Our Remuneration

Penco Insurances Limited trading as Penco, Which Mortgage acts as intermediary between you, the consumer, and the product producer with whom we place your business.


Pursuant to provision 4.58A of the Central Bank of Ireland’s September 2019 Addendum to the Consumer Protection Code, all intermediaries must make available on their website a summary of the details of all arrangements for any fee, commission, other reward or remuneration provided to the intermediary which it has agreed with its product producers. This remuneration summary therefore provides you with details of the remuneration Penco, Which Mortgage receives from product producers when we place your business with them.

What is remuneration?

Remuneration is the payment earned by us for work undertaken on behalf of the producer and you, the consumer. The amount of remuneration is generally directly related to the value of the products arranged and sold.

What is commission?

Commission is payment which may be earned by us for the work we undertake on behalf of the product producer and you as we offer and facilitate transactions on your behalf with the product producer. Commission is usually paid as a percentage of the premium paid or amount invested or amount borrowed.

There are different types of remuneration and different commission models:

Commission Model Description of Commission Model
Single Commission Payment Payment is based on a percentage of the premium paid/amount invested.
Initial Commission Payment Payment is based on a percentage of the premium/amount invested.
Trail Commission Payment Payment is based on a percentage of the underlying value of the investment.
Renewal Commission Payment Payment is made at intervals throughout the term of the policy or product, usually a percentage of the premium paid.
Indemnity Commission Payment Payment is made before the commission is deemed to be earned, therefore in advance. Indemnity commission may be subject to a clawback* (obligation to repay unearned commission previously paid) if a consumer lapses or cancels the product before the commission is deemed to be earned. Other forms of indemnity commission are advances of commission for future sales granted to intermediaries in order to assist with set costs or business development.

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

What is a fee?

A fee is a payment for professional services and expertise. In respect of Life Assurance, Pensions and Investments, and Mortgages, it may be necessary for us to charge a fee for the professional services rendered by us and where we advise you on a non-commission basis or product. Where we charge a fee, it will be agreed with you in writing prior to provision of service.

The following fees may apply to professional services rendered in respect of Non-Life Insurance:

Initial Fees and Renewals

Private Motor Up to a maximum of € 200
Commercial Motor Up to a maximum of € 200
Household Up to a maximum of € 200
Commercial Risks Up to a maximum of 25% of the premium

Alterations, Adjustments, Cancellations and Return Premiums

Private Motor Up to a maximum of € 75
Commercial Motor Up to a maximum of € 100
Household Up to a maximum of € 100
Commercial Risks Up to a maximum of € 1000

Where you have agreed to remunerate us in respect of professional services rendered by way of a fee, please be advised that VAT at the current applicable rate applies to all fee transactions.

Other types of payment/remuneration

We may earn a non-monetary benefit which we will only accept if it enhances the quality of our service to you, our client. For example: attendance at a product seminar or assistance with branding, IT support, etc.

How might the various forms of commission apply to the different products?

Life Assurance, Pensions and Investment Products

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

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

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

Non-Life Insurance

Non-Life Insurance products such as private motor, commercial motor, household, commercial risks, are typically subject to a Single/Initial Commission model, based on the amount of premium charged for the insurance product.


Commission may be earned by us for arranging credit for you, such as mortgages. The single or initial commission model is the most common commission model applied to the sale of mortgage products by us, the mortgage credit intermediary.

Click on a link below to access a list of the product producers that we hold Agency Appointments with and the commission options available to us.


Penco - Wealth

Penco - Insurance