While 2020 will be remembered for its lockdowns and the impact of these measures on the real economy, multi-asset investors ended the year weary but unscathed. My three takeaways from the year are:
1.Never fight the Fed:
The Federal Reserve’s efforts to stabilise the bond market proved to be the turning point for financial markets. The European Central Bank (ECB) and Bank of England added further fire power, but credit spreads started to narrow as soon as the Federal Reserve started buying US treasuries, mortgage securities and corporate debt. By opening up US dollar liquidity to other central banks, the Federal Reserve prevented the onset of a financial contagion after the pandemic.
2. Sterling – a shock absorber:
Ever since the Brexit referendum, UK investors have become accustomed to sterling’s volatility. While this may be hedging nightmare for large corporates, UK investors have benefited from the procyclicality of the pound. Whenever there is a shock to the global economy, sterling tends to fall in value versus the US dollar, the euro and the Japanese yen. This benefits UK based multi-currency investors and is the main reason we have chosen not to hedge our foreign equity exposures.
Naysayers of the 60/40 portfolio were surprised once more as long duration bonds had another stellar year. The death of fixed income, a theme espoused by absolute return managers, was rebuffed once again in 2020.
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Atlantic House Fund Management LLP Pillar 3 Disclosure TThese statements are not part of the audited financial statements and therefore have not been subject to review or audit by the firm’s auditors. Overview The EU Capital Requirements Directive (“CRD”) sets out the regulatory capital framework which is overseen in the UK by the Financial Conduct Authority (”FCA”) and the Prudential Regulatory Authority (“PRA”) through the General Prudential Sourcebook (“GENPRU”) and the Prudential Sourcebook for Banks, Building Societies and Investment Firms (“BIPRU”). From 1 January 2014, with the implementation of the Capital Requirement Directive IV (CRV IV), regulations under BIPRU for this firm have been replaced by: - The Capital Requirements Regulation (“CRR”) - IFPRU sourcebook of the FCA handbook - additional standards released by the European Banking Authority The FCA framework consists of three 'Pillars': • Pillar 1: Minimum capital requirements • Pillar 2: Supervisory review process: the need to assess whether the capital held under Pillar 1 is sufficient to meet the additional risks not covered by Pillar 1 • Pillar 3: Disclosure requirements allowing market participants to assess information on a firms' risks, capital and risk management procedures The Financial Conduct Authority outlines the minimum disclosure requirements. The information below satisfies Atlantic House Fund Management LLP Pillar 3 requirement. Frequency of Disclosure Atlantic House Fund Management LLP will report their Pillar 3 disclosure annually or upon material change. These disclosures are based on the firm's position as at the account reference date of 30th June 2020. The Pillar 2 (ICAAP) capital requirements are excluded from this summary but are reviewed annually or upon material change These disclosures have been validated by the partners and are not subject to an audit except to the extent where they are equivalent to disclosures made under accounting requirements. Scope of Application This disclosure is made on an individual basis.
Risk Management The partners of the firm, in addition to the risk mapping structure of the ICAAP, are very much involved with the day to day running of the firm including the continual assessment of risk. They meet on a regular basis to discuss current projections for profitability, regulatory capital management, business planning and risk management. The partners manage the firm's risks through a framework of policy and procedures having regard to relevant laws, standards, principles and rules (including FCA principles and rules) with the aim to operate a defined and transparent risk management framework. These policies and procedures are updated as required. The firm is relatively small with an operational infrastructure appropriate to it size. The ICAAP has identified the most significant risk types to which Atlantic House Fund Management LLP to be as follows: • Operational Risk: This is the risk associated with inadequate, or the failure of, internal processes or external factors such as regulation. The legislative and political environment that Atlantic House Fund Management LLP operates in could be made more restrictive therefore reducing or removing profitability. Mitigation is that other systems are available to structure the business should the current business model become unavailable or impractical to use. People risk is mitigated by a flexibility of the work force to cover each key member’s responsibilities with no individual being critical to the company. IT risk is mitigated with daily backups, remote access and an efficient business continuity plan. • Business Risk: This is the risk that external factors, such as a fall in market appetite will result in an unexpected loss. A slowing economic environment could lead to a lessening appetite for the funds that Atlantic House Fund Management LLP act as investment advisor. This is mitigated by a low cost structure, flexible working arrangements and expanding funds under management. Reputational risk could be involved if Atlantic House Fund Management LLP gets involved with a fund that fails. This is mitigated by only marketing the products of very large and well established banks. • Liquidity Risk: This is the risk that Atlantic House Fund Management LLP will have insufficient funds to meet their capital requirements. Atlantic House Fund Management LLP is sufficiently financially robust to suffer a long period without any income generation and have the ability to raise further capital, should they so require. • Concentration Risk This is the risk that either too much of Atlantic House Fund Management LLP's business is concentrated in too small a sphere of operation or that the client base is concentrated in too few accounts. Atlantic House Fund Management LLP currently has an extensive client base within their funds. The sector of the business is very specialised but it is considered that there will always be a requirement for these types of funds. Capital Resources June 2020 £‘000s Core Tier 1 Capital 210 Total Tier 2 capital 0 Capital Resources Requirement 157 Capital adequacy in compliance with IFPRU 3, 4, 6 & 7 Atlantic House Fund Management LLP have forecasts in place to ensure that they will continue to meet they regulatory capital requirement on an ongoing basis. Atlantic House Fund Management LLP is a BIPRU €50,000 Limited Licence firm and, as such, are not required to calculate their operational risk capital requirement under Pillar 1 in accordance with BIPRU 6. Instead they are required to calculate a Fixed Overhead requirement in accordance with GENPRU 2.1.53R. The following figures are based on the GABRIEL return basis June 2020. The Credit Risk Capital Requirement is made up of the Credit Risk Capital Component and the Counterparty Risk Capital Component. The Credit Risk Capital Component is calculated in accordance with BIPRU 3.5 – The Simplified Method. The company makes an 8% adjustment on all fixed assets, debtors and prepayments and a 1.6% adjustment on all bank balances in accordance with BIPRU 3.4.127 – 3.4.133, resulting in a Credit Risk Capital Component of zero. The Counterparty Risk Capital Component is calculated in accordance with BIPRU 14.2.1 and is zero. The total Market Risk requirement, (BIPRU 11.5.12), has been calculated at zero and the Commodity PRR is zero. s
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