Custodian and Investment manager


Custodian Financial Institution
1A. Custodial bank
BNY Mellon

$29.5 trillion under custody or administration
$1.7 trillion under management
100+ countries

Established 1784, oldest bank in USA
S&P credit rating "AA-"
Custodian fees 0.1% p.a.
KYC / AML - none as assets belong to insurer
1B. Custodial Financial Institution
Santander Securities Puerto Rico br>S&P rating "A-"
Custodian fees - Nil
Trading costs - $0.06 per equity
Fixed income 0.05% to 0.25%
1C. Custodial bank
Reyl & Cie, Switzerland
Custodian fee 0.3% to 0.5% p.a. depending on amount
Policy Investment Manager
2A. SEC registered Investor

US insurance law prohibits policyholder to manage their own policy assets. As the insurer is a US person, te investment advisor must be SEC registered. However, there is an exemption for foreign private investment advisors.
SEC Investor act of 1940
Foreign Private Adviser Exemption Section 202(a)(30) of the Advisers Act defines a foreign private adviser as an investment adviser that meets all of the following conditions:
  • has no place of business in the United States;
  • has in total, fewer than 15 clients and investors in the US in private funds advised by the adviser;
  • has aggregate assets under management of less than $25 million attributable to clients in the United States including US domiciled private funds and US investors in private funds advised by the adviser;
  • does not hold itself out generally to the public in the United States as an investment adviser; and
  • does not advise registered investment companies or registered business development companies.
An investment adviser that meets all of the conditions of the exemption set forth above is not required to register as investment adviser. In such case, the advisor will be a consultant. See section 2B below.
2b. Consultant
For non SEC registered advisors.
Conditions for Consultant in managing the portfolio:
Rebalance once a quarter
Emergency trades allowed
Instructions given to insurer, who will pass instructions to custodian FI
Restricted to listed securities
2C. Policyholder does not currently utilise an investment manager

If policyholder currently does not employ an investment manager, e.g. self-directed investments, then the policyholder can use Reyl & Cie as custodian, and appoint Reyl Overseas as the SEC registered investment advisor on the policy.