© Marco Galli 2019
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PRE-CONTRACTUAL INFORMATION
Pursuant to art. 165 of the Regulation adopted by Consob Resolution no. 20307/2018 (the “Intermediaries Regulation”), the following information is provided regarding Dr. Marco Galli (hereinafter the “CONSULTANT”) and the services he provides.
The information contained in this Document must be provided to the client or potential client before they are bound by an agreement for the provision of investment advisory services or, in any case, before the provision of such service.
The recipient of this document is invited to read the following before making any decision regarding the signing of an investment advisory contract.
The CONSULTANT is available to provide further information regarding the nature and characteristics of the investment advisory service.
1. INFORMATION ABOUT THE CONSULTANT
Name and Surname: Marco Galli
Address: Via Filippo Turati, 30 - 20121 Milan
Website: www.marcogalli.biz
E-mail: marco.galli@marcogalli.biz
PEC: marcogalli1@pec.it
Phone: +39 329 8318621
Registered with resolution no. 1109 of 23/05/2019 in the CFA section of the single register of financial advisors
2. LANGUAGE USED
The Client may communicate with the CONSULTANT and receive documents and information from them in Italian.
3. METHODS OF COMMUNICATION USED
The sending of letters, information notes, statements, any notifications and any other declaration or written communication, including changes to the information contained in this Document, unless otherwise provided by law or contract, will be made to the Client with full effect at the address indicated at the time of signing the contract or subsequently communicated in writing.
The Client may choose, at the time of signing the contract relating to the consultancy service or by subsequent written communication, to receive information via a durable non-paper medium and, in particular, via e-mail. To this end, the Client will provide a valid e-mail address accessible only to them and undertakes to keep it active (or to communicate in writing a different valid e-mail address) for up to 14 months after the termination of the contract.Communications and/or any notifications to the CONSULTANT must be made by the Client to the CONSULTANT's address or by certified email to the addresses indicated above.
The sending of recommendations by the CONSULTANT and the confirmation of the execution of operations by the Client may be carried out using the following methods:
⎕X mail (registered letter with return receipt)
⎕X hand delivery⎕ internet communication platforms with users specifically indicated by the Consultant
⎕X ordinary email, to the address indicated in the contract
⎕X certified email (PEC), at the address indicated in the contract
4. REGISTRATION IN THE REGISTER PROVIDED FOR BY ART. 18 BIS OF LEGISLATIVE DECREE 24.2.1998, NO. 58
It is hereby declared that the CONSULTANT is registered in the section of the register referred to in art. 18 bis of Legislative Decree 24.2.1998 (TUF) maintained by the Supervisory Body provided for by art. 31, paragraph 4 of the aforementioned Decree, by resolution of 23/05/2019 no. 1109.
The name and contact address of the Organization are:
Supervisory Body and Keeper of the Single Register of Financial Advisors – OCF
Via Tomacelli 146, 00186 Rome (RM).
5. REPORTS ON THE EXECUTION OF THE CONSULTING SERVICE
The CONSULTANT sends the Client the following reports relating to the provision of the consultancy service:
- at least every semester, a report containing the composition and performance of the Portfolio;
- within 60 days from the end of the calendar year, a report containing a) an updated statement indicating the reasons why the Portfolio corresponds to the Client's preferences, objectives, and other characteristics, b) the recommendations provided during the reference period, c) in aggregate form, the costs and charges of the Service provided and of the Financial Products and services subject to recommendation.
6. CONFLICT OF INTEREST POLICY
Pursuant to art. 177 of the Intermediaries Regulation, the CONSULTANT has adopted a Conflict of Interest Policy aimed at:
- identify, with reference to the investment advisory service, the circumstances that generate or could generate a conflict of interest that may harm the interests of one or more clients including their sustainability preferences;;
- define the procedures to follow and the measures to adopt to prevent or manage such conflicts.
The procedures and measures adopted are aimed at identifying and preventing conflicts of interest that may arise between the CONSULTANT and the Client or between the Client and other clients of the CONSULTANT at the time of providing the Service covered by this Contract, in order to prevent such conflicts of interest from negatively affecting the Client.
The CONSULTANT, where the measures adopted are not sufficient to avoid, with reasonable certainty, the risk of damaging the Client's interests, will clearly inform the Client on a durable medium of the general nature and/or sources of potential conflicts of interest arising from the recommendations provided, as well as the measures taken to mitigate the related risks, so that the Client can make an informed investment decision.
The Client may request the CONSULTANT for further analytical details regarding the conflict of interest management policy at the previously indicated contacts
7. WORK PERFORMED AND METHOD OF EXECUTION
The CONSULTANT provides investment advisory services as per art. 1, paragraph 5, letter f) of the TUF, consisting of the “provision of personalized recommendations to a client, upon their request or at the initiative of the service provider, regarding one or more transactions relating to financial instruments”
In particular, the service provided by the CONSULTANT concerns:
a) the analysis of the allocation of the client's overall Portfolio and the assessment of the efficiency of the products held;
b) any possible reformulation of the portfolio's asset allocation and of the financial instruments and products held, based on the information provided by the client;
c) the periodic assessment, on an annual basis, of the adequacy of the Portfolio
The personalized recommendations provided to the Client in execution of the service may concern a wide range of financial instruments falling within the following categories listed in Annex 1, Section C, of the TUF
a) Securities.
b) Units and shares of UCIs.
Personalized recommendations may also concern financial products other than financial instruments, such as financial products issued by insurance companies and financial products issued by banks, as well as portfolio management services and order reception and transmission services.
At the Client's request, the recommendations may concern the ancillary services referred to in Article 1, paragraph 6 of the TUF.
The aforementioned consulting activity is aimed at both retail clients and professional clients
In carrying out the activity, the CONSULTANT is not obliged to update the recommendations provided to the Client or to inform the Client of any losses incurred on the instruments subject to recommendation.
The Client is free not to proceed with the investment/disinvestment operations recommended in execution of this contract.
The Service may also be provided by the CONSULTANT in a place other than his/her domicile.
The CONSULTANT is not authorized to carry out the operations recommended to the client, who may perform them through authorized intermediaries (banks, SIM, SGR) within the scope of investment services and activities provided by them.
As remuneration for the performance of the consulting service, the Client is required to pay the CONSULTANT a fee commensurate with the content and value of the service.
In the absence of a unique method for quantifying the fee, it may vary depending on the complexity and size of the assets under advisory, the objectives and risk profile of the client, and, in general, the time that the CONSULTANT will dedicate to the analysis and study of the specific case. Therefore, the CONSULTANT undertakes to submit to the potential Client, after the latter has provided the necessary information summarized above, and in good time before the Client is bound by an agreement for the provision of the consultancy service, a personalized fee estimate. The terms and timing of payment will be indicated in the aforementioned estimate.
The fee paid by the Client constitutes, by law and by contractual obligation, the only form of remuneration for the CONSULTANT for the services provided to the Client; the CONSULTANT is prohibited from receiving compensation (incentives) from third parties.
The CONSULTANT is required, by professional ethics, to be independent from the issuers of the recommended financial products, as well as from the intermediaries authorized to provide investment services within which the Client executes the recommendations.
In providing the consultancy service, the CONSULTANT may not hold funds or securities belonging to clients.
The Client and the CONSULTANT may agree that the CONSULTANT is authorized to view the Client's investments with the banks, financial intermediaries, or asset management companies used by the Client, without any authorization to operate. They may also agree that said investment firms send information on transactions carried out by the Client directly to the CONSULTANT.
For more information on the contents of the advisory service and on the obligations of the ADVISOR and the client, please refer to the investment advisory contract, which must be signed prior to the provision of the service.
8. PERIODIC ASSESSMENT OF ADEQUACY
In providing investment advisory services, the CONSULTANT gives the Client recommendations regarding investment or divestment operations which, if carried out, ensure the adequacy of the Portfolio with respect to the Client's profile reconstructed on the basis of the information provided through completion of the Questionnaire submitted to them before the conclusion of this contract or during any subsequent updates.
In particular, the CONSULTANT verifies that the recommended operation:
- corresponds to the Client's investment objectives, including their risk tolerance;
- is such that the Client is financially able to bear the risks associated with the investment in line with their investment objectives;
- is of such a nature that the Client possesses the necessary knowledge to understand the risks associated with the management of their portfolio.
The CONSULTANT carries out a periodic assessment of the adequacy of the Portfolio on an ANNUAL basis.
The suitability assessment is carried out to allow the advisor to act in the best interest of the client. It is therefore essential that the Client, by completing the Questionnaire provided by the ADVISOR, provides correct and updated information regarding:
- his/her knowledge and experience in investments regarding the specific type of product or service;
- his/her financial situation, including his/her ability to bear losses;
- your investment objectives, including your risk tolerance;
- your sustainability preferences.
The Client is required to inform the CONSULTANT of any updates to the information.
The aforementioned information allows the CONSULTANT to understand the essential characteristics of the Client and to recommend financial products and investment services that are suitable, with particular reference to their risk tolerance and capacity to bear losses, as well as their sustainability preferences; if the Client does not provide the information required in the Questionnaire, the advisory service cannot be provided.
The Client must be aware that incorrect or untruthful answers may compromise the reliability of the adequacy assessment and reduce their level of protection.
The CONSULTANT is required to refrain from making recommendations if none of the financial products and investment services are suitable for the Client.
9. INTEGRATION OF SUSTAINABILITY FACTORS
Since the advice provided by the CONSULTANT concerns the financial portfolio as a whole, the assessment of sustainability factors is carried out at the portfolio level. This means that, overall, the portfolio must be aligned with the client's sustainability preferences, even though, for risk management reasons or to achieve the client's objectives, some individual instruments used may not be individually aligned with the client's preferences.
The assessment of environmental, social, and governance sustainability characteristics is carried out, depending on the type of instrument/product, according to the information declared by the issuer pursuant to current regulations or by using external evaluation models (ratings) and/or analyses conducted internally.
10. OTHER PROFESSIONAL ACTIVITIES CARRIED OUT BY THE CONSULTANT
The CONSULTANT provides the following additional activities in addition to the investment advisory service:
· Analysis and research on financial instruments and products
· Consulting for the assessment and coverage of asset and income risks
· Consulting for the assessment and coverage of supplementary pension needs
· Consulting for the optimal management of income flows
· Consulting for personal and family financial planning
· Consulting in negotiations with investment and insurance companies regarding the conditions applied
· Consulting for the coordination of assets, finances, and economics between private activities and professional or business activities
The aforementioned activities, although personalized, do not concern specific financial instruments or financial products.
The performance of the aforementioned activities is governed by a specific contract, separate from the one relating to investment advisory services, which provides for the payment of a fixed or variable fee as agreed with the client from time to time, commensurate with the content and value of the service provided.
The activities indicated above are not subject to supervision by Consob and the Organization, nor to supervision by other Authorities.
11. PROPOSED INVESTMENT STRATEGIES
In carrying out the consulting service, the CONSULTANT is not focused on specific categories or a particular range of financial instruments.
The CONSULTANT does not propose standardized investment strategies but evaluates the most appropriate strategy for each Client, taking into account the Client's investment objectives, risk tolerance, and financial situation, including their capacity to bear losses.
© Marco Galli 2019
Privacy Policy
Cookie Policy