LEGAL AND COMPLIANCE
HFMC Wealth Asset Management Ltd – Authorised and Regulated by the Financial Conduct Authority with entry number 194722 on the FCA register – Incorporated in England & Wales as Limited Company, Registered Number 03891979.
Registered Address for HFMC Asset Management Ltd is Russell House, 140 High Street, Edgware, Middlesex, HA8 7LW.
The content of this website does not constitute financial advice and is provided for general information purposes only and should not be relied upon when making financial decisions at the expense of obtaining professional advice.
The information contained within this website is based on the UK regulatory regime and is therefore restricted to consumers based in the UK.
Please note that the FCA does not regulate tax, trusts, National Savings, estate planning or cashflow modelling.
Whilst HFMC Asset Management Ltd uses reasonable care to ensure the information and material appearing on this website is accurate and up-to-date, we cannot guarantee that it is comprehensive or up-to-date at all times.
Errors and omissions may occur, and the user should not take the accuracy of the information and material for granted or rely upon it as a statement or representation of fact. If users are in any doubt, they should check directly with HFMC Asset Management Ltd.
The information and material on all of the pages of this website is provided as a general illustration of HFMC Asset Management Ltd and the services it offers. The information and material contained herein is not intended to and neither does it create any business, contractual or employment relationship and neither is it supplied for any other purpose not explicitly stated.
HFMC Asset Management Ltd has no control over the use to which the information and material provided on all of the pages of this website may be put by the user.
Access to the HFMC Asset Management Ltd website is solely at the user’s risk and accordingly HFMC Asset Management Ltd, its principals, employees, or agents, shall not be liable for any loss of profits or contracts or any other indirect or consequential loss or damage arising out of or in connection with the use of such information and material or of its access on this website whether by corruption, virus or otherwise.
HFMC Asset Management Ltd EXPRESSLY DISCLAIMS ANY AND ALL GUARANTEES OF ANY KIND, WHETHER EXPRESS OR IMPLIED, INCLUDING ANY GUARANTEE OF FITNESS OF THE INFORMATION OR MATERIAL FOR A PARTICULAR PURPOSE.
The HFMC Asset Management Ltd website including the content of the pages is subject to English law.
Ownership of the content of this website and restriction of use
The entire content of our website is protected by copyright laws and intellectual property rights. You may download and use information and material from our website for your personal use. However you may not copy, reproduce, distribute or modify the content of our website for commercial or public use without prior written consent from us.
You should not rely solely on the information on our website.
We are committed to dealing with complaints effectively and fairly in accordance with the Financial Conduct Authority’s complaint handling rules and guidance. If our clients have cause to complain, it will be dealt with by a dedicated team focused on ensuring that clients are treated fairly during the process. You may complain to us by writing or telephoning at the address and telephone numbers detailed in this website.
If our clients are not satisfied with the outcome of their complaint, they will have the right to refer it to the Financial Ombudsman Service, free of charge, at The Financial Ombudsman Service Exchange Tower, London E14 9SR, or by going to their website www.financial-ombudsman.org.uk.
Accuracy of information
Whilst all reasonable steps have been taken to ensure that the information contained on our website is accurate and complete at the date of publication, no warranty or guarantee is given, and no liability is accepted for any loss incurred. Errors or omissions in the information may occur because of a number of factors which are inherent in any Internet access system and are not within our control. The information contained in this website is subject to change without notice.
HFMC Asset Management Ltd, and any of our affiliates, officers, directors, employees, or agents provide the website and the information on an “as is” basis. We (and they) do not make any express or implied warranties, representations, endorsements, or conditions with respect to the website or the information. This includes, without limitation, warranties as to operation, non-infringement, usefulness, completeness, accuracy, currency, reliability and fitness for a particular purpose.
Any links on this website that lead to sites maintained by third parties, over which we have no control, are provided solely as a convenience to users and use of those sites will be at your own risk.
HFMC Asset Management Pillar 2 Disclosure
HFMC Asset Management Ltd (‘the firm’) is required by the Financial Conduct Authority (FCA) to disclose information relating to the capital it holds and each category of material risk it faces to assist users of its accounts and to encourage market discipline. These disclosures aim to provide information on the risk exposures faced by the firm and the risk assessment process it has in place to monitor these. Known as Pillar 3 disclosures, they are required to be made under Chapter 11 of the Financial Conduct Authority’s Prudential Sourcebook for Investment Firms (BIPRU) and is complimentary to the firm’s Internal Capital and Risk Assessment (ICARA).
The Pillar 3 disclosure document has been prepared by the firm in accordance with the requirements of BIPRU 11. Unless otherwise stated, all figures are as at the 5 April 2022 financial year-end.
The board will issue Pillar 3 disclosures on an annual basis after the year-end and will publish it with the annual accounts or directly to the firm’s website.
The firm has a risk management process in place to ensure that it has effective systems and controls to identify, monitor and manage risks arising in the business. The firm’s senior management review the process regularly to enhance it as required.
The firm’s board of directors take overall responsibility for the risk management process and for setting its risk appetite; its Compliance Officer is responsible for the implementation and enforcement of the firm’s risk principles. The firm will take appropriate action if any risks it identifies falls outside of the tolerance for risk or if it identifies weakness in mitigating controls.
The board meets regularly to review compliance and operational matters and to assess management accounts that demonstrate the adequacy of the firm’s regulatory capital.
The board has identified specific risks applicable to the firm as business, operational, credit, market and liquidity.
The firm faces a risk to its revenue from a decline in assets under management that would arise from a sharp fall in markets for a protracted period and from a loss of client assets to which poor portfolio returns might contribute.
To mitigate our business risk, we regularly analyse various economic scenarios to model the impact of economic downturns on our financial position, and have a focus on smoothing volatility in portfolios.
The firm faces risks which might arise in relation to its administration and trading on systems, third party providers, people, technology, business process and data management.
The firm has established operational procedures and controls to reduce the potential risks; the board regularly review the robustness of these procedures and those of its counterparties. The firm’s senior management undertakes a full risk assessment at least annually. While the primary focus is on mitigating risk the firm does hold professional indemnity insurance to protect against any losses that may arise as well as key man insurance.
The main credit risk to which the firm is exposed is in respect of the investment management fees it collects, which constitute the majority of debtors, and on the cash it holds on deposit.
There is mitigation in that the fees are debited to client portfolios and that the firm’s bank accounts are held with large international credit institutions. There has been no history of bad debts.
While the firm faces an indirect risk from markets given the potential impact on client portfolios it does not hold any client assets nor any trading positions. The firm’s collection of fees in Sterling minimises foreign exchange risk.
The firm manages all cash and borrowing requirements to maximise potential interest income whilst ensuring the firm has sufficient liquid resources to meet the continued operating needs of the business. This is supported by a robust budgeting and forecasting process which has the full involvement of the senior management team.
As at 5 April 2022 the firm held own funds of £204,024.
As at 5 April 2022 the firm’s capital requirement was £119,000 as the greater of its estimated wind-down costs and its fixed overheads requirement (FOR) of £119,000.
The FOR is based on annual expenses and no allowable deductions were made from this total for the purposes of its calculation. The firm will monitor its expenditure on a quarterly basis and take into account any material fluctuations so as to determine whether the FOR remains appropriate to the size and nature of the business or whether it would need to make an intra-year adjustment. The board reviews the capital adequacy position on a quarterly basis. The firm has further reviewed the costs to wind down the business and will continue to evaluate the position.
Satisfaction of capital requirements
The firm holds capital over this requirement. In managing its capital, the firm considers the variety of requirements and expectations; it will retain sufficient capital to support its current and projected business activities, in accordance with both the firm’s own internal assessment and the requirements of its regulator.
PILLAR 3 REMUNERATION CODE STATEMENT for year ending 5 April 2022
Scope and application of the requirements
BIPRU 11.5 sets out the disclosure requirements in relation to the remuneration of code staff with which all firms regulated by the Financial Conduct Authority (FCA) are required to comply. The firm is a Tier 4 firm and the following disclosures are intended to satisfy fully the requirements of the Remuneration Code (‘the Code’).
Disclosure of compliance with the Code
The firm has in place internal policies, practices and procedures consistent with the FCA’s rules and regulations for Tier 4 firms. The remuneration committee fully acknowledge their responsibilities under the Code. They acknowledge their overriding responsibility to ensure that the firm’s remuneration and dividend policies, practices and procedures are:
- in line with the business strategy, objectives and long-term interests and values of the firm;
- consistent with and promote sound and effective risk management and do not encourage risk-taking that exceeds the firm’s level of tolerated risk;
- appropriate to attract, motivate and retain suitable staff;
- representative of the underlying performance of the business and do not reward individuals for poor performance; and
- inclusive of measures to avoid conflicts of interest.
The following disclosures have been made in accordance with the FCA rules and regulations as outlined under BIPRU 11.5.18 and SYSC 19A, specifically in the context of the firm’s obligations under the Code.
As permitted by the Code, the firm has adopted the FCA’s proportionality approach for Tier 4 firms in applying the requirements of the Code. All decisions in relation to the remuneration of Code staff are made and by its remuneration committee, with no input from external consultants. Remuneration is determined with reference to several factors including, but not limited to, the performance of the individual, the firm and the individual’s adherence to the Company’s risk management and compliance procedures.
Variable remuneration which is paid in the form of bonuses is rewarded after full consideration of these factors, together with an assessment of any current or potential risks to the business in the context of these payments. No element of variable remuneration is linked to the performance of underlying investment portfolios.
The firm’s Code staff, received aggregate remuneration of £204,123.