Collective Portfolio Management

Collective portfolio management firms (CPMs) are involved in operating and managing funds on the AIF (Alternative investment funds) or UCITs (undertakings for collective investment in transferable securities) routes and come under scope of the respective EU-wide directives. Such fund managers may also undertake MiFID business such as discretionary portfolio management which brings them within the remits of MiFID as collective portfolio management investment firms (CPMIs).

Whilst setting up a fund can be a costly exercise and the regulatory burdens can be heavy, several smaller firms may choose to make use of a regulatory hosting platform to operate as an appointed representative of a principal firm and avoid being directly authorised for fund management activity. However, many decide to be directly authorised and regulated with full control of their activity. Brexit poses several imminent threats to fund managers who passport their services out of the UK and across the EU.

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Fund managers have to meet strict rules on financial promotions and more recently the FCA has been taking a closer look at fund liquidity risks. CPMIs that engage in MiFID business will be in scope of the new UK prudential regime for investment firms (IFPR) and will have to adopt to the new rules from January 2022 onwards. Our Consultants are experienced working with CPMs and CPMIs and supporting all regulatory, compliance, and risk functions. Speak to us for any compliance related matters and we will be glad to help.

How Pillar 4 Can Help

Authorisation

         Pro bono initial assessment of your authorisation aspirations and guidance on regulatory  permissions

         Full application support on a project managed basis from start to finish

         Guidance on navigating the FCA’s current approach to CPM activity including key concerns

         Support in formulating the right governance structure for your firm

         Staff skills and competency assessments

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IFPR implementation 

         Pro bono initial assessment of the impact of IFPR on your business

         Financial modelling and full implementation of the IFPR and shift from ICAAP to ICARA

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Risk management

         Developing integrated risk management, capital monitoring, and reporting tools

         Developing suitable pillar 2 approaches

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On-going compliance support

         Providing specialist advise

         Revamping compliance monitoring programmes to something practical and workable in  line with regulations

         Providing risk based on-going compliance monitoring and testing 

         Support in regulatory reporting and capital adequacy reporting