Courtiers Investment Services Limited

Limits on what they may do

• Courtiers Investment Services Ltd will not accept, without prior written consent of the Authority, any new clients, or any new client money or custody assets, from new or existing clients.

  1. Courtiers Investment Services Ltd will not accept, without the prior written consent of the Authority, any new clients, or any new client money or custody assets, from new or existing clients. This applies from the date of the VREQ and applies to Courtiers Investment Services Ltd (CIS) and their appointed representatives, Snowdon Financial Ltd and Paragon Financial Planning. 2. Paragraph 1 does not apply to the acceptance of new client monies or custody assets from existing clients and / or third parties by CIS as a result of or in relation to the following: 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 custody assets from the client; b) Existing clients making contributions (but not transfers) to existing ISAs and pensions prior to 5 April 2024; c) Existing clients continuing to make ongoing contributions to an investment product under an arrangement which predates this notice; d) In-flight transfers agreed as at 29 February 2024 e) Receipt of dividends or coupons; f) Rights issues; g) Corporate actions including maturing bonds; h) Settlement of trades instructed but not yet settled as at the date of the requirements; and i) Margin calls and movements associated with open trades and positions. j) Clients who have been auto enrolled to the CIS SIPP by their employer may be onboarded, but individual clients may not start a new investment management or ongoing advice agreement with any part of the Courtiers group. 3. For the avoidance of doubt in paragraph 1, this does not include the onboarding to CIS of clients who are currently contracted to receive services from a regulated entity within the Courtiers group, i.e. current clients from other entities listed below in the Courtiers group from another entity may transfer to CIS. 4. For the avoidance of doubt, paragraph 1 does include any new clients who onboarded with another entity listed in the Courtiers Group after the date of the VREQ, i.e. a new customer at another entity cannot be onboarded and transferred to CIS after the date of the VREQ. 5. CIS will not cancel or change the service level of any ongoing service arrangements already in place with clients as at the date of this VREQ. CIS must not prevent the offboarding of a client if the client has chosen to cancel their service. 6. CIS will notify the FCA at the earliest opportunity of the governing body’s decision to begin any wind down process for the firm.

• Courtiers Investment Services Limited will not, without the prior written consent of the Authority, in any way dispose of, withdraw, transfer, deal with or diminish the value of its own assets, whether in the UK or elsewhere.

  Asset Restriction Courtiers Investment Services (CIS) makes this application as the lead organisation and does so on behalf of each other firm within the Courtiers Group, including Brunswick Investment Management (FRN 616322). 1. Courtiers Investment Services Limited (CIS) will not, without the prior written consent of the Authority, in any way dispose of, withdraw, transfer, deal with or diminish the value of its own assets, whether in the UK or elsewhere. 2. CIS shall not make payments to the directors, shareholders or other senior management within the Group, other than salary, reasonable expenses and other contractually agreed sums (not including loans, dividends or other such payments) agreed prior to the date of this VREQ. Any payments after the date of the VREQ would require prior written consent by the Authority. 3. For avoidance of doubt, transfers between the Group’s banks or securities accounts or between companies within or out with the Group require the prior written consent of the FCA. 4. The asset restriction does not apply to monetary payments, or the disposal of assets made by firms within the Group in the ordinary course of business, of £20,000 or less, whether as a single transaction or a combination of related transactions. For the avoidance of doubt, the following payments shall not be regarded as payments in the ordinary course of business: a) Payments of unusual or significant amount to the Group’s controllers, shareholders, Directors, Officers, Employees, or any connected persons. b) The making of any capital distribution or payment of any dividend. c) The making of any gift or loan by any firm within the Group to any party. d) Payments made as part of any financial reorganisation of its business (whether share or asset based). 5. The assets restriction does not apply to: a) Transactions giving effect to instructions initiated by clients of any firm within the Group, other than any clients that are also the Firm’s controllers, members, officers or employees. b) Payments of funds to the Group’s suppliers in the ordinary course of business and in satisfaction of the Group’s contractual obligations. c) Usual and proper salary payments made by the Firm, where such salaries have been agreed prior to 18 March 2024 or the imposition of the VREQ. d) Payments of reasonable legal cost and expenses; Liquidity Requirement 6. The group must hold a minimum of the firm’s Liquid Assets Threshold Requirement as assessed in the Group ICARA, approved by the governing body on 12 February 2024, as being £1,845,000 plus an Additional Liquidity Amount (ALA) of £2,000,000 (that is £1,845,000 + £2,000,000 = £3,845,000) in cash in an account at an authorised UK credit institution that is held in the firm’s own name and is controlled solely by the firm. 7. The ALA referred to in paragraph 7 must not be subject to the rights or interest of any other person (for example any form of security, lien, netting arrangement, right of setoff or preferred creditor arrangement), save where such rights arise due to the terms and conditions routinely applied to such accounts by the relevant credit institution. 8. The ALA referred to in paragraph 7 may be used only: a) To make client redress payments, b) To meet costs associated with any additional remedial actions required by the Authority, c) To ensure that, in the event of firm wind-down, this can be completed in an orderly manner, or d) In any other circumstances, with the express consent of the Authority. 9. No matter the expenditure required, the Group capital and liquid assets must not drop below the statutory minimums required. Securing of records 10. 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.