Legal and Compliance

Legal & Compliance

HFM Columbus Partners LLP is authorised and regulated by the Financial Conduct Authority with entry number 427640 on the FCA register.

HFM Columbus Wealth Management Ltd is authorised and regulated by the Financial Conduct Authority with entry number 146717

HFM Columbus Asset Management Ltd is authorised and regulated by the Financial Conduct Authority with entry number 194722 on the FCA register.

The registered address of all HFM Columbus companies 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.

HFM Columbus uses reasonable care to make sure that the information and material appearing on this website is accurate and up-to-date.

However, 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 HFM Columbus.

The information and material on all of the pages of this website is provided as a general illustration of HFM Columbus 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.

HFM Columbus 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 HFM Columbus website is solely at the user’s risk and accordingly HFM Columbus, 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.

HFM Columbus 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 HFM Columbus website including the content of the pages is subject to English law.

 

HFM Columbus Asset Management Ltd

Pillar 3 and Remuneration Disclosure

Scope and application of Directive requirements

The disclosures in this document are made in respect of HFM Columbus Asset Management Ltd which provides discretionary investment management services.

The firm is a limited licenced firm as defined by the FCA.

Risk management objectives and policies

Our risk management policy reflects the FCA requirement that we must manage a number of different categories of risk. These include: liquidity, credit, market, interest rate, business and operational risks.

i. Liquidity 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.

ii. Credit risk

The main credit risk for the firm relates to fees due for discretionary management services, being the risk that a client does not pay amounts due for services provided. This risk is mitigated by the high number of clients in respect of which amounts are due at any one time. The risk of non payment is also reduced due to the nature of the clients as they i.e. they are typically wealthy individuals.

The firm’s revenues also include annual management charges received from clients based on a percentage of client assets under management. These charges are made directly to the clients’ portfolios and therefore the credit risk relating to this income is minimal.

iii. Market Risk

The firm is indirectly subject to market risk as a significant element of income is dependent upon the value of client funds under management. This risk is mitigated by the asset allocation strategy adopted, which ensures that clients have highly diversified portfolios with limited exposure to any one asset class. Accordingly exposure to market risk is considered minimal.

iv. Interest rate risk

The firm has no borrowings and no exposure to interest rate risk.

v. Business Risk

The firm’s Pillar 2 business risk assessment principally takes the form of a fall in assets under management following a market downturn that leads to lower management fees, although other risks such as loss of investment managers and systems failures are also considered. To mitigate our business risk, we regularly analyse various different economic scenarios to model the impact of economic downturns on our financial position.

vi. Operational Risk

Operational risk is defined as the potential risk of financial loss or impairment to reputation resulting from inadequate or failed internal processes and systems, from the actions of people or from external events.

Major sources of operation risk include: outsourcing of operations, IT security, internal and external fraud, implementation of strategic change and regulatory non-compliance.

The firm operates a robust risk management process which is regularly reviewed and updated with details being provided to all staff. The firm’s Compliance Oversight is responsible for the periodic reviews and recommending any changes to the Board

All senior management will bear responsibility for internal controls and the management of business risk as part of their accountability to the board.

Individuals are responsible for identifying the risks surrounding their work, implementing controls over those risks and reporting areas of concern to their line manager.

The Compliance Oversight will provide the board with a half yearly summary report on all significant risk issues using a traffic light system – red (unacceptable), amber (watch list) and green (acceptable).

vii. Capital resources

Pillar 1 requirement

In accordance with GENPRU 2.1.45R (calculation of variable capital requirement for a BIPRU firm), our capital requirement has been determined as being €50,000 and not the sum of our credit risk capital requirement and our market risk capital requirement.

Pillar 2

Our overall approach to assessing the adequacy of our internal capital is set out in our Internal Capital Adequacy Assessment Process (ICAAP). The ICAAP process involves separate consideration of risks to our capital combined with stress testing using scenario analysis. The level of capital required to cover risks is a function of impact and probability. We assess impact by modelling the changes in our income and expenses caused by various potential risks over a 1-year time horizon. Probability is assessed subjectively.

In addition, we have reviewed the outputs of our risk reviews to quantify any risks identified. This has identified a number of key business risks which we have classified against the risk categories contained in GENPRU 1.2.30R and reviewed the guidance in BIPRU 2.2.61-65.

Our Pillar 2 capital requirement, which is our own assessment of the minimum amount of capital that we believe is adequate against the risks identified, has been assessed as no greater than our Pillar 1 requirement.

Other risks

The firm operates a very simple business model. Accordingly, many of the specific risks identified by the FSA do not apply.

Regulatory capital

The main features of HFM Columbus Asset Managements capital resources for regulatory purposes, as at 31/3/12 are as follows:

Capital item: £000s

Tier 1 capital (called up share capital, share premium account, profit and loss account, externally verified interim net profits) 88.843

Total of tier 2 and tier 3 capital (broadly long and short term subordinated loans) 0

Deductions from tier 1 and tier 2 capital 0

Total capital resources, net of deductions 88.843

The firm holds regulatory capital in accordance with the Capital Requirements Directive. All such capital is classified as Tier 1 capital and is therefore of the highest quality.

Remuneration Disclosure

All staff receive a fixed salary, which is reviewed each year.

Staff are not entitled to an annual bonus, but may receive discretionary bonuses. Any such bonuses are determined by reference to quantitative and qualitative assessment of performance.

Total remuneration paid to Investment Managers was £180,000.

 

 

 

 

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