Money & Co IFISA Portfolio – is it covered by the FSCS?

The P2P platform Money & Co has launched a “Money & Co Portfolio” service, which can be held via an Innovative Finance ISA.

Money & Co is a “pick your own” P2P platform through which investors lend money directly to firms raising money via the platform. With the “Portfolio” service, investors’ money is managed by Bramdean Asset Management who invest in a range of loans offered by the Money & Co platform.

Money & Co Portfolio’s literature advertises “Fixed rate returns of 7% after fees”.

Eagle-eyed readers will have noticed that I briefly warned against a possible clone scam, based on misleading advertising and the use of a newly-registered URL which was different to Money & Co’s usual one (moneyandcoportfolio.com rather moneyandco.com). Money & Co has confirmed that the offer is genuine and not a clone firm scam. My concerns over misleading advertising, however, remain.

Money and Co has retained Vimiera Limited as a tied agent to market the Money & Co Portfolio via the isamoney.co.uk.

At time of writing, the front page of isamoney.co.uk claims in big letters that the investment is “covered by the FSCS”.

ISAmoney.png

Most retail investors will think of “covered by the FSCS” in the sense it applies to an FSCS-backed deposit, where the FSCS pays up if the bank you lend your money to goes bust.

It is important that investors understand that this is an investment in P2P loans and the FSCS will not pay up if the underlying borrowers default on their loans (in which case you risk losing 100% of the money invested in that particular loan).

The FSCS also does not apply if Bramdean Asset Management makes poor decisions and most of your loans lose money. Poor performance by a portfolio manager does not automatically make them liable. (Otherwise anyone whose investments underperformed would complain and get their money back.)

Vimiera also previously issued Facebook ads to the public which referred to “IFISA offering 7% fixed returns net after fees, asset backed, managed portfolio FSCS protection with flexible draw down”. After I raised my concerns a few weeks ago, the Facebook ads were removed pending a review by by Money & Co’s compliance team. The above isamoney.co.uk promotion however remains visible at time of writing.

Vimiera is not authorised itself to issue financial promotions. It is not explicitly stated on Vimiera’s isamoney.co.uk website which FCA-regulated company has authorised the promotion to be issued to the public.

Who are Money & Co?

Money & Co was founded in 2013 by Nicola Horlick, a well known fund manager. It is a trading name of Denmark Square Limited. Denmark Square Limited does not file full accounts, but its most recent accounts (March 2018) suggest it remains loss-making, with “retained earnings” moving from minus £7.1 million in 2017 to minus £8.6 million in 2018. Due to its small size, the accounts were not audited and did not include a profit and loss account.

Who are Vimiera?

Vimiera Limited, the tied marketing agent behind the isamoney.co.uk website, was set up in June 2018 by Barry Stubley and Lynne Ashton.

Prior to founding Vimiera, Barry Stubley was from February 2013 to April 2014 a director of Premier Advice Club Limited, part of Investaco Asset Management, an unregulated introducer not to be confused with Investec Asset Management.

After leaving Premier Advice Club, Stubley incorporated Contemporary Investors Club Limited, which remained dormant until Stubley dissolved it in September 2018, shortly after launching Vimiera.

Should I invest in the Money and Co Portfolio?

This blog does not give financial advice. The following are statements of publicly available facts or widely accepted investment principles, not a personalised recommendation. Investors should consult a regulated independent financial adviser if they are in any doubt.

P2P investment is a legitimate and regulated sector. Personally I don’t think the returns from P2P generally compensate for the risks of lending to very small companies, but this is a personal preference.

Money and Co’s “Loans for Sale” page currently shows a total of 11 different companies seeking investment via Money and Co (albeit some companies are offering multiple loans in different projects). A portfolio of loans to 11 small companies would not be nearly as diversified as a standard corporate bond fund which would typically be invested across dozens or hundreds of companies listed on major stock exchanges.

Before investing investors should ask themselves:

  • How would I feel if the majority of my loans defaulted and I lost significant amounts of money?
  • Is my portfolio big enough that I could permanently lose a large part of my investment and not worry about it?
  • Am I genuinely happy with the risks of P2P lending, or did I come to Money & Co Portfolio because I was attracted by the “covered by the FSCS” statement?

Investors who are happy with the risks associated with P2P and lending to small businesses will need to do their own due diligence.

Investors who are looking for an investment which is “covered by the FSCS” should not invest in P2P loans to small companies which have a risk of significant losses should the borrowers default.

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One thought on “Money & Co IFISA Portfolio – is it covered by the FSCS?

  1. In the light of the London Capital & Finance debacle, is anyone looking closely at the activities of another big name, Money&Co? Nicola Horlick’s latest project seems to be a Frankenstein’s monster of glossy advertising fronting a corporate structure which has a scent of conflicts of interest and corporate sleight of hand.

    We can all agree that IFISAs and peer-to-peer platforms offer significant opportunities for UK investors providing they are well run with responsible due diligence, professional management and independent oversight. What happens though when the FCA permits directors of entities regulating a peer-to-peer platform to also be directors of entities benefitting from investments onto that platform? Welcome to the world of Money&Co and Nicola Horlick.

    As background, Nicola Horlick is the controlling shareholder and director of Bramdean Asset Management LLP, the FCA regulated company which has signed off on the activities of Money&Co Portfolio Limited. Nicola Horlick also sits on the board of Money&Co Portfolio Limited.

    The company which has benefitted most on the Money&Co platform appears to be an entity named Seascape. Scratch the surface and you will find that, interestingly, Seascape has the same business model as Dolphin Trust Gmbh, and some common senior executives. Scratch a bit deeper and lo and behold sitting next to Nicola Horlick on the board of Money&Co Portfolio Limited is one Christopher Moss, legal adviser to Dolphin (and presumably Seascape) and, under that, sits Money&Co Portfolio Services where one James Hall, who is believed to be an Account Manager for Dolphin, purports to be a “Director”. Charles Smethhurst, Dolphin CEO, was quoted on the Money&Co website. This is all publicly available information. Indeed, to complete the circle, Money&Co Portfolio Services appears to an Appointed Representative of Bramdean Asset Management LLP.

    So what is the relevance of Dolphin you may ask? Well, on 20 August 2018, Charles Smethurst wrote to Far East Investors warning that Dolphin loan notes would not be redeemed in accordance with their terms (so potential default). There is also a suggestion that Dolphin might be a connected party to on-going Serious Fraud Office investigations into Trafalgar Multi-Asset Fund. Now such information, were it to become widely known, might put off investors into Dolphin. Enter Seascape, a shiny brand new special purpose vehicle. One would assume that Bramdean would be fully aware as to whether Seascape might be a device to hide from potential investors any investments going into a Dolphin-related entity, or indeed, for investor transparency, whether any Dolphin connection should be overtly declared.

    Now the borrower guidelines on the Money&Co website set out a whole screed of criteria which companies raising funds via the Money&Co platform must comply with. These include such criteria as being an established business as demonstrated through having 3 years of financial accounts. Interestingly, Seascape, an SPV with no filed accounts, no trading history and ostensibly completely outside Money & Co’s borrower guidelines has been permitted to raise funds into an ISA using the Money&Co platform. How can this be possible or permissible? What tangible and realisable security does Seascape own upon which investor funds are secured? It would of course make more sense if Dolpin is behind Seascape.

    No doubt Money&Co Portfolio Limited would argue that, legally, it is not connected with Dolphin. Any assertion that Money & Co Portfolio Limited is nothing to do with Dolphin is a statement that many might find to difficult to accept and would beg further questions into both the common executive leadership and how Seascape has been permitted to be a borrower on the platform absent full compliance with the published borrower guidelines. And who would bless this happening? Bramdean and Nicola Horlick would seem to be best placed to explain.

    In the event that there is any connection between Seascape and Dolphin the obvious question is whether there was any deliberation in the obscuring of Dolphin behind corporate blinds. If there is any connection the end result would be the same, namely to assist Dolphin to raise funds from UK investors through an ISA facilitated by Money&Co / Bramdean.

    Are any readers aware of the noise in the market that investments into Money&Co have allegedly being promoted to retail clients on the basis that investments into Seascape benefit from FSCS protection by dint of the connection with Bramdean? It is noteworthy that, unlike some other sites, Money&Co did not prominently make it clear that FSCS protection was not available to investors, something that other regulated entities have insisted upon prior to signing off on such websites. Was this deliberate or an oversight? If any investments have been made into Seascape via Money&Co on the assumption that FSCS protection exists then this would potentially be an echo of the situation faced by investors into London Capital & Finance.

    The final question is whether the FCA or any financial journalists have looked closely into the activities of Money&Co. Nicola Horlick is a huge name in the financial services industry – but could it not be perceived as a conflict of interests to control both a regulated entity and a platform while being a director of a business linked with an underlying borrower and their fund-raising team? The consequences of the FCA permitting or facilitating such a potential conflict of interest are plain to see.

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