Monthly Archives: March 2015

The Great MPF Ripoff: One Index Fund for the Price of Ten

Hong Kong’s MPF system forces everyone to save for their retirement. It also forces them to pay unnecessary fees to multiple layers of various middlemen who add little, if any, value.

Diagram of the Various MPF “Stakeholders” Who Collect Fees

ETF vs. MPF

If one buys the exchange-traded fund known as the Tracker Fund of Hong Kong (TraHK) directly off the stock exchange, one will only pay 0.1% per year in ongoing fees. It is the cheapest way to invest in the Hang Seng index.

However, if one invests in the Hang Seng index through an MPF scheme, one will pay up to eleven times more than necessary. This is surprising because most MPF schemes do nothing more than take one’s money and put it in the TraHK, something which many people are willing and capable of doing by themselves without any assistance from fee-collecting middlemen.

Below is a chart which lists all of the MPF funds that invest in the Hang Seng index. The cheapest MPF fund costs 0.69% per year. The most expensive fund is 1.08% per year. 

All of the funds invest in exactly the same stocks, so the differences in fees are a reflection of how efficient (or greedy) the scheme providers are.

Chart - MPF Hang Seng Tracker Funds

FER stands for Fund Expense Ratio. The funds at the bottom of the chart are relatively new, so data is not yet available for them. Info in the chart was obtained from MPFA’s Fee Comparative Platform on March 20, 2015.

HSBC has by far the most money invested in its MPF funds (multiples higher than its nearest competitor), which means HSBC should be able to utilize its economies of scale to offer the lowest fees. However, HSBC charges almost 40% more than the lowest-cost competitor. This indicates that HSBC may be managing its schemes poorly, or perhaps gouging its customers.

MPFA Caps Middleman Fees at Nosebleed Levels

Earlier this month, the MPFA announced a number of new reforms to the MPF system which are supposed to take effect in 2016. One of the purposes of the reforms is to bring down MPF fees.

Every MPF scheme provider will be required to introduce a “core fund” that uses a passive investing strategy, meaning that each core fund will operate like an index fund. The total ongoing fees will be capped at 1%, which is ten to twenty-five times more expensive than a good ETF index fund. (In the US, ETF fees are as low as 0.04%.)

The people at MPFA have suggested that a passively managed fund charging 1% per year is “good value”, raising questions about whether or not they are in touch with reality.

Core Fund FER Capped at 1 Percent (Circled)

Screenshot from MPFA’s June 2014 Consultation Paper, page 5

Although the new fee cap of 1% is allegedly intended to help bring down fees, it will in fact exert zero pressure on many scheme providers. The MPFA has published data showing that the average ongoing fees for MPF index funds is 0.98%—already below the new cap.

Average FER for Index Tracking Funds

Screenshot from MPFA’s June 2014 Consultation Paper, page 33

Without Providing a Rational Explanation, HK Government Protects Financial Interests of MPF Middlemen at the Expense of Ordinary Hong Kongers

When the Mandatory Provident Fund Schemes (Amendment) Bill 2014 was being discussed last year, a man named Peter Wong proposed giving Hong Kongers the legal right to invest their MPF contributions directly in fixed-term bank deposits, individual stocks, and the Tracker Fund of Hong Kong (TraHK) without the high-cost “help” of multiple layers of fee-collecting middlemen.

The government rejected Mr. Wong’s proposal, saying that the MPF middlemen were needed to “save scheme members from undue investment risks”.

In the case of TraHK, this claim makes no sense. Hong Kongers face the same investment risks whether or not they purchase TraHK directly or indirectly via a complicated MPF scheme.

The government also claimed that investing in TraHK via MPF middlemen was “more efficient and flexible” because it allowed Hong Kongers to avoid “small-amount transactions so as to lower the cost impact.”

It is true that upfront fees might be relatively high if one were investing only $1,500 HKD at a time (HSBC charges $50 HKD, which is roughly 3.3%), but if one wanted to transfer a year or more of MPF contributions, i.e. tens or hundreds of thousands of HK dollars, the upfront fee would be relatively low, just a small fraction of a percent.

More importantly, even if one paid a high upfront fee, it would still be far less costly than paying high annual fees for decades on end.

Peter Wong’s Proposal and the Government’s Response

Illustration of the Damage Caused by MPF’s High Ongoing Fees

Suppose one works for 40 years (from age 25 to 65) and invests $1,500 per month in an MPF Hang Seng index fund that costs 1% per year. One will be paying 0.9% more than is necessary, since a direct investment in TraHK costs only 0.1%. 

Due to compounding effects, high annual MPF fees will translate into unnecessary losses that are magnified more and more each year.

If the TraHK averages 6% returns per year, by the time one reaches the age of 65, the losses will amount to $490,316. This is nearly half a million dollars that a Hong Konger could and should be getting for his or her retirement.

The chart below summarizes the math:

Illustration of the Impact of High Ongoing MPF Fees

Numbers were calculated using a compound interest calculator on TheCaculatorSite.com

Stephen Vines, for South China Morning Post: “It is arguable that the whole scheme is nothing short of being a scandal.”

Yesterday, South China Morning Post published an article written by Stephen Vines, in which he suggested that the MPF system is “nothing short of being a scandal”.

He noted that fees are abnormally high and returns are abnormally low. He contacted an MPFA official to request an explanation for why investors aren’t being allowed to invest directly in ETF funds, such as TraHK, without paying fees to a smorgasbord of middlemen.

He said, “[I] received a response that left me none the wiser as it consisted of a muddled explanation of structures, difficulties of administration and lots of other bureaucratic stuff.”

Vines concluded, “Hong Kong investors can expect to continue being short changed, while in the rest of the world the enormous revolution in the fund management industry is seemingly unstoppable…MPF investors can only look on with envy.”

How to Complain to the MPFA

Ripped off Hong Kongers who want to keep more of their retirement money can complain to the MPF regulator by calling 2918 0102 or by sending an email to mpfa@mpfa.org.hk.

Hong Kong-Headquartered Financial Advice Groups Placed on Thailand’s Investor Alert List

Platinum and Infinity Logo (3)

Companies related to Platinum Financial Services Limited and Infinity Financial Solutions Limited have been placed on the Thai SEC Investor Alert List for unlicensed securities and derivatives business.

Section 289 of Thailand’s Securities and Exchange Act states that any person who undertakes securities business without a license “shall be liable to imprisonment for a term of two to five years and a fine from two hundred thousand baht to five hundred thousand baht and a further fine not exceeding ten thousand baht for every day during which the contravention continues.”

Platinum Financial Services

On Feb 4th this year, the Thai Securities and Exchange Commission (SEC) placed PFS International Consultants Limited on its Investor Alert List for “unlicensed securities and derivatives business”.

According to the SEC alert, PFS International Consultants Limited shares a web address with Platinum Financial Services Limited, a company which is licensed to sell insurance products in Hong Kong. The CEO of Platinum Financial Services Limited is Mark Kirkham.

Kirkham is a member of the general committee of the Hong Kong Confederation of Insurance Brokers, a self-regulatory organization which regulates Platinum Financial Services Limited.

The news about Platinum’s Thai company being placed on the SEC investor alert list was first published on Andrew Drummond’s website, in an article called, “Beware of Newspapers in Southeast Asia Offering Financial Advice“.

More recently, the news was also featured in the South China Morning Post in an article titled, “Hong Kong-linked company appears on Thai SEC alert list“.

Last year, the South China Morning Post also reported that a Platinum-related company was under scrutiny by the Hong Kong securities regulator (SFC) for dealing in securities without a license. The article was called, “Fallen Centaur fund linked to regulatory executive“.

According to Section 114 of the SFO, the maximum penalty for carrying on a business in an SFC-regulated activity without a license is “a fine of $5000000 and…imprisonment for 7 years and, in the case of a continuing offence, to a further fine of $100000 for every day during which the offence continues”.

Ex-clients of Platinum have shared their stories with the author of this blog.

Infinity Financial Solutions

On June 5th, 2012, a company called Infinity Marketing Solutions was placed on the Thai SEC Investor Alert list for carrying on unlicensed securities and derivatives business. The website of the company was listed as www.infinityfinancialsolutions.com.

Infinity Financial Solutions Limited is an insurance brokerage licensed to sell insurance products in Hong Kong. Infinity’s CEO is Trevor Keidan. The company’s new website, www.infinitysolutions.com, states that Keidan resides in Hong Kong.

Infinity was fined by the Hong Kong CIB last month for failure to “maintain…professional indemnity insurance at the required limit of indemnity”.

Ex-clients of Infinity have shared their stories with the author of this blog.

Investment-Linked Insurance Scammers Lure Victims to Macau after Regulators Ban Worst Practices in Hong Kong

The worst types of investment-linked assurance scams (ILAS) were banned in Hong Kong at the beginning of 2015.  Many observers have long speculated that scammers would find ways to circumvent the ban.

One Chinese language newspaper has finally confirmed that the scammers have succeeded:

According to insiders interviewed by The Sun, some unnamed insurers and corporate insurance brokers—with offices in both Hong Kong and Macau—have teamed up to lure unsuspecting victims to Macau, where regulators have not yet banned the corrupt practices and ripoff products which inspired the creation of this blog.

The scammers are specifically targeting mainland Chinese, baiting them with free plane and ferry tickets to Macau, where the victims can be fleeced with impunity. The Sun did not say whether Hong Kongers and local residents of Macau were also being targeted.

[Note: Macau is the “Las Vegas of Asia”, well-known for its casinos. It is just a one-hour ferry ride from Hong Kong.]

The Scammers Make Headlines in Macau

Two days after The Sun reported that mainlanders were being targeted, the Macau Business Daily ran an article titled, “Caution 101“, which is featured very prominently on the newspaper’s home page:

The article states, “Business Daily has approached the Monetary Authority of Macau and the Macau Insurers’ Association to verify the reported practice but had not received a reply by the time the story went to press.”

Media inquiries and headlines such as the one above are no doubt putting pressure on Macau’s regulators to bring the city’s regulations in line with Hong Kong’s.

Hong Kong is currently under pressure to bring its regulations in line with the UK’s.

Who Are the Unnamed Scammers?

The latest reports didn’t say which insurers and corporate insurance brokers were targeting mainlanders, but one of them is likely Convoy. According to Convoy’s 2014 Interim Report, it had 17 brokers in Macau, and its business was growing:

Convoy - Ramping Up Activity in Macau

According to the Monetary Authority of Macau’s website, there are only four corporate insurance brokers authorized to sell ILAS in Macau (see red circles):

One of the four corporate brokers is Sun Hung Kai. A couple of years ago, an ILAS victim told the author of this blog that Sun Hung Kai was heavily promoting Zurich Vista (a very notorious ILAS) and promising so many “free” fund units that it would offset losses incurred by surrendering existing ILAS policies to pay for a new Vista policy.

According to MAM’s website, there are eleven life insurers authorized to do business in Macau:

Below are the provisional 2014 Macau life insurance business statistics for January to September, showing which insurers did the most life insurance business (though not necessarily the most ILAS business):

The top 6 insurers, in terms of gross premiums, are:

  1. China Life
  2. AIA
  3. MassMutual
  4. AXA
  5. FWD
  6. Manulife

It’s not clear which of the above insurers have teamed up with brokers to sell ripoff ILAS products in Macau, but it is certainly not just one of them.

Obama Administration Makes Strong Case for Outlawing “Backdoor Payments” to Financial Advisers

On February 23, US President Barack Obama announced:

“Today, I’m calling on the Department of Labor to update the rules and requirements that retirement advisors put the best interests of their clients above their own financial interests. It’s a very simple principle: You want to give financial advice, you’ve got to put your client’s interests first.  You can’t have a conflict of interest.

Department of Labor officials have denied that commissions will be banned, but Obama’s choice of words (“you can’t have a conflict of interest”) suggests the opposite. The first draft of the new rules will be released in a few months.

Explaining the motivations behind the reforms, Obama cited some very disturbing statistics and academic studies. He also gave a powerful moral argument. Referring to the practice of some fund managers and insurance companies using secret “backdoor payments” to induce financial advisers to recommend their inferior products, he said, “It offends our basic values of honesty and fair play.”

Council of Economic Advisers Publishes a Must-Read Report

On the same day that Obama gave his speech, the White House Council of Economic Advisers (CEA) issued a report, titled, The Effects of Conflicted Investment Advice on Retirement Savings.

The report surveys the academic literature on the topic of conflicted investment advice. The research overwhelming concludes that commissions have a serious corrupting influence on financial advisers and a colossal negative impact on the retirement savings of Americans. The CEA estimates that investors are being bilked out of tens of billions of dollars every year—just in retirement accounts alone.

CEA Debunks the Investment Industry’s Insidious Propaganda

In defense of its deceptive practices, the investment industry never tires of repeating the same ludicrous, self-serving arguments, many of which have no factual or logical basis.

The CEA debunked some of these arguments in its report:

“Some observers have asserted that advising structures using conflicted payments are the only way that savers with lower balances can obtain advice and that without such advice the adequacy of their retirement savings would suffer. This argument, however, falls short in multiple ways and overlooks channels that could provide high-quality, conflict-free advice to moderate-income savers at the same cost as conflicted advising structures.

First, advisers can provide the same quality of advice while receiving non-conflict-based payments as they can when receiving a payment of equal amount based in conflict. The cost of advice depends primarily on the resources necessary to provide it—the adviser’s time, IT infrastructure, and other inputs—rather than the form of the adviser’s compensation. Thus, an adviser receiving payment through non-conflicted structures should be able to provide advice at the same cost as an adviser receiving conflicted payments, as long as the inputs in time and infrastructure are equal. If advisers serving moderate-income Americans can remain profitable regardless of whether they receive conflicted or non-conflicted compensation, one would expect the number of advisers working with lower-balance savers to remain the same regardless of whether conflict-based payment systems remain in use. 

Second, the prevalence of conflicted payments today may actually interfere with low-balance savers’ ability to get advice. Ongoing developments in the financial industry are sharply reducing the cost of advice, but it may be difficult for new entrants providing quality, unconflicted, low-cost advice to compete on price when other advice erroneously appears to be free. Therefore the prevalence of hidden fees and conflicted payments may make it more difficult for low-cost, high-quality alternatives to compete on a level playing field, reducing moderate-income Americans’ available options for inexpensive advice. As just one example, new approaches to advice that exploit technological advances are allowing firms to offer personalized advice at costs well below those of traditional advice.

Finally, savers with modest balances today tend to become savers with larger balances tomorrow. According to the Employee Benefit Research Institute, more than 60 percent of IRA contributors in 2010 contributed in at least one of the next two years and nearly 40 percent contributed in every year from 2010 to 2012 (Copeland 2014). A significant motivator for the services provided to low-balance customers today is likely their potential to become higher balance customers in the future. Financial advisers have strong incentives to work with lower-balance savers regardless of whether using conflicted or non-conflicted payment structures.”

CEA Finds that Mandatory Disclosure of Conflicted Payments Is, by Itself, an Inadequate Solution

Although transparency is desperately needed in the investment industry, the CEA cites academic research that suggests transparency often “backfires” in the case of conflicted payments, resulting in weaker consumer protections and less ethical behavior on the part of financial advisers:

Mandatory Disclosure Is Not a Solution

CEA Concludes Its Report by Highlighting the UK and Australia’s Ban on Conflicted Payments, Implying that this Is the Best Way Forward

After arguing that disclosure of conflicted payments would not effectively reduce exploitation of investors, the CEA introduced some better ideas. The CEA specifically mentioned the United Kingdom and Australia’s ban on conflicted payments:

International Policy Changes to Mitigate Conflicted Advice

US Department of Labor Says, “We Can Fix This”

On Feb. 23, the same day as Obama’s speech, the US Department of Labor released the below video, which summarizes the problem of conflicted investment advice. The video concludes by saying, “We can fix this.”

Coalition of Consumer Groups Petition US Government to End Legalized Corruption on Wall Street

Several organizations, such as the Americans for Financial Reform, the Pension Rights Center, and the Consumer Federation of America, have joined together to support the new reforms being proposed by the Obama administration. The organizations have set up a website, SaveOurRetirement.com, and have created a petition which can be signed HERE.

Petitioning US Government

US Initiative Will Inspire More Countries to Follow

The United States is the most influential country in the world when it comes to finance. If the US implements significant regulatory reforms—such as a ban on conflicted payments—it will put increased pressure on other countries to follow.

Obama’s latest speech and the White House CEA report are undoubtedly already having international influence, simply by raising awareness of the enormous harm caused by conflicted investment advice and the urgent need for reform.

Useful Links

Obama’s Speech on C-SPAN (with Transcript)
http://www.c-span.org/video/?324512-3/president-obama-remarks-aarp

Council of Economic Advisers: Report on the Effects of Conflicted Investment Advice
http://www.whitehouse.gov/sites/default/files/docs/cea_coi_report_final.pdf

US Department of Labor: Protect Your Savings
http://www.dol.gov/featured/protectyoursavings/

US Department of Labor: FAQ on the New Rules
http://www.dol.gov/featured/ProtectYourSavings/faqs.htm

US Consumer Groups for Financial Reform
http://saveourretirement.com/

Petition: Tell Washington to Stand Up to Wall Street
https://www.change.org/p/united-states-congress-tell-washington-to-stand-up-to-wall-street

Post-Implementation Review of the United Kingdom’s Ban on Conflicted Payments (1)
http://www.fca.org.uk/your-fca/documents/post-implementation-review-of-the-retail-distribution-review-phase-1

Post-Implementation Review of the United Kingdom’s Ban on Conflicted Payments (2)
http://www.fca.org.uk/your-fca/documents/research/rdr-post-implementation-review-europe-economics

Information about Australia’s Ban on Conflicted Payments
http://asic.gov.au/regulatory-resources/financial-services/future-of-financial-advice-reforms/

LM Sales Manager, Martin Venier, Reappears with Self-Promotional Website

Martin Venier Profile PhotoIf LM victims were wondering what happened to LM’s Hong Kong sales manager, Martin Venier, they now have an answer.

He recently set up a website, MartinVenier.org, through which he is promoting himself and the financial services of an alleged group of scientific, mathematical, and economic experts.

The alleged group calls itself “Portfolio Resilience Investor Analytical Services (PRIAS)”. A search for the group on the internet retrieves no results, except for Venier’s website.

Portfolio Resilience Investor Analytical Services

One of the services offered by PRIAS is described as “Curation Filtering”. A search for “curation filtering” suggests that the phrase was invented by Venier and his colleagues. Its meaning is unclear.

Note that the words “curation” and “filtering” are synonyms, so joining them together is redundant—a bit like combining the words “bamboozle” and “swindling”.

Self Managed Hedge Fund

Listed under “Curation Filtering” is a service called the “Self-Managed Hedge Fund (SMHF)”.

Unlike “Curation Filtering”, a search for “Self-Managed Hedge Fund” does retrieve results.

One of those results is the “First Meetup for Cybertraders Anonymous“, which took place in Sydney Australia on July 25, 2013 and was organized by a guy named Kingsley Jones.

At the meeting, Jones said he would be giving a presentation on the Self-Managed Hedge Fund, and he’d reveal how to become George Soros “in your bedroom”.

Kingsley J - Become Mr Soros in your bedroom

Six months ago, Jones announced on Twitter that the SMHF had been launched:

Self-Managed Hedge Fund is Here - 27 Aug 2014

On his blog, Martin Venier claims he is in Australia (and very busy with clients), so it’s possible that he is collaborating with Jones, helping to promote the SMHF, aiming to get obscenely rich from his bedroom.

[Note: About six months ago, Venier appeared to be a member of an Australian bitcoin group. This info was obtained from a link which has since been deleted. Several bitcoin scams have recently been in the news.]

The Big Investment Lie

Michael Edesess, author of The Big Investment Lie: What Your Financial Adviser Doesn’t Want You to Know, is scathingly critical of financial advisers and fund managers. He argues that most of them collect unjustifiably high fees for doing little more than ripping off investors.

Given that Edesess’ criticisms are aimed precisely at people like Venier and the others who were involved with the LM scam, it is surprising that Venier published an article written by Edesess on his website:

Edesess Photo on Venier's Website

Photo is of Michael Edesess. He was recently a visiting fellow at City University of Hong Kong. He also wrote a handful of articles for South China Morning Post.

One of Edesess’ quotes perfectly describe the LM debacle:

Corrupt Financial Advisory Services

Another of Edesess’ quotes aptly describe the mumbo jumbo (e.g., “curation filtering”) which Venier’s PRIAS group uses to describe its services:

Complicated-Sounding Products

At first, I assumed that Venier had published Edesess’ article without Edesess’ permission, so I contacted Edesess to warn him.

Stunningly, Edesess confirmed that he had known Venier for years and had given him permission to publish the article.

Even more surprisingly, Edesess told me that he did not believe that Venier was knowingly involved in any fraudulent activity when he worked at LM. He said the LM situation was “complicated”, and he did not believe that Venier should be held responsible.

However, after receiving my email, Edesess contacted Venier and asked him to remove the article from his website, which Venier has now done.

Edesess told me he “did not have time to deal with the matter”, presumably meaning that he did not want to be perceived as connected in any way with LM. He says he is currently working on a start-up in the United States.

Is Venier Innocent or Was Edesess Duped?

Readers of Martyn Terpilowski’s LM Emails will recall that, in late 2011, as Terpilowski was desperately trying to get his clients’ money out of the MPF, Venier made statements which suggested that the fund was operating like a Ponzi scheme. Specifically, Venier suggested that old investors were being paid back with new investors’ money, rather than with profits earned from investments.

When Terpilowski pointed this out to Venier, and when he pointed out that it was unethical (if not illegal) to continue promoting a fund in which existing investors were locked in against their will, Venier just dodged the issues, never giving a satisfactory response.

This was nearly one and half years before LM went up in smoke.

Martin Venier’s Cognitive Dissonance

In a couple of sections on his website, Venier talks about the psychological phenomena of “cognitive dissonance” and “confirmation bias”. Although he does not explicitly say it, it is easy to imagine that Venier is describing his own experiences at LM, particularly his experiences interacting with Martyn Terpilowski:

Martin Venier's Cognitive Dissonance, Internal Pain, and Physical Tension 

Venier no doubt had “uncomfortable feelings” when hearing Terpilowski call the MPF a Ponzi scheme and a fraud. This may have led Venier to seek information which confirmed the views (the LM sales pitch) which he was paid to believe and disseminate.

Venier claims that he created his new website “to prevent us from becoming victims of groupthink”. He seems to believe that he is uniquely qualified to perform this service, perhaps due to his firsthand experience.

Why 'We' Exist (underlined in red)

Notice the paragraph underlined in red. It seems as if Venier is subconsciously warning readers to carefully consider his former role at LM (i.e., the context shaping his current thoughts and actions) before assessing the information and services on his website.

Venier Continues to Criticize Everyone But Himself

After LM collapsed, Venier and Terpilowski had a very heated email exchange, in which Venier insulted Terpilowski, accused him of throwing his clients under the bus in order to cash in on LM’s excessive commissions (when the opposite was true), and he threatened to call the police. Venier never apologized for being wrong or for his role in helping LM defraud thousands of investors (whether wittingly or unwittingly).

Now, on his new website, Venier continues to construe himself as being totally innocent, while simultaneously casting blame on everyone else. He even describes himself as an “advocate for investors”.

Venier specifically blames fund managers (presumably Peter Drake), financial advisers, and investors for having “unrealistic expectations” that the MPF could “generate liquidity and capital stability simultaneously.” He says it was “a task all properly trained financial market practitioners understand is not achievable.”

Presumably, Venier views himself as “a properly trained financial market practitioner” who never had “unrealistic expectations” for the MPF. If that is true, it raises the question: Why didn’t he blow the whistle on Peter Drake and the so-called financial advisers, rather than continue facilitating the fraudulent marketing of the LM MPF to inexperienced retail investors?

Venier maintains he was innocent, but his commentary suggests that he was complicit.

Venier heaps blame on financial advisers for not disclosing the excessive commissions which LM paid, yet Venier is silent on whether LM did anything wrong by paying excessive commissions to incentive financial advisers to distribute a fund which Venier admits was doomed to fail.

Venier additionally criticizes financial advisers for being ignorant, lacking “real market experience”, having “poor formal training”, and promoting the MPF using false or misleading information. (Note that Venier admits to training these advisers, so maybe he should take some responsibility.)

Venier also blames some investors for “lacking savings” (i.e., investing aggressively in MPF’s promise of high and safe returns in order to make up for their lack of savings), which implies that Venier knew the MPF was being illegally/improperly sold to retail investors (i.e., those investors with less than $1 million USD in savings and no professional investing experience).

Below are two screenshots of Venier’s self-written biography on his website. The first screenshot is the original version. The second screenshot shows a paragraph about LM which Venier recently revised. Notice that Venier never actually says he worked for “LM”. Instead, he says he worked for “a fund manager with Australian property assets”.

Original Version

Who Is Martin Venier (Underlined)

Red underlining and comments were added for emphasis.

Revised Section on LM

Venier's Revised Bio (LM Section)

Illegal Activity?

Venier recently removed the content from the “Services” section of his website. It once openly promoted services including: Portfolio Resilience Investor Analytical Services, Curation Filtering, and the Self-Managed Hedge Fund.

The website now says it is not promoting anything:

Services Suddenly Restricted to Members Only

It’s unclear why Venier made the changes, but perhaps he was afraid of being reported to the SFC for violating Section 103 of Hong Kong’s Securities and Futures Ordinance (issuing unauthorized investment advertisements to the Hong Kong public), which is a criminal offense.

A screenshot of all his original service offerings is here:

Martin Venier's Services

Interestingly, the “Contact” page of Venier’s website shows that the PRIAS group is currently doing business in a region which appears to be Hong Kong (see the purple dots):

Current PRIAS Consulting Client Locations Screenshot

A search on the SFC’s website indicates that the PRIAS group is not licensed to do business in Hong Kong. Carrying on a business in an SFC-regulated activity without an SFC license is a criminal offense (see SFO Section 114).

Further Reading

The LM Emails (#7): New Sales Manager, Martin Venier, Implied that LM Was Operating Like a Ponzi Scheme

The LM Emails (#10): When Asked If LM Gave Special Treatment to Bond Investors, Martin Venier Dodged the Question

The LM Emails (#13): When LM Collapsed, Salesman Martin Venier Offered No Apologies—Only Insults and Threats