Open letter to iCapital.biz Berhad

Below is a open letter from Tan Tuan Phin who contacted me and asked me to publish the below letter. I hope many people can attend the AGM and vote according to their opinion, and possibly voice their concerns (if any). 

To ICAPITAL.BIZ Berhad,

Being a shareholder which owns 274,300 shares not including the shareholdings of my close family members, I wish to voice out my concerns regarding about the recent performance of ICAPITAL.BIZ BERHAD and wish it can be discussed in the Q&A session in the coming AGM on 24 September 2016.

Sadly I am not able to attend the AGM due to another appointment on 24 September 2016.

You may refer to my enquiries to ICAPITAL.BIZ Berhad as follows:

1)      Relative Poor Performance of the Fund from 2011 to 2016

ICAPITAL.BIZ Berhad		2016	2015	2014	2013	2012	2011
Cash Level		303,481,263	257,951,378	240,390,544	208,005,028	133,735,511	115,907,950
Investment		126,022,371	145,596,798	185,731,507	209,700,211	262,657,722	270,506,528
Total Valuation		429,503,634	403,548,176	426,122,051	417,705,239	396,393,233	386,414,478
% Cash VS Total Valuation		71%	64%	56%	50%	34%	30%

Based on the figures extracted from the annual report, the Compounding Annual Growth Rate of total investment plus cash and cash equivalents since year 2011 to 2016 is performed poorly at a CAGR of 1.78% per annum which is almost equivalent to non-performance at all or in another terms, basically wasted 6 years opportunity to grow the fund for the benefit of shareholders. Not every shareholders have a lot of 6 years to wait.

Kindly address and explain why has the fund performed so poorly for the past 6 years.

2)      Increased Management and Advisory Fees

ICAPITAL.BIZ Berhad	2016	2015	2014	2013	2012	2011
Management & Advisory fee	6,150,684	6,374,708	6,218,982	6,179,782	5,789,726	5,105,346

The management & advisory fee has been increasing at an annual compounding rate of 3.15%, while the performance of the investment fund is only growth at CAGR of 1.78% as highlight in my question No. 1. The growth rate of management and advisory fee is not in-line with the growth of the fund, while the growth pace of management & advisory fee is getting higher than the fund’s performance. (CAGR of Management & Advisory Fee = 3.15% > CAGR of Cash plus Investment = 1.78%)

Kindly address and explain why the CAGR of the increase in Management & Advisory Fee is higher and comparatively faster than the CAGR growth of the Cash plus Investment of ICAPITAL.BIZ Berhad.

3)      Increased in Impairment Loss on Investment

ICAPITAL.BIZ Berhad	2016	2015	2014	2013	2012	2011
Impairment loss	12,506,585	2,392,124	513,988	-	-	-

The impairment loss of the fund’s investment has been on an increasing trend. Especially for Boustead Holdings Berhad which is currently sit at an unrealised loss of RM2,177,080 and yet to be impaired.

a)      What is the rationale for not impairing the remaining RM2,177,080 of Boustead Holdings Berhad although almost similar amount (RM2,392,124) has being impaired for Malaysia Smelting Corporation Berhad? Does this practice comply with the Malaysian Financial Reporting Standards?

b)      The Fund has great opportunity to sell both Boustead Holdings Berhad and Parkson Holdings Berhad during year 2011 where both companies’ share were valued at peak of RM40,073,148 and RM54,901,782, however, the opportunity was not properly seize by the management and resulting in significant losses after 5 years.

Did the management of ICAPITAL.BIZ Berhad constantly followed up on the companies in their portfolio such as regular company visit or meeting with their management?

What are the policies and steps to be taken by the management to avoid making such wrong decision in future?

4)      Comparison of ICAPITAL.BIZ Berhad vs Berkshire Hathaway

As at 31 July Each Year	2016	2015	2014	2013	2012	2011
Berkshire Hathaway ($)	216,000	214,000	188,124	173,900	127,445	111,500
ICAPITAL.BIZ Berhad (RM)	2.29	2.28	2.46	2.40	2.24	2.16

After peruse through several years of ICAPITAL.BIZ Berhad’s annual report, I noticed that the management loves to compare the Fund’s performance against Berkshire Hathaway since both funds are closed-end fund.

The table above clearly explains the significant gap in performance of the both fund. If a person invested in both fund respectively, the CAGR of Berkshire Hathaway’s Share is 11.65% compared against the relative sluggish performance of ICAPITAL.BIZ Berhad’s 0.98% from year 2011 to 2016.

Which means ICAPITAL.BIZ Berhad has not performed at all for the past 6 years. This lead us back to the justification whether the management and advisory fees are commensurate for the poor performance of ICAPITAL.Biz Berhad.

Kindly address this issue and advise the management next course of action in order to improve in the Fund’s performance or reduce the management and advisory fees that reflects the actual performance of the fund.

Does the directors of ICAPITAL.BIZ Berhad review the fund manager performance in a periodic basis? What is the directors’ yardstick on the measurement of fund manager’s performance?

Or in a much serious scenario, if the fund still perform poorly in the coming years, have the board ever consider replace the fund manager or liquidate the fund that will give a higher return for the benefit of shareholders?

Regards,

A Very Concerned Shareholder

Tan Tuan Phin

iCapital: "Ostrich policy" will not solve the issues (4)

City of London has sent the following letter to the Board of Directors of iCapital:


Clients of City of London Investment Management Limited (CLIM) own 21,970,900 ICAP shares (15.7%). There has been no action in response to any of the points that were raised in our letter to you dated 26^th August 2015, which set out our concerns regarding ICAP's poor performance and persistently wide discount to NAV.  CLIM therefore confirms that it intends to continue voting against the re-election of incumbent directors. Accordingly, CLIM intends to vote against the re-election of Madam Leong So Seh at ICAP's 12^th AGM on Saturday, 24^th September 2016.

·     Performance

We reiterate our call for performance comparisons in shareholder communications to be made on a total return basis, which is universally accepted in the investment industry as best practice.

The total return in the five years to end May 2016 for the FTSE Bursa Malaysia Index has been 23.1% cumulative (equivalent to 4.2% pa). In comparison ICAP's NAV return has been 13.0% cumulative (2.5% pa). The share price return over this period has been even worse due to discount widening, at 6.4% cumulative (1.3% pa). These performance figures have been sourced from Bloomberg.

The Chairman stated, in his letter to shareholders, dated 19^th July 2016, that ICAP has 'performed beyond expectations'.  We wish to make clear that ICAP's performance over the past five years has fallen significantly short of our own expectations.

·     Cash Management

We note the continued extraordinarily high cash level, which has persisted at over 50% for 3 years and on which shareholders have been paying fees for fund management and investment research services. Cash at each calendar year end since ICAP was launched (31 December 2005 to 31 December 2015) has averaged 39%. ICAP is clearly operating with surplus cash which, in our opinion should be returned to shareholders.

·     Expense Ratio

ICAP's expense ratio in 2016 was 1.9% (2015: 1.9%) which compares unfavourably with other country specific closed-end funds. The most significant item is the aggregate 1.5% incurred for fund management and investment research. CLIM urges the Board to negotiate competitive fees in order to reduce the expense ratio to an acceptable level.

·     Discount Control

ICAP's prospectus dated 26 September 2005 explained clearly that the return for closed-end fund investors is a product of NAV performance and the discount movement. The Chairman's letter to Shareholders in the 2016 Annual Report refers to a 4% rise in ICAP's NAV for the 12 months ended 31 May 2016. However it does not mention that the share price actually declined over this period, because the discount widened. The discount averaged 22% in 2016 versus 20% in 2015 (source: Bloomberg). Neither the level nor the trend is acceptable and CLIM is disappointed that the Board has again failed to take any action to address this problem.

CLIM notes from the 2016 Annual Report the Board's deliberations on 27^th July 2015 regarding share buy-backs and the accompanying statement that the "Fund's NAV could deteriorate if it uses its available fund to purchase own shares". Repurchasing shares at a discount to NAV will actually increase the NAV per share and in CLIM's opinion this would be a sensible use of ICAP's cash, particularly in view of the Manager's apparent shortage of investment ideas.

ICAP's prospectus included a section (6.7, page 64) on managing discounts, noting that the options available include 'share repurchase, open-ending, takeover, liquidation'. CLIM urges the Board to consider all these options and to formulate a strategy to reduce the discount from its present unacceptable level.

MSWG announced it will raise certain issues at iCapital's AGM, for instance regarding the "other expenses" and the impairment loss. I hope they also support the above issues as described by City of London.

iCapital: "Ostrich policy" will not solve the issues (3)

Last year I wrote two articles about iCapital's annual report, here and here.

iCapital published its new 2016 annual report, and I am sorry to say, it is even worse.

This time there is no mentioning at all of the large discount of the share price versus its NAV price, which is a rather common problem of Closed End Funds (CEFs) and also to shareholders of iCapital.

The last quoted NAV is RM 3.13, its share price is RM 2.34 for a rather large discount of 25%.

Also, again there is no proper reporting how iCapital performed the last 3 or 5 years, something that is completely standard for unit trust funds.

Interestingly, there might be hope for shareholders of iCapital. Bursa has published a "Proposed review of the framework for collective investments schemes", which includes CEFs.

Feedback can be given until September 19, 2016.

Hopefully next year iCapital will be forced to give a much more comprehensive account of its performance and other matters according to the new Bursa framework.

Strange that it had to come to this, surely iCapital as a licensed fundmanager with a long history should have revealed all the extra information on a voluntarily basis. And if it didn't, then the Board of Directors should have stepped in. Both the fundmanager and the Board of Directors must have known about the proposed framework and the additional information that would be requested.

iCapital: "Ostrich policy" will not solve the issues (2)

In addition to my previous posting on this subject, "Kian Wei" has reposted it in his category "Good articles to share" on i3investor.com. Both postings received quite a few comments by readers.

"Wilson Tan" has published this link on the Facebook page of Capital Dynamics, on which the company reacted:

The reaction seems rather strange, although less so in the Malaysian context where "shooting the messenger" seems to be the national pastime (anyone following the recent Malaysian scandals will agree with that, I guess).

What does it matter who I am, how many shares I have, when I bought them, at what price and at what exchange rate? People must first give a detailed description of this before they can raise an issue?

Regarding who I am, I have a profile on my blog. I am writing this blog because I am passionate about corporate governance issues in the Malaysian context. I don't make any profit whatsoever on it. There is also no hidden agenda, I write how I see things.

Regarding most companies that I write about I don't have a position, in iCapital I do however, which I announced. I own 200,000 shares of iCapital.biz (I guess Capital Dynamics could even have checked that themselves), some family members and friends have smaller positions, some sold them because of the disappointing results in the last years.

Does the above information change any of the issues raised in my posting? I don't think so. What matters is the issues itself.

But not a single answer is given about these issues, despite the claim that all of my postings about iCapital are "slanted and biased" according to Capital Dynamics. One would have guessed that it would be easy to give some examples of that, or at least a hint.

Another rather disturbing comment by Capital Dynamics, again in the "shoot the messenger" category:


"Dear Wilson Tan, according to the industry in London, City of London uses a "whispering campaign" tactic on funds that they attacked. They use social media, traditional media, etc and not disclose their hidden agenda."


There might be some suggestion that I am connected to City of London. Just to be clear, I don't know City of London (or Laxey for that matter), have never contacted them, met them or corresponded with them in any way, shape or form.

City of London has published a letter on August 28, 2015 which can be found here.

Some snippets:


CLIM [City of London Investment Management Limited] is opposing the re-election of incumbent directors because of the Board's inadequate response to ICAP's poor performance and persistently wide discount to NAV.

ICAP's total return NAV performance in the five year period 2 June 2010 to 29 May 2015 is +43.8%. This appears respectable compared to the capital only FBMKLCI +35.6% but it is profoundly disappointing compared to the FBMKLCI total return +60.4% (source: Bloomberg). Shareholders are given no explanation of this poor result from stock selection over this longer period.

The five year index total return referenced above, equivalent to a satisfactory 10% pa, indicates that shareholders would have benefitted overall from a fully invested strategy. ICAP's high cash holding throughout this 5 year period suggests a lack of skill in respect of market timing and a limited ability to identify undervalued assets. In these circumstances it is questionable whether ICAP should be incurring fees on cash.

ICAP's expense ratio in 2015 was 1.9% (total expenses as a percentage of the average of opening and closing shareholders' equity) which compares unfavourably with other country specific closed-end funds. In view of ICAP's poor NAV performance it is also pertinent to compare total expense ratios less than 0.5% pa for exchange traded funds that give investors Malaysian equity exposure. Boards have a duty, in CLIM's opinion, to negotiate competitive fees.

ICAP's original prospectus explained clearly that the return for closed-end fund investors is a product of NAV performance and the discount movement. The 2015 Annual Report does not refer to the impact on shareholders' overall return of the discount, which widened over the 12 months ended 31 May 2015 to 21% from 17%, and averaged 20%. Over five years to end May 2015 the discount has also averaged over 20% (source: Bloomberg).  The Board has failed to take any action to address the discount which has, in our opinion, been unacceptably wide. CLIM notes that ICAP's prospectus included a narrative on the tools available to Boards to narrow or eliminate the discount, including share repurchase, open-ending and liquidation. This section in the prospectus also referred to the possible replacement of existing management.

We are dismayed by the reference in the Chairman's 2015 Letter to  Share Owners, to 'investors with shorter-term focus to start requesting our Fund to look into other shorter-term options which do not benefit share owners in the longer-term'. ICAP's performance has been disappointing over the past five years and CLIM regrets the Board's unwillingness to engage with its shareholders to explore possible solutions to this problem. 

 

For the avoidance of doubt, in respect of its investment in ICAP, CLIM is not and never has acted in association with any other ICAP shareholder. CLIM is a long term investor in closed-end funds and first purchased ICAP shares in May 2010. In the interests of full transparency this letter is being made public.

In "digitaledge weekly" of September 14, 2015 (pages 18 and 30) a long article on the same subject:

"icapital.biz largest shareholder says fund fees high, to vote down director appointments"

It is noted that "Advertising, AGM and 'other' expenses have been rising at ICAP".

And "shareholders might want to ask how the fund's spending compares to what its manager spends on the same effort and how the spending fits the closed-end fund's goal".

Will we finally get proper answers regarding the issues raised?

iCapital: "Ostrich policy" will not solve the issues

I have written several times about iCapital (of which I am a long time shareholder), most notably here and here.

The two elephants in the room regarding iCapital's share performance are:

• Persistent underperformance relative to its benchmark (KLCI) since 2008
• Persistent discount to its NAV price since 2008

The new year report has been published, so I was interested to see how the company handles both matters. Well, the way the issues are handled is best described by the below picture:

"Underperformance, discount ...... I don't see any ...... do you?"

In the Netherlands this is called "Ostrich Policy": "to ignore obvious dangers or problems and pretend they don't exist; the expression derives from the supposed habit of ostriches to stick their head in the sand rather than face danger".

Lets start with the results for the latest year:

That is really disappointing, given that the funds cash level was a whopping 65% throughout the year. That cash is generating interest of about 3 per cent a year, so one would have thought that the fund would have performed clearly better than the KLCI.

One reason for this is the management fee (including relatively high expenses for advertisements and AGM), the total is about RM 7 Million. That translates to about 1.75% per year, which is not a problem if the fund is fully invested and outperforms. But it is a problem if 2/3rd is held in cash, earning about 3% per year on that cash, of which more than half is eaten away by fees and expenses.

Given the persistent high cash level, the board of directors should renegotiate the management fee, for instance a lower fee for the cash it is holding (one does not need a degree in rocket science to manage a fixed deposit), and a higher fee for the equity part. However, no indication is found in the year report that this is even considered.

All the outperformance of the fund came in the first few years. The last seven and a half years the fund has underperformed, especially if dividends are accounted for. The combined effects of the underperformance and discount is shown in the red column, showing that the share price has actually decreased since December 31, 2007.

One must therefore put question marks behind the comment by the Chairman:

Also puzzling is the comment regarding "shorter-term options which do not benefit share owners in the longer-term", how is it possible that company decides this for its share holders?

On December 31, 2013 the NAV was around RM 3.10 while the share price was around RM 2.47 for a discount of around 20%. Apparently the fund manager could not find enough value and decided to raise cash levels to 50%. If the fund had decided to discontinue and return back the money to shareholders, surely share holders would have been in a much better situation than currently (the share price is now RM 2.18).

iCapital continues to harp on its performance since its IPO. But which percentage of the shares is actually still held by the same persons who bought them at the IPO? If people bought their shares say 1, 3 or 5 years ago, would they not be interested in the performance over that period, instead of the performance since IPO? The performance over those intervals are simply disappointing.

Another puzzling comment is the following:

There is absolutely no need to seek for viable options to address the discount, they have been conveniently listed in iCapitals IPO brochure, as described in my previous posting:

• Shareholder activism: this is very ironic, given the way the fund and its manager have responded so far on any attempts in this direction (for instance here)
• Share repurchase: in my opinion an excellent way to decrease the discount
• Open ending
• Takeover
• Liquidation: again an excellent way to get away of the discount; after this the investors can decide themselves where they want to invest in
• Managed distribution policy

Another issue is that there seems to be an "obsession" with Warren Buffett and Berkshire Hathaway. Rather surprisingly, since Berkshire Hathaway is a US based fund (and thus accounted in USD, a currency that has performed very strongly relative to all currencies including the RM), investing a lot of money in non-listed companies, and only being interested in large acquisitions while iCapital is focused on Malaysian listed companies (which might include small caps, given its small size).

In other words, if there was ever a comparison between apples and oranges, this would be it.

Another rather interesting issue is that Warren Buffett and Charlie Munger each only charge USD 100K per year in wages, versus USD 1.5 Million (RM 6.4 Million) charged by the fund manager of iCapital, despite Berkshire Hathaway having a market cap of more than a thousand times the market cap of iCapital.

I have no idea where iCapital got these charts from, but they must be completely wrong. One of the best investors in the world has an annual compound return on its NAV of -0.39% over the last ten years?

The reality is very different according to the last year report, despite its huge size it actually was able to book very decent increases in its book value:

Another matter is that Berkshire Hathaway announced the following:

In other words, it might be better to look at the market value of Berkshires shares instead of the (understated, conservative) NAV.


[1] What iCapital should have done (instead of focus on Berkshire Hathaway) is give a clear and correct (that is based on dividends reinvested, it is not giving those at the moment) comparison of iCapitals performance versus similar funds, like the Malaysian ETF or Malaysian equity based unit trusts of reputable fund managers over the last 10, 5, 3 and 1 year periods. That would be comparing apples with apples.

[2] Next to that it should have openly discussed the persistent discount to its NAV, and why it has not taken any of the six measures as described in its IPO brochure. Those measures were listed there for a good reason, to assure potential investors that if there is a persistent discount, then there are measures (and implicitly: those measures will be taken).

[3] And lastly, it should have openly discussed the expenses and fees, which have been simply too rich in the last years given the high cash levels.


I used to have a lot of sympathy for iCapital and its founder Tan Teng Boo, they have been good for Bursa in areas of educating Malaysian investors. But that sympathy is decreasing each year, at least with me.

iCapital: questions regarding adjourned AGM and expenses (4)

iCapital announced:

iCapital: questions regarding adjourned AGM and expenses (3)

I guessed that the letter from the City of London would have settled the matter, but I was wrong.

According this article on the website of The Sun, Tan Teng Boo has reacted to the letter, some snippets (emphasis is mine):


"Share owners are still not able to make an informed decision as the reasons given by City of London are inadequate, baseless and utterly weak," he said.

He said the fact that the letter was not addressed to the share owners shows that the foreign fund had no intention to clarify their position to all share owners of the fund and called upon City of London to revise and substantially improve its standards of corporate governance.

"The letter by City of London is a clear testament of the foreign fund's lack of integrity. By giving such superficial reasons for the opposition of Resolution 4, the foreign fund makes a mockery out of the other 3,400 share owners."


I am really speechless. Mr. Tan is not even a member of the Board of Directors of iCapital, he is an interested party in this all, being the fund manager who received more than RM 6 Million in fees over the past one year alone.


According to Tan, his views were supported by the Minority Shareholder Watchdog Group, whose CEO Rita Benoy Bushon said that best practices encourage shareholders, especially institutional shareholders, to explain their reasons for opposing a director's re-appointments, especially independent directors.


Well, City of London did explain their reasoning, my guess would be that the MSWG is ok with that. And I strongly doubt that MSWG agrees with the aggressive tone of the first paragraphs, especially the underlined parts.

Tomorrow the adjourned AGM will be held, MSWG is usually present (and vocal) on those meetings, I am very interested what their opinion is in the above matter.

I think Mr. Tan went way too far in this matter, and that the Board of Directors of iCapital should significantly step up their game.

I have written before about the persistent discount to the NAV of iCapital's share price which has lasted already for about six years, which did coincide with the underperformance of the fund over the same years.

In the IPO documents (mostly here and here) detailed ways are described to deal with the discount. I am puzzled why the Board of Directors of iCapital has not taken any active measures regarding this matter (except for a one-off dividend). Some snippets of the IPO document from 2005 (CEF is Closed-End Fund):

 

 

 

iCapital: questions regarding adjourned AGM and expenses (2)

I wrote before about these issues regarding iCapital.

According to The Sun Daily website:


City of London Investment Management Co Ltd has written a letter to fund manager Tan Teng Boo to explain why it and Laxey Partners Ltd, the single largest shareholder of icapital.biz with 11.39%, plan to vote against the reappointment of Tunku Abdul Aziz Tunku Ibrahim as a director was due to the length of time he has been retired.

"Directors should not start a new term in office if they have retired from active employment for more than five years. City of London believes that the skills and contributions of a director outside this criterion may be too far removed from current business practices or thinking to truly add value to the board over the long term," City of London's portfolio manager Oliver Marchner said in a copy of the letter sent to SunBiz.

It also pointed out that Tunku Aziz as a board member has no "requisite experience and knowledge of a listed closed-end funds (CEFs) and has retired from active employment for more than five years.

In relation to the composition of the board, City of London's portfolio manager Oliver Marchner made reference to Section IV paragraph 2a of its Statement on Corporate Governance and Voting Policy for Closed-End Funds (9th Edition).

The Statement on Corporate Governance and Voting Policy for Closed-End Funds can be found here.

I hope that the letter is public, and that iCapital will publish the letter in an official announcement at Bursa's website. Since the last AGM was adjourned because of the question why City of London decided to vote against the director, other shareholders should be informed about their answer.

iCapital: questions regarding adjourned AGM and expenses

iCapital's AGM was recently adjourned. That in it self is already quite unusual. AGMs cost money and time, surely there should be a good reason to ask for an adjournment.

According to an article in The Star (some snippets):


During the Oct 11 AGM, the resolution was not tabled, as shareowners holding a 11.39% stake had already indicated their intention to vote against it two days before the shareholders’ meeting.

“The real issue is whether the 11.39% should control icapital. If they can block the reappointment of one director with only an 11.39% share ownership, what is there to prevent them from abusing their power again?”


Did Tan Teng Boo really say "abusing"? If a shareholder (in this case most like a fund) votes in what it thinks is the best way, can that be labelled as "abuse"? Most likely they simply act in the best interest of their investors. Is there any rule that they breached?


"He said shareholders who opposed the resolution should issue a statement on their rationale for doing so, even though it was not required from a procedural and legislative perspective."


I can't recall ever any meeting being adjourned to ask one of the shareholders for the reason of its voting. And why should shareholders issue statements on their rationale? I am sorry to say, but this sounds beyond weird.


Another matter is that I always regarded Dr Tan as being "stingy", that is, "stingy" in a good way, like Warren Buffett being notoriously stingy in spending. Examples are the cost to list iCapital (which was probably a record low for any Bursa listed company), its year report (without any photo's or colours), etc.

To my surprise, things have rather changed, from the 2014 year report:

Advertisements shooting up from 21K to 708K, AGM expenses increasing from 99K to 452K (and most likely increasing again due to the extra AGM needed). Those are strange increases in expenses, atypical for Tan.

Total operational expenses are RM 8.6M, after deducting the 514K for impairment RM 8.1M. On a fund of RM 426M that means 1.9% expenses. That is still considered ok.

But when one realizes that a whopping RM 240M is simply held in cash (one doesn't need a degree in Rocket Science to manage that), then expenses seem to be on the high side.

I own a managed account where the fund manager only charges fees on the invested part (excluding the cash). If we use the same formula for iCapital then the expenses on the RM 186M investments suddenly are a whopping 4.4% per year, much too high for my liking.

These expenses would also explain (partially) the underperformance of the fund, about which I wrote before.

An interesting discussion on this stock at LowYat forum.

SC enforcement

Quite a few fresh enforcement actions by the Securities Commission, here, here and here.

More details on the civil suit against Kenneth Vun and six others.

Lots of regulatory settlements regarding share manipulation and insider trading "without admission or denial of liability". I am not much a fan of the last part, but it might be a practical way to finalize the cases, which often stretch back many years in the past.

Capital Dynamics Asset Management (Tan Teng Boo's firm) was mentioned: "Failure to disclose the deferred performance fees chargeable annually in the statements issued to its clients", and received a directive "to disclose to its clients the chargeable performance fees to date, in the statement issued to its clients by 31 December 2014".

Cases against Apex Investment Services and AmInvestment Bank were older.