AlTi RE Limited

Limits on the record

• This firm may handle your money in passing but must not hold it, so payments should go to the product provider, never to a personal account.
• No new business

  1. The Firm must not, without prior written consent of the FCA: a. where the Firm acts as Alternative Investment Fund Manager (‘AIFM’), for or on behalf of any fund, accept any new investors or accept any additional investor capital; b. establish, become the AIFM of, or take on the management of any funds; c. seek to act as a regulatory Principal (except for the existing Appointed Representatives) nor appoint any new Appointed Representatives; d. appoint or act as an investment manager for, or on behalf of, any AIFM or fund; e. appoint or act as an ‘arranger’, or deal as an agent, for any new business (including both regulated and unregulated); f. provide investment advice, or provide investment management services, to transaction entities; or g. must not increase the amount of the existing debt or equity when refinancing or renewing deals, save for where there is a need for additional capital in order to protect existing investors’ interests.

• Assets requirement

  1. The Firm must not, other than in the ordinary course of business or without the prior written consent of the Authority, in any way dispose of, withdraw, transfer, deal with or diminish the value of any of its own assets (whether in the United Kingdom or elsewhere). 2. The firm must not terminate its existing Appointed Representative agreements without the prior written consent of the Authority. 3. The assets requirement does not apply to monetary payments, or the disposal of assets made by the Firm in the ordinary course of business. For the purposes of paragraph 2, the Authority considers that the following would be in the ordinary course of business: a. transactions giving effect to instructions initiated by clients of the Firm, other than any clients that are also the Firm’s controllers, members, officers or employees; b. payments of funds to the Firm’s suppliers or other third parties in satisfaction of the Firm’s contractual and/or legal obligations (including but not limited to payments of or on account of professional fees or expenses, including but not limited to legal, compliance and/or other professional fees or expenses of any professionals or consultants appointed by the Firm to advise in connection with its restructuring/wind down or otherwise); c. usual and proper salary payments made by the Firm; and d. the transfer or disposal of any of the Firm’s or its fund’s investment management agreements to any third party, provided that (a) the Firm gives the Authority no less than five working days’ prior written notice of any such transfer or disposal, such notice to include details of the investment management agreements to be transferred or disposed and the details of any counterparty, and (b) the Authority provides its written consent to the Firm for such a disposal. 4. For the purposes of paragraph 2, the Authority considers that the following payments would not be regarded as payments made in the ordinary course of business: a. payments of unusual or significant amounts to the Firm’s controllers, members, officers, employees or any connected persons (which shall include any management or performance fees); b. the making of any capital distribution; and c. the making of any gift or loan by the Firm to any party.

• Reporting requirements

  1. The Firm must provide the Authority with 5 working days’ notice that it is required to re-finance an existing debt deal or raise capital for an existing deal (as outlined in Requirement 1.g of the No new business requirement) and provide details of such including how the any additional capital is required to protect existing investors’ interests, before beginning re-financing or capital raising.