cover to protect all/part of the mortgage and accept the shortfall
o Use the existing cover for a different purpose and take additional cover for the mortgage

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o Where existing cover is completely unsuitable, cancel this cover and replace with a new policy (see section
on policy replacement)
Whatever solution is decided upon, this must be accurately documented in the SDN. Details of all existing cover that has
an intended purpose of mortgage protection must be included in the SDN.
Where the customer agrees to a protection need but is not happy for you to make a recommendation, you must document
in the HUB the customers reasons for wanting to leave the shortfall unaddressed.
Refer to Appendix 6 for further guidance or to Insurance Helpdesk (if required)
Existing ASU
You should not make a recommendation to cancel/replace an existing ASU policy and where the customer chooses to
retain this you must take into account when making recommendations for Income Protection, in addition any existing
ASU cover cannot be documented as Family Protection.
Existing Buildings/Contents.
Where a customer has existing buildings and/or contents cover this must be accurately recorded in the existing cover
section of the Hub.
Where the customer intends replacing the existing policy(s) with a new policy this must be recorded in the Hub. The
SDN should obviously contain details of your recommendation for the new policy. Where the customer wants to retain
the policy (e.g. remortgage) accurate details must also be recorded in the SDN.
Where the customer has an existing buildings-only or contents-only policy the buildings/contents drop down must be
selected.

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3.10 Policy Replacement
You must never make a recommendation to cancel and replace an existing policy unless you have received a copy of
the relevant policy to enable you to make a comparison and establish that the replacement policy is more suitable.
If you recommend that an existing policy be replaced the reason for this must be accurately recorded in the SDN. It is
not acceptable to arrange a new policy and simply leave it for the customer to decide whether to cancel or retain.
You must also ensure that any loss of cover/benefit from the old policy is discussed fully with the customer and that
details are recorded in the SDN. If the underwriting decision includes ratings or exclusions that aren’t on the existing
policy being cancelled, then refer to the Insurance desk for further guidance and save all full email trails to the case.
If you make a recommendation to replace a policy you must discuss the reasons (including circumstances) that lead to
this recommendation with your line manager prior to the sign up.
Your line manager must review this with you including how you will document this in the Existing Protection Policies
section of the SDN and your line manager’s notes must be recorded on the Hub to confirm they agree with your
recommendation and your SDN is accurate.
When the case has been submitted you must email casechecking@connells.co.uk to make them aware of the policy
replacement and save this email to the case.
Existing Life LTA or DTA Policy - Please refer to the relevant scenario in the Protection Guidance notes appendix of
this PASM
Existing CIC
You must never advise the customer to cancel an existing Critical Illness policy. In such cases you should must
recommend appropriate top-up policy(s) and highlight any shortfall in cover to the customer and record in SDN.
Alternatively, if appropriate, you can refer to an R05 Advisor.

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Existing IP
You can (if appropriate) advise the customer to replace an existing Income Protection policy, this recommendation must
be appropriate for the customers circumstances and it must be clearly documented on the file the reason for the
recommendation. An example of an appropriate reason may be a deferred period that is no longer suitable due to
changes to the client’s employment.
Existing Aviva Policies
In cases where the client has an existing Aviva protection policy, it may be possible to modify the client’s existing policy
instead of cancelling it and arranging a replacement (using the Life Changing Benefits). Therefore, when
considering the customer’s existing Aviva policies, you should consider whether these can be modified before you
make a recommendation to replace them.
In this scenario contact should be made with Insurance Desk to gain guidance and steps to follow. All full email trails
relating to this must be saved to the case.
3.11 Life Change Benefit
If the customer has an existing Aviva product which was previously recommended by Connells Group, there is the possibility that the
customer could utilise the Life Change Benefit.
In this scenario contact should be made with Insurance Desk to gain guidance and steps to follow. All full email trails relating to this
must be saved to the case.
3.12 Additional options
You must discuss and agree any other additional options. All additional options must be discussed with the customer and client
preferences detailed on the case including reasons why the customer has chosen or declined additional options.
Aviva offer additional option for clients which can be added to their policy. All of these additional options are available at outset at an
additional cost. Please refer to the Aviva Handbook(s) for detailed descriptions.

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These options are; Upgraded Critical Illness cover (this is however our standard recommendation where Critical Illness is required),
Upgraded Children`s Critical Illness cover, Extra Care cover, Total Permanent Disability, Fracture Cover and Global Treatment.
All additional options must be discussed with the customer and client preferences detailed on the case/SDN including reasons why the
customer has chosen or declined additional options. Details of any additional options recommended and the reasons for the
recommendation must be included in the SDN. Under no circumstances should options be added without having discussed these with
the customer
Upgraded Children`s CIC will be treated as per all other additional options, however a recommendation can only be made if the
clients currently have children, one of the parties is currently pregnant or they are planning a family.
Increasing Cover (Indexation)
The scope of our protection advice is to protect the mortgage and as such it is not permissible to add increasing cover to any life or
CIC recommendation except for a mortgage on a shared equity/HTB/ownership scheme. In this case, increasing cover should only
be applied to the LTA portion of cover designed to cover the shared equity/ownership element. You cannot apply indexation to the
DTA covering the mortgage amount. If, due to minimum/lowest premium, it is best to recommend one LTA policy for both the
Repayment Mortgage & Shared Equity/HTB/ownership element, this must not include increasing cover.
Waiver of Premium
If you make a recommendation for Waiver of Premium, Aviva offer deferred periods of 1, 3, and 6 months.
It would normally be expected that your recommendation of a deferral period for WOP would be aligned with your customer’s employer’s
sick pay arrangements and these arrangements should be documented in the Fact Find. However, it is permissible to select a different
deferral period with an appropriate justification. You must document in Solutions HUB the reason you have recommended the relevant
deferral period.
Where a customer is not eligible for WOP or an eligible customer has chosen not to include WOP, you must document the reasons
for this in the Solutions Hub.

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Joint policy holders may have different deferred periods within the same policy.
Always refer to the Aviva Occupation Guide for eligibility on WOP.
3.13 Buildings and Contents Recommendations
Buildings Cover – You must inform the customer that the sum insured can be determined either by the rebuild cost
provided by the surveyor or from guidelines provided by Ageas. N.B. Where a rebuild cost has been provided by a
surveyor for a particular property, this must be used rather than the guidelines provided by Ageas.
Contents Cover – The level of contents cover required must be determined by the customer based on their own
knowledge of the value of their possessions. The client should complete an Ageas contents calculator to determine the
value of their (future) home’s contents and wherever possible, this should be added to the Documents section of the Hub.
Ageas – Statement of Fact - The Ageas Statement of Fact forms the basis of the contract between the customer and
Ageas Insurance. You must review this document together with the customer in order to confirm and agree that the
content is correct and that the customer understands it. Should any discrepancies be found or should any of the
information be incorrect, you must advise Ageas without delay as any errors or omissions may invalidate cover. You
must provide the customer with a copy of the Statement of Fact.
B&C Cover for Cash Buyers - Buildings and Contents cover may be recommended to cash buyers but, as you are not
able to carry out non-advised sales, a protection only fact find and affordability assessment would be required.

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SECTION 4 – PREPARING SOLUTIONS
4.1 When preparing your solutions you must consider every case on its individual merits and must always recommend the
least expensive solution that best meets the customers’ demands and needs and this may require you to consider different
options (e.g. joint or single, standalone or combined). You must ensure that any proposed recommendations:
 are suitable for the customer, and;

 are affordable for the customer, and;
 that the customer is eligible to apply, and;
 that the customer has a reasonable chance of claiming, and;
 that you have established any limitations that may occur, and:
 result in the right outcome by covering the identified demands and needs of the customer
At this stage you are able to exclude any needs that the customer does not wish to pursue and should focus on identifying
suitable recommendations to meet those needs that the customer wishes to pursue. When preparing your
recommendations you must adhere to the following levels of cover for those that apply ensuring that the total
recommendations are affordable:
 Death – You should recommend sufficient cover to protect the full mortgage and any added fees, for each party to
the mortgage for the full term, taking into account the repayment method and any existing cover that the customer
wishes to use to protect the mortgage.
 Critical Illness – You should recommend sufficient cover to protect the full mortgage and any added fees, for each
party to the mortgage for the full term, taking into account the repayment method and any existing cover that the
customer wishes to use to protect the mortgage.
Aviva offer two forms of Critical Illness Cover, Core Critical Illness and Upgraded Critical Illness.
Our standard recommendation is to recommend Upgraded Critical Illness cover, however where NDI does not
permit, you should recommend Upgraded CIC within available NDI but allow the customer to vary to Core Critical
Illness cover (having discussed both options), you need to produce illustrations for both Core and Upgraded Critical
Illness and save to the case. Discussions with the customer should take place with regards to their preference to a
lower level of Upgraded cover or a higher level or Core cover and documented on the case.

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 Ill Health/Injury (Income Protection) – You should recommend a sufficient amount to fully protect earned income
for each party to the mortgage in the event of them being unable to work due to ill health or in the event of an injury
up to Selected Retirement Age or, if not known, State Pension Age (subject to Aviva maximums) taking into account
any existing cover (including employer benefits). Aviva do not offer house persons or unemployed persons cover.
 Will - to ensure that the estate is disposed of in accordance with the customer(s) wishes in the event of death.
 Buildings – to cover the rebuild cost of the property due to an event as described in the policy.
 Contents – to cover the full cost of reinstatement due to losses resulting from an event described in the policy
Protection only cover
Life, CIC and combined Life and CIC cover may be arranged on an own life, joint life first death basis for a party not
named on the mortgage The party not named on the mortgage recommendation can only be party to a protection
recommendation where this is an insurable interest.
Income Protection can also be arranged for the party not named on the mortgage provided that the individual to be
insured is contributing to the household budget.
In those circumstances where minimum premiums mean that an additional sum assured is generated over the sum
assured arranged for mortgage protection, the additional cover should be deducted from the sums assured described
above and any top up arranged for the remaining sum assured. Where this means that a proportion of the protection
sum assured will not have indexation of cover, this must be documented in the SDN
It is accepted that there may be a small difference of up to £1,000 in the level of cover recommended (Life/CIC), where
identified by Case Checking some leniency will be given on the grading of these cases.
Unless the customer can afford to fully address all the needs that they want to pursue, it may be necessary to consider a
number of different options in order to establish the least expensive solution that best meets the needs and you must allow
yourself time to do this properly. Where affordable you must always recommend sufficient cover to fully address the need.
Where NDI is an issue you should prepare solutions taking into account the customers preference to cascade or spread
the cost. You will, therefore, make one of three recommendations in respect of each need that the customer wants to
pursue:
1. If affordable, sufficient cover (sum assured, term etc.) to address the full need

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2. If the full recommendation is not affordable, reduced level of cover to partially address the need
3. Where no cover is affordable you must recommend no cover.
For example, a customer wants to pursue Life, Critical Illness and contents cover (in that order) but you establish that
there is likely to be insufficient NDI to fully address all 3 needs. If the customer has stated a preference to cascade cost
your recommendations may be:
1. Sufficient cover to fully address the need for Life Cover

2. Cover to partially address the need for Critical Illness Cover
3. No cover to protect contents
Cascading is almost always likely to be the most suitable solution for customer(s) with a limited budget and it is, therefore,
imperative that you fully understand the customer(s) order of priority. Spreading the amount available over a number of
policies will be the least favourable option and it is unlikely that this will be an effective solution unless this can be justified
(e.g. the customer(s) already have cover in more than one area and simply require top-up policies).
Whatever the customer(s) preference, you must record this in the SDN.
Prior to making recommendations, you should prepare illustrations and put together appropriate customer literature (e.g.
Aviva Policy Summary(s) (KFD), etc.). You must now take time to ensure that the customer is eligible, identify whether
there will be any shortfalls in cover, whether any parts of the cover will not apply and whether the customer will be affected
by any limitations or exclusions within the policy. These are described as follows:
 Shortfall - A shortfall can be where the customer has accepted your recommendation in full but this does not
completely satisfy the need(s) of the customer (e.g. it may be that the customers mortgage continues to age 75 but
under the policy rules, critical illness cover must cease at max age permitted by Aviva product
recommended/chosen meaning that they will have a shortfall of cover on the mortgage. Please refer to the appendix
guide, page 43 of the PASM, for guidelines on ages. Alternatively, the customer may accept your recommendation
but for a reduced level of cover/term. This is important as you will need to draw the customers attention to any
shortfalls so that they are able to make an informed decision and these will need to be recorded in the SDN.

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Exclusions/limitations – A customers circumstances (e.g. employment, medical history) may mean that specific
exclusions or limitations apply and you must be aware of these as they must be brought to the customers attention and
details must be recorded in the SDN. You should, however, consider the General Data Protection regulation rules regarding
sensitive personal data when completing your records. Please refer to Aviva Occupation Guide.
For clarity, cover must not be arranged for business protection, Whole of Life or for Inheritance Tax planning.
SECTION 5 – PRESENTATION OF ADVICE
5.1 When presenting protection advice, you must explain to the customer how your proposed solution meets their identified
needs, and take time to ensure that they have fully understood.
When presenting the Hub Facts document(s) relating to your advice, you must ensure that you provide the customer(s)
with sufficient information regarding the features, benefits, shortfalls, limitations etc. to enable them to make an informed
decision. You must provide illustrations, Key Facts documents etc. for all policies recommended. Full details of the
information that you must verbally highlight to the customer(s) at recommendation stage are contained in the following
annexes:
 Life Cover - Appendix 1

 Critical Illness with Life Cover - Appendix 2
 Critical Illness - Appendix 3
 Income Protection - Appendix 4
 Buildings/Contents - Appendix 5
Where a customer decides not to proceed with a recommendation you should record the reasons for decline in the SDN.
5.2 Varying Your Advice
Where you have made a recommendation for full or partial cover and the customer chooses to vary this (e.g. reduce sum
assured, term, deferred period, etc.) the variation is still your recommendation and responsibility as a consultant and must
be within our scope of advice.

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You must record the reasons why the variation is still a suitable alternative for the customer in the Solutions Hub (Accepted
with changes – Reason for decision section). In such cases, before proceeding with any application, you must highlight
any shortfall and include details in the SDN.
You must not vary your advice to provide the customer with cover in excess of their mortgage needs, except where this is
unavoidable due to minimum premium.
Customer wishes to vary DTA recommendation to LTA
If, after a recommendation has been made for DTA to protect a Repayment mortgage, the client wants to vary the
recommendation due to their preferences or needs, it may be appropriate to discuss with the client the option of LTA if for
example they are taking a reduced level of cover.
In all instances, your recommendation must be for DTA and the accepted variance will therefore be for the LTA.
It is not acceptable to vary your recommendation simply for better value. A justifiable reason as to why the recommendation
has been varied from DTA to LTA must be provided in the variance section of the SDN
5.3 Will
Prior to completing applications, you must explain to the customer(s) who the policy benefits will be paid to and
any consequences of not having an up to date will.
A Will only is considered protection only so Credas (ID) is required together with an SDN to document the
recommendation and customer decision. Ideally a review of all protection needs takes place, also documented in the
Fact Find and SDN.
5.4 Trusts (Referrals)
A trust is an arrangement that allows a third party, or trustee, to hold assets on behalf of a beneficiary or beneficiaries and
can be arranged in many ways in order to specify exactly how and when the assets pass to the beneficiaries. Trusts can

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be extremely complicated and under no circumstances should you provide advice to customers in this respect although
these can be referred to Aviva.
Where a recommendation is made for a life or life and CIC policy on a single life basis you must provide the customer(s)
with a copy of the pre-printed leaflet “Choosing Whether to Place Your Policy in Trust”.
Ultimately, the customer is responsible for deciding whether to place their policy in trust and whilst Aviva can
provide specimen trust documentation they do not offer advice in this respect. If the customer wants advice with
regard to trusts they must be advised to seek independent legal advice (this can usually be offered by the
customer’s conveyancer).
5.5 Application
 If practical, you should always offer the customer the opportunity to complete any application forms themselves.
 If you are completing on the customers behalf, you must ask clear questions exactly as they appear on-screen.
 You must explain to the customer that they should answer all questions honestly and accurately as any deliberate
misrepresentation of fact(s) may result in non-payment of a claim.
 You must ask all of the underwriting questions fully, providing full details of any medical conditions or treatment/
medication, and must never make assumptions.
 You must ensure that any appropriate declarations are read by or to the customer
 If the customer is replacing an existing policy, you must advise them that this should not be cancelled until the new
policy is on risk and that it is the responsibility of the client(s) to cancel the existing policy
 You must explain to the customer how and when to make a claim
 You must explain to the customer their cancellation rights as applicable
 Where an application has been completed on behalf of the customer, the customer should always be given the
opportunity and the time to read prior to submission.
 You should not use the unknown occupation definition unless approved by Insurance Helpdesk or Aviva
Underwriting Helpdesk (where a reference number will be given). This should be included in your notes on the Hub.
You must never edit the health and lifestyle information in an Aviva application after the initial underwriting decision has
been given, unless the customer contacts you with further disclosures.

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This means that we would not expect to see changes to information such as the customer’s height and weight, change to
smoker status or changing a ’Yes’ to a ‘No’ in relation to pre-existing medical conditions without a record in Hub of when
the customer notified you of the change.
We must avoid any instances of our customers’ having their Aviva claims declined due to “misrepresentation” by either
you or the customer. This would clearly be a material issue for the customer, and the business.
It is imperative all Aviva underwriting questions are answered accurately and honestly, reflecting the customer’s true
circumstances, these questions should be answered in conjunction with the customer.
Failure to do so will increase the chances of a claim not being paid when the customer needs it most.
It is a disciplinary offence to purposefully manipulate an Aviva application in order to obtain a more favourable underwriting
outcome.
Any application amended after an initial underwriting decision has been made and where the amendment would improve
the terms offered by Aviva will automatically refer back to Aviva Underwriters, for review and so the new information can
be checked with the applicant.
Unless the case is a decline or 180 day expiry, you must not re-key an application unless you have approval from Insurance
Helpdesk or the pre-sales Underwriting at Aviva (evidence of this to be retained on the case in the form of the reference
number or email).
If you are contacted by a customer wishing to change an answer in their application, you should discuss and
confirm the accurate information with the customer. Once you have confirmed the information, you must amend
the Aviva application accordingly and if appropriate, advise the customer of any new premium or underwriting
outcome. You must then add a note to the case in the Hub to confirm the reason for making the amendment, then
notify your supervisor of the amendment made and the reason for doing this (e.g. ‘customer has advised new
medical condition’).

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Having completed the application(s) you must explain to the customer what will happen next (e.g. underwriting, medical
etc.). It is advisable to point out that they will receive a cancellation notice and that they only need to return this if they do
not want to proceed with the policy.
Finally, it is important to remind the customer(s) that the recommendations you have made are based on their
circumstances, demands and needs at that time and that cover should be reviewed regularly to ensure that it is still
sufficient and appropriate for their needs.
5.6 Placing Policies on Risk
You should inform all customers that policies will be placed on risk at exchange of contracts. Under no circumstances
should policies be placed on risk before exchange unless the customer has explicitly requested this, and you have
submitted the `Early On Risk` instruction form to MBU detailing the reasons that the policies are to go on risk early.
Under no circumstances should a start/commence date be entered on any Aviva application or within MUMS by a
protection advisor. This may result in disciplinary action.
Where immediate cover is required you must provide the customer with oral disclosure of the SDN content and provide
the customer with a hard copy of that document within 2 working days.
SECTION 6 – POST SALE ACTIVITIES
6.1 Prepare Statement of Demands and Needs
 A Statement of Demands and Needs (SDN) is required in all cases where needs have been identified, even
where no protection has been recommended.
 Where an application for buildings insurance is referred, you should produce the SDN but not include a premium
for buildings insurance. Once the premium has been agreed/ provided by Ageas, MBU will finalise and issue the
SDN.

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As a minimum, the SDN must document the following:
 The customer(s) protection needs.

 Details of any existing protection.
 Details of any recommendations made to cancel or replace an existing policy.
 The customer(s) views.
 Full details of recommendations made and how these meet the needs of the customer.
 Full details where customer has chosen a different level of cover or opted for single/separate policies.
 Details of any additional options selected.
 Details of any shortfalls in cover.
 Details of any significant limitations/exclusions that will affect ability to claim.
 Confirmation of affordability
Completion
Section 1 – Needs Identified.

Section 2 – Existing Arrangements. Where these exist, full details (see Section 3.9) must be recorded in the SDN.
Section 3 – Replacement Policies. Where you are recommending the cancellation/replacement of an existing life
insurance policy, you must explain the reasons for this and document the advantages and disadvantages
of this course of action. The disadvantages must highlight any features/benefits that will be sacrificed on
cancellation. (see PASM Section 3.10)
Section 4 – Your Views. The customer(s) views must be recorded for each need area
Section 5 – My Recommendations. This section must be accurately completed depending on whether a full, partial or
no recommendation has been made and where the customer has chosen to vary or decline, the reasons
must be accurately recorded. Where your recommendation is not the least expensive (e.g. standalone
life/CIC has been recommended) the reason(s) for this must be recorded.
Section 6 – Important Information. This section must be accurately completed to highlight any shortfalls in cover and
any specific significant limitations or exclusions that to apply to the customer(s)
Section 7 – Affordability. In this section you must calculate and record the total combined costs of your
recommendations and cover taken. It is not necessary to include the plan fee in these calculations as this
is covered separately.

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The SDN will be issued to the customer by the MBU.
Any subsequent change to advice or products applied for will require a Change of Advice (COA) and a further SDN.
The SDN can be accessed in the Hub.
Where an amendment to the mortgage results in a change to the amount of borrowing or the term of the mortgage you
must ensure that this is discussed with the customer and that protection policies applied for are reviewed accordingly and
that an appropriate COA if applicable and SDN is provided.
Declined Applications
If you customers application is declined, you can make a referral to Dynamo. Please see the referral process on Engage

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When you make the following disclosures, you must also ensure your
Customer has understood all areas of your discussion and that you
have answered any questions.
Appendix 1 – LIFE COVER (VERBAL DISCLOSURES)
What you must tell the customer(s) at recommendation stage

The policy provider
Whether the policy is DTA (decreasing) , Level Term
The policy premium and total premium cost over the term
Whether premiums are guaranteed to remain the same throughout or will increase
(if increasing option selected).
The lump sum benefit of the policy and whether there is any shortfall in term/cover
or details of any over-insurance
That benefits will not increase (unless increasing option selected)
Whether any optional options can be added (e.g. increasing, WOP, fracture cover
a description, and any additional cost
The term of the policy
That they will be required to continue paying the premium during any period of
incapacity (or during the chosen deferred period if WOP selected)
Any specific exclusions or limitations of the policy.
The policy has no surrender value
The customers right to cancel
Appendix 2 – LIFE WITH ADDED CIC COVER (VERBAL DISCLOSURES)

The policy provider
Whether the policy is DTA (decreasing), Level Term
(if increasing option selected) or may change (if reviewable premiums selected)
Upgraded critical Illness benefit
Whether any optional options can be added (e.g. increasing, WOP, fracture
cover,) a description, and any additional cost
What conditions are covered and that some types of cancer are not covered
Childrens benefits (and limitations)
Clients existing policy may have more illnesses and/or better definitions (if
applicable)
The customers right to cancel and how to do this
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Appendix 3 - CRITICAL ILLNESS COVER (VERBAL DISCLOSURES)

The policy provider
Whether the policy is DTA (decreasing) , Level Term
Upgraded critical illness benefit
Whether any optional options can be added (e.g. increasing, WOP, fracture
cover,) a description, and any additional cost
What conditions are covered and that some types of cancer are not covered
Childrens benefits (and limitations)
Clients existing policy may have more illnesses and/or better definitions (if
applicable)
Appendix 4 - INCOME PROTECTION (VERBAL DISCLOSURES)

The policy provider
The monthly benefit of the policy and whether there is any shortfall in term/cover or
details of any over-insurance
If 2 year recurrent benefit option is selected, that the benefits will be limited to
throughout the term as a single continuous period or a collection of shorter periods
Whether any options can be added (e.g. increasing, fracture cover, 2 year recurrent
benefit), a description, and any additional cost
The deferred period(s) recommended and the reasons (e.g. how they fit with
existing cover or benefits)
That payments from an employer (e.g. sick pay), continuing earnings from any
occupation and/or continuing benefits from any accident or sickness policy may
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reduce any payment at the point of claim, and that some means tested benefits may
affect the amount of benefit payable
That they may be required to continue paying the premium during the early months
of any period of claim (depending on the deferred period selected) or throughout if
WOP not selected
How benefits will be determined in the event of a claim (e.g. activities of daily
work/living)
If the client resides outside any of the countries listed in the Policy Summary for
more than 13 weeks during any 12 month period benefits may be restricted or not
paid
Appendix 5 – BUILDINGS & CONTENTS (VERBAL DISCLOSURES)

Monthly premium
Level of Buildings cover. The customer must be provided with an explanation of how
this has been assessed (e.g. survey report, calculator)
Level of Contents cover and the fact that this is based on the customer(s)
assessment of cost of replacement/reinstatement
Any applicable excesses (compulsory and voluntary)
What will be covered and what won't be covered
Definition of high risk items
The policy is a monthly renewable contract
Any specific exclusions or limitations of the policy as detailed in the provider
literature

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Appendix 6
Connells Group
Guidance notes for Life & CIC protection recommendations
IMPORTANT POINTS TO NOTE:

It is important we document our reasons for recommending protection policies and that we act in the best
interest of our customers at all times.
• Repayment Mortgage – Always recommend a Decreasing Term Policy (DTA) * refer to PASM for minimum
premiums
• Interest Only Mortgage – Always recommend a Level Term Policy (LTA) – NO RPI (Indexation)
• RPI (Indexation) – Can only be added to any Help to Buy/Shared Ownership/Shared Equity recommendation
(and income protection policies).
• Customer variations for a Level Term Policy must not include RPI except in the instance of covering a shared
equity/HTB/shared ownership element
• Minimum Premium – Where DTA results in minimum premium and cover in excess of the mortgage amount,
you must produce an LTA illustration and both must be saved in the HUB
• If a customer has a specific requirement to use DIS as part of their mortgage protection, for the purposes of
calculating any top-up recommendations, treat the DIS policy as an existing LTA policy to the clients retirement
age
• You must recommend the cheapest policy that meets your customer’s needs for example; your customer has
had a change in health, lifestyle or medical history and a Top Up is more appropriate
• If a top up recommendation is made a full rationale must be added to the SDN
• You must always take into consideration any shortfall between the initial mortgage debt and current protection
Please note that at all times we should be acting in the customers best interest and that we show our calculations and reasons for advice
clearly in notes on the HUB. In ALL instances where we recommend ANY policy cancellations you must refer to your MSSM

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1) Shared Equity/Help to Buy Scheme/Shared Ownership
Recommendation
• Repayment mortgage – DTA for the term of the mortgage

• Shared Equity/ HTB/ Shared Ownership Loan – LTA with RPI
(Indexation) for the term of the Scheme
Example:
£200,000 purchase price x 20% equity share = £40000
Shared Equity/HTB Scheme/Shared Ownership Recommendation = £40,000

LTA with RPI (Indexation) policy for the term of the Scheme
£200,000 purchase price x 5% deposit = £10,000
£200,000 – £40,000 - £10,000 = £150,000
Mortgage Recommendation = £150,000 DTA Policy for the term of the

mortgage
If the mortgage recommendation includes any fee added to the mortgage your
recommendation must include the added fees.
Please note that at all times we should be acting in the customer’s best interest and that we show our calculations and reasons for advice clearly in notes
on the HUB. In ALL instances where we recommend ANY policy cancellations you must refer to your MSSM

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2. Existing DTA Life Cover shorter term and the amount of borrowing is the same.
Recommendation
Your customer has an existing DTA Policy that has a shorter policy
term than the total mortgage term.
As the existing Life DTA policy will leave the customer short in
years and cover at the end of the term, if there are no changes to
your customer’s health then a recommendation to cancel and
replace for the total initial mortgage debt should be made.
If the customer does not wish to cancel or there are any changes to
their health, lifestyle or medical history, a recommendation for a top
up policy should be considered.
Top Up:
• Refer to the mortgage payment schedule balance at the end

of the existing policy term.
• Recommend an LTA top up for the term of the mortgage
debt (T)
•
Example;
The existing cover is £150,000 over 26 years.

The initial mortgage debt is £150,000 over 31 years.
Recommend is an LTA for £40,000 (A) over 31 years (T)
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3. Existing DTA Life only, CIC only and Life & CIC Cover with a Longer Term and the amount of
borrowing is the same or less
Recommendation
Your customer has an existing DTA Policy
that has a longer policy term than the total
mortgage term.
If the amount of the borrowing is the same
or less, then no recommendation is to be
made as the existing cover should be used.
For Life only - you can recommend a
cancel and replacement policy if it is in the
customers best interest.
Recommendation
Your customer has an existing DTA policy with the same

term and the initial mortgage debt is the same or less.
If the amount of the borrowing is the same or less, then

no recommendation is to be made as the existing cover
should be used.
Life Only
For Life only, you can recommend a cancel and
replacement policy if it is in the customer’s best interest.
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4. Existing DTA Life only, CIC only and Life & CIC with a Longer Term and the amount of
borrowing is greater.
Recommendation
Your customer has an existing DTA policy with a longer term and
the initial mortgage debt is greater.
Life only
Your recommendation should be to cancel the existing policy and
replace with a new DTA for the full mortgage and term, unless it
is more beneficial to the customer to have a top up.
CIC-only or Life & CIC
T Produce an illustration on an LTA basis for the top up. This will be
for the difference between the existing policy amount and the
initial mortgage debt (A).
Using your ESIS repayment schedule your term will be the point
the mortgage debt meets the existing policy amount (T).
Example;
The existing DTA is £150,000 over 31 years.
Recommendation is an LTA for £50,000 over 18 years.
Please note that at all times we should be acting in the customer’s best interest and that we show our calculations and reasons for advice clearly in
notes on the HUB. In ALL instances where we recommend ANY policy cancellations you must refer to your MSSM

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5. Existing DTA Life only, CIC only and Life & CIC with the same Term and the amount of
borrowing is greater
Recommendation
Your customer has an existing DTA policy with the same term and
the initial mortgage debt is greater.
Life only
You must produce two quotes:
A 1. A new DTA for the initial mortgage debt and term with the
view to cancel and replace the existing policy
2. An LTA top up for the difference in the initial mortgage debt
and over the mortgage term
CIC only or Life & CIC

Produce an illustration on an LTA basis for the top up. This will be
for the difference between the existing policy amount and the
initial mortgage debt (A) over the term of the mortgage (T).
Example;
The existing DTA is £150,000 over 26 years.
T Recommendation is an LTA for £50,000 over 26 years.

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6. Existing DTA Life only, CIC only and Life & CIC with the SAME Term and the amount of
borrowing is the same or less
Recommendation
Your customer has an existing DTA policy with the same term and
the initial mortgage debt is the same or less.
If the amount of the borrowing is the same or less, then no

recommendation is to be made as the existing cover should be
used.
Life Only
For Life only, you can recommend a cancel and replacement policy
if it is in the customer’s best interest.

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7. Existing DTA Life only, CIC only and Life & CIC with a SHORTER term and the amount of
borrowing is greater
Recommendation
Your customer has an existing DTA policy that has a shorter term
than the mortgage and the debt is greater.
1. Establish "A" the difference between the existing policy and the
initial mortgage debt.
A 2. Establish "B" the remaining mortgage balance at the point the

existing policy's term expires.
3. The LTA should be recommended for the greater of "A" or "B" for
the term of the initial mortgage debt (T).
Example;
The existing DTA is £150,000 and has 25 years remaining; according

to the mortgage payment schedule, the balance for the mortgage at
B this point will be £51,017.
Therefore:
A = £50,000
B = £51,017
T Recommendation is an LTA for £51,017 over 31 years.
Life only
For Life only, you can recommend to cancel the existing policy and
replace with a new DTA. Refer to PASM.

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8. Existing LTA Life only, CIC only and Life & CIC with a SHORTER Term borrowing is greater
Recommendation
Your customer has an existing LTA policy that has a shorter term
and the existing policy does not cover the initial mortgage debt.
A 1. Establish "A" the difference between the existing policy and

the initial mortgage debt.
2. Establish "B" the remaining mortgage balance at the point the
existing policy's term expires.
3. The LTA should be recommended for the greater of "A" or "B"
for the term of the initial mortgage debt (T).
Example;
The initial mortgage debt is £150,000 for 26 years.
B The existing LTA is £100,000 and has 19 years remaining;

according to the mortgage payment schedule the balance for
the mortgage at this point will be £56,933.
Therefore:
A = £50,000
B = £56,933
Recommendation is an LTA for £56,933 over 26 years (T).
T Life only
For Life only, you can recommend to cancel the existing policy
and replace with a new DTA. Refer to PASM.

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9. Existing LTA Life only, CIC only and Life & CIC Cover with the SAME or LONGER term than
the initial mortgage debt and borrowing is less
Recommendation
Your customer has an existing LTA Policy that has the same
or longer term than the initial mortgage debt.
Life only
For Life only, if it is cost effective for the customer to do so
you can recommend to cancel the existing policy and replace
with a new DTA. Refer to PASM.
CIC only or Life & CIC

If the amount of the borrowing is the same or less, then no
recommendation is to be made as the existing cover should
be used.

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10. Existing LTA Life only, CIC only and Life & CIC Cover that has the SAME or LONGER term as
the initial mortgage debt and the borrowing is greater
Recommendation
Your customer has an existing LTA policy that has same or

longer term than the initial mortgage debt and the borrowing is
A greater.
1. Refer to the mortgage payment schedule. At the point where

the mortgage balance drops below the cover provided by the
existing policy use this as the term (T).
2. Produce a DTA top up illustration for the excess initial

mortgage debt above the existing protection – "A” illustrates the
amount of the cover (being the shortfall between the mortgage
amount and the cover provided by the existing policy).
Example;

The existing LTA is £125,000 over 26 years.
Recommendation is DTA for £25,000 over 7 years.
Life only
For Life only, if it is cost effective for the customer to do so you
can recommend to cancel the existing policy and replace with a
new DTA. Refer to PASM.

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11. Existing LTA Life only, CIC only and Life & CIC Cover has a SHORTER Term and
Borrowing is the same
Recommendation
Your customer has an existing LTA policy that has a shorter

term than the initial mortgage debt.
1. Produce illustration for full cover on a DTA basis.
2. Produce top up illustration. This will be on an LTA basis

for the mortgage balance once the existing policy has
ended (A) for the term of the mortgage debt (T).
See graph for your potential recommendation.
Life only
A For Life only, if it is cost effective for the customer to do so

you can recommend to cancel the existing policy and
replace with a new DTA. Refer to PASM.
T

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12. Part Repayment, Part Interest Only Mortgage.
Recommendation
Your customer has a part and part initial mortgage debt.
• Where the mortgage is on a part & part basis the

recommendation must be for DTA to cover the
repayment amount (A) and LTA for the Interest
Only amount (B) over the mortgage term (T).
• An LTA illustration for the full mortgage amount
A over the term must be prepared for a cost

comparison.
See graph for your potential recommendation.
Where both DTA and LTA are at minimum premium and

cover the full mortgage amount then both illustrations
must be produced, discussed with the customer and
saved to the case. The recommendation can be for
B either DTA or LTA.
Note:
Do not include indexation on the LTA element of your
T recommendation.
Consideration should be given to the customer existing
repayment vehicles and any attached life cover.

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PROTECTION

Connells Group – Protection Advice Standards Manual Version 3.9

Version No Amendment Amendment Date Reason

CONNELLS GROUP MORTGAGE SERVICES