Regulatory Information


Fisher Investments Luxembourg, Sàrl (“Fisher Investments Luxembourg”) is a private limited liability company incorporated in Luxembourg (Company Number B228486) and is regulated by the Commission de Surveillance du Secteur Financier (“CSSF”). Fisher Investments Luxembourg’s registered address is: K2 Building, Forte 1, 2a rue Albert Borschette, Third Floor, L-1246 Luxembourg.

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

Fisher Investments Luxembourg 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 Luxembourg, Fisher Investments UK, Fisher Investments or other affiliates.

Fisher Investments is the parent company of Fisher Investments Luxembourg 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 Luxembourg regulatory regime, including the Luxembourg act of 18 December 2015 and the Système d’indemnisation des investisseurs Luxembourg  (“SIIL”), apply to the activities of Fisher Investments Luxembourg. If a client has a valid claim against Fisher Investments Luxembourg and Fisher Investments Luxembourg is unable to meet its liability because of its financial circumstances, SIIL may compensate the client for the full amount of the claim up to €20,000. Clients can contact Fisher Investments Luxembourg or SIIL to obtain more information regarding the conditions governing such compensation. However, such protections do not apply in relation to the services of Fisher Investments UK, Fisher Investments, any custodian or bank located outside of Luxembourg, or to the extent a client’s assets are invested in non-Luxembourg funds or ETFs.

This document constitutes the general views of Fisher Investments Luxembourg and should not be regarded as personalised investment or tax advice or a reflection of client performance. No assurances are made that Fisher Investment Luxembourg 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 Luxembourg.

Complaints

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

by writing to:     Head of Compliance

Fisher Investments Luxembourg
K2 Building, Forte 1
2a rue Albert Borschette
Third Floor
L-1246 Luxembourg

or by calling:       +352 2786 7320

Subsequently, you may have a right to complain directly to the CSSF. A copy of Fisher Investment Luxembourg’s complaints handling procedure is available on request. Further details in respect of the CSSF can be found at this website: http://www.cssf.lu/en/consumer/complaints/.

Top Brokers and Execution Quality (2018)

Below are the five top execution centers for each type of financial instrument from 2018 for Fisher Investments Luxembourg 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 Luxembourg.

** 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:

  • 5 Trade Date Open Rank: 5
  • 10 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.