Client Asset Protection at Levantine & Co.
Introduction
This document outlines the regulatory and operational measures Levantine & Co (Pty) Ltd implements to protect client assets and uphold the highest standards of responsible investment management. Levantine & Co is a licensed Financial Services Provider, authorised and regulated by the Financial Sector Conduct Authority (FSCA) in accordance with the Financial Advisory and Intermediary Services (FAIS) Act. In addition, we are classified as an Accountable Institution (AI) under the Financial Intelligence Centre (FIC) Act.
Together, the FAIS Act and FIC Act establish a comprehensive regulatory framework that sets strict requirements for client protection. These include obligations related to fair treatment, data privacy, financial soundness, asset safeguarding, and the prevention of financial crime through robust anti-money laundering (AML) and counter-terrorism financing (CTF) controls.
Asset Ownership and Segregation
Levantine & Co acts as the discretionary investment manager, authorised to make investment decisions within an agreed mandate on behalf of clients. However, the firm does not hold or take custody of client assets. All investments and cash are securely held by third-party custodians, ensuring that client assets are not reflected on Levantine & Co’s balance sheet and remain protected even in the event of the firm’s insolvency.
To deliver our investment services, we operate through a selection of regulated investment platforms such as Credo, Morningstar and Swissquote. These platforms provide the technology for executing trades and reporting, while arranging for the custody of client assets with licensed custodians
Custodians are legally responsible for holding and safeguarding client investments. A key custodian used is BNY Pershing, a leading provider of clearing, settlement, and custody services. It operates as a wholly owned subsidiary of BNY Mellon, an AA-rated global bank trusted by leading financial institutions
Custody accounts protect client assets with strong safeguards and offer key benefits:
- Full Segregation: Client assets are held in separate, individually recorded accounts. They are never mixed with other investors’ holdings or with the custodian’s own funds.
- Beneficial Ownership: Although assets may be held in a nominee structure for administrative reasons, the client remains the ultimate beneficial owner, with the investor’s name and holdings clearly recorded.
- Transparency and Control: Clients maintain full legal ownership of their assets and have access to real-time reporting, offering clear visibility into holdings and transactions.
- Global Market Access: Through a network of sub-custodians, custodians enable clients to invest in multiple markets while complying with local rules.
- Risk Mitigation: Custody banks reduce operational, settlement, and counterparty risks with strong controls. In rare trade failures, the custodian—not the client—bears the risk. Daily reconciliation of transactions also helps prevent errors and reporting issues.
This structure – with Levantine & Co managing investments, regulated platforms providing infrastructure, and trusted custodians safeguarding assets—ensures transparency, legal clarity, and strong investor protection.
Regulatory Oversight and Audit
Levantine & Co is a licensed Financial Services Provider regulated by the FSCA under the FAIS Act. The firm is subject to independent annual audits, regular financial reporting, and internal compliance reviews to ensure continued adherence to regulatory standards and the protection of client interests. All appointed third-party service providers, including investment platforms and custodians, are likewise highly regulated. They must maintain strong governance and control frameworks, undergo regular audits, and conduct ongoing checks to ensure client asset records are accurate and that only authorised instructions are accepted. This layered oversight guarantees that client assets are managed securely and in full compliance with applicable regulations.
Professional Indemnity Insurance
Levantine & Co holds professional indemnity and fidelity insurance to protect both clients and the firm against financial losses arising from professional negligence, fraud, or dishonesty. The insurance coverage meets industry standards for wealth management firms and is reviewed annually to ensure it aligns with the firm’s size and risk exposure.
The Financial Service Ombudsman
Levantine & Co is committed to handling client complaints promptly, fairly, and in full compliance with regulatory requirements. Clients are encouraged to raise any concerns directly with us by following our internal complaints resolution process, available on our website, which is designed to ensure that all matters are addressed transparently and efficiently.
If a client is not satisfied with the outcome of this process, the complaint may be escalated to the FAIS Ombud. The FAIS Ombud is an independent and impartial statutory body that offers a free and accessible service for resolving disputes between financial services providers and their clients. The Ombud aims to deliver fair outcomes without the need for formal legal proceedings. Further information about the FAIS Ombud is available at: www.faisombud.co.za
Protection of Personal Information
Levantine & Co takes client privacy seriously and complies fully with the Protection of Personal Information Act (POPIA). Personal data is collected and used only when necessary to meet regulatory requirements and deliver services. All information is kept confidential and secured through robust systems. Data is shared only with client consent. Clients have the right to access, correct, or object to the use of their personal data at any time.