Country Manuals Independent Portfolio Manager/Advisor (EAM) –
We would like to inform you that BRP has updated its COUNTRY MANUALS INDEPENDENT PORTFOLIO MANAGER/ADVISOR for the following jurisdictions:
JERSEY OUT OF COMPANY’S COUNTRY OF ESTABLISHMENT (Def, RS & BT)
Regulatory Summary, Behaviour Template
Material changes
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 significant regulatory changes since the last publication of this
Country Manual.
We would point out the following:
(1) For onsite socialising and provision of business cards the answers are now Grey zone/YES to emphasise that onsite activity should be on an occasional basis.
(2) For provision of marketing brochures on a reverse solicitation basis the answers are now Grey zone/YES to emphasise that local advertising rules should be complied with.
(3) For gathering information for investment profiles the answer has changed from YES to Grey zone/YES to emphasise that local advertising rules should be complied with.
(4) For receipt of unsolicited brokerage orders in Jersey it is assumed that such orders are passed to the Bank’s country of establishment for execution.
(5) For reporting of performance for managed accounts the reference to local deposit adverting rules has been removed as this is not relevant. The answer for such activity by remote means is consequently changed from Grey zone/YES to YES.
Non-material changes
The documents have been reformatted onto the latest templates. Further non-material changes have been made throughout the documents. For streamlining purposes, several BT conditions have been reworded without introducing material changes.
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 “JERSEY” 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 coulor.
Best regards,