Our last post focussed on how a manager using a UK MiFID licence to market EU funds may continue to do so post-Brexit. We now turn our attention to how a manager relying on a UK MiFID licence to operate individually managed accounts may continue to do so.

Business as Usual for Separately Managed Accounts

You are an investment manager using a MiFID licence in the UK to run separately managed accounts. As things currently stand, there is a good chance that come March 2019, you will fall outside the MiFID regime and alternative arrangements will need to be made.

You could set up an EU 27 regulated MiFID firm, AIFM or UCITS management company, although as mentioned in our last post, this will involve a lengthy approval process, significant substance requirements and associated costs.

Again, a more efficient solution would be to utilise the permission of an existing management company to manage the accounts. If you have your own EU 27 management company you could simply use this permission and of course, if not, enlist the services of a third-party management company.

The third and possibly most straight forward option is to appoint an existing third-party EU 27 MiFID firm. This option should be familiar to those managers based in the UK but is less common throughout the rest of the EU.

Carne is here to help in any of the above scenarios. We operate regulated management companies in both Ireland and Luxembourg with well over 100 employees across the two jurisdictions. We also provide substance to management companies in Ireland and can support management companies and MiFID firms in both Ireland and Luxembourg generally.

Finally, Carne will soon be able to assist clients further by managing accounts on their behalf through its own MiFID entity.

Next, we will look at challenges of accessing the UK investor market.