A. Description of the Advisory Firm
The Mass Group L.L.C-FZ (hereinafter “The Mass Group”) is a Limited Liability
Company. The firm was formed in February 2024, and the owners are Shaun Brookman
and Daniyal Abbas.
B. Types of Advisory Services
Portfolio Management Services
The Mass Group offers ongoing portfolio management services based on the individual
The Mass Group primarily offers investment advisory, financial planning and
consultancy services to UK expatriate clients who are resident in the United States of
America.
Pension Advisory Services
The main services offered under Pension Advisory are but not limited to:
- UK Pension Plan Options and Consultancy
- UK State Pension Options and Consultancy
- IRA Rollover Options and Consultancy
UK Pension Plan Options and Consultancy
The Mass Group works with UK expatriate clients to assess the transfer and investment
options available for their existing pension scheme(s) arising from former employment
into a personal self-directed pension scheme, most commonly known as a Self-
Investment Personal Pension (“SIPP”). A SIPP is UK registered and regulated pension
scheme in the United Kingdom.
A transfer of pension benefits is a complex process and requires specialist advice to
ensure all numerical and non-numerical factors have been suitably assessed. Clients
typically have the right to transfer benefits away from former employer based defined
contribution/money purchase schemes or defined benefit/final salary schemes into a
SIPP. Some of the reasons why a client may consider a transfer are but not limited to:
- Wider investment options
- Consolidation of multiple schemes into one
- Ability to nominate beneficiaries of choice
- Flexible income drawdown options
For defined benefit/final salary schemes, the client will have to be engaged with a UK
Pension Specialist adviser to obtain an Appropriate Independent Advice report,
required under UK legislation.
Should a client proceed with a transfer of their existing pension benefits to a SIPP, the
funds are held and invested through an investment platform (the “investment platform
provider”) who act as the custodian. The Mass Group will never receive or have custody
of client pension funds.
The SIPP is a pension product offered by a regulated pension trustee, authorized by the
relevant regulatory body, for the UK this is the Financial Conduct Authority. The
pension trustees will have their own terms and conditions and fees, which should be
reviewed by clients. The Mass Group will engage with pension trustees, on behalf of
clients, for the purpose of implementing and/or managing a SIPP. Pension trustees
include but are not limited to:
1. Novia Global Ltd
Cambridge House
Henry Street
Bath, BA1 1JS
United Kingdom
Novia Global Limited is authorized and regulated by the Financial Conduct
Authority. Register Number: 653661
2. IFGL Pensions
Third Floor, Cotton House
Old Hall Street
Liverpool, L3 9TP
United Kingdom
IFG Pensions Limited is authorized and regulated by the Financial Conduct
Authority. Register Number: 458576
The Mass Group will also engage with investment platform providers, on behalf of
clients, for the purpose of investment of funds. Investment platform providers include
but are not limited to:
1. RL360
International House
Cooil Road, Douglas
Isle of Man, IM2 2SP
British Isles.
Registered in the Isle of Man number 053002C. RL360 Insurance Company Limited is
authorized by the Isle of Man Financial Services Authority.
2. Ardan International
Royal Court, Castletown
Isle of Man, IM9 1RA
British Isles
Ardan International Limited is incorporated in the Isle of Man with Company
Number 007984V and registered address at International House, Cooil Road,
Douglas, Isle of Man, IM2 2SP, British Isles. Licensed by the Isle of Man Financial
Services Authority with license number 1365
3. Novia Global
Cambridge House
Henry Street
Bath, BA1 1JS
United Kingdom
Novia Global Limited is a registered company in England & Wales. Register
Number: 9042249. Novia Global Limited is authorised and regulated by the Financial
Conduct Authority. Register Number: 653661
The Mass Group will provide ongoing management and portfolio management services
for the funds held in client SIPPs. The appointed investment advisor representative will
assess the client’s attitude to risk before creating an investment allocation. Ongoing
reviews will be provided at least annually.
The Mass Group will also offer portfolio management services to individuals who have
existing SIPPs.
We do not offer tax advice, including but not limited to, guidance on any US tax
reporting obligations and/or other tax consequences associated with clients' pension
transfers. It is advisable that you seek your own tax advice, especially concerning
procedures outlined in tax treaties between the United States and the UK (or any other
relevant jurisdiction) to prevent double taxation on your UK/EU pension arrangements.
UK State Pension Options and Consultancy
As part of The Mass Group’s aim to provide holistic financial planning, we may also
provide consultancy to clients who have accrued benefits under the UK State Pension
via National Insurance whilst employed in the UK.
Clients who have been previously enrolled into the UK State Pension via National
Insurance and now live in the United States of America, have the ability to make
voluntary contributions to the HMRC to ensure they receive the full benefit payable
when they reach state pension age.
The consultation and action will consist of the below process:
- Assist clients obtain a forecast of their existing UK State Pension benefits built up
under National Insurance from HMRC
- Provide clients with an assessment detailing their UK State Pension benefits
including:
o Their current entitlement
o The calculation used to arrive at their benefit
o Confirmation of the age benefits are payable from
o The frequency of payments
o How payments will increase over time
o Options to delay payments passed the state pension age
o Details of the voluntary contribution options available and the cost of those
o A full cost analysis to assess the suitability of voluntary contributions against
the increase pension payment received in exchange
- Guide and assist clients who wish to make voluntary contributions by assisting with
the relevant HMRC applications
The service will be charged on a fixed fee basis agreed with the client from outset.
We do not offer tax advice, including but not limited to, guidance on any US tax
reporting obligations and/or other tax consequences associated with clients' pension
transfers. It is advisable that you seek your own tax advice, especially concerning
procedures outlined in tax treaties between the United States and the UK (or any other
relevant jurisdiction) to prevent double taxation on your UK/EU pension arrangements.
IRA Rollover Options and Consultancy
As part of our consulting and advisory services, we provide recommendations and
guidance regarding your employer retirement plan or other qualified retirement
account. Our suggestions may involve considering the rollover or partial rollover of
assets from your employer's retirement plan or other qualified retirement
account, into
an individual retirement account ("IRA") which we may then manage on your behalf.
Additionally, we extend our management services to apply to funds and securities
rolled into an IRA or another account, for which we will receive compensation.
It is crucial for you to be aware that many employers allow former employees to retain
their retirement assets in the company plan, and current employees may have the option
to move assets out of their company plan before retirement or changing jobs. When
deciding whether to complete the rollover to an IRA, and considering the available
options, you should carefully weigh the costs and benefits of each. Typically, you will
have four options:
1. Leave funds in your employer's (former employer's) plan
2. Transfer funds to a new employer's retirement plan
3. Opt for a taxable distribution by cashing out
4. Roll the funds into an IRA rollover account
Some of the key considerations to determine are but not limited to:
1. Are there investment restrictions in your existing employer retirement plan
2. Are you provided with ongoing investment advice under the employer retirement
plan and if so, is this cost free
3. Are there any restrictions on income withdrawal options under the employer
retirement plan rules
4. Your existing employer retirement plan may have lower fees than those that would
be incurred following a rollover and ongoing management services
5. Your 401k is likely to be covered under the Employee Retirement Income Security
Act (ERISA)
Should you choose to roll over the assets to an IRA under our management, an asset-
based fee will be charged as outlined in Item 5. This practice introduces a conflict of
interest, as individuals providing investment advice on our behalf have an incentive to
recommend rollovers for the purpose of generating fee-based compensation.
Importantly, you are not contractually obligated to complete the rollover, and even if
you do, there is no obligation to have the assets managed by us.
Each option comes with its advantages and disadvantages as well as tax considerations,
which we strongly recommend clients to seek advice on prior to making any changes to
their existing scheme.
Portfolio Management Services
The Mass Group offers ongoing portfolio management services based on the individual
goals, objectives, time horizon, and risk tolerance of each client. The Mass Group creates
an Investment Policy Statement for each client, which outlines the client’s current
situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in
the selection of a portfolio that matches each client's specific situation. Portfolio
management services include, but are not limited to, the following:
• Investment strategy • Personal investment policy
• Asset allocation • Asset selection
• Risk tolerance • Regular portfolio monitoring
The Mass Group evaluates the current investments of each client with respect to their risk
tolerance levels and time horizon. Risk tolerance levels are documented in the Investment
Policy Statement, which is given to each client.
The Mass Group seeks to provide that investment decisions are made in accordance with
the fiduciary duties owed to its accounts and without consideration of The Mass Group’s
economic, investment or other financial interests. To meet its fiduciary obligations, The
Mass Group attempts to avoid, among other things, investment or trading practices that
systematically advantage or disadvantage certain client portfolios, and accordingly, The
Mass Group’s policy is to seek fair and equitable allocation of investment
opportunities/transactions among its clients to avoid favoring one client over another
over time. It is The Mass Group’s policy to allocate investment opportunities and
transactions it identifies as being appropriate and prudent among its clients on a fair and
equitable basis over time.
Financial Planning
Financial plans and financial planning may include, but are not limited to: investment
planning; life insurance; tax concerns; retirement planning; college planning; and
debt/credit planning.
Services Limited to Specific Types of Investments
The Mass Group generally limits its investment advice to mutual funds, fixed income
securities, insurance products including annuities, equities, ETFs (including ETFs in the
gold and precious metal sectors) and commodities. The Mass Group may use other
securities as well to help diversify a portfolio when applicable.
Written Acknowledgement of Fiduciary Status
When we provide investment advice to you regarding your retirement plan account or
individual retirement account, we are fiduciaries within the meaning of Title I of the
Employee Retirement Income Security Act and/or the Internal Revenue Code, as
applicable, which are laws governing retirement accounts. The way we make money
creates some conflicts with your interests, so we operate under a special rule that
requires us to act in your best interest and not put our interest ahead of yours. Under
this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations
(give prudent advice);
• Never put our financial interests ahead of yours when making recommendations
(give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in
your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.
C. Client Tailored Services and Client Imposed Restrictions
The Mass Group will tailor a program for each individual client. This will include an
interview session to get to know the client’s specific needs and requirements as well as a
plan that will be executed by The Mass Group on behalf of the client. We will assess their
overall wealth and other assets to determine how this impacts their capacity for loss need
to take on risk. We will also consider the type of other assets they hold, their liquidity and
their personal circumstances such as the number of dependents they have and their ages.
The Mass Group may use model allocations together with a specific set of
recommendations for each client based on their personal restrictions, needs, and targets.
Clients may impose restrictions in investing in certain securities or types of securities in
accordance with their values or beliefs. However, if the restrictions prevent The Mass
Group from properly servicing the client account, or if the restrictions would require The
Mass Group to deviate from its standard suite of services, The Mass Group reserves the
right to end the relationship.
D. Wrap Fee Programs
A wrap fee program is an investment program where the investor pays one stated fee that
includes management fees and transaction costs. The Mass Group does not participate in
wrap fee programs.
E. Assets Under Management
The Mass Group has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts: Date Calculated:
$0 $0 February 2024