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Why a global ETF is delisting from the LSE (and what happens next) post image

The Amundi Prime Global ETF (PRWU / PR1W) is delisting from the London Stock Exchange (LSE).

Though the ETF will continue life on Germany’s Xetra exchange, you can’t own that version in an ISA.

You can own it in a taxable account. But that will have serious tax implications if Amundi does not gain UK reporting fund status for the Xetra incarnation of the ETF.

Moreover, affected investors are being given just a few weeks’ notice to make consequential decisions, and with scant and confusing information.

Potential issues raised by PRWU owners include:

  • Triggering a capital gains tax event if you decide to sell the ETF from a General Investment Account (GIA).
  • Not having time to sell PRWU held within an ISA should you miss the relevant communications from your broker, or if you’re acting as the executor of a will.
  • Confusion about whether the transfer of the ETF from a Lifetime ISA causes a withdrawal penalty on the government bonus.
  • Potentially not being able to sell their ETF for months afterwards if they miss the deadline to sell prior to the delisting event, judging by reports from investors caught up in a previous delisting.

Delisting drama

So why is this happening and what are the rules if it happens to you?

Before continuing, I’d like to thank Monevator readers Peter Rabbit and J. They raised the alarm with helpful comments on Monevator’s low-cost trackers page and via email.

Also, let’s be clear that neither an ETF delisting nor closure means you’ll lose your money, in case you’re worried about that.

The main consequences are:

  • Potentially making a loss if you’re sold to cash and end up being out of the market for a time.
  • Not being able to access your money for a while if your broker handles the situation badly.
  • Being forced into a capital gains event. (Though I think there’s reason to believe that Amundi will reacquire UK reporting tax status for the ETF. I’ll explain why below.)
  • Loss of some ISA benefits if sale or redemption isn’t made in time.

Why is the Amundi Prime Global ETF delisting?

In brief, Amundi is moving the ETF’s domicile from Luxembourg to Ireland.

That’s good news for most investors because they’ll pay less withholding tax on the fund’s US securities due to Ireland’s superior tax treaty with the States.

But it’s bad news for UK investors, thanks to our old friend Brexit.

Prior to Brexit, fund firms could distribute their products across European Economic Area (EEA) borders using common passporting rules.

It was easy. No need to delist your ETF from the LSE.

Then, as Brexit approached like a small moon, the FCA invented the Temporary Marketing Permissions Regime (TMPR) to enable business to carry on.

However, TMPR does not cover new financial products registered with the FCA since 30 December 2020.

Want to promote your new EEA domiciled fund in the UK today? Then recognition is yours via the alternative Overseas Fund Regime (OFR).

But alas, the OFR only began accepting applications from 30 September 2024.

In between times, fund providers had to resort to the UK’s ‘Section 272’ recognition process. This choice piece of bureaucracy has been described variously as ‘cost intensive’, ‘time consuming’, and ‘legally expensive’.

Numerous articles quote industry insiders referring to Section 272’s bad reputation and its deterrent effect upon companies wishing to launch new funds in the UK.

Nice work Global Britain!

The OFR is supposed to be a much easier and less expensive route to market. Though still not as cheap and effective as the old passporting regime.

Amundi-ng its own business

Amundi Prime Global’s OFR application is apparently underway. But not in time to enable the Irish version of the ETF to be LSE-listed before the Luxembourg sub-fund disappears.

And apparently Amundi wasn’t minded to hang around on behalf of its UK investors.

Assuming the ETF regains UK recognition, then this ETF will be back on the LSE at some point. But Amundi pushed ahead with the nuclear option anyway, announcing the delisting on 16 October 2024 and giving investors until 15 November to decide if they wish to redeem their shares via the fund manager.

And this timeline was shortened for those investors who report first hearing about the delisting from their brokers some days later.

The impact of delisting on investors

I personally think ISA owners are best off selling the ETF while they’re still in full control of the situation.

The rules on non-qualifying investments1 in a stocks and shares ISA say:

Where the new investments are not qualifying investments, managers must, within 30 calendar days of the date on which they became non-qualifying investments, either:

– sell them (in which case the proceeds can remain in the stocks and shares ISA)

– transfer them to the investor to be held outside the ISA.

LISA qualifying investment rules are the same as for stocks and shares ISAs.

I can’t find out if a broker transferring non-qualifying investments from a LISA would incur a withdrawal charge designed to negate the government bonus.

But that seems probable, otherwise news of the “AWESOME LISA hack you MUST TRY” would probably have gone viral by now.

Meanwhile, there’s quite a bit of guidance out there advising that if delisted shares (remember: ETFs count as shares) are transferred outside of your ISA, then you can’t replace that money without reducing your annual allowance.

In other words, you should sell the ETF while it still resides within your tax shelter.

The consensus view is that your holding’s market value on the date of transfer is your base cost for future capital gains calculations. So you can’t carry over a capital loss from your ISA, but neither should you be stuck with an immediate capital gain.

However, HMRC’s ISA pages are silent on the issue. Or at least I haven’t been able to find the answer within.

And I’d rather not rely on whatever a random broker’s agent or HMRC forum denizen claims that day.

De-list of To Dos

All of which leads me to conclude that the safest course of action is to sell while you can. All other priorities are rescinded.

Once you sell you can then immediately reinvest the proceeds into another LSE-listed ETF that replaces Amundi Prime Global in your line-up. There are plenty to choose from.

I wouldn’t worry about other retail investors doing the same thing. It won’t move the price and is unlikely to nudge the needle much on the spread either. Amundi Prime Global’s spread was around 100th of a percent on 8 November. A non-issue.

In theory, you have until 21 November to sell (that’s the ETF’s last day of LSE trading). But InvestEngine for one told its ISA owners to sell by 31 October or else it’d take action unilaterally around 7 November.

‘Unilateral’ here means your broker sells for you if haven’t opened a (taxable) GIA with them.

If you do have such a taxable account and you don’t sell beforehand, then your broker will instead transfer the new-style Prime Global ETF into your GIA upon completion of the merger. The merger is slated for 22 November but that’s subject to change.

However, it’s a bad idea to let an ETF without UK reporting fund status hang around outside your tax shelters. (See the ‘Taxable account’ section below).

I don’t think you can depend on the extra 30 days the stocks and shares ISA rules imply you get either.

That’s because the communications received by affected investors suggest that brokers will either sell or transfer on their own timeline if you don’t act yourself.

Does delisting affect SIPPs?

Amundi’s notice to shareholders says:

The Receiving Sub-Fund is eligible for self-invested personal pension (SIPP) purposes under UK tax law. Nevertheless, each SIPP provider may impose its own restrictions.

(The ‘receiving sub-fund’ referred to is the Xetra-listed version of Prime Global.)

I haven’t found any reports of SIPP owners being affected. Still, you may need to take action if your broker doesn’t allow you to trade European-listed ETFs.

One broker advises (with reference to shares generally) that you’ll have to call its telephone trading desk to offload delisted stock if you miss the deadlines. A bit tedious and likely more expensive.

Still, if you fancy holding the new ETF and your current platform doesn’t do Europe then you could transfer it to a different broker who does. There are enough decent options, though it does mean incurring charges on another platform.

My own brokers don’t support European-listed ETFs. So personally I’d sell and replace Amundi Prime Global before the last day of trading.

Taxable accounts and capital gains events

Without UK reporting fund status, capital gains are taxed at your marginal income tax rate. Even worse, the CGT exemption allowance does not apply.

Bad, bad, bad.

However, being an unrecognised overseas fund needn’t stop Amundi Prime Global from achieving UK reporting fund status.

Other LSE delisted Amundi ETFs found this happy place in good time.

For example:

  • EPRE was delisted on 5 July 2023. The LSE sub-fund merged with versions trading on multiple European exchanges. HMRC states reporting fund status came into effect for those back on 31 January 2018.
  • WGES was delisted on 1 February 2024. It merged with its Xetra counterpart which had gained reporting fund status from 17 January 2024.
  • RUSG was delisted on 8 July 2024. It merged with its Xetra equivalent, MWOT. Reporting fund status was granted from 8 July 2024.

So anyone who doesn’t want to trigger a capital gains event by selling PWRU / PR1W may not have to worry about UK reporting fund status if they can wait for the Irish incarnation to appear.

In fact, I haven’t yet found an example of an Amundi ETF delisting from the LSE and only leaving behind a non-reporting fund version.

That said, I can’t claim to have searched every instance. And this time might be different.

Obviously this is a tricky decision that could backfire either way. Ideally, Amundi can give you a straight answer about its plans if you need it. You can call customer service on 0207 074 9598 or email Retail-UK-ETF@amundi.com

You can also check which overseas funds have UK reporting fund status by downloading an Excel document from the dedicated gov.uk page. Search the spreadsheet using the fund’s ISIN code.

The Irish version of Amundi Prime Global is not present in the latest update dated 9 October 2024.

Why do Amundi ETFs keep delisting?

Amundi isn’t the only ETF provider to have delisted ETFs from the LSE over the past several years. But it has been hyperactively pruning its range in the wake of its 2022 takeover of the Lyxor ETF brand.

Normally, delistings eliminate niche products that are struggling to make a profit.

However Prime Global has $1.5 billion under management, according to Amundi.

So Amundi is not delisting the ETF because it failed to gain traction in the market. In fact, it’s protecting the fund’s competitiveness by moving it to Ireland.

Amundi has obviously decided that move can’t wait for the outcome of its OFR application. So it’s seemingly not too bothered about losing any UK investors caught in the regulatory cross-fire.

Indeed the company has done little more than provide the 30-calendar-day notice period required. Meanwhile affected owners are struggling with ineffectual communication from their brokers.

All of which makes me think customer service still has a long way to go in the investment industry.

Are other large ETFs at risk?

I’d be surprised if this proves to be a problem that gets notably worse in the future.

The UK is the second biggest European market for UCITS funds (ETFs fall into that category).

Moreover ETF Stream recently quoted BNP Paribas Asset Management’s global head of business development ETF and index solutions, Lorraine Sereyjol-Garros, as saying:

Some clients, such as in the Nordics, Middle East, Latin America, and Asia prefer LSE listings over mainland Europe, so it enables us to target the domestic market and international clients

Thankfully then, we’ve still got market power as a country. It seems likely to me that fund managers who haven’t launched new products in the UK over the past few years were waiting for OFR to go live.

Unsurprisingly implementation kept being delayed, though it seems we’re finally off to the races now.

Be that as it may, delistings are a natural part of the ETF ecosystem. And yet retail investors aren’t always being given enough time – nor adequate information – to confidently respond.

Brokers are on point for this as they hold the direct relationship with the customer.

It wouldn’t be that hard to write a comprehensive guide to delisting. They’re welcome to start with the points raised above.

Take it steady,

The Accumulator

  1. Scroll to the Changes to investments held in a stocks and shares ISA section. []
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Weekend reading: home truths

Weekend Reading logo

What caught my eye this week.

There is an interesting article in the Financial Times this week that explains that new build properties aren’t as small as we’ve all been led to believe:

It turns out that, rather than shrinking, new homes have become larger.

The frequently used 76 sq m figure is simply wrong and does not reflect the reality of the recent housing market. A housing market analyst tracked the source of this figure to a report published in 1996 that was based on new builds in the 1980s and early 1990s […] the smallest on average of any period.

Unfortunately, the 76 sq m continues to appear in new articles and reports — a true zombie statistic.

Instead, new homes have actually been getting larger and are now slightly bigger, on average, than existing homes.

Apparently Help to Buy – or Help to Buy Bigger, as wags dubbed it – drove the building of more suburban four- and five-bedroom homes, at the expense of fewer city centre flats.

This doesn’t match what I’ve seen in London, of course.

But hey! It’s a big country out there…

Neal Hudson’s article is full of interesting facts. Give it a read if you’re interested in property (and please consider subscribing to the FT if you read a lot of these search links. I do and it’s a treat!)

Breathing space

With Labour aiming to see 1.5m new homes being built – um, someday – I presume this apparent trend for roomier living space will need to be reversed.

Especially as the listed housebuilders’ focus on making bigger ‘executive homes’ targeting DINKYs to rattle around in might be yet another reason why young people find nice no-frills starter flats so hard to snag.

I’m all for higher-density development. Provided the model is classy areas like London’s Maida Vale or Paris’ famously beautiful mid-rise boulevards. Not the high-rise horrors of yesteryear, obviously.

But I suppose that the desirable urban apartment model might face an uphill battle while lockdown – and the near-universal desire for a bit of outdoor space it inspired – is still fresh-ish in our memories?

Have a great weekend.

[continue reading…]

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UK and Europe dumps on Trump

UK and Europe dumps on Trump post image

When it came, Donald Trump’s reelection to the White House as anarchist in chief wasn’t unexpected.

But the scale of his victory – and just how quickly the result was declared – was a surprise.

No wonder markets scrambled to recalibrate in the hours that followed.

The morning in London after the night before saw nearly all risk assets open higher. (Gold was one notable exception).

But as the day wore on, American stocks overwhelmingly prevailed.

US equities ended Wednesday broadly 2% up – and nearly 6% higher for the US small cap index.

But UK and European shares floundered. Indeed the German market closed down for the day.

Tariff-ick

To some extent the market was clearly trying to price in the now-certainty of President Trump – and hence the imminent possibility of some incarnation of his much-touted protectionism and trade tariffs.

For instance, here’s how high-end spirit makers traded over the past few days:

Source: Google Finance

You can see shares in all these companies fell 3-7% the day after the election. If Trump applies tariffs of 20-40% to French cognac, say, then Remy will sell less of it in the crucial US market. So that’s rational.

But note I’ve also included Brown-Forman – the US maker of Jack Daniel’s – alongside the European brands. And it fell too – more than 7% – the day after the election.

That’s equally rational. If the US imposes tariffs then so will its trading partners.

David Ricardo explained 200 years ago why countries do best following free trade principles.

But we live in an era where many people prefer tweets to textbooks, and protectionism and nationalism are back in fashion.

Musky smell

Imposing high tariffs will hurt global trade and make the US a little poorer than it would otherwise have been (although I’d concede the rest of the world will probably come off worse).

One reason the US will suffer is because the dollar will likely strengthen in a more fractious world. This will make US exports less competitive on the global stage, even excluding the tariff tit-for-tat.

Again, any student of economics knows this.

But Trump’s tariffs aren’t really designed to increase wealth. They are for winning votes, and for supporting his favoured industries and companies.

Here’s a striking example of the latter, pitching Tesla against the iShares Global Clean Energy ETF:

Source: Google Finance

Trump says he will roll back environmental initiatives and cut government programmes aimed at driving renewable energy take-up. This should benefit fossil fuel companies. Especially coal miners.

True, it didn’t work out that way last time, for various reasons.

But that’s the ‘Trump Trade’ view.

And here we can see iShares’ global clean energy ETF did modestly puke on Trump’s victory on Tuesday.

Yet at the same time shares of Tesla – a dominant manufacturer of electric vehicles and solar energy products – saw its largest one-day share price gain since the pandemic.

Of course Tesla’s CEO and major shareholder, Elon Musk, pretty much ran Trump’s re-election ‘ground game’ and turned his social media platform X (formerly Twitter) into an electioneering machine. Musk himself many times repeated false election fraud claims.

Given the relative performance of the iShares Clean Energy ETF and Musk’s clean energy and transport company following the result, it seems probable the market is putting more weight on Musk’s political proximity to Donald Trump than on the fundamentals for Tesla versus other similar stocks.

Now, we could debate all day how America ‘won’ the 20th Century.

However I’d contend that a largely meritocratic and competitive capitalist system wedded to a genuine shareholder democracy played an outsized role in pulling it and its citizens ahead.

By contrast, a return to crony capitalism and the robber baron era won’t be in the interests of most Americans.

Trump 2.0: sequel fatigue

All that said, as I write – two days on from election – there are signs the initial post-Trump moves in the markets are waning.

Those drink makers rose today. Gains in Germany are about twice those logged in New York so far.

This suggests the knee-jerk post-election market move was as much a symptom of some traders being out of position and/or hedges being unwound – plus a bit of emotional tumult – than a completely sober repricing of risk and reward.

After all, the only thing we know for sure about a Trump presidency is that it will be unpredictable.

Tariffs, for example, could be implemented at a high level. Or they could just be a negotiating tactic.

The same will be true across the barrage of uncertainty we can look forward to. Whether it be the future of international relations and bodies such as NATO and the UN, to an immigrant wondering if they’ll be deported.

The possible, probable, and unthinkable will only coalesce in the months and years ahead.

Zero sum games

If we are to take Trump and his followers at their word, the election result is a mandate to pursue an America First policy of bilateral agreements, tariffs, and regulatory rollback aimed, they would say, at making America Great Again.

That America is already the richest country in the world and by far its strongest-performing economy – with leadership in most of the key industries including AI, and with the strongest military and nuclear stockpiles – appears not to matter to the electorate.

Maybe after the huge inflation shock of the past couple of years and the hollowing out of American hard industry over the past 30, that’s fair enough, in so far as it goes.

America is an unequal society, and while the average American is much richer and earns a lot more than the average Brit, that hardly matters to Joe Sixpack enviously eying millionaires on Instagram while he struggles to afford a home.

However Trump can’t reverse the technological progress behind so much societal change.

And even in as much as his tariffs might superficially favour certain US groups, they’ll ultimately do more harm than good. Just like last time.

As per the Brookings Institute’s assessment of Trump 1.0:

  • American firms and consumers paid the vast majority of the cost of Trump’s tariffs.

  • While tariffs benefited some workers in import-competing industries, they hurt workers in sectors that rely on imported inputs and those in exporting industries facing retaliation from trade partners.

  • Trump’s tariffs did not help the U.S. negotiate better trade agreements or significantly improve national security.

None of this would have surprised Ricardo.

But what might have raised his eyebrows is that the country with the most globally dominant firms – the biggest winner of the global order that its grandparents and great-grandparent’s forged with their sweat and blood – would now vote against its own economic interest.

A world of pain

If the US does go down the protectionist path, then the forces of Hubris and Irony will one day have their revenge.

Little comfort for those of us caught up in the consequences, admittedly.

Indeed where Trump is correct is that the UK, Europe, and the rest of the free world has benefited enormously from US economic and military leadership over the past 80 years.

If the US retreats, we’ll feel it economically and in our politics and national security. Needless to say Britain looks particularly exposed following our own quixotic decisions of the past few years.

The US can probably coast for a couple of decades however on the momentum of its enormously successful economy.

And if this political movement endures then its leaders can find other scapegoats by the time the costs are clear.

Identity theft

Of course this election wasn’t just about economics. In part Trump’s popularity must be a backlash against the extremes of the progressive agenda over the past couple of decades.

On that note, it might surprise my usual half-a-dozen critics to hear I was noting to friends last week how the Democrats’ website flagged it was fighting for 16 groups – from African Americans to Latinos to Women – but it apparently didn’t see the white male majority among its constituents:

At a time when more American women go to college then men – including for professions such as law and medicine – while the relative earnings of men without a college degree have declined for decades, you can see this could stick in the craw, regardless of your views about the bigger societal picture.

In fact early post-vote analysis suggests many minorities voted for their candidate of choice, rather than the one supposedly prescribed to some identikit community. Lots of Latinos voted for Trump, for example.

I’m all for it. Personally I’m no fan of the extremes of identity politics. We’re all equal individuals as I see it, and while structural inequalities do still exist, an enlightened government can seek to improve things without pitting groups as victims and oppressors, and putting people into boxes along the way.

Some Monevator readers think I lean very left. However as I’ve noted many times before, my own friends think I’m the semi-acceptable face of the right.

In reality I’m that unfashionable 1990s’ middleman – economically a capitalist, but socially a liberal.

That’s because when it comes to both trade and society, I believe the same thing…

…we’re all in it together.

Born in the USA

To conclude, the political shift in the US hardly has me jumping for joy. But there’s not much I can do about it.

For at least the next four years, political risk is back on the table. Especially if you’re an investor in individual companies with any exposure to foreign markets or foreign competition.

We’ll all feel the knock-on effects. From our mortgage rates – Trump’s plans seem inflationary, which will keep US rates higher than otherwise, with consequences for our own interest rate in the UK – to our taxes. For instance we’ll probably have to spend more on defence.

I’ll leave issues such as sleeping at night with an aggressive Russia on the borders of Europe as an exercise for the reader.

Finally, comments welcome, but please focus on the economy and markets.

I know I mentioned identity politics above, but that was because leaving it unsaid would clearly only present half the story.

There’s a vast Internet out there for those who want to go down that rabbit hole.

Botty mouths

On that note, since the election, Monevator comments have been inundated with spam-like postings such as this (identity redacted):

The spam filter identifies them as such. The posters have no prior history of posting on Monevator. They are not on our mailing list. I presume Russian or Chinese bot farms are the source.

But honestly it’s sometimes hard to tell the difference between bot-spam and the bold and radical views of our one or two Blimpian readers. So I’ll delete anything not about global trade, markets, or investing with extreme prejudice for the sake of an on-topic discussion. Save your fingers!

Finally I wish America – a country I’m very fond of – and all her citizens the best of luck.

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Reduce tax on savings by parking cash in gilts [Members]

Are you paying tax on your savings interest? Would you like to pay less tax? Well, it turns out you can, by stashing your cash in gilts1. It’s a legal and safe option that I’ve personally overlooked until now.

The trick is to move your money out of savings accounts and into certain individual gilts:

This article can be read by selected Monevator members. Please see our membership plans and consider joining! Already a member? Sign in here.
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