Introduction, Scope and Purpose

Goldcin Partners LLP (the Firm) is regulated by the Financial Conduct Authority (FCA) as a Markets in Financial Instruments Directive (MiFID) investment firm.

Under the Investment Firms Prudential Regime (IFPR) and the MIFIDPRU section of the FCA Handbook, Goldcin Partners LLP is categorised as a small and non-interconnected (SNI) investment firm and this document has been produced in to meet the MIFIDPRU 8 disclosure obligations as applicable to SNI firms.

In accordance with the rules, the disclosure herein is appropriate to the size, nature, scope, and complexity of the Firm’s activities.

As an SNI firm, Goldcin Partners LLP does not hold client money, is not permitted to deal on its own account and meets other size tests (stays under certain assets under management, client orders handled amounts, annual gross revenue, and other thresholds).

SNI firms are required to maintain own funds that is the higher of the (1) permanent minimum capital requirement (£75k) or (2) its fixed overheads requirement.

The Permanent Minimum Capital Requirement (£75k) is determinative for Goldcin Partners LLP. The Firm must at all times maintain own funds that is at least equal to or greater than the Permanent Minimum Capital. The level of relevant fixed overhead cost remains below this level. As an SNI firm, Goldcin Partners is not subject to any K-factor requirements.

During the 12-month accounting period ended the 31st of March 2024 the Firm complied fully with the overall financial adequacy rule and operated well within the requirements of the MIFIDPRU.

The own funds of a firm are the sum of its Common Equity Tier 1 Capital, Additional Tier 1 Capital, and Tier 2 Capital.

Goldcin Partners LLP holds own funds and all such funds are classified as Common Equity Tier 1 Capital and is therefore of the highest quality.

Thus under MIFIDPRU 8.1, the public disclosure of the funds is not required (applies only for AT1 capital instruments).

The Firm’s capital resources are deemed to be sufficient and will continue to be monitored throughout the year to ensure this position is maintained for the business to be able to remain financially viable throughout the economic cycle and if the Firm does have to wind down, it can do so in an orderly manner.

Governance

As an SNI investment firm, Goldcin Partners LLP has implemented a clear organisational structure with transparent and consistent lines of responsibility; it has arranged effective processes to identify, manage and monitor the risks the Firm is or might be exposed to; it has adopted adequate internal control mechanisms. The arrangements has been confirmed appropriate and proportionate to the nature, scale and complexity of the risks inherent in the business model and the activities of the Firm and compatible with the requirements in the FCA Handbook.

The business is managed with an approach that seeks to minimise risks that the Firm is exposed to. At the same time, the business aims to utilise working capital to its maximum potential for the Firm to grow, always recognising the importance of the balance between regulatory capital and making sound business judgements.

Furthermore, the partners undertake business model assessment, planning and forecasting of capital and liquidity needs, both on an ongoing basis and were they to have to wind down; Appropriate and credible recovery actions to restore own funds or liquid resources are determined should it become necessary.

The Firm has completed its ICARA (Internal Capital and Risk Assessment) document to determine its net wind-down requirements and any additional own fund requirements to fund its ongoing operations.  

Remuneration policy and practices

Goldcin Partners LLP is subject to the FCA Rules on remuneration.  These are contained in the FCA’s Remuneration Code located in the SYSC Sourcebook of the FCA Handbook.

It should be noted that at present, the Firm does not have any direct employees. The Firm is a partnership; thus payment is made to the partners via profit distribution. As of SYSC 19G.4.4 the residual profits of a limited liability partnership distributed among partners and not linked to work or performance, in the FCA’s view, are not remuneration. The Partners only divide available profits, adding that the profits are only paid to partners after the Firm has satisfied its capital resource requirements under MIFIDPRU.

As an SNI firm, Goldcin Partners is not required to establish a remuneration committee.

Conclusion

Goldcin Partners LLP maintains sufficient own funds to meet the UK regulatory requirements. Since the commencement of the Firm’s activities the partners have kept cash balances  in excess of the requirements, and do not carry any debt at any time.

Goldcin Partners LLP is a small firm conducting simple activities with a simple operational structure. Accordingly, many of the specific risks identified by the FCA do not apply.

Goldcin Partners LLP is not a member of a group and therefore is not required to prepare consolidated reporting for prudential purposes.

Goldcin Partners LLP does not have a significant investment in a financial sector entity therefore it does not pose harm to other market participants or to the markets.

The Firm is not planning to implement any material changes to its business therefore it doesn’t calculate the anticipated impact of the changes on its fixed overheads requirement.

Frequency of disclosure

Unless otherwise stated, MIFIDPRU 8 disclosures are published annually concurrently with the Annual Report and ICARA completion in accordance with regulatory guidelines.

Location

MIFIDPRU 8 disclosure report is available on the Firm’s website at: https://www.goldcinpartners.com/

Copies of the above (MIFIDPRU 8 Disclosure) and the Firm’s Internal Capital and Risk Assessment (ICARA) document also are available on request by writing to us at info@goldcinpartners.com