| Country Manuals Independent Portfolio Manager/Advisor (EAM) GIBRALTAR OUT OF COMPANY’S COUNTRY OF ESTABLISHMENT (Def, RS & BT) Regulatory Summary We have reviewed and updated the documents to take into account an evolving interpretation of the regulatory framework and can confirm that there have been no relevant regulatory changes since the last publication of this Country Manual. The wording in the RS has been revised and simplified. Behaviour Template We would point out the following: (1) For onsite socialising and provision of business cards the answers are Grey zone/YES to emphasise that onsite activity should be on an occasional basis. (2) The answers for providing investment advice by remote means based on an ongoing investment advisory agreement are now Grey zone/Yes to emphasise that this is tolerated practice and is permissible only to the extent that any recommendation is in relation to a financial instrument covered by the agreement and is in accordance with the risk profile of the client. Non-material changes (1) In a number of instances the comments for Grey zone/YES have been changed to reflect standardised comments that BRP has adopted as a result of using a new editing platform for the creation of manuals. The underlying reasoning has not changed. (2) Several comments have been slightly reworded (without introducing material changes) to reflect the regulatory situation/current interpretation of the regulatory framework more accurately. BT Short Comparison BRP has created a comparison document allowing users to quickly identify the modifications made compared to the previous version of the PB Manual (BT Short Comparison). The BT Short Comparison can be found on BRP’s platform (mybrponline) in the Search tab by entering in the Document Field “CM EAM BT SHORT COMP” and “GIBRALTAR” in the Target Country Field. The BT Short Comparison should be read as follows: The first column contains a short description of the activity in question. The second column contains the answers of the previous version of the Country Manual (online until the day of the alert). The third column contains the new answers of the most recent version of the Country Manual. Only the modified answers are displayed (in color). If the answers in the new version are unchanged compared to the previous version, they are shaded in grey. Best regards, |
