Clause No

Clause Heading

Amendment(s)

1

General

Please read this document in conjunction with Our following documents:

·       Privacy Policy 
·       Best Execution for Client Deals Policy
·       Conflict of Interest Policy
·       Terms and Conditions (Personal or     
 Corporate) as applicable to your circumstances which can be found on Our website www.alphabanklondon.co.uk.

2

Services

We have updated the examples of Complex financial instruments in Clause 2.3 to include unlisted shares. 

For non-advised services, we have included Clause 2.7 stating that we may provide you with a list of products (bonds or ETFs) that are available through Our execution-only service.

In Clause 2.8, we have clarified that Our staff are available to call from 9am to 5pm UK time, Monday to Friday, excluding UK public holidays.

4

Fees and Expenses

In Clause 4.1, we have provided additional details and an explanation as to how investment tariff amendments are communicated, where Our current Investment Tariff can be found, and what notice periods are applicable for any changes thereto to become effective.

In Clauses 4.4, 4.5 and 4.6, we have included two more charge types: Inducements and Mutual Fund Rebates.  We have further clarified what a mutual fund rebate is, how they work and how we will advise you of such rebates received by the Bank on an annual basis so as to be transparent and in doing so comply with MIFID II regulations.

5

Client Money

We have changed the section heading from “Client Money” to “Client Money Under CASS Rules”. CASS Rules are the rules that govern how institutions hold client money and assets. As a Bank there are certain differences applicable to ABL where you also hold an account from which you can directly fund investment purchases from and receive dividends and sale proceeds to.

6

Safe Custody Services and Security

In Clause 6.1, we have removed deposit stocks and money market instruments to avoid confusion and reiterated that Our Best Execution products offering includes equities, bonds, and mutual funds.

In Clause 6.2, we have explained further how Nominee fees are calculated and may apply to an account. Please see Our Investment Tariff available on Our website for further clarification

www.alphabanklondon.co.uk/mdocuments-library.

Reference to unavailable or unrecognised jurisdictions’ list has been removed.

In Clause 6.4, we have taken the opportunity to reinforce and remind you that “Your securities may normally be held in an omnibus account with other clients’ assets. In the event of an irreconcilable shortfall following the failure of a custodian or sub-custodian, you might experience delays in recovering your assets and possibly an increased risk of loss.”

7

Settlement Procedures

Clause 7.2 has been updated so that it clarifies that your account may be debited before the actual settlement occurs or potentially if the settlement fails.

8

Conflicts of Interest and Material Interests

As we only provide an “Execution Only” service and do not provide services such as research, we have removed the term “full-service firm” from Clause 8.1.

In Clause 8.6, we now reference Our Conflict-of-Interest Policy which has been refreshed and been made available on Our website

www.alphabanklondon.co.uk/conflicts-of-interest-policy instead of Schedule 2 which has now been removed from the Terms of Business document.

9

Best Execution

In Clause 9.1, we provide an enhanced explanation of the term “Best Execution” in compliance with MIFID II and TCF principles.

In Clause 9.3, the criteria for Best Execution have been updated to consider the following execution factors: price; costs; speed; the likelihood of execution and settlement; size and nature of the order; and any other considerations.

Clause 9.4 explains aggregate client orders and IPOs in greater detail.

Clause 9.7 references the latest version of Our Best Execution for Client Deals Policy, which is available on Our website www.alphabanklondon.co.uk/best-execution-for-client-deals-policy.

10

Default Remedies

Clause 10.2 now references the interest rate applicable when you are in default in paying any amount when due to the Bank. This has been increased from 5% to 6% plus Bank of England Base Rate or equivalent reference rate of the currency of the account.

11

Data Protection

The data protection Clause in 11.1 has been revised to clarify how we collect, process, and retain your information in accordance with applicable regulations.

Clause 11.2 references Our latest Privacy Notice which can be found on Our website; please visit Our website for more details www.alphabanklondon.co.uk/wp-content/uploads/2022/01/GDPR-Privacy-Notice-External.pdf      

12

Information we provide to you

Clauses 12.1 and 12.2 have been revised and 12.3 has been added to clarify your responsibility regarding marketing materials which should not be shared with any other person, the terms of an investment or its performance characteristics and that we are not responsible for any investment, tax, legal, or accounting-related advice or consequences.

15

Representations and Warranties

We have added Subclause 15.1 (g) which reminds you of your responsibility to ensure that the information you provide to us is true, accurate, and not misleading.

16

General

Clause 16.1 has refined the definition of delivery to mean when first supplied to you upon opening a new Account, along with the requirement to provide the Bank with a written acceptance of these Terms of Business and the consequences if this is not done.

Clause 16.2 which addresses amendments to these Terms of Business has been rewritten to clarify how amendments may be communicated to you, as well as any applicable notice periods.

We have added new clauses to clarify Our policies and practices around the Death of Sole Account Holder (Clause 16.3 (e)) and the Death of Joint Clients (Clause 16.13 (a) (iii)). For more information, please refer to Our Bereavement Notification section on Our website www.alphabanklondon.co.uk/deceased.

Clause 16.9 reminds you that in accordance with the appropriate regulations, we will record telephone conversations with you and a copy of the call recording will be retained for a period of five years.

17

Notices

For your investments and cash, Clauses 17.1 (d) and 17.3 now allow you to receive monthly Valuation Reports through secure email.

When you opt for physical Valuation Reports, you will receive them quarterly by post as per Clause 17.3.

18

Changes to Your Personal Circumstances

In Clause 18.1, we have reminded you of your obligation to ensure that any changes to your personal circumstances should be notified to Us promptly.

19

Complaints

We have added Clause 19.2 to advise you that the Bank will send you a written acknowledgment in the case of a Complaint.

In Clauses 19.5 and 19.7, we have also updated the Financial Ombudsman Service and Information Commissioner’s Office contact details respectively.

20

Investor Compensation

In this section, we have updated the information in relation to Financial Services Compensation Scheme that might be available to you for your investments and added the Financial Services Compensation Scheme contact details.

21

Governing Law and Jurisdiction

In Clauses 21.1 and 21.2, we have updated the governing law and jurisdiction to correctly reflect that it is England and Wales, and not just England.

Schedule 1

Investment Services

Under the heading “Our services may include” we have removed the sentence “sending research and market reports to you” as this is not a service we provide as an Execution only venue.

Schedule 2

Best Execution for Client Deals Policy

A separate Best Execution for Client Deals Policy can now be found on Our website

www.alphabanklondon.co.uk/best-execution-for-client-deals-policy. This replaces the Order Execution Policy information previously found in Schedule 2 of Our 2018 Terms of Business document.

Schedule 3

Conflicts of Interest Policy

A separate Conflicts of Interest Policy can now be found on Our website www.alphabanklondon.co.uk/conflicts-of-interest-policy. This replaces the Conflicts of Interest policy previously found in Schedule 3 of Our 2018 Terms of Business document