Background
This is the disclosure made in accordance with the UK Financial Conduct Authority (FCA) The Prudential sourcebook for MiFID Investment Firms (MIFIDPRU). The rules in MIFIDPRU provide that as a Small Non-Interconnected firm (SNI) we must disclose the matters set out below. the firm may omit one or more of the required disclosures if it believes that the information is immaterial. Unless stated as otherwise, all figures contained in this disclosure are based on the firm’s audited annual reports for the year ending 31st March 2024.
Frequency
These MIFIDPRU disclosures will be reviewed on an annual basis as a minimum. The disclosures will be published as soon as is practical following the finalisation of the firm’s annual Report & Accounts.
Verification
The information contained in this disclosure has not been audited by our firm’s external auditors and does not constitute any form of financial statement.
Publication
Our firm’s MIFIDPRU disclosure reports are published on our website.
Risk management objectives and policies
Our risk management policy reflects the FCA requirement that we must manage several different categories of risk. These include liquidity, credit, market, and operational risks.
Liquidity risk
The firm manages all cash and borrowing requirements to maximise potential interest income whilst ensuring the firm has sufficient liquid resources to meet the continued operating needs of the business. This is supported by a robust budgeting and forecasting process which has the full involvement of the senior management team.
Credit risk
The main credit risk for the firm relates to clients withdrawing funds from an underlying platform resulting in fees not being paid or a Platform going out of business and not paying fees due.
In the unlikely event that one of the firm’s platforms should cease trading, the firm believes the intermediary could transfer most client assets to another platform within 3 to 6 months and recover the “lost” management fees from the new platform.
Clients have every right to withdraw monies or move to another provider, however with our strong client engagement process and the intermediary having regular annual reviews, this would appear unlikely.
Market risk
The main market risk is that there is a significant economic downturn which in turn impact investment markets and AUM – correspondingly impacting One Four Nine Portfolio Management Ltd.’s recurring income streams.
The market could fall significantly impacting the level of investment management fees paid and on-going remuneration.
One Four Nine Portfolio Management Ltd is 100% owned by One Four Nine Group which has a significant wealth management and advisory business. One Four Nine Portfolio Management Ltd therefore has financial support from the broader group.
Operational risk
Operational risk is defined as the potential risk of financial loss or impairment to reputation resulting from inadequate or failed internal processes and systems, from the actions of people or from external events.
Major sources of operation risk include outsourcing of operations, IT security, internal and external fraud, implementation of strategic change and regulatory non-compliance.
The firm’s Compliance Oversight is responsible for the periodic reviews and recommending any changes to the management body.
All senior management will bear responsibility for internal controls and the management of business risk as part of their accountability to the board.
Individuals are responsible for identifying the risks surrounding their work, implementing controls over those risks and reporting areas of concern to their line manager.
The Compliance Oversight will provide the management body with regular reports on all significant risk issues.
Other risks
The firm operates a simple business model. Accordingly, many of the specific risks identified by the FCA do not apply.
Remuneration Code Disclosure
The firm is subject to the MIFIDPRU Remuneration Code. For the year ending 31st March 2024, relevant remuneration was as follows:
Fixed Remuneration £155,933
Variable Remuneration £0.00
