Helford Capital Partners LLP

Limits on what they may do

• This firm may handle your money in passing but must not hold it, so payments should go to the product provider, never to a personal account.
• Immediate prohibition on advice and arranging in relation to the Affected Fund

  Immediate prohibition on advice and arranging in relation to the Affected Fund 1. The Firm must, immediately upon notification of these Requirements, cease permitting its appointed representative, Lend Direct Limited (FRN: 779059), to: (a) advise on investments in relation to the Affected Fund; (b) arrange (bring about) any transaction involving the subscription for, acquisition, disposal, transfer or redemption of units or other interests in the Affected Fund; (c) make arrangements with a view to any such transaction; or (d) arrange safeguarding and administration of assets in relation to the Affected Fund. 2. The Firm must take all reasonable steps to ensure that Lend Direct Limited does not accept any new instruction or business, or process or progress any existing instruction or transaction, in relation to the Affected Fund, except where strictly necessary to protect the interests of affected customers and with the Firm’s prior written approval. Termination of the appointed representative agreement with Lend Direct Limited 3. The Firm must, as soon as reasonably practicable and in any event by no later than 5.00 pm on 30 September 2026, terminate the appointment of Lend Direct Limited. 4. With effect from the termination required by paragraph 3, the Firm must not permit Lend Direct Limited to: (a) carry on any regulated activity under the responsibility of the Firm; (b) accept any new appointment, mandate or business on behalf of the Firm; or (c) represent or hold itself out as an appointed representative of, or as otherwise acting under the regulatory responsibility of, the Firm. 5. The Firm must take all reasonable steps to ensure that, with effect from the termination required by paragraph 4, all references to Lend Direct Limited acting as an appointed representative of the Firm are removed from all websites, financial promotions, customer or investor communications and other relevant materials. Protection of customers and orderly cessation 6. The Firm must take all reasonable steps to secure the orderly transfer, completion or cessation of Lend Direct Limited’s outstanding regulated activities and obligations in relation to the Affected Business. 7. In complying with paragraph 6, the Firm must: (a) put in place and implement appropriate arrangements for the transfer, completion or orderly cessation of the Affected Business, including any outstanding advice, applications, transactions, loans, security arrangements and asset-safeguarding or administration arrangements; (b) ensure that all customer assets, monies, books, records, security documents and operational arrangements relating to the Affected Business are appropriately protected and preserved; (c) ensure, so far as reasonably practicable, continuity of customer servicing, transaction processing, the safeguarding and administration of assets, regulatory reporting and all other material functions; (d) ensure that Lend Direct Limited does not provide any new advice, arrange or make arrangements in relation to any new transaction, accept any new business, incur any new liability, or make any material change in relation to the Affected Business, except where reasonably necessary to protect customers and with the Firm’s prior written approval; and (e) ensure that customers, counterparties, asset custodians or administrators and any other relevant persons are informed promptly of any relevant change and that customers are not exposed to avoidable harm as a result of the termination.

• Prohibition on reappointment

  8. Following the termination required by paragraph 4, the Firm must not, without the prior written consent of the Authority: (a) reappoint Lend Direct Limited as an appointed representative or introducer appointed representative; (b) enter into any arrangement under which Lend Direct Limited carries on a regulated activity under the responsibility of the Firm; or (c) permit Lend Direct Limited to resume any of the regulated activities comprised in the Affected Business under an appointed representative arrangement with the Firm. 9. Paragraph 8 does not prevent the Firm from obtaining records, information or other reasonable assistance strictly necessary to complete the transfer, completion or cessation required by paragraphs 6 and 7, provided that in doing so the Firm will not: (a) undertake any new regulated activity or new business; (b) advise on investments or arrange, or make arrangements with a view to, any new transaction; or (c) enter into any new transaction, commitment or liability, or undertake any safeguarding or administration of assets, for a customer.