Regulatory Incubation

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.


FSA Operator Functions
Sturgeon Ventures LLP is authorised to act as operator of unregulated collective investment schemes(CISs), those which are not themselves authorised by the UK Financial Service Authority (FSA) and therefore which cannot be promoted to the general population. Close ended companies, eg investment trusts are not CISs and therefore do not require an operator. A non-exhaustive list of those entities which do is UK Limited Partnerships and Limited Liability Partnerships, open-ended investment companies and unauthorised unit trusts.

Before unregulated CISs can be promoted, prior confirmation is needed of the high net worth or sophisticated investor status of the recipients, the requirements varying dependent on the type of investors and type of CIS involved.

SVs operator business falls into two categories as follows;

(i) A UK registered/constituted CIS where the manager/advisers to a CIS may not need or want to be regulated by the FSA, e.g. property fund or film finance investment. In those circumstances the CIS will require an operator who is FSA regulated to perform the operator function. In order for the operator to be seen to be "operating", the operator appoints the manager and other functionaries.

(ii) A UK registered/constituted CIS where the manager is regulated by the FSA but does not want to carry out the operator or other administrative functions for commercial reasons, such as financial promotion reviews of documentations, marketing presentation oversight. This includes private equity funds or private funds established in the UK with an equity/debt based profile (or any other investment activity which is an FSA regulated activity).

FSA Authorised UCITS Distributor for overseas funds with no UK presence


Please contact us for a meeting and to discuss fees on info@sturgeonventures.com

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. 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.

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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 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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TRAINING
UCIS - Financial Promotions Training offered

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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