GHC CAPITAL MARKETS LTD.

Limits on what they may do

• Restriction on New Model B Clients, and Accepting New Monies and Assets from Existing Model B Clients

  Restriction on New Model B Clients 1. The Firm must not, without the prior written consent of the FCA, onboard any new clients as part of any existing Model B relationships. 2. The Firm must not, without the prior written consent of the FCA, enter any new Model B arrangement with a third party. Restriction on Accepting New Monies and Assets from Existing Model B Clients 3. The Firm must not, without the prior written consent of the FCA, accept any new client money or assets from any existing Model B clients. 4. Paragraph 3 does not apply to the acceptance of new client money or assets from existing Model B clients and/or third parties on their behalf by the Firm in the following cases: a. re-investing the investment gains or redemption proceeds from the sale of an existing asset, where this does not require the acceptance of new client money or assets from the client; b. making contributions to existing ISAs and pensions excepting any new ISA account transfers; c. participating in the issuance of additional rights by entities in which they are invested at the Effective Date, provided that such transactions may not be settled from existing uninvested client monies held by the Firm in the account in which the shares are held or in a general investment account and that the Firm provides the FCA with such information as it specifies concerning transactions falling within this paragraph (c) within two (2) working days of closure of the relevant issuance; d. Settlement of trades or transactions instructed but not yet settled as at the Effective Date; e. Transfers between client money accounts; f. Transfers on the instruction of clients of the Firm to transfer their assets/monies to a third party; and g. Transfers of client monies or assets held as at the Effective Date between clients of the Firm, where such transfer is executed on the clients instructions. 5. For the purposes of paragraph 3, the Firm will not have ‘accepted’ client monies or assets if it returns an unsolicited deposit into its bank account within a period of two (2) working days of receipt without having dealt with those monies and/or assets within that period.