LCM FAMILY LIMITED

Limits on the record

• The Firm must immediately cease all regulated activity.

  Restriction on activities 1. The Firm must immediately cease all regulated activity. Should the Firm receive further client instructions or receipt of client money via the Model B arrangement after the Effective Date: (i) the Firm must notify the Authority of this by email within 24 hours of receipt of such money; and (ii) the Firm and its custodian must take all reasonable steps to return such money as soon as is reasonably practicable. 2. Save as required to comply with these Requirements, the Firm must not move or facilitate the movement of client assets, client money or clients, including onboarding, off-boarding or transfer(s), without the prior written consent of the Authority. 3. Nothing in these requirements should be taken to require the Firm or any of its directors to take any action which conflicts with a duty to consider the interests of creditors, should such a duty arise after the Effective Date. Assets requirement 4. Save as set out in paragraphs 2 and 3 above and in paragraph 5 below, the Firm must not, 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, and any funds it holds for, or to the order of customers or investors (whether in the United Kingdom or elsewhere), whether held by the Firm as at the Effective Date or acquired thereafter. 5. The Firm may continue dealing with or disposing of any of its own assets in the ordinary and proper course of business provided that the sum or value of such dealings or disposals, whether as a single transaction or a combination of related transactions, does not exceed £10,000 (or £15,000 in the case of legal expenses). 6. For the avoidance of doubt, for the purposes of paragraph 5 above, the following would be in the ordinary and proper course of business: (i) Any fees incurred or paid in exchange for professional advisory services provided to the Firm. (ii) Any salaries of the Firm’s staff, including to its directors, contractors or any other employees, where such salaries have been agreed prior to the Effective Date. 7. For the avoidance of doubt, for the purposes of paragraph 5 above, the following would not be in the ordinary and proper course of business: (i) The making of any distribution to the Firm’s shareholders including by way of capital distribution or dividend. (ii) The making of payments to clients for any reason including out of goodwill. (iii) The payment of commission or the provision of loans to employees of the Firm or any parties with close links to the Firm. (iv) The making of any gift or loan by the Firm to any party, or the entry into any financial reconstruction, sale of any part of the Firm (whether share or asset based) or reorganisation. 8. Paragraphs 4 to 7 constitute an assets requirement within the meaning of section 55P(4)(a) of the Act. 9. The Firm must, within 72 hours of the Effective Date, (i) write to all its customers; and (ii) publish in a prominent place on all websites and social media accounts in its name, and on all platforms to which its customers have access, informing of the imposition of the Requirements and their effect, in a form and by a method of delivery each to be agreed in advance with the Authority. 10. Once the notifications referred to in paragraph 9 above have been made, within 24 hours, the Firm must provide to the Authority: (i) A list of all parties to whom notifications have been sent; and (ii) 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.