Legal and regulatory
All the extra things you should know.
The term MFM INVESTMENT Limited, ‘Moneyfarm’ or ‘us’ or ‘we’ refers to the owner of the website whose registered office is 90-92 Pentonville Road, London N1 9HS. Our company is registered in the UK and Wales under registration number 9088155. The term ‘you’ refers to the user or viewer of our website.
- The content of the pages of this website is for your general information and use only. It is subject to change without notice.
- Neither we nor any third parties provide any warranty or guarantee as to the accuracy, timeliness, performance, completeness or suitability of the information and materials found or offered on this website for any particular purpose. You acknowledge that such information and materials may contain inaccuracies or errors and we expressly exclude liability for any such inaccuracies or errors to the fullest extent permitted by law.
- Your use of any information or materials on this website is entirely at your own risk, for which we shall not be liable. It shall be your own responsibility to ensure that any products, services or information available through this website meet your specific requirements.
- This website contains material which is owned by or licensed to us. This material includes, but is not limited to, the design, layout, look, appearance and graphics. Reproduction is prohibited other than in accordance with the copyright notice, which forms part of these site terms.
- All trademarks reproduced in this website, which are not the property of, or licensed to the operator, are acknowledged on the website.
- Unauthorised use of this website may give rise to a claim for damages and/or be a criminal offence.
- From time to time, this website may also include links to other websites. These links are provided for your convenience to provide further information. They do not signify that we endorse the website(s). We have no responsibility for the content of the linked website(s).
- Your use of this website and any dispute arising out of such use of the website is subject to the laws of England and Wales and the English courts will have exclusive jurisdiction
- If you have any concerns about material which appears on our site, please contact email@example.com.
Definitions and interpretations
The following definitions and interpretations shall be considered in the context of this document:
Client, Customer, You: Means any person holding an account with us.
Complaint: As defined on the FCA Handbook, means any oral or written expression of dissatisfaction, whether justified or not, from or on behalf of a person, about the provision of, or failure to provide, a financial service or a redress determination, which: 1. Alleges that the complainant has suffered (or may suffer) financial loss, material distress or material inconvenience; and 2. Relates to an activity of that respondent, or of any other respondent with whom the company has some connection in marketing or providing financial services or products, which comes under the jurisdiction of the Financial Ombudsman Service.
FCA: Means the Financial Conduct Authority
FOS: Means the Financial Ombudsman Service
Us, We, The Company: Means MFM Investment Ltd, trading as MoneyFarm.
Summary of the Complaints Handling Procedure
- All complaints shall be addressed, in first instance, to the Client Relationship Management team using the contact details provided at the bottom of this document. They will deal with your complaint diligently and seek to provide an immediate resolution, no later than 3 business days after the date of your complaint.
- If your complaint cannot be dealt within 3 business days, we will send you an acknowledgement of receipt and your complaint will be dealt by the Compliance Team. We will seek to provide you with a final response within 8 weeks from the date of your complaint.
- If we cannot provide you with a final response by the 8th week from the date of your complaint, we will write to you explaining the reasons, and we will include an estimation of when we will be able to provide you with the final response.
- If more than 8 weeks have passed from the date of your complaint without us having provided you with a final response, or you remain dissatisfied with the response we will have provided you, you are entitled to refer your complaint, free of charge, to the FOS by following the steps outlined on their website at http://www.financial-ombudsman.org.uk/consumer/complaints.htm
- Upon resolution of your complaint, we will provide you with a Summary Resolution Communication in accordance with the FCA rules.
Treating Customers Fairly
Both the Client Relationship Management Team and the Compliance Team shall thoroughly examine any complaint and the relevant associated information as required to reach a fair outcome for the client, and communicate with the client in a fair and respectful manner at all times.
WARNING: Any specific instructions from a client may prevent us from taking the steps set out below that we have designed and implemented to obtain the best possible result for a client.
1. TREATING CUSTOMERS FAIRLY
We are dedicated to treating our clients fairly, which includes, amongst other aspects, ensuring we have and follow adequate policies and procedures to achieve Best Execution for our clients.
2. BEST EXECUTION
- When executing orders for clients, we are required by the FCA’s rules relating to best execution, to take all reasonable steps to obtain the best possible result for our clients, taking into account the following execution factors: the (i) price, (ii) costs, (iii) speed, (iv) likelihood of execution and settlement, (v) size, (vi) nature or (vi) any other consideration relevant to the execution of an order.
- For the purposes of delivering best execution for our retail clients in circumstances where there is more than one competing venue to execute an order, in order to assess and compare the results for the client that would be achieved by executing the order on each of the execution venues that is capable of executing that order, our own commissions and costs for executing the order on each of the eligible execution venues will be taken into account.
Our obligation to deliver best execution for a retail client where there are competing execution venues is not intended to require us to compare the results that would be achieved for our client with results that might be achieved for the same client by any other firm, on the basis of a different execution policy. Nor are we required to compare the differences between our commissions which are attributable to differences in the nature of the services we provide to clients.
- We have developed this policy and procedures with our execution venues to both achieve and record that each order that has been fulfilled in accordance with the FCA’s rules relating to best execution.
This policy, and our supplementary procedures relating to the policy, will be reviewed periodically and in any event at least on an annual basis.
- We will monitor the effectiveness of our best execution arrangements on a regular basis in order to identify and, where appropriate, correct any deficiencies. We will review our order execution arrangements and the contents of this policy on an annual basis.
We will notify clients of any material changes to our order execution arrangements or best execution policy.
- Relevant factors will be considered by our execution venue to achieve the best execution possible for clients, including stock liquidity, ability to deal on more than one market trading system choices and any specific conditions attached to the order by the client. If these factors and any other pertinent information are duly considered, we anticipate best execution will be attained for the client. We will inform the client if any particular bargain conditions are attached which may restrict the achievement of our best execution obligations.
- The principles of best execution apply equally to single orders or orders which are aggregated.
3. ORDER HANDLING
- When handling orders on behalf of clients, we will take the following steps in order to comply with the FCA rules relating to order handling: (a) we will promptly and accurately record and allocate orders executed on behalf of clients; and (b) we will carry out comparable client orders sequentially and promptly unless the characteristics of the order or prevailing market conditions make this impracticable or the interests of the clients require otherwise.
- We transmit client orders to our counterparties on a ‘first come, first served’ basis. In general, we aim to keep the time for the handling of orders to a minimum. After checking orders for consistency, orders are placed at a selected counterparty. We will monitor this dealing process.
- We will notify clients of any material difficulty relevant to the proper carrying out of orders promptly upon becoming aware of the difficulty.
- We will always aggregate orders so that we ensure the same outcome for each instrument. It is unlikely that the aggregation of orders and transactions will work to the disadvantage of any client, given that we do not take orders directly from the client, but rather we execute orders on a discretionary basis.
Aggregated orders have significant benefits for the client, the main benefit being the lower cost. When aggregating orders we will make sure that: (a) they are initiated with the same set of execution instructions; (b) if they are initiated on the same day and; (c) if they will follow exactly the same order chain (e.g. same custodian). [If an aggregated order is partially executed, the order will be settled for the different clients on a pro rata basis, according to the contribution made to the aggregated order. Our order management system is specifically designed to permit only pro rata allocation whenever an aggregated order is partially executed.
- The Company does not execute any orders for its own account.
Eligible investments include:
(a) Exchange Traded Funds (ETFs): orders may be transacted via electronic order books, retail service providers, agency crosses, direct telephone engagement and electronic algorithmic systems;
(b) Exchange Traded Commodities (ETCs): orders may be transacted via electronic order books, retail service providers, agency crosses, direct telephone engagement and electronic algorithmic systems.
5. EXCUTION VENUES
We select our counterparties with skill, care and diligence to ensure that they also meet the FCA rules on Best Execution, and we review our relationships with our counterparties on an annual basis.
We do not operate via Direct Market Access (DMA). Instead, we execute orders via Saxo Capital Markets Limited UK, an FCA regulated institution of sufficient reputation that provides us with a full solution from order routing to clearing, settlement and custody services, this translates into cost efficiency for both MoneyFarm and our clients.
Should you wish to know more, please contact us via e-mail at firstname.lastname@example.org or via phone on 0800 433 4574 (from the UK) / +44 (0) 203 745 6990 (from abroad).
MONEYFARM – TRADING AS MFM INVESTMENT LIMITED – LEI 213800O61IIMGUQNGI04
Annual report on top five brokers and quality of execution
In accordance with COBS 11.2A.34R(6) (incorporating Article3 (3) of RTS28, MFM Investment Limited (“MFM” or “the Firm”) is required to publish the top five investment firms in terms of trading volumes, where it transmitted or placed client orders for the execution divided per class of financial instruments and information of execution obtained.
RTS 28 report for the period to 31 December 2019
|Class of Instrument||Exchange Traded Derivatives (ETFs) – Retail Clients|
|Notification if <1 average trade per business day in the previous year||Yes|
|Top five brokers ranked in terms of trading volumes||Portion of volume traded as a percentage of total in that class||Portion of orders executed as a percentage of total in that class||Percentage of passive orders||Percentage of aggressive orders||Percentage of directed orders|
|Saxo Capital Markets UK Limited<br>LEI 2138002TJAEVDAI8BF78||100%||100%||0%||0%||0%|
In addition to the table above, in accordance with Article 3(3) of RTS 28, MFM hereby publishes a summary of analysis and conclusions the firm has drawn from detailed monitoring of the quality of execution obtained in 2019.
|Requirements under Article 3(3)||<strong>MFM’s Response</strong>|
|An explanation of the relative importance the firm gave to the execution factors of price, costs, speed, likelihood of execution or any other consideration including qualitative factors when assessing the quality of execution||MFM regards all execution factors as set out in its order execution policy, however price and the likelihood of execution remain the factors of highest importance by MFM followed by cost and speed of the order covered by the broker.|
|A description of any close links, conflicts of interest and common ownership with respect to any investment firm used to transmit or place orders.||MFM does not have any close links, conflicts of interest or common ownership with respect to any investment firm used to transmit or place orders.|
|A description of any specific arrangements with any investment firm regarding payments made or received, discounts, rebates or non-monetary benefits received||We have currently selected a single entity for execution and we may confirm that: (i) this provides the best possible results for our clients on a consistent basis; (ii) we can expect that the selected entity will enable us to obtain results for clients that are at least as good as the results that could reasonably be expected from using alternative entities for execution. Our broker is subject to an ongoing monitoring process, which includes, regular reviews of performance of execution services, and the broker’s ability to trade effectively on our client’s behalf. MFM has entered into a trading agreement with the selected entity, according to which MFM pays: (i) a transaction fee for trading on the trading platform; (ii) a custody fee for the safeguarding and administration of assets. MFM does not receive any payments, discounts, rebates or non-monetary benefits from the selected entity.|
|An explanation to the factors that led to a change in the list of execution factors.||This is the second report and there are no changes to note in the list of execution venues listed in the firm’s order execution policy.|
|An explanation of how order execution differs according to client categorisation, where the firm treats categories of clients differently and where it may affect the order execution arrangements.||All MFM clients are treated the same under its order execution policy.|
|An explanation of whether other criteria were given precedence over immediate price and cost when executing client orders and how these other criteria were instrumental in delivering the best possible result in terms of the total consideration to the client||No other criteria were given precedence when providing retail clients with best execution|
|An explanation of how the investment firm has used any data or tools relating to the quality of execution, including any data published under Delegated Regulation (EU) 2017/575 [RTS27]||During 2019, MFM has regularly monitored the quality of execution obtained from the investment firm used to place client orders.<br>MFM is satisfied that it had adhered to the requirements set out in its Order Execution Policy in seeking to obtain best execution for its clients by reference to all relevant factors.<br>Each trade is monitored by the Portfolio Managers when placing the trade instruction to ensure that it is executed on the best terms available. It is a prerequisite of the terms of business of the brokers used by MFM that they must provide best execution.|
|Where applicable, an explanation of how the investment firm has used output of a consolidated tape provider||Not applicable, as there are currently no consolidated tape providers in Europe.|
We are committed to taking measures to recognise, supervise, examine and resolve conflicts of interest. We recognise that it is not possible to eliminate all sources of conflict of interest; however, safeguarding clients’ welfare remains our primary objective. This policy encompasses the relationships with clients and third party contacts.
We define a conflict of interest as being either:
(a) between us and you as a client; or
(b) between yourself and another client where your interests are materially affected.
We have identified areas where a conflict of interest may arise. They include, but are not limited to:
(a) services in different capacities at the same time;
(b) providing advice or management;
(c) acting for more than one client in a transaction;
(d) holding information on other clients that would affect you or them if it is disclosed;
(e) receiving gifts or entertainment which could conflict with our duties to you;
(f) employees pursuing activities or personal relationships potentially detrimental to you; and
(g) personal account holdings in companies or other investments being recommended by us.
- Our protocols are noted below and we consider them satisfactory to allow us to act without bias to prohibit damage to your interests. At all times stringent criteria to address and resolve conflicts is followed. Protocols have been developed and introduced to manage conflicts of interest. Our employees are provided with relevant training about the protocols and standards of conduct expected thereafter. Our management remains responsible for ensuring the protocols and resources are sufficient to identify and attend to a conflict as it may arise.
- We maintain an internal log of conflicts that arise, listing how each conflict was monitored and any solution which was developed and applied to resolve the problem and to prevent the client’s interests from being disadvantaged. The effectiveness of our protocols is assessed by internal audit staff members who execute their duties in a wholly independent capacity.
- We have in place protocols to prevent unauthorised access or inappropriate dissemination of information.
- Where our functions could create an internal conflict our duty lines are kept separate and individual management and reporting structures are established. The operations functions are maintained and conducted separately from the front office functions and in both an appropriate level of qualification, expertise and supervision is applied.
- Staff remuneration is by means of a basic salary which is not linked to the underlying performance of the company. A remuneration committee agrees and monitors awards to achieve consistency and equitability and does not lead to conditions which may foster conflict.
- Inducements from third parties are acceptable with respect to a service we provide to you if it is disclosed to you and if it is the payment of a normal fee.
- Personal account dealing rules are in place for all staff.
- A register of all gifts to staff and valued in excess of £150 is maintained and approved by a senior manager.
Where we are unable to resolve a conflict of interest we will notify you formally in writing. This disclosure will permit you to evaluate whether it is appropriate to continue using our services in respect of the pertinent conflict.
Where we have examined the conflict of interest and its cause it may inform you of its decision not to act on your behalf if it determines no other course of action is possible.
In the context of its investment process, Moneyfarm considers a range of risk and return parameters. The ETFs selected in current Moneyfarm portfolios do not currently have an explicit screening on ESG Ratings or sustainability factors. However, we believe that sustainability factors are an important consideration in multi-asset portfolio construction and risk management. In fact, sustainability factors can potentially impact asset prices in a variety of ways, including changing market conditions, availability of scarce resources, regulatory environment and consumer preferences. They can impact individual companies, specific sectors and geographic regions.For this reason, despite the underlying ETFs not having any explicit ESG screening, for the current portfolios offering, Moneyfarm monitors the ESG Ratingat a portfolio level in order to avoid a high concentration of the investments in ETFs with a low ESG rating or non-rated ETFs.
Moreover, we are currently working on launching an ESG proposition of a set of "socially responsible" ETFs, not only aimed at further decreasing the impact of sustainability risks on its Model Portfolios, but also at contributing positively to sustainable development and achieving sustainable investment objectives by channeling clients’ investments to companies with a lower environmental impact and higher ESG ratings.
For further details, please check our ESG Integration Policy
How regulation works
We tell you we are regulated but what does that mean?
Regulation in the UK
You might be bored just by reading that title, but regulation is there for a reason. It’s there to protect the interests of the consumer (that’s you), and to ensure that financial organisations (that’s us) manage your money properly. So the fact that we’re regulated is a good thing, it’s not easy to get regulatory permission, and you have to comply with some really high standards.
Regulation for you breaks down into three areas:
The Financial Conduct Authority (FCA) aim to make financial markets work well so that consumers get a fair deal. That means they protect consumers, enhance market integrity, and promote competition. Moneyfarm report to the FCA monthly to prove that we’re looking after your investments properly.
For further information visit fca.org.uk
The Financial Ombudsman Service (FOS) is the UK’s official expert in sorting out problems with financial services. If you have an issue with Moneyfarm, and we hope you don’t, you can complain directly to us, if we don’t respond quickly enough you can report this to the FOS.
For further information visit financial-ombudsman.org.uk
The Financial Service Compensation Scheme (FSCS) covers financial organisations regulated in the UK, that includes us. In the event that Moneyfarm becomes insolvent whilst owing you money, you are covered for claims up to the value of £85,000
For further information visit fscs.org.uk