How are the main tax novelties of the Anti-Fraud Law going to impact us?

The author explains the great changes that will affect taxation with the new anti-fraud regulations.

Published in the BOE of last Saturday, July 10, 2021, and with entry into force the day after its publication, except for some provisions in which its effects are delayed 3 months, the law has been enacted whose title already gives an idea of ​​the multiple scope that regulates: “Law on measures to prevent and combat tax fraud, transposing Directive (EU) 2016/164 of the Council, of July 12, 2016”.

It establishes rules against tax avoidance practices that directly affect the functioning of the internal market, modification of various tax regulations and in terms of gambling regulation.

As a general summary, we can anticipate that the rights and guarantees of taxpayers, the vast majority of whom are not fraudsters, are giving way due to the repressive norms of those punishable activities that limit and constrain, progressively and continuously, the scope of personal freedom of all citizens, to limits where one wonders if the remedy is not worse than the disease.

Thus, we briefly summarize some of the most relevant novelties of the law:


-In relation to the taxation of the tacit capital gain in case of transfer of domicile of an entity within the scope of the European Union (Exit Tax).

It accrues when a taxpayer moves his assets or his fiscal residence out of the tax jurisdiction of the State of residence, to tax the economic value of any capital gain created in its territory (even if that capital gain has not yet been realized at the time of departure). ).

The new rule replaces the deferral regime previously provided for in the case of a change of residence of an entity to another Member State of the EU or the European Economic Area that has entered into a mutual assistance agreement with Spain in matters of collection of tax credits, for the tacit capital gains generated before their transfer until the moment in which the patrimonial elements were transferred to third parties, by an immediate accrual regime on the occasion of the change of residence, although the installment by equal annual fifths is allowed, in the fiscal year transfer and in the following four years, at the request of the taxpayer.

This provision is applied with similar characteristics in the case of taxpayers subject to IRNR who transfer both an isolated element and their activity as a whole to a State with the characteristics indicated in the previous paragraph.

-The regime of the Variable Capital Investment Companies (SICAV), is modified without great importance, establishing new requirements that reinforce their collective nature and avoid their use as a single-person investment vehicle through the use of fictitious partners (“mariachis”). Thus, to compute the minimum number of partners, a minimum investment level of 2,500 euros per partner (12,500 in the case of investment companies by compartments) is required, and entities must maintain a register of partners during the tax prescription period.


– Obligation to declare the virtual currencies and the collections and payments made with them. With effect from July 11, 2021, regulations are established that allow the verification of the taxpayer’s obligation to declare in the Wealth Tax and in the Income Tax, the value and profits derived from such assets.

-On the taxpayer’s side, the obligation to inform about the virtual currencies located abroad, of which he is the owner, has the status of beneficiary or authorized or in some way holds the power of disposition, is established; guarded by persons or entities that provide services to safeguard private cryptographic keys on behalf of third parties, to maintain, store and transfer virtual currencies. This obligation is reinforced by the imposition of a penalty of 5,000 euros for each piece of information that should have been declared with a minimum of 10,000 euros.

-On the side of the depository person or entity, the obligation of persons residing in Spain or abroad, who provide services to safeguard private cryptographic keys on behalf of third parties, to maintain, store or transfer virtual currencies, is established, the obligation to provide the Tax Administration with information on all the virtual currencies that are kept in custody, including the balances in each virtual currency or in cash, identifying the authorized holders or beneficiaries of such balances.

This obligation extends to communicating the acquisition, transmission, exchange and transfer operations in which they intervene or mediate, presenting a nominal list of intervening subjects with an indication of their address, tax identification number, class and number of virtual currencies, their price and operation date.


-A modification is incorporated, apparently minor but of considerable importance in the liquidation of this tax in the form of onerous property transfers related to real estate. Until now, the tax base was determined by reference to the “real value” of the transferred property, an indeterminate legal concept of conflicting fixation.

It is replaced by the concept of “value” equating it to “market value” defined as “the most likely price for which a good could be sold free of charges between independent parties.” In addition, it is presumed, unless there is evidence to the contrary, that the market value will be the reference value set in the electronic office of the General Directorate of Cadastre. It is an undoubted improvement in legal certainty related to the cost of real estate acquisitions.


-In relation to the regulations of the Autonomous Community applicable to non-residents, the right to apply the regulations approved by the Autonomous Community where the highest value of assets and rights for all non-resident taxpayers is located. Initially this right was not granted to non-residents, later it was extended to EU residents to avoid the discriminatory treatment that had been observed in court.

With this modification, the application of the regulations of the Autonomous Community in which most of the assets are located is extended to all non-residents. Thus, the lien of the non-resident who owns only one property, a frequent case, is equated to the lien of residents.


– Prohibition of tax amnesties. With the dubious practical effects that it may have to avoid future legislative modifications, it is provided “… the establishment of any extraordinary instrument of fiscal regularization that may imply a reduction of the tax debt accrued in accordance with current regulations is prohibited.”

-Modification of the system of surcharges for extemporaneous presentation of declarations.

The new applicable surcharge is 1% plus an additional 1% for each full month of delay with which the self-assessment or declaration is filed with respect to the term established for filing and payment. If the presentation is made after 12 months have elapsed from the end of the period established for the presentation, the surcharge will be 15%.

In addition, the regularization corresponding to other periods of the same tax concept that has been regularized by the Administration without sanction is excluded from the surcharge, provided that it is regularized before 6 months from the liquidation.

The previous system (5% in the first 3 months, 15% thereafter until the end of the year and 20% thereafter, plus interest on arrears) entailed a “jumping error” that discouraged filing returns in intermediate periods.

– Prohibition of production and possession of computer programs or systems that allow the manipulation of accounting and management data, It establishes (…) the obligation on the part of producers, marketers and users that the computer or electronic systems and programs that support the accounting processes of invoicing or management of those who develop economic activities, guarantee the integrity, conservation, accessibility, legibility, traceability and inalterability of the records.

Without interpolations, omissions or alterations of which the proper annotation is not left in the systems themselves. This provision is reinforced with an extremely onerous sanctioning regime, which incurs in a debatable “punitive copyright law”: the mere production of systems or programs that allow the manipulation of accounting and management data, or possession without adequate certification. , will be sanctioned with a fixed fine of 150,000 euros, for each year and for each system if they have been sold and 50,000 euros if they have not been sold to third parties, for their simple possession.

Operations in which any of the parties involved act as an entrepreneur or professional for an amount equal to or greater than 1,000 euros or its equivalent in foreign currency cannot be paid in cash.

-Judicial authorization to enter the domicile of the taxpayers. The need for prior judicial authorization for the entry into the domicile of the taxpayers is confirmed and the terms of the application agreement that must be formulated by the Administration are established, although this agreement (and the entry requested) is allowed to be prior to the start of the administrative procedure in question, must be duly justified and reasoned in relation to the purpose, necessity and proportionality of said entry, all in accordance with the jurisprudence of the Supreme Court.

-Modifications of the law of notaries in relation to the deregistration in the fiscal census of entities. It is modified to ensure that entities that have been removed from the tax census of legal entities cannot make entries in any public registry, nor grant deeds before a notary.

For these purposes, the obligation to include the tax identification number in the public deed by which any type of legal entity is created or constituted is expressly confirmed, and the provision of a computerized system through which the General Council of the Notaries will provide the Tax Administration with the identification of those entities with a revoked tax identification number that have tried to grant a public document.

-Limitation of cash payments. Operations in which any of the parties involved act as an entrepreneur or professional for an amount equal to or greater than 1,000 euros or its equivalent in foreign currency cannot be paid in cash. This limit is set at 10,000 for private individuals with tax domicile outside of Spain.

***F. Javier Rodriguez Santos He is a partner of the law firm B. Cremades & Asociados

Caser Asesores enlarges its network of agents in Madrid with Álvaro Sevillano, former head of CoreCapital

He ceased as president, general director and director last spring when he clashed with the Ballvé family (Campofrío).

Caser Financial Advisors offices.

Caser Financial Advisors reinforces its network of agents in Madrid with the incorporation of a heavyweight in the industry, Alvaro Sevillanowho until a few months ago was the head of the family office CoreCapital Finance.

Sevillano, who co-founded CoreCapital, stepped down as chairman, CEO and director last spring colliding with the Ballvé family (Campofrío), main customer of family officeas reported by this newspaper.

With more than 15 years of experience in the sector, Sevillano had previously worked in other relevant positions, as an independent professional at Bankinter, advising large assets, and at other entities such as Banif Banca Privada, Morgan Stanley, Caixa Banca Privada, Lloyds TSB Bank and Deutsche Bank.

The new signing comes to join the team of more than 35 financial agents that are part of the network specialized in financial advice that the Caser Group launched in 2019 and that it directs Helen Calaforra.

Thus, professionals such as Javier Ballarat, Álvaro Merino, Reyes Barquero, Susana Checa, Juan Pablo Ordovás or Mario Durán, among others, have joined the specialized entity in 2021, which closed the 2020 financial year with a net growth of 185 million euros and more than 800 clients.

Metagestion dismisses its CEO and ‘burns’ its third executive team in three years

The manager owned by the largest shareholder of the Montebalito construction company finalizes the return as CEO of Carlos Flores.

Miguel Méndez, in an archive photo of Metagestion.

Metamanagement increases your problems. The independent fund manager, one of the oldest in Spain, has dismissed its general manager, Miguel Méndez, after the poor results harvested in its two main strategies, especially in the one that has to do with the international stock market. It is the third executive team that ‘burns’ in three years. As Invertia has learned, the firm completes the return as CEO of Carlos Flores, who was already its president for just over a year between 2019 and 2020.

The two flagships of Metagestion are the funds MetavalueIberian equities, and International Metavalue, which invests in stocks from around the world. The first only rises 2.5% so far this year, compared to a revaluation of 10% in its index. The photo in the second is even worse. lose more than one -17%, while its comparable index rises 21.2%. Quite a burden, being in the last positions of the ranking.

Méndez has not been able to turn the situation around and has been dismissed for José Alberto Barreras, owner and president of Metagestion. Barriers is in turn the majority shareholder of the construction company Montebalitowhich is listed on the Continuous Market and whose personal fortune is managed by the manager that is under the umbrella of the construction group.

Carlos Flores.

Carlos Flores.

But the outputs in Metagestion do not end there. Another of the fund managers, closely linked to Méndez, has submitted his resignation. Is about Julian Lirolaaccording to sources close to the investment firm.

The question that investors are now asking is: who manages these and the rest of the house’s funds? The only manager left on staff is Ignatius Salido, since Alfonso Batalla left the daily management of the funds last December to take charge of the personal investments of the construction businessman. However, the firm has already opened a selection process to find replacements.

Flores, a fundamental profile

In these comings and goings of executives and managers, everything seems to indicate that it will be Carlos Flores who will take charge of the manager from now on, who is closing his contract in the absence of the last fringes. Flores arrived with Méndez in a double managerial signing in the summer of 2019. The first was given the presidency with commercial tasks and the aspiration to internationalize the firm, and the second depended on the general management with responsibilities for the products and investments of its wallets.

but both They collided from the first minute. Flores had a marked character as a long-term fundamental analyst, compared to technical analysis and trading of short term imposed by Méndez. That particular internal battle resulted in the departure of the first shortly after arriving. But now Barreras has pulled the agenda and has asked him to come back, with room to reintroduce the old philosophy of the house, which was long-term and, even, very dedicated to the value investing.

Flores has worked for firms such as ICBC Standard Bank, Bank of America Merrill Lynch, Goldman Sachs or Deutsche Bank, in positions related to the structuring of derivatives, sale of fixed income and currencies or financing and risk solutions, among others. Currently, he is a Managing Partner of Stormharbour Securities.

Madrid Stock Exchange.

Madrid Stock Exchange.
Europe Press.

Metagestion is responsible for more than 475 million euros in investment funds, according to Inverco with June data, although it managed more than 600 million precisely two years ago, very close to maximums, when it incorporated Méndez and Flores in the first stage of this. The lack of credibility before the investment community due to its constant rotation of teams, the bump in profitability and the Covid-19 crisis have formed the perfect storm for the shop. None of the parties involved have responded to the questions of this newspaper.

And, if he hasn’t lost more clients in this time, it’s because he keeps a collaboration agreement with the OCU,your main customer. OCU Inversiones recommends the Metagestion funds among its partners, although it is not a formal agreement, several of the sources consulted testify.

Horos and Beka fished in rough waters

The truth is that Metagestion has always been a manager with many changes in its leadership. But what we have experienced in the last three years has been a true roller coaster. In the summer of 2018, Javier Ruiz -at that time, Director of Investments-, Alejandro Martín and Miguel Rodríguez they went to Horos Asset Management as majority partners, which was started by José María Concejo, who for a few months -at the beginning of 2017- had also been CEO of Metagestion.

Today, your background Horos Value Iberia is the most profitable among those who invest in the stock markets of Spain and Portugal, with a rise in the year of more than 22%, surpassing its comparable Metavalor by practically 2,000 basis points.

The team that replaced them, made up of Fernando Cifuentes (a veteran of Metagestion) and Javier Martín, ended up joining Beka Finance in 2019 for its Asset Management division. Cifuentes is the director of Fondos Abiertos and Martín, the director of Investments.

There are numerous voices inside and outside that criticize the interference and personalism of Barreras, more an expert in real estate than anything else, in the daily administration of the manager, hindering the work of its executive teams. Despite the fact that he has had several offers to sell the investment firm, all of them have been rejected by him or the negotiations have been broken by the other, given the high price claims that the construction businessman has.

One of his daughters, Anabel Barreras, advises him however sell part of the capital -around 20% would be willing- to some external investment group, in such a way that it would give them financial lung and help them in the professionalization of the manager while Barreras father could continue flying over it but without an executive position. We will have to be attentive to see what happens in this new stage.

According to the firm itself, which has confirmed through an official statement the appointment of Flores after the news published by this newspaper, his total assets amount to more than 550 million if pensions and other portfolios are taken into account. “In this new stage, Metagestion maintains its objective of business growth focused on four fundamental lines: the growth in assets of the entity’s historical funds, the constitution of a new fund in Luxembourg to accommodate international business, the opening of an office in Barcelona and the start-up of the division of private and corporate portfolio management recently approved by the CNMV”, they explain from the manager.

Deutsche Bank ‘fishing’ in Caixa, Rothschild, March and Santander to strengthen its private banking

The German bank has already incorporated almost 25 high-net-worth bankers so far this year.

Deutsche Bank steps on the accelerator to grow in its high-net-worth businesses: private banking and wealth management, this second dedicated to the richest. The German bank has already made almost 25 signings -and some promotions- of private bankers so far this year, with a special focus on large fortunes. Among his latest additions to wealth in Madrid and Barcelonafour professionals have arrived from CaixaBank, Edmond de Rothschild, Banca March and Santander.

The first of them is Jesus Pardo de Santayana, one of the strong men of CaixaBank in the capital, where he held the position of coordinating director of private banking in Madrid. His experience as a manager of large assets dates back to Morgan Stanley, where he started in 2007. But, in 2008, the Catalan group took over the private banking and fund and pension managers of the American for around 600 million euros, which meant the transfer to the then La Caixa of its investment professionals.

Another recently landed in the Spanish subsidiary of the German giant is Henry Velascowho began his career as a tax attorney but then changed course to Abante as a financial advisor, where he remained from 2012 to 2018. His last posting was as a private banker at Edmond de Rothschild, where he spent two and a half years.

The third is Borja Martin, who also started out as a tax advisor. However, he then spent almost seven years at Banco Santander (including its Chilean delegation), from 2009 to 2016, as office manager and private banker, a role the latter has held for almost two years at Renta 4 Banco and close to four in Banca March before his new change. These three bankers have joined the Madrid team.

For his part, in Barcelona he has enrolled Paul Lives from Santander Private Banking. He has been linked to the Cantabrian group in Catalonia since 2007, first as an office manager and later as a private banker.

Objective, 100 ‘top’ bankers

As Deutsche Bank, whose Wealth Management and Private Banking segments in Spain are led by Borja Martos, has reiterated on several occasions, its intention was be reinforced with 25 private bankers in the first semester of 2021 and reach a total number of wealth managers on the payroll that would be around one hundred by the end of the year.

With a little more slowness with respect to its objective for June, but it has already incorporated almost 25, among which there have been some internal promotions.

The German bank’s commitment to your business core of high net worth has been articulated since 2020 under the umbrella of the International Private Bank division, created that same year and directed in Spain by Fernando Souza.

It includes all the business of individuals, companies, private banking and wealth managementthese last two operated jointly and coordinated by Martos since the end of last year, as published by Invertia.

After the business restructuring that it carried out in the geographies where it is present, Deutsche Bank stated its objective of being the bank of reference for business families worldwide.

As highlighted Claudius of Sanctis, head of International Private Bank, during the last Investors Deep Dive last December, the bank is “in a privileged position to offer this segment of clients a single solution for all their needs, both from a private and business point of view”.

At the end of 2020, the assets managed by Deutsche Bank in its private banking in Spain as a whole amounted to €10.3 billionaccording to him ranking produced by the magazine ‘Funds People’.

Among the latest initiatives of the banking group in our country to attract new customers, the launch of a platform to invest in European bank deposits (Deposit Market), the first sustainable deposit in the Spanish market (Depósito Sostenible DB) or the imposition of its DB Strategic Asset Allocation (SAA) portfolios among small investors.

Talenta recovers the autonomy of its sicav and gives a pinch of 75 million to Credit Suisse

By becoming a manager, the Barcelonan goes on to manage the dozen sicavs she had with Credit Suisse herself, although they will continue to collaborate.

Jordi Jofre, partner and president of Talenta Gestión.

The Barcelona talent It’s getting older. Thanks to this movement, the securities agency recently converted into a manager has recovered the autonomy over its sicavwhich to date were managed by Credit Swiss. Altogether, something more than 75 million euros that suppose for the Swiss another pinch in its accounts of Spain, although they will continue collaborating.

Talent Management, led by Jordi Jofre and Carlos Cabanasbecame in April the first manager of collective investment institutions (SGIIC) to see the light in 2021. Founded in 2009 and with assets under the advice and management of €780 millionaccording to its own data from last year, is aimed at private banking customers in Levante and the Balearic Islands.

To date, his 13 sicavs were not ‘owned’. As happens to many investment firms that do not have their own management company, they had to ‘rent’ the umbrella of a third entity. That is, Credit Suisse Management, who was responsible for its administration and management in bureaucratic, legal and operational terms, although Talenta had mandated the sub-management of the investments.

Now, having a management company, a good part of them (a dozen) have already been transferred, pending the completion of the import of the other three. All of them are of medium size, being the largest Drive Investmentswith more than 11 million, and Micron Investmentsover nine million.

On the sidelines is Platino Financiera, the sicav of the Asensio family (Grupo Zeta, Prensa Ibérica), which although it has more than 100 million euros, is managed by UBS with mandates to Talenta, Abante and JPMorgan.

Departures at Credit Suisse

As Invertia has learned from sources in the sector, Talenta has not completely broken with the Swiss bank. In fact, it has delegated part of the administrative tasks to Credit Suisse Management, while Credit Suisse AG Sucursal en España continues to be the depository entity.

Credit Suisse Spain.

Credit Suisse Spain.

But this represents a loss of income for Credit Suisse by disregarding the main activity -and more expensive- on these sicav, which now falls to Talenta. And it doesn’t do him any good at a time when his local business is in question after having been the protagonist of numerous resignations and departures of bankers throughout the summer.

As this newspaper has been reporting, eight private bankers and asset managers have left Credit Suisse to set up their own investment firm, Welcome Asset Management, headed by Ignacio Laviña and Javier Alonso. For his part, Ignacio Llano has signed on as head of the new real estate segment for the great fortunes in Spain that JPMorgan has set up.

Carlos Núñez also went as a private banker to Banca March, where Michael Matossian (the historical head of private banking in Spain for Credit Suisse) has been an advisor since the spring.

Euroclear fuels competition with Allfunds and Inversis after buying the fund supermarket MFEX

The Belgian has taken over the Nordic platform and adds pressure to the European wholesale market, which is led by Allfunds and where Inversis wants to grow.

Euroclear headquarters in Poland.

More competition for mutual fund supermarketsespecially for the Spanish Allfunds and Inversis Banco. Belgian financial group Euroclear has closed the purchase of the Nordic platform MFEX, which puts pressure on the wholesale network from which these investment products so in vogue among customers are distributed, especially with the ultra-low interest rates maintained by the ECB.

Euroclear, whose business is based on post-trade services, that is, the settlement and custody of national and cross-border securities (bonds, shares and derivatives) for investment funds, had announced its agreement with MFEX last March. The financial terms of the transaction have not been disclosed.

For those who do not know MFEX, it is in the top-10 of the largest investment fund platforms in Europe, a ranking led by the Spanish Allfunds. The MFEX group was founded in Sweden in 1999. Its general manager for Spain and Portugal is Antonio Manso, who came to the firm in 2018 from Ahorro Corporación and in 2020 was promoted to first sword. It should be remembered that, in 2018, MFEX had acquired the Spanish platform Ahorro Best Funds from Ahorro Corporación.

The Nordic company covers a global market amounting to 320,000 million euros in assets under management. In addition to distributing funds, it also does trading, custody and data technology solutions, a market infrastructure business that is expanding and to which practically all the wholesale platforms in the sector are going. In your case, it distributes among the banks, insurers and other finalist investment firms that are hooked on its platform more than 80,000 investment funds from 960 different managers.

The Euroclear operation is part of a context of high competition in the old continent for this type of wholesale supermarkets. A business niche that the Spanish Inversis Banco (of the Banca March group) wants to attack after its failed sale attempt at the beginning of 2019.

Investments and Allfunds

As Inversis has recently announced, it will allocate 100 million euros over the next three years to grow both in Spain and abroad. Its two strategic pillars are to undertake purchases and advance in its technological transformation and in the digitization of investment services. In this second aspect, Accenture is helping you thanks to a strategic alliance.

Since 2010, the March’s wholesale investment bank, led by Albert del Cid, it already offers some services in Switzerland, Portugal, the United Kingdom, Chile, Peru and Uruguay. But he wants to grab a bigger piece of the pie in Europe and also in Latin America. On their roadmap is the launch of investment services in Luxembourg and they are following the evolution of regulations on crypto assets to set foot in the digital currency sector such as bitcoin or ethereum.

Allfunds headquarters in Madrid.

Allfunds headquarters in Madrid.

Both MFEX (which is in the top-10 European) such as Inversis (for the moment outside this ranking) have to deal with the spectacular growth of the also Spanish Allfunds. The wholesale bank of funds and wealthtech lead by Juan Alcaraz It has been listed since April on Euronext Amsterdam, in what has been the largest IPO of a national company in many years.

Through June, Allfunds’ assets under management increased by 16.4% compared to 2020, to close to €1.4 trillion. Their Half-year net profit was 117.4 million euros, 94% more than in the same period of the previous year, when it reached 60.6 million in the middle of the first wave of Covid-19. Since its debut, Allfunds stock has revalued 21%, up to 16.78 euros by title.

Allfunds’ reach is global, where it also competes with MFEX, although its scale is much larger. At that level, his main rival is Pershing, the platform of BNY Mellon and one of the largest on the planet. At the moment, Allfunds is focusing its growth on Europe (France and Germany)does not leave the United States aside and, above all, wants to be a relevant actor in Asia.

It was already present in Singapore and Hong Kong and a few days ago it received authorization to operate in Shanghai through a local office, to balance its strong position in the market offshore as a new entrant on the market offshore of the region, the fastest growing in the world.

The CNMV tightens liquidity control in investment funds and includes the reverse stress test

It draws a proposal for a technical guide in this regard that will be in public consultation until next October 15.

Rodrigo Buenaventura, president of the CNMV, in his speech at the 'Finance Observatory' of EL ESPAÑOL and Invertia.

The National Securities Market Commission (CNMV) tightens liquidity control in investment funds. The Spanish supervisor of financial markets is going to submit to public consultation a proposal for a technical guide (see here) on the management and control of the liquidity of the collective investment institutions (CII), which also includes the sicav New features include reverse stress tests.

It is an initiative included in its 2021 action plan which aims to unify all the relevant supervisory criteria applicable in this area that the CNMV has been transmitting to entities in recent years. As explained by the body chaired by Rodrigo Bonaventurethe guide also takes into account the results of the recent actions carried out at a national and European level, highlighting the Supervisory Convergence Action carried out by ESMA -the community supervisor- during 2020.

“Entities that deviate from these criteria must justify their actions and be able to prove that they adequately comply with legal obligations,” the CNMV remarks.

The supervisor is extremely concerned about less liquid assets that are gaining more and more weight in fund portfolios due to the environment of low or negative interest rates: small and mid-caps, high-yield bonds, or high-yieldfixed income from emerging countries, securitisations, subordinated debt or unlisted assets.

In particular, the technical guide proposal contemplates what content should be included in the procedures of IIC managers to guarantee adequate management and control of the liquidity risk of their funds, with the aim of avoid the generation of damages and conflicts of interest between investors. and she goes to look “the proper alignment between the liquidity profile of the assets and liabilities of each IIC”.

Reverse stress tests

For example, compliance must be given, “with a reasonable margin”, of the principle of proportional sale of liquid and less liquid assets (or slicing approach). Detailed guidelines are included on the methodologies to determine the ratios or liquidity levels of financial instruments, the estimation of the time horizons for sales, as well as the scenarios for reimbursements and other payment obligations, and the stress or resistance tests.

The managers must consider in their procedures, on the one hand, the circumstances under which the different tools established by the regulations would be applicable (notice periods, temporary indebtedness, subscriptions/partial redemptions, side-pockets…) also ensuring its proper implementation and, on the other, the use of anti-dilutive mechanisms (among which it is worth highlighting the valuation of the portfolio at prices bid either askand the swing pricing) to avoid conflicts of interest between participants who subscribe or redeem against those who remain.

One of the novelties is that, taking into account the characteristics of the IIC, it is also recommended to carry out reverse stress tests (either reverse stress testing), in which starting from a very serious liquidity situation (in which it has even been necessary to activate an exceptional tool, for example a temporary suspension) the circumstances that could give rise to them are analysed, among others, by maintaining certain weightings in assets with reduced levels of liquidity, or due to certain investor movements or exceptional market events.

The public consultation on the aforementioned technical guide will be open until the next day October 15th 2021, with the usual procedure followed by the CNMV for these cases.

Family Enterprise Partners incorporates from Kefren Capital its new Director of Analysis and Operations

Javier S. Nieto Sales arrives from the ‘family office’ of Inés Entrecanales and Pelayo Primo de Rivera.

An executive in a suit.

investment firm Family Enterprise Partners has been reinforced with Javier S. Nieto Sales as new partner and Director of Analysis and Operations, from also family officeKefren Capital by Inés Entrecanales and Pelayo Primo de Rivera.

Nieto has been Kefren’s Administration and Finance manager for more than six years. With more than 20 years of experience, his professional career has always been linked to the world of investments, portfolio management, venture capital and real estate. He coincided with Rafael Alberca, co-founding partner and CEO of the firm, at Family Office Solutions, later Wealth Solutions, where Nieto worked for six years as Director of Analysis and Operations.

Family Enterprise Partners, which was born a year ago and founded by Daniel Cervantes and Rafael Alberca to provide wealth management services to family officesit is financial agent of Diaphanum in Spain and partner in the registered investment adviser (RIA, in English) of Miami (United States), and advises family groups between Spain and Latin America.

“With this incorporation, we not only reinforce our analysis and operations capabilities, but also incorporate talent and experience for the benefit of our clients, which allows us to continue growing and positioning ourselves as the firm in Spain and Latin America focused on family business”, says Pool.

Didier Saint-Georges: Edouard Carmignac has ‘batteries’ left and sees a corporate operation as very unlikely

“It’s easy to be big, but not so easy to be big and efficient at the same time,” he says in an interview with Invertia, the last one before his retirement.

Didier Saint-Georges.

About three and a half decades in the financial markets. That is the time that has passed Didier Saint-Georges analyzing and managing stocks and bonds for investors, making them earn (a lot of) money through the carmignac investment funds in the last 15. But every road comes to an end.

The French manager announced a few weeks ago that He will retire on October 1. Investors around the world are orphaned by one of their main gurus, the one who has been number two in Edouard Carmignac and the main executor of the philosophy of the French group, responsible for 41,000 million euros in assets.

“It is easy to be great, but it is not so easy to be great and efficient at the same time”, he says as the culmination of a long and successful career, praising the spirit and the wickerwork of Carmignac. His origins, however, go back to entities such as JPMorgan and Merrill Lynch, groups that took him to large capitals such as New York, London and Paris. Always Paris and her glamor.

Saint-Georges has been passing through Spain for several days, explaining to clients how the investment funds they have contracted will be left once he retires definitively. And the message is only one: continuity. The manager reserved a slot for invested, to whom he has granted his last interview to a Spanish media outlet while he is still active. He is convinced that Edouard, the Alma mater of Carmignac, he still has ‘batteries’ left for a while and that it is quite unlikely to see the largest independent manager in the neighboring country and one of the main ones in Europe involved in a corporate operation.

What financial market did you find when you started and what markets are you leaving us now, in a post-Covid 2021?

I started in this business in September 1987, and in October of that same year there was a crash market. I have experienced several crises: the dot com, Lehman Brothers… There is a lesson from all of them. A bubble does not grow out of nothing, it grows around a reality. Then the reality is totally overextended, it becomes excessive and, therefore, there is a correction. A bubble is an exaggeration of reality. But that doesn’t change reality. If you look at the years 2007-2008 and you had the big winning companies, if you had done the right thing, even with the correction, ten years later these companies are much stronger.

As an investor, you have to manage market risk, crises, otherwise you won’t survive. But you also have to remember that there are always trends that survive crises, and it is equally important to capture these trends.

We have learned one thing from this latest coronavirus crisis. For the first time, it was admitted that central banks were not enough to provide liquidity to the system. This time governments have had to step forward with extraordinary fiscal policy measures. But this pumping of liquidity has inflated everything, increasing the discrepancy between the real economy and the price of financial assets, and once again fueling bubbles in financial assets. That is why we are going to have to take into account again the double aspect: risk management and taking advantage of long-term trends.

As an investor, you have to manage market risk, but also capture long-term trends. And now they are fueling bubbles in financial assets again

And which are the companies that will survive the coronavirus?

Long-term trends are again linked to technology. If we have more inflation in the future, it will be necessary to see which companies are capable of resisting an increase in costs. The key differentiator is pricing power, the ability to protect margins. Because potential growth remains very low, perhaps 2%. Companies that do well in a low-growth scenario will continue to be the best. There is a premium towards quality.

Perhaps one thing that will change is inflation. This crisis has created a deep dislocation, not only in the financial markets, everywhere, but also in the real economy. Now demand is going up, people are getting back to normal, but low inventories create huge shortages in many materials. From semiconductors to food, through raw materials. These shortages are not easy to repair. And this creates a risk.

The population as a whole has more savings after the pandemic, the shortage will generate an increase in the prices of goods, but there are some sectors where companies will not have the power to set prices and for these companies there will be a narrowing of margins , because if the final price does not grow as fast as the wholesale price, the margin will pay dearly. This crisis has reinforced the competitive advantage of powerful players with pricing power.

The President of the European Central Bank, Christine Lagarde.

The President of the European Central Bank, Christine Lagarde.

What balance do you make of Christine Lagarde’s mandate at the head of the ECB?

Lagarde has it much easier than Jerome Powell. The ECB will have some milestones in how it reduces its monetary support, but it will be very progressive. In the United States, however, the Fed has to deal with a more pronounced increase in prices in the system. There the question is: How do I control the increase in inflationary pressure without bursting the bubble? It’s going to be a tough job in the next 12 months on your part. Lagarde is not in this situation yet. Europe can continue in a scenario of monetary support in the style dovish and very progressive in the withdrawal of stimuli.

What is the key to Carmignac’s success?

Protect customer money in times of crisis while keeping an eye on and capturing long-term trends. The Anglo-Saxon proverb says that “long term is your friend” (“the long term is your friend”), but you cannot tell an end customer that in a year of crisis his fund has lost 30% or 40%, because at that very moment your relationship with him ends.

In recent decades, we have survived many crises and have stood out positively in them. That made us famous and that’s where our reputation was built. But we have also captured in the last 30 years the super cycle of raw materials, the rise of emerging markets or the technology wave.

As the markets have become more complex and we have managed more money, we have beefed up the teams with more fund managers, analysts or other resources, but we have also found that this is not enough. You still need efficiency in your decision process. You can have huge teams but run the risk of not having the agility or decision-making skills needed when you have to. We have managed to combine all this increase in resources with an effective decision-making process. It’s easy to be great, but it’s not so easy to be great and efficient at the same time.

The strategic investment committee, with Edouard Carmignac at the center.

The strategic investment committee, with Edouard Carmignac at the center.

What do you think will be the star fund of the house in five years? Will Carmignac Patrimoine and Carmignac Sécurité continue to be the best sellers as before?

If I as a client had enough tolerance for volatility, I might buy a pure equity fund. Carmignac Investissement is a great fund, but you have to be aware of the inherent volatility that can be found in this asset class. In Spain, but also in France or Italy, there is a lot of aversion to volatility, and this leads me to think that the preference for diversified and conservative funds will remain very strong, so there is still room for funds like Carmignac Patrimoine or Carmignac Sécurité, who manage risk.

Is his retirement the step prior to Edouard Carmignac’s retirement?

Edouard is very well, as am I. In addition, he still has a passion for this business, and at the same level as his other passions such as contemporary art or sports. But he has the ability to enjoy all these passions together at the same time. He has made it clear that his daughter Maxime will take the reins at some point. She has been assuming more and more importance in recent years but, at the moment, I don’t see in him a sign that she wants to retire in the near future.

Maxime Carmignac.

Maxime Carmignac.

Who will replace you as CEO and within the strategic investment committee?

Nobody is indispensable. I don’t need to be replaced by anyone in particular, there is a very cohesive team with a process where everyone participates. The strategic investment committee has been expanded by one person recently with Keith Ney and will now be reduced by one person when I leave, and that’s fine. It is exactly what is needed: a focused and efficient committee.

Do you think it is likely that Carmignac will end up participating in a corporate operation with another manager?

Edouard and Maxime have made it very clear that they want Carmignac to remain independent. First, there is a culture of control that has always been convinced that independence and freedom are absolute conditions to remain so effective. If you got into an operation, you would lose effectiveness. Being independent is in the company’s DNA. But, in addition, experience says that when independent firms lose their independence, their withdrawal or decline quickly begins. In this business, being independent is a competitive advantage.

Afi creates a ‘venture capital’ to invest in Spanish ‘start-ups’ that it will later absorb

The group chaired by Emilio Ontiveros allocates one million euros to invest in up to 15 ‘fintech’, ‘edtech’ or ‘data science’ companies.

Afi headquarters in Madrid.

important initiative of International Financial Analysts (Afi). The consulting and education group chaired by the famous economist Emilio Ontiveros has created a society of venture capital at the corporate level with which you will invest one million euros in up to 15 start-ups Spanish of fintech, edtech either data science in order to integrate their products and services a posteriori. Or even absorb the companies themselves, if necessary.

The vehicle in question has been named as Afi Corporate Venturing. It is 100% owned by Afi, it is a company not regulated by the National Securities Market Commission (CNMV) and, therefore, it will not give entrance to external investors.

The project was born at the initiative of Elizabeth Gayaconsultant for corporate finance in Afi, and Ignatius Astorqui, market analyst. Supervision is carried out by Pablo Manuecopartner responsible for the group’s Corporate area.

Emilio Ontiveros, president of Afi, in a file photo.

Emilio Ontiveros, president of Afi, in a file photo.

“We want to go one step further in our consulting and training efforts by investing in the capital of companies that have the same DNA as Afi”, that is, that have to do with the finance, technology and education, fencing Manueco.

With this initiative, “we have a strategic purpose, not only financial: identify new products and services that we later incorporate into our service offerings and to our clients”.

Up to 250,000 euros per investee

The 180 business consultants that Afi has will be able to support the start-ups invested in various aspects. The group will provide them with knowledge, open commercial doors for them and carry out joint developments with the firms. The areas in which this program will move revolve around fintech, insurtech, wealth management, edtech, analytics Y data science.

The budget with which Afi Corporate Venturing has been endowed amounts to one million euros. It will be invested over the next year or year and a half in the capital of between five and 15 investees, depending on the amount dedicated to each company. The limit that has been set is 250,000 euros per investeeand almost all of them will be based in Spain.

Unlike venture capital funds or venture capital more traditional, the resources come from the afi treasuryso the implementation of the investment program will be “very fast” since they do not have to raise money from any institutional client, private bank or family office as is often the case in this industry.

Among the requirements that must be met by start-ups for Afi to lay her eyes on them, they must be “of very recent creation, in the initial stages of their development, but with at least six months of track record”, and they must have a “business plan, a committed team, a large and growing market size and, above all, an innovative solution”, lists Gaya, one of the program’s creators.