Compliance Consultancy

Sturgeon Ventures LLP is authorised and regulated by the FSA. The firm is made up of 5 divisions; the Corporate Finance Division, the Investment Management Division, the Fund Capital Introduction division (set up January 09), the Regulatory Incubation Division and the Compliance Consulting Division, often two divisions work together on certain projects. We also have a Headhunting and Business Development business which falls outside of the regulated work.

Regulatory Incubation Benefits
Benefit of trading under umbrella, no capital to put up to the FSA, no financial returns, time to prove your concept works, time to get relevant experience or exams in place, so that we can sign off your competency. Introductions to invaluable other services to help smooth the path, still a level of independence and time to build your brand.
Please contact us for a meeting and to discuss fees on info@sturgeonventures.com

Regulatory Incubation Division
First option – Option 1

Incubation is conducted under the regulatory “umbrella” of Sturgeon Ventures LLP, and the applicant firm becomes an Appointed Representative of Sturgeon Ventures LLP. The monthly fee is a set rate each month for up to three** people (see below for more people) operating under the umbrella as Appointed Representatives.

The monthly compliance monitoring fee whilst operating under the umbrella is an additional set rate. The compliance fee includes the full authorisation process instigated at a time deemed by both parties as correct. Normal Authorisation is Charged if not included, depending on complexity. (an annual FSA fee per approved person for investment advisors known as Periodic Fees charged to us by the FSA and passed on to you if you are on our books through Dec 30th each year) you pay this directly to the FSA when independently authorised.

The minimum umbrella period is usually 6 months, special sits are available
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Second option (favourite option for start-ups) – Option 2

Monthly umbrella fee is set fee a month (for up to three people as above) plus compliance monitoring at a lower rate than Option 1 a month whilst operating under the umbrella.

Under this option, the FSA authorisation process fee is a fixed fee depending on complexity of application agreed at time of engagement, for a Part IV application for an investment management firm or an energy market participant firm or a full corporate finance firm, or for arrangers – introducers, or corporate finance firm; made at the time deemed by Sturgeon Ventures and the client to be appropriate. This fixed fee is to be paid in two instalments: half at the start of the process and half upon authorisation.
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Third option – Option 3 –
(Introduced by “Another compliance consultancy/lawyer” who has already agreed to carry out Part IV Authorisation application)

NOTE: (This option is used for firms who have been introduced to us by other compliance consultancies). The other consultancies will prepare the Part IV Authorisation for the FSA and potentially the on-going compliance

Monthly umbrella is a set monthly charge (for up to three people in the umbrella as above) plus compliance at a set monthly rate whilst operating under the umbrella, min contract time is three months; we work with the compliance consultancy/lawyer doing the application. If you are on our books through December 30th of any year, you will be liable for the approved persons fee**, billed to us in June, even if you have by then left the umbrella. You will then be billed as an independent company the following year, this will be initialled in the contract as this is an important obligation.

Under this option a third party will do the FSA Authorisation for you. This is the case if you have been introduced to us by a third party purely for the time whilst under the umbrella. You may during the authorisation period still need as to act as a Locum for you, for the authorisation to occur this is a further set fee a month invoiced once the Authorisation is submitted to the FSA.

We like our umbrella clients to stay with us for ongoing monitoring, if you have used another compliance consultant for the Authorisation itself, and they introduced us to you, you may wish them to do the ongoing monitoring. If that is the case they will do your compliance manual as part of their ongoing monitoring when you leave the umbrella, as you will no longer be able to use ours.
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IMPORTANT NOTICE FOR ALL REGULATORY UMBRELLA CLIENTS:

Our fees are as above only on the basis that Regulatory Umbrella Clients of Option 1&2, agree at the time of the contact initiation to use at all 3 parts, the umbrella, the authorisation, and the ongoing compliance, option 3 is only the umbrella.

For either option 1 or 2 above, the minimum term of compliance contract commitment after authorisation is 2 years for quarterly visits and 12 months for monthly visits, thereafter subject to a 3 month written notice period.
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We also offer a Locum Service – a Locum Investment Manager at a set fee per month, or slightly less per month for an Investment Advisor. Appropriate persons are seconded by Sturgeon Ventures LLP. Many other compliance advisory firms use us for this service, we are well known to the FSA. If you are going to use our locum for your application with the FSA, you are billed from the day the application is sent into the FSA, as they are approving the firm on the basis we are part of it. No new, authorisation, will be accepted with only one authorised person, we have the FSA evidence for this if you need it. If you need two fund managers, whilst you train your internal staff, this is particularly useful for those setting up investment management firms from overseas, who do not know the UK regulatory environment.

We will issue invoices on a monthly basis, and for regular payments we prefer a standing order to be set up.

****LOCUMS minimum contract for a locum for a new authorisation is 6 months, for others on the team to gain competency in accordance with the FSA’s best practice for competency.

CAPITAL INTRODUCTION TEAM
We have a Capital Introduction Team, which will take on new funds subject to a meeting and due diligence process, but have to already be signed up as an incubatee. We do not fund raise for all incubatees.

COMPLIANCE DIVISION
“BELUGA”
Firm visited monthly or time in our offices available 12/5 all queries, contracted for 1 year minimum – 3 months written notice

Retained full compliance advisory service fee is set plus VAT per month, providing for up to two half day visits a month and/or offsite work as and when needed if in London, travelling expenses will be added if outside of London. This will include all Form A work, Variation of Permission, liaising with the FSA, a quarterly compliance monitoring report, training and competence reviews, anti-money laundering annual training, PA trading monitoring, financial promotion reviews, and keeping up to date on all applicable regulatory changes.

NOTE: We do not prepare or take responsibility for client firm’s quarterly or annual financial returns and CRD (capital requirements) for the full authorisation, but can recommend suitable accountants/advisory firms for that purpose with competitive fees.

“OSCIETRA”
Firm is visited every quarter (4 on site-visits per year set rate per visit and report) minimum contract is 1 year

“SEVRUGA”
Firm is visited every 6 months (2 on site visits, and a hi-level monitoring report) min contract is 1 year

NOTE: that the quarterly meetings do not include ongoing compliance support away from the quarterly meeting.
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“HEALTH CHECK”

We will conduct “Health Checks” on a daily/weekly rate dependent on level of work required, For example a morning/half day visit is a set rate.

We offer discounted rates for a regular quarterly meeting, with report, for a quarter or bi-annual, for a min engagement 2 visits a year in London, out of London travelling expenses will be added.

We also do compliance training for brand new authorised firms, who may have done the authorisation themselves, but need a manual, and compliance forms, and a monitoring program to run internally, quote further to a discussion.

“Health Checks” can review items such as the following (list not exhaustive and will be tailored according to a Firm’s requirements and activities). We also run “Legal Health Checks” in conjunction with a panel of lawyers depending on your needs and location, to review your Engagement Letters, Client Agreements, Policies, Terms of Business, employment Contracts, very important to review in conjunction with an ever changing regulatory environment.

Firm’s procedures can be reviewed (compliance manual, anti-money laundering procedures, client take on procedures, company procedures manual).
Policies, such as Conflict of Interest, Corporate Responsibility, Best Execution, Treat the Customers Fairly – Policies and Procedures
Personal Account Dealing
Financial Promotions including a website, that correct disclaimers are in place
Approved Persons Register
Breaches Register
Senior Management Arrangement
Training & Competency logs
Risk Maps
Quarterly Compliance Monitoring Reports
Management Information/ongoing business plans
Complaints
Human resource procedures – new employees in line with FSA requirements

When a review is completed, we will issue a report and if necessary corrective action, will be recommended. Further visits can then be planned to review that recommendations have been carried out
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One off Projects

Sample Bespoke work – typical fees

Form A (per form)             £750 - £1000 plus VAT (+ we collate references, and                                       all HR docs prior to submission)
Variation of Permission     £5,000+ plus VAT depending on complexity
New Authorisation            £8,000 - £15,000 plus VAT
Change of Control             £10,000 plus VAT
Change of legal Entity       £7,000 plus VAT
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TRAINING
We will run in-house training sessions on -
Data Protection
Anti-Money Laundering
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Other Information:

http://www.fsa.gov.uk/smallfirms/index.shtml
The above link may be useful as a new firm about to work within the rules of the FSA.




Contact us by email info@sturgeonventures.com
Sturgeon Ventures LLP is Authorised and Regulated with the Financial Services Authority
FRN # 452811

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