The FCA’s rules on personal account dealing (COBS 11.7) are not applied for discretionary investment management services if there is no prior communication between the portfolio manager and the person to whom personal account dealing rules would apply (COBS 11.7.5). This exception applies to the relationship ETFmatic has with our clients as there is no prior communication between ETFmatic and our clients about the specific trades we execute to rebalance our client’s portfolios. .
However, persons working in certain professions (e.g. financial services, consulting, legal and accounting firms or government departments) may be subject to company-specific policies on personal account dealing that are more restrictive.
Find out more about approach here: https://etfmatic.com/whitepaper