The client requested legal advisory regarding the implementation of a Model Portfolio services in Peruvian territory. This service consists in non-personalized investment models provided periodically to clients, which contain investment strategies with ideal allocations to specific funds that may not be locally registered, cross-listed or cross-registered in the local market.
In this particular case the client requested legal advice if the scenario when this service would be outsourced to Peruvian brokers dealers. We helped the client to put in practice this new service providing the recommendations and the specific disclaimers to be used in the documents in order to not trigger any licensing requirement not only in the interaction with local investors but also before the broker dealer that the client would celebrate an agreement with.
We provided specific details on how Blackrock and the broker dealer should behave in order to not contravene any local regulation.
