CoalitionOfTheIndependent

A manifesto to better support independent financial advisers

For Professional Investors Only

CAPITAL AT RISK

They discussed the fact that when a business owner sells to a consolidator he or she is immediately able to access a great deal of support and help. But there is little done between independent firms to provide support if they do not choose this route. Amongst the key themes to emerge was a desire for firms to work better together to create an independent academy to encourage those coming into the profession to join independent businesses.

We do not claim to have answers to all these challenges. However, we aim here with this white paper to fuel the debate as we continue to work with those partners who have chosen Albemarle to find ways to support their independence and grow their businesses.

Charlie Parker, Managing Director,
Albemarle Street Partners

Foreword

At Albemarle Street Partners we work with a group of financial advisory businesses which are making their way as independent companies at a time when much of the sector is engaged in rapid consolidation.

In December 2021, a group of chief executives sat down to discuss this challenge and there was one key sentiment that came out;

Shaping the future of independent advice

How will independent financial advisers thrive in the era of rapid consolidation?

Independence matters

What has been the impact of consolidation on client outcomes?

What can we do about it?

A five-step manifesto to support the independent advice sector

The power of a centralised investment proposition

Why a structured investment solution supports independent firms

Introducing Albemarle: the boutique investment partner for independent firms

Discover how we have built our business to support the independently-minded IFA

The research in full

Explore the range of issues we analysed with leading financial advisers

Contents

The financial advice market is in a period of rapid consolidation but for advisers who want to retain their independence, it is critical they come together to shape the future of advice for the benefit of their businesses and clients.

In light of the dizzying rate of consolidation that continues to eat into the independent advice market, Albemarle Street Partners in conjunction with leading chief executives from independent firms has created the Coalition of the Independent.

This collection of forward-thinking advisers understand the merits of ensuring the continuation of smaller advice firms and has set out an action plan of practical changes that ensure a vibrant future for advice.

Under the Coalition of the Independent’s action plan, the independent financial advice market cannot just survive the lure of consolidation but thrive.

While consolidation in the advice market is not a new phenomenon, a demographic shift and ramp-up in regulation has made it increasingly prevalent in recent years. The introduction of the Retail Distribution Review (RDR) sped up the process in the early 2010s and subsequent regulation - including Mifid II, PRIIPS, and most recently the Investment Firms Prudential Regime (IFPR) - all ensured it became more economically viable to be part of a large network than a one-man band.

Shaping the future of independent advice

Independence matters

While the cards may sometimes seem stacked against smaller players, this does not mean independence isn’t worth fighting for. The impact of a shrinking advice market and the lack of choice it brings for consumers is a major concern for advisers.

A recent survey of 49 advisers by Albemarle revealed nearly three-quarters (73%) believed the consolidation of the advisory market had not been positive for clients.

A staggering 59.1% of those polled said the main drawback of a more consolidated sector was a ‘weaker focus on the best interests of clients’, while 28.5% said the main drawback was ‘less individualised financial advice’, and the third biggest issue with consolidation was ‘a loss in the diversity of approach across the sector’ (12.2%).

At a roundtable of advisers held recently by Albemarle Street Partners, firms explained why they will resist the pull of consolidation and remain independent.

The pull is real and persistent: of those surveyed by Albemarle, 84% of advisers had received at least one approach to sell their firm or book of business in the past year. A huge 73.4% of advisers had received three or more approaches, with another 8.1% receiving two approaches and 2% receiving one approach. Only 16.3% of the advisers asked had not received any offers.

Overall do you believe consolidation in the financial advisory market has been positive for clients?

Ray Tuffield, managing partner of Courtney Havers LLP, was wary that consolidators are trying to ‘squeeze advisers into hubs’.

While economies of scale are usually a boon to adviser businesses that sign up, Medical & Financial director Simon Dickerson warned that they ‘don’t appear to benefit the clients’.

Justine Roberts, director of Medical & Financial, which specialises in advising medical professionals, was similarly defensive of her clients.

‘I almost don’t trust anybody else to look after them. We don’t want them to be taken advantage of by having to pay fees that are charged too high, or worry that they’re not being looked after properly by a firm trying to make square pegs fit into round holes.’

Richard Read, director of City-based Augustine Financial Planning, described his firm as ‘fiercely independent’ and will remain that way for his clients.

Andrew Moore, managing director of Alexander Beard Group, has chosen to use a panel of providers. He said

He said that as the company had grown ‘it has become harder and harder to manage the various different recommendations of the advisers’ and as ‘product governance regulations came in, it was turning into a nightmare’.

The Coalition of the Independent is calling for modest, practical steps to make it easier for advisers to continue trading as a one-man-band or smaller business, by tackling the problems of succession planning, recruitment, regulation, and fees.

There is no denying that the independent advice market is highly fragmented, with more than 26,000 advisers registered with the Financial Conduct Authority (FCA) in 2019. While it may be easier for the regulator to police a smaller number of larger firms, the cannibalisation of the sector leaves clients with less choice and at the mercy of homogenous financial plans and high fees.

By coming together with one voice and pushing for change, advisers can shape the future of their profession.

What can be done about it?

Action on the cost of borrowing that will help advisers meet capital adequacy standards and allow them to grow through acquisitions

Succession planning has been a perennial problem in the advice profession and with the average age of advisers remaining stagnant, the issue looks set to remain.

The lack of internal succession planning has been paramount in the rise of consolidators, hoovering up small advice firms when their principals finally decide to retire. With no one to pass the business to, the cash-ready consolidators can swoop in.

But advisers are concerned that too many advisers are succumbing to consolidators for lack of any other plan. Part of the issue is the difficulty smaller firms have in raising cash to buy-out peers.

The Albemarle survey of advisers found that while 16.6% of advisers want to grow through acquisition and have a plan, another 8% wanted to acquire other firms but did not know how to finance it, and 2% wanted to acquire but didn’t know how to find opportunities.

At the roundtable discussion, business owners outlined the difficulty they have in investing in their business as they are limited by borrowing restrictions and the FCA’s capital adequacy demands.

Adding to the complexity around capital adequacy is the Investment Firms Prudential Regime (IFPR) that will be implemented this year and could well increase the regulatory capital requirements of firms that fall under this regulatory umbrella.

Step 1

George Goward, managing director of George Square Financial Management, said the FCA ‘makes it so difficult for companies in the mid-size’ to be able to take on another firm due to capital adequacy rules.

He added the FCA needs to consider making it ‘easier to borrow’.

Tuffield agreed that the borrowing options for firms are limited as traditional lenders have not historically wanted to help.

He argued that while ongoing fees are not a guaranteed income stream it is a ‘secure income’ that should be recognised by lenders.

Increasing education and awareness of advice as a profession at a grassroots level

The problem with succession planning is multi-layered and one of the underlying issues is a lack of new recruits choosing advice as a career path. While there have been a variety of schemes designed to attract younger generations into the industry over the years, they have had limited positive results, with law and accountancy continuing to trump financial advice as careers of choice.

Retaining and recruiting staff is a serious concern for firms. When asked to rank their concerns, retaining staff was logged as the second biggest concerns, with recruiting staff coming in third.

While there are a handful of financial planning degrees available to students in the UK, the path to becoming a financial adviser is not an obvious one, and there is little encouragement to join the profession.

While lucky breaks are inherent in climbing onto and up the career ladder, recruiting the next generation of financial planners should not be left to luck or chance. Promoting financial advice as a viable career option for young people at a grassroots level should be made a priority for the industry.

Step 2

Cathy Nolan, an adviser at Burton & Fisher Financial Services in Lancaster, is already Diploma qualified and holds the CF8 long-term care accreditation at the age of 24 but she did not set out to be an adviser.

She went straight into banking from sixth form where she ended up as a ‘small cog in a big machine’, and although she made a fortuitous leap into financial advice, it was not presented as an option.

Nolan warned of a ‘missed generation’ of advice, due to the lack of promotion of the career and said firms face a ‘generation gap’ if older advisers are not more forward-thinking in their succession planning, bringing new blood into the industry before it’s too late.

What is the biggest challenge of independence?

Creation of an independent academy of advisers to encourage advice as a second career

The Coalition of the Independent has recognised that a steady stream of entrants into the advice market is vital to the survival of smaller businesses. Without new blood entering the market, older advisers could be forced into the arms of consolidators as a last-ditch succession plan.

FCA statistics show the average adviser in the UK is over the age of 50 and there are few new recruits coming into the profession, with law and accountancy continuing to be the preferred career path of choice of younger people.

Having qualified as an adviser, West found a self-employed role through a connection in his local area but has since decided to take a salaried role at an advice firm. New recruits are vital for firms to grow and when surveyed by Albemarle, 46.9% of advisers agreed with the statement ‘we should focus on attracting and incentivising good, employed advisers’.

Just 6.1% believed businesses should attract self-employed advisers and 38.7% said ‘both employed and self-employed approaches can form part of growing our business.

Whether salaried or self-employed, recruitment is a pressing issue. The recruitment gap in the profession could be filled by those who have lost their jobs in the coronavirus pandemic or who are just looking for a career change. With greater promotion of the benefits of becoming an adviser, the flexibility it can offer, the rewarding client outcomes, and the potential for plentiful remuneration, this gap could be closed by new, older recruits who bring with them a host of life experiences.

Step 3

This problem could be tackled head on with the promotion of financial advice not just as an option for those setting out on their careers, but for people planning a career change. The more people who are encouraged into the profession, and the more pathways they are given, the greater chance of smaller advice firms remaining independent.

Merseyside-based Alastair West decided to switch career paths at the age of 40 after a two-decade career in IT. He used the Covid-19 pandemic to complete his Diploma level training in just six months and said he was drawn to financial advice as it provided an opportunity to use both his problem solving skills and work face-to-face with clients.

West said the life experience he brings to the role is beneficial, even if he isn’t from a finance or sales background and the Diploma qualification has provided the technical skills and regulatory knowledge to carry out the job. However, he said further people could be encouraged into the sector if there was a greater focus on the soft skills needs to be an adviser, such as conducting a meeting and ensuring all aspects of a financial plan are spoken about in a natural way.

Addressing the cost of compliance in the reform of FCA and FSCS fees to ensure smaller firms are paying a proportionate sum for regulation

The cost of compliance for advisory firms is a perennial problem, with smaller firms shouldering an increasing burden of FCA handbook complexity and the corresponding regulatory costs.

However, the biggest cost for advisers is the Financial Service Compensation Scheme (FSCS) and the rising expense of professional indemnity insurance. Following research by PIMFA, it warned that FSCS levies have increased to ‘unsustainable’ levels in recent years, and found 45% of advisers it surveyed had seen their FSCS costs rise by over 100% in the last five years, while 26% had seen professional indemnity premiums rise over 100% in the same timeframe.

When asked what goals the advisory community should be pushing towards, many advisers polled by Albemarle mentioned reform or overhauling of the regulator and the fees advisers pay.

One major bone of contention with the regulator and the FSCS within the adviser profession has been that financial planners feel their share of the regulatory fee is disproportionate to the amount of complaints made to the FCA and the number of claims made to the FSCS that concern their part of the financial services industry.

Dickerson agreed with the statement that ‘the regulator is happy to see far fewer firms through consolidation to provide a more structured market place to regulate’ when asked for their opinions on the regulatory environment.

This is a prevailing theme within the adviser community, with a vast majority – 87.5% - of advisers also agreeing with this statement when polled by Albemarle.

Just 6.2% of advisers agreed with the statement: ‘it is a priority for the regulator to provide a supportive environment for smaller independent firms’.

Step 4

Simon Dickerson, a director at Medical & Financial, said if he could encourage advisers to join together to push for one achievable goal, it would be a ‘reduction in regulatory cost and burden’ and a ‘fair, risk-based FSCS levy’.

‘The FCA’s definition of a small firm is quite different from a typical small firm,’ he said.

Encouraging light-touch regulation that is proportionate to the size of the firm but also focuses on creating positive outcomes for consumers rather than just preventing poor outcomes

Proportionate regulation of advisory firms, including fairer FCA and FSCS fees, chimes with adviser calls for lighter-touch regulation for those firms that cause the least harm to the financial services industry.

Coping with regulatory pressure was the top-ranked issue for adviser firms polled for the Albemarle study, with

and

% of respondents names it the most pressing issue

% of advisers ranking it either second and third most important.

While lighter-touch regulation of businesses may seem self-serving, it is quite the opposite. Currently, regulation is focused on preventing poor outcomes which necessitates the need for heavy-handed rules, punitive levies, and an overbearing burden for smaller firms. If the regulator shifted its focusing towards creating positive outcomes for consumers, the need for regulation would be lighter and the burden for smaller advisory firms may not be as great. This would enable advisers to help more people as the cost of advice would reduce.

By focusing on positive outcomes for consumers, not only would the cost of taking advice reduce ensuring advice was available to more consumers but it would see a greater number of consumers benefit from positive outcomes, meaning there would be fewer claims for the FSCS, creating a virtuous circle for regulation and claims.

While 36.7% of advisers asked believe a more consolidated sector makes for an ‘easier sector for the regulator to monitor’, Read is a dissenting voice.

Read said in discussions with regulators, they say they support small and medium-sized business and he believes the FCA is not interested in regulating a handful of large IFA firms that do not have clients interests at their heart like smaller businesses do.

However, he said it is a ‘political game’ and the regulator ‘has to be seen to be looking after the Retail Plan and that is costly for the small businesses because we don’t have the economies of scale they have in the bigger businesses’.

Step 5

Commenting at the Albemarle roundtable event, Richard Read of Augustine Financial Planning, said:

0.6

How does a centralised investment proposition help?

Growing an advisory business, providing consistent investment plans for clients, all while ticking the right regulatory boxes to maintain independence is no mean feat.

It is no wonder so many advisers have felt compelled to sell to consolidators. Retaining the prize title of independent may be more difficult but with the right help and support, advisers can continue to offer their clients the best financial planning that includes a consistent, measurable, and reliable investment proposition, and future-proof their businesses.

Putting a centralised investment proposition (CIP) at the heart of your advice process can be a benefit for both your clients and your business. There has been a long-running trend for advisers to adopt CIPs and managed portfolio services to enable them to create more predictable financial outcomes for their clients.

When polled, advisers confirmed that a CIP can help an independent firm to deliver consistent client outcomes and grow as a business, with 65.3% agreeing with the statement, and just 16.3% disagreeing.

However, there is scope for more advisers to outsource their investment functions, with just 40% of advisers outsourcing their investment management or research function, and another 14.5% stating they were exploring it as an option for their business.

At Albemarle, we know an advisers’ time is precious and better spent face-to-face with clients building their financial futures, and our team is dedicated to finding you the most compelling investment opportunities across the universe of funds, ETFs, shares, and investment trusts, to create both active and index portfolios.

As technology sits centre stage in adviser businesses, our managed portfolios are available across platforms.

Outsourcing investment solutions means advisers can access a diverse and actively managed portfolio of investments that dovetail with your clients’ risk profile and objectives, without losing any control of your clients.

By providing clients with an improved investment proposition, you can also help to future-proof your business. Financial advisers are freed up to focus on the most important part of their business; their client relationships.

Outsourcing investment has practical benefits, such as providing access to specialist expertise, reducing business risk, and by offering tailored portfolios with different risk profiles to clients, advisers are also fulfilling their regulatory requirements.

In short, by taking out the complexity and time-consuming nature of putting portfolios together, advisers can get back to doing what they do best: advising their clients.

Do you believe a centralised investment
process can help your firm deliver consistent client outcomes and grow as a business?

About

albemarle

with Eleanor Williams,
partnerships director

Q&A

WHAT BENEFIT DOES ALBEMARLE HOPE TO BRING TO ADVISER BUSINESSES AND CLIENTS?

In essence, what we are trying to do is enable advisers to reap the benefits of discretionary management - providing a much more structured investment outcome for clients while lowering the administration burden - without them losing all of the good things about running money themselves. We work with advisers to make sure they are close to the investment process; they know why decisions are made, can explain those decisions to clients, and the adviser can ensure they are making a meaningful impact on the investment decision. Adviser partners work with us because we have a focused team of people working across the business that are present, they are there to help them with any obstacles they encounter along the way, and therefore help the advisers keep their clients better informed. One way we do this is to provide advisers with an enormous amount of investment content that they can choose to brand themselves, but more importantly, we make content that works for them and their clients. This isn’t a white-labelling exercise, it is about creating an investment proposition that works for the adviser. Rather than the adviser feeling like they are losing, or giving away, their clients’ investments, the adviser and the client are both getting more as the adviser can draw on Albemarle’s research and help facilitate a deeper investment relationship with their client.

WHAT IS UNIQUE ABOUT ALBEMARLE’S PROPOSITION COMPARED TO OTHER DFMS?

It is less about being ‘unique’ and more about the fact that people have to make a choice about who they want to work with. We are working with firms every day, we are invested in how they put together their business strategy, how they want to develop it, and people work with us because they like the way we work - that is far more important than a unique selling point in terms of our investment proposition. That said, we believe that the distinct features that people value most are the tools we create to enable them to create more specific investment goals for their clients. We also work hard to meet the overall proposition pricing point advisers are targeting. We are better able to do this than many others because our expertise extends beyond collectives and into owning direct securities on the platform of the adviser’s choice.

DOES THE INVESTMENT PROPOSITION AIM TO DELIVER OUTCOMES-BASED RETURNS?

The amount of risk a client is willing to take with their investments has the biggest bearing on the outcome they will receive. Our goal is to make optimal use of the risk a client is willing to take. At Albemarle, we aim to add value by ensuring our investment proposition enables advisers to deliver their clients’ outcomes, and more value will be added to the adviser by the greater proportion of their clients reaching their goals. There are some things that we offer that are unique. One of those is that we have the capacity for advisers to expand on the model portfolio service by using not only funds in the portfolio, but also direct investment in shares. This is a trend we are seeing among advisers and they acknowledge that when they want to deliver a very specific investment goal, including using direct investments, they can do so at a lower cost. Of course, it is not for everyone and some advisers will want to use funds based model portfolios. There are benefits for advisers in building a very direct portfolio. When clients own a lot of funds, say 20, 30, or 40 funds, a lot of the benefits of active management disappear. Indeed you can mathematically see that there is almost no stock-specific risk or opportunity remaining in the portfolio. We wanted to give advisers the option to retain the diversification benefits of broad multi-asset portfolio but using direct investments alongside funds. Since we started running direct portfolios a year ago, we have seen clients migrate. Whether an adviser chooses to use funds, or stocks, or a mixture of both - all of those are a reasonable choice. The most important thing is having all the tools in the box to build a proposition around the adviser’s own philosophy.

ARE THERE ANY INVESTMENT TRENDS THAT ALBEMARLE HAS IDENTIFIED?

We added ethical fund options to our model portfolios and they have done very well. It is fair to say it is still a minority of our client base using them, but it is there for those who chose them. When it comes to ethical investing we are at a pivotal moment in time, not just for the retail investor uptake in ethical funds but also from a top down, institutional investment standpoint, as institutional investors are encouraged to take ethical, social, and governance (ESG) into account when investing. At the moment, ethical investing is probably offering super-normal returns because of the weight of money moving into the sector. It is a trend that has a real ability to deliver higher returns than normal at the moment.

WHAT ADDITIONAL RESOURCES DOES ALBEMARLE BRING TO ADVISER PARTNERS?

We are part of a larger boutique Atlantic House Investments Limited. The team there comes from a derivatives background. That makes them highly mathematical and evidence-based. Every problem is analysed on the basis of the data that can contribute to finding an answer. in their theory. That knowledge base we have at the company gives us the fire power to deploy proprietory investment models built on long-term analysis of how asset classes behave, or how they are most likely to behave. In turn this allows us to deliver a proposition with an understanding of the expected returns the portfolios are likely to make, and deliver more specific investment goals for our advisers’ clients. We understand the paths of our portfolios, and so we also understand the uncertainty that sits around them. We are not in the business of over-promising and under-delivering. When putting together our portfolios we look at how the asset class will behave, and given the risk that the client is willing to take, what outcome is plausible, and in what range that return will be in. This allows us to determine whether it is possible to deliver a specific goal. In making our investment decisions, transparency is key. All of the funds we chose to put in the portfolios have notes attached to them that set our investment decision, and advisers can see what research we have done and see how we’ve come to our decision - there is no smoke and mirrors. Advisers can read up on these funds, do their own research, and importantly they can challenge us on our views. This business is our baby and we want to build it to last and not promise our clients more than we can deliver.

HOW FOCUSED ARE YOU ON KEEPING PRICES LOW?

There are a lot of model portfolio services that are trying to get costs as low as possible and what we’ve seen is a trend for those with low costs to buy semi-fettered, in-house funds. There is a pile them high, selling it cheap mentality but with a limited client relationship with each firm. We don’t think the focus is on putting prices down but on doing more for the money. We, of course, hope we can get people a better outcome in terms of returns but the fact is there is a large number of clever people all trying to solve the same problem and deliver returns to clients. What we can do on top of this is work hardest to make sure the clients understand what is happening with their money. We want to give people peace of mind over our investment process and that is more important than whether a model portfolio is three basis points cheaper. When it comes to cost, the focus should be on the cost of bespoke portfolios. Historically they have been around 1%, and this should be addressed, rather than whether a model portfolio service is 20 basis points or 25 basis points. What we are doing is giving advisers the ability to provide a more bespoke service, but on their own platform. Clients who need bespoke investment services have typically been moved to the DFM’s own-custody, but we are working with the adviser to use the platforms they want to use. Higher net-worth clients have also seen their portfolios split over three or four DFM services in a bid to diversify, but we find that when we help our partners to bring all these portfolios together to visualise them we find they are often all pointing in one direction and actually have less diversification than one portfolio could have.

HOW DOES USING ALBEMARLE IMPACT THE ADVISER-CLIENT RELATIONSHIP?

Our client is the adviser. At Albemarle, we do not have direct retail clients ourselves, so the way we partner with firms should remove the worry that the advisers’ relationship with their clients will be diluted in any way. The issue with some DFMs is that however hard they try not to take clients from an adviser - and 99.9% of the time DFMs do not want to take clients because it doesn’t make good business sense - sometimes a client will call up and ask to work directly with the DFM. We work with advisers, we work with the platform they have chosen, and we try hard to work alongside whichever strategy they have chosen to run their business in order to give the adviser more control. Advisers are putting a lot of trust in us when they choose to work with us; we know they are making big changes in the structure of their businesses and their communications with their clients. We want advisers to make the right decision and the best people they can speak to are our existing clients. They are going to tell the truth, they are going to identify what works, and where the challenges of moving to our system were, advisers can then make their own decision.

WHAT REGULATORY DRIVERS ARE THERE FOR THE MOVE TO CENTRALISED INVESTMENT PROPOSITIONS?

In general, a move to a centralised investment proposition reduces the risk in an adviser business. Using a proposition like Albemarle means an adviser can be confident that whatever the client’s risk profile, they will get a consistent outcome, which relieves the regulatory burden on the adviser. We know it is tough to run an advice firm and develop an investment proposition. Independent small firms have seen their PI go up, especially if they have done defined benefit transfer work, and Financial Conduct Authority fees have gone up - advisers are being squeezed harder than ever. We want to support them with an investment proposition that helps them build their business into something bigger without having to join a network and give a lot away, or sell to a consolidator without realising the true value of the business. Building a centralised investment proposition into their businesses, means advisers are building long-term value into the business. It makes a huge difference to the value in a business. There are myriad regulatory burdens on advice firms and it is hard work to get discretionary management permissions and is also a financial commitment that most advisers do not think it wise to make. We work with advisers to deliver the right outcomes for their client and to build value in their business - advisers are always front and centre of what we do, and their advice philosophy remains at the heart of their business.

About the respondants

Overall do you believe consolidation in the financial advisory market has been positive for clients?

When you think about business models how do you think you should grow?

What is the biggest challenge of independence?

What do you consider to be the main benefits of a more consolidated financial advice sector?

What do you believe are the main drawbacks of a more conslidated financial advice sector?

Would you like to grow your business through acquisition?

Do you believe a centralised investment
process can help your firm deliver consistent client outcomes and grow as a business?

Do you currently outsource your investment or research function to external providers?

Our Research in full

Our research was conducted between January and February of 2022 through online email survey.

Eleanor Williams
Partnerships Director

eleanor.williams@aspim.co.uk
+44 7791 565 006

Sarah Kennedy
Partnerships Support

sarah.kennedy@aspim.co.uk
+44 7507 873 005

get in touch For more information

© 2022 Albemarle Street Partners All Rights Reserved. The information, data, analyses, and opinions contained herein (1) include the proprietary information of Albemarle Street Partners, (2) may not be copied or redistributed without prior permission, (3) do not constitute investment advice offered by Albemarle Street Partners, (4) are provided solely for informational purposes and therefore are not an offer to buy or sell a security, and (5) are not warranted to be correct, complete, or accurate. Albemarle Street Partners shall not be responsible for any trading decisions, damages, or other losses resulting from, or related to, this information, data, analyses, or opinions or their use. Albemarle Street Partners is a trading name of Atlantic House Investments Ltd, which is authorised and regulated by the Financial Conduct Authority (“FCA”).