Bovill EIS bite-sized bash
Transcript of Bovill EIS bite-sized bash
The EIS bash Regulation, but bite-sized
Gillian , Richard, Tracy & Laura
Caught up in AIFMD
Alternative Investment Fund Managers Directive
• EIS caught in the nets
• Trend is to be a “small authorised” AIFM
• The big decision: an EIS AIF or a bespoke portfolio
Fund vs Bespoke Portfolio
Fund Bespoke portfolio
One strategy Client specific decisions
Product Service
Managing an AIF Managing Investments
Appropriateness Suitability
AIFMD MiFID
Marketing, marketing, marketing
Spotted!
EIS marketing under scrutiny
plus
• Changes post AIFMD
• NMPIs Non mainstream pooled investments
» Ordinary retail vs HNWI & Sophisticated
• DOFPs Direct offer financial promotions
Direct Offer Financial Promotions
• Retail welcome: 10% or advised sales
• Appropriateness test for non advised
• Applies to ‘non readily realisable securities’
• Remember! Not all marketing material is caught
Supervision more visible
• Financial promotions
• Mystery shopping
• FCA interviews
Emerging theme: ‘conduct risk’
• Moving beyond rules
• Lots of onus, little direction
• Good and poor outcomes
New style reporting
Annex IV
Reporting on AIFs and AIFMs
XML or Gabriel option
Not designed with EIS in mind
CoRep
Capital Adequacy for “IFPRU” firms
XBRL
Risk weighted balance sheet
New rules imminent…
Social media
• Retail rules - tough in small spaces
• #ad
• Use of images
• Sharing & retweeting
How not to use images in Twitter
New rules imminent…
Advised vs non-advised models
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Suitability
Advice
permissions
Guidance tools
Simplified,
Focused
or
Full Advice
Our predictions
Industry Regulation
Social investment & SITR
HNWI limit rise: delayed
EIS moving online
Build up to MiFID II Markets in Financial Instruments Directive
More EuVECAs
Focus on transparent charges
Your to do list
EIS Fund managers
• Only 2 weeks to Annex IV deadline
• Dust off procedures
• Remember to register any new funds
EIS bespoke portfolio managers
• Get MiFID II on your radar
• Check your suitability practices
All
• Put conduct risk on your board’s agenda