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For aspiring Appointed Representatives and Fund Managers


Starmark was established in 1998.  In 2005, Starmark Investment Management Limited (SIML) (previously Starmark Trading Limited) received authorisation from the Financial Services Authority, now the Financial Conduct Authority (FCA) to engage in investment management business. Since then, SIML has engaged in broking and fund management activities and has acted as Investment Manager for a number of offshore funds.

More recently, SIML has focused on providing regulatory umbrella services to facilitate activities of those who wish to advise on and arrange regulated business for professional clients via the Appointed Representative (AR) route and aspiring fund managers who wish to manage/trade client money by way of a fund or managed account. This involves obtaining the FCA's CF1 (AR) (director) and CF30 (customer) controlled functions for the AR through the Approved Persons Regime, and Certification status under the  Senior Managers & Certification Regime (SMCR) for those wishing to engage in fund management. ARs may not trade, so trading is done in the name of the authorised entity SIML with the AR acting as trading advisor. We recognise that regulatory costs can be a big issue for start-up operations which often expect to have only a few million to manage in the early days, so we offer a very competitive pricing arrangement to try to reduce the pain. We believe that we can do this by strictly controlling our own costs and avoiding trying to be all things to all people. The larger umbrella companies, which mostly cover the whole range of clients including retail, need to cover higher operating costs and regulatory risks associated with retail. We have decided to avoid the retail market and deal only with professional clients. 

Over the years we have established a close relationship with Ifina, a global fund administration company. Ifina also focuses on the smaller start-up funds, dealing only with professional clients. They offer very competitive pricing and the full range of administration services across many jurisdictions. We currently act as investment manager for several funds administered by Ifina in the Cayman Islands and have previously worked with them in the BVI.

The scope of SIML’s activities can be viewed on the FCA Register under reference number 190249. As indicated earlier, SIML deals only with professional clients and is not authorised to hold client funds.

If you are contemplating starting up a business as an Appointed Representative and/or in fund management please get in touch.


Eldon Kerr , or

Allan Kerr

What is an appointed representative?

An appointed representative is a firm that conducts regulated business under the umbrella of an FCA authorised firm, which acts as its ‘principal’. The principal firm takes regulatory responsibility for the appointed representative, and must ensure that the AR abides by all FCA Rules and its Code of Conduct. ARs must understand and comply with the regulatory requirements relating to their business.  The principal firm must be allowed access to staff, premises and records so that they can carry out their regulatory responsibility to monitor AR activities.

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