PRELIMINARY INFORMATION
Dr. Christian Saba, based in Bonn, holds a business license as an insurance broker pursuant to Section 34d Paragraph 1 of the German Trade Regulation Act (GewO) and is registered in the intermediary register pursuant to Section 11a GewO under registration number D-OQ41-GEYFT-46.
Dr. Christian Saba is also registered as a financial investment advisor with a license pursuant to Section 34f of the German Trade Regulation Act (GewO) under registration number D-F-110-159M-30 and broker open-ended investment funds authorized in Germany.
There are no holdings in or by insurers or their parent companies.
Furthermore, Dr. Christian Saba holds legally compliant professional liability insurance coverage.
If you wish to verify the entries in the insurance intermediary register, you can do so at any time via the website www.vermittlerregister.info, by telephone at +49 180 60 05 85 0 (fixed price €0.20/call; mobile network rates may vary), or by contacting the DIHK e.V., Breite Straße 29, 10178 Berlin, telephone: +49 30 20308-0, website: www.dihk.de, the joint body responsible for maintaining the register pursuant to Section 11a of the German Trade Regulation Act (GewO).
Information on remuneration and third-party payments in insurance brokerage
You do not have to pay any direct remuneration to the advisors for insurance brokerage services unless you have expressly agreed otherwise with them. The advisors’ remuneration for insurance brokerage is paid by the product provider as a commission upon successful policy issuance or, if applicable, portfolio transfer. This remuneration is already included in the insurance premium. Beyond the commission, advisors receive no further monetary compensation in connection with insurance brokerage. In addition to their commission, advisors may also receive non-monetary benefits from third parties, such as informational materials, training, etc. Advisors are entitled to accept and retain all such benefits as compensation. There is no right to demand their return pursuant to Sections 667 and 675 of the German Civil Code (BGB) (agency).
Scope of the Investment Advice License
The license pursuant to Section 34f of the German Trade Regulation Act (GewO) authorizes the provision of investment advice or the brokerage of contracts for units or shares in domestic open-ended investment funds, open-ended EU investment funds, or foreign open-ended investment funds that may be distributed under the German Investment Code (Section 34f, Paragraph 1, No. 1 GewO).
Information about issuers and providers of financial products for which brokerage or advisory services are offered
Brokerage and advisory services are provided for financial products across the entire spectrum of the German market, insofar as this is permitted under the regulatory authorization as a financial investment broker pursuant to Section 34f of the German Trade Regulation Act (GewO).
Information about remuneration and third-party payments, cost disclosures
Your advisor is not a fee-based financial investment advisor as defined in Section 34h of the German Trade Regulation Act (GewO). Therefore, you are not required to pay any fee or other advisory charge directly to your advisor for investment advice or brokerage services for financial products pursuant to Section 34f of the German Trade Regulation Act (GewO), unless you have expressly agreed to this with them. Your advisor’s remuneration for investment advice or brokerage services is provided in the event of a transaction (order) through payments from the product provider or contractual partner from the costs of the product or transaction (third-party payments). These payments may be accepted and retained by the advisor as remuneration. There is no right to the return of these payments pursuant to Sections 667 and 675 of the German Civil Code (BGB). Details regarding any payments received or made can be found in the ex-ante and ex-post cost information. You will receive cost information in advance (ex-ante) before placing any order. This information is broken down into product and service costs and includes any payments made to your advisor as well as any foreign currency costs. The initial, ongoing, and exit costs are listed individually and as total costs in euros and as a percentage, and the impact of the total costs on the return is shown. You will also receive detailed cost information about your acquired financial investments once a year throughout the entire product lifecycle. The agreed-upon fee is payable for any advisory agreement concluded with the advisor at your request. The terms of the advisory agreement apply.
Contract Information
Your assigned advisor will provide you with investment advice and brokerage services for financial investments upon request. The advisory or brokerage agreement is implicitly concluded through the conclusive conduct of both you and the advisor. Investment advice and brokerage are ad hoc, one-off services.
The advisor’s obligations under this agreement end automatically:
– in the case of investment advice, with your investment decision;
– in the case of brokerage, with the product partner’s decision to accept or reject the order.
The advisor has no post-contractual monitoring or support obligations. The advisor does not regularly review the suitability of the financial investments recommended or brokered to you. Ongoing monitoring and any necessary review of the investments is solely your responsibility.
Issuer and Provider Details
Dr. Christian Saba will gladly provide you, upon request, with a list of current contractual partners in the area of financial investment brokerage.
Communication Channels
Communication between you and the advisor regarding advice and brokerage of financial investments can take place in person, by mail, telephone, email or via social media channels and messaging services (e.g., WhatsApp, Signal, Twitter, SMS, etc.). Refer to the existing Privacy Policy Page for more information about how your data is .
Recording of Telephone Conversations and Electronic Communications (According to Section 18a of the German Financial Investment Brokerage Ordinance – FinVermV), the advisor is obligated to record all content of telephone conversations and electronic communications (e.g. email) with you as soon as they relate to the advice or brokerage of financial investments. It is irrelevant whether the conversation was initiated by you or the advisor. The recording must include, in particular, the parts in which the offered investment advice or brokerage, the risks, the return opportunities, or the structure of specific financial investments or types of financial investments are discussed. The recording obligation also applies if the telephone conversation or electronic communication does not lead to the conclusion of such a transaction. A copy of the recordings of these conversations and communications will be made available to you upon request for a period of 10 years. You have the right to object to the recording at any time. If you do so, however, the advisor may not provide you with investment advice or brokerage services initiated by telephone or electronic communication. In this case, communication is limited exclusively to the communication channels to which you have given your consent. Communication with the advisor in person or by mail is always possible.
Disclosure of Conflicts of Interest
Unfortunately, conflicts of interest cannot always be avoided when providing investment advice and brokerage services. Therefore, to protect you, the advisor has implemented organizational measures to manage conflicts of interest, which we would like to inform you about below.
Conflicts of interest can exist between the advisor/their employees and clients, as well as between clients themselves.
Conflicts of interest can arise in particular:
- From the advisor’s own sales interest in the sale of financial investments (especially in investment advice or any proprietary products)
- When multiple client orders coincide
- From receiving or granting benefits (e.g., sales commissions/ongoing commissions/other benefits in kind) from or to third parties in connection with investment advice or brokerage for the client
- Through performance-based compensation of employees and advisors
- Through obtaining information that is not publicly available (insider information)
- From private investment transactions by employees and advisor
- From relationships with issuers or clients
- From dual roles for product partners and clients
Conflicts of interest can lead to the advisor not acting in the client’s best interests. This can potentially result in a financial disadvantage for the client. To prevent extraneous interests from influencing investment advice or brokerage, the advisor is directly responsible for identifying, avoiding, and managing conflicts of interest.
Specifically, the following measures, among others, are being undertaken to minimize the underlying conflict of interest:
| Nature of conflict of interest | Measure(s) to counter the conflict of interest |
| Own sales interest in investment products | . Creation of organizational procedures to safeguard client interests in investment advice . Refraining from sales targets, software-supported advice to consider client information . Regular training |
| Concurrent client orders | Processing client orders in the order of their receipt |
| Incentives from or to third parties | . Establishment and monitoring of regulations for the acceptance/granting of incentives . Ex ante and ex post cost disclosure to the client . Receipt and granting of incentives from and to third parties only on the condition that they do not conflict with the client’s interests |
| Performance-based compensation | . No performance-based compensation . Establishment and monitoring of appropriate compensation systems for employees |
| Obtention of non-public or insider information | . Establishment of information barriers . Regular monitoring of customer and employee ongoing business affairs. |
| Relationship with product providers | . Monitoring of the conformity of product terms with current market conditions . Monitoring of customer and employee ongoing business affairs . Establishment of information barriers |
| Dual roles for product partners and customers | . Establishment of information barriers . Monitoring of customer and employee ongoing business affairs . Monitoring of the conformity of product terms with current market conditions |
Despite the measures outlined to alleviate conflicts of interest, it cannot be guaranteed that your interests will be protected in every case. Furthermore, there are instances where the measures taken are insufficient to reasonably ensure that the risk of impairing customer interests is avoided.
Dr. Christian Saba would like to draw your attention in particular to the following points:
When distributing financial investments, the advisor receives industry-standard paid compensation from third parties, as described above. Further information can also be found in the ex-ante and ex-post cost statements. Detailed information on any payments received or made can also be obtained from your advisor upon request. In addition, the advisor and their related agents receive standard, non-monetary perks in the form of sales and informational materials, participation in conferences, seminars, and other training events, hospitality as part of customary networking, and technical services and equipment for accessing third-party information and distribution systems.
Further information on the principles in force for managing conflicts of interest is available upon request.
Dr. Christian Saba’s aim is always to provide you with high-performing insurance coverage and investment products tailored to your needs. Should any errors occur despite our best efforts, please get in touch with us.
Should you ever be dissatisfied with the services provided by Dr. Christian Saba, you have the option to contact the following out-of-court dispute resolution bodies:
Insurance Ombudsman Association
P.O. Box 080 632, 10006 Berlin
E-mail: beschwerde@versicherungsombudsmann.de
Ombudsman for Private Health and Long-Term Care Insurance
P.O. Box 06 02 22, 10052 Berlin
E-mail: ombudsmann@pkv-ombudsmann.de
Alternative Dispute Resolution
If, in the exceptional case of a complaint, an amicable solution cannot be reached with you, Dr. Christian Saba is prepared to participate in dispute resolution proceedings before a recognized consumer arbitration board; you have the option to then contact the following organization:
Arbitration Board for Commercial Insurance, Investment, and Credit Brokerage
Glockengießerwall 2, 20095 Hamburg
E-mail: kontakt@schlichtung-finanberatung.de
Additional addresses of arbitration boards and options for out-of-court dispute resolution can be obtained from the Federal Financial Supervisory Authority (BaFin), Graurheindorfer Strasse 108, 53117 Bonn (www.bafin.de)
Legal Basis for Liability
The evaluations, analyses, and recommendations provided by Dr. Christian Saba are based on the documents provided by the interested party. Dr. Christian Saba expressly points out that incomplete or missing information or documents may lead to errors, for which it assumes no liability. The advice is based on the tax and legal regulations and ordinances in effect on the date of the consultation. No liability can be accepted for future changes in jurisprudence, tax legislation or their application in administration and the associated deviations from the statements made by the undersigned.
