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Terms and conditions

Effective from 16 November 2026

These Terms and Conditions set out the agreement between:

You – this means:

  1. the person we've opened a Managed General Investment Account, a Managed ISA and/or a Managed Lifetime ISA for;
  2. the person we’ve opened a Self-Managed General Investment Account and/or a Self-Managed ISA for;
  3. the Registered Contact in respect of a Managed Junior ISA;
  4. you as the member of your Managed Personal Pension (as agent for the pension provider Embark Services Limited), for which we provide a Managed Personal Pension Account; and/or
  5. any person to whom we provide Wealth Services.

and

Us – Whenever you see 'we', 'us' or 'our', we're referring to J.P. Morgan Personal Investing Limited (J.P. Morgan Personal Investing), formerly known as "Nutmeg" or "Nutmeg Saving and Investment Limited". Any references to "Nutmeg Saving and Investment Limited" or "Nutmeg" should be read as referring to J.P. Morgan Personal Investing.

The agreement between you and us is made up of the terms in this document, the information that you provide to us, the Schedule of Fees and Charges, and any other document that you and we agree applies.

The agreement forms a legal contract between you and us and comes into effect when we accept your application for a service or Product. You should read this document and the other parts of the agreement carefully before applying for a service, Portfolio or Product. 

If there is anything that you do not understand, please email support@personalinvesting.jpmorgan.com for more information.

A. Finding your way around these terms

This document contains the terms that apply to our services and your Portfolio. This includes matters such as:

  • big picture information on the services and Products we offer – see section B;
  • how we'll contact each other and how we support those with accessibility needs – see section C and section D;
  • a summary of important legal points – see section E;
  • how you can keep your accounts secure – see section F;
  • the terms which apply to the Products which we offer, except where specified otherwise in respect of a specific Product (see section G), including:

- what you need to do to become and continue to be a customer, including minimum investment amounts – see section 1;

- details on your right to cancel – see section 2;

- the Wealth Services and Managed Portfolio services we provide – see section 3, section 4 and section 5;

- how you can pay in and withdraw amounts from a Product – see section 6 and section 11;

- how we will buy and sell investments for you – see section 7;

- how we will hold the cash and investments in your Portfolio – see section 8 and section 9;

- when we may accept instructions from you or others on your behalf – see section 12;

- when we might change the terms – see section 18;

- when we might block your access to the services – see section 14;

- what happens when things don't go as expected, and liability – see section 16 and section 17; and

- how the agreement can be ended – see section 20;

  • the additional terms which apply only to a Managed ISA and Self-Managed ISA, a Managed Junior ISA, a Managed Lifetime ISA or to a Managed Personal Pension Account you hold with us – see section H;
  • other information on complaints, the Financial Ombudsman Service and compensation arrangements – see section I;
  • the terms which apply only to Self-Managed Investing Service and Self-Managed Products you hold with us – see section J; and
  • a glossary of the definitions used in these terms – see section K.

Some of the words in these terms have a special meaning. These words are capitalised in this document and their meaning is set out in section K below.

These terms are always available on our website and you can download or print them. If you want to know about other formats that we can provide, please contact us.

B. The big picture

When you sign up to J.P. Morgan Personal Investing, we may provide you with Wealth Services and/or open a Portfolio for you. Your Portfolio will be used to buy and sell investments. Those investments will be held in one or more Products within your Portfolio.

  • We may provide a discretionary management service in relation to your Managed Portfolio, which means that we will make all investment decisions on your behalf.

    We make these decisions to help you achieve the investment goal for the Investment Parameters that you choose for your Managed Portfolio. "Investment Parameters" are investment frameworks that we agree with you in order to manage your Managed Portfolio, including the Investment Styles and your attitude to risk.

    We will give you simplified financial advice to help you decide which Investment Parameters are best suited to you.
  • We may also provide Self-Managed Products through our Self-Managed Investing Service. This is an execution-only service, which means you make your own investment decisions and we do not manage investments on your behalf.

    We do not provide investment advice or personal recommendations in relation to the Self-Managed Investing Service. We also do not assess the suitability or appropriateness of Self-Managed Products or Self-Managed Eligible Investments for you, and you are responsible for deciding whether any investment is right for you.

    Section J describes the service that will apply to any Self-Managed Product that we provide to you.

Product types

We provide a Managed General Investment Account, Managed ISA, Managed Junior ISA and/or Managed Lifetime ISA. We also provide a Managed Personal Pension Account to hold your Managed Personal Pension. When we refer to a Managed General Investment Account, Managed ISA, Managed Junior ISA, Managed Lifetime ISA or Managed Personal Pension Account in these terms, we mean our Managed Products, which together make up your Managed Portfolio and in respect of which we make investment decisions for you.

We also offer a Self-Managed General Investment Account and a Self-Managed ISA. These are our Self-Managed Products, which you hold through our Self-Managed Investing Service, our execution-only service, where you make your own investment decisions and we do not manage your investments for you. Please see section 29 (on the Self-Managed Investing Service) for more information.

You may be able to open one or more of the Products described above with us, depending on your eligibility. All our ISA products are Stocks and Shares ISAs. We do not offer a Cash ISA or an Innovative Finance ISA.

We also offer a Financial Planning and Advice Service to help you identify which Managed Product types and Investment Parameters are suitable for you based on your financial circumstances and goals. This service is not available in relation to our Self-Managed Products.

Investments

When we buy and sell investments for you in your Managed Portfolio, we Deal exclusively in exchange-traded funds and exchange-traded certificates ("ETFs"), though we may Deal in other investment types in the future.

The Self-Managed Eligible Investments you can hold in our Self-Managed Products include securities listed on regulated exchanges such as NASDAQ, the New York Stock Exchange and the London Stock Exchange, and we may add to or change the range of Self-Managed Eligible Investments we make available from time to time.

When we Deal for you, and when we execute orders you place in relation to your Self-Managed Products, we try to get the best possible outcomes for you. We do this by following our Order Execution Policy. You can read our Order Execution Policy here.

Investment risks

Investing carries risks, including that the value of your investments may go down as well as up. You should be sure to retain enough emergency cash outside your Portfolio. Three months' salary is a good starting point.

Our Customer Investment Risks document gives more information on the risks of buying investments. You should read this information before applying for a Portfolio or Product.

Tax

We will not provide you with legal or tax advice in connection with your Portfolio, Product, services or any investments. You are responsible for any matters relating to your own tax or legal position. If you are, or become, required to pay taxes in connection with the Portfolio, you (and not we) are responsible for paying these.

Fees and charges

We charge an annual management fee in relation to your Managed Portfolio. This is calculated as a percentage of the value of investments that we hold in your Managed Portfolio.

We charge separate fees if you use our Self-Managed Investing Service.

We also charge a separate fee if you use our Financial Planning and Advice Service.

Please see our Schedule of Fees and Charges for more information on our fees.

There are other charges that you have to pay to the providers of the investments in your Portfolio. These charges may vary from time to time. Other charges may also apply, for example where we carry out a Deal for you. Further details are provided here.

These fees and charges will be deducted from your Portfolio. Please see our Schedule of Fees and Charges for more information.

C. Getting in contact

We’re here for you. You can get in touch with us by secure email (we call this Messages), by webchat at https://www.personalinvesting.jpmorgan.com/contact-us, by telephone on 020 3598 1515 or email at support@personalinvesting.jpmorgan.com

If we need to get in touch with you, we will contact you through Messages. You must sign in to our website to read any Messages we send you. We may also call you by phone, use email or the post to contact you. 

We aren’t responsible if you don’t get information or notices from us because we’ve used out-of-date contact details. That’s why it’s really important that you:   

  • tell us as soon as possible if your contact details change; and
  • check your emails and Messages regularly.

We may record and monitor telephone conversations and electronic communications with you. We will store these records for at least seven years, during which time you can ask us for copies.

We will always use English to communicate with you.

D. Accessibility

We can provide alternative accessible formats for certain documents. If you need them or want more information on how we help those with accessibility needs, you can contact us.

E. Important information

You can let us know that you’d like to cancel this agreement without giving a reason within 30 days of entering into it (see cancellation). 

You can also end your agreement at any time by giving us 30 days’ notice (see ending this agreement and closing your Portfolio).

We will treat you as a retail client. This means that you will benefit from the protection available to retail clients under the FCA Rules.

Our website Terms and Conditions and our Privacy Policy also apply to you.

F. Security

Your Security Credentials are key to keeping your money, investments and information safe.

To make sure that your Portfolio isn't accessed by an unauthorised person you must keep your Security Credentials safe. Here are just a few security tips to get you started. 

Don't:

  • tell anyone or allow anyone to access your Security Credentials (for example, by telling a friend your Security Credentials or providing them to an AI agent);
  • write your Security Credentials down without disguising them;
  • set up Security Credentials that can be easily guessed by anyone else (the less obvious the better!); or
  • log in, or stay logged in, using a device if you're not in full control of it or it's not in your possession.

Do: 

  • review your Security Credentials regularly to check they are still appropriate; and
  • update the app regularly (depending on the update, you may not be able to log in if you haven't done this).

If you lose (or someone takes) your Security Credentials or if you think someone else has accessed your Portfolio you must contact us as soon as possible.

We'll ask for information or other help, and assist (and ask you to assist) the police in any investigation.

Here's why this is important

If your Security Credentials are used to access your Portfolio, we'll assume we're dealing with you. We may follow any instructions we receive and give access to information about your Portfolio.

G. Terms that apply to our Products

1.

Conditions you must meet to become and remain our customer

1.1

In order to have a Portfolio and/or for us to provide you with services, you must:

  • be at least 18 years old;
  • hold a UK Bank Account;
  • complete any application form or transfer form that we may reasonably request;
  • provide us with any information that we reasonably request and ensure that the information is accurate and complete. This includes, but it is not limited to, any information we may request to enable us to comply with transaction reporting requirements under Applicable Requirements, and information that we need to check your identity or the source of funds that you pay into your Portfolio. If you are a Chase UK Introduced Customer, we may receive certain information about you from Chase UK in accordance with the terms you have entered into with Chase UK and, in this case, we may not require you to provide such information again;
  • if any information you have provided to us, or confirmed to us, changes, you should notify us as soon as possible;
  • if you become aware that we have made an error or have provided you with incorrect information, you should notify us as soon as possible;
  • be the owner of all of the assets in the Portfolio (except for assets in a Managed Junior ISA) and ensure that there are no restrictions on the transfer, sale or ownership of any assets in the Portfolio except for any such restriction arising under or in connection with this agreement;
  • make and maintain a minimum investment into each Product. For our Managed General Investment Account, Managed ISA and Managed Personal Pension Account this is £500. For our Managed Lifetime ISA and Managed Junior ISA this is £100. For Income Investing Pots, the minimum investment amount is £10,000. Please note that there is no minimum investment amount for our Self-Managed General Investment Account and Self-Managed ISA, but you’ll need to have enough funds to cover the cost of any investment you choose to buy;
  • meet any other criteria that apply to the type of Product(s) that you want to open (see section 24.3 in respect of our Managed ISA and Self-Managed ISA, section 25.3 in respect of our Managed Lifetime ISA, section 26.4 in respect of our Managed Junior ISA, and section 33 in respect of specific requirements for Self-Managed Products we provide to you);
  • comply with the law that applies to you in connection with the Products and services that we provide to you;
  • take reasonable care to keep your Security Credentials safe; and
  • behave reasonably and honestly towards us and those who act on our behalf.

If you don't meet these conditions, then we can refuse to open a Portfolio or Product or provide services to you. If you stop meeting these conditions after we have opened a Portfolio for you or started providing services, section 17.1 will apply.

Please also note that if you are a client of the J.P. Morgan International Private Bank (J.P. Morgan SE – London Branch) you may not be eligible to open or access certain Products and/or services via the online private bank website.

1.2

We will generally only provide services to you if you are resident in the UK. If you live or are tax resident outside the UK and want to open a Portfolio or use our services, you should contact us at support@personalinvesting.jpmorgan.com. We do not provide Portfolios or services to US Persons.

1.3

You must tell us if you move to a different country, become tax resident in a different country, or become a US Person. If this happens, we may end this agreement, close any of your Products, sell your investments, and/or stop providing any of our services and close your Portfolio in accordance with sections 20.4, 20.5 and 20.6.

If you become a US Person, we may sell your investments as stated in section 20.6 and we may withhold a portion of your cash to satisfy US withholding tax requirements (back-up withholding). This withholding will not be applied to your Managed Junior ISA or your Managed Personal Pension.

1.4

You may apply for a Product or access our services as a Chase UK Introduced Customer through the Chase UK app, in accordance with Chase UK terms and conditions. Even where you do so, we remain responsible for providing any Products and investment services available under these terms. Any suitability assessment, assessment of your Investment Parameters, investment recommendation, investment advice, custody service, dealing service, investment services, Self-Managed Product or Managed Product that we may provide you is provided by us (and, in relation to the Managed Personal Pension, ESL) and not by Chase UK. Products provided by us are not guaranteed by Chase UK.

2.

Cancellation

Your rights to cancel

2.1

You have the following rights to cancel this agreement and/or a Product that we open for you:

  • you can cancel this entire agreement within 30 days of it coming into effect;
  • you can cancel a Product within 30 days of us confirming to you that the Product is open; and/or
  • you can cancel a transfer from another ISA manager into your Managed ISA, Managed Lifetime ISA, Managed Junior ISA and Self-Managed ISA within 30 days of us receiving that transfer.

2.2

If you wish to cancel, you must send us a Message or email to support@personalinvesting.jpmorgan.com, expressly stating that you wish to cancel.

What happens if you cancel

2.3

If you cancel, you will have no further obligations in relation to the service or the Product and you will not be charged any fee for cancelling.

2.4

You agree that we can start providing the relevant service(s) or Product(s) to you before the end of the 30-day cancellation period.

2.5

If you cancel, we will return the amount that we have received from you in relation to the Product(s) that you are cancelling based on the market value of such Product(s) on the date the amount received is refunded, minus a proportionate charge for our costs and charges up to the date of the Product closure and any expenses or losses necessarily incurred by us or on our behalf in order to conclude outstanding transactions for your Product.

If the market value of the Product(s) decreases during the cancellation period, you will receive a refund of an amount equal to less than your original investment.

By way of example only, if we received £1,000 from you in relation to the Product(s), and, on the date of the refund, the market value of this investment is £990, and we have incurred costs and expenses of £1, the amount refunded to you will be £989. Such costs and expenses will typically relate to the costs we have incurred in managing the investment, and the expenses we have accrued in concluding the outstanding transactions related to your Product. The amounts set out within this paragraph are provided for guidance only and should not be relied upon.

Cancelling a Managed General Investment Account, Self-Managed General Investment Account, Managed ISA, Self-Managed ISA, Managed Lifetime ISA, or Managed Junior ISA

2.6

If you cancel a Managed General Investment Account, Self-Managed General Investment Account, Managed ISA, Self-Managed ISA, Managed Lifetime ISA, or Managed Junior ISA within the 30-day period, we will pay the amount owed to you under section 2.5 to your UK Bank Account or to another UK bank account in your name.

We will treat you as though you have not subscribed to the Managed ISA, Managed Lifetime ISA, Self-Managed ISA or Managed Junior ISA.

If you cancel a transfer from another ISA manager, we will take reasonable steps to return the transfer to that ISA manager.

Cancelling a Managed Personal Pension

2.7

If you cancel your Managed Personal Pension with Embark Services Limited ("ESL"), then your agreement with us in respect of your Managed Personal Pension Account will also be cancelled. ESL is the provider and operator of your Managed Personal Pension. ESL is a company registered in England, company number 2089815, and is authorised and regulated by the FCA. See section 27 of this agreement for more information on the terms that apply to the Managed Personal Pension.

Wealth Services

3.

Financial Planning and Advice Service

3.1

Our Financial Planning and Advice Service is designed to identify which Managed Product types and Investment Parameters are suitable for you based on your financial circumstances and goals. This service is optional, and we will charge you a separate fee for it as set out in the Schedule of Fees and Charges.

We do not provide this service in relation to any Self-Managed Products we provide to you.

Our Financial Planning and Advice Service is split into the following three categories: Core, Enhanced and Advice Review.

3.2

As part of our 'Core' Financial Planning and Advice Service, we will carry out a fact-finding process with you to understand your financial situation and goals. Using that information, we will give you personalised recommendations for your investments with us. A comprehensive advice report will set out our personalised recommendation(s) regarding which, if any, Managed Product type(s) and Investment Parameters are suitable for you and your goals.

3.3

As part of our 'Enhanced' Financial Planning and Advice Service, we will perform the services outlined in section 3.2 above and also carry out a detailed income and expenditure analysis and a cash flow model which will be included in your comprehensive advice report.

3.4

Our 'Advice Review' Financial Planning and Advice Service is a needs-based service which is designed to support you with changes to your financial situation that have occurred within 5 years of using either the Core or Enhanced Financial Planning and Advice Service. We will review any changes in your personal circumstances, assess the impact on your financial situation and prepare a comprehensive advice report. Depending on the materiality of changes in your circumstances, we may advise you to use our Core or Enhanced Financial Planning and Advice Service instead of the Advice Review.

3.5

The Financial Planning and Advice Service will consider your overall circumstances, including any other products or services you hold with other providers. All of your financial products will be factored into the comprehensive advice report that we prepare for you as part of the Core, Enhanced and Advice Review. However, the Financial Planning and Advice Service offers 'restricted advice'. This means we will only make investment recommendations on the range of Managed Products and Investment Parameters that we offer.

3.6

The Financial Planning and Advice Service is a one-off service, and we will not carry out any ongoing or follow-up review of whether your Managed Products or Investment Parameters remain suitable for you, unless you request our 'Advice Review' service for a separate fee.

3.7

We will not provide you with tax advice in connection with the Financial Planning and Advice Service. You are responsible for any matters relating to your own tax position. We recommend that you obtain your own independent tax advice tailored to your individual circumstances.

3.8

After an initial meeting with our advisers and once we have determined that the Financial Planning and Advice Service is appropriate for you, we will send you an invoice. Payment for the Financial Planning and Advice Service is due and payable upon receipt of the invoice.

Wealth Planner

3.9

The Wealth Planner is our free digital wealth planning solution designed to provide you with financial guidance.

As part of the Wealth Planner service, you will engage in a fact-finding process and will be required to provide information on your financial circumstances (including any investments you hold, whether with us or with other providers) and financial goals. We may pre-fill certain fields with information related to Products you have with us.

Based on this information, Wealth Planner will provide hypothetical projections of the future performance of your wealth and will help you to identify potential options available to you to progress towards your goals.

3.10

The Wealth Planner does not provide investment advice, personal recommendations or instructions regarding any specific products or investment strategies, nor does it instruct you on actions to take in relation to such products. Wealth Planner is designed to provide general financial guidance to assist you in identifying the potential options available to you, and narrowing down those options. It does not provide an exhaustive list of options that may be available to you. It does not tell you what to do or what investments (whether or not held in a Product offered by us) to buy or sell.

At points, the Wealth Planner may direct you to other sources of help. The Wealth Planner may also suggest that you explore obtaining financial advice, which would provide you with personalised recommendations in relation to specific investments.

You should not take any action relying solely on the information presented in the Wealth Planner, as no element (including outputs and any projections) constitutes restricted, holistic, simplified, or independent financial advice, a personal recommendation or similar. Before taking any action, you should do your own research, compare different options and providers, and consider speaking to a financial adviser to obtain financial advice tailored to your personal circumstances.

Forecasts shown in the Wealth Planner are a hypothetical illustration of how investments similar to yours might perform over time, calculated as an average of a range of possible outcomes. The forecasts are not a projection of the future value of your specific investments (whether held in a Product offered by us or another provider). Forecasts are not a reliable indicator of future performance and all information presented in the Wealth Planner is for educational/informative purposes only.

We will not provide you with legal or tax advice in connection with the Wealth Planner service. You are responsible for any matters relating to your own legal or tax position. If you are unsure, we recommend that you obtain your own independent legal and/or tax advice tailored to your individual circumstances.

The Wealth Planner is only suitable for individuals who are UK resident and not resident in any other jurisdiction.

3.11

No data entered into the Wealth Planner, nor any actions taken by you in relation to the Wealth Planner, will result in any changes to your account, including any Products you hold with us.

The output of the Wealth Planner does not take into consideration any promotional or non-standard rates that may apply to your account at present or in the future.

3.12 

The Wealth Planner and its projections are not suitable for you if you only include in the fact-finding process:

(a)          any personal or stakeholder pension (whether or not it is held with us);

(b)          an onshore bond (as that term is defined by the FCA);

(c)           an offshore bond (as that term is defined by the FCA);

(d)          a combination of any of the above; or

(e)          any one of the above or any combination of any of the above plus cash that you hold and/or income you earn.

If you meet the criteria above, you should not use the Wealth Planner, as the projections do not include standardised deterministic rates.  

This section 3.12 does not apply to you if you include the items or combination of items listed in (a) to (e) above alongside other financial instruments, including investments held within Stocks and Shares ISA, or structured deposits.

Relationship Manager

3.13

We reserve the right to assign to you a dedicated Relationship Manager, subject to certain eligibility criteria, who will act as a personal point of contact for you.

3.14

We reserve the right at any time to assign a new Relationship Manager to you on either a temporary or permanent basis.

We also reserve the right at any time to either suspend or cancel the provision of this service.

3.15

If you are assigned a Relationship Manager by us and you do not want to receive this service, you can send an email to support@personalinvesting.jpmorgan.com stating that you wish to opt out of this service.

Will and Power of Attorney drafting services

3.16           

We may introduce you to an unaffiliated third party legal services provider (Hugh James Solicitors) for will and Power of Attorney drafting services.

Please note that we do not provide these legal services or any legal advice.

Any such services are provided solely by Hugh James Solicitors under a separate contractual agreement between you and them. This means that your use of the legal service will be subject to Hugh James Solicitors’ own terms and conditions and privacy policy, which you should read carefully. We are not a party to any contract between you and Hugh James Solicitors and payment for the legal service will be made by you to Hugh James Solicitors. For the avoidance of doubt, we are in no way responsible for the quality of, nor do we guarantee or take any liability for, any service or legal advice provided by Hugh James Solicitors. We are not liable for any loss or damage you may suffer in connection with your use of, or reliance on, the legal service provided by Hugh James Solicitors.

If you are not sure whether this service is suitable for you, you should seek independent professional advice.

4.

Managed Portfolio: Choosing your Investment Parameters and our Simplified Advice Service

This section does not apply to any Self-Managed Products we provide to you.

4.1

When you open a Managed Product with us you will choose which Investment Parameters to apply to that Managed Product so that we know how to manage the Managed Product(s) for you. We will provide you with financial advice to help you make this decision. We call this our "Simplified Advice Service". 

We will also provide you with our Simplified Advice Service if you want to change your Investment Parameters. 

We will require you to use the Simplified Advice Service annually to ensure that the Investment Parameters are still suitable for you.

4.2

Our Simplified Advice Service is designed to identify which Investment Parameters are suitable for you. We use a streamlined process to do this, which means that we will ask you specific questions to understand your investment needs and objectives in relation to the Managed Product. 

We will make a recommendation as to which, if any, Investment Parameters meet those needs and objectives. We will not consider your wider financial needs or circumstances or any other investments that you hold outside the Managed Portfolio, including in any Self-Managed Products you hold with us.

4.3

Our Simplified Advice Service is "restricted advice". This is because we will only consider the range of Investment Parameters that we offer when making a recommendation to you. 

We will not consider whether any other product or service that may be available from another provider might be suitable, or more suitable, for you.

5.

Managed Portfolio: Discretionary Management

This section does not apply to any Self-Managed Products we provide to you.

5.1

Your Managed Portfolio is a discretionary management portfolio. This means that we will make investment decisions in respect of your Managed Portfolio and the Managed Products within it at our discretion, subject to the Investment Parameters that you have chosen.

5.2

You must provide us with information that we request to enable us to make investment decisions which are suitable for you. This includes information about you, your financial circumstances, your financial knowledge and experience, your attitude to risk and your investment objectives. 

You must tell us as soon as possible if this information changes.

5.3

You authorise us to enter into arrangements or transactions on your behalf. We may invest any amount or any proportion of your Managed Portfolio and/or Managed Product in any suitable ETFs, or Fractional Entitlements (that is, rights to part of an investment, rather than a whole investment) to suitable ETFs, and we may do so in any currency, and on any financial market. 

5.4

We will provide you with a suitability report which explains the investment decisions we take in respect of your Managed Portfolio.

5.5

We can make investment decisions which apply to other customers' portfolios as well as yours, provided that we are satisfied that the decision is suitable for you.

5.6

We may offer you access to educational resources and general information related to investing. These resources are intended to provide you with a better understanding of investment concepts, risks, and strategies.

5.7

Our discretionary management service is not a guarantee that the investments in your Managed Portfolio will perform as you, or we, expect.

6.

Paying amounts into your Portfolio

Paying in cash

6.1

We can accept payments of cash into our Managed General Investment Account, Managed ISA, Managed Lifetime ISA, Managed Junior ISA, Self-Managed General Investment Account and Self-Managed ISA where they are made from any UK bank account in your name. You can make such payments by debit card, Direct Debit (for your Managed Products), or bank transfer. Payments by Direct Debit are not supported for the Self-Managed General Investment Account and Self-Managed ISA.

6.2

The Managed Personal Pension terms and conditions between you and ESL set out how you can make payments into your Managed Personal Pension. 

6.3

We apply a minimum amount of £75 to card payments into your Portfolio.

6.4

When you make a payment by debit card or Direct Debit, your money will be held in our name with a Payment Service Provider (PSP) of our choice and we will take reasonable steps to ensure your money is segregated from the PSP's assets. The PSP will typically transfer your money to us within three business days. Once the funds are received by us, they will be protected as detailed in section 9.1. We will allocate amounts to your Portfolio only once we have received cleared funds and all the information we need to do so.

6.5

Payments should be made in pounds sterling.

6.6

If you have more than one Product and you send us money without telling us which Product you want to pay it into, we may either reject that money or allocate it to any one of your Products.

6.7

We may, in accordance with the Applicable Requirements regarding financial crime, reject any payments into your Portfolio, reject your instructions to invest, liquidate your investments held with us, restrict access to your dashboard, require you to transfer your Product(s) to another provider, decide not to continue to rebalance your Portfolio(s), or take any other reasonable action, where we know or suspect that you are not the beneficial owner of the amount paid (that is, the amount paid does not belong to you and/or that you are not entitled to it).

6.8

All money that is paid into an account needs to be allocated to a Pot. If you have one Pot, any money you pay in will be automatically allocated to your Pot.

However, if you have more than one Pot and make a bank transfer (excluding transfers initiated using Easy Bank or "Pay in via Chase UK" functionality), we cannot be sure which Pot you would most like to allocate the money to.

Unless you instruct us otherwise, we will prioritise your tax-advantaged Pot (i.e., any Managed ISA Pot or a Self-Managed ISA), if you have one, as follows:

(i)         If you have only one tax-advantaged Pot (i.e. a single Managed ISA Pot, or a Self-Managed ISA) and you have not exhausted your Custom Subscription Limit (see section 24.10 on setting up a Custom Subscription Limit) (or, where you have not set one, the overall annual subscription limit for that tax year), we will allocate your payment to that tax-advantaged Pot, as relevant, to the extent possible. We will never automatically allocate to your Managed Lifetime ISA (if you hold one with us).

(ii)        After exhausting your Custom Subscription Limit (or, where you have not set one, the overall annual subscription limit for that tax year), we will allocate the remaining, as well as any subsequent payment(s) within the same tax year, into the Pot that you hold which is not tax-advantaged (i.e., a Pot within a Managed General Investment Account, or your Self-Managed General Investment Account). This assumes that you hold only one Pot which is non tax-advantaged.

Please note that if you:

  • have more than one tax-advantaged Pot (e.g. a Managed ISA Pot and a Self-Managed ISA), or more than one non tax-advantaged Pot (e.g. a Managed General Investment Account Pot and a Self-Managed General Investment Account) and we cannot determine where you want your payment to be allocated, or
  • you have exhausted your Custom Subscription Limit and do not have any non tax-advantaged Pots,

your cash will be held as unallocated cash. This means that it will not be treated as held within a Pot. We do not currently pay interest on unallocated cash. We may then contact you to request that you allocate the cash to one of your Managed Pots or Self-Managed Products so that it can be invested.

Where you do not hold a tax-advantaged Pot or Product, or you have already used your Custom Subscription Limit (or, where you have not set one, the overall annual subscription limit for that tax year), your unallocated cash cannot be placed in a tax wrapper and may not receive any tax advantages.

How we Deal for your Portfolio

Section 7 explains how we buy and sell investments for your Portfolio, and reflects the regulatory requirements which apply to us when we do so.

Please see further details on how we Deal for you for any Self-Managed Products we provide to you in section 36.

7.

We will carry out each Deal for your Portfolio in accordance with:

  • the Applicable Requirements;
  • the rules of any market on which the Deal is done; and
  • our Order Execution Policy which sets out the arrangements that we have put in place to ensure that we Deal for you in accordance with "best execution". "Best execution" is our obligation under the Applicable Requirements to take all sufficient steps to obtain the best possible results for you when carrying out Deals for your Portfolio.

7.1

We can carry out a Deal for you as your agent, or act as principal and enter into a Deal with you on our own account. Please see section 36.2 for more information on how we Deal for you when providing a Self-Managed Product.

7.2

If we agree to execute a Deal for you in accordance with your specific instructions, it may not be possible for us to obtain the best result that would otherwise be available to you at the time of the Deal.

7.3

You agree that we may Deal on your behalf outside of a Regulated Market or Multilateral Trading Facility (MTF) when we believe it is in your best interests to transact in this way. 

(An MTF is a non-exchange based trading system which accommodates deals between multiple parties). 

7.4

When we carry out a Deal for your Portfolio, we may combine it with Deals for other clients or for ourselves in accordance with our Order Execution Policy. This is called "Order Aggregation". 

We will do this where, at the time we Deal, we reasonably believe that the Order Aggregation is unlikely to be to your disadvantage overall. However, the result of the Order Aggregation may actually be to your disadvantage in relation to a particular Deal compared to if we had bought or sold your investments separately.

7.5

Where we Deal for you in Fractional Entitlements to investments, these Deals can only be effected through us by combining your entitlement with those belonging to our other clients or ourselves so that we can Deal in a whole investment. A Fractional Entitlement cannot be traded without this process and can only be sold through us to realise cash. This section 7.5 only applies to Managed Products. Please note that we do not deal in Fractional Entitlements for any Self-Managed Products we provide to you.

7.6

The price of an investment may change between us placing a Deal and when it is executed. This means that, on execution, there may be slightly less cash and more investments in your Portfolio than intended (or vice versa). We will take steps to resolve this at the next opportunity. 

A price change may mean that your Portfolio has a negative amount of cash for a short period. This happens where there is not enough cash in the Portfolio to cover an increase in the price. Where this happens we: (1) cover any shortfall using our money to ensure there is always enough cash in the client money account; and (2) sell the surplus investments to give the Portfolio a positive cash balance as soon as we can.

Specific risks apply in relation to any Self-Managed Products we provide to you. See sections 37 (on foreign exchange risks) and 36.11 (on risks of placing orders outside Market Hours), for more information.

7.7

This section 7.7 only applies to Managed Products. It does not apply to any Self-Managed Products we provide to you.

At settlement, cash amounts related to your trades (to be taken from or added to your Pot as the case may be) are rounded to the nearest penny by following a process known as "Banker's rounding" (also known as "half to even" or "rounding to the nearest even number"). For more information on how this process works please see here.

Treatment of rounding differences

Where there are rounding differences after the positions have been posted to your Pot, we will cover any:

i.           Rounding up differences by transferring money from our own account, or

ii.          Rounding down differences by transferring money to our own account.

8.

How we hold the investments in your Portfolio

Section 8 explains how we hold the investments which are in your Portfolio and reflects the regulatory requirements which apply to us when we do so. Please contact us if you have any questions about section 8.

How your investments are registered

8.1

We are the custodian of the investments in your Portfolio and we will hold them for you in "safe custody" in accordance with the Applicable Requirements. This means that they will be kept separate from our own investments and ownership of your investments will be registered in the name of either:

  • our nominee company, a Sub-Custodian (i.e. a financial institution which we appoint to hold assets on our behalf) or a nominee company of the Sub-Custodian or a nominee company of a third party appointed by a Sub-Custodian. Our nominee company, Sub-Custodian or the nominee company of the Sub-Custodian or third party appointed by a Sub-Custodian, will have legal title to the investments and you will retain beneficial ownership at all times (which means that you will be entitled to the investments and relevant income); or
  • our nominee company, a Sub-Custodian or a nominee company of the Sub-Custodian or a nominee company of a third party appointed by a Sub-Custodian located outside the UK, where the relevant investments are subject to the law or market practice of a jurisdiction outside the UK and where we have taken reasonable steps to determine that it is in your best interests to do so, or that it is not feasible to do otherwise, because of the nature of the applicable law or market practice.

8.2

If we register your investments in the name of our nominee company, a Sub-Custodian or a nominee company of the Sub-Custodian or a nominee company of a third party appointed by a Sub-Custodian located in a jurisdiction outside of the UK:

  • different settlement, legal and regulatory requirements may apply from those in the UK; and
  • there may be different practices for the separate identification of safe custody investments.

This means that the protection of your investments may be different depending on the jurisdiction in which the Sub-Custodian operates.

Mixing your investments with those belonging to other customers

8.3

You agree your investments will be mixed with investments held by our nominee company, a Sub-Custodian or a third party appointed by a Sub-Custodian for other customers. This means that:

  • your investments will not be separately identified from those of other customers except within our records;
  • when we receive investments or money on behalf of more than one customer in connection with mixed holdings (for instance in a bonus or rights issue or takeover) we will allocate them between customers on a pro rata basis, in accordance with the Applicable Requirements;
  • if a share issue or other corporate event favours small investors your actual allocation may be less than it would be if your investments were registered in your own name; and
  • sometimes amounts or investments may arise which would not have arisen if the investments had been registered in your own name. You may not be entitled to any such additional amounts or investments.

8.4

We have controls in place to ensure that your investments are not used to settle trades of another customer.

Regardless of the controls and measures in place there can be instances when shortfalls in money or investments can occur. This can be just during the working day or sometimes for a longer period.

If there is a shortfall in any of the holdings of our nominee company, a Sub-Custodian or a third party appointed by a Sub-Custodian you may share proportionally in such losses. 

Where we identify a discrepancy that results from or reveals a shortfall, or during an investigation where we deem it appropriate to do so, we will allocate a sufficient amount of our own money to cover the value of the shortfall, which we will hold as client money.

8.5

To the extent that your Portfolio holds Fractional Entitlements to investments (that is, rights to a part of an investment), your entitlement will be reflected in our records. 

A Fractional Entitlement exists only in our records and cannot be sold without being combined with other Fractional Entitlements to make a whole investment. This means that in the event of our insolvency you would not be able to have these Fractional Entitlements returned to you and they would have to be sold in order to realise their cash value. This could impact on the extent to which, or the speed with which, you would be able to recover your Fractional Entitlements. 

This section 8.5 does not apply to any Self-Managed Products we provide to you. We do not hold Fractional Entitlements as part of Self-Managed Investing Service.

Our responsibility for nominees and Sub-Custodians

8.6

We accept responsibility for the acts or omissions of a nominee company controlled by us or any J.P. Morgan company as if those acts or omissions were our own.

8.7

We may appoint a third party in the UK or overseas to act as Sub-Custodian in accordance with the Applicable Requirements. Where we do this, we will exercise all due skill, care and diligence in the selection, appointment and periodic monitoring of that Sub-Custodian. We may appoint a Sub-Custodian which is part of the J.P. Morgan group. Please see our Conflicts of Interest Policy for more information on how we take measures to prevent conflicts of interest, including when we work with our affiliates within the J.P. Morgan group.

However, we accept no responsibility for the default or other failure to perform by a Sub-Custodian, a third party appointed by a Sub-Custodian or any nominee company of the Sub-Custodian or third party appointed by a Sub-Custodian except to the extent that we have failed to exercise such due skill, care and diligence. 

If your Portfolio holds a Managed ISA or a Self-Managed ISA, Managed Lifetime ISA, or Managed Junior ISA, then sections 24.14, 25.13 or 26.18 (as relevant) will also apply to that Product.

8.8

Where your investments are held by a Sub-Custodian or a third party appointed by a Sub-Custodian, we cannot ensure that you would not lose any investments if that Sub-Custodian or a third party appointed by a Sub-Custodian fails. 

In order to show that your investments are not available to the creditors of a Sub-Custodian or a third party appointed by a Sub-Custodian, we will take reasonable steps to ensure that a Sub-Custodian’s or a third party appointed by a Sub-Custodian's records show that the investments are held for you and that they do not belong to us, a Sub-Custodian, any third party appointed by a Sub-Custodian or any nominee company of a Sub-Custodian or third party appointed by a Sub-Custodian.

In the event that a Sub-Custodian, a third party appointed by a Sub-Custodian or any nominee company of a Sub-Custodian or third party appointed by a Sub-Custodian becomes insolvent, we will seek to recover your investments through all means reasonably available to us, including from the administrator or insolvency practitioner appointed to deal with that entity's affairs. During such period, we may not be able to Deal in the affected investments.

Entitlements arising from your investments

8.9

We or any Sub-Custodian or a third party appointed by a Sub-Custodian will be responsible for claiming and receiving dividends and other entitlements automatically arising in respect of your investments. Where these entitlements are in cash, we will reflect these entitlements in your Portfolio and hold them as client money.

Sometimes withholding taxes or other deductions may apply to such entitlements. We or our Sub-Custodian or a third party appointed by a Sub-Custodian can, where required to comply with legal or regulatory requirements, withhold or deduct tax or other amounts from such payments and deduct the costs incurred in doing so from your Portfolio. If you are eligible to reclaim any such withholdings or deductions it will be your sole responsibility to do so.

Accrued dividends are rounded to the nearest penny prior to payment into your Pot by following a process known as "Banker's rounding" (also known as "half to even" or "rounding to the nearest even number"). For more information on how this process works please see here.

Treatment of rounding differences

Where there are rounding differences after the dividends have been posted to your Pot, we will cover any:

i.           Rounding up differences by transferring money from our own account, or

ii.          Rounding down differences by transferring money to our own account.

What we can do with your investments

8.10

Neither we nor any Sub-Custodian, a third party appointed by a Sub-Custodian or any nominee company of the Sub-Custodian or third party appointed by a Sub-Custodian will lend your investments to anyone else or use them to raise finance.

8.11

You authorise us, and our nominee company, a Sub-Custodian or a nominee company of the Sub-Custodian or a nominee company of a third party appointed by a Sub-Custodian, to hold or transfer investments (or entitlements to them) with or to: securities depositaries, clearing or settlement systems, account controllers or other participants in the relevant systems in the course of providing the service. 

  • These investments or entitlements will be separately identifiable from any investments or entitlements held in the same system for our own account. 
  • These entities may be located in or outside the UK.
  • You agree that we will be bound to act in accordance with the rules of the relevant depository or clearing or settlement systems. 

We will not be responsible for the default or failure of such entities, any other counterparty or of any depositary or agent of those entities. Our ability to deliver any securities or payments to you as a result of a Deal is limited to the extent that we receive those securities or payments from those entities.

8.12

We can transfer your investments to another person as set out at section 19.3.

Sub-Custodian’s right to set off and other rights over your cash and investments  

8.13

You expressly authorise us to grant our Sub-Custodian or a third party appointed by a Sub-Custodian to the extent permitted by Applicable Requirements, the right to:

  • retain, sell, consolidate, or merge any cash or investments,
  • deduct or set off any amount from any cash or investments, and 
  • exercise a lien, or other legal rights over any cash or investments,

in order to meet any liabilities or obligations arising in connection with the provision of custody services.

These rights may be exercised without notice and will only be granted to the extent that they are permissible under the Applicable Requirements.

Our rights to give your investments to charity if we cannot contact you

8.14

If we have not received instructions in relation to your Managed General Investment Account, Self-Managed General Investment Account, Managed ISA, Self-Managed ISA, Managed Junior ISA or Managed Lifetime ISA for at least 12 years and we have taken reasonable steps to contact you but cannot do so, we may sell your investments and pay the proceeds and/or transfer your investments to a charity of our choice. We will only do so if permitted by Applicable Requirements.

Where we do this, we will pay you a sum equal to the value of the investments at the time they were sold or transferred if you later contact us to claim your investments.

8.15

The Managed Personal Pension terms and conditions between you and ESL set out how your investments will be dealt with.

9.

Client Money

Section 9 explains how we keep the cash in your Portfolio, and reflects the regulatory requirements which apply to us when we do so. Please contact us if you have any questions about section 9.

Your money will be kept separate from our money

9.1

Where we hold cash in your Portfolio we will hold it as "client money" in accordance with the Applicable Requirements. This means that we will keep money that we hold for you separate from our own money.

Your money is held in an account with an approved bank

9.2

Your money will be placed in a client money bank account with an approved bank in accordance with the client money rules.

9.3

We will exercise due skill, care and diligence when we decide which approved bank(s) to use and periodically review that decision. 

We will not be responsible for any acts, omissions or the default of the approved bank or those who act on its behalf, except to the extent that we have failed to exercise such due skill, care and diligence. 

In the event that an approved bank becomes insolvent we will seek to recover your money through all means reasonably available to us, including from the administrator or insolvency practitioner appointed to deal with that approved bank's affairs.

If your Portfolio holds a Managed ISA or Self-Managed ISA, Managed Lifetime ISA, or Managed Junior ISA, then sections 24.14, 25.13 or 26.18 (as relevant) will also apply to that Product.

Your money will be mixed with that belonging to other customers

9.4

Your money will be mixed in client money bank accounts with money belonging to our other customers. This means that your client money will not be separately identified from that of our other customers.

If an approved bank does not hold enough money in the relevant client money bank account to meet your entitlement and those of all of the other customers (for example, because the relevant approved bank becomes insolvent), you and the other customers would share that loss in proportion to the size of your respective entitlements.

Other third parties that can hold your money

9.5

You authorise us to allow another person, such as an exchange, clearing house or intermediate broker, to hold or control your client money for the purposes of Deals that we make for you through or with that other person.

9.6

We can also transfer your money to another person as set out at section 19.3.

Your money may be held outside the UK

9.7

Your money may be held outside the UK if:

  • an approved bank holds a client money bank account outside the UK; or
  • we effect a Deal on your behalf, or income is paid on investments, outside the UK which means that your client money has to pass through a third party such as an exchange, clearing house or intermediate broker located outside the UK.

In these circumstances the applicable legal and regulatory regime will be different from that in the UK. If the person holding your money cannot meet their obligations, then your money may not be treated in the same way as it would have been treated if it had been held in the UK.

We will, to the extent possible, make a claim on your behalf to recover your money, including, where applicable, through any available compensation scheme.

Interest payable on your money

9.8

We may pay you interest on the cash we hold for you at a rate determined by us. Information on our current interest rates can be found here.

9.9

Where applicable, interest will accrue daily from the working day after your cash is settled and allocated into your Pot and accrue up to the date your Pot is closed.

For example, when you make a payment by debit card or Direct Debit, your money will be held in an account in our name with a Payment Service Provider (PSP) as indicated in section 6.4. The PSP will typically transfer your money to us within three business days and interest will accrue daily once your money is allocated into your Pot.

We will pay your interest into the Pot in which it was accrued.

Interest will be paid on a quarterly basis. Each quarter will end on the first Sunday of March, June, September and December each calendar year. Each interest payment will include all the interest accrued up to the end of the relevant quarter.

Interest will be paid to you on the 20th of March, June, September and December. If the 20th falls on a weekend or bank holiday in England, then we will pay your interest on the following business day.

Accrued interest is rounded up to the nearest penny prior to payment into your Pot.

9.10

If we decide to change our interest rate, we will give you reasonable notice. If you are not willing to accept the change, you may choose to end this agreement immediately as set out in section 18.5.

9.11

Cash only Pots

You can create a cash only Pot (i.e. Pot 100% allocated to cash) within your Managed General Investment Account, Managed ISA, or Managed Lifetime ISA. This option is not available for Income Investing Pots.

Any subscriptions you make to your cash only Pot within your Managed ISA or Managed Lifetime ISA will be held within your ISA tax wrapper and contribute towards your subscription limit.

9.12

A cash only Pot is not available for your Managed Junior ISA, Managed Personal Pension Account, and/or any Self-Managed Products you hold with us.

9.13

As the money in your cash only Pot is not invested, we will not charge you management fees on the cash. Cash only Pots will accrue interest as stated in section 9.8.

9.14

A cash only Pot is not a Cash ISA and must not be used for long-term savings. See here for more information on cash only Pots and their intended use.

9.15

A cash only Pot that is unlikely to be either invested or withdrawn in the short term should not be held in your Product(s) with us.

9.16

If you do not use your cash only Pot in line with these terms, we may take action under these terms to stop providing you with services and/or freeze or block access to your Portfolio and/or Product(s) as stated in section 17.1.

Our rights to give your money to charity 

9.17

After you close your Managed General Investment Account, Self-Managed General Investment Account, Managed ISA, Self-Managed ISA, Managed Junior ISA or Managed Lifetime ISA, it is possible that further monies may reach your account (for example, dividend payments).

For all Products, if the balance of your account is less than £1 after we have determined that all monies due to you have been received, we reserve the right to pay that small balance to a registered charity of our choice and you specifically consent to us doing so. If you would like further information on this process or about the registered charities to whom we may pay such balances, please contact us.

In the case of a Self-Managed General Investment Account or Self-Managed ISA, where further monies reach your account following a request to close the relevant Self-Managed Product, we may keep the Self-Managed Product open for a period of up to six calendar months to allow any such monies to be received. At the end of that period, if the balance of the relevant Self-Managed Product is £0, we shall close the Self-Managed Product. If there is any residual balance remaining in the relevant Self-Managed Product, the Self-Managed Product will remain open unless and until that balance is withdrawn or otherwise transferred in accordance with these terms.

9.18

Where permitted by the Applicable Requirements, if:

  • there has been no movement in the balance of the client money in your Managed General Investment Account, Self-Managed General Investment Account, Managed ISA, Self-Managed ISA, Managed Junior ISA or Managed Lifetime ISA (except for payments or receipts of interest, charges or similar items) for a period of at least six years and
  • we have taken reasonable steps to contact you but cannot do so,

we may stop treating money that we hold for you as client money and may pay it to a charity of our choice.

Where we do this, we will pay you a sum equal to that paid to charity if you later contact us to claim these amounts.

9.19

The Managed Personal Pension terms and conditions between you and ESL set out how your money will be dealt with.

10.

Rights and actions arising in relation to your investments

This section 10 does not apply to any Self-Managed Products we provide to you. Please see sections 44 (on product documentation and disclosures), 45 (on Corporate Actions) and 48 (on statements and reports) for information on the rights and actions that apply in relation to investments held in Self-Managed Products.

10.1

If you ask us in writing to do so, we will arrange for you to receive the relevant regulatory product information document for the ETFs in which your Portfolio is invested, such as a KID (Key Information Document) or, where applicable, a KIID (Key Investor Information Document) or other manufacturer document.

10.2

If you ask us in writing to do so, we will, in relation to any relevant company or unit trust in which your Portfolio is invested, arrange for:

  • you to receive the annual reports and accounts and other investor information issued by that company or unit trust; and
  • you to receive information about a relevant shareholders' or unitholders' meetings and for you to attend and vote (if applicable).

10.3

We will also tell you what you need to do if you want to exercise any rights attached to your investments in another way.

10.4

We will inform you of any rights issues, takeover offers, capital reorganisations, conversion or subscription rights (collectively "Corporate Actions") that affect or relate to your investments. We will act on your instructions in relation to such Corporate Actions, including any standing instructions that you have given to us

10.5

To the extent that your Portfolio holds Fractional Entitlements to investments, the rights set out in sections 10.2 to 10.4 above will not apply.

11.

Managed Portfolio: Withdrawals of cash or assets from your Portfolio

This section 11 does not apply to any Self-Managed Products we provide to you. Please see sections 40.1 and 41.2 for an explanation of the process for withdrawing cash and assets which applies in relation to Self-Managed Products.

Withdrawing cash

11.1

You can make a withdrawal in cash from a Managed General Investment Account, or a Managed ISA you hold with us at any time.

You can make a withdrawal in cash from a Managed Junior ISA or Managed Lifetime ISA subject to limitations on withdrawals that apply to those Products. Please see section 25 and section 26 for more information.

The Managed Personal Pension terms and conditions between you and ESL set out how you can make withdrawals from your Managed Personal Pension.

11.2

If you want to make a withdrawal you will need to give us an instruction telling us how much you want to withdraw and, if you have more than one Product, which Product(s) you want the withdrawal to be made from.

11.3

For any Managed Product(s) that you hold with us, provided that there is sufficient value in the relevant Managed Product(s), we will process your withdrawal request at the next trading cycle. We will pay the money to the UK Bank Account when we receive it. Unless you give us specific instructions to do otherwise, we will do this by paying any cash held in your Managed Product(s) and then, to the extent necessary, by selling your investments. For Income Investing Pots, please also refer to sections 11.7 to 11.12.

Withdrawing or transferring investments

11.4       

Except to the extent that we hold Fractional Entitlements in investments for you, you can make a withdrawal of investments (i.e. where the investments are paid to you rather than to a third party ISA manager) from a Managed ISA, Managed Lifetime ISA or Managed Junior ISA, subject to the limitations on withdrawals that apply to those Products at sections 24, 25 and 26.

11.5          

Except as set out in section 11.4, withdrawals or transfers of investments from your Portfolio are subject to our prior agreement.

In some circumstances we may be able to facilitate an In Specie Transfer to another third party provider.

Where an In Specie Transfer is not available, the transfer may need to be effected in cash (following sale of the relevant investments) or by such other method as we determine, acting reasonably and in accordance with these terms. If we cannot carry out your instructions, we may contact you to request further instructions.

We are not able to effect a withdrawal or transfer of Fractional Entitlements in investments. We agree only to sell those Fractional Entitlements and effect a cash withdrawal or transfer to that extent.

Details of the In Specie Transfers we currently support are available here. If you have any questions about withdrawing or transferring your investments, please contact support@personalinvesting.jpmorgan.com.

11.6          

We may charge a fee for effecting a withdrawal or transfer of investments as set out in the Schedule of Fees and Charges.

Income Investing  

11.7 

If you have an Income Investing Pot, the income (e.g., dividends, interest, etc.) generated from the investments in that Pot will be automatically paid to your UK Bank Account (Income Payment), rather than being reinvested.

Income Investing Pots are not available for any Self-Managed Products we provide to you.

11.8 

Income Payments will occur monthly, on the 24th day of each month. If the 24th falls on a weekend or bank holiday in England, we will pay your income on the previous business day.

Interest on your cash (including income balance pending payment) will accrue and be posted to your Income Investing Pot on a quarterly basis, in accordance with section 9 (i.e., on the 20th of March, June, September, and December). Interest will be paid to your UK Bank Account as part of your Income Payment, along with other income.

Income Payments from your Income Investing ISA will be treated as withdrawals from your Managed ISA tax wrapper, according to section 24.24 of these terms.

11.9 

The income from your investments may fluctuate from month to month. To reduce that volatility and promote steady Income Payments, we may hold back some income during periods of higher returns to offset periods of lower returns. This is called "smoothing", as this feature is intended to "smooth out" periods of high and low returns.

You can opt out of this feature at any time. If you do so, all your accrued income will be paid in your next Income Payment.

If you have additional questions about "smoothing" please see here.

In both scenarios, all income awaiting payment to you will be held as client money in accordance with section 9 of these terms.

11.10 

If no income has been earned in your Income Investing Pot, no Income Payment will be made. Income Payments are not guaranteed.

Additionally, the Income Payment may not be processed if, by three business days prior to the 24th:

  • We could not verify your UK Bank Account details; or
  • You have moved outside of the UK or changed your tax residency; or
  • We receive notice of your death; or
  • Your account has been blocked or suspended according to these terms.

If, for these or any other reasons, we are not able to make your Income Payment, we will hold any income we receive as cash (income balance) and proceed with the Income Payment(s) as soon as possible and in accordance with our payment cycle in section 11.8. All income awaiting payment to you will be held as client money in accordance with section 9 of these terms.

Additionally, in the event that you move to a different country, the processes explained in sections 1.2 and 1.3 will apply.

11.11 

If you close, withdraw or no longer have an Income Investing Pot, your scheduled Income Payments will continue until the last income generated by your investments is paid out to your UK Bank Account as provided in section 11.7.

The proceeds generated from selling your investments in an Income Investing Pot will not be paid out as part of the regular Income Payments but will be processed via separate transaction(s).

11.12

If you instruct a transfer of your Income Investing ISA to another ISA manager according to section 24.20 and 24.21, your Income Payments will continue if we are unable to forward them to your new ISA manager, until your last income is paid out to your UK Bank Account.

Partial transfers are allowed according to section 24.20. In those cases, a portion of your investments in your Income Investing Pot will be sold and transferred as cash. Any scheduled Income Payments will not be split.

12.

Your instructions

12.1

You can give us instructions in relation to your Portfolio by using the method(s) that we agree with you from time to time. We are not obliged to acknowledge receipt of your instructions.

12.2

We may, at our discretion, delay or not carry out an instruction:

  • until we can contact you to clarify or check your instruction, if we reasonably believe that it is in your interests to do so;
  • if your Portfolio and/or Product (as relevant) does not hold sufficient investments and/or cash for us to follow your instruction;
  • if we reasonably suspect that the instruction was not given by you; or
  • if we reasonably suspect that another person has accessed, or is attempting to access, our systems, your Security Credentials and/or otherwise interact with your Portfolio.

We will not be liable for any loss or expense that you incur as a result of such a delay or refusal, provided that we have acted reasonably.

12.3

We may act on any instruction where we reasonably believe in good faith that the instruction is from you and is correct, without carrying out any further checks or investigations.

We will not be liable for following an instruction which is not in fact genuine, provided that we have acted reasonably and in good faith.

We will not be liable for investigating, not investigating, or not following any instruction that we reasonably believe may not be genuine, provided that we have acted reasonably and in good faith when we have done so.

For the avoidance of doubt, if we become aware or reasonably suspect that you have used (or tried to use) an AI agent to access our systems, otherwise interact with your Portfolio or to give us an instruction, we reserve the right to treat this as the involvement of another person other than you, in which case any instructions provided may not be treated as valid.

In relation to any references in these terms to you appointing, authorising or allowing another person to interact with or operate your Portfolio or give us instructions, “another person” shall be construed to include an AI agent.

Appointing someone else to operate your Portfolio

12.4

You can appoint another person to operate your Portfolio for you. To do this, you'll need to provide us with a Power of Attorney signed by you. You cannot do this for a Managed Junior ISA. We also do not offer this for any Self-Managed Products we provide to you.

12.5

Sometimes another person may also be appointed to act for you. This could happen if you're unable to operate your Portfolio yourself, for example because you have a mental incapacity.

As long as we receive the correct legal documentation confirming the appointment, we'll allow that other person to operate your Portfolio. Until we've received these documents we won't allow any other person to give instructions on the Portfolio, for example to make a withdrawal or close it.

12.6

If we know that a person's legal authority to act for you has ended, we won't accept an instruction from them about your Portfolio.

12.7

These terms apply to any person allowed or appointed to use your Portfolio, but you'll be responsible for everything they do. This includes if they make you breach these terms.

12.8

You agree that we can follow instructions from ESL in relation to any Managed Personal Pension Account where it is reasonable for us to do so.

13.

Managed Portfolio: Statements and Reports

This section 13 does not apply to any Self-Managed Products we provide to you. Please see section 48 on the statements and reports which apply in relation to Self-Managed Products.

13.1

Where we provide you with our discretionary management service, we will send an electronic statement and valuation report in respect of your Managed Portfolio every three months.

This statement and report will include details of the cash and investments that we hold for you; the interest, dividends and other payments received; Corporate Actions arising; how the Portfolio has performed; transactions carried out; and the fees and charges deducted; the income you have earned in your Portfolio if you have selected Income Investing for any Product.

13.2

You can ask us by Messages to provide a confirmation that we provide discretionary management services to you where your employer requires one. We will provide this free of charge. We will usually provide this by email but if an original signed letter is required, we can write to you.

14.

Access to your Portfolio and our services

14.1

We may temporarily prevent access to your Portfolio and/or Products and/or our services where it is reasonably necessary for us to do so in order to comply with the Applicable Requirements, or to carry out important maintenance or upgrades to our services.

14.2

We can block access to your Portfolio and/or Products if we reasonably suspect there has been unauthorised or fraudulent use of your Portfolio or we have reasonable concerns about the security of your Portfolio (including where we have reason to suspect you have allowed an AI agent to access our systems or otherwise interact with your Portfolio).

We'll let you know if we do this, and why, unless it would be unlawful for us to tell you or it would affect the security of your Portfolio.

If possible, we'll tell you before we put a block in place but, if we can't, we'll tell you immediately after we've done it. We'll remove a block as soon as the reason for it ends.

We may get you to change your Security Credentials if we reasonably believe this is necessary to keep your Portfolio secure.

We can also restrict and/or suspend your access to the Self-Managed Investing Service in accordance with section 42.

15.

Your Information

15.1

Our Privacy Policy explains how we'll use your information.

15.2

We'll also give information to others if:

  • we are required to do so by law or public duty (e.g. if we believe you may have tax obligations in other countries, we may have to disclose that information directly to tax authorities); or
  • we need to disclose to protect our own interests (e.g. in any legal proceedings); or
  • we have your specific agreement.

15.3

You explicitly consent to us accessing, processing, and retaining any information you provide to us, for the purposes of providing the Portfolio and the services to you in accordance with these terms. This doesn't affect any rights and obligations you or we have under data protection legislation.

You may withdraw this consent by closing your Portfolio. If you do this, we'll stop using your data for this purpose, but may continue to process your data for other purposes.

16.

Our responsibility to you

This section 16 does not apply in relation to any Self-Managed Products we provide to you. Please see section 49 which explains our responsibility to you in relation to the Self-Managed Investing Service.

16.1

We will not be responsible for any losses to you unless those losses are directly caused by our negligence, wilful default or fraud.

16.2

Except in relation to our selection of Sub-Custodians (in which case section 8.7 applies) or an approved bank (in which case section 9.3 applies), we will be responsible for the acts or omissions of our agents and sub-contractors as if those acts or omissions were our own.

16.3

We will not be liable to you for any act or omission by us which we reasonably believe to be necessary to avoid us breaking Applicable Requirements.

16.4

We won't be responsible for any losses to you if we can't perform our obligations under these terms because of abnormal or unforeseeable circumstances beyond our control (or the control of any third parties acting for us), the consequences of which were unavoidable despite all efforts to the contrary.

16.5

Nothing in these terms will exclude or restrict any duty owed to you under the Applicable Requirements or any liability that Applicable Requirements do not allow us to exclude or restrict.

17.

What happens if you do not meet your obligations and your liability to us

17.1

If you seriously or persistently fail to meet your obligations under these terms or fail to meet any of the conditions for our Products:

  • we may stop providing you with services or freeze or block access to your Portfolio and/or Product(s);
  • we may end this agreement and close your Portfolio and/or Product(s) immediately by giving you notice in writing; and/or
  • you will be responsible for reimbursing us for our losses that arise as a result of such failure.

17.2

Where you do not meet your obligations to us (as set out above in section 17.1) you are responsible for reimbursing us for any costs or liabilities which we properly and reasonably incur as a result of complying with our obligations under these terms or Applicable Requirements.

17.3

If the value of any Managed Product which is a Managed ISA or a Managed General Investment Account falls below £500 because of a withdrawal or transfer that you have made, we may sell any investments in that Product and hold cash for you until you make a payment or transfer into the Product which brings the value back above £500. For Income Investing Pots, the applicable amount is £10,000.

17.4

If the value of any Managed Product falls below £75, we may sell the investments in that Managed Product and hold only cash for you. This section 17.4 does not apply to any Self-Managed Product.

Our right of set off

17.5

If you have cash or investments in your Portfolio, we may "set it off" against any amount you owe us or any J.P. Morgan company which is due for payment.

17.6  

We'll always write to you before we use our right of set off. We'll only use this right if we think it's reasonable, taking into account your circumstances and the Applicable Requirements.

We can use cash or investments in your Portfolio even where there's a court decision against you or you are fined (including interest arising after the date of the decision or fine) except where we're prevented by the court or Applicable Requirements.

18.

Changing these terms

Our rights to change these terms

18.1

We may change the terms of this agreement at any time where:

  • the change is to respond to a change to Applicable Requirements, to new industry guidance or codes of practice, or decisions or recommendations that we have to follow (such as those from a court, an ombudsman or a regulator);
  • the change is an increase to our costs and charges to respond to cost increases associated with providing the service and/or Portfolio and/or Products; or
  • the change is to take account of changes in technology, the systems we use to provide the service, or the investment and financial systems.

We'll only make changes for these reasons if it's reasonable for us to pass the impact of that change on to you. In all cases, we'll always be proportionate in how we respond to a change.

18.2

We may also change the terms of this agreement (including fees and charges as set out in the Schedule of Fees and Charges) at any time for any other valid reason not specified in section 18.1 above.

18.3

We may also make changes to the terms of this agreement where the change would not be to your disadvantage. For example, we may make changes to:

  • improve or clarify this agreement;
  • make this agreement fairer to you or easier to understand; or
  • introduce a new optional product or service.

18.4

Where we make a change to the agreement, we will tell you what that change is, the reason for the change and the date on which the change will come into effect. Unless Applicable Requirements prevent us from doing so or where the change is not to your disadvantage, we will give you reasonable prior written notice of any change to these terms.

We may correct clerical errors, typographical mistakes, formatting issues, cross-referencing errors and other similar inaccuracies in this agreement at any time. Where such changes do not adversely affect you or materially change your rights or obligations, we may make those corrections without giving you prior written notice.

Your rights where we make a change

18.5

If you are not willing to accept a change we make to these terms, you may choose to end this agreement immediately. If the change is not for one of the reasons given in section 18.1 or 18.3, we will agree to waive any costs and charges that would normally apply on termination.

19.

Assignment or transfer of this agreement

19.1

You may not assign or transfer your rights or obligations under these terms to any other person unless you get our consent in advance.

19.2

We may delegate some or all of our obligations to another person, in accordance with these terms and the Applicable Requirements. We may assign our rights and obligations under these terms at any time. We will tell you before such an assignment takes effect.

Transfer of business

19.3

If we transfer to a third party the business to which these terms, your client money and/or investments relate, you agree that we may transfer your client money and/or investments to that third party as part of the transfer of business, provided that:

  • the client money and/or investments are transferred on terms which require the third party to whom they are transferred to return your client money and/or investments to you as soon as practicable at your request; and
  • if the amount of client money and/or investments transferred is not less than £25, either:

    - the client money and investments transferred will be held in accordance with the Applicable Requirements relating to the holding of money and investments (as applicable); or

    - we have exercised all due skill, care and diligence in assessing whether the third party to whom your client money and/or investments are transferred will apply adequate measures to protect these sums and/or investments.

19.4

If we transfer your client money and/or investments as we have described, we will give you notice no later than seven days after the transfer, informing you:

  • whether or not the client money and/or investments will be held by the person to whom they have been transferred in accordance with the client money rules and/or the Applicable Requirements relating to the holding of investments (as applicable) and, if not, how the client money and/or investments being transferred will be held by that person; and
  • the extent to which the client money and/or investments transferred will be protected under a compensation scheme; and that you may opt to have your transferred client money and/or investments returned to you as soon as practicable at your request.

20.

Ending this agreement and closing your Portfolio or Products

When you can end the agreement

20.1

You may end this agreement and/or close any of your Products at any time, by giving us 30 days' notice by Messages.

20.2

If you give notice to close your Managed Personal Pension, we will treat this as notice to also close your Managed Personal Pension Account.

When we can end the agreement

20.3

We may end this agreement, close, consolidate or merge any of your Products and/or stop providing any of our services to you at any time by giving you 30 days' notice. An example of a reason to 'consolidate' or 'merge' your Products may be where we have discontinued a particular type of Product and therefore transfer any investments you may hold in such discontinued Product to a different one of an equivalent risk level.

20.4

We may end this agreement, close, consolidate or merge any of your Products and/or stop providing all or part of our services to you in connection with your Products, including but not limited to, rejecting transfer requests, refusing incoming payments, rejecting instructions to invest, liquidating investments, restricting access to your dashboard, requiring you to transfer your Product(s) to another provider, deciding not to continue to rebalance your Portfolio(s), terminating any tax wrapper, or taking any other reasonable action, immediately if:

  • you seriously or persistently fail to meet your obligations under this agreement;
  • you move to another country, change your tax residency or become a US Person;
  • your conduct towards our staff (including anyone acting on our behalf) is or has been abusive, offensive and/or violent;
  • we reasonably suspect any services or Products are being used to facilitate fraudulent activity; or
  • keeping the agreement in place and/or providing you with the Product(s) and/or services would be contrary to the Applicable Requirements.

We will inform you if we decide to do any of these things, unless to do so would be a breach of the Applicable Requirements or impracticable.

We have additional rights of this type which apply in relation to our Self-Managed Products we provide to you. Please see section 42 on our rights to suspend Self-Managed Investing Service for further information.

How we close your Products

20.5

If you or we terminate the agreement and/or close a Product, we will:

  • complete transactions for your Product that have already started but not yet completed; and
  • transfer the cash and/or investments in your Product in accordance with section 20.6.

20.6

So that we can close your Product, you must tell us how you want to withdraw and/or transfer your cash and/or investments from that Product in accordance with section 11.

If you do not do this within a reasonable timeframe, we may sell your investments and pay the resulting cash in your Product to your UK Bank Account or to another account in your name.

If you become a US Person, we may sell your investments, and we may withhold a portion of your cash to satisfy US withholding tax requirements (back-up withholding). This withholding will not be applied to your Managed Junior ISA or your Managed Personal Pension.

20.7

If you or we end the agreement or close a Product, you will be liable for our costs and charges up to the date of the Product closure and any expenses or losses necessarily incurred by us or on our behalf in order to conclude outstanding transactions for your Product.

We will not apply the annual management fee (as set out in the Schedule of Fees and Charges) to any Managed Product once your investments have been sold and held as cash.

20.8

Unless we have ended this agreement or closed your Portfolio/Product under section 20.3, or you are ending the agreement under section 18.5 because we have made a change to these terms, costs and charges may apply for the transfer of cash and/or investments. Please see the Schedule of Fees and Charges.

20.9

The sections of these terms which cover how we will hold cash or assets for you in relation to our Product(s) will remain in place after the date any Product is closed until we have transferred all cash and investments to you from that Product.

21.

Death

21.1

In the event of your death, we will follow the instructions of your personal representatives once we have received satisfactory proof of their authority. Your personal representatives will be bound by this agreement.

22.

If there’s a dispute between us

22.1

English law applies to this agreement and any dealings we had before you and we entered into this agreement.

22.2

The courts of England and Wales have jurisdiction to hear any disputes about this agreement, unless you live in another part of the UK in which case any disputes may be brought in that part of the UK.

23.

Third Parties

23.1

A person who is not a party to this agreement cannot enforce or enjoy the benefit of any of its terms.

H. Terms that apply only to particular types of Product

The terms under this section H may contain references to the ISA Regulations. Please contact us if you have any questions.

24.

Terms applying to a Managed ISA or Self-Managed ISA with us

What is our Managed ISA or Self-Managed ISA?

24.1

Our Managed ISA or our Self-Managed ISA are Stocks and Shares ISAs which we operate as ISA manager in accordance with the ISA Regulations.

24.2

Your Managed ISA or Self-Managed ISA will only be exempt from UK capital gains tax and income tax if it is valid under the ISA Regulations.

Opening a Managed ISA or Self-Managed ISA with us

24.3

In addition to the requirements that apply to our Products generally, in order to open a Managed ISA or Self-Managed ISA with us you must be either: 

  • resident in the UK; or 
  • if you do not live in the UK, a Crown servant (for example diplomatic or overseas civil service) or their spouse or civil partner; and

In relation to a Managed ISA (but not a Self-Managed ISA) you must also open and have a Managed General Investment Account with us.

24.4

Unless you tell us otherwise, we will automatically renew your active Managed ISA or Self-Managed ISA at the beginning of each subsequent tax year. Therefore, even if you do not make any subscriptions to your Managed ISA or Self-Managed ISA for an entire tax year or more, you do not need to reapply for your Managed ISA or Self-Managed ISA and you may resume your contributions at any time (provided that your Managed ISA or Self-Managed ISA is not otherwise terminated in accordance with these terms).

24.5

We will open your Managed ISA or Self-Managed ISA once we have received:

  • a valid application from you and your first subscription; or
  • where you are transferring cash to us from another ISA with a different provider, a valid transfer form and receipt of the relevant cash from your previous ISA.

Subscriptions to your Managed ISA or Self-Managed ISA

24.6

You can subscribe to your Managed ISA in cash as set out in section 6 or by transferring cash from a Managed General Investment Account you hold with us. You can subscribe to your Self-Managed ISA in cash as set out in section 6, but cannot transfer in cash from any other Product you hold with us, including a Self-Managed General Investment Account.

Multiple ISA Subscriptions

24.7

Where permitted by the ISA Regulations, you may open and/or subscribe to your Managed ISA or Self-Managed ISA with us in addition to other Stocks and Shares ISA(s) that you may have with other ISA manager(s), provided that you remain within the overall annual subscription limit.

24.8

In each tax year you can only subscribe in accordance with the applicable subscription limit for that tax year. The current subscription limit is set out here.

24.9

All subscriptions to the ISA account(s) you have with us or with other ISA managers will count towards your overall annual subscription limit for that tax year.

24.10

As part of the Managed ISA or Self-Managed ISA set up process and once a year thereafter, we will ask you to set your own Custom Subscription Limit. You will be able to change your Custom Subscription Limit at any time to the extent that it is (i) not less than the subscription(s) you already made to your ISA(s) and Lifetime ISA(s) during that tax year and (ii) no more than your overall annual subscription limit for that tax year.

Please note that the Custom Subscription Limit feature is only intended to help you keep track of your ISA subscriptions, and you are responsible for ensuring you do not exceed your overall annual subscription limit as set out in the ISA Regulations or HMRC guidance.

  • If you do not set a Custom Subscription Limit as part of your Managed ISA or Self-Managed ISA set up, a default subscription limit will automatically be applied to your Managed ISA or Self-Managed ISA, which shall be the overall annual subscription limit for the current tax year.
  • If you set up a Custom Subscription Limit as part of your Managed ISA or Self-Managed ISA set up, and do not change that Custom Subscription Limit in subsequent years, we will apply the same Custom Subscription Limit for each year unless and until you change your Custom Subscription Limit.

You should set your Custom Subscription Limit by taking into account the amount you have paid into (or plan to pay into) ISA(s) of any type held with us or elsewhere during each tax year. This includes Stocks and Shares ISAs, Lifetime ISAs, Cash ISAs and Innovative Finance ISAs you may have with other managers and that should be reflected in your Custom Subscription Limit. Your Custom Subscription Limit may not exceed the overall annual subscription limit for that tax year.

We will automatically count contributions you make into your Managed ISA(s), Self-Managed ISA(s) and Managed Lifetime ISA(s).

When you intend to make a contribution that would exceed your Custom Subscription Limit (or, where you have not set a Custom Subscription Limit, the overall annual subscription limit for that tax year) we will let you know. Any contribution (or part of a contribution) you make above your Custom Subscription Limit will be held in accordance with the following rules:

(a)          For contributions into your Managed ISA, the excess will be placed in your Managed General Investment Account.

(b)          For contributions into your Self-Managed ISA, the excess will be held as unallocated cash until we receive instructions from you. This means that it will not be within an ISA tax wrapper or held within a Self-Managed General Investment Account. We do not currently pay interest on unallocated cash, as set out in section 9.8. We may contact you to request that you allocate the cash to one of your Products so that it can be invested.

These rules will apply unless you instruct us otherwise.

It will be your responsibility to periodically check your Custom Subscription Limit to confirm it is up-to-date and to ensure you do not contribute more than the overall annual subscription limit in each tax year.

If instructed by HMRC, we may need to place contributions into your Managed General Investment Account, or hold contributions as unallocated cash, as applicable.

24.11

If you cease to be UK resident then you will not be permitted to make any further subscriptions to your Managed ISA or Self-Managed ISA.

Transfers to your Managed ISA or Self-Managed ISA

24.12

Where permitted by the ISA Regulations, you may transfer cash to your Managed ISA or Self-Managed ISA with us from another ISA that you hold. If you have questions about when the ISA Regulations would permit you to make a transfer, please contact us.

Details of the In Specie Transfers we currently support are available here.

What you must do in respect of your Managed ISA or Self-Managed ISA

24.13

At all times while you have a Managed ISA or Self-Managed ISA with us, you must:

  • meet the eligibility requirements at section 24.3 above and tell us immediately if you no longer meet them;
  • not subscribe more than the applicable subscription limit in any tax year to your Managed ISA, your Self-Managed ISA, any Stocks and Shares ISAs, any Cash ISAs, any Lifetime ISAs and/or any Innovative Finance ISAs;
  • be the beneficial owner of (this means that you own or are entitled to) all the cash and investments in your Managed ISA or Self-Managed ISA; and
  • not use the investments and/or cash in your Managed ISA or Self-Managed ISA as security for a loan.

If you do not meet these requirements, we can take the steps set out at section 17.1 and/or your Managed ISA or Self-Managed ISA may be invalid under the ISA Regulations.

How we will manage your Managed ISA or Self-Managed ISA

24.14

We may delegate any of our functions or responsibilities as ISA manager to any other person provided that we are satisfied that person is competent to carry out those functions or responsibilities.

24.15

You authorise us to make disclosures to HMRC as reasonably required for us to comply with the ISA Regulations.

24.16

If we have reason to believe that your Managed ISA or Self-Managed ISA is invalid, we will notify you and we may take any reasonable steps which are required or permitted by the ISA Regulations in respect of that invalidity. If your Managed ISA or Self-Managed ISA becomes invalid, it may no longer be (or may not have been) exempt from UK capital gains tax and income tax.

24.17

In some circumstances, an invalid Managed ISA or Self-Managed ISA you hold with us (see section 24.13) will be eligible for repair under the ISA Regulations. If this is the case, then we will take reasonable steps to repair the Managed ISA or Self-Managed ISA.

24.18

If any investments in your Managed ISA or Self-Managed ISA are evidenced by share certificates or other documents evidencing title, these will be held by us or as we may direct.

24.19

If an ISA investor dies, it is sometimes possible for the surviving spouse or civil partner to inherit an additional one-off ISA allowance. This is known as an "additional permitted subscription". We may agree to accept additional permitted subscriptions into our Managed ISA or Self-Managed ISA. This means that, if we agree to accept additional permitted subscriptions:

  • on your death, your spouse/civil partner will be able to make additional permitted subscriptions into a Managed ISA or Self-Managed ISA you hold with us; and
  • on the death of your spouse/civil partner, you will be able to make additional permitted subscriptions into a Managed ISA or Self-Managed ISA with us.

Please note that if we do not agree to accept additional permitted subscriptions, you or your spouse/civil partner will need to transfer the additional permitted subscription allowance to a third party ISA manager.

Please get in touch with us if you have any questions (see section C above for ways of getting in contact with us).

Following the third anniversary of your death, we will close your Managed ISA or Self-Managed ISA and transfer the existing funds into your Managed General Investment Account, Self-Managed General Investment Account or into unallocated cash at our discretion. As a result, any ISA tax benefits will no longer apply. Any tax benefits accrued up to that date will remain unaffected. We also do not pay interest on any unallocated cash as set out in section 9.8.

We do not provide legal or tax advice. If you have questions, we recommend that you obtain your own independent legal and/or tax advice tailored to your individual circumstances.

Transfers to another ISA manager

24.20

Where permitted by the ISA Regulations, you can ask us to transfer your Managed ISA or Self-Managed ISA to another ISA manager. We will usually only make such a transfer in cash, by selling your investments and then making the transfer.

If we agree to make a transfer in investments, we may charge a fee for this as set out in the Schedule of Fees and Charges.

We are not able to effect a withdrawal or transfer of Fractional Entitlements in investments. We will only sell those Fractional Entitlements and effect a cash withdrawal or transfer to that extent.

If you only hold a Managed ISA, we permit partial transfers, but if you want to transfer subscriptions you have made in the current tax year you must transfer all of your current tax year's subscriptions. We will not permit you to transfer only part of the current tax year's subscriptions.

Details of the In Specie Transfers we currently support are available here.

24.21

If you hold both a Managed ISA and a Self-Managed ISA with us, any transfer to another ISA manager must include all the monies and investments held with us across both Products.

We will process any transfer from your Managed ISA or Self-Managed ISA within 30 days of receiving your request (which will be given to us by your new ISA manager). You can ask us to make the transfer at a particular time in which case we will endeavour to meet this request.

Withdrawals from your Managed ISA or Self-Managed ISA

24.22

You can make withdrawals of cash and/or investments from your Managed ISA in accordance with section 11 and from your Self-Managed ISA in accordance with sections 40 and 41. If you ask us to, we will move the cash and/or investments from your Managed ISA into your Managed General Investment Account. We are currently unable to move cash and/or investments from your Self-Managed ISA into your Self-Managed General Investment Account on request.

24.23

We will process any withdrawal from your Managed ISA or Self-Managed ISA within 30 days of receiving your request. You can ask us to make the transfer at a particular time in which case we will endeavour to meet this request.

24.24

We do not offer a flexible Managed ISA or Self-Managed ISA. This means that amounts that you withdraw from your Managed ISA or Self-Managed ISA cannot be paid back into your Managed ISA or Self-Managed ISA without counting towards the subscription limit for that tax year.

25.

Terms applying to a Managed Lifetime ISA with us

What is our Managed Lifetime ISA?

25.1

Our Managed Lifetime ISA is operated by us as ISA manager in accordance with the ISA Regulations. It is designed to be used for you to make your first home purchase and/or to save for later life. Our Managed Lifetime ISA is a Managed Product which we offer alongside a discretionary portfolio management service.

25.2

Your Managed Lifetime ISA will be exempt from UK capital gains tax and income tax if it is valid under the ISA Regulations. You may also be eligible for a government bonus to be paid into your Managed Lifetime ISA.

Opening a Managed Lifetime ISA with us

25.3

In addition to the requirements that apply to our Products generally, in order to open a Managed Lifetime ISA with us you must:

  • be either: 
    - resident in the UK; or 
    - if you do not live in the UK, a Crown servant (for example diplomatic or overseas civil service) or their spouse or civil partner;
  • be under the age of 40 at the time you open the Managed Lifetime ISA; and
  • not have any other Lifetime ISA in respect of the same tax year.

25.4

Unless you tell us otherwise, we will renew your Managed Lifetime ISA at the beginning of each subsequent tax year.

25.5

We will open your Managed Lifetime ISA once we have received:

  • a valid application from you;
  • your first subscription; and
  • confirmation from HMRC that we may open your Managed Lifetime ISA. If HMRC does not give this confirmation within 15 days of your application then we will return any subscription amounts that you have paid to us and we will not be able to open your Managed Lifetime ISA.

Subscriptions to your Managed Lifetime ISA

25.6

You can subscribe to your Managed Lifetime ISA in cash as set out in section 6.

25.7

In each tax year you can only subscribe in accordance with the applicable subscription limits for that tax year. The current subscription limits are set out here.

25.8

You must make your first subscription to your Managed Lifetime ISA before you reach the age of 40. You cannot make subscriptions to your Managed Lifetime ISA once you reach the age of 50.

25.9

If you cease to be UK resident then you will not be permitted to make any further subscriptions to your Managed Lifetime ISA.

25.10

We will not accept any subscriptions into your Managed Lifetime ISA once we have been notified of your death.

Transfers to your Managed Lifetime ISA

25.11

Where permitted by the ISA Regulations, you may transfer cash to your Managed Lifetime ISA with us from another Lifetime ISA you hold.

What you must do in respect of your Managed Lifetime ISA

25.12

At all times while you have a Managed Lifetime ISA with us, you must:

  • meet the eligibility requirements at section 25.3 above and tell us immediately if you no longer meet them;
  • not subscribe more than the applicable Managed Lifetime ISA subscription limit in any tax year to this Managed Lifetime ISA;
  • not subscribe more than the applicable overall subscription limit in any tax year to your Managed Lifetime ISA, any Cash ISAs, any Stocks and Shares ISAs and/or any Innovative Finance ISAs;
  • not subscribe to your Managed Lifetime ISA once you have reached the age of 50;
  • be the beneficial owner of (this means you own or are entitled to) all the cash and investments in your Managed Lifetime ISA; and
  • not use the investments and/or cash in your Managed Lifetime ISA as security for a loan.

If you do not meet these requirements, we can take the steps set out at section 17.1 and/or your Managed Lifetime ISA may be invalid under the ISA Regulations.

How we will manage your Managed Lifetime ISA

25.13

We may delegate any of our functions or responsibilities as ISA manager to any other person provided that we are satisfied that person is competent to carry out those functions or responsibilities.

25.14

You authorise us to make disclosures to HMRC as reasonably required for us to comply with the ISA Regulations.

25.15

If we have reason to believe that your Managed Lifetime ISA is invalid, we will notify you and we may take any reasonable steps which are required or permitted by the ISA Regulations in respect of that invalidity. If your Managed Lifetime ISA becomes invalid, it may no longer be (or may not have been) exempt from UK capital gains tax and income tax and you may not be (or may not have been) entitled to a government bonus.

25.16

In some circumstances, an invalid Managed Lifetime ISA you hold with us (see section 25.12) will be eligible for repair under the ISA Regulations. If this is the case, then we will take reasonable steps to repair the Managed Lifetime ISA.

25.17

If any investments in your Managed Lifetime ISA are evidenced by share certificates or other documents evidencing title, these will be held by us or as we may direct.

25.18

If an ISA investor dies, it is sometimes possible for the surviving spouse or civil partner to inherit an additional one-off ISA allowance. This is known as an "additional permitted subscription". We may agree to accept additional permitted subscriptions into our Managed Lifetime ISA. This means that, if we agree to accept additional permitted subscriptions:

  • on your death, your spouse/civil partner will be able to make additional permitted subscriptions into a Managed Lifetime ISA you hold with us; and
  • on the death of your spouse/civil partner, you will be able to make additional permitted subscriptions into a Managed Lifetime ISA with us.

Please note that if we do not agree to accept additional permitted subscriptions, you or your spouse/civil partner will need to transfer the additional permitted subscriptions allowance to a third party Lifetime ISA manager.

Please get in touch with us if you have any questions (see section C above for ways of getting in contact with us).

Lifetime ISA government bonus

25.19

If your Managed Lifetime ISA qualifies for a government bonus under the ISA Regulations, we will claim that bonus from HMRC. We will apply any bonus that we receive to your Managed Lifetime ISA in accordance with the ISA Regulations.

25.20

If HMRC rejects a claim that we make for a government bonus to be paid in respect of your Managed Lifetime ISA, we will tell you within 14 days and you have the right to appeal to HMRC against that decision within 90 days.

25.21

Bonus rates are set by the government and are subject to change. You can see the current rates here.

25.22

If HMRC pays any government bonus amounts in respect of your Managed Lifetime ISA in error, then you will be responsible for repaying those amounts to HMRC. We can:

  • deduct these amounts from your Managed Lifetime ISA in order to pay them to HMRC; and/or
  • reduce the amount of any subsequent claim for a government bonus that we make in respect of your Managed Lifetime ISA to take account of that error.

Transfers to another ISA Manager

25.23

Where permitted by the ISA Regulations, you can ask us to transfer all of the value in your Managed Lifetime ISA to another ISA manager. If you have questions about when the ISA Regulations would permit you to make a transfer, please contact us.

We will usually only make such a transfer in cash, by selling your investments and then making the transfer. If we agree to make a transfer in investments, we may charge a fee for this as set out in the Schedule of Fees and Charges.

We are not able to effect a withdrawal or transfer of Fractional Entitlements to investments. We agree only to sell those Fractional Entitlements and effect a cash withdrawal or transfer to that extent.

We do not allow partial transfers from our Managed Lifetime ISA.

25.24

We will process any transfer from your Managed Lifetime ISA within 30 days of receiving your request (which will be given to us by your new ISA manager). You can ask us to make the transfer at a particular time in which case we will endeavour to meet this request.

25.25

If we have claimed but not yet received a government bonus in respect of your Managed Lifetime ISA at the time that we make the transfer, we will pay that amount to the new ISA Manager once we have received it.

Withdrawals from your Managed Lifetime ISA

25.26

You may at any time ask us to make:

  • a partial withdrawal from your Managed Lifetime ISA in cash which will be used to pay some or all of the deposit on your first home purchase and meets certain criteria required by the ISA Regulations. Please refer to our support article that contains important information on these criteria;
  • a partial withdrawal from your Managed Lifetime ISA in cash and/or investments where you are terminally ill. We will process this withdrawal from your Managed Lifetime ISA within 30 days of receiving your request and such evidence of your terminal illness as we may reasonably request to comply with the ISA Regulations; or
  • a withdrawal of everything in your Managed Lifetime ISA in cash and/or investments. We will process this withdrawal from your Managed Lifetime ISA within 30 days of receiving your request.

You can ask us to make any such withdrawal or transfer at a particular time in which case we will endeavour to meet this request. Where you have made a withdrawal of everything in your Managed Lifetime ISA, we will close your Managed Lifetime ISA once we have processed the withdrawal.

In the event that you want to withdraw a government bonus which is due but has not yet been paid in relation to your Managed Lifetime ISA, we will need to receive this amount and calculate any penalty due before we can process your request to withdraw it. This may cause a delay in our ability to process a withdrawal within the timeframes described above.

25.27

A penalty may apply to a withdrawal from your Managed Lifetime ISA. Further guidance can be found here. We will deduct any penalty applicable to a withdrawal from your Managed Lifetime ISA in accordance with the ISA Regulations.

25.28

In summary, a penalty is applicable to a withdrawal from your Managed Lifetime ISA unless:

  • it is made in order to enable your right to cancel your Managed Lifetime ISA as described at section 2;
  • it is made on or after your 60th birthday;
  • it will be used to pay some or all of the deposit on your first home purchase and meets certain other criteria required by the ISA Regulations. Please refer to our support article that contains important information on these criteria;
  • you die and we have received such evidence of your death as we may reasonably request; or
  • you are diagnosed as suffering from a terminal illness and we have received such evidence of this as we may reasonably request to comply with the ISA Regulations.

25.29 

Due to the restrictions on making withdrawals from your Managed Lifetime ISA it is not possible to have an Income Investing Pot within this Product.

26.

Terms applying to a Managed Junior ISA with us

What is our Managed Junior ISA?

26.1

Our Managed Junior ISA is a Stocks and Shares Managed Junior ISA which we operate as ISA manager in accordance with the ISA Regulations. Our Managed Junior ISA is a Managed Product which we offer alongside a discretionary portfolio management service.

26.2       

Your Managed Junior ISA will be exempt from UK capital gains tax and income tax if it is valid under the ISA Regulations.

26.3     

The Managed Junior ISA is held by you as the Registered Contact on behalf of a child for whom you have parental responsibility. Once the child becomes 18 years old the Managed Junior ISA is converted into a normal Stocks and Shares ISA in their name.

Opening a Managed Junior ISA with us

26.4  

In addition to the requirements that apply to our Products generally, in order to open a Managed Junior ISA with us on behalf of a child:

You, as the Registered Contact, must:

  • open and have a Managed General Investment Account with us (in respect of which no minimum investment amount will apply); and
  • have parental responsibility for the child (although you do not have to live at the same address) and provide us with such evidence of your parental responsibility as we may reasonably request; and

the child must:

  • be under the age of 16 at the time that the Managed Junior ISA is opened;
  • have been born on or after 3 January 2011 or not have a Child Trust Fund account (or, if the child has one, transfer it to us as part of the onboarding process);
  • be resident in the UK or if the child does not live in the UK, be a dependent of a Crown servant (for example diplomatic or overseas civil service); and
  • not have any other Stocks and Shares Junior ISA, as required by the ISA Regulations.

26.5

Unless you tell us otherwise, we will renew your Managed Junior ISA at the beginning of each subsequent tax year.

26.6

We will open your Managed Junior ISA once we have received:

  • a valid application from you and the first subscription into the Managed Junior ISA; or
  • where a transfer is being made to us from another Junior ISA manager, or a Child Trust Fund, a valid transfer form and receipt of the relevant amounts from the previous ISA or Child Trust Fund.

Subscriptions to your Managed Junior ISA

26.7

You can subscribe to your Managed Junior ISA in cash as set out in section 6.

26.8

To the extent permitted by the Applicable Requirements, we may agree to accept cash subscriptions to your Managed Junior ISA from a person other than the Registered Contact.

26.9

In accordance with the ISA Regulations, all payments made into a Managed Junior ISA shall be deemed to be a gift and will be non-refundable.

26.10       

Subscriptions to the Managed Junior ISA can only be made up to the applicable subscription limit for that tax year. The current subscription limit is set out here.

Transfers to your Managed Junior ISA

26.11

Where permitted by the ISA Regulations, cash can be transferred to your Managed Junior ISA from another Junior ISA or Child Trust Fund held by the child.

What you must do in respect of the Managed Junior ISA

26.12

At all times while you are the Registered Contact in respect of a Managed Junior ISA with us, you must:

  • meet the eligibility requirements that apply to you at section 26.4 above and tell us immediately if you no longer meet them;
  • tell us immediately if the child does not meet, or has not met at any point since the Managed Junior ISA was opened, the eligibility requirements that apply to them at section 26.4 above;
  • not subscribe more than the applicable subscription limit in any tax year to any Junior ISA and any Cash ISAs that the child may hold;
  • ensure that the child is the beneficial owner of (this means that they own or are entitled to) all the cash and investments in the Managed Junior ISA; and
  • not use the investments and/or cash in the Managed Junior ISA as security for a loan.

If you do not meet these requirements or if the child does not meet the eligibility requirements at section 26.4 above then we can take the steps set out at section 17.1, require that you be replaced as the Registered Contact, and/or the Managed Junior ISA may be invalid under the ISA Regulations.

26.13

The Managed Junior ISA cannot be used as security for a loan. Any attempt to do so will be void.

26.14

If the child becomes bankrupt, the Managed Junior ISA will not pass to any person acting on behalf of the child's creditors. The Managed Junior ISA will continue to be held by you as the Registered Contact on behalf of a child for whom you have parental responsibility.

Registered Contact

26.15

As Registered Contact you will be our point of contact for all statements and other correspondence regarding the Managed Junior ISA and all instructions and information must come from you.

26.16

There can only be one Registered Contact for the Managed Junior ISA at any one time. We will not accept instructions from a person with a Power of Attorney in respect of a Registered Contact or from the child (unless they are also the Registered Contact).

26.17

In accordance with the ISA Regulations, we will replace the Registered Contact only:

  • where a person who has parental responsibility for the child and otherwise meets the criteria set out in section 26.4 applies to us to act as Registered Contact for our Managed Junior ISA; and
  • the existing Registered Contact has consented to the change (in such form as we reasonably require) except in certain circumstances prescribed by the ISA Regulations e.g. the existing Registered Contact has died or cannot be contacted.

The ISA Regulations permit the child in respect of a Managed Junior ISA to become the Registered Contact once they have reached age 16. However, we require the Registered Contact to be at least 18 and so we will not agree to any such request from the child. Once the child reaches age 18, section 26.29 will apply.

How we will manage your Managed Junior ISA

26.18

We may delegate any of our functions or responsibilities as ISA manager to any other person provided that we are satisfied that person is competent to carry out those functions or responsibilities.

26.19

You authorise us to make disclosures to HMRC as reasonably required for us to comply with the ISA Regulations.

26.20

If we have reason to believe that your Managed Junior ISA is invalid, we will notify you and we may take any reasonable steps which are required or permitted by the ISA Regulations in respect of that invalidity. If your Managed Junior ISA becomes invalid, it may no longer be (or may not have been) exempt from UK capital gains tax and income tax.

26.21

In some circumstances an invalid Managed Junior ISA (see section 26.12) will be eligible for repair under the ISA Regulations. If this is the case, we will take reasonable steps to repair the Managed Junior ISA.

26.22

If any investments in the Managed Junior ISA are evidenced by share certificates or other documents evidencing title, these will be held by us or as we may direct.

26.23

Please note that additional permitted subscriptions are not relevant for our Managed Junior ISA.

Transfers to another ISA manager

26.24

Where permitted by the ISA Regulations, you can ask us to transfer all of the value in the Managed Junior ISA you hold with us to another Junior ISA manager. If you have questions about when the ISA Regulations would permit you to make a transfer, please contact us.

We will usually only make such a transfer in cash, by selling any investments and then making the transfer. If we agree to make a transfer in investments, we may charge a fee for this as set out in the Schedule of Fees and Charges.

We are not able to effect a withdrawal or transfer of Fractional Entitlements to investments. We agree only to sell those Fractional Entitlements and effect a cash withdrawal or transfer to that extent.

We do not allow partial transfers from our Managed Junior ISA.

26.25

We will process any transfer from your Managed Junior ISA within 30 days of receiving your request (which will be given to us by the new ISA manager). You can ask us to make the transfer at a particular time in which case we will endeavour to meet this request. After we have completed the transfer, we will close your Managed Junior ISA.

Withdrawals from your Managed Junior ISA

26.26

In accordance with the ISA Regulations, no withdrawals may be made from the Managed Junior ISA before the child's 18th birthday unless:

  • the child is terminally ill and a terminal illness claim has been agreed with HMRC in accordance with the ISA Regulations (although we reserve the right to make our own checks); or
  • the child dies and we have received such evidence of the death as we may reasonably require.

26.27

We will process any withdrawal from your Managed Junior ISA within 30 days of receiving your request and the necessary evidence. You can ask us to make the withdrawal at a particular time in which case we will endeavour to meet this request. After we have completed the withdrawal, we will close the Managed Junior ISA.

Before the child reaches the age of 18

26.28

Before the child reaches the age of 18, we will write to you and/or the child to:

  • request such information as we may reasonably require in order to comply with the ISA Regulations and any other Applicable Requirements; and
  • explain that the Managed Junior ISA will convert into an "adult" Managed ISA on the date that the child turns 18 years old.

If you or the child have not provided us with such information as we may reasonably require in order to comply with the ISA Regulations and any other Applicable Requirements by the date specified in our written communications, we may sell the investments and hold the proceeds as cash in the Managed Junior ISA (if we sell the investments before the child turns 18) or the Managed ISA (if we sell the investments after the child turns 18). If we exercise this right, we will not apply the annual management fee (as set out in the Schedule of Fees and Charges) to the Managed Junior ISA or the Managed ISA (as applicable) unless and until we reinvest the cash.

When the child reaches the age of 18

26.29

When the child reaches the age of 18, we will:

  • stop accepting subscriptions into the Managed Junior ISA;
  • convert the Managed Junior ISA into an "adult" Managed ISA; and
  • request the child's instructions in respect of that Managed ISA.

The terms at section 24 will apply to that Managed ISA.

We will not accept any new subscriptions into that Managed ISA until the child has made such declarations and provided us with such information as we may reasonably request in order to comply with the ISA Regulations.

26.30   

Due to the restrictions on making withdrawals from a Managed Junior ISA it is not possible to have an Income Investing Pot within this Product.

27.

Terms applying to a Managed Personal Pension Account

27.1

The terms in this section 27 apply where you are the member of a Managed Personal Pension with Embark Services Limited ("ESL").

27.2

The agreement in respect of your Managed Personal Pension is between you and ESL. You can see this agreement here. ESL is the provider and operator of your Managed Personal Pension. ESL is a company registered in England, company number 2089815, and is authorised and regulated by the FCA.

27.3

We will provide a Managed Personal Pension Account to hold the cash and investments in your Managed Personal Pension in accordance with this agreement. Our Managed Personal Pension Account is a Managed Product which we offer alongside a discretionary portfolio management service.

27.4

ESL has appointed Embark Trustees Limited to be the trustee of the cash and investments in your Managed Personal Pension and is therefore the legal owner of the cash and investments in your Managed Personal Pension Account. However, we will deal with you (as ESL's agent) in accordance with this agreement.

27.5   

It is not possible to have an Income Investing Pot within your Managed Personal Pension.

I. Other information you should know

Complaints

Making a complaint

If you're unhappy with our service for any reason, please contact us through Messages or by emailing complaints@personalinvesting.jpmorgan.com.

We'll aim to provide you with a decision as soon as we can. Further details about our complaints process are available below.

How to make a complaint

To make a complaint, please get in touch with us by Messages or by emailing complaints@personalinvesting.jpmorgan.com. Alternatively, you can write to us at:

J.P. Morgan Personal Investing Limited – Client Complaints Manager
25, Bank Street
Canary Wharf
London
E14 5JP.

We'll contact you about your complaint and work together to try and find a resolution. We will acknowledge your complaint within five working days.

What happens next?

We will investigate your complaint and aim to resolve your complaint as quickly as possible, but for most complaints it could take up to eight weeks. We'll send you a final response which will explain our investigation and resulting resolution.

Keeping you up-to-date

We'll keep you informed of our progress while we investigate your complaint.

Your rights with the Financial Ombudsman Service

If you're unhappy with how we've dealt with your complaint, you can ask the Financial Ombudsman Service to look into it for you. They'll do so free of charge – but you must contact them within six months of our response.

They can be contacted using the following details:

Financial Ombudsman Service, Exchange Tower, Harbour Exchange, London, E14 9SR

Tel: 0800 023 4567 or 0300 123 9123

Email: complaint.info@financial-ombudsman.org.uk.

If you would like further information about the Financial Ombudsman Service, you can find it on their website at www.financial-ombudsman.org.uk.

Contacting the FCA

If you don't think we've met our legal requirements, you can also submit information about this to our regulator, the Financial Conduct Authority:

Financial Conduct Authority

12 Endeavour Square, London, E20 1JN

0800 111 6768 or 0300 500 8082

consumer.queries@fca.org.uk

www.fca.org.uk

Information about compensation arrangements

We are covered by the Financial Services Compensation Scheme (FSCS). The FSCS can pay compensation to investors if an investment firm is unable to meet its financial obligations. In respect of investment business, an eligible claimant is entitled to claim up to the current FSCS limit for investments.

For more information about the scheme (including the current limits, amounts covered and eligibility to claim) please contact us, visit the FSCS website www.fscs.org.uk, see our FAQ page, and/or contact the FSCS on 020 7741 4100 or 0800 678 1100. Please note only compensation related queries should be directed to the FSCS.

Our authorisation details

J.P. Morgan Personal Investing Limited is authorised and regulated by the Financial Conduct Authority. Our Financial Services Register number is 552016. You can check these details by visiting the Financial Conduct Authority's website at www.fca.org.uk or contacting them on 0800 111 6768.

Conflicts of Interest

There may be limited circumstances in respect of any of our Products and/or services in which a conflict exists between your interests and those of us, other J.P. Morgan companies or our other clients. To mitigate and control these conflicts we have drawn up a Conflicts of Interest Policy. A summary of this document is available here, although you may request a copy of the full policy at any time by contacting us.

J. Terms applying to the Self-Managed Investing Service

28.

The terms which apply to the Self-Managed Products and the Self-Managed Investing Service

Section J will apply to any Self-Managed Products and the Self-Managed Investing Service that we offer. However, other sections of these terms also contain provisions which apply to the Self-Managed Products and Self-Managed Investing Service. This means that section J must be read together with other sections of these terms.

Where there is an inconsistency between a provision of this section J and another part of these terms, the provision in section J shall apply.

The following table lists the main terms that apply to Self-Managed Products and the Self-Managed Investing Service and indicates where they are covered in these terms.

Topic

Where it is covered in the terms

Big picture information

Section B (The big picture)

How we will contact each other and how we support those with accessibility needs

Section C (Getting in contact)
Section D (Accessibility)

A summary of important legal points and how you can keep your accounts secure

Section E (Important information)
Section F (Security)

What you need to do to become and continue to be a customer, and how we will use your information

Section G, 1 (Conditions you must meet to become and remain our customer)
Section G, 15 (Your information)
Section J, 33 (Self-Managed Investing Service Eligibility Criteria)

Details on your right to cancel 

Section G, 2 (Cancellation)

The Self-Managed Investing Service and Self-Managed Products we provide (including the Self-Managed Explore Tools)

Sections J, 29 (Description of the Self-Managed Investing Service and Self-Managed Products)
Section J, 30 (No assessment of appropriateness/suitability)
Section J, 31 (Self-Managed Explore Tools)

The investments you can buy, sell and hold with us as part of the Self-Managed Investing Service

Section J, 32 (Investments you can buy or sell)

What fees we will charge you in relation to the Self-Managed Investing Service

Schedule of Fees and Charges
Section J, 47 (Fees)

How you can pay in cash or withdraw cash from a Self-Managed Product

Sections G, 6.1 and 6.3 to 6.8 (Paying in cash)
Section J, 41 (Cash payments in and out)

How you can transfer an investment into or out of a Self-Managed Product

Section J, 39 (Transferring investments into your Self-Managed Products)
Section J, 40 (Transferring investments out of your Self-Managed Products)

How we will hold the cash in your Self-Managed Product

Section G, 9 (Client Money)
Section J, 43 (How cash is held in the Self-Managed Products)

How we will hold the investments in your Self-Managed Product

Section G, 8 (How we hold investments in your Portfolio)
Section J, 46 (How your investments are held)

What we are required to provide in relation to, and actions arising from, your Self-Managed Eligible Investments

Sections J, 44 (Product documentation and disclosures)
Section J, 45 (Corporate Actions)
Section J, 48 (Statements and Reports)

When we may accept instructions from you or others on your behalf

Sections G, 12.1 to 12.3 (Your instructions)
Section J, 35 (Providing Instructions)

How we will execute trades for you, how we will facilitate non-GBP trades, and the information we may require from you

Section G, 7, 7.2 to 7.4, 7.6 (How we Deal for your Portfolio)
Section J, 36 (How we will execute your instructions in relation to the Self-Managed Investing Service)
Section J, 37 (Foreign Exchange)

When we may change the terms

Section G, 18 (Changing these terms)

What happens when things don't go as expected, including our responsibility to you and your responsibility to us

Section G, 17 (What happens if you do not meet your obligations and your liability to us)
Section J, 49 (Our responsibility to you in providing the Self-Managed Investing Service)

How the agreement can be ended, transferred or assigned

Section G, 19 (Assignment or transfer of this agreement)
Section G, 20 (Ending this agreement and closing your Portfolio or Products)

When we might suspend your access to the Self-Managed Investing Service

Section G, 14 (Access to your portfolio and our services)
Section J, 42 (Rights to suspend Self-Managed Investing Service)

What happens if you die, if there is a dispute between us and treatment of third parties

Section G, 21 (Death)
Section G, 22 (If there’s a dispute between us)
Section G, 23 (Third Parties)

US tax information required for any US securities you buy, sell or hold through the Self-Managed Investing Service

Section J, 34 (US tax information)

The additional terms which apply to a Self-Managed ISA you hold with us

Section H, 24 (Terms that apply to a Managed ISA or Self-Managed ISA with us)
Section J, 38 (Self-Managed ISA)

Other information on complaints, the Financial Ombudsman Service and compensation arrangements

Section I (Other information you should know)

A glossary of the definitions used in these terms

Section K (Definitions)

29.

Description of the Self-Managed Investing Service and the Self-Managed Products

29.1     

Our Self-Managed Investing Service is an execution-only platform. This means that we do not manage the investments on your behalf. Instead, our Self-Managed Investing Service lets you buy and sell Self-Managed Eligible Investments at your discretion, including a selection of UK-listed and US-listed company shares, UK-listed investment trusts and ETFs.

We reserve the right to add, remove or amend any Self-Managed Eligible Investments at any point at our discretion. We may provide you with appropriate notice where reasonable and practicable.

We will follow your instructions and act as an agent to execute Deals for you through our arrangements with the firm that we work with to execute the trades, known as the Principal Broker.

29.2         

The Self-Managed Investing Service is intended for investment purposes by retail clients, who are acting as consumers only. Our Self-Managed Investing Service is not designed for high-frequency trading by, for example, day traders or those engaged in commercial trading activities.

In the course of providing the Self-Managed Investing Service, we do not provide you with any personal recommendations or personalised advice on investment, financial, tax, legal, regulatory, or other matters and no communication or information provided by us in relation to the Self-Managed Investing Service should be construed as such.

The Financial Planning and Advice Service and the Wealth Planner are separate, standalone services. We do not provide our Financial Planning and Advice Service in relation to our Self-Managed Products or any Self-Managed Eligible Investments.

29.3

As part of the Self-Managed Investing Service, you will have the option to open one or both of the following Self-Managed Products:

  • Self-Managed General Investment Account 
  • Self-Managed ISA 

30.

No assessment of appropriateness or suitability

We do not assess the suitability or appropriateness of the Self-Managed Products or Self-Managed Eligible Investments we provide to you in relation to the Self-Managed Investing Service. This is because:

  • we are not required to assess suitability as we do not provide any investment advice or personal recommendations to you or discretionary portfolio management in relation to the Self-Managed Investing Service; and
  • we are not required to assess appropriateness due to the selection of investments that we offer as part of the Self-Managed Investing Service, as well as our adherence with other requirements under FCA Rules.

This means that you do not benefit from any protections under FCA Rules on assessing appropriateness and suitability. You are responsible for obtaining the appropriate information and/or financial advice you may need to make independent assessments about any investment decisions you make under the Self-Managed Investing Service. If you are unsure about any decision you make, such as choosing a Self-Managed Product, Self-Managed Eligible Investments or any other action in relation to the Self-Managed Investing Service, please seek independent advice. 

31.

Self-Managed Explore Tools

The Self-Managed Explore Tools will be available to all customers of the Self-Managed Investing Service.

We offer these tools to help you get access to pricing, data, information or news on Self-Managed Eligible Investments that you might find helpful when making your investment decisions.

These tools allow you to:

  • access data and information on Self-Managed Eligible Investments, including relevant pricing, fundamental and technical asset details such as aggregate stock ratings, ESG profiles and target prices;
  • access regulatory documents available for Self-Managed Eligible Investments; and
  • read news on relevant markets and Self-Managed Eligible Investments.

The information and data provided by the Self-Managed Explore Tools (including, but not limited to, aggregate stock ratings, price targets, news and curated asset collections made available by third parties) do not constitute independent investment research, financial advice or our opinion and should not be interpreted or relied on as such. You must not rely solely on any information or data provided by the Self-Managed Investing Service when making investment decisions and you should conduct your own research and/or seek independent advice if you are unsure.

When we provide marketing content in relation to particular investments, we may make available content produced by third parties, which incorporates data or content issued by third parties. This content does not constitute independent research or financial advice. You should be aware that this content has not been prepared in accordance with legal requirements designed to promote the independence of investment research, and that it is not subject to any prohibition on dealing ahead of the dissemination of investment research.

Please note that some of the information and news included on the Self-Managed Explore Tools is made available by third parties. While we have taken reasonable steps to source the information and news from a reputable source, we are not responsible for the accuracy of information provided by, or derived from, third party sources.

Any information, data or content provided or sourced from third parties does not represent our views or opinion.

32.

The investments you can buy or sell

32.1      

You can only invest in Self-Managed Eligible Investments through the Self-Managed Investing Service. The Self-Managed Eligible Investments include, but are not limited to, securities listed on regulated exchanges such as NASDAQ, the New York Stock Exchange and the London Stock Exchange.

Our right to add new Self-Managed Eligible Investments

32.2         

We reserve the right at our discretion at any time to add new investments which qualify as Self-Managed Eligible Investments onto the Self-Managed Investing Service.

Our right to suspend or withdraw Self-Managed Eligible Investments

32.3          

We reserve the right at any time to suspend or withdraw any Self-Managed Eligible Investments from the Self-Managed Investing Service for any reason. Where we have suspended or withdrawn an investment from our list of Self-Managed Eligible Investments, you will not be able to buy this investment using our Self-Managed Investing Service.

Our obligation to notify you if we suspend or withdraw Self-Managed Eligible Investments that you hold

32.4         

If we suspend or withdraw a Self-Managed Eligible Investment from the Self-Managed Investing Service that you hold, we will notify you. Where practicable, or if we are required to do so, we will provide reasonable notice before the suspension or withdrawal takes effect. 

What happens if a Self-Managed Eligible Investment that you hold is suspended or withdrawn from the Self-Managed Investing Service

32.5         

Where we decide to suspend or withdraw a Self-Managed Eligible Investment that you hold from the Self-Managed Investing Service:

  • you will generally be able to continue to hold the investment, view its current price, and sell it or transfer it to another provider willing to accept the transfer; and
  • we will generally permit you to continue to hold the relevant investment for six months from the date of our notice, to allow you to sell or transfer the investment to another provider. If you do not act within this period, we reserve the right to sell down your holding in the suspended or withdrawn investment upon providing reasonable prior notice to you. 

Where a Self-Managed Eligible Investment that you hold is affected by circumstances outside our control (for example, because it ceases to be tradeable, is suspended from trading or is removed from the relevant exchange):

  • we may no longer be able to show you the current price of the investment;
  • depending on the circumstances, we may be able to facilitate a sale of the investment through our Self-Managed Investing Service or facilitate a transfer of the investment to another provider willing to accept the transfer; and
  • we reserve the right, following prior notice to you, to take such action as we consider appropriate in relation to the investment, including arranging for the sale or transfer of the investment where reasonably necessary. 

33.         

Self-Managed Investing Service eligibility criteria

33.1          

The conditions you must meet to become and remain our customer in section 1 (on conditions you must meet to become and remain our customer) also apply to Self-Managed Products and the Self-Managed Investing Service. You cannot be onboarded as a customer of the Self-Managed Investing Service if you do not meet these requirements.

If you wish to open a Self-Managed ISA, you must also meet the criteria specified in section 24.3 (on specific requirements to open a Managed ISA or Self-Managed ISA with us).

33.2    

In addition, you must also meet the following requirements to open and continue to hold a Self-Managed Product:

  • you must be a UK resident or, if you do not live in the UK, a Crown servant (for example diplomatic or overseas civil service) or their spouse or civil partner;
  • you must hold UK tax residency and provide a National Insurance Number (a UK tax identifier); and
  • you must not be a US Person.

Please note, there is no option for joint ownership of any Self-Managed Products.

Please also note that if you are a client of the J.P. Morgan International Private Bank (J.P. Morgan SE – London Branch) you are not eligible to open a Self-Managed Product via the online private bank website.

33.3     

You do not need to make a minimum deposit to open a Self-Managed Product, nor maintain a minimum balance to continue holding a Self-Managed Product, but you’ll need to have enough funds to cover the cost of any investment you choose to buy.

33.4         

You must tell us if you move to a different country, become tax resident in a different country, or become a US Person. If this happens, we may end this agreement, close any of your Self-Managed Products and/or sell your investments, and/or stop providing all or part of our services and close your Portfolio in accordance with sections 20.4, 20.5 and 20.6 (on when we can end this agreement).  

34.         

US tax information

34.1      

Before you can buy any US securities through the Self-Managed Investing Service, you will be required to sign and submit a valid W-8BEN form to declare that you are not a US Person. Completion of this form may allow you to claim a reduced rate of US withholding tax on US-source income (for example, when you receive any dividend payments on US securities), provided you:

  • have a UK address;
  • hold UK tax residency; and
  • do not hold US tax residency or US citizenship.

Please note that we only support US-UK tax treaty rates when applying withholding tax and will support treaty benefits for UK residents only. This means that if you hold UK tax residency but do not reside in the UK, then you will not receive this tax benefit.

We may be unable to apply the benefits of the US-UK tax treaty if we hold information or documentation indicating that you may not be eligible, including where we hold a permanent or mailing address for you outside the UK, where our records contain US indicia (i.e. information suggesting a connection to the United States, such as a US place of birth, address or telephone number), or where you are a US Person (including a US citizen or US tax resident). In these circumstances, a higher rate of US withholding tax may apply.

34.2         

For ease of submission, the W-8BEN fields will be auto-completed using the most up-to-date details we have from you. In no circumstances do we provide tax advice, and we accept no responsibility for any information inputted through this auto-completion process. You are responsible for ensuring that all information contained in the W-8BEN form is accurate, complete and up to date at the time of submission. You must not submit the form if any information contained in it is incorrect.

If any of your details change following your most recent submission, you must submit a new form immediately with the up-to-date details.

You can trade non-US securities through the Self-Managed Investing Service whether or not you have signed and submitted a valid W-8BEN form. However, once you have purchased a US security through the Self-Managed Investing Service, you will be required to maintain a valid W-8BEN form on file with us for so long as you hold any US securities and, in any event, until the end of the calendar year in which you last held a US security.

34.3       

If you already hold US securities prior to submission of a valid W-8BEN form or your W-8BEN form has become expired or invalid (because, for example, you are no longer eligible for the tax benefit as you no longer have UK tax residency or reside in the UK), and you do not submit a valid W-8BEN form, we reserve the right to sell any US securities held in your Self-Managed Products. You will be responsible for any costs and expenses associated with such disposal and we will not be liable for any loss you suffer from such action. 

34.4          

If your W-8BEN form expires or otherwise becomes invalid, the tax treatment of your holdings may change. We will not support:

  • backdating or forward-dating of address changes;
  • administration of any tax refunds you may be entitled to; and
  • retroactive refunds.

34.5        

We reserve the right to use any data included in the W-8BEN forms, and we may be required to provide to HMRC, the US Internal Revenue Service, or any other relevant tax authority, information related to the Self-Managed Products we hold for you.

35  

Providing instructions

35.1         

Sections 12.1 to 12.3 (on providing instructions) apply to instructions you give us in relation to Self-Managed Products. References to your Portfolio in those sections include any Self-Managed Product you hold with us.

35.2      

As you cannot appoint another person to operate your Self-Managed Product, sections 12.4 to 12.8 (which relate to appointing someone else to operate your Portfolio) do not apply to the Self-Managed Investing Service.

35.3         

Please note, you can only give us instructions to carry out Deals in respect of the Self-Managed Investing Service via our app and website. For example, we do not take instructions to carry out Deals over the phone.

35.4

In general, instructions you give to Deal form a commitment which, once submitted for dealing, cannot subsequently be amended or revoked by you.

However, there are some limited circumstances where an instruction can be cancelled. These circumstances are as follows:

  • where you give an instruction to Deal outside of Market Hours; and
  • during the time between placing the order outside Market Hours and the markets re-opening, you instruct us to cancel the order in question.

We retain the right to reject your instruction to cancel an order placed outside of Market Hours at our discretion where it is reasonable for us to do so (for example where we have already taken steps to submit the order in question for Dealing).

36

How we will execute your instructions in relation to the Self-Managed Investing Service

36.1

Section 7 (on how we Deal for your Portfolio) will apply in relation to the execution of trades under the Self-Managed Investing Service, unless stated otherwise.

Section 7.1 (on carrying out a Deal as agent or principal) does not apply. We will only carry out a Deal for you as agent under the Self-Managed Investing Service and not as principal. See section 36.2 below for more information.

Section 7.5 (on dealing in Fractional Entitlements) does not apply either. We will not Deal for you in Fractional Entitlements in respect of any trades instructed under the Self-Managed Investing Service.

Section 7.7 (on treatment of rounding differences) does not apply to the Self-Managed Investing Service. We will not apply Banker's rounding to trades carried out through the Self-Managed Investing Service. See section 36.5 below for more information.

We will carry out all Deals instructed by you through the Self-Managed Investing Service in accordance with our Order Execution Policy, available here.

36.2     

When you place an order to Deal, we will execute the trade as your agent through the Principal Broker, who may facilitate the trade by entering into a separate transaction in the market. The contract to Deal is formed between us (on your behalf, as your agent) and the Principal Broker. We will pay the Principal Broker fees for facilitating this service.

In some instances, including where there is significant price variation, we and/or our Principal Broker may cancel your order (or any unexecuted part of it). For example, we may apply price tolerance limits when executing an order to prevent a trade from being completed at a price outside those limits. Where practicable, we will notify you of a cancellation and you may need to place the order again.

36.3

We will generally execute your instructions as “market orders”. This means:

  • for orders made during Market Hours, an order to buy or sell will be executed promptly; or
  • for orders made outside Market Hours, an order to buy or sell will be executed as soon as practicable when markets re-open.

“Market orders” will typically be executed at the best available price at the time of execution in accordance with our Order Execution Policy. However, we may apply price tolerance limits to your market orders. This means that we may cancel a market order if, before it is executed, the expected execution price moves beyond certain limits in a way that would be detrimental to you.

36.4  

We reserve the right to introduce other types of order in the future. We will give you appropriate notice before we make such changes, so that you may take advantage of any types of order available to you.

36.5         

You must ensure that your account has enough cash to execute and settle any orders you place. We will not execute any orders for which you have insufficient cash in your Self-Managed Product.

If, in exceptional circumstances, you have insufficient cash to settle a trade, despite passing our pre-trade checks, we may at our discretion use our own cash to allow a trade to settle where it has already been executed. In these circumstances, we have the right to deduct (set-off) any money or liability that you owe us from the cash or investments in your Portfolio.

This could include setting it off against any investment income received such as dividends or interest, and/or closing your open positions or selling Self-Managed Eligible Investments or other investments that we hold for you. We will notify you in advance if we intend to exercise such rights in accordance with sections 17.5 and 17.6 (on our right of set off).

Where rounding differences arise at settlement, after the relevant positions have been posted to your Self-Managed Product (including in relation to Stamp Duty Reserve Tax), we will:

      i.        cover any rounding up differences by transferring money from our own account; and

     ii.        cover any rounding down differences by transferring money to our own account.

36.6    

If you provide instructions for a trade during Market Hours, the trade will be executed in real time, but there will always be a short delay before execution. Our price quotes are only indicative and so during this short delay, the market may move in an unfavourable direction.

This means that, for example, if you place an order to sell a share at our quoted price of £100 but, during the short delay between placing the order and execution, the price of the share falls to £97 for reasons beyond our control, then you will have made £3 less than you anticipated from selling the share. These changes in price can result in a loss of profit or a larger loss than you had anticipated. We will not be responsible for any financial loss to you as a result of these changes in price.

36.7

We may delay or fail to execute a transaction because of market conditions beyond our reasonable control, which may prevent us from Dealing in accordance with our Order Execution Policy or Applicable Requirements, or if the customer fails any pre-trade checks, including but not limited to, anti-money laundering, know-your-customer or funding requirements.

If the trade fails to settle (i.e., we do not receive cash proceeds from the buyer for a sale by you or the delivery of assets by a seller for a purchase by you), we will notify you as soon as reasonably practicable, discuss your options for settlement and use our reasonable endeavours to settle the trade for you. You agree that we may enter into an identical trade with a separate counterparty or unwind the trade and adjust our books and records to reflect the status of the cash or assets we hold for you (i.e., to reflect the actual position on our books).

36.8          

If we receive any fees, commissions or other benefits from any intermediaries in accordance with Applicable Requirements, we will inform you. If we cannot confirm the amount, we will explain how it has been calculated.

36.9       

Please note that there is a risk of partial execution where there are market conditions beyond our reasonable control that may cause only part of your order to be executed. For example, this may occur where there is insufficient liquidity in the relevant market, meaning that there are not enough buyers or sellers for the full quantity of investments you have instructed us to buy or sell.

There is also a risk that, in respect of orders for non-UK securities, the asset trade executes but the FX (foreign exchange) component of the trade fails for reasons beyond our reasonable control.

If only part of your order can be executed, we will treat the executed portion of your order as valid and take reasonable steps to manage the partial execution in accordance with our Order Execution Policy and Applicable Requirements. Provided we have taken these steps, we will not be responsible for any loss or costs you incur as a result of your order being only partially executed.

36.10      

We reserve the right to select the execution venue (the place where the trades occur) or arrange execution in different markets in accordance with our Order Execution Policy.  

Orders placed outside Market Hours

36.11   

If you decide to place an order outside of Market Hours, you will be quoted the previous trading day’s closing price, and the order will be executed as soon as practicable at the best available price when the market re-opens.

During the lapse of time between placing the order outside Market Hours and the markets re-opening, there may be a significant difference between the closing price quoted to you outside Market Hours and the next best execution price achieved at opening.

This means that, for example, if you place an order to buy a share on the London Stock Exchange at 7pm GMT after trading has closed at a quoted closing price of £100 and, for reasons beyond our control, the next best price at opening at 8am GMT on the following trading day was £103 then, provided you have sufficient funds in your account to cover the difference, you will have paid £3 more than you had anticipated per share. Our Customer Investment Risks document gives more information on these risks.

We are not responsible for any financial loss to you as a result of market movements for orders placed outside Market Hours.

When your trades will settle

36.12         

You should be aware that purchases and sales of Self-Managed Eligible Investments depend on the standard contractual settlement cycles in relevant markets and this may be a period of several days (for example, two working days for most UK Self-Managed Eligible Investments). This is known as ‘contractual settlement’, and it may take place before your trade actually settles.

We will update your account to reflect the delivery or receipt of assets or cash on the trade date (i.e., from the point at which an order is executed). This will be prior to contractual settlement of the trade. This means that we will show you your traded positions, pending contractual settlement.

Before a trade has contractually settled, there are certain restrictions on what you can do with the relevant assets or proceeds:

  • You cannot withdraw funds from the sale of an asset until the trade has contractually settled.
  • You may use the proceeds from a sale to purchase another asset, provided that the contractual settlement date of the asset you are buying is on or after the settlement date of the asset you sold.
  • If you buy an asset, you may sell it again before it has contractually settled; however, the proceeds from any sale will only be available for withdrawal once the trade has settled.

Our reporting requirements in relation to any trades we execute for you

36.13

When you trade in certain investments, we may be required to report information relating to you and any Deals that we carry out for you to the FCA or another regulator. We will ask you for the information we require to make these reports, and you are required to provide this to us in line with section 1.1 (on conditions you must meet to become and remain our customer). You may not be able to trade with us until we have received this information.

37.

Foreign exchange

When buying or selling Self-Managed Eligible Investments in a currency other than pounds sterling, such as securities listed on the New York Stock Exchange or NASDAQ, we will arrange for the necessary foreign exchange (“FX”) conversion through our FX Broker so that the purchase or sale can be settled in the required currency (usually US dollars). The FX conversion will be carried out so that it settles at the same time, or substantially the same time, as the purchase or sale of the Self-Managed Eligible Investment.

When you buy or sell a Self-Managed Eligible Investment in a currency other than pounds sterling, you should be aware that you may be subject to additional risks in relation to FX rates. Changes in these FX rates can directly affect what your investment is worth in pounds sterling. Depending on how the FX rates move, this could either increase or decrease the value of your investment in pounds sterling. Our ‘Customer Investment Risks’ document has more information on the risks of buying or selling Self-Managed Eligible Investments.

For any fees and charges related to FX conversion, please see our Schedule of Fees and Charges.

38.

Self-Managed ISA

Section H, 24 (on terms applying to a Managed ISA or Self-Managed ISA) applies to a Self-Managed ISA. Our Self-Managed ISA is a Stocks and Shares ISA which we operate as ISA manager in accordance with the ISA Regulations. It is not a Cash ISA.

If you hold ISAs with other providers in addition to any Self-Managed ISA, please refer to sections 24.7 to 24.11 (on terms relating to multiple ISA subscriptions).

While we will ask you to set your own Custom Subscription Limit to help you track your ISA contributions, you remain solely responsible for ensuring that your combined subscriptions across all ISAs do not exceed your overall annual subscription limit as set out in the ISA Regulations or HMRC guidance. We do not accept liability for any penalties, charges, taxes or sums payable to HMRC where you have breached this subscription limit.

39.         

Transferring investments into your Self-Managed Products

Transferring investments into your Self-Managed Products with us requires what’s known as an In Specie Transfer.

Details of the In Specie Transfers we currently support are available here. We will only accept an In Specie Transfer where we determine at our discretion that the relevant investments to be transferred are Self-Managed Eligible Investments and where operationally possible.

40.      

Transferring investments out of your Self-Managed Products

40.1  

In the context of the Self-Managed Investing Service, sections 11.4 to 11.6 (on withdrawing or transferring investments) do not apply. This section 40 applies instead.

Withdrawals or transfers of investments from your Portfolio are subject to our prior agreement.

We will only facilitate an In Specie Transfer to an alternative provider in circumstances where:

  • we are instructed to undertake an In Specie Transfer by you or your new provider;
  • your new provider accepts the relevant investments that we hold for you, and we have determined that it is operationally possible for us to complete the transfer; and
  • there are no other legal or regulatory constraints on transferring the investments that we hold for you, including re-registration or settlement requirements and/or any transfer restrictions.

Where an In Specie Transfer is not available, the transfer may need to be made in cash (following sale of the relevant investments) or by such other method as we determine, acting reasonably and in accordance with these terms. If we cannot carry out your instructions, we may contact you to request further instructions.

Details of the In Specie Transfers we currently support are available here.

If you have any questions about withdrawing or transferring your investments, please contact support@personalinvesting.jpmorgan.com.

40.2       

Where an In Specie Transfer cannot be completed, we accept no liability for this. We will offer you available alternatives, including a cash transfer where appropriate. 

40.3       

Please note that your ability to place trades in respect of the investments in your Self-Managed Product will be suspended once you or your new provider has instructed us to commence the transfer process. You are not permitted to trade those investments during that period.

In addition to the above, any transfer of investments from a Self-Managed ISA to another ISA manager will be subject to sections 24.20 and 24.21 (on transfers to another ISA manager), including restrictions on partial transfers and applicable timeframes.

41.        

Cash payments in and out

Cash payments in

41.1      

For the Self-Managed Investing Service, sections 6.1 and 6.3 to 6.8 (on paying amounts into your Portfolio) apply (with references to “Portfolio” including the Self-Managed Products). The exception is that we don’t currently accept Direct Debit payments into the Self-Managed Products.

We will make reasonable efforts to process any transfer of cash into your Self-Managed Products as soon as reasonably practicable.

The time it takes for money to become available for investment will depend on the payment method used (for example, open banking typically takes one to two business days). However, there may be circumstances, for reasons beyond our reasonable control, where we will be unable to process these transfers within the expected timeframe.

Cash payments out

41.2       

Section 11 (on withdrawals of cash or assets from your Managed Portfolio) does not apply to any Self-Managed Products we provide to you. The following terms apply instead.

You can withdraw cash that you hold from a Self-Managed General Investment Account and a Self-Managed ISA you hold with us at any time, subject to the contractual settlement provisions applicable when investments are sold that are outlined in section 36.12.

If you want to make a withdrawal you will need to give us an instruction telling us how much you want to withdraw and, if you have more than one Self-Managed Product, which Self-Managed Product(s) you want the withdrawal to be made from.

We will make reasonable efforts to process any cash withdrawal request within three business days of the request. However, there may be circumstances, for reasons beyond our reasonable control, where we will be unable to process these withdrawals within this timeframe and we are not liable for any losses caused by such delay.  

Please note that this clause applies to any cash you hold within a Self-Managed Product. If you hold Self-Managed Eligible Investments and wish to withdraw the value of these investments in cash, they must first be sold. You may submit a sell instruction at any time in accordance with section 35 (on providing instructions in relation to Self-Managed Products). The sale proceeds will become available for withdrawal as cash under this section 41.2 when the trade has been contractually settled in accordance with section 36.12 above.

42.

Rights to suspend the Self-Managed Investing Service

We reserve the right to restrict and/or suspend your access to, and our provision of, the Self-Managed Investing Service or otherwise take any action reasonably required in accordance with Applicable Requirements, in instances where you are (or we reasonably suspect you are):

  • engaging in trading strategies aimed at exploiting errors in price quotes and/or concluding trades at off-market prices;
  • engaging in excessive trading of investments which can impose unreasonable financial costs or operational demands on us;
  • engaging in insider trading, market abuse, fraudulent behaviour and/or otherwise not complying with Applicable Requirements;
  • engaging in any conduct which we suspect or reasonably believe is in breach of any Applicable Requirements;
  • not providing instructions yourself; and/or
  • allowing another person to access our systems, access your Security Credentials, otherwise interact with your Portfolio and/or give instructions on your behalf.

We'll let you know if we do this, and why, unless it would be unlawful for us to tell you. You agree to reimburse us for any losses suffered by us in connection with any action we take under this section.

43.    

How client cash is held in the Self-Managed Products

43.1     

For the Self-Managed Investing Service, section 9 (on client money) applies (with references to “Portfolio” including the Self-Managed Products).

Section 6.8 (Paying in cash) applies where you make a bank transfer (excluding transfers initiated using "Pay in via Chase UK" functionality) and we cannot be sure which Product you would most like to allocate the money to.

43.2         

You may only hold cash in a Self-Managed Product for the purpose of investing in Self-Managed Eligible Investments. A Self-Managed Product is intended for investment purposes only. Any cash held within a Self-Managed Product is not a bank deposit or a Cash ISA and should not be used as a long-term savings account or for any other purpose.

43.3     

If you keep cash in your Self-Managed Products for an extended period of time without using it for investment, we reserve the right to automatically transfer uninvested cash back to your UK Bank Account.

Internal transfers

43.4       

You will not be permitted to transfer cash (or investments) between any Self-Managed Products, meaning you cannot transfer cash (or investments) already within your Self-Managed ISA into your Self-Managed General Investment Account (and vice-versa).

Likewise, you cannot transfer cash (or investments) between Self-Managed Products and Managed Products. By way of example only, you cannot transfer cash (or investments) already held within your Self-Managed ISA into your Managed ISA (and vice-versa).

44.        

Product documentation and disclosures

In the context of the Self-Managed Investing Service, section 10 (on rights and actions in relation to your investments) does not apply. This is because section 10 deals with investments we manage on your behalf. With Self-Managed investments, there is often documentation (e.g. Key Investor Information Document) specific to the securities you choose to invest in, that would be applicable instead.

Where a Key Investor Information Document (KIID), Key Information Document (KID), Key Features Document (KFD), prospectus or other regulatory product information document (such as a product summary) has been produced for a Self-Managed Eligible Investment, we will make this available to you on our app or website and you may request a copy to be sent to you free of charge.

You should read all product information documents made available to you before instructing us to invest. By providing instructions for us to execute a trade under the Self-Managed Investing Service, you confirm that you have engaged with, read and understood the applicable regulatory information document we have provided to you.

45. 

Corporate Actions

45.1   

In the context of the Self-Managed Investing Service, section 10.4 (on instructions relating to Corporate Actions) does not apply.

We will not notify you of any Corporate Actions relating to Self-Managed Eligible Investments held through the Self-Managed Investing Service, unless we are required to do so. However, where practicable, we may choose to provide such notifications at our discretion.

For the purposes of the Self-Managed Investing Service, we generally only support Corporate Actions which are mandatory (i.e. actions which apply to your investments automatically, without you needing to elect to take part).

45.2      

Where a mandatory Corporate Action occurs in relation to a Self-Managed Eligible Investment you hold, which allows holders to make certain elections, we will apply the default option specified by the issuer. This means that we will not act on any instruction from you in relation to such an election. That default option may not be the outcome most favourable to you.

Unless we expressly state otherwise, voluntary Corporate Actions (i.e. those which apply only if you elect to take part) are not available in relation to any Self-Managed Eligible Investments you hold through the Self-Managed Investing Service. This means that where such Corporate Actions occur, we will not make any election on your behalf, the relevant entitlement will ordinarily lapse, and you may receive nothing in respect of it.

We currently do not support the exercise of shareholder rights such as voting rights (including proxy voting) or attendance at general meetings.

45.3        

While processing Corporate Actions relating to specific investments, we may need to suspend the investments that are subject to the relevant Corporate Action. This means that for a period of time until we have completed processing the Corporate Action (typically the payment date or such later date on which your position is updated), you will not be able to sell or transfer the relevant investments.

For example, where there is a stock split (i.e. where the issuer increases the number of shares to reduce the price per share), we may need to withhold your existing holdings in those shares while we process this Corporate Action.

Where possible, we will inform you when any investments are suspended and indicate how long this suspension may last. You may still be able to buy new holdings of the relevant investment during this period.

If you have instructed a transfer of investments that are subject to a Corporate Action, the transfer will be paused and will resume once the Corporate Action has been processed and any related restrictions have been removed.

45.4      

Certain Corporate Actions may result in intermediate or temporary securities or entitlements (for example, nil-paid rights, paid rights, or warrants). Unless we expressly state otherwise, we may, at our discretion, arrange for such intermediate securities or temporary entitlements to be sold on your behalf. Where a sale is not available, practicable or successful, the relevant intermediate or temporary security or entitlement may lapse. Please note that, in these circumstances, you may not receive any value (or the full value) of the relevant security or entitlement, and it may expire without value.

45.5    

Corporate Action entitlements are reflected in our records based on your positions as at the trade date. In some cases, a trade may have been executed but not yet settled by the relevant record date. As a result, a Sub-Custodian or paying agent may not recognise the investment as being held for you and may not deliver the related entitlement. Where an entitlement is due based on our records but is not received because the trade has not settled, we will take reasonable steps to seek recovery of the entitlement through the market claim process.

45.6        

Where cash, securities or other entitlements are due to you as a result of a Corporate Action, we will credit them to your Self-Managed Product as soon as reasonably practicable after we receive them. Please note that, particularly for overseas investments (i.e. non-UK), there may be a delay between the date an entitlement becomes payable and the date we receive and credit it to your account.

45.7         

We may need to correct, amend or reverse the processing of a Corporate Action (including any related credit, debit, delivery of securities, or cash payment) where, for example, we have processed a Corporate Action incorrectly, received incorrect information, or are instructed by the relevant issuer, agent, Sub-Custodian or other third party to do so.

You agree that, where a correction or reversal is required, we will take any reasonable action required to make that correction, amendment or reversal.

45.8 

Some Corporate Actions (including those relating to overseas issuers or securities traded or settled overseas) may be subject to local legal, regulatory, tax or other restrictions. Where permitted by applicable law, we may in our discretion limit, not offer, or restrict your ability to participate in any such Corporate Action, and we may process the Corporate Action in accordance with applicable market practice and/or the procedures of the relevant issuer.

45.9    

Further to section 46 (How your investments are held) below, you cannot hold Fractional Entitlements (meaning a portion of an asset, for example a fraction of a share) in any Self-Managed Eligible Investments held in the Self-Managed Products.

If you are entitled to Fractional Entitlements as a result of a Corporate Action which cannot be aggregated and converted into whole shares, you will not receive these Fractional Entitlements. Instead, the fractional portion may be

(a) rounded down so that you receive only the nearest whole number of shares, in which case no cash compensation may be paid in respect of the fractional portion, or

(b) settled by a cash payment in lieu of the fractional portion (cash‑in‑lieu). When cash-in-lieu is payable, the amount credited to you may be based on, or calculated by reference to, (i) cash-in-lieu amounts received by us from the issuer and/or a Sub-Custodian and/or (ii) the net proceeds of any sale of the relevant Fractional Entitlements. The cash-in-lieu payable on any sale of Fractional Entitlements may therefore differ from any cash-in-lieu rate or amount announced in connection with the Corporate Action, and the amount you receive may be less than the amount announced.

46.      

How your investments are held

For the Self-Managed Investing Service, section 8 (on how we hold investments in your Portfolio) applies (and references to “Portfolio” include the Self-Managed Products).

Section 8.5 (on reflecting Fractional Entitlements in our records) does not apply because you cannot hold Fractional Entitlements in any Self-Managed Eligible Investments held in the Self-Managed Products.

47.            

Fees

If you have insufficient funds in your Self-Managed Products to cover our fees as set out in our Schedule of Fees and Charges, the fees will continue to accrue until additional funds are deposited into the account (for example, through interest, dividends, contributions or when assets are sold), which will be used to cover such fees. We also have rights to set off any amounts you owe us against cash and investments we hold for you in sections 17.5 and 17.6 (on our right of set off).

48.  

Statements and reports

48.1 

A contract note will normally be sent or made available to you when we carry out a Deal (at the latest, this will be provided to you the following business day). This contract note is typically sent to customers using our secure Messages function. This contract note will confirm execution of the trade and contain key details of the Deal.

If you think any details of the contract note are wrong, or if you receive notice of a Deal that you do not recognise, you must contact us immediately. We may issue an updated contract note where we become aware that the original note was materially incorrect.

48.2  

We will send you an electronic statement and valuation report every three months.

This statement and report will include the following information from the reporting period, about your investments held in Self-Managed Products:

  • details relevant to the reporting period of the cash and investments that you hold with us;
  • the interest, dividends and other payments you’ve received;
  • any Deals you’ve instructed us to carry out;
  • Corporate Actions relevant to investments we hold for you;
  • the fees and charges deducted and/or incurred; and
  • an indication of whether any Self-Managed Eligible Investments that we hold for you are subject to certain rules and regulations.

48.3         

You may request additional valuation reports in respect of your Portfolio at any time.

48.4      

Once a year, we’ll send you an electronic statement showing the costs and charges you’ve paid in relation to your Portfolio during the year.

49.       

Our responsibility to you in providing the Self-Managed Investing Service

49.1 

To the extent permissible under Applicable Requirements, we will not be responsible for any losses you incur in connection with the Self-Managed Investing Service unless those losses are directly caused by our negligence, wilful default or fraud.

This includes losses arising directly or indirectly from:

  • market conditions that prevent us from executing your instructions in line with our Order Execution Policy and/or other Applicable Requirements;
  • unavailability of the service or the services we use due to maintenance or upgrades that delays or prevents us from executing your instructions promptly;
  • the performance of third parties when executing your instructions, including the Principal Broker;
  • acts, omissions or insolvency of clearing houses (financial intermediaries who are part of the trading process) and/or electronic dealing systems or any action we reasonably take in response, where these are due to technical reasons outside our control;
  • tax liabilities or losses that may arise from your investments;
  • FX fluctuations in cross-currency transactions;
  • restrictions on trading in certain instruments imposed by governments, exchanges or other authorities;
  • delays, errors or failures in trade execution due to high trading volumes, third parties or exchange outages;
  • order cancellations, modifications or rejections;
  • settlement delays or non-delivery of securities where this is not caused by us;
  • acts or omissions by us which we reasonably believe to be necessary to avoid us breaking Applicable Requirements;
  • losses to you if we can't perform our obligations under these terms because of abnormal or unforeseeable circumstances beyond our control (or the control of any third parties acting for us), the consequences of which were unavoidable despite all efforts to the contrary;
  • where, for reasons outside our control, we are unable to process payments into a Self-Managed Product within the expected timeframe;
  • any loss resulting from us not making you aware of any Corporate Actions, as we are not responsible for doing so; and
  • any action we take (including suspending your access to the Self-Managed Investing Service, refusing to act on an instruction and/or order cancellations) where we have reason to believe an instruction was not given by you and/or where we have reason to suspect unauthorised access to our systems, your Portfolio and/or Security Credentials by another person.

49.2        

Except in relation to our selection of Sub-Custodians (in which case section 8.7 applies) or an approved bank (in which case section 9.3 applies), we will be responsible for the acts or omissions of our agents and sub-contractors as if those acts or omissions were our own, to the extent required under the Applicable Requirements.

49.3    

Nothing in these terms will exclude or restrict any duty owed to you under the Applicable Requirements or any liability that Applicable Requirements do not allow us to exclude or restrict.

K. Definitions

AI agent means any software, tool or system that uses artificial intelligence, an algorithmic decision-making process or a machine-learning model to act on a person’s behalf (whether autonomously or semi‑autonomously).

Applicable Requirements means

(a)          any obligation that applies to us or any J.P. Morgan company under any law or regulation (including any tax legislation or rules made by an applicable regulatory body), or as the result of a decision by a court, ombudsman or similar body;

(b)          any obligation that applies to us or any J.P. Morgan company under any industry guidance or codes of practice which we follow; or

(c)           any other legal or regulatory requirement, which, in each case, is applicable to these terms and/or the provision of a service or Product to you by us or any J.P. Morgan company.

Cash ISA is an ISA that allows you to earn interest on your savings without paying tax on it. This is not a product we currently offer.

Chase UK means J.P. Morgan Europe Limited.

Chase UK Introduced Customer means a person who, at the time they apply for a Product through the Chase UK app is an existing customer of Chase UK, and who is introduced to us through the Chase UK app with a view to us providing our investment Products and services.

Corporate Actions means an event initiated by a publicly traded company (or triggered by its securities) that changes the company’s capital structure, the terms of its securities, or the rights/entitlements of investors (for example, rights issues, takeover offers, capital reorganisations, conversion or subscription rights).

Custom Subscription Limit means the ISA contribution limit that you may set up for your Managed ISA or Self-Managed ISA as described in section 24.10.

Deal means each transaction to buy or sell an investment which we carry out for your Portfolio.

ESL means Embark Services Limited. ESL is the provider and operator of the Managed Personal Pension. ESL is a company registered in England, company number 2089815, and is authorised and regulated by the FCA.

ETF means an exchange traded fund or exchange traded certificate which is listed on a recognised stock exchange. Please see here for further guidance on ETFs.

FCA means the Financial Conduct Authority.

FCA Rules means the Financial Conduct Authority's Handbook of Rules and Guidance.

Financial Planning and Advice Service is our personalised financial advice service to help you decide which Managed Product types and Investment Parameters are suitable for you based on your individual financial circumstances and goals.

Fractional Entitlement means a right to a part of an investment (rather than a whole investment).

FX means foreign exchange.

FX Broker means J.P. Morgan Securities plc or any other FX broker as selected by us at our discretion from time to time.

HMRC means His Majesty's Revenue & Customs.

In Specie Transfer means a transfer of investments from another provider to your account with us, or from your account with us to another provider, whilst keeping them invested rather than selling them and paying the cash proceeds.

Income Investing is our investment strategy designed to regularly pay out income (e.g., dividends, interest, etc.) generated by the investments in your Income Investing Pot to your UK Bank Account. Income Investing may result in lower growth potential as compounding returns may be less than those of an accumulation or growth strategy. JPMorgan Asset Management ETFs will be included within this Investment Style. It is not possible to choose Income Investing for a Managed Personal Pension, a Managed Junior ISA or a Managed Lifetime ISA. Income Investing is not relevant to any Self-Managed Product we provide to you.

Income Investing Pot means a Pot for which you have selected the Income Investing strategy.

Income Payment refers to the monthly payment to you of income generated by your investments in your Income Investing Pot, which includes any interest earned on cash held within that Pot. Income Payments are not guaranteed.

Investment Parameters means the investment parameters that we agree with you in order to manage your Managed Portfolio, including the Investment Styles and your attitude to risk.

Investment Style(s) means each of the investment styles that we offer for you to select in relation to your Managed Portfolio and/or Managed Product(s).

ISA means an Individual Savings Account as defined in the ISA Regulations.

ISA Regulations means the Individual Savings Account Regulations 1998 as amended from time to time.

J.P. Morgan company is any company that controls or is controlled directly or indirectly by JPMorgan Chase & Co., or is under common control with JPMorgan Chase & Co. A company has "control" if it can direct the management and policies of another company through, for example, ownership of shares (and voting rights) or by a contract. Products provided by J.P. Morgan Personal Investing Limited are not guaranteed by J.P. Morgan Europe Limited, JPMorgan Chase Bank N.A. or J.P. Morgan SE - London Branch.

Line of Stock means the investment(s) that you hold in each company or unit trust in which your Portfolio is invested.

Managed General Investment Account means any Managed Product that we hold for you which is not a Managed ISA, a Managed Junior ISA, a Managed Lifetime ISA or a Managed Personal Pension Account.

Managed ISA means an Individual Savings Account as defined and governed by the ISA Regulations. Whenever we say 'our' Managed ISA or similar, we refer to the Stocks and Shares ISA you hold with us in relation to which we offer a discretionary portfolio management service in accordance with these terms.

Managed Junior ISA means a Stocks and Shares Managed Junior ISA. Whenever we say 'our' Managed Junior ISA or similar, we refer to the Managed Junior ISA you hold with us in relation to which we offer a discretionary portfolio management service in accordance with these terms.

Managed Lifetime ISA means a Stocks and Shares Managed Lifetime ISA. Whenever we say 'our' Managed Lifetime ISA or similar, we refer to the Managed Lifetime ISA you hold with us in relation to which we offer a discretionary portfolio management service in accordance with these terms.

Managed Personal Pension means the Managed Personal Pension plan provided by ESL.

Managed Personal Pension Account means an investment account in which we hold cash or investments held by ESL as the provider of the Managed Personal Pension.

Managed Portfolio means any and all of the Managed Products that we provide to you.

Managed Product means any and each Managed General Investment Account, Managed ISA, Managed Junior ISA, Managed Lifetime ISA or Managed Personal Pension Account that we hold for you in accordance with these terms, in respect of which we make all investment decisions on your behalf. A Managed Product does not include a Self-Managed General Investment Account or a Self-Managed ISA.

Market Hours means the hours in which a relevant financial market, offering Self-Managed Eligible Investments, is open for trading.

Messages means our secure email system, formerly known as "Nutmail".

MTF means a 'multilateral trading facility', which is in summary a non-exchange-based trading system which accommodates deals between multiple parties.

Order Aggregation means where we carry out a Deal for your Portfolio and combine it with Deals for other clients or for ourselves in accordance with our Order Execution Policy.

Portfolio means any and all Products that we provide to you.

Pot means a sub-allocation of any Product that we hold for you. In the context of the Self-Managed Products, you will have one Pot for each Self-Managed Product we hold for you.

Power of Attorney is a form of legal document which allows you to appoint a person to act on your behalf.

Principal Broker means J.P. Morgan Securities plc or other broker as selected by us at our discretion from time to time.

Product means any and each Managed Product and/or Self-Managed Product that we hold for you in accordance with these terms.

Registered Contact means the registered contact in relation to a Managed Junior ISA, which is, in summary, a person with parental responsibility for the eligible child who has been designated as the registered contact. We do not permit the eligible child themselves to be a registered contact of a Managed Junior ISA.

Regulated Market means a type of exchange which is regulated by the FCA as a recognised investment exchange – an example of a regulated market is the London Stock Exchange.

Relationship Manager means an individual employed by us or any J.P. Morgan company, or an agent acting on their behalf, who will act as your dedicated Relationship Manager assigned to assist you with any Managed Products (and related services) that you hold with us.

Security Credentials means a password, PIN, passcode, memorable information, biometric or other information which we've given you or you've set up to use in connection with your Portfolio.

Self-Managed Eligible Investments means the specific selection of securities offered as part of the Self-Managed Investing Service.

Self-Managed Explore Tools means any features or functionalities provided within the Self-Managed Investing Service allowing you to access pricing, data, information and/or news on Self-Managed Eligible Investments.

Self-Managed General Investment Account means an account you hold with us in relation to which you receive the Self-Managed Investing Service which is not a Self-Managed ISA. Whenever we say 'our' Self-Managed General Investment Account or similar, we refer to the Self-Managed General Investment Account you hold with us.

Self-Managed ISA means a Stocks and Shares ISA you hold with us as defined and governed by the ISA Regulations in relation to which we offer the Self-Managed Investing Service. Whenever we say 'our' Self-Managed ISA or similar, we refer to the Self-Managed ISA you hold with us.

Self-Managed Investing Service is our execution-only platform to enable you to invest in Self-Managed Eligible Investments at your discretion via the Self-Managed Products.

Self-Managed Product means any and each Self-Managed General Investment Account or Self-Managed ISA that we hold for you in accordance with these terms.   

Simplified Advice Service means our simplified and restricted financial advice service to help you decide which Investment Parameters to allocate to your Managed Portfolio as described at section 4.

Sub-Custodian means a financial institution which we appoint to hold assets on our behalf.

UK Bank Account means the personal UK bank account in your name that you nominate in writing from time to time for the purpose of making and receiving payments from your Portfolio (this includes Income Payments where you have selected Income Investing for a Managed Product).

US Person means a customer considered by the US Internal Revenue Service as a US person at the relevant time. If you are unsure whether you are a US person, please seek independent tax advice.

Wealth Planner is a free digital wealth planning solution designed to provide you with financial guidance, which allows you to map your financial goals and obtain a snapshot of your current wealth situation.

Wealth Services means a suite of consumer support services we offer, including Financial Planning and Advice Service, Wealth Planner, Relationship Manager, and any other services that we may choose to offer in the future.