Pillar III Disclosures 2022

1. Introduction

Daintree Wealth Management Limited is a private client wealth management firm, authorised and regulated in the United Kingdom by the Financial Conduct Authority (‘FCA’).

Under the FCA’s Prudential Sourcebook for Banks and Investment Firms (‘BIPRU’), Daintree Wealth Management Limited is classified as a BIPRU €50K Limited Licence investment firm. As such, it is required to comply with the three “Pillars” of the EU’s Capital Requirements Directive (‘CRD’) framework. These are:

Pillar 1, which sets out the minimum amount of capital the Firm needs to meet its regulatory requirements;

Pillar 2, which requires us and our regulatory supervisors to consider the requirement to hold additional capital against risks not covered in Pillar 1. In the UK, this is implemented through the Internal Capital Adequacy Assessment Process (“ICAAP”) undertaken by Daintree Wealth Management Limited, and by the FCA through the Supervisory Review and Evaluation Process (“SREP”);

Pillar 3, which requires us to disclose to market participants key information about our underlying risks, risk management controls and capital position.

The purpose of this document is to meet our obligation in respect of Pillar 3.

2. Disclosure Policy

Daintree Wealth Management Limited is a directly authorised discretionary fund management and financial advisory company.

Daintree Wealth Management Limited makes Pillar 3 disclosures on at least an annual basis, as soon as practicable following the end of our Financial Year. These are provided on our corporate website, www.daintreewm.com . Under the rules of BIPRU 11, the firm may omit certain information from the Pillar 3 disclosure, in specifically defined circumstances, where it believes that the disclosure contains information that is immaterial, proprietary or confidential. We confirm that we have not omitted any disclosures on these grounds.

All figures in this document are correct at 31st September 2022 unless stated otherwise.

3. Risk Management Policies and Objectives

Risk Appetite

Our interpretation of risk appetite is how comfortable would we be if a risk were to emerge. This is quite a subjective analysis, however, it does gauge how the Board is feeling about the risks within our firm.

The current view is that the Board are relatively comfortable with the key risks potentially affecting the Firm, but we will keep this in view on an ongoing basis.

The Board will review the overall effectiveness and relevance of the Firm’s system and controls for each financial year. The Board will also carry out an evaluation of the major risks affecting the business and the processes in place within the business to control and monitor such risks on an ongoing basis. On this basis the Board will report and disclose its findings and whether it believes that all necessary actions have been, or are being, taken to remedy any significant failings identified as part of the ongoing risk management process and that no significant weaknesses were identified during the year.

The Firm’s activities are non-complex and the Firm does not hold client money or assets or trade on its own account.

Risk Management Framework

In order to ensure that the Daintree Wealth Management Limited regularly reviews and monitors all the potential areas of risk to the business, the Firm has put in place a risk management framework which enables all senior management and any relevant committee and the Board to be kept fully informed of any potential risks to the business and also how those risks might impact the group’s capital adequacy position.

A Risk Matrix has been designed which captures the core fundamental risks inherent in the firm and assesses how those risks are managed and mitigated, the key indicators that would suggest if the risk is likely to materialise together with an assessment that each risk may have on the Firms regulatory capital. This is the core assessment of the Pillar 2 requirements.

A thorough Compliance Monitoring Programme (“CMP”) is managed via an annual programme of reviews. Details of the CMP and the current status are provided to the Board on a regular basis, with any material issues being escalated to the Board immediately they are identified.

The CMP also includes undertaking stress and scenario testing of its key risks to determine the impact to our current and future profitability and balance sheet.

The key risk exposures the Firm faces and the mitigating controls in place are listed below:

Credit Risk

The value of the assets that we manage or advise upon could reduce for a variety of reasons, including the loss of clients and a reduction in the value of a clients’ portfolio either due to market movements or poor portfolio performance. The highest potential risks are:

Loss of Clients – The firm has a diverse client base for our discretionary managed clients. We currently have 216 client relationships with 302 active accounts. The current average client size across all portfolios is £255,000. Client relationship management and retention is at the very centre of operations. Should a client be deemed to be ‘at risk’ a formal action plan would be managed to prevent the loss of the client.

Poor relative performance is monitored and reported on an ongoing basis. Should the performance be such that either we or the clients were unhappy with portfolio performance, we would instigate a formal action plan, as discussed above.

Operational Risk

The risk resulting from inadequate or failed business processes and systems. Daintree Wealth Management Limited seeks to monitor potential sources of errors arising from its operations and continually strengthen our internal systems and processes, supervisory and oversight functions to reduce our residual risk exposure. The Firm maintains resilient infrastructure, and regularly tests its Business Continuity and Disaster Recovery arrangements to limit the impact of potential external events. Additionally the Firm maintains comprehensive Professional Indemnity Insurance cover to cap our exposure to potential large claims or operational losses.

There are two registered investment managers, who act as a contingency for each other. The Chief Investment Officer maintains a buy list with target prices for all holdings and potential holdings, to assist with any transitional phase, should that be required.

Liquidity Risk & Market Risk

Reduction in Portfolio Values – The two principal reasons for a reduction in the value of a clients’ portfolio, would either be adverse market movements or poor relative investment performance. We have modelled the impact of a downturn in the markets, with the result that our assets under management/advice could fall by 41% before ongoing profitability were to fall into a loss-making situation. Our current view is that such a market correction is unlikely.

The key liquidity requirements within the firm are the cashflows within the business and how a non-receipt of funds may significantly impact the firm.

At present the firm is not materially reliant on any one client for income (materiality is defined as any exposure to one client which may impact by the balance sheet by more than 10%).

Business Risk

The firm has undertaken an analysis of how a significant increase, or decrease, in business volumes may impact the firm. It is envisaged that the client base of approximately 216 clients, could more than double before the principal of the firm would require any assistance in managing those relationships.

4. Business Strategy

The mission of Daintree Wealth Management is to provide the highest standards of advice, discretionary investment management and service to its clients. We wish to establish a successful partnership with our clients, our staff and product providers that respect the interests and the goals of each party.

We strive to maintain and increase our current customer base by providing our services in a manner whereby the fair treatment of customers is consistently at the heart of the business.

Success is measured by our clients choosing us above the competition because of their belief in our ability to meet or exceed their expectations on cost, service and expertise.

5. Capital Resources

As at 31st September 2022 the firm’s Capital Resources are expected to be £288k which cover a capital adequacy requirement of approximately £145k. This provides a surplus of £143k. (This is taking into account a conservative estimate of net profits for 2022).

The following table itemises the components of the Capital Resource Requirement, the Firm’s Pillar 2 current Capital figures and the Total Capital and Surplus.:

Capital RequirementsDate: 31 September 2022
Fixed Overhead Requirement£117k
Base requirement£84k
Credit Risk£0
Market Risk£0
Pillar 1 total£117k
Wind Down Analysis£28k
Pillar 2 Total£28k
Pillar 1 and Pillar 2£145k
Current Total Firm Capital£288k

It is anticipated that there will not be any material changes to the firm’s regulatory capital requirement. Should there be any changes, these will be considered carefully and documented within this document.

6. Remuneration Code

SYSC 19F, which came into force on 1 January 2018, requires that where remuneration arrangements have the potential to create material conflicts of interest between individuals and Clients:

(a) Incentives must not be solely or predominantly based on quantitative commercial criteria, and must take fully into account appropriate qualitative criteria reflecting compliance with the applicable regulations, the fair treatment of clients and the quality of services provided to clients.

(b) A balance between fixed and variable components of remuneration must be maintained at all times, so that the remuneration structure does not favour the interests of the firm or its relevant persons against the interests of any client.

SYCS 19 requires Daintree Wealth Management Limited to implement remuneration policies and procedures consistent with sound risk management and which do not incentivise staff to take risks outside the Company’s risk profile.

In line with FCA Rules and Guidance, Daintree Financial Management Limited has deemed that it does not need to comply with the prescriptive quantitative requirements in SYSC 19C on variable remuneration as these are not appropriate to the nature scope and complexity of its activities. Nevertheless, Daintree Wealth Management Limited has adopted a remuneration policy (“the Remuneration Policy”) that covers all aspects of staff reward, including all fixed and variable components of remuneration, such as salaries, pensions and other benefits. The Policy is intended to incentivise and reward performance and encourage staff retention, but to do so in a manner that:

a) Is consistent with, and promotes sound and effective risk management;

b) Does not encourage risk-taking which is inconsistent with the risk profiles of the Company or its clients; and

c) Does not impair our compliance with our duty to act in the best interests of clients.

The Policy comprises a number of interlinked components, which are applied depending on the level of an individual’s seniority within the business:

Annual Pay Review – Awards are based upon the job evaluations and with reference to market rates.

Annual Bonus (Short Term Incentive Compensation) – Awards are based on a combination of Company and Personal Performance factored against market rates. Company results adjust the level of personal performance awards available based upon agreed business measures such as New Money, Assets, profit and loss, customer scope, expenses etc.

All staff performance measurement is subject to qualitative as well as quantitative commercial criteria and at least one performance measurement for all staff must be linked to risk control

Code Staff

FCA BIPRU Remuneration Code staff comprises categories of staff including senior management, risk-takers, staff engaged in control functions and any employee receiving total remuneration that takes them into the same remuneration bracket as senior management and risk-takers, whose professional activities have a material impact on the firm’s risk profile.

In line with the requirements of the Code, Daintree Wealth Management Limited has identified the key individuals in the firm who act either as senior managers, risk takers or control functions. These individuals are nominated “Code Staff”.

There is 1 Code staff where the aggregate remuneration expenditure in respect to Code Staff as at 31st September 2022 was as follows: £140,000.