Investment & Portfolio Consultants Limited Pillar 3 Disclosure and Policy for the period 1st July 2020 – 30th June 2021
The Pillar 3 disclosure of Investment & Portfolio Consultants Limited (“the Firm”) is set out
below as required by the FCA’s “Prudential Sourcebook for Banks, Building Societies and
Investment Firms” (BIPRU) specifically BIPRU 11.3.3 R. This is a requirement which stems
from the UK’s CRDIII implementing Regulations which represented the European Union’s
application of the Basel Capital Accord. The Firm is no longer formally subject to CRD but
remain subject to the UK’s implementation Regulations of CRD prior to CRDIV. The
regulatory aim of the disclosures is to improve market discipline.
The Firm will be making Pillar 3 disclosures at least annually. The disclosures will be as at
the Accounting Reference Date (“ARD”), 30th June.
Media and Location
A summary disclosure will be published on IPC’s website and the full disclosure will be
available on request from IPC’s Compliance Officer.
The information contained in this document has not been audited by the Firm’s external
auditors, as this is not a requirement, and does not constitute any form of financial
statement and must not be relied upon in making any judgement on the Firm.
The Firm regards information as material in disclosures if its omission or misstatement
could change or influence the assessment or decision of a user relying on that information
for the purpose of making economic decisions. If the Firm deems a certain disclosure to
be immaterial, it may be omitted from this Statement.
The Firm regards information as proprietary if sharing that information with the public
would undermine its competitive position. Proprietary information may include
information on products or systems which, if shared with competitors, would render the
Firm’s investments therein less valuable. Further, the Firm must regard information as
confidential if there are obligations to customers or other counterparty relationships
binding the Firm to confidentiality. In the event that any such information is omitted, we
shall disclose such and explain the grounds why it has not been disclosed.
The CRD, to which the Firm remains subject as a consequence of the UK CRDIII
implementing Regulations, have three pillars; Pillar 1 deals with minimum capital
requirements; Pillar 2 deals with Internal Capital Adequacy Assessment Process (“ICAAP”)
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undertaken by a firm and the Supervisory Review and Evaluation Process through which the
Firm and Regulator satisfy themselves on the adequacy of capital held by the Firm in relation
to the risks it faces and; Pillar 3 which deals with public disclosure of risk management
policies, capital resources and capital requirements.
The regulatory aim of the disclosure is to improve market discipline.
The Firm is a MiFID Investment Management Firm. It provides a number of investment
services including management, advice and brokerage. The Firm does not hold client money
or assets. The Firm’s greatest risks have been identified as business and operational risk.
The Firm is required to disclose its risk management objectives and policies for each
separate category of risk which include the strategies and processes to manage those risks;
the structure and organisation of the relevant risk management function or other
appropriate arrangement; the scope and nature of risk reporting and measurement systems;
and the policies for hedging and mitigating risk, and the strategies and processes for
monitoring the continuing effectiveness of hedges and mitigants.
The Firm has assessed business and operational risks in its ICAAP and set out appropriate
actions to manage them.
The Firm has an operational risk framework (described below) in place to mitigate
operational risk. The Firm’s main exposure to credit risk is the risk that fees cannot be
collected and as some fees are paid in advance or linked to transactions the risk of noncollection
is low. Therefore, the overall credit risk is considered low. The Firm holds all
cash and performance fee balances with banks assigned high credit ratings.
Market Risk exposure has been assessed by the Firm and is limited to the Firm’s exposure
to foreign currency exchange rate risk and hence to any assets held on the Firm’s Balance
Sheet denominated in a foreign currency. The Firms Reporting Currency is GBP and all
foreign currency assets are converted into GBP where possible on a regular basis.
Background to the Firm
The Firm is incorporated in the UK and is authorised and regulated by the FCA as a MiFID
Investment Management Firm. The Firm’s activities give it the BIPRU categorisation of a
Only Investment & Portfolio Consultants Limited is covered by the ICAAP as the Firm is
not a member of a UK Consolidation Group.
The Firm is a BIPRU Investment Firm without an Investment Firm Consolidation Waiver
deducting Material Holdings under (GENPRU 2 Annex 4).