Updated Client Terms and Conditions and Adviser Terms of Business will come into effect on or shortly after 30 January 2023.

Detailed below are explanations for the key changes.

Client Terms and Conditions Adviser Terms of Business
On page 9, under the “Cash” heading, we have clarified the situation with regard to interest on Cash held with our Banking Partners.

On page 10, we state that if the overall interest rate we receive is less than 0% (a negative interest rate), we will pass the cost of depositing your cash holdings on to you.

(on page 7)

  • To note Embark’s right to make relevant checks on the Financial Adviser Firm.
  • To clarify Advisers’ obligations with regard to maintenance of Platform Users’ email addresses, and at such time as they become no longer authorised to act on a Client’s behalf.
You are able, under the new T&Cs, to set up an automatic regular asset purchase if you wish (see page 12). (on page 9)

  • To codify Advisers’ responsibilities in terms of verifying the identity of Clients and other third parties.
You can elect to have the charges from your ISA deducted from your GIA, if you have one. This will also apply to the Adviser Charges (see page 16). (on page 10)

  • To document the Advisers’ necessary compliance with all Regulatory Requirements in relation to product governance.
  • To address instructions for linking online accounts for charging purposes (“Family Linking” option, new to Scottish Widows Platform).
Family Linking (see page 17) will, under certain circumstances, allow you to link your accounts with those of other family members in order to benefit from lower Ongoing Account Charges. (on page 11)

  • To state the circumstances under which Embark will / will not accept Defined Benefit Transfers.
Under “Adviser Charges” on page 17, we’ve noted there may be a regular initial Adviser charge set up when you start a regular contribution for specified period of time. (on pages 12-14)

  • To provide comprehensive detail about our revised processes and your new options with regard to Adviser Charges
  • To clarify the circumstances under which Embark may cease making payments to Advisers.
On page 26, we’ve stated that there may be an Account  Charge for administering your Embark Personal Pension. (on page 20)

  • To explain EISL’s entitlement to assign or otherwise transfer its rights and obligations  under these Terms to another firm.
(on page 21)

  • To give full information as to the circumstances in which Embark may terminate these Terms, and the effects of such termination.