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The Trustee Invoice Health Check

Wealth Protection & Family Structures

How to spot hidden charges, challenge misaligned billing, and use the complaint route properly

Money stress is not just about the numbers. It is about the not knowing. When invoices are unclear, you cannot plan, you cannot compare, and you cannot feel in control.

This article gives you a practical, step-by-step health check for trustee invoices, including FATCA/CRS costs, compliance reviews, and exit fees. It also explains what to do if you believe you are being charged outside your agreed terms.

Step 1: Get the three documents that matter

Before you analyse anything, gather:

  • your engagement letter or service agreement,
  • the terms and conditions and any fee schedule,
  • the invoice and any supporting breakdown.

If your provider cannot produce a clear fee schedule, that is your first red flag.

Odin’s approach is simple: the pricing and downloadable fee schedules are publicly available, because clients should not have to ask for basic clarity.

Step 2: Categorise every line item into one of six buckets

Put every invoice line into one of these categories:

  1. Annual responsibility fee (governance and role)
  2. Time-based admin (work done)
  3. Disbursements (third-party and government costs)
  4. Compliance reporting (FATCA/CRS and similar)
  5. Compliance reviews (file refresh and annual review)
  6. Exit/transfer/storage (leaving, handover, archiving)

If a line item does not fit, query it

Step 3: The “where is this in the terms?” question

For each bucket, ask one question:

Show me where this charge is set out in the terms, or agreed in writing.

A transparent provider will not be threatened by that question, they will welcome it.

Odin’s published schedule, for example, sets out the logic behind time charging, minimum time units, and charge-out ranges. That is the standard you should expect.

Step 4: Time charges: check the three common problem areas

Time-based billing can be fair, but only if it is controlled.

Check:

  • Minimum time charge: is each small task rounded up? (Some models have a 15-minute minimum per activity.)
  • Who is doing the work: are senior rates used for routine admin?
  • Urgency uplift: if higher rates apply, were they agreed in advance?

If the invoice shows a pattern of “tiny tasks” billed at chunky minimums, ask for a summary of time entries, and ask how work is allocated between team members.

Step 5: FATCA/CRS: are you paying twice?

Here is the cleanest way to check:

  • Is there a fee for submission (a disbursement)?
  • Is there additional time billed for preparation?

That can be correct, but it must be explicit. Odin’s pricing states that the FATCA/CRS fee is the submission disbursement and that preparation time is charged separately. If your invoice does not separate these, ask for the split.

Also ask:

  • Was a report actually required this period?
  • Was it a nil return?
  • Did anything change in the structure that justified extra work?

Step 6: Compliance reviews and client file refresh, what should you get?

If you are paying for a compliance review, you should understand what outcomes it produces.

At a minimum, you should be able to ask:

  • what was reviewed,
  • what was updated,
  • whether the risk rating changed,
  • whether any remedial actions were needed.

If you are repeatedly being asked for the same documents, without explanation, that is not just frustrating, it is inefficient, and you should challenge the cost. Odin’s schedule states that annual compliance reviews are time-based, which makes clarity on scope even more important.

Step 7: Exit fees and transfer fees, confirm them before you move

This is where clients often feel trapped.

Check whether your provider charges for:

  • scanning documents,
  • storage (electronic or physical),
  • retrieval of files,
  • transfer to new trustees or a new provider, including minimum transfer fees.

Even when fees are legitimate, they should never be sprung on you at the point you are already stressed and trying to change provider.

If you believe fees do not align, here is the escalation route

Start calm, and stay factual:

  1. write to the provider and clearly state you are raising a complaint,
  2. specify the lines you dispute and what resolution you want,
  3. request the supporting breakdown, or time entries, for those lines.

If you are dealing with a firm regulated by the Isle of Man Financial Services Authority, the Authority’s consumer guidance encourages complaining to the regulated entity first, then referring to the Isle of Man Financial Services Ombudsman Scheme if you remain unhappy with the response, or your complaint is rejected.

You are entitled to complain. You are entitled to clarity. You are entitled to say, “This is not acceptable”.

Call to action

If you are reading this and thinking, “I have been putting up with this for too long”, you probably have.

Compare your current provider’s fee transparency with Odin’s published approach and pricing schedules.
Want to discuss your situation? Email rowen@odinfiduciaries.com