As you are likely aware from your working with CWU and reviewing propositions on our website, CWU has been an appointed representative of Share In Limited, which is authorised and regulated by the FCA. Share In has notified us that it is required to bring this relationship to an end, and we are operating on the basis that our agreement with Share In terminated with effect from 26 June 2020. The basis for this requirement has not been formally explained to CWU. However, you are most likely aware that the FCA is moving over the next few months to bring into force rules that will permanently prohibit the marketing of so-called “speculative illiquid securities” (e.g. minibonds for real estate finance). We consider that the position Share In has taken is integrally connected with this.
CWU has sought legal advice as to its resultant position, and is in the process of moving its finance raising operation to a new model, that can exist lawfully outside regulation. We understand that you may have some questions or concerns and so we’ve included some frequently asked questions available below. However, if your query or concern is not covered then please get in touch:
I have investments on the platform. What is their status?
All current investments made via the Crowd With Us (CWU) platform remain valid and will continue under the terms set out when you invested*. CWU uses MangoPay to manage payments to investors and will work with MangoPay to ensure that moneys due to you reach your e-wallet and are there for you to transfer out to your bank account if you wish.
*Please note: Capital at risk. The value of your investment can go down as well as up and historic performance is not a guide to future performance.
I have recently just invested via the platform. What happens next?
If you have recently invested via the platform and the investment was completed, this investment will continue under the terms set out when you invested. You should consult the information memorandum relevant to your transaction for details of its terms. Other than this, you do not need to take any action (though if you are concerned, you are always welcome to contact us for a discussion).
If your investment did not complete prior to 26 June 2020, the date on which our relationship with Share In terminated, then you should have noticed already that we returned your subscription to your e-wallet. We may also have approached you to discuss an investment of these moneys via our new operating model, which, on the basis of advice that CWU has received, subsists outside regulation.
How will you update me on my existing investments (from before the Share In termination)?
The platform will remain accessible to you, you will continue to be able to log in to your account and view your investments. CWU will continue to provide updates via the platform, alerting you via email when updates are posted. Your investments will continue under the terms set out when you invested.
I’ve got money in my general wallet on the platform. What do I need to do?
You don’t need to do anything. If you’d like to continue investing, see point below.
If you’d like to withdraw any money from your general CWU wallet.
• Log in to your account
• Visit your portfolio
• If you already have a bank account attached to your account, simply withdraw funds
• If you do not have a bank account attached, please add this using the link on the left-hand side of your portfolio page. Please note the bank account must be a sterling account with a UK clearing bank opened in your name (or your name jointly with another or others). Then you can withdraw your money.
Can I still invest with CWU?
YES – however, the model for investing is changing and you should review the revised structure on the website. IMPORTANT: under legal advice, we have developed a model that sits outside regulation, and the basis for this will be explained on the website; but a feature of this is that there is no recourse to the Financial Ombudsman Service should you have a complaint or to the Financial Services Compensation Scheme should CWU default in its obligations or cease trading.
Do I need to close my account with CWU?
At CWU, we of course hope that you will continue to work with us under the new model. But we anticipate that some investors will not wish to do so. We will of course be sorry to lose you. In this regard, you should contact us to indicate that you wish to terminate your relationship with CWU. We will facilitate the withdrawal of all moneys in your e-wallet, and if you have any outstanding investments via the platform, we will ensure that moneys due to you are transferred directly to your bank account as they fall due for payment.
How do I communicate with you?
To discuss anything relating to your account on the CWU platform, you can communicate through the messaging service. Simply send us a message via the message portal in your account area.
How do I make a complaint?
We want to ensure you are not negatively impacted by this change; but sometimes things go wrong. We would hope to resolve most issues straight away so please email us on email@example.com
to tell us how we can help.
So that we can help you as promptly as possible, you will need to provide:
• Your personal details
• A summary of what you believe to have gone wrong and
• What you expect us to do to put things right
Our commitment is to try to resolve your complaint within 10 working days. For more complex issues, we may need longer to look into what has happened and we may ask you for further information to help us reach a decision. In the case of a protracted investigation, we promise to provide frequent updates (typically fortnightly).
If you are unhappy with the outcome, you can ask the Financial Ombudsman Service (FOS) to carry out an independent review of your complaint. In any event, you have the right to ask the FOS to review your complaint if we have been unable to resolve it within 8 weeks.
The FOS can help UK residents with most complaints if you are:
• A consumer
• A business employing fewer than 10 persons that has an annual turnover that doesn't exceed €2 million
If you are unsure whether the FOS will consider your complaint, please contact them directly for advice. The service the FOS provides is free and impartial and contacting them at any stage of your complaint will not affect your legal rights. The contact details for the FOS are:
The Financial Ombudsman Service
South Quay Plaza
183 Marsh Wall
Their phone numbers are +44 (0)300 123 9123 or +44 (0)800 023 4567.
You can send an email to: firstname.lastname@example.org
– the FOS jurisdiction only applies in relation to business undertaken with CWU while it was an appointed representative of Share In. The FOS has no jurisdiction in relation to any business undertaken under our new (unregulated) business model.
What do I do if my personal details change?
You are able to update your personal details (address, password, marketing preferences) via the platform in your account. You can add or update your bank account details via your portfolio.
If you require any further updates, please contact us via the platform messaging service.