Client Registration

To allow you to continue with your enquiry we need to categorise you.
You will be registered with us as one of these:

High Net Worth Individual
Sophisticated investor
High net worth company
Professional client
Elective professional investor

A High Net Worth Individual (“HNWI”) is exempt under article 48 of the FSMA 2000 if they had an annual income to the value of £100,000 or more throughout the financial year immediately preceding today's date and/or had net assets to the value of £250,000 or more throughout the financial year immediately preceding today's date. Net assets for these purposes do not include:

  • the property which is your primary residence or any money raised through a loan secured on that property;
  • any rights of yours under a qualifying contract of insurance; or
  • any benefits (in the form of pensions or otherwise) which are payable on the termination of your service or on your death or retirement and to which you are (or your dependants are), or may be, entitled.

By agreeing to be categorised as a HNWI, you agree to be communicated financial promotions of certain types of investments, principally: 


  1. Shares or stock in unlisted companies 

  2. Collective investment schemes, where the underlying investment is in unlisted 
company shares or stock 

  3. Options, futures and contracts for differences which relate to unlisted shares or 
stock. 


A certified sophisticated investor is an individual: 


  1. who has a written certificate signed within the last 36 months by a firm confirming he has been assessed by that firm as sufficiently knowledgeable to understand the risks associated with engaging in investment activity in non-mainstream pooled investments; and
  2. who has signed, within the period of twelve months ending with the day on which the communication is made, a statement in the following terms:

    SOPHISTICATED INVESTOR STATEMENT
    
I make this statement so that I can receive promotional communications which are exempt from the restriction on promotion of non-mainstream pooled investments. The exemption relates to certified sophisticated investors and I declare that I qualify as such. I accept that the investments to which the promotions will relate may expose me to a significant risk of losing all of the money or other property invested. I am aware that it is open to me to seek advice from an authorised person who specialises in advising on non-mainstream pooled investments.

High net worth companies are exempt under article 49 of the FSMA 2000 (Financial Promotion) Order 2005. This includes :

  1. any body corporate which has, or which is a member of the same group as an undertaking which has, a called-up share capital or net assets of not less than—
    1. if the body corporate has more than 20 members or is a subsidiary undertaking of an undertaking which has more than 20 members, £500,000; 

    2. otherwise, £5 million;
  2. any unincorporated association or partnership which has net assets of not 
less than £5 million;
  3. the trustee of a high value trust;
  4. any person (“A”) whilst acting in the capacity of director, officer or employee of a person (“B”) falling within any of subparagraphs (a) to (c) where A’s responsibilities, when acting in that capacity, involve him in B’s engaging in investment activity;
  5. any person to whom the communication may otherwise lawfully be made.

A Professional Client is a client who is not designated as a Retail Client as per the FCA Conduct of Business Handbook https://www.handbook.fca.org.uk/handbook/COBS/3/5.html


Each of the following is a Professional Client unless and to the extent it is an Eligible Counterparty or is given a different categorisation:

  1. an entity required to be authorised or regulated to operate in the financial markets. The following list includes all authorised entities carrying out the characteristic activities of the entities mentioned, whether authorised by an EEA State or a third country and whether or not authorised by reference to a directive:
    1. a credit institution;

    2. an investment firm;

    3. any other authorised or regulated financial institution; d) an insurance company;
    4. a collective investment scheme or the management company of such a scheme;
    5. a pension fund or the management company of a pension fund;
    6. a commodity or commodity derivatives dealer;
    7. a local; 

    8. any other institutional investor;
  2. in relation to MiFID or equivalent third country business a large undertaking meeting two of the following size requirements on a company basis:
    1. balance sheet total of EUR 20,000,000;
    2. net turnover of EUR 40,000,000;
    3. own funds of EUR 2,000,000;
  3. in relation to business that is not MiFID or equivalent third country business a large undertaking meeting any of the following conditions:
    1. a body corporate (including a limited liability partnership) which has (or any of whose holding companies or subsidiaries has) (or has had at any time during the previous two years) called up share capital or net assets of at least £5 million (or its equivalent in any other currency at the relevant time); 

    2. an undertaking that meets (or any of whose holding companies or subsidiaries meets) two of the following tests:
      1. a balance sheet total of EUR 12,500,000;
      2. a net turnover of EUR 25,000,000;
      3. an average number of employees during the year of 250;
    3. a partnership or unincorporated association which has (or has had at any time during the previous two years) net assets of at least £5 million (or its equivalent in any other currency at the relevant time) and calculated in the case of a limited partnership without deducting loans owing to any 
of the partners;
    4. a trustee of a trust (other than an occupational pension scheme, SSAS, 
personal pension scheme or stakeholder pension scheme) which has (or has had at any time during the previous two years) assets of at least £10 million (or its equivalent in any other currency at the relevant time) calculated by aggregating the value of the cash and designated investments forming part of the trust's assets, but before deducting its liabilities;
    5. a trustee of an occupational pension scheme or SSAS, or a trustee or operator of a personal pension scheme or stakeholder pension scheme where the scheme has (or has had at any time during the previous two years):
      1. at least 50 members; and
      2. assets under management of at least £10 million (or its equivalent in any other currency at the relevant time);
    6. a local authority or public authority.
  4. a national or regional government, a public body that manages public debt, a central bank, an international or supranational institution (such as the World Bank, the IMF, the ECB, the EIB) or another similar international organisation;
  5. another institutional investor whose main activity is to invest in financial instruments (in relation to the firm's MiFID or equivalent third country business) or designated investments (in relation to the firm's other business). This includes entities dedicated to the securitisation of assets or other financing transactions.

An Elective Professional Opt Up Client is a person ordinarily a “Retail” client who wishes to be treated as a “Professional” category client as per the FCA handbook COBs https://fshandbook.info/FS/print/FCA/COBS/3.

To enable us to categorise you as an Elective Professional Opt Up you will need to complete a questionnaire.

After this has been completed you must follow the instruction in the statement below.

The statement below details the rights and protections afforded to Retail investors that are lost when the client opts up to be designated as a Professional.

The statement below must be read and understood:

STATEMENT: Financial Conduct Authority (“FCA”) Classification

On the basis of information we have about you, or you have given us, and with reference to the rules of the FCA (see http://fshandbook.info/FS/html/FCA/COBS/3/5), we have categorised you as a Professional client by reason of your expertise, experience and knowledge in relation to investing in our financial products and other investment opportunities.

Please note that your categorisation as an elective Professional client applies only for the purpose of enabling us or our affiliates to promote financial products and investment opportunities to you and that you will not be treated as our client for any other purpose.

As a consequence of this categorisation, we are informing you that you will lose the protections afforded exclusively to Retail clients under the FCA rules. In particular:

  • communications and financial promotions made to you will not be subject to the detailed form and content requirements of the FCA’s rules, including those regarding costs and associated charges, that apply in the case of Retail clients;
  • when communicating with you, we are required to ensure that such communications are fair, clear and not misleading. However, we may take into consideration your status as a Professional client when complying with such requirements and in assessing whether any communication to you is likely to be understood by you and contains appropriate information for you to make an informed assessment of its subject matter; 

  • we will not be restricted from promoting financial products and investment opportunities which are not regulated in the UK and in doing so need not warn you further as regards the protections you will lose;
  • because participants in our financial products and investment opportunities are not (or will not on first participating be) Retail clients, we are able to agree with any fund investment that we do not owe a duty of best execution;
  • because participants in our financial products and investment opportunities are not Retail clients, the detailed FCA rules on periodic statements are disapplied. You will however still receive statements in accordance with the other constitutional documents;
  • in the event that we cease to provide investment advisory services, we are not required to ensure that any business which is outstanding is properly completed but we will nevertheless agree to do so; and
  • you will have no right of access to the UK’s Financial Ombudsman Service. 
Please read and sign the declaration below to confirm you have read and understand this written notice and wish to be treated as a Professional client. If you do not agree to the signing of this declaration, we are unable to conduct business with you in regard to the financial products and investment opportunities we wish to communicate and market to you.