Country Manuals Independent Portfolio Manager/Advisor (EAM)
BRP SA is glad to announce the publication of its COUNTRY MANUAL INDEPENDENT PORTFOLIO MANAGER/ADVISOR for the following jurisdiction:
– LEBANON OUT OF THE COMPANY’S COUNTRY OF ESTABLISHMENT (Def, RS & BT)
Regulatory Summary
Material changes
This document has been entirely reviewed with the help of our local lawyers in order to reflect an evolution in the interpretation of the legal and regulatory framework, in particular, with regard to the following:
– The exemption granted to “Approved Institutions” (qualified clients) in Series 2000 Licensing and Registration Regulation regarding advertisement and marketing activity applies only to investment and not to banking activities. Consequently, it is no longer possible to actively introduce a third-party foreign custodian bank’s custody services, or to collect relevant supporting documents, e.g. ID or KYC, even when dealing with qualified clients. This is however possible upon a client’s request;
– It is still permitted to provide investment advice to qualified and non-qualified clients based on an ongoing advisory agreement. However, any transaction under such an agreement must be carried out by the foreign bank based on an express instruction from the client.
Non-material changes
Some comments have been slightly reworded (without introducing material changes) to reflect the regulatory situation/current interpretation of the regulatory framework more accurately.)
Behaviour Template
The answers in the BT have been aligned to those contained in the RS.
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 “LEBANON” 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,