We have the SMCR coming along in less than 3 months’ time. Are you ready? Is anyone ready? I’m not that convinced anyone really is.

The banks have already been through it but now it’s the time of the asset management industry and, judging by the nonchalance shown, I am not too certain many senior managers have realised the changes and expectations of the regulator which is just around the corner.

At a recent conference, Lord Myners, (incidentally my first boss back in the 80’s), welcomed the forthcoming introduction of the SMCR. Notably, he commented it was like a return to the days when many investment houses were partnerships and the partners took the liability of the business and, thus the responsibility if things went wrong. Today, accountability is moving away from the franchise holder approach of recent years, to senior managers and the collective responsibility has moved to personal responsibility. A positive approach says Myners.

Lord Myners

The tone of the business comes from above and sets the whole agenda as far as ethics and the approach to governance. It is true you can judge a company from the top and, if a senior manager has disdain for internal controls then you can bet your bottom dollar the whole business will reflect that. Examples have littered the industry over the year’s and, you could say if the SMCR had been in before the financial crisis, the wrong doings at RBSmight well have been avoided! A weak chairman not controlling their CEO- a recipe for disaster if ever there was one!

Fred Goodwin

With the advent of the SMCR we have the opportunity in the asset management industry to change things for the better, especially where risk has been exposed in recent months with Mr Woodford et al.   I would advocate if businesses struggle to implement the SMCR then they shouldn’t be in this game. It should be proportionate whilst being flexible but most importantly, at all times accountable.  We need to avoid the box ticking exercise that many firms seem to think that all this new governance. It is all about culture. What is endemic in your business should be for the greater good and ultimately investors. But we do have a dilemma potentially between directors and shareholders of public businesses.  Will shareholders give managers enough scope to implement SMCR, even if it means the returns to shareholders fall? It could be a serious conflict, meaning businesses may lose senior management getting voted off the boards by the shareholders for failing in their shareholder value for delivering strong corporate governance and accountability.

The SMCR is one further step to restoring the public’s faith in the asset management industry, although I would argue we have a long way to go. One aspect that is yet to be fully addressed is the significant conflict between the benefits to the investors and that of the managers of the business. Just as Turkeys tend not to vote for Christmas, there are many situations that arise in the running of an asset management business when there comes a time a senior executive has to make a decision that has the potential to go against their personal situation and, rather in favour of the investor.

Here is an example. A board is aware the is a cheaper option in the running of their fund  that being with a different provider.  However the consequence is a need to change the board and thus, they would lose their position. Tough call eh?  . What a dilemma and one I know exists and has existed before. So, how do we get around that and restore the confidence in the industry and avoid the “Self-Preservation Society” culture that seems to pervade everywhere.

At a meeting earlier this month, I met Matthew Priestley, a very experienced individual who has years of working in the area of fund governance. We were discussing the various changes in the fund management industry over the years and yet, the same mistakes were being made, time after time, just like a scene out of Groundhog Day!  The topic of oversight was clearly part of our conversation in light of the various articles that have appeared on social media platforms and in the pages of the trade press, as well as some national papers.   What we found amazing is despite the noise over Woodford, there has been no noticeable movement to change the status of many managers when it comes to how they see oversight.  To many, the idea of evidence-based oversight is an anathema and they would rather ‘tick a box’ than actually spend time demonstrating they are on top of the situation with regards the risk aspects of their business.

Now I am not suggesting all fund managers deliberately ignore regulatory controls but, more that the regulation is often so vague and unclear that many managers don’t realise that by just saying “yes’ to questions on oversight isn’t enough. You have to demonstrate you actually know what is going on within your fund and you have a clearly documented oversight process, not only giving comfort to the regulator but just as important, to investors.

The regulator has been remiss on many things over the years. It has spent far too long down amongst the weeds dealing with the minutia of the industry rather than addressing the key endemic and systemic problems we have. Some would argue that some of the rules that have been imposed by the FCA are not actually understood by the regulator itself!   The average age and experiences are woefully low amongst all regulators. Lots of people but not enough substance!

In recent weeks we have seen many fund buyers, particularly in the wealth management space, request full liquidity reports from fund managers. Some managers have responded quickly and accurately but not all have the ability to do so and have resorted to stress scenarios that, in reality may not be fit for purpose. I would challenge many managers to stand up to scrutiny when it comes to fully knowing what the position their portfolio would be in the event of perfect storm scenario. The problem is many just do not want to have to do it plus the independence of the report could be challenged. We need to see a raft of independent risk managers looking at the industry so as to allow managers to focus on what they do best. Some would argue fund managers should be monitoring risks at all levels however, in this day of challenging regulators and more savvy investors and advisers, there most definitely is an obligation for managers to articulate risk at all levels within their portfolios.

So, let us embrace the SMCR and be open to scrutiny with an approach that encourages independent thinking and never forgetting whose money it is……the investors.

“Hang on a minute lads, I’ve got a great idea…err, err..!”

Have a great and sunny weekend!

Stuart Alexander


gemini investment management london-1024

In other news...


You must submit your agreement before access to the site can be granted


This website is directed at institutional clients and individuals who have taken appropriate professional advice, who possess the necessary experience, knowledge and expertise to make their investment decisions and properly assess the risk that it incurs.

Gemini Capital Management (Ireland) Limited, trading as GemCap, is a limited liability company registered under the registered number 579677 under Irish law pursuant to the Companies Act 2014 which is regulated by the Central Bank of Ireland, reference number C155302. Its principal office is at Ground Floor, 118 Rock Rd, Booterstown, Co. Dublin, A94 V0Y7 and its registered office is at 1 WML, Windmill Lane, Dublin 2, D02 F206.

GemCap acts as management company and global distributor to GemCap Investment Funds (Ireland) plc.

GemCap Investment Funds (Ireland) plc is an umbrella fund with segregated liability between sub-funds incorporated as an investment company with variable capital registered under the registered number 485081 under Irish law pursuant to the Companies Act 2014 and authorised by the Central Bank of Ireland, reference number C67292, pursuant to the European Communities (Undertakings for Collective Investment in Transferable Securities) Regulations 2011 (as amended) ), having its registered office at 1 WML, Windmill Lane, Dublin 2, D02 F206(“the Fund”) .

The contents of this site have been prepared solely for information purposes and is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to law or regulation. GemCap and the Fund does not give or make any guarantee, representation, warranty or other promise or confirmation (whether express or implied) as to its accuracy or completeness.


Risk Warnings

Please remember that the value of investments and the income from them can fluctuate (this may partly be the result of exchange rate fluctuations) and you may not get back the full amount invested. Past performance may not a reliable guide to future performance. A comprehensive list of risk factors is detailed in the Prospectus and the key investor information document (“KIID”) and an investment should not be contemplated until the risks are fully considered. The Prospectus and KIID can be viewed at

GemCap does not provide financial, investment, tax or any other professional advice in any way and none of the information on this site should be construed as such. None of the information contained on this site constitutes an offer to buy or sell or a solicitation, recommendation, invitation by or on behalf of GemCap to buy or sell any security, product, service or investment. Any opinions expressed on this site do not constitute investment advice and independent advice should be sought where appropriate. The view and/or opinions expressed by GemCap through this or any other platform, may be subject to change.

The shares in the Fund have not been and will not be registered under the US Securities Act of 1933 (the “1933 Act”) as amended or the securities laws of any of the states of the United States. The Shares may not be offered, sold, transferred, pledged or delivered, directly or indirectly, in or into the United States or to or for the account or benefit of any US Person except pursuant to an exemption from, or in a transaction not subject to the registration requirements of the 1933 Act and any applicable state laws, nor in any jurisdiction in which the Fund is not authorised to be publicly sold. The Fund is available only in jurisdictions where their promotion and sale are permitted.

The information contained on the website may not be redistributed directly or indirectly to any citizen or resident of the United States or any other jurisdiction where its distribution may be restricted by law. It is the responsibility of persons accessing the website to ensure compliance with the above.

Disclaimer for Investors in Switzerland

The Fund and its sub-funds, Calamos Global Convertible Fund and Third Avenue Real Estate Value Fund has been approved by the Swiss Financial Market Supervisory Authority FINMA (“FINMA”) for offering to Swiss non-qualified investors.

This website may contain advertising.

In Switzerland, the representative is ACOLIN Fund Services AG, Leutschenbachstrasse 50, CH-8050 Zurich, whilst the paying agent is Banque Cantonale Vaudoise, Place St.-François 14, CH-1003 Lausanne.

Swiss investors may obtain free of charge from the representative in Switzerland, the relevant fund documents, namely the prospectus, the key investor information documents, the articles of association, as well as the annual and semi-annual reports.


Past performance results are no indication of future results. Issuance and redemption commissions are not included in the performance figures. Performance results referring to a period of less than twelve months (year-to-date-performance, start of investment fund within the last twelve months) are no reliable indicator for future results due to the short comparison period.


Additional information for Qualified Investors in Switzerland:

The below-mentioned investment funds, which are also disclosed on this website, are neither registered with FINMA nor under contract for representation to Swiss investors. These investment funds may not be distributed neither to Swiss non-qualified and qualified investors nor exclusively to Swiss qualified investors:


GemCap Investment Funds (Ireland) Plc

Atlantic House Defined Returns Fund

Atlantic House Global Defined Returns Fund

Atlantic House Total Return Fund

Atlantic House US Enhanced Equity Fund

Causeway Defined Growth Fund

GSI Global Sustainable Value Fund

GSI Global Sustainable Focused Value Fund

London & Capital Global Balanced Fixed Income Fund

London & Capital Global Conservative Fixed Income Fund

London & Capital Global Defensive Equity Fund (this Fund has terminated and accordingly, Shares in this Fund are no longer available for investment)

London & Capital Global Growth Fund

London & Capital Global Growth Fixed Income Fund

London & Capital Global Star Equity Fund

London & Capital Global Balanced Fund

Principal Asset Allocation Fund

Semper Total Return Fund

TEAM International Equity Fund




This GemCap website and material contained herein (including information from third parties) is provided ‘as is’, without any representation or endorsement made and without warranty of any kind whether express or implied, including, but not limited to, the implied warranties of satisfactory quality, fitness for a particular purpose, non-infringement, compatibility, security, completeness and accuracy.

By entering this site, you acknowledge and agree that the use of this site is at your own risk and to the extent permissible by applicable law, in no circumstances, including (but not limited to) negligence, shall GemCap be liable for any direct, indirect, incidental, special, consequential, or punitive damages, losses, costs or expenses nor for any loss of profit that results from the use of, or inability to use this site or any material on any site linked to this site (including but not limited to any viruses or any other errors or defects or failures in computer transmissions or network communications) even if we have been advised of the possibility of such damage. In addition, no liability can be accepted by GemCap in respect of any changes made to the content of this site by unauthorised third parties. All express or implied warranties or representations are excluded to the fullest extent permissible by law. We do not warrant that this site does not infringe any intellectual property rights of third parties.

No data transmission over the internet can be guaranteed as totally secure. Whilst GemCap strives to protect such information and every effort has been made to implement security protocols, in line with relevant legislation to ensure safe processing and storage of any data transmitted, we do not guarantee and cannot ensure the security of any information which you transmit to us. Accordingly, any information which you transmit to us is transmitted at your own risk.

The GemCap website is not a substitute for independent professional advice and users should obtain any appropriate professional advice relevant to their particular circumstances.

The information on this site is issued by GemCap.



If you use the internet quite a bit, there’s a good chance you’ve heard of cookies.

But what are they?

Also known as HTML cookies, tracking cookies or magic cookies, these tiny files are automatically downloaded by your computer when you’re browsing online. Don’t worry – they’re perfectly safe. But we’d still like to take a moment to explain what cookies do, which ones we use and how to remove them – if you really want to.

Are Cookies Safe?

Yes, cookies are safe. The information they collect is completely anonymous. We never, ever, collect personal information using cookies. What’s more, cookies are not harmful to your computer, they take up minimal space and they can be removed with just a few clicks.

GemCap’s Cookie Functionality

  • Cookies provide enhanced functionality and speed to our site
  • These cookies help us to recognise your computer when you visit and enable us to improve your visits to our website
  • Cookies assist us in identifying what kind of visitor/user you are, for us to provide you with the most relevant content

How Can I Remove Cookies?

Most computers are set to download cookies automatically, so if you’re happy with everything you’ve read, simply carry on as you were. However, if you’re at all concerned about having cookies on your computer, deleting them is simple.

Show me how to remove cookies

Likewise, you can also change your computer settings so that it won’t download any more cookies.

Show me how to change my cookie settings

The information on this site is issued by Gemini Capital Management (Ireland) Ltd, which is registered in Ireland No. 579677. The registered address for the company is 1 WML, Windmill Lane, Dublin 2, D02 F206, Ireland.