Financial services and regulation - Recognition of relevant ...

Learning Outcomes

This article outlines the UK regulatory framework for financial services under the Financial Services and Markets Act 2000 (FSMA 2000), including:

• FSMA 2000 regulatory framework and the roles of the FCA and PRA
• The general prohibition on unauthorised regulated activities (s 19 FSMA 2000)
• Specified activities and specified investments under the Regulated Activities Order (RAO) 2001
• The “by way of business” test in the context of solicitors’ work
• Key RAO exclusions and their limits for insurance distribution (introducing, acting via an authorised person, trustee/personal representative, necessary, takeover)
• The s 327 FSMA professional firm exemption and SRA Financial Services (Scope) Rules and SRA Financial Services (Conduct of Business) Rules (status disclosure, accounting for commission, record-keeping)
• The financial promotions regime under s 21 FSMA and the Financial Promotion Order (FPO) 2005 (real-time vs non-real-time communications and approval requirements)
• Insurance distribution and consumer credit issues in everyday practice (defective title insurance, ATE insurance, fee instalment arrangements), and routes to authorisation, exemption, or exclusion
• Consequences of FSMA breaches, including criminal liability and potential unenforceability of agreements
• Recognition of financial services issues and application of correct legal principles in SQE1 assessments

SQE1 Syllabus

For SQE1, you are required to understand the financial services regulatory structure under FSMA 2000 and how it impacts solicitors' work, including identifying when client matters involve potential financial services issues (particularly regulated activities and specified investments) and understanding available exemptions, especially the s 327 exemption, with a focus on the following syllabus points:

• The overall regulatory framework for financial services under FSMA 2000.
• The scope of the general prohibition (s 19 FSMA 2000).
• Identifying specified activities and specified investments as defined in the Regulated Activities Order (RAO) 2001.
• Recognising the criteria for the s 327 exemption for professional firms.
• Understanding the implications of carrying out regulated activities without authorisation or exemption.
• The Financial Promotion regime in s 21 FSMA 2000 and the FPO 2005, including real-time vs non-real-time communications and approval requirements.
• SRA Financial Services (Scope) Rules and SRA Financial Services (Conduct of Business) Rules, including status disclosure, accounting for commission, execution-only confirmations, and record retention.
• Insurance distribution activities under the Insurance Distribution Directive (IDD) regime and the extra restrictions for insurance-related work.
• Consumer credit activities that may arise in practice (e.g., credit broking, debt adjusting, debt counselling) and relevant exemptions (e.g., interest-free instalments).

Test Your Knowledge

Attempt these questions before reading this article. If you find some difficult or cannot remember the answers, remember to look more closely at that area during your revision.

1. Under FSMA 2000, what is the 'general prohibition'?
2. Which piece of secondary legislation primarily defines 'specified activities' and 'specified investments'?
3. Can a solicitor advise a client on the merits of investing in shares of a specific company without potentially carrying out a regulated activity?
4. What are two key conditions for a solicitor's firm to rely on the s 327 exemption?

Introduction

Solicitors often encounter financial elements within client matters, such as conveyancing involving mortgages, company work involving share transactions, or administering estates with investment portfolios. While solicitors are not typically financial advisors, their activities can sometimes fall within the scope of financial services regulation, primarily governed by the Financial Services and Markets Act 2000 (FSMA 2000). Understanding this regulatory environment is essential to avoid breaching the law and to advise clients appropriately.

This article focuses on recognising when a solicitor's actions might constitute a 'regulated activity' under FSMA 2000, the implications of the 'general prohibition' against unauthorised activity, and the key exemptions available to legal professionals.

The UK framework separates conduct regulation and prudential supervision, principally through:

• The Financial Conduct Authority (FCA), which regulates the conduct of firms and financial markets, with objectives that include consumer protection, market integrity, and effective competition.
• The Prudential Regulation Authority (PRA), part of the Bank of England, responsible for the safety and soundness of systemically significant firms (e.g., banks and insurers).

FSMA 2000 provides the central legal structure, implemented and detailed by Treasury orders (notably the RAO 2001) and supplemented by SRA rules that apply to solicitors relying on the professional firm exemption.

The Regulatory Framework

The UK's financial services sector is regulated by two main bodies established under the Financial Services Act 2012:

1. Financial Conduct Authority (FCA): Regulates the conduct of all financial services firms and the prudential regulation of firms not overseen by the PRA. Its objectives include consumer protection, market integrity, and fostering competition.
2. Prudential Regulation Authority (PRA): A part of the Bank of England, responsible for the prudential regulation of significant firms like banks and insurers, focusing on their safety and soundness.

FSMA 2000 provides the overarching legal framework, establishing prohibitions and requirements for carrying out financial activities.

FSMA is supported by Treasury secondary legislation. Most “what counts” questions are answered by the RAO 2001 (specified activities and investments) and the FPO 2005 (financial promotions), both of which are frequently updated. Solicitors who rely on the professional firm exemption must also comply with the SRA Financial Services (Scope) Rules and the SRA Financial Services (Conduct of Business) Rules (e.g., status disclosure, commission accounting, records, and execution-only confirmations).

The General Prohibition (Section 19 FSMA 2000)

Section 19(1) FSMA 2000 contains the 'general prohibition'.

Key Term: General Prohibition
The rule under s 19 FSMA 2000 stating that no person may carry on a regulated activity in the UK unless they are an authorised person or an exempt person.

Breaching the general prohibition is a criminal offence, carrying penalties of imprisonment and/or an unlimited fine (s 23 FSMA 2000). Agreements made in contravention of s 19 may also be unenforceable against the other party (s 26 FSMA 2000).

An authorised person generally means a firm or individual authorised by the FCA or PRA. An exempt person includes those benefiting from specific exemptions within FSMA 2000 or related orders, such as professional firms meeting the conditions of s 327.

The prohibition applies broadly. Any activity satisfying the statutory test for a regulated activity (specified activity, specified investment, carried on by way of business, and no exclusion) falls within s 19 unless authorisation or exemption is present. The “business” limb is interpreted realistically in the context of professional practice; advice provided in the course of a solicitor’s work normally satisfies it.

Regulated Activities

For the general prohibition to apply, an activity must be a 'regulated activity'. Under s 22 FSMA 2000, an activity is regulated if it meets all of the following criteria:

1. It is an activity of a specified kind (a 'specified activity').
2. It relates to an investment of a specified kind (a 'specified investment').
3. It is carried on by way of business.
4. No exclusion applies.

The Treasury specifies the relevant activities and investments, primarily in the Financial Services and Markets Act 2000 (Regulated Activities) Order 2001 (SI 2001/544) (the 'RAO').

The Business Test

The activity must be conducted 'by way of business'. For solicitors, advice or assistance given within their professional practice generally meets this test. Advice given in a purely personal capacity (e.g., to a family member informally) would typically not.

The business test does not turn on whether a fee is charged for the particular piece of advice. What matters is the overall context: is the activity carried on in the course of a business? Thus, as part of a legal retainer, a short piece of investment-related guidance that contributes to a client’s matter will often be “by way of business” even if unbilled.

Specified Investments

Part III of the RAO lists numerous specified investments. You do not need to memorise the entire list, but you must be able to recognise common examples relevant to legal practice.

Key Term: Specified Investment
An investment of a type listed in Part III of the RAO 2001. Activities relating to these investments may be regulated.

Common examples include:

• Shares in a company (Art 76)
• Debentures, loan stock, bonds (Art 77)
• Government and public securities (e.g., gilts) (Art 79)
• Units in a collective investment scheme (e.g., unit trusts) (Art 81)
• Rights under a contract of insurance (e.g., life policies) (Art 75)
• Regulated mortgage contracts (Art 88) - broadly, first legal mortgages on residential property where the borrower is an individual or trustee.
• Deposits (Art 5) - but note that accepting deposits is the primary regulated activity here.

Importantly, land itself is NOT a specified investment. Therefore, merely advising on the purchase or sale of land does not typically constitute a regulated activity relating to a specified investment.

Practical tip: mixed transactions are common. For instance, a share sale with associated warranties might also involve options, guarantees, or instruments creating indebtedness. Some elements may be specified investments whereas others (e.g., the sale of land or assets) are not. Always isolate the investment-related component before applying FSMA.

Specified Activities

Part II of the RAO lists the specified activities. Again, you must recognise common examples:

Key Term: Specified Activity
An activity listed in Part II of the RAO 2001. Carrying on such an activity in relation to a specified investment by way of business may require authorisation.

Examples relevant to solicitors include:

• Dealing in investments as agent (Art 21): Buying, selling, subscribing for, or underwriting specified investments on behalf of a client.
• Arranging deals in investments (Art 25): Making arrangements for another person (client or otherwise) to buy, sell, subscribe for, or underwrite a specified investment. This is broadly interpreted.
• Managing investments (Art 37): Managing assets belonging to another person involving the exercise of discretion.
• Safeguarding and administering investments (Art 40): Both safeguarding (custody) and administration (services related to the assets) must be present.
• Advising on investments (Art 53): Giving advice to a person in their capacity as an investor (or potential investor) on the merits of buying, selling, subscribing for, or underwriting a particular specified investment.

“Arranging” is interpreted broadly. Sending a signed acceptance to a broker, introducing a client to a platform with further involvement, or coordinating execution can be arranging. Conversely, purely administrative communications without facilitation or recommendation may be outside Art 25.

Revision Tip

General advice (e.g., explaining the features of different types of investments like shares vs bonds) is usually not a specified activity under Art 53. The activity becomes regulated when the advice pertains to the merits of investing in a particular specified investment (e.g., advising a client to buy shares in Company X).

Exam Warning

General advice (e.g., explaining the features of different types of investments like shares vs bonds) is usually not a specified activity under Art 53. The activity becomes regulated when the advice pertains to the merits of investing in a particular specified investment (e.g., advising a client to buy shares in Company X).

Worked Example 1.1

A solicitor is advising a client on setting up a new company. The client asks whether it would be better to fund the company through bank loans or by issuing shares. The solicitor explains the general advantages and disadvantages of debt versus equity finance.

Is the solicitor carrying out a regulated activity?

Answer:
No. The solicitor is providing generic advice about funding structures, not advising on the merits of investing in shares of a particular company or taking out a particular loan instrument (which could be specified investments). This does not fall under Art 53 RAO.

Worked Example 1.2

During probate administration, a solicitor is instructed by the executor to sell shares held by the deceased in a publicly listed company (PLC). The solicitor contacts a stockbroker and instructs them to sell the shares.

Is the solicitor carrying out a regulated activity?

Answer:
Possibly. Arranging the sale of shares (a specified investment) could fall under Art 25 RAO (Arranging deals in investments). Dealing as agent (Art 21) might also be relevant depending on the exact instructions given. However, exclusions or exemptions might apply (see below).

Exclusions from Regulated Activities

Even if an activity appears to be a specified activity relating to a specified investment carried on by way of business, it is NOT a regulated activity if an exclusion applies. The RAO contains numerous exclusions. Key examples relevant to solicitors include:

• Introducing (Art 33 RAO): Arranging deals (Art 25) is excluded if it involves merely introducing the client to an authorised person (like an Independent Financial Adviser - IFA) or distributing an authorised person's communications, provided the solicitor takes no further part in the transaction and does not receive commission for the introduction (other than from the client). Does not apply to insurance contracts.
• Acting through an Authorised Person (Art 29/30 RAO): Arranging (Art 25) or dealing as agent (Art 21) is excluded if the transaction is entered into on advice given to the client by an authorised person, or where the client (not seeking advice from the solicitor) deals through an authorised person. Again, the solicitor must not receive undisclosed commission. Does not apply to insurance contracts.
• Acting as Trustee or Personal Representative (Art 66 RAO): Arranging, managing, safeguarding, advising, or dealing as agent is excluded if done while acting as a trustee or personal representative (PR), unless remunerated specifically for that activity (separate from usual trustee/PR fees) or holding oneself out as providing such services. Does not apply to insurance distribution.
• Activities carried on in the course of a profession or non-investment business ('Necessary' Exclusion) (Art 67 RAO): Advising, arranging, safeguarding, or dealing as agent is excluded if it is a necessary part of other professional services provided, and not remunerated separately. This is interpreted strictly – the regulated activity must be subordinate and essential for the main professional service. Does not apply to insurance distribution.
• Sale of a Body Corporate ('Takeover' Exclusion) (Art 70 RAO): Arranging, advising, or dealing as agent is excluded if the transaction involves acquiring or disposing of shares representing 50% or more of the voting rights in a company (or otherwise acquiring day-to-day control). Does not apply to insurance contracts.

Solicitors regularly rely on these exclusions in day-to-day practice. However, reliance is fact-specific. For example, a simple introduction to an IFA is excluded, but drafting investment instructions or negotiating pricing may amount to arranging. Likewise, a PR selling a portfolio can rely on Art 66, provided they do not receive separate investment-related remuneration and do not hold out investment services.

Revision Tip (Exclusions)

Note that several key exclusions (Introducing, ATP, Necessary, Takeover) specifically do not apply to insurance-related activities. Insurance distribution is subject to its own regime (see below).

Worked Example 1.3

A solicitor acting on a house purchase arranges a life insurance policy linked to the client's mortgage. The solicitor receives a commission from the insurance company but does not inform the client or account for it. The firm relies on the s 327 exemption.

Has the firm complied with the conditions for the s 327 exemption?

Answer:
No. The firm received a pecuniary reward from a person other than the client (the commission from the insurer) arising out of the activity (arranging the insurance) and failed to account for it to the client. This breaches a key condition of the s 327 exemption. The firm may also have breached the SRA's specific conduct rules regarding commissions.

Exemption for Professional Firms (s 327 FSMA 2000)

If a solicitor's activity is a regulated activity (specified activity + specified investment + business test + no exclusion applies), they will breach the s 19 general prohibition unless they are authorised by the FCA or can rely on an exemption. The most important exemption for solicitors is the s 327 exemption for members of Designated Professional Bodies (DPBs).

The Law Society (and therefore the SRA) is a DPB. This allows SRA-regulated firms (known as Exempt Professional Firms or EPFs when relying on this) to carry out certain regulated activities without needing FCA authorisation, provided strict conditions are met.

Key Term: Exempt Regulated Activity
A regulated activity carried on by a member of a Designated Professional Body (like an SRA-regulated firm) which is exempt from the general prohibition under s 327 FSMA 2000 because certain conditions are met.

The key conditions for the s 327 exemption are:

1. Incidental Provision: The regulated activity must be incidental to the provision of the professional services provided by the firm. It cannot be a major part of the firm's business. The SRA Financial Services (Scope) Rules state it must arise out of, or be essential to, a specific professional service provided to that client.
2. No Separate Remuneration: The firm must not receive any pecuniary reward or advantage from anyone other than the client for the regulated activity, for which it does not account to the client. This prevents firms receiving undisclosed commissions related to exempt regulated activities.
3. Permitted Activities Only: The firm must only carry on regulated activities permitted under the exemption (as set out in the SRA Scope Rules and the FSMA 2000 (Professions) (Non-Exempt Activities) Order 2001). Certain higher-risk activities are prohibited.
4. Regulation: The firm must be regulated by a DPB (like the SRA) and comply with its rules (e.g., SRA Financial Services (Conduct of Business) Rules).

Under the Conduct of Business Rules, solicitors must:

• Provide clear written status disclosure before providing any service that involves carrying on a regulated activity, including stating that the firm is not authorised by the FCA and naming the regulated financial services activities carried out.
• Keep records of transactions and any commission earned, demonstrating how the firm has accounted to the client.
• Confirm execution-only arrangements in writing (i.e., that no advice has been given on a retail investment and the client persisted in seeking execution), and retain records for six years.

Exam Warning (s 327 Exemption)

Remember the s 327 exemption is narrow. The activity must be genuinely incidental to the main legal work, and the rules on commission and permitted activities are strict. Do not assume the exemption applies automatically just because a solicitor is involved.

Worked Example 1.4

A corporate solicitor negotiates the sale of 60% of the voting shares in a private company and, as part of the “bundle” of services, recommends a specific investment fund for the client’s surplus proceeds and arranges subscription forms.

Can the solicitor rely on the professional firm exemption for the share sale and the fund subscription?

Answer:
The share sale element is covered by the RAO “takeover” exclusion (Art 70), so arranging or advising on the acquisition/disposal of control does not amount to a regulated activity. The recommendation and arrangement of units in a specific fund is a separate regulated activity (advising/arranging in relation to a specified investment) that is not covered by Art 70. Reliance on s 327 would require that the investment work is incidental to the legal service; recommending a particular fund is unlikely to be “incidental” and would take the activity beyond the scope of the exemption.

Worked Example 1.5

A litigator settles a damages claim and, at the client’s request, provides high-level information about cash deposits vs gilts and introduces the client to a wealth manager, taking no further part. No fee or benefit is received from the wealth manager.

Is the solicitor within FSMA?

Answer:
Generic information about deposits and gilts is not advising on a particular investment under Art 53. A pure introduction to an authorised person is excluded under Art 33. No regulated activity is carried on.

Financial Promotions (Section 21 FSMA 2000)

Separate from the general prohibition on regulated activities (s 19), s 21 FSMA 2000 restricts financial promotions. An unauthorised person must not, in the course of business, communicate an invitation or inducement to engage in investment activity, unless the content is approved by an authorised person.

Key Term: Financial Promotion
A communication, in the course of business, that invites or induces someone to engage in investment activity (e.g., buy/sell specified investments).

This covers advertisements, emails, letters, website content, and even oral communications that encourage investment activity related to controlled investments (which largely overlap with specified investments). Various exemptions exist under the Financial Services and Markets Act 2000 (Financial Promotion) Order 2005 (FPO), including exemptions for professional firms relying on the s 327 exemption, subject to conditions (FPO arts 55/55A).

Key points:

• Both real-time (e.g., personal meetings, phone calls) and non-real-time (e.g., letters, emails, brochures, websites) communications are caught. “Solicited” communications may attract different exemptions compared to unsolicited.
• The RAO exclusions do not apply to financial promotions; an activity may be unregulated yet still be a controlled promotion under s 21.
• Communications must be approved by an authorised person unless a specific FPO exemption applies (e.g., communications to existing clients in certain circumstances, trustee/PR communications, takeover communications).

Breaching s 21 is a criminal offence (s 25 FSMA 2000). In practice, EPFs use standard wording for websites and marketing and often have their financial promotions pre-approved or rely on narrow FPO exemptions. Any approval must be explicit; merely sending a communication to an authorised person does not amount to approval.

Worked Example 1.6

A probate solicitor emails beneficiaries explaining that the estate will shortly dispose of the deceased’s listed shares and encourages them to consider buying a tranche, attaching analyst reports. The firm is not authorised.

Is this caught by the financial promotions regime?

Answer:
Yes. The email likely invites or induces engagement in investment activity concerning controlled investments (shares). Unless an FPO exemption applies or the content is approved by an authorised person, s 21 would be breached. Note that RAO trustee/PR exclusions do not disapply s 21 FSMA.

Insurance Distribution Activities

Arranging or advising on contracts of insurance often falls under a specific regime implementing the Insurance Distribution Directive (IDD). Many standard FSMA exclusions (e.g., Art 67 Necessary Exclusion) do not apply. Firms relying on the s 327 exemption to conduct insurance distribution activities (e.g., arranging ATE insurance in litigation or defective title insurance in conveyancing) must comply with additional requirements under the SRA Scope Rules and Conduct of Business Rules, including potentially appointing an insurance distribution officer and meeting specific information requirements for clients.

Insurance work brings its own obligations in addition to FSMA:

• Provide pre-contract information tailored to the client’s demands and needs.
• Avoid conflicts of interest and ensure any remuneration arrangements do not impair compliance.
• Make status disclosures and commission accounting clear and in writing.
• Keep records (including demands-and-needs statements and commission logs) for at least six years.

Failure to comply may amount to both a FSMA breach (if the activity falls outside the exemption) and SRA misconduct.

Worked Example 1.7

A conveyancer recommends a specific defective title insurance product, helps complete the proposal, and receives a commission from the insurer for placement. The commission is not disclosed to the client.

Can the firm rely on s 327?

Answer:
No. Insurance distribution exclusions are limited. The activity is not “incidental” if it becomes a separate monetised service, and the firm must account to the client for any pecuniary advantage. The failure to disclose and account for commission breaches the s 327 condition and SRA Conduct of Business requirements.

Consumer Credit Activities

Certain activities relating to consumer credit (e.g., credit broking, debt adjusting, debt counselling) are regulated activities under FSMA. Solicitors whose work involves these areas (e.g., allowing clients extended time to pay fees, which might constitute providing credit) need to consider whether they require FCA authorisation or if their activities fall within the s 327 exemption. Specific exemptions exist for certain fee payment arrangements (e.g., allowing payment in up to 12 instalments over 12 months without interest).

Practical examples:

• Credit broking: Introducing a client to a third-party lender to fund litigation or a corporate transaction can engage consumer credit regulation. Pure introductions to authorised lenders may be excluded; more involvement can trigger credit broking.
• In-house credit: Allowing a client to pay fees in instalments may amount to providing credit. A common exemption covers arrangements with no interest and no more than 12 instalments over 12 months. If interest is charged or the term exceeds the exemption, authorisation may be required unless s 327 applies and its conditions are satisfied.

When dealing with credit-related services, apply the same discipline: check whether the activity relates to a specified investment, whether an RAO exclusion applies, and whether the s 327 exemption is available. Separately, test whether a financial promotion is being made (e.g., marketing of instalment plans) and whether any FPO exemptions apply.

Exam Warning (Consumer Credit)

Allowing fee instalments can constitute the provision of credit. If interest is charged or the term exceeds 12 months/12 instalments, authorisation may be required. Even interest-free arrangements can trigger s 21 FSMA if promoted improperly.

Consequences of Breach and Unenforceability

Carrying on a regulated activity without authorisation or exemption is a criminal offence (s 23 FSMA 2000). Agreements made in contravention of s 19 FSMA may be unenforceable against the other party (s 26 FSMA 2000), subject to limited court powers to allow enforcement where just and equitable. Breach of s 21 FSMA (financial promotions) is a separate offence (s 25 FSMA 2000) and can carry significant penalties.

For solicitors, FSMA breaches can also lead to SRA regulatory action (e.g., findings of misconduct concerning honesty, integrity, and compliance with the law), reputational damage, and civil exposure. Firms should keep robust records and ensure clear governance: status disclosures, commission accounting, execution-only confirmations, and retention of records (commonly six years) are essential controls.

Putting It All Together: Practical Recognition Steps

When a potential financial services issue arises in practice:

• Identify the investment: is it a specified investment (shares, gilts, units, insurance rights, mortgages, etc.)?
• Identify the activity: is it specified (advising, arranging, dealing, managing, safeguarding)?
• Confirm it is carried on by way of business (in practice, most legal services contexts will be).
• Check for any exclusion under the RAO (e.g., introduction to an authorised person, acting via an authorised person, trustee/PR, necessary, takeover).
• If no exclusion applies, test whether the s 327 exemption can be used:
  • Is the activity incidental to the legal service?
  • Is it within permitted activities?
  • Has the firm complied with SRA Scope and Conduct of Business Rules (including status disclosure and commission accounting)?
• Independently consider whether any financial promotion is being made under s 21 FSMA:
  • Real-time vs non-real-time communications.
  • Approval by an authorised person or reliance on an FPO exemption.
• For insurance or consumer credit, remember the special regimes and narrower scope of exclusions.

Applying this structure ensures recognition and management of FSMA problems before they become breaches.

Key Point Checklist

This article has covered the following key knowledge points:

• Financial services in the UK are regulated primarily under FSMA 2000 by the FCA and PRA.
• Section 19 FSMA 2000 prohibits carrying on 'regulated activities' without authorisation or exemption (the 'general prohibition').
• A regulated activity involves a 'specified activity' relating to a 'specified investment' carried on 'by way of business' where no 'exclusion' applies.
• Specified activities (e.g., advising, arranging, dealing) and specified investments (e.g., shares, insurance, mortgages) are defined mainly in the RAO 2001. Land is not a specified investment.
• Various exclusions in the RAO (e.g., necessary activities, acting via authorised persons, trustee/PR activities, takeovers) can take an activity outside the definition of regulated activity, but many do not apply to insurance.
• Section 327 FSMA 2000 provides an exemption for professional firms (like SRA-regulated firms) to conduct 'exempt regulated activities' if they are incidental to professional services and other conditions are met (e.g., no undisclosed commission, permitted activities only).
• Section 21 FSMA 2000 restricts unauthorised 'financial promotions'. Approval by an authorised person or reliance on a specific FPO exemption is usually required.
• Insurance distribution and consumer credit activities have specific regulatory considerations for solicitors with narrower exclusions and additional SRA requirements.
• Breaches can lead to criminal offences, unenforceability of agreements, and disciplinary action by the SRA. Robust status disclosure, commission accounting, execution-only confirmations, and record-keeping help maintain compliance.

Key Terms and Concepts

• General Prohibition
• Specified Investment
• Specified Activity
• Exempt Regulated Activity
• Financial Promotion