Regulatory Information


Fisher Investments Ireland Limited trades under the name Fisher Investments Ireland (“Fisher Investments Ireland”). Fisher Investments Ireland and its trading names are registered with the Ireland Companies Registration Office under numbers 623847, 629722, 629724, 629725 and 629723. Fisher Investments Ireland is authorised and regulated as an investment firm by the Central Bank of Ireland. Fisher Investments Ireland’s registered address is: 3 George’s Dock IFSC, 2nd Floor, Dublin 1, Ireland.

Fisher Investments Ireland’s representatives meet with qualified private clients who are interested in learning more about the discretionary investment management services of Fisher Investments Ireland.

Fisher Investments Ireland partially outsources aspects of the day-to-day investment advice, portfolio management, and trading functions to its affiliates. In particular, preparation of investment suitability reports will be partially conducted by Fisher Investments Europe Limited, trading under the name Fisher Investments UK (“Fisher Investments UK”), and the day-to-day portfolio strategy decision-making will be conducted by Fisher Asset Management, LLC, trading under the name Fisher Investments (“Fisher Investments”). Trading functions may be carried out by Fisher Investments Ireland, Fisher Investments UK, Fisher Investments or other affiliates.

Fisher Investments is the parent company of Fisher Investments Ireland and Fisher Investments UK and is established in the USA (Delaware Secretary of State number 3936233) and regulated by the US Securities and Exchange Commission (SEC# 801-29362). Fisher Investments UK is authorised and regulated by the UK Financial Conduct Authority (FCA number 191609).

The protections of the Irish regulatory regime, including the Investor Compensation Scheme (“ICS”), apply to the activities of Fisher Investments Ireland. The ICS pays 90% of net loss up to a maximum of €20,000 in certain circumstances when an investment firm authorised by the Central Bank is goes out of business. However, such protections do not apply in relation to the services of Fisher Investments UK, Fisher Investments, or any custodian or bank located outside of Ireland. The assets of clients in Ireland will generally be held with a custodian in Ireland. In addition, to the extent your assets are invested in non-Irish funds or ETFs, these protections will not apply. Additional information in respect of the ICS can be found online at https://www.investorcompensation.ie/.

This document constitutes the general views of Fisher Investments Ireland and should not be regarded as personalised investment or tax advice or a reflection of client performance. No assurances are made that Fisher Investments Ireland will continue to hold these views, which may change at any time based on new information, analysis or reconsideration. Nothing herein is intended to be a recommendation or forecast of market conditions. Rather, it is intended to illustrate a point. Current and future markets may differ significantly from those illustrated here. In addition, no assurances are made regarding the accuracy of any assumptions made in any illustrations herein.

Investing in financial markets involves a risk of loss and there is no guarantee that all or any invested capital will be repaid. Past performance neither guarantees nor reliably indicates future performance. The value of investments and the income from them will fluctuate with world financial markets and international currency exchange rates.

Not all past forecasts were, nor future forecasts may be, as accurate as others. There can be no assurances that investment returns from a particular strategy or allocation will exceed returns from another strategy or allocation.

This document has been approved and is being communicated by Fisher Investments Ireland.

Complaints

Fisher Investments Ireland seeks to provide a high standard of service to clients at all times. If you have a complaint about services provided by Fisher Investments Ireland or its affiliates, please contact:

by writing to:     Head of Compliance
                                Fisher Investments Ireland
                                3 George's Dock, 2nd Floor
                                International Financial Services Centre
                                Dublin 1
                                D01 X5X0, Ireland
or by calling:       +353 [●]

If you are dissatisfied with the outcome of any complaint made to Fisher Investments Ireland, or you do not receive a response within such time, you may complain directly to the Financial Services and Pensions Ombudsman (“FSPO”).  Further details in respect of FSPO can be found at this website: https://www.fspo.ie/make-a-complaint/.

Top Brokers and Execution Quality (2018)

Below are the three top execution centers for each type of financial instrument from 2018 for Fisher Investments Ireland clients. Our firm provides this information annually to comply with MiFID II regulations.

* The execution venue ranking information is 2018 historical data from Fisher Investments UK (“FI UK”) with respect to clients who were transitioned from FI UK to Fisher Investments Ireland.

** Average Execution Score Rank: All executions for each approved broker are measured against three trading benchmarks:

  • Trade Date Open
  • Volume Weighted Average Price (VWAP)
  • Trade Date Close

Differences between average prices and benchmarks are expressed in percentage terms (difference divided by trade value) and are rolled-up by broker into a weighted average percentage difference across each of the three benchmark measures. All 29 approved brokers are ranked across the three different benchmark measures (top-rank meaning the smallest % difference from the benchmark). A weight is applied to each benchmark ranking (Trade Date Open = 70%, VWAP = 15%, Trade Date Close = 15%) and the average ranks are rolled-up into a final “Average Execution Score Rank.”

Example:

Broker X:

  • Trade Date Open Rank: 5
  • Volume Weighted Average Price (VWAP) Rank: 10
  • Trade Date Close Rank: 15
  • Avg. Execution Score Rank = (70% * 5) + (15% * 10) + (15% * 15) = 7

Execution quality is reviewed on a weekly basis by the Trading team utilizing Trade Cost Analysis (“TCA”) software. A summary of the TCA is generated quarterly and reviewed in detail with the Trade Practices Committee. Any outliers are reviewed to determine what factors contributed to the execution results and if the factors were within the trader’s/broker’s control.

Investing in financial markets involves the risk of loss and there is no guarantee that all or any capital invested will be repaid. Past performance neither guarantees nor reliably indicates future performance. The value of investments and the income from them will fluctuate with world financial markets and international currency exchange rates.