Stewardship Code
Under Rule 2.2.3R of the FCA’s Conduct of Business Sourcebook, Copper Street Capital LLP (“Copper Street” or the “firm”) is required to include on this website a disclosure about the nature of its commitment to the UK Financial Reporting Council’s Stewardship Code (the “Code”) or, where it does not commit to the Code, its alternative investment strategy. The Code is a voluntary code that sets out a number of principles relating to engagement by investors with UK equity issuers.
Pillar 3 Disclosures
The purpose of this document is to set out the Pillar 3 disclosures of Copper Street Capital as of December 2019.
The Capital Requirements Directives (CRD) for the financial services industry is a supervisory framework in the European Union which reflects the Basel II and Basel III rules on capital measurement and capital standards. The capital framework consists of three Pillars:
- Pillar 1 determines the minimum capital requirements of firms to cover credit, market, and operational risk. These comprise: base capital resources requirements; credit risk and market risk capital requirements; and the fixed overhead requirement.
- Pillar 2 requires firms to analyse the risks to the business and then consider whether the risks are mitigated to an appropriate standard. If the firm feels that the risks are not adequately mitigated then they should allocate capital against those risk. Stress and scenario tests are conducted to ensure that the processes, strategies and systems are comprehensive and robust and that the allocation of capital is sufficient
- Pillar 3 complements Pillars 1 and 2 and improves market discipline by requiring firms to disclose information on their capital resources and requirements, risk exposures and their risk management framework.
The CRD came into effect on 1 January 2007, establishing a revised regulatory capital framework governing the amount and type of capital that must be maintained by credit institutions and investment firms based on the provisions of the Basel II Capital Accord.
CRD IV, effective from 1 January 2014, implements the Basel Ill agreement in the European Union. It was designed primarily for credit institutions and banks but is also applicable to certain investment firms. Copper Street Capital does not fall into this category and remains subject to the CRD III legislation.
The CRD is implemented in the United Kingdom by the UK Regulators, The Prudential Regulatory Authority (PRA) and The Financial Conduct Authority (FCA).
Pillar 3 Disclosures – Copper Street Capital 2019
RTS28 Annual Qualitative Disclosure
This disclosure if being made pursuant to Article 3(3) of RTS 28 and/or Article 65(6) of the MiFID II Delegated Organisational Regulation, which require firms to disclose, for each class of financial instruments traded for clients during the period, a summary of the analysis and conclusions drawn from the execution quality monitoring that the Firm has undertaken.
This disclosure covers the following classes of financial instruments that were traded during the period. Copper Street Capital has a sole focus in financials and it invests across the capital structure of financial companies from debt to equity with a global mandate.
RTS28 Quantitative Top 5 Disclosure
This disclosure is being made pursuant to Article 3(1) of RTS 28, which require firms to disclose, for each class of financial instruments traded during the period, the top 5 venues or
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