DISCLOSURES AND DISCLAIMERS
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II) PILLAR 3 DISCLOSURE as of 30/06/2021
Macrocapital Limited, is registered in England and Wales with company number 04014398 and for over twenty-one years now (since March 2001) is authorised and regulated by the Financial Conduct Authority (IMRO and FSA in the past) as an Investment Manager (195463).
Part of the regulatory requirements and in particular of the Capital Requirement Directive (‘CRD’), is to carry out an Internal Capital Adequacy Assessment Process (‘ICAAP’) at least in the end of its financial year. Since January 2022 the new IFPR – Investment Firms Prudential Regime changes come into force and with that new capital and risk calculations. These new calculation factors known as K factors will form the content of the Internal Capital Adequacy Risk Assessment (ICARA) which replaces the ICAAP.
As far as capital requirements are concerned, Macrocapital Limited is a ‘BIPRU’ Limited License Firm, that doesn’t hold or control client money. This is explained in the Financial Conduct Authority (‘FCA’) Handbook and particularly within the FCA Prudential Sourcebook for Banks, Building Societies and Investment Firms (‘BIPRU’).
This regulatory capital has 3 pillars of capital requirements that have to be followed:
I] Pillar 1 is a variable capital requirement based on the sum of operational, market and credit risk requirements. Every firm must maintain at all times capital resources equal to or in excess of the amount specified.
II] Pillar 2 is an additional capital requirement related to risks not covered in Pillar 1. It requires firms and their supervisors to review whether additional capital should be held against risks not covered in Pillar 1 as well as instigate and oversee additional controls to mitigate such risks or a combination of these two approaches.
III] Pillar 3 is a requirement to publish certain details of capital and risk management and to review and update this information at least annually.
Under the current rules, a firm may omit one or more disclosures where the information provided by such disclosure is not regarded as material. As our services are offered to a very select set of customers and we are currently not marketing we do not disclose detailed information to the wider public.
The required Pillar 3 disclosures below apply solely to Macrocapital Limited as a legal, authorised and regulated by the Financial Conduct Authority, entity.
The company's risk management focuses on the major areas of market risk, operational risk and business risk. The management of the firm has sufficient experience to manage risks appropriately and has a compliance director who regularly monitors risk by reviewing reports prepared by external compliance consultants.
The company's capital comprises of called up share capital and the audited profit and loss account.
A summary of the company's capital is as follows:
Called up share capital 380
Revaluation reserve 42
Profit and loss account (251)
Total capital 172
Market, operational, and credit risk
The company is a small firm with a simple operational infrastructure and in the directors' opinion the simplified standard approach to credit, market, and operational risk is appropriate.
The company has assessed its Pillar 1 and Pillar 2 capital requirement to be £45K.
The Pillar 1 capital resource requirement is the higher of the base capital requirements (a fixed number equal to €50,000) and the variable capital resource requirements.
(The latter is the higher of i) the Fixed Overhead Requirement(13 weeks of the Firm’s annual expenses excluding variable costs.) and ii) the sum of the Credit Risk and Market Risk Capital Requirements-which are very small for our company.) .
III) Disclosure of commitment to the Financial Reporting Council's Stewardship Code ("The Code") under FCA COBS 2.2.3R.
Macrocapital Limited ("The Firm") is an investment manager based in the United Kingdom and authorised and regulated by the Financial Conduct Authority.
We endeavour to apply our approach on stewardship to all companies that we invest in on behalf of our clients. Our approach is consistent with the Firm's overall aims, which are to provide good long-term performance to our clients, and keeping clients' interests paramount.
The Firm monitors all investee companies as part of its general investment policy and approach. The Firm takes action in line with its investment objectives where its research of publically available information warrants such action.
However, given the nature of our chosen investment strategy, this approach does not include active engagement with UK listed investee companies, nor do we consider that our clients would expect such engagement.
If our investment strategy changes in such a manner that the provisions of the Code become relevant, the Firm will amend this disclosure accordingly.
IV) SFDR - Sustainable Finance Disclosure Regulation
SFDR aims to increase transparency on how financial market participants integrate sustainability into their investment decisions and recommendations. It introduces a classification system with new disclosure requirements for investment products.
The aim of SFDR is to promote transparency by ensuring that fund managers disclose their approach to sustainability. Macrocapital Limited will include disclosures on its website, in its managed account prospectuses and in its annual report. The implementation of SFDR and other related sustainable finance regulations is expected to run from 10 March 2021 until at least the end of 2022, meaning that Macrocapital Limited will continue to implement and provide more transparency in the years to come.
The SFDR applies to Macrocapital Limited because we manage managed accounts. We may also provide investment advice, which means we are a financial advisor for SFDR purposes.
Financial market participant Macrocapital Limited, with LEI: 213800OYOFGU1OAG2S92 does not consider principal adverse impacts of its investment decisions on sustainability factors.
All our discretionary strategies are based on technical driven trading on listed futures and options on equity indices or currencies. Having thoroughly establishes what the sustainability impacts would be of these strategies we have found they are none, particularly for the size of trades we place and the holding period. Furthermore, most of our strategies are very bearish. We believe we are looking at a very substantial correction and most likely a period of depression like the 1930's. where sustainability criteria will most likely not be sustainable and for now we are not looking to change that and integrate sustainability on our policies
The present statement is the consolidated principal adverse sustainability impacts statement of Macrocapital Limited. This principal adverse impacts statement covers the reference period from 1 January 2021 to 31 December 2022.
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Interests in any fund mentioned on this website, now or in the future, (a “Fund”) may not be purchased by US Persons as defined under Regulation S promulgated under the US Securities Act of 1933. The information and material on this website is not for distribution and does not constitute an offer to sell or the solicitation of any offer to buy any securities in the United States.
The information and material on this website is intended only for the person or entity to which it is addressed and may contain confidential and/or privileged material. Any retransmission, dissemination or other unauthorised use of this information by any person or entity is strictly prohibited.
The information and material on this website have been provided to you for informational purposes only and may not be relied upon by you in evaluating the merits of investing in a Fund. Information and material on this website are not intended as, and is not to be taken as, an offer or solicitation with respect to the purchase or sale of interests in the Funds, nor does it constitute an offer or solicitation in any jurisdiction, including those in which such an offer or solicitation is not authorised or to any person to whom it is unlawful to make such a solicitation or offer. Any decision to purchase interests in a Fund described on this website must be based solely upon the information contained in the prospectus of the relevant Fund.
The information on this website should not be considered to be legal or tax advice, and each prospective investor should consult with its own legal counsel and tax advisers as to all matters concerning an investment in shares in the Funds. Although the information in this website is believed to be materially correct, no representation or warranty is given as to the accuracy of any of the information provided. Certain information included in this website concerns economic trends and performance and is based on or derived from information obtained from sources considered to be reliable. Macrocapital cannot guarantee the accuracy of information, however and has not independently verified the assumptions on which such information is based. Furthermore, to the extent permitted by law, neither Macrocapital nor any of its agents, service providers or professional advisers assumes any liability or responsibility nor owes any duty of care for any consequences of any person acting or refraining to act in reliance on the information contained in this website or for any decision based on it.
You should always bear in mind that:
a) the value of investments and any income from them may go down as well as up. You may not get back all of your original investment.
b) past performance should not be seen as an indication of future performance.
c) indications of past performance displayed on this website will not necessarily be repeated in the future.
d) rates of exchange may cause the value of underlying investments to go up or down.
e) applications to invest in any product referred to on this website must only be made on the basis of the documentation relating to the specific investment.
If you are in any doubt about the information contained on this website please contact us or consult your usual professional financial adviser, if you have one.
Opinions and any other information on this website are provided by Macrocapital Ltd for personal use and informational purposes only. No information provided on this website in relation to any product or investment should be construed as advice to you on the suitability or otherwise of that product or investment for you or any other person, such suitability depending on all the circumstances of the person concerned. Nothing contained on the website constitutes investment, legal, tax or other advice nor is it to be relied on in making an investment or other decision. You should obtain relevant and specific professional advice before making any investment decision.
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You may download or print individual sections of the site for your personal use and information only provided that you ensure that all copyright notices and other proprietary notices are displayed on such downloaded or printed sections. You may not reproduce (in whole or in part), transmit (by electronic means or otherwise), modify, link into or use for any public or commercial purpose the site without the prior written permission of Macrocapital.
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This website, including information and materials contained in this website, text, graphics, software, links and other items are provided "as is", "as available". Macrocapital does not warrant the accuracy, adequacy, completeness, timeliness or availability of the information and data contained in this website, and expressly disclaims liability for errors or omissions in this website. There is no warranty of merchantability, no warranty of fitness for a particular purpose, no warranty of non-infringement, no warranty of any kind, implied, express or statutory, in conjunction with this website.
To the extent permitted by applicable laws and regulations, in no event will Macrocapital be liable for any damages, including, without limitation, direct or indirect, special, incidental, or consequential damages, losses or expenses arising in connection with this website or use or misuse thereof or the inability by any party to use such website, or in connection with any failure of performance, error, omission, interruption, defect, delay in operation or transmission, computer virus or line or system failure, even if Macrocapital, or representatives thereof, are advised of the possibility of such damages, losses or expenses.
As a condition of your use of this website, you agree to indemnify and hold harmless Macrocapital and its affiliates, and the directors and employees of Macrocapital and its affiliates from and against any and all liabilities, claims, damages, losses or expenses, including legal fees and expenses, (together, "Losses") arising out of your access to or use of this website, save to the extent that Macrocapital may not exclude or limit its own liability for such Losses pursuant to applicable laws or regulations.
This website is established in England by Macrocapital in accordance with and shall be governed by, and your browsing in and use of this website shall be deemed acceptance of, the laws of England and Wales. A condition of using this website is that in the event of any dispute or proceeding you irrevocably submit to the exclusive jurisdiction of the English Courts and waive any objection to proceedings in such courts on the grounds of venue or on the grounds that the proceedings have been brought in an inconvenient forum.
Macrocapital may revise these Terms at any time by amending this page. You are expected to check this page from time to time to take notice of any changes Macrocapital makes, as they are binding on you.
Each time you use this website, a condition of use is that you comply with the above Terms.