Update BRP Country Manual Asset Management
Costa Rica
BRP has published its latest update concerning
the Country Manual Asset Management
for Costa Rica
| SOURCE OF CHANGES | ANSWERS |
|---|---|
| Law/Regulation | No |
| New Position of the Authorities | No |
| Evolution of Expert’s interpretation | Yes |
Definitions & Concepts, Regulatory Overview and Behaviour Template
Material changes
The changes/modifications are as follows:
Brand advertising (without mentioning specific information about strategies, financial products and/or investment services) is not per se a licensable activity and is therefore permitted. The Country Manual Asset Management Behaviour Template (CM AM BT) therefore now provides the answer “YES” in all scenarios. However, foreign (non-licensed) investment firms must be careful not to mention or provide any information about specific investment services and/or financial products.
In addition, the provision of macroeconomic analysis and financial research (without mentioning specific information about strategies, financial products and/or investment services) is not explicitly regulated in Costa Rica, provided that the information is only generic and does not constitute an advertisement or offer of personalised investment advice, and is therefore now also permitted (without restriction) onshore in Costa Rica (at target), if conducted indirectly via/with locally licensed intermediaries/distributors. Accordingly, the CM AM BT provides the answer “YES” for the relevant onshore scenario.
The same applies to the (active) marketing of services and mandates by a foreign (non-licensed) investment firms. This is now permitted without restriction onshore in Costa Rica (at target) if conducted indirectly via/with locally licensed intermediaries/distributors. The CM AM BT therefore also provides the answer “YES” for the relevant onshore scenario.
Non-material changes
Some comments and content have been slightly reworded in the CM, without introducing substantive changes to reflect the regulatory situation/current interpretation of the regulatory framework more accurately.
For more information, please contact us: info@brpsa.com
Geneva, January 10th, 2025