Unregulated investment schemes posted Thursday, 8 April 2010
FSA are in the process of conducting a themed review of unregulated business, more particularly such things as EIS, VCTs and Film Partnerships, and we suggest firms should adopt the following process;-
Before an adviser discusses any aspect or feature of any unregulated investment or scheme with a retail client, he/she will need to firstly obtain a signed Self-Certified Sophisticated Investor or a Certified High Net Worth Individual statement from the client. This also applies to existing clients with whom an adviser may wish to discuss unregulated investments or schemes. Contact us if you need a copy of the relevant statements.
If a client's circumstances are such that neither statement can be signed, or the client for whatever reason chooses not to sign the form, an adviser cannot comment, advise or recommend any unregulated investment. This procedure also applies to introductions to external providers of unregulated products and/or schemes.
The impact of this is that firms cannot complete any type of unregulated investment business with retail clients, unless they fall within the exemptions as stated above. This also applies to VCT's, unless the provider confirms that their VCT is not classified as a UCIS.
Before an adviser discusses any aspect or feature of any unregulated investment or scheme with a retail client, he/she will need to firstly obtain a signed Self-Certified Sophisticated Investor or a Certified High Net Worth Individual statement from the client. This also applies to existing clients with whom an adviser may wish to discuss unregulated investments or schemes. Contact us if you need a copy of the relevant statements.
If a client's circumstances are such that neither statement can be signed, or the client for whatever reason chooses not to sign the form, an adviser cannot comment, advise or recommend any unregulated investment. This procedure also applies to introductions to external providers of unregulated products and/or schemes.
The impact of this is that firms cannot complete any type of unregulated investment business with retail clients, unless they fall within the exemptions as stated above. This also applies to VCT's, unless the provider confirms that their VCT is not classified as a UCIS.