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Thanks for your email & assistance.
How long do you think it will take to receive an answer?
Yes, I am happy to wait for an answer.
Thanks for your response. Here are the answers:
I can either hold client funds in
a) In one of my own designated accounts (based in a bank in the UK)
b) In an account offshore
c) my broker is based in Europe so active invested funds are held with them.
The algorithm is written by me/colleague. I work in the derivatives industry and I am a software engineer by trade with 15 years experience. (Hence why I am clueless of the legal issues.)
Any offshore jurisdiction that has a stable political regime. Anywhere in Europe or even Asia.
Apologies if my answers seem generic and open. It is just I want to be flexible to find the easiest way to set this up. Also it should give you more options to work with.
I would say both. We would want to target high net worth investors as well as consumer market. .
In the general consumer market, the average person has no idea about an ETF or a index tracking fund. So we would want to help them make the right decision.
No worries. Please take your time. I am in no rush :-)
Thanks for your response. I will approve your answer.
Just few points:
Would you know what is the minimum requirement to become FCA regulated for this type of activity? e.g. qualifications required.
And also what the cost of this would be?
One last question after discussing with my colleague.
If we built the product itself, without being regulated say. And setup the company offshore. And we did NOT advertise to a UK consumer. But one day ...a UK consumer signed up organically to the website via stumbling on our website via word of mouth or a google organic search. So they stumbled on it discreetly and signed up to use the product (the product was not advertised). Is that fine and legal? (we could have a gentlemans agreement contract on the website).
Because in your last email you said
"Without having FCA authorisation you will not be able to sell any financial products to your average consumer."
"Offshore - The only issue is you would still be prohibited from advertising this investment openly to UK Consumers. Any selling of the product would have to be discreet."
So what the above implies is...if we are not regulated and someone in the UK lands on the site and signs up discreetly, then this should be fine. However if someone in the UK lands on the site and signs up via an advertisement we created... than this would be illegal.