Track record as a nominee of a regulated fund

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Community Member

Aug 01, 2023

Hi, our previous fund sits as a nominee of an FCA regulated fund, we manage all the investments and fundraising, they manage the reporting and compliance with the FCA to allow us to operate. This is a fairly standard structure for early stage funds in the UK but we were told that this impacts our investing track record and should consider ourselves as 'raising our first fund'.

I have got conflicting opinions on how this impacts our track record - could anyone explain why this is potentially negative?

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1 answer

Haw Kuo

Accepted Answer

Nov 13, 2023

While we can't speak specifically as to an FCA regulated fund or being the nominee thereof - there are general principles to keep in mind.

Typically, vehicles may not be considered as being helpful for a "first fund" if:

the fund managers are not in complete control (and also own) of all of the fund's entities;
there is no management company (firm/brand) that will be carried over;
the fund is part of (or connected to) a larger structure (or regulatory regime) where there are entities involved that the fund managers do not control or own;

AngelList is one example - as investors do not own or operate the vehicles and are considered "consultants", AngelList vehicles are not considered helpful as a track record for a "first fund" (though they may be helpful for an angel investing track record, potentially).

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