Equity For Growth (Securities) Limited

Limits on the record

• Corporate finance business only.

  The firm must not conduct designated investment business other than corporate finance business.

• Restriction on activities

  1. The Firm must immediately cease carrying on all regulated activities for which it has a Part 4A permission, other than where it has the express written consent of the Authority.

• Notification requirements

  2. The Firm must, by no later than 4 pm on 7 November 2024, (i) write to all its customers; and (ii) publish in a prominent place on its website and on all platforms upon which its customers are placed, informing each of them of the imposition of the Requirements and their effects, in a form and by a method of delivery each to be agreed in advance with the Authority; 3. Once the notifications referred to in sub-paragraph (2) above have been made, within 24 hours, the Firm must provide to the Authority: a) A list of all parties to whom notifications have been sent; and b) Confirmation that, to the best of its knowledge, the Firm has sent the specified notifications (in the form agreed with the Authority) to all relevant parties.

• Retention and notification requirements

  4. The Firm must secure all books and records and preserve all information, including material held via online/cloud-based systems to which the Firm has access, in relation to regulated activities carried on by it. These include but are not limited to all: a) Client lists; b) Communications with clients; and c) Financial records. These books, records and information must be retained in a form and at a location within the UK to be notified to the Authority within 24 hours of the receipt of this notice. The records must be retained in a form and at a location such that they can be provided to the Authority, or to a person named by the Authority, promptly upon its request.

• Asset requirement

  5. Save as set out in sub-paragraph (6) below, the Firm must not, without the prior written consent of the Authority, take any action which has, or may have had the effect of in any way disposing of, withdrawing, transferring, dealing with or diminishing the value of any of its own assets, and any funds it holds for, or to the order of, its customers (whether in the United Kingdom or elsewhere). Any request for consent envisaged by this Requirement is to be made by the Firm in writing to the Authority. 6. Sub-paragraph (5) above does not apply to monetary payments or the disposal of assets made by the Firm in the ordinary course of business, including the following circumstances: a) Payments in satisfaction of any money awards made by the FOS; b) Payments to the Firm’s suppliers and in satisfaction of any existing contractual obligation by the Firm, on the proviso that any such payment has first been approved in writing by the Authority. To enable the Authority to consider any such requests for payment, the Firm must first provide the Authority with written details of the proposed recipient of any such payment, the amount of the payment and a justification for the payment; c) Payments to legal advisors of the Firm; and d) Usual and proper salary payments made by the Firm, where those payments have been agreed prior to the imposition of these Requirements. 7. For the purpose of sub-paragraph (6), the following will not be regarded as payments in the ordinary course of business: a) Payments of unusual or significant amounts to the Firm’s controllers, shareholders, partners, directors, officers, employees or any connected persons; b) The making of any capital distribution; c) The making of any gift, loan or dividend; d) Payments made as part of any financial restructuring or reorganisation of its business, or from the sale of any part of the Firm’s business (whether share or asset based); and e) Salaries to any staff employed by the Firm which has not been approved in writing by the Authority. 8. The terms and effect of sub-paragraphs (5) to (7) above comprise an asset requirement within the meaning of section 55P(4) of the Act.