MacDonagh Boland Crotty MacRedmond Limited trading as Aon MacDonagh Boland

Background to the Contraventions The contraventions relate to the administration of premium rebates and overpayments made in respect of the Firm’s Bikecare and Taxicare insurance products and to the Firm’s failure to have adequate systems and controls in place to process those premium rebates and overpayments in respect of these products properly. The Firm self-identified the issues and brought them to the attention of the Central Bank. The Firm has co-operated with the Central Bank during the course of its investigations into the matter and has repaid all affected customers with interest. In relation to the failure of the Firm to obtain the customer’s prior written agreement, the Firm had previously clearly disclosed the fees to customers in its Terms of Business and other client communications. 3 Penalty decision factors The penalties imposed in this case reflect the importance the Central Bank places on compliance with the systems and controls and the premium rebates and overpayment handling requirements of the Handbook and the Code, particularly where such failures result in consumer detriment.