Arnold Stansby & Co. Limited

Limits on what they may do

• The Firm must not onboard any new clients, must not accept any new client money or assets from new or existing clients, and must not dispose of, withdraw, transfer, deal with or diminish the value of any of its own assets – effective 17/02/2025 (part 1)

  Restriction on Onboarding New Clients 1. The Firm must cease, except with the Authority's prior written consent, onboarding new clients with effect from the Effective Date.   Restriction on Accepting New Monies from Existing Clients 2. The Firm must not, except with the Authority's prior written consent, accept any new client money or assets from new or existing clients with effect from the Effective Date. 3. Paragraph 2 does not apply to the acceptance of new client money or assets from existing clients and / or third parties by the Firm in the following cases: a. Existing clients re-investing the investment gains or redemption proceeds from sale of an existing asset, where this does not require the acceptance of new client money or assets from the client; b. Existing clients making contributions (but not transfers) to existing ISAs and pensions prior to 5 April 2025; c. Existing clients 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 date of the requirements; 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 customers of the Firm, where such transfer is executed on the customer’s instructions. 4. For the purposes of paragraph 2, 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.

• The Firm must not onboard any new clients, must not accept any new client money or assets from new or existing clients, and must not dispose of, withdraw, transfer, deal with or diminish the value of any of its own assets – effective 17/02/2025 (part 2)

  Asset Restriction 5. The Firm must not, without the prior written consent of the FCA, in any way dispose of, withdraw, transfer, deal with or diminish the value of any of its own assets. 6. Save as to when paragraph 4 applies, the Firm must ensure that all client money and assets are appropriately ringfenced in a designated client money account or accounts in line with its CASS obligations. 7. The assets restriction does not apply to monetary payments or the disposal of assets made by the Firm in the ordinary course of business, amounting to no more than £10,000 whether as a single transaction or a combination of related transactions. The following payments shall not be regarded as payments in the ordinary course of business: a. Payments of unusual or significant amounts to the Firm’s controllers, shareholders, directors, officers, employees or any connected persons (which shall include any management or performance fees or discretionary bonus). b. The making of any capital distribution or payment of any dividend. c. The making of any gift or loan by the Firm to any party. d. The entry into any financial restructuring, sale or reorganisation of any part of the Firm (whether share or asset based). 8. The assets restriction does not apply to: a. Transactions giving effect to instructions initiated by customers. b. Payment to existing customers of monies owed to them by the Firm. c. Payments of funds to the Firm’s suppliers or other third parties in the ordinary course of business and in satisfaction of the Firm’s contractual and legal obligations. d. Usual and proper salary payments made by the Firm. e. The transfer or disposal of any of the Firm’s or its fund’s investment management agreements to any third party, provided that (a) the Firm gives the Authority no less than five working days’ prior written notice of any such transfer or disposal, such notice to include details of the investment management agreements to be transferred or disposed and the details of any counterparty, and (b) the Authority provides its written consent to the Firm for such a disposal. 9. Sub-paragraphs (5) to (8) constitute an assets requirement within the meaning of section 55P(4)(a) of the Act. Notification Requirements  10. The Firm must by 17 February 2025 notify in writing all customers and custodians directly affected by the Requirements of the imposition and effect of these Requirements in a form to be agreed in advance with the FCA. 11. By 17 February 2025, the Firm must publish in a prominent place on its website, www.arnold-stansby.com, a notice setting out the terms and effects of these Requirements in a form to be agreed in advance with the FCA. 12. A Senior Management Function holder of the Firm must provide written confirmation to the FCA that it is in compliance with these Requirements by email by 14:00 every Friday, until such time as it is notified in writing by the FCA that it may cease to do so. Secure Records  13. With immediate effect, the Firm must secure all books and records and preserve all information and systems which may be relevant to demonstrating compliance with these Requirements and must retain these in a form such that they can be provided to the FCA promptly upon request.