Legal & Regulatory Information
A J Buckley Asset Management Ltd, Registered in England number: 02730015
The Old Rectory, Church Street, Weybridge, Surrey, KT13 8DE
tel: 01483 426300
fax: 01483 426123
VAT registration number: 591811920
Office address: Robuck House, Brighton Road, Godalming, Surrey, GU7 1NS
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A J Buckley Asset Management Ltd is authorised and regulated by the Financial Conduct Authority and is entered on the FCA register under FRN 154371 (www.fsa.gov.uk/register/). Please note that this is an external website and will take you away from this page.
Pillar 3 Disclosure
We the undersigned, being the Directors of the Company, unanimously RESOLVE:
To make public the following information on the Company’s capital, risk exposures and risk assessment processes in accordance with the FSA’s Prudential sourcebook for Banks, Building Societies and Investment Firms, Chapter 11 (Pillar 3):
A.J.BUCKLEY ASSET MANAGEMENT LTD (the “Company”) was incorporated with limited liability in England and Wales on 9 July 1992 and is authorised and regulated by the Financial Services Authority (the “FSA”) to provide investment management services. The Company is categorised as a limited activity firm by the FSA for capital purposes. Pillar 3 disclosures fulfils the Company’s obligation to disclose to market participants key pieces of information on a firm’s capital, risk exposures and risk assessment processes.
I. Risk Management Objectives and Policies
The Directors of the Company determine its business strategy and the risk appetite. They have designed and implemented a risk management framework that recognizes the risks that the business faces. The Directors of the Company also determine how those risks may be mitigated and assess on an ongoing basis the controls and procedures necessary to manage those risks. The Directors of the Company and Compliance Officer meet on a regular basis and discuss projections for profitability, liquidity, regulatory capital, business planning and risk management.
As an investment manager, the Company considers the following as key risks to its business:
Business risk – This risk represents a fall in asset under management in the Funds, the loss of key staff or a lack of client and investor diversification which may reduce the management and performance fee income earned by the Firm and hinder its ability to finance its operations and reimburse its expenses. Business risks are assessed and mitigated as part of the Internal Capital Adequacy Assessment Process (”ICAAP”).
Operational risk – This risk covers a range of operational exposures from risk of trading errors to risk of breach of a Fund’s investment objectives. Legal and reputational risks are also included within the category of operational risk. Operational risks and mitigants are assessed as part of the ICAAP.
Credit risk – This risk relates to the exposure to the Funds for non-payment of management and performance fees and counterparty exposure relating to the Company’s bank balances and any other debtors. This is monitored by the Company’s accountant and reported monthly to the Compliance Officer.
II. Capital Resources
The capital resources of the business comprises Tier 1 capital with no deductions.
As a limited licence firm able to hold client money, the capital resources requirement is calculated as the total of Pillar 1 and Pillar 2 capital.
Pillar 1 capital is the greatest of:
1. a base capital requirement of Euro 125,000;
2. the sum of market and credit risk requirements; and
3. the Fixed Overhead Requirement (“FOR”).
Pillar 2 capital is calculated by the Company as representing any additional capital to be maintained against any risks not adequately covered under the requirement in Pillar 1 as part of its ICAAP. It is the Company’s experience that its capital requirement normally consists of the FOR, although market and credit risks are reviewed monthly.
The Company applies a standardised approach to credit risk, applying 8% to the Company risk weighted exposure amounts, consisting mainly of management fees due but not paid, and bank balances. Having performed the ICAAP it is the Company’s opinion that no additional capital is required in excess of its Pillar 1 capital requirement.
As at 30/6/12 the Company’s regulatory capital position is:
Tier 1 capital: Company Capital and Audited Reserves as at 30 June 2012
Total Capital Resources Requirement for 2011/12 (Fixed Overhead Requirement)
III. Management of the ICAAP
The approach of the Company to assessing the adequacy of its internal capital to support current and future activities is contained in the ICAAP. This process includes an assessment of the specific risks to the Company and the internal controls in place to mitigate those risks. Finally, an assessment is made of the probability of occurrence and the potential impact, in order to arrive at a level of required capital, as relevant. The Company’s ICAAP is formally reviewed by the Directors of the Company approximately every 6 months, but will be revised should there be any material changes to the Company’s business or risk profile.
Anthony J Buckley Director,
Linda P Pannett Director
Paul Willans Director
James J Buckley Director
Patricia M R Buckley Director
A PDF of the above document can be downloaded here.