The FSA is currently looking at the promotion and advice process in respect of unregulated collective investment schemes and is sending out letters (which will refer to an on-line questionnaire) to a sample of firms.
It is assumed that the targets are High Street financial advisers rather than the asset managers of offshore Hedge Funds who are also involved in the promotion of such funds.
However the filtering process is unclear e.g. whether firms without ‘Retail’ on their Part IV will be excluded; whether the trigger is simply the activity of ‘advising’ coupled with investment instrument ‘unit’ etc.
In any event, firms may feel it worthwhile revisiting their financial promotions procedures and in particular for compliance with COBS 4.12.
