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THE FIDUCIA MASTERTRUST “Simply a Smarter Way to Invest” A Total Portfolio Management Service Fiducia Wealth Management Limited Dedham Hall Business Centre Brook Street, Dedham Colchester Essex CO7 6AD Tel: (01206) 321045 Fax: (01206) 321044 Email: [email protected] www.fiduciawealth.co.uk Fiducia Wealth Management Ltd is authorised and regulated by the Financial Services Authority CONTENTS

“Simply a Smarter Way to Invest” A Total Portfolio ...€¦ · “Simply a Smarter Way to Invest” A Total Portfolio Management Service Fiducia Wealth Management Limited Dedham

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Page 1: “Simply a Smarter Way to Invest” A Total Portfolio ...€¦ · “Simply a Smarter Way to Invest” A Total Portfolio Management Service Fiducia Wealth Management Limited Dedham

THE FIDUCIA MASTERTRUST

“Simply a Smarter Way to Invest”

A Total Portfolio Management Service

Fiducia Wealth Management Limited

Dedham Hall Business Centre

Brook Street, Dedham

Colchester

Essex

CO7 6AD

Tel: (01206) 321045

Fax: (01206) 321044

Email: [email protected]

www.fiduciawealth.co.uk

Fiducia Wealth Management Ltd is authorised and regulated by the Financial Services

Authority

CONTENTS

Page 2: “Simply a Smarter Way to Invest” A Total Portfolio ...€¦ · “Simply a Smarter Way to Invest” A Total Portfolio Management Service Fiducia Wealth Management Limited Dedham

Fiducia Wealth Management Ltd. Dedham Hall Business Centre, Brook Street, Colchester, Essex, CO7 6AD.

Fiducia Wealth Management Ltd. is authorised and regulated by the Financial Services Authority. FSA No. 408210.

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Section One

• Introduction to Fiducia Wealth Management Page 3

• The Fiducia Mastertrust explained Page 4

Section Two

• Risk profile methodology Page 9

• Portfolio construction and investment process Page 12

• Charges Page 16

• Summary of the key benefits Page 18

Section Three

• Transact - financial strength and client security Page 21

Appendix

• Effect of discounted fund management charges Page 28

• Glossary Page 29

Page 3: “Simply a Smarter Way to Invest” A Total Portfolio ...€¦ · “Simply a Smarter Way to Invest” A Total Portfolio Management Service Fiducia Wealth Management Limited Dedham

Fiducia Wealth Management Ltd. Dedham Hall Business Centre, Brook Street, Colchester, Essex, CO7 6AD.

Fiducia Wealth Management Ltd. is authorised and regulated by the Financial Services Authority. FSA No. 408210.

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SECTION ONE

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Fiducia Wealth Management Ltd. Dedham Hall Business Centre, Brook Street, Colchester, Essex, CO7 6AD.

Fiducia Wealth Management Ltd. is authorised and regulated by the Financial Services Authority. FSA No. 408210.

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FIDUCIA WEALTH MANAGEMENT LIMITED

Fiducia is a leader in the provision of independent wealth management and

offers a distinctive service to meet the particular needs of private clients,

business owners, family groups, trustees and charities.

We understand that those who have higher income, more affluence and

significant wealth or are concerned about succession issues require a special

quality and scope of advice in order to take account of their more complex

needs.

The key features of that service are:

• Putting clients’ interests first at all times,

• Commitment to holistic financial principles that encompass a total advice

service,

• The adoption of open architecture principles in order to provide a truly

independent and client focused investment service,

• The Mastertrust Investment Account - an actively managed, risk

controlled, personal portfolio which enables all current and future

investments to be consolidated and managed in accordance with each

client’s personal risk profile.

• Our ‘own brand’ Self Invested Personal Pension (SIPP) and Small Self

Administered Scheme (SSAS) developed in association with leading

independent pensioneer trustees, which enables us to provide a truly

bespoke service. Where property purchase is involved, valuers, property

managers, banks and solicitors are appointed to suit our clients’ needs and

preferences.

• A close working relationships with private banks, tax strategists, trustees,

fiduciaries, lawyers, accountants and property specialists.

The result is a complete, independent and locally based wealth management

service.

Page 5: “Simply a Smarter Way to Invest” A Total Portfolio ...€¦ · “Simply a Smarter Way to Invest” A Total Portfolio Management Service Fiducia Wealth Management Limited Dedham

Fiducia Wealth Management Ltd. Dedham Hall Business Centre, Brook Street, Colchester, Essex, CO7 6AD.

Fiducia Wealth Management Ltd. is authorised and regulated by the Financial Services Authority. FSA No. 408210.

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THE FIDUCIA MASTERTRUST

The Background

The concept of an integrated portfolio investment service can be traced back to the

development of ‘wrap accounts’ in the United States of America in the 1970’s, and the

equivalent ‘master trusts’ in Australia in the 1980’s.

There are a small number of companies in the UK that provide these electronic trading

and custodial platform facilities. We have undertaken due diligence in terms of

security, service and charges. At present, we actively work with three, which are:

• Investment Funds Direct, which is owned by Royal London.

• Integrated Financial Arrangements plc, otherwise known as Transact.

• Novia Financial plc.

The role they each fulfil is that of an execution only and custodial service, they do not

manage the client portfolios. Fiducia has its own investment management process and

is the investment adviser. The resulting buy or sell trades are then executed by the

platform on instruction.

In global terms, these accounts now hold hundreds of billions of investments and

pensions on behalf of private investors and the concept is being adopted on an ever

increasing global scale.

Page 6: “Simply a Smarter Way to Invest” A Total Portfolio ...€¦ · “Simply a Smarter Way to Invest” A Total Portfolio Management Service Fiducia Wealth Management Limited Dedham

Fiducia Wealth Management Ltd. Dedham Hall Business Centre, Brook Street, Colchester, Essex, CO7 6AD.

Fiducia Wealth Management Ltd. is authorised and regulated by the Financial Services Authority. FSA No. 408210.

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WHAT IS A TOTAL PORTFOLIO MANAGEMENT SERVICE?

It comprises a bespoke investment account that can hold virtually the entire range of

traditional investments – such as the following collective funds:

• Unit Trusts, OEICS and ICVCs

• Investment Trusts

• UK approved funds domiciled offshore

• Shares registered on a UK Stock Market

• UK approved Offshore Funds.

We are for the first time able to create a single investment account for each client

which specifically reflects their risk profile. With the benefit of open architecture, the

antidote to the packaged products manufactured by the big brands of financial services,

this personal portfolio is created and managed for all of each client’s planning needs.

This has allowed us to create a suite of financial planning wrappers which include:

• Onshore Investment Bond

• Offshore Investment Bond

• ISA account

• The full range of Pension Plans

• A full range of Self Invested Pension Plans (SIPP) and Small Self Administered

Schemes (SSAS)

• An extensive range of Trusts.

• Investment Trusts

• UK approved funds domiciled offshore

The technology of the custodians has been integrated with our own processes enabling

us to transform our back office and embrace the latest technology. This in turn enables

us to achieve greater efficiency and accuracy by eliminating third parties who add no

or little value.

Page 7: “Simply a Smarter Way to Invest” A Total Portfolio ...€¦ · “Simply a Smarter Way to Invest” A Total Portfolio Management Service Fiducia Wealth Management Limited Dedham

Fiducia Wealth Management Ltd. Dedham Hall Business Centre, Brook Street, Colchester, Essex, CO7 6AD.

Fiducia Wealth Management Ltd. is authorised and regulated by the Financial Services Authority. FSA No. 408210.

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WHAT ARE THE BENEFITS?

The Fiducia Mastertrust Account facilitates the consolidation of all existing,

uncoordinated, non-aligned investment assets and plans into a single integrated

investment account, which is a crucial development in the concept of holistic financial

planning.

We are able to work with each client to develop a personal portfolio style which

accurately reflects their financial objectives and risk profile.

That means one level of fees, one standard of paperwork and one point of contact.

Each client can check their portfolio on line whenever they wish. As a result, we are

able to spend more time adding real value for our clients and to help them focus on the

decisions that really matter.

It enables us to “un-bundle” individual investment plans and creates an “open

architecture” structure directly linked to each personal investment account. Clients

will still require tax based computations but those plans, which essentially deliver tax

based outcomes (such as ISAs and Pensions), are part of the overall financial planning

process no longer segregated arrangements, enabling reviews and decisions to be better

coordinated.

The single, overall investment strategy, reflecting the identified risk profile, can be

reviewed and the changes implemented at the same time for each of the underlying

plans. Fund selection is by our Risk Metrics analysis which considers all UK approved

funds in order to arrive at a “best of best” outcome.

Page 8: “Simply a Smarter Way to Invest” A Total Portfolio ...€¦ · “Simply a Smarter Way to Invest” A Total Portfolio Management Service Fiducia Wealth Management Limited Dedham

Fiducia Wealth Management Ltd. Dedham Hall Business Centre, Brook Street, Colchester, Essex, CO7 6AD.

Fiducia Wealth Management Ltd. is authorised and regulated by the Financial Services Authority. FSA No. 408210.

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HOW DOES IT WORK?

The Fiducia Mastertrust Account is a portfolio builder, dealing service and tracking

device combined into one. It is part software, part process and part management

expertise which consolidates every activity into one investment process, which is then

documented into one central, integrated report.

It can accept existing as well as new investments. Most existing investments can be

transferred to the Account usually by a re-registration process. The entry levels are

appropriate for the service being provided and do have flexibility.

Fiducia, in its investment management role, provides advice in terms of the overall

investment strategy. When decisions are agreed the custodian will undertake the

appropriate transactions on instruction from Fiducia.

Those funds are either retained in a General Investment Account or allocated to the

range of tax based plans, such as, ISAs, Onshore Bond, Offshore Bonds, the whole range

of Pensions etc.

There are two further facilities:

• The Account is also able to hold shares which are traded on any of the London

Stock Exchanges.

• A deposit account offering instant access and paying a competitive rate of

interest.

Formal valuations are provided every six months including an end of tax year

consolidated tax certificate to accompany the Self Assessment Tax Return. Each client

also has secure internet access, via their account and PIN numbers, providing daily

valuations and fund information on a personalised web page.

Page 9: “Simply a Smarter Way to Invest” A Total Portfolio ...€¦ · “Simply a Smarter Way to Invest” A Total Portfolio Management Service Fiducia Wealth Management Limited Dedham

Fiducia Wealth Management Ltd. Dedham Hall Business Centre, Brook Street, Colchester, Essex, CO7 6AD.

Fiducia Wealth Management Ltd. is authorised and regulated by the Financial Services Authority. FSA No. 408210.

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SECTION TWO

Page 10: “Simply a Smarter Way to Invest” A Total Portfolio ...€¦ · “Simply a Smarter Way to Invest” A Total Portfolio Management Service Fiducia Wealth Management Limited Dedham

Fiducia Wealth Management Ltd. Dedham Hall Business Centre, Brook Street, Colchester, Essex, CO7 6AD.

Fiducia Wealth Management Ltd. is authorised and regulated by the Financial Services Authority. FSA No. 408210.

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RISK PROFILE METHODOLOGY

We firstly assess each client’s risk profile which is a compromise between risk attitude

and risk capacity. To explain, risk attitude is a measurement of each client’s

willingness to risk a less favourable outcome in an attempt to achieve a more

favourable one – the “risk/return trade off”. Risk capacity however is about each

client’s ability to sustain a less favourable outcome without compromising their original

goals and objectives. Therefore, risk capacity is affected by:

I. time horizons, which can allow for the recovery of investment losses and,

II. total wealth, which can cushion the effect of a decline in portfolio value.

We take account of both factors and as a result the appropriate amount of risk is

generally the lesser of the two components.

Around fifteen years ago, academic studies on risk tolerance identified that, as with

intelligence and personality, this is a psychological trait, in other words one that

generally remains the same over time. This has led to an assessment process that meets

accepted psychometric principles.

In 1997 the School of Psychology at the University of New South Wales, Australia,

devised and tested a 25 point questionnaire.

This risk profiling model, known as FinaMetrica, is now widely recognized as a leading

risk profiling system and as a result we have adopted FinaMetrica as a key element of

our investment management process.

Page 11: “Simply a Smarter Way to Invest” A Total Portfolio ...€¦ · “Simply a Smarter Way to Invest” A Total Portfolio Management Service Fiducia Wealth Management Limited Dedham

Fiducia Wealth Management Ltd. Dedham Hall Business Centre, Brook Street, Colchester, Essex, CO7 6AD.

Fiducia Wealth Management Ltd. is authorised and regulated by the Financial Services Authority. FSA No. 408210.

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HOW FINAMETRICA IDENTIFIES EACH CLIENT’S RISK PROFILE

1. The Questionnaire

The questionnaire which consists of 25 questions takes around 15 minutes to

complete and generates a personal risk profile report.

2. The Risk Profile Report

Each client is notified of their outcome and an explanation of how to interpret

the result. The report also identifies the most appropriate risk group and

investment style by means of a scoring algorithm.

3. Identifying Future Goals and Setting Priorities

This is the holistic planning overview, establishing agreement on where clients

are today in financial terms, where they want to be in the future and their

priorities.

We also gather the relevant factual and aspirational information to qualify those

statements in terms of financial values and timescales. Once that is achieved and

agreed, there are clear and measurable objectives for the investment planning

process.

4. The Gap Analysis

The FinaMetrica questionnaire asks each respondent to indicate the level of

return they would expect their portfolio to earn, taken as an average over ten

years and expressed in relation to current deposit interest rates.

FinaMetrica is also able to generate the historical returns achieved for each of

the preferred portfolios, over the period from 1 January 1970 to date.

The results may highlight a gap between expectations and those historical

returns. In these circumstances there are various options that need to be

discussed, for example:

• To take more risk to try to achieve a better outcome

Page 12: “Simply a Smarter Way to Invest” A Total Portfolio ...€¦ · “Simply a Smarter Way to Invest” A Total Portfolio Management Service Fiducia Wealth Management Limited Dedham

Fiducia Wealth Management Ltd. Dedham Hall Business Centre, Brook Street, Colchester, Essex, CO7 6AD.

Fiducia Wealth Management Ltd. is authorised and regulated by the Financial Services Authority. FSA No. 408210.

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• To increase the sums being invested

• To modify goals or extend timescales

Of course, in the happy event that the historical returns exceed expectations,

risk can be reduced as can the level of investment; goals can be accelerated,

raised or added.

These discussions on the gap analysis are key to the process of managing

expectations, by directly relating the historical and forecast rate of realistic

return that flows from the identified risk profile to the goals and timescales that

have been set.

5. Obtaining Informed Consent and Commitment

This is essential before any plan is implemented. The Risk Profile report is an

objective, robust, plain-English assessment.

If, in developing specific recommendations, trade-offs are required:

• They will have been made knowingly

• The pros and cons of the options will have been clearly qualified

• The final decisions will be agreed and recorded

Conclusion - This logical, statistical, psychometric process creates the means to identify

each client’s risk profile and achieve agreement as to the basis of the specific planning

strategy and timescale to be adopted.

Page 13: “Simply a Smarter Way to Invest” A Total Portfolio ...€¦ · “Simply a Smarter Way to Invest” A Total Portfolio Management Service Fiducia Wealth Management Limited Dedham

Fiducia Wealth Management Ltd. Dedham Hall Business Centre, Brook Street, Colchester, Essex, CO7 6AD.

Fiducia Wealth Management Ltd. is authorised and regulated by the Financial Services Authority. FSA No. 408210.

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PORTFOLIO CONSTRUCTION AND INVESTMENT PROCESS

Risk Budgeting

The Risk Profile scores identified by FinaMetrica have enabled us to create six portfolio

styles:

• Cautious

• Prudent

• Balanced

• Growth

• Adventurous

• Bespoke.

Each of the portfolio styles has been carefully constructed to ensure that they are

aligned to the questions and outcomes of the FinaMetrica risk profiling questionnaire.

The degree of ‘risk’ taken within each style of portfolio is calculated directly from the

FinaMetrica questions and allows us to create a ‘risk budget’ for each of our portfolios.

The ‘risk budget’ is the maximum amount of ‘risk’ that we can expose each of the

respective portfolios to in order to achieve the rates of returns highlighted within the

FinaMetrica risk profiling questionnaire.

Asset Allocation

Asset allocation controls the risk in a portfolio; it creates diversification and ensures the

underlying investments do not have a high correlation in terms of their response to

particular market conditions. The overall objective is to achieve low correlation

especially within the low risk tolerance portfolios.

Inflation

Depending on the investment time scale, inflation can have a significantly adverse

effect by eroding the real value of investments. This is the major risk to capital left on

deposit. In the short-term i.e. 3-5 years, inflation is unlikely to have as great an impact

on capital values as volatility. However, over the longer term inflation is a greater risk

than volatility.

Page 14: “Simply a Smarter Way to Invest” A Total Portfolio ...€¦ · “Simply a Smarter Way to Invest” A Total Portfolio Management Service Fiducia Wealth Management Limited Dedham

Fiducia Wealth Management Ltd. Dedham Hall Business Centre, Brook Street, Colchester, Essex, CO7 6AD.

Fiducia Wealth Management Ltd. is authorised and regulated by the Financial Services Authority. FSA No. 408210.

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FUND SELECTION BY RISK METRICS

The objective is to identify and select the individual funds to be included in each

portfolio. The sophisticated investment software we use enables us to gain direct access

to over 25 years of historical fund price data, which is updated daily and analyse the

performance of over 14,000 onshore and offshore funds.

Our objective is to identify the ‘best of best’ funds based on both quantitative and

qualitative assessments.

We have created a Risk Metrics based filtering model to identify the best performing

funds measured in terms of their Alpha, Standard Deviation, Tracking Error and Sharpe

Ratio. This identifies the leading funds in each asset class and sector.

We then undertake qualitative research in which we take account of factors such as:

• Strength of the investment process for each fund and how long it has been in

place,

• Continuity of investment personnel,

• Investment style and whether it has proved durable over time,

• The clarity of the stated investment objectives,

• Strong and consistent past performance record,

• Favourable risk adjusted returns,

• The individual stock selection process.

In order to evaluate information on a uniform basis we ask each investment house to

complete a detailed questionnaire before any of their funds are considered for our

approved fund list. We also have regular ongoing contact with the Fund Managers and

their senior representatives.

All the funds on that list are subject to ongoing review, as are the model portfolios. We

apply the same process to funds not on our approved list to ensure we do not overlook

any funds that at some future time may meet our criteria.

The individual funds that make up our approved list are subject to review at least every

month and potential changes are considered by the Investment Committee.

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Fiducia Wealth Management Ltd. Dedham Hall Business Centre, Brook Street, Colchester, Essex, CO7 6AD.

Fiducia Wealth Management Ltd. is authorised and regulated by the Financial Services Authority. FSA No. 408210.

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Tax Planning

Once the portfolio risk profile has been agreed and the overall planning objectives

defined and prioritised, we are able to add further value by considering the best means

of mitigating or eliminating the payment of tax, whether personal income, capital

gains, inheritance or corporation tax.

The Mastertrust Account enables the funds to be applied in such a way as to achieve

the most tax effective outcome.

The overall effect is that the investment performance of the Mastertrust Account is

further enhanced by a separate layer of tax planning.

Page 16: “Simply a Smarter Way to Invest” A Total Portfolio ...€¦ · “Simply a Smarter Way to Invest” A Total Portfolio Management Service Fiducia Wealth Management Limited Dedham

Fiducia Wealth Management Ltd. Dedham Hall Business Centre, Brook Street, Colchester, Essex, CO7 6AD.

Fiducia Wealth Management Ltd. is authorised and regulated by the Financial Services Authority. FSA No. 408210.

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THE CHARGES

There is a transparent cost structure which is achieved by segregating the service into

its three separate components, as follows:

The Cost of the Investments - The Fund Managers

The Cost of Transactions - The custodial platform

The Cost of Advice - Fiducia

The Cost of Investments

These are the fees charged by the fund managers who manage the underlying assets.

Discounts are negotiated by the custodian produce significant savings on the initial and

annual charges that would otherwise apply. The level of discount is constantly being

extended as the total value of funds with each custodian continues to grow. All the

discounts are passed directly to the investors and in many cases funds are now bought

on Institutional terms with no initial charge.

The Cost of Transactions

Custodial platforms provide an execution only service for which a custody and

transaction charge is made. The charges for the selected custodial platform are referred

to within the illustrations provided at the time specific recommendations are made. In

addition to the transactional fees, there may be a facility administration charges for any

of the specialist wrappers that are appropriate to the planning.

The Cost of Advice

As Wealth Managers, our role is to devise, establish and manage each portfolio. The

process by which we establish each client’s risk profile, undertake fund research and

manage the ongoing investment advice has been referred to earlier.

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Fiducia Wealth Management Ltd. Dedham Hall Business Centre, Brook Street, Colchester, Essex, CO7 6AD.

Fiducia Wealth Management Ltd. is authorised and regulated by the Financial Services Authority. FSA No. 408210.

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That role requires not just technical, investment and tax knowledge but also a very

clear understanding of the individual circumstances, resources and future plans of each

client.

We do not take commission form any of the counterparties to the transactions. We are

paid by our clients for our services either from the portfolios or by a separate fee

arrangement.

Initial Fees discount

I. new funds up to £ 99,999 - 2.5%

II. £ 100,000 - £ 249,999 - 1.85% 26%

III. £ 250,000 - £ 499,999 - 1.50% 40%

IV. £ 500,000 - £ 999,999 - 0.95% 62%

V. above £1,000,000 - 0.60% 76%

This covers the meetings, analysis of existing arrangements, identifying, agreeing and

prioritising future planning, risk profiling, research, preparing, presenting and

implementing a financial plan.

Annual Fees

1% per annum of fund value. This covers the ongoing investment management service,

the annual investment performance review and recommendations, an annual meeting

to review the overall financial plan.

Total Typical Portfolio Charges

The overall initial and annual charges will vary slightly depending on the makeup of

each portfolio and the discounts obtained on the underlying fund management charges.

The figures shown on the next page are a guide and are based on our Balanced portfolio

as at January 2011.

Portfolio Values Total Initial Charge Total Annual Charge

I. £100,000

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Fiducia Wealth Management Ltd. Dedham Hall Business Centre, Brook Street, Colchester, Essex, CO7 6AD.

Fiducia Wealth Management Ltd. is authorised and regulated by the Financial Services Authority. FSA No. 408210.

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II £300,000

III £600,000

IV £1,000,000

Figures based on an average Investment fund initial of 0.17% and average AMC of

0.73% (See Appendix 2).

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Fiducia Wealth Management Ltd. Dedham Hall Business Centre, Brook Street, Colchester, Essex, CO7 6AD.

Fiducia Wealth Management Ltd. is authorised and regulated by the Financial Services Authority. FSA No. 408210.

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THE KEY BENEFITS OF THE FIDUCIA MASTERTRUST ACCOUNT

1. Investment Choice

Each client portfolio is able to invest in any UK registered Unit Trust, OEIC,

Investment Trust or approved onshore fund. It can also register any shares listed

on the London Stock Exchange, although Fiducia does not provide advice on this

class of asset.

2. Competitively Discounted Charges

Across all seven portfolios, the custodian facility charges are discounted

depending on the portfolio size. Our own charges for investment advice are also

discounted in line with valuations.

3. Daily Valuations

A current portfolio valuation is provided 24 hours a day via the custodian’s

website.

The portfolio valuation will show the total value of the portfolio, the value of

each sub-account and the value of the individual investment funds held within

each account plus the percentage movement in value since the fund was bought.

4. Records

Records of all transactions, including fees and other deductions can also be

viewed on line. At the end of each tax year each client will receive a

consolidated tax statement for both income tax and capital gains tax.

This means it is not necessary for clients to maintain their own records.

5. Periodic Reporting

• Portfolio valuation

• Cash account summary

Page 20: “Simply a Smarter Way to Invest” A Total Portfolio ...€¦ · “Simply a Smarter Way to Invest” A Total Portfolio Management Service Fiducia Wealth Management Limited Dedham

Fiducia Wealth Management Ltd. Dedham Hall Business Centre, Brook Street, Colchester, Essex, CO7 6AD.

Fiducia Wealth Management Ltd. is authorised and regulated by the Financial Services Authority. FSA No. 408210.

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As at 5th April annually

• Portfolio valuation report

• Statement of transactions

• Cash account summary

• Full dividend statement

• Tax voucher (if applicable)

• Realised Capital Gains Statement (if applicable)

6. Linked accounts for discount purposes

As the value of the invested funds grows there are automatic reductions in the

annual management charge made by the custodian who will also allow family

members and relatives who reside at the same address to have their portfolios

linked to one another for charging purposes, which means the entire family

group benefits from lower charges.

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Fiducia Wealth Management Ltd. Dedham Hall Business Centre, Brook Street, Colchester, Essex, CO7 6AD.

Fiducia Wealth Management Ltd. is authorised and regulated by the Financial Services Authority. FSA No. 408210.

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SECTION THREE

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Fiducia Wealth Management Ltd. Dedham Hall Business Centre, Brook Street, Colchester, Essex, CO7 6AD.

Fiducia Wealth Management Ltd. is authorised and regulated by the Financial Services Authority. FSA No. 408210.

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INTEGRATED FINANCIAL ARRANGEMENTS PLC

[1] FINANCIAL STRENGTH AND CLIENT SECURITY

[1.0] INTEGRATED FINANCIAL ARRANGEMENTS PLC

Integrated Financial Arrangements plc (“IntegraFin”) was incorporated in 1999 and has

offered the Transact wrap service since 2000. It has net assets of more than £12.9

million, based upon the September 2007 audited accounts and, at the time of writing

(October 2008), its funds under direction exceed £5.5 billion. IntegraFin’s Board has

been careful to ensure that the holders of the company’s voting shares do not include in

their number any institution that could be seen to be competing with the company or

the advisers with whom it deals. As a result, no UK financial services product provider

or fund manager has a shareholding, and the register comprises mainly private

individuals.

IntegraFin has made profits in every month since June 2003; an achievement unusual

so early in the life of a new financial services company. Indeed, it has paid dividends to

shareholders in 2007 and 2008.

In addition to the standard visits and reviews by the relevant regulatory bodies,

IntegraFin has been the subject of independent financial strength and due diligence

reviews conducted by private capital investors, the Association of Investment Trust

Companies (on behalf of its members) and consulting actuaries AKG (on behalf of two

IFA networks). It has satisfied all parties.

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[1.2] REGULATORY STATUS & CAPITAL ADEQUACY

IntegraFin is authorised and regulated by the Financial Services Authority (“FSA”). It is

authorised, amongst other things, to:

· hold client money;

· hold customer assets; and

· pass and execute customer orders.

As part of FSA regulation, IntegraFin has to maintain a designated level of capital

adequacy. This requirement applies to all similar FSA regulated companies and is

designed to protect investors by ensuring that enough capital is reserved to allow the

FSA to supervise a suitable transfer of the business should there be a need to do so.

Based upon the audited FSA return for the year ending September 2007, IntegraFin’s

qualifying capital is more than £3.9 million above the designated requirement.

Additionally, as part of FSA regulation, IntegraFin’s executives and relevant senior

employees have to be assessed and found to be of good character and appropriately

experienced for the nature of the company's activities. The FSA also has powers to

undertake supervisory visits to our premises.

Over and above the standard programme of visits by the FSA, and IntegraFin’s own

programme of compliance work, IntegraFin has appointed external auditors to conduct

a programme of regular compliance monitoring of Transact’s systems and procedures.

The reports from these audits go directly to the board and are available for review by

the FSA.

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[1.3] PROCEDURAL CONTROLS

Internal procedures are designed to protect investor assets.

Upon opening a Transact portfolio, every investor nominates a bank account into

which they wish all payments from their portfolio to be made. This is the only account

into which any cash withdrawal from a Transact Portfolio can be paid and, although

investors are able to request transactions via the web, they can only change this

nominated account with an original “wet signature” request to IntegraFin.

Client Services Managers (the people responsible for the maintenance of clients’

Portfolios) are segregated from Investment Accountants (the people who handle

clients’ assets). The processes resulting from this segregation limit in number those who

have access to the various stages of a withdrawal payment such that any client payment

or withdrawal goes through at least three levels of access (and individuals) before the

resultant payment is made. IntegraFin has implemented more than just the regulatory

minimum series of checks and balances to ensure the protection of investors' assets.

[1.4] SYSTEMS SECURITY

IntegraFin has security in place to protect its systems from attack. Transact-Online, our

website is protected by two firewalls and all user PCs have anti-virus software installed

which is updated at least weekly.

[1.5] DISASTER RECOVERY

IntegraFin has a disaster recovery plan in place to enable it to restore operations in the

event that their premises are destroyed or become inaccessible because of a disaster.

Critical to this is the remote back up strategy which has full copies of all systems and

the data which is created daily which is stored off site in London and in Melbourne,

Australia.

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[2] CLIENT ASSET PROTECTION & COMPENSATION

[2.1] CUSTODY

IntegraFin has a wholly owned subsidiary called Transact Nominees Limited:

• whose business is limited solely to the holding of investments or activities

directly related to the holding of investments; and

• in whose name all investments belonging to its clients are registered as

nominee.

While Transact Nominees acts as a registered holder of title to investments, it retains

physical custody of almost no client assets as:

• client monies are held by FSA authorised banks in IntegraFin's name;

• almost all client assets are dematerialised (i.e. not held in a physical form);

and

• paper certificates are only held temporarily at IntegraFin’s premises (pending

dematerialisation).

IntegraFin’s activity is restricted to the maintenance of the registers detailing client

holdings and directions to buy and sell the assets according to client instructions.

This arrangement ensures that there is a clear and distinct separation of those assets

relating to Transact clients and those that are IntegraFin’s own business assets.

[2.2] THE FAILURE OF INTEGRAFIN

In the unlikely event that IntegraFin, or one of its group companies, should fail, the

segregation of client assets from company assets means that the vast majority of client

assets could be transferred back to clients “in specie”.

In the even more unlikely event that this process could not occur, investors may be

entitled to redress under the Financial Services Compensation Scheme (FSCS), or, in

the case of IntegraLife International Ltd, through the Isle of Man Government

Insurance & Pensions Authority under the Compensation of Policyholders Regulations

(IOMIPA).

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We have been advised that the levels of compensation offered by these schemes are as

follows:

(a) FSCS for investments (GIA and Stocks and Shares ISA) - a maximum of £48,000 per

claim. This is made up of 100% of the first £30,000 and 90% of the next £20,000.

(b) FSCS for cash - if cash is held for investment business purposes (i.e. pending

investment), the FSCS would consider those investment funds to be an “investment”

loss and the investment compensation limit of £48,000 would apply. However, in all

other circumstances (including in Cash ISA deposits) cash is treated simply as cash and

would be subject to a £50,000 limit per client.

(c) FSCS for life policies (Personal Pensions & Onshore Bond) – a maximum of

100% of the first £2,000 and 90% of the unlimited remainder.

(d) It is our understanding that smaller occupational pension schemes, namely our

Executive pension plan (as a single member money purchase arrangements and our S32

contract, (now registered pension schemes), will fall within the remit of the protection

offered by the FSCS to personal pensions (as set out above).

(e) IOMIPA (Offshore Bond) – a maximum of 90% of the liability arising at the time of

the claim.

IntegraFin also has indemnity and fidelity insurance in place to protect investors' funds

in the event of misfeasance or defalcation.

[2.3] THE FAILURE OF BANKS

IntegraFin is required to treat all money held by it on any client’s behalf in accordance

with the rules set out in the FSA’s Handbook.

Our policy is currently to hold client money (“cash”) at a minimum of four FSA

authorised UK banks in client money accounts that comply with all the relevant

regulatory requirements for such accounts. At all times, at least two of these accounts

are established with full operational (rather than just deposit) functionality. This

ensures that there is always a fall-back position to protect both transactional

capability and liquidity.

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Each client’s cash is required to be held proportionally across all of our client money

accounts. Should any of these banks not be able to return deposits on a permanent basis

in circumstances when a claim could be made to the FSCS, then a limit of £50,000

would apply per client per bank.

Cash held in the Transact Onshore and Offshore Bonds is not protected under the FSCS

in the event of the failure of an underlying bank deposit. In the case of the Offshore

Bond, this is because the FSCS does not apply to offshore business. In the case of the

Onshore Bond, this is because the life company providers of UK life policies which do

not include a trust element (which means all onshore bonds) are not eligible claimants.

Instead, protection is provided to each wrapper in the circumstances and to the extent

described at [2.2(c)] and [2.2(e)] above.

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APPENDIX

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Appendix 1 – Effect of discounted fund management charges

An example of IFDL Succession discounted terms based on our Balanced Portfolio as at

March 2011.

Standard

Initial

Charge

Standard

Annual

Charge

Negotiated

Initial

Charge

Negotiated

Annual

Charge

0.00 0.00 0.00 0.00

3.00 1.00 0.00 0.50

0.00 0.50 0.00 0.48

3.00 1.00 0.00 0.50

5.00 1.25 0.00 0.63

3.75 1.50 0.00 0.75

4.00 1.50 0.00 0.75

4.00 1.50 0.00 0.75

4.00 1.50 0.00 0.75

5.25 1.50 0.00 0.75

5.25 1.50 0.00 0.75

5.00 1.50 0.00 0.75

4.00 1.50 0.00 0.75

4.25 1.50 0.00 0.75

4.00 1.50 0.25 0.75

4.00 1.00 0.00 0.75

4.00 1.50 0.00 0.75

5.00 1.50 0.00 0.75

4.25 1.50 0.00 1.00

0.50 1.50 0.50 1.50

4.00 1.50 0.00 0.75

5.25 1.75 0.00 0.88

5.00 1.50 0.00 0.88

3.76 1.33 0.02 0.73

Cash Deposit

M&G UK Inflation Linked Corporate Bond A Acc

Standard Life Inv Global Index Linked Bd Inst Acc

M&G Strategic Corporate Bond A Acc

Invesco Perpetual Tactical Bond Acc

Threadneedle Emerging Market Loc Ret Net Inc 1 GBP

M&G Global Convertibles Fund GBP A Acc

Invesco Perpetual Japan Acc

Aberdeen Emerging Markets A Acc

Insight -Absolute Fund of Funds A Acc GBP

Standard Life Inv Glo Abs Ret Strategies Inst Acc

Newton Real Return A GBP Inc

Schroder Global Property Securities A Acc

Ignis UK Property Acc

Invesco Perpetual High Income Inc

M&G Recovery A Acc

Aberdeen World Equity A Acc

M&G Global Basics A Acc

First State Global Listed Infrastructure Acc A

BlackRock Gold & General Acc

Allianz RCM Global Agricultural Trends - A - GBP

Newton Global Higher Income Inc

HG Capital Trust

Simple Average of Fund Charges

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Appendix 2 - Glossary

Alpha: This is a measurement of how well a fund has outperformed its benchmark.

Risk Metrics: The process by which funds are assessed as measured by the level of risk

undertaken by a fund manager. Risk metrics usually analyse the performance of a fund

to a relevant benchmark index over a defined 36 month period.

Sharpe Ratio: This is a measurement of a fund’s performance in accordance to the level

of risk taken.

Standard Deviation: This measures the volatility of returns over a defined period of

time.

Tracking Error: This describes the volatility of the difference in returns between a fund

and its benchmark.