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Downing
AIM NISA
Key Features and
Terms & Conditions
Contents
Objectives3
Your Investment3
Risks4
Questions and Answers
5
Definitions 8
NISA Terms and Conditions
9
Notes on Application
11
The Downing AIM Estate Planning NISA (“Downing NISA”) is a tax wrapper for the Downing AIM Estate
Planning Service which has its own memorandum (the “Service Memorandum”). You should read the Service
Memorandum before investing into the Downing NISA.
This Key Features Document (“KFD”) will help you consider the most important information and relevant facts
and figures regarding the Downing NISA prior to you making your investment decision and should be read in
association with the Downing NISA Investor Guide and the Service Memorandum.
The Financial Conduct Authority (“FCA”) is the independent financial services regulator. It requires us,
Downing LLP, to give you this important information to help you to decide whether our Downing NISA is right
for you. You should read this document and the Service Memorandum carefully so that you understand what
you are buying, and then keep these documents safe for future reference.
Downing LLP has established a Stocks & Shares NISA. Brooks Macdonald Asset Management Limited is both
the Plan Manager and the Administrator of the Downing NISA.
This document constitutes a financial promotion pursuant to Section 21 of the Financial Services and Markets
Act 2000 and is issued by Downing LLP
Your attention is drawn to the risk factors set out on page 9 of the Service Memorandum. Nothing in this
document should be regarded as constituting legal, taxation, investment or other advice and you are advised
to consult your own professional adviser before contemplating any investment.
This document does not constitute, and may not be used for the purposes of, an offer or invitation to treat
by any person in any jurisdiction outside of the United Kingdom. It does not constitute a public offering in
the United Kingdom. Any decision to invest in this product should be made on the basis of the information
contained in this brochure and the terms and conditions. Any references to tax laws or levels in this document
are subject to change. Past performance is not a guide to future performance and may not be repeated. The
value of shares can go down as well as up and you may not get back the full amount invested. You should
consider an investment in this product as a long-term investment.
The information contained in this document may not be reproduced in any form without the express
permission of Downing LLP and to the extent that it is passed on care must be taken to ensure that this is
in a form which accurately reflects the information presented here. Whilst Downing LLP believes that the
information is correct at the date of this production, no warranty on representation is given to this effect and
no responsibility can be accepted by Downing LLP to any intermediaries or end users for any action taken on
the basis of the information.
Downing LLP (registered in England No OC341575) is authorised and regulated by the Financial Conduct
Authority. Company Registered Office: Ergon House, Horseferry Road, London SW1P 2AL.
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Downing AIM Estate Planning NISA
Objectives
The objective of the Downing NISA is to offer you a tax-efficient route to investing into a NISA
containing AIM Shares, obtaining relief from inheritance tax after two years, whilst also generating
capital growth.
Your Investment
•
You may keep your investment for as long as you wish, because it has no fixed term
•
You may transfer an existing NISA from other NISA managers to the Downing NISA in specie or in cash
•
You may withdraw from your Downing NISA at any time by instructing us in writing
•
You may, at any time, transfer your Downing NISA to another NISA manager of your choice either in specie
or in cash.
The following investment levels apply to the Downing NISA (including the Downing AIM
Estate Planning Service):
Minimum initial lump sum or in specie valuation:
£50,000
Maximum NISA investment in the 2014/15 tax year:
£15,000
Minimum withdrawal:£1,000
The minimum aggregate initial subscription to the NISA is £50,000. If the transfer value of your existing NISA
is less than £50,000, the difference can be invested into the Downing AIM Estate Planning Service and up to
the maximum NISA limit may be subscribed or transferred on an annual basis from the Downing AIM Estate
Planning Service to the Downing NISA.
For example:
If you transfer your existing NISA with a value of £30,000, then the minimum top-up subscription of £20,000
is required in the Downing AIM Estate Planning Service. Thereafter, up to the maximum NISA limit (see limits
above) may be subscribed or transferred on an annual basis from the Downing AIM Estate Planning Service to
the Downing NISA.
Downing AIM Estate Planning NISA
3
Risks
These risks apply to investment in the Downing NISA and should be read in conjunction with the risks set out
on page 9 of the Service Memorandum.
4
•
The favourable tax treatment given to NISAs may not be maintained. The rates of and reliefs from taxation
may change over time and apply directly to you as a UK investor.
•
Past performance is not a guide to the future. AIM shares carry a higher degree of risk of losing money
than other UK listed shares. It may be difficult to deal in these shares. There can be a big difference
between the buying price and the selling price of AIM shares. If AIM shares have to be sold quickly, you
may get back much less than you paid for them. Prices of AIM shares may change quickly and may go
down as well as up. It may be difficult to obtain reliable information about the value of AIM shares or a full
understanding of the nature of the risk to which they are exposed.
•
Taking excessive withdrawals may erode the capital value of your Downing NISA, for example when
investment returns are low but your withdrawals are high.
•
Income can fluctuate, both in monetary value and in percentage terms.
•
The price you pay includes initial and annual costs, which will have an effect on the value of your
investments. Initial costs, in particular, will have an immediate effect so you should always consider your
Downing NISA as a medium to long term investment (minimum of five years).
•
If you take advantage of any cancellation rights you may be granted, you may not get your original
investment back if the price of assets falls between the date of investment and the date of cancellation.
•
If you are transferring an existing NISA to us, any income or growth on your investment may be reduced if
there is a market rise during the period in which your transfer is being administered.
•
You should ensure that you are aware of any exit or transfer charges made by your existing NISA Manager.
•
We do not provide taxation or investment advice.
Downing AIM Estate Planning NISA
Questions and Answers
What is a NISA?
How do I invest?
From 1 July 2014, ISAs were reformed into NISAs,
with equal limits for cash and stocks & shares. A NISA
permits investment with the benefit of protection
from income tax and capital gains tax. There is no
capital gains tax payable on the profits made on a
NISA and there is no further income tax to pay on
distributions.
Before opening a Downing NISA you should consult
your Independent Financial Adviser (“Adviser”), and
read the Terms & Conditions included within this
document as well as the Service Memorandum for
the Downing AIM Estate Planning Service. You can
then complete the Downing NISA Application Form
(you need to complete the application form attached
to the Service Memorandum if you have less than
£50,000 to invest in the Downing NISA), and return it
to your Adviser.
As tax exempt arrangements, NISAs must be
administered by Managers approved by HM Revenue
& Customs who are obliged to ensure that the
statutory regulations are observed. NISAs allow
investment into two investment options: i) Cash and
ii) Stocks & Shares. You can only open one Stocks &
Shares NISA and one Cash NISA per tax year.
You can invest up to £15,000 in either a Cash NISA or
a Stocks & Shares NISA or a combination of both.
We only offer a Stocks & Shares NISA.
Who can invest in a Stocks & Shares
NISA?
Anyone aged 18 or over may invest in a Stocks &
Shares NISA, provided they are resident or ordinarily
resident in the UK for tax purposes. This includes
government employees serving overseas and their
spouses or civil partners. NISAs may not be taken out
by companies or in joint names.
How is my money invested?
When we have selected suitable AIM Shares,
and appropriate terms and conditions have been
negotiated, we will purchase AIM shares on your
behalf. Any dividends received from the AIM Shares
will be reinvested by us or held in the client account.
How much will my advice cost?
You will need to agree any fees payable to your
Adviser with him or her. Further details of charges are
provided on page 6.
What right do I have to change my mind?
You may exercise your cancellation rights by writing
to us at the address at the end of this document.
The cancellation period is 14 days after you receive
our Cancellation Notice. It is important for you to be
aware that your investment may be subject to market
fluctuations outside of our control; this may result in
you receiving less back than your original investment
in the event that you cancel your application.
Lump sum investments may be made by personal
cheque (payable to ‘BMAM General Client A/c No2
re Client Name ’) or by bank transfer (payment details
are on page 11). If a cheque is drawn on a building
society account, in accordance with ML Regulations,
it should be endorsed by the building society to
confirm that the monies have come from your own
account. Cheques must be denominated in Sterling
otherwise they will not be accepted. Applications with
‘PO Box’ or ‘care of’ addresses are not acceptable.
If your permanent address is a retirement home,
nursing home or hospice, this address can be
accepted.
You can make additional investments into your
Downing NISA, up to the maximum allowance each
year, by sending us a personal or bank/building
society endorsed cheque along with a completed
Application Form, for the additional amount.
How do I notify you of a change in my
personal details?
If you wish to change the personal details that we
hold for you, you should inform us in writing to the
address at the end of this document. Please enclose
any appropriate documentation or certified copies
of the documentation accompanied by appropriate
signatures. You should also notify your Adviser of any
change to your personal details.
If you notify us of a change in your address we will
write to your new and old address to acknowledge
this change within five Business Days. Current
procedures state that if you request a withdrawal
from your account within six months of your change
of address notification we reserve the right to request
additional verification of your instruction.
Downing AIM Estate Planning NISA
5
What are the charges?
These charges are the same as those described in the
Service Memorandum. For the avoidance of doubt
they are only paid once.
Initial Charges
Downing’s initial charge
Downing’s initial charge is 2.5% of the amount
subscribed (less any initial Adviser charges) plus
VAT, where no initial commission is payable to your
Adviser (e.g. for advised applications). Where initial
commission is payable to an Intermediary (e.g. for
execution only), our initial charge will be 5.5% plus
VAT. Our initial charge will be deducted from the
amount subscribed. Out of our fees, we will pay
all set up costs, including initial commission where
applicable. Downing’s initial charge will be reduced
by 0.5% for applications received and accepted by 31
December 2014.
Initial Adviser Charge
If an Adviser Charge has been agreed between you
and your Adviser in respect of the Downing NISA, this
may be facilitated from the investment. The fee will
be deducted from the amount subscribed and paid
to your Adviser. Alternatively, you can pay this fee
personally to your Adviser.
Ongoing Charges
Downing’s management charge
Downing will charge a fee of 2% plus VAT of the
Portfolio Value where no annual trail commission
is payable to your Adviser. Where annual trail
commission is payable to an Intermediary, we will
charge an annual fee of 2.5% plus VAT. Out of our
fees, we will pay the insurance premium, custodian
and nominee fees and annual trail commission, where
applicable.
Annual Adviser Charge
If you have agreed an annual Adviser Charge with
your Adviser, we will facilitate this through the Service.
The annual Adviser Charge will be deducted from
your Portfolio and paid to your Adviser once a year.
Alternatively, you can pay this fee personally to your
Adviser.
Downing does not charge administration,
arrangement, performance or success fees.
Other charges
Probate valuations
Valuations of up to six listed securities: £250 plus VAT
Valuations of seven or more listed securities: £200
plus VAT and £10 plus VAT for each security held
Dealing fees
We do not charge dealing fees; however, third party
transactional fees will apply.
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Downing AIM Estate Planning NISA
Commission
Advisers who are permitted to receive commission
(e.g. for execution only clients) can be paid initial
commission, usually at the rate of 2.0% of the amount
subscribed, plus annual trail commission, usually
at the rate of 0.5% of the Portfolio Value they have
introduced. Commission is payable by us from our
fees.
What documentation do I receive?
We will send you half yearly reports made up to 31
March and 30 September each year, containing a
summary of transactions and details of all investments
in your Portfolio, together with an investment
commentary. You will be able to view your investment
portfolio online using the web-based access provided
by the Administrator. We will send you an annual tax
letter within three months of the end of each tax year.
Can I withdraw funds?
Yes, you may withdraw funds from your portfolio
in full or in part at any time. If you wish to do this,
send us your signed written instructions and we
will sell sufficient AIM Shares. It is anticipated that
withdrawals will usually be satisfied within 10 business
days of our receipt of your written request. You can
fax an instruction to 020 7416 7652 or email contact@
downing.co.uk with your instruction. Redemption
instructions given by fax or email must be followed
up with the original signed instructions prior to
redemption proceeds being remitted. Payment
will be made by BACS if your bank account details
have been verified or by cheque to your registered
address, within one day of settlement of the AIM
shares. A contract note will be sent within one
Business Day.
If you would like your proceeds to be sent by BACS
please send us a void cheque or paying-in slip to
enable your bank details to be verified.
The minimum withdrawal is £1,000 or otherwise at our
discretion.
Please note that the Downing NISA does not offer a
regular (e.g. monthly) income option.
What is the taxation position?
The rate of, and relief from, taxation depends upon
your own personal tax position and may vary over time.
All gains arising from an investment in a NISA are
currently free of any further UK tax. You do not
currently have to declare your Downing NISA on
your tax return. This information is based on our
understanding of current UK legislation and may
change in the future. Additionally the portfolio value
should qualify for up to 100% relief from inheritance
tax after just two years.
What use do you make of my personal
data?
We will keep any information that we hold about
you in any appropriate format for the purpose of
the administration and accounting of your Downing
NISA and for any other purpose which is necessary
for the performance of this contract or our powers,
duties and discretions under the relevant rules and
regulations.
When is this document updated?
This document was prepared as at 2 July 2014
specifically for the purpose of Downing NISA
investors and potential investors. Key Features for the
Downing NISA will be reviewed at least once a year,
and updated if necessary. You will be given at least 30
days’ notice of any changes.
How can I obtain further information?
Further information can be obtained from your
Adviser.
Our staff are not permitted to provide advice on the
merits, suitability or otherwise of investing in the
Downing NISA. If you have an administrative query or
wish to close your Downing NISA you should write to
us at:
Downing LLP
Ergon House
Horseferry Road
London
SW1P 2AL
How do I complain?
If you wish to complain about any aspect of the
Downing NISA you should write to us at:
Downing LLP
Ergon House
Horseferry Road
London
SW1P 2AL
This will initiate our formal complaint procedure.
Details of our complaint procedures are available
upon request. If your complaint has not been
satisfactorily resolved within eight weeks you may
write to the Financial Ombudsman Service, South
Quay Plaza, 183 Marsh Wall, London E14 9SR. Their
helpline is 0800 0234 567 and their email address is:
[email protected].
The Financial Services Compensation Scheme
(“FSCS”) is the UK’s statutory fund of last resort for
customers of authorised financial services firms. This
means that FSCS may pay compensation if a firm is
unable, or if likely to be unable, to pay claims against
it. FSCS is an independent body, set up under the
Financial Services and Markets Act 2000 (“FSMA”).
Their service is free to consumers and their website
can be found at www.fscs.org.uk. The FSCS will apply
to investments made into the Downing NISA.
Governing law
Your dealings with us, both before and after you have
made an investment, will be construed and governed
in accordance with English law. Disputes arising
under, out of or connected with your dealings with
us will be subject to the exclusive jurisdiction of the
English courts. All documentation we provide to you
relating to your Downing NISA will be in the English
language.
Downing AIM Estate Planning NISA
7
Definitions
8
Account
your UK bank or building society account
Administrator, Plan Manager and Custodian
Brooks Macdonald Asset Management Limited
Adviser
independent financial adviser chosen by you to advise on
the suitability of your investments
Adviser Charge
fee agreed between you and an FCA authorised and
regulated adviser, for advice and related services
AIM
the junior market, established in 1995 by the London
Stock Exchange, providing trading facilities for shares of
smaller companies.
AIM Shares
AIM shares which are held in your Portfolio
Business Day
any day, excluding Saturdays, Sundays and public holidays
Cancellation Notice
a letter sent to you explaining that you have 14 days to
cancel your application if you change your mind
CGT
capital gains tax
Downing NISA
the NISA tax wrapper managed by Downing LLP to invest
in AIM shares
FCA
Financial Conduct Authority
FCA Rules
rules issued from time to time by the FCA
FSMA
Financial Services and Markets Act 2000
HMRC
Her Majesty’s Revenue & Customs
IHT
Inheritance tax
Intermediary
authorised intermediary who signs the Application
Form and whose details are set out in section 9 of the
Application Form
Investment(s) or Portfolio
assets held from time to time within the Downing NISA
and money used to begin or top up the NISA.
Investor Agreement
investor agreement set out in the Service Memorandum
Market Value
value of investments listed on a recognised stock market
measured using bid price plus, where applicable, any cash
ML Regulations
Money Laundering Regulations 2007
NISA Application Form
application form to invest in the Downing NISA available
from Downing
NISA or New Individual Savings Account
scheme of Investment satisfying the conditions prescribed
in the Individual Savings Account (Amendment No. 2)
Regulations 2014
Nominee
holder of Investments on behalf of another (and as
defined for the purpose of the FCA Rules)
Portfolio Value
Market Value of your Portfolio (including any cash) less
any Withdrawals
Terms & Conditions
terms & conditions relating to the Downing NISA,
including those contained in the Service Memorandum
Withdrawals
amounts withdrawn by you from your Portfolio, whether in
cash or stock transferred in specie at Market Value
We, us, our, Downing or the Manager
Downing LLP
You and Your
an Investor who applies to open (or who holds a Downing
NISA) on these Terms & Conditions or where relevant any
attorney appointed under an Enduring or Lasting Power
of Attorney registered with the Court of Protection
Downing AIM Estate Planning NISA
NISA Terms and Conditions
The terms and conditions set out in the Investor
Agreement in the Service Memorandum are
applicable to the management of your Portfolio
of AIM Shares, save where explicitly amended
or replaced by the following NISA terms and
conditions, which apply to your Downing NISA:
1. Investing in the Downing NISA
1.1 Subject to the NISA Regulations, you have
the right at any time by notice in writing to us to
transfer in cash all or part of your Downing NISA
(with all rights and obligations of the parties to it) to
another NISA manager. Instructions to transfer all
of your Downing NISA Investments will entitle us to
terminate your Downing NISA.
You should note:
(a) that you may lose IHT Relief in respect of your
Downing NISA;
(b) that it may not be practicable for the AIM Shares
to be sold, in which case there may be a delay in
completing the withdrawal. If it is practicable to
effect, and you decide to proceed with a withdrawal,
we will, unless you otherwise request, effect the
withdrawal as soon as practicably possible; and
(c) we have a lien over your portfolio in respect of
damages or accrued but unpaid fees and shall be
entitled to dispose of all or any AIM shares in order
to discharge your liability and to pay any balance to
you.
1.2 We will keep records that identify your
Investments separately. All shares acquired on your
behalf will be registered in the name of the NISA
Administrator’s nominee. Your Portfolio will not
be lent to third parties and no borrowings may be
made by us against the security of your Portfolio. All
documents evidencing title to your Portfolio shall be
held by the Administrator or the Custodian in safe
custody.
If we receive notification of your death, your
Downing NISA will be terminated. Your Downing
NISA will cease to benefit from any tax advantages
from the date of your death. The AIM Shares will
be realised in full and the proceeds paid to your
personal representative, or alternatively the holding
may be transferred upon receipt of the necessary
documentation. On termination, a contract note will
be sent to you or your personal representative.
1.3 Whilst your cash is awaiting investment it is
protected and held by the Administrator in a client
money account maintained in accordance with the
FCA Rules. No interest will be paid on cash pending
investment or held for payment to you. Instead any
interest accrued will be used to cover the cost of
administering the Downing NISA. If your Downing
NISA holds more than 50% in cash for more than six
months without you providing instructions to invest
the cash then we reserve the right to close the
account and return all monies to you.
2.2 We will be entitled to terminate the Downing
NISA by giving you 30 days’ written notice served on
you to take effect from receipt of the notice by you.
You may be required to sell all of your AIM Shares in
your Downing NISA and/or transfer your Portfolio to
another NISA Manager.
2. Termination (NB: the following
section replaces section 14 of
the Investor Agreement in the
Memorandum)
(b) we cease to be appropriately authorised by the
FCA or we become insolvent we shall endeavour
to make arrangements to transfer your Downing
NISA to another NISA manager; in which case
that manager shall assume our role under this
Agreement, failing which the Agreement shall
terminate forthwith and, subject to Clause 15 of
the Service Memorandum, the Investments in your
Portfolio shall be transferred into your name or as
you may otherwise direct.
2.1 Without prejudice to the completion of
transactions already initiated, you have the right
to terminate your Downing NISA at any time by
providing us with written notice. We will make such
transfers in cash and payments out of your Downing
NISA as you direct, subject to liquidity. Your
Downing NISA will be treated as being terminated
on the date the final payment of any proceeds is
made to you.
If:
(a) we give you not less than 30 days’ written notice
of our intention to terminate our role as Manager
under this Agreement; or
2.3 If you exercise your cancellation rights, we shall
refund any monies paid by you less any charges we
have already incurred for any service undertaken
in accordance with the terms of the Investor
Agreement. The Custodian is obliged to hold your
investment monies until we and the Custodian have
completed satisfactorily our money laundering
checks.
Downing AIM Estate Planning NISA
9
3. Records
5. Confidential information
3.1 The Plan Manager will maintain all such records
relating to your Downing NISA as are required by
the NISA Regulations and will make such returns
to HMRC for the purposes of taxation, and provide
all such details of taxation to you as we may be
required to do under the NISA Regulations.
5.1 None of the Manager, Custodian or Investor
shall disclose to third parties or take into
consideration information either:
3.2 We will notify you in writing if, by reason
of any failure to satisfy the provisions of the
NISA Regulations, your Downing NISA has, or
will, become void for the purposes of the NISA
Regulations. In this case and on your instruction and
within the time stipulated by you, either:
or
a) your Downing NISA or part of your Downing NISA
shall be transferred to another NISA manager in
accordance with the NISA Regulations relating to
transfers, or
b) all or some of the AIM shares held in the Downing
NISA and any cash shall be transferred or paid to
you.
4. Anti-money laundering
4.1 Anti-money laundering regulations aim to
prevent criminal property being used or disguised
as legitimate wealth. To satisfy these regulations
you will have to produce satisfactory evidence of
your identity before we can do business with you,
and from time to time thereafter. This identification
process is designed to assist in the prevention of
crime within the financial services industry. If you do
not provide the information when requested, we
may be unable to accept any instructions from you
or provide you with any services.
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Downing AIM Estate Planning NISA
a) the disclosure of which by it would be or might be
a breach of duty or confidence to any other person;
b) which comes to the notice of an employee, officer
or agent of the Manager or the Custodian but
properly does not come to the actual notice of that
party providing services under this Agreement.
5.2 The Manager and the Custodian will at all
times keep confidential all information acquired in
consequence of the services, except for information
which:
(a) is in the public knowledge;
(b) they may be entitled or bound to disclose under
compulsion of law;
(c) is requested by regulatory agencies or relevant
tax authorities;
(d) is given to their professional advisers where
reasonably necessary for the performance of their
professional services; or
(e) is authorised to be disclosed by the other party.
The Manager and the Custodian shall use all
reasonable endeavours to prevent any breach of this
sub-clause.
Notes on Application
Please contact us on 020 7416 7780 if you have any questions
relating to the completion of the NISA Application Form.
Procedure for application
The Downing NISA Application Form is available from www.
downing.co.uk or by calling Downing on 020 7630 3319. You
must complete the Downing NISA Application Form and
send it, together with your payment and money laundering
verification, to: Downing LLP, Ergon House, Horseferry Road,
London SW1P 2AL.
Method of payment
Payment should be made by cheque, drawn on an account
in the name of the Applicant, made payable to “BMAM
General Client A/c No2 re Client Name” or by electronic
bank transfer, to account name: “BMAM General Client
A/C No2”; account number: 10067934; sort code: 16-00-55;
bank: Royal Bank of Scotland, Southern Corporate Office,
London Corporate Service Centre, PO Box 39592, 2 1/2
Devonshire Square, EC2M 4XJ. When payment is made by
electronic bank transfer, please ensure that the Investor’s
surname and initials are included in the information to the
payee bank.
The minimum aggregate initial subscription to the NISA is
£50,000 (subject to Downing’s discretion). For example, if
you transfer your existing NISA with a value of £30,000, then
a minimum top-up subscription of £20,000 is required in the
Downing AIM Estate Planning Service. Thereafter, up to the
maximum NISA limit (£15,000 for the 2014/15 tax year) may
be subscribed or transferred on an annual basis from the
Downing AIM Estate Planning Service to the Downing NISA.
Applications will be dealt with on a first come first served
basis and we reserve the right to accept or reject any
application at our sole discretion.
By signing the Application Form, you hereby confirm that
you consent to the use of your personal information as
follows. Except as stated below, we will not make available
or disclose the personal information provided by you as
part of the application to any person or entity outside us,
the Administrator, Plan Manager or the Custodian without
your consent. This personal information will be stored on
our database, and by the Administrator, Plan Manager
and Custodian. This personal information may be used by
us to send you our details of new and existing products
(including by email) unless you notify us in writing that it may
not be used in this way. We are registered under the data
protection laws of the United Kingdom.
Money laundering regulations
Minimum subscription
Allocation of applications
Data protection
It is a condition that applications comply with the ML
Regulations. We require verification of identity from you.
Pending the provision of satisfactory evidence as to the
identity of the Investor and/or any person on whose behalf
the Investor appears to be acting, we may, in our absolute
discretion, retain an Application Form lodged by you and/or
the cheque or other remittance relating thereto. Verification
of identity may result in delay in dealing with your application
and in rejection of your application.
We reserve the right, in our absolute discretion, to reject any
application in respect of which we consider that we have not
received evidence of such identity satisfactory to us within
a reasonable period. In the event of an application being
rejected in any such circumstances, we reserve the right,
in our absolute discretion, but shall have no obligation, to
terminate any contract relating to or constituted by such
Application Form (in which event the money payable or paid
in respect of the application will be returned (without interest)
to the account of the drawee bank from which such sums
were originally debited). The submission of an Application
Form will constitute an undertaking by you to provide
promptly to us such information as may be specified by us as
being required for the purpose of the ML Regulations.
1. Adviser Certificate
Verification of your identity may be provided by means
of a “Confirmation of verification of identity” in the
prescribed form from a UK or European Economic Area
financial institution (such as a bank or stockbroker) or
other regulated person (such as a solicitor, accountant or
appropriate financial adviser) who is required to comply
with the ML Regulations. The relevant financial institution or
regulated person will be familiar with the requirements and
the relevant form.
2. Original/certified documentation
or
(One item from List A AND one item from List B)
List A
(Verification of Identity)
• Current signed passport
• Current UK Driving
Licence
• HM Revenue & Customs
Tax Notification
• Firearms Certificate
List B
(Verification of Address)
• Recent* utility bill (but not a
mobile telephone bill)
• Recent* local authority tax bill
• Recent* bank or building
society statement
• Recent* mortgage statement
from a recognised lender
Please send original (not passport or driving licence) or certified
copies of the documents. Copies must be certified as a true
copy of the original by a UK lawyer, banker, authorised financial
intermediary (e.g. financial adviser or an FCA authorised
mortgage broker), accountant, teacher, doctor, minister of
religion, postmaster or sub-postmaster. The person certifying
the document should state that the copy is a true copy of the
original, print their name, address, telephone number and
profession and sign and date the copy.
*“Recent” means within the last three months.
Downing AIM Estate Planning NISA
11
Version 1 / December 2014
Ergon House
Horseferry Road
London SW1P 2AL
020 7416 7780
[email protected]
www.downing.co.uk
Downing LLP is authorised and regulated by the Financial Conduct Authority
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