The disclosure document (the 'KIID') on HL's website is wrong and still reflects the 0.09% charge. Link here You can also observe that whilst the KIID is wrong, the quoted OCF is correct at 0.03 within the 'COSTS' section. Where things go wrong again is when the client is shown all 'costs and charges' they can expect over a period of time (This is mandated by the Regulations) See HERE

It's fair to say lesser experienced investors would come away from the situation with no idea what they were going to pay for this product. This is counter to the regulators expectations and why Costs and Charges Regulation exists.

HERE is some light reading on a review carried out by the FCA in to such issues in 2019 https://www.fca.org.uk/publications/multi-firm-reviews/mifid-ii-costs-and-charges-disclosures-review-findings

It's fair to suggest this is a data vendor issue but aren't HL ultimately responsible for the data they show to clients?

OTC is not a 'listed' Exchange as defined by the HMRC. That means assets listed solely on these Exchanges are not allowed to be held in a Stocks & Shares ISA (there are exceptions and a few technically complex caveats to this but they do not apply in the case of ZIVO)

Hargreaves Lansdown may not have affected clients - we can not know. Any client that is holding ZIVO on HL should be removed from the ISA wrapper. HL should then report any breach of the rules and any client impact. But by still allowing the asset within the ISA wrapper HL are exposing themselves to greater risk of regulatory fines and demostrating they do not have 100% grip on their instrument data and critical processes that should prevent issues such as this.

MiFID wanted to 'protect' consumers. Whether is does or doesn't is not really important. It certainly made things more, ahem, 'complex'. Either way, this is a breach of the rules. The rules (see here) reuire a pretty simple warning and questionnaire (like this) to be presented

No, not the worse crime ever, but a pretty simple data issue for us to spot - so why haven't Trading212 ?

OTC is not a 'listed' Exchange as defined by the HMRC. That means assets listed on these Exchanges are not allowed to be held in a Stocks & Shares ISA (there are exceptions and a few technically complex caveats to this but they do not apply in the case of VAPO)

Trading212 may not have affected clients - we can not know. Any client that is holding VAPO on Trading212 should be removed from the ISA wrapper. Trading212 should then report any breach of the rules and any client impact. But by still allowing the asset within the ISA wrapper Trading212 are exposing themselves to greater risk of regulatory fines and demostrating they do not have 100% grip on their instrument data and critical processes that should prevent issues such as this.

OTC is not a 'listed' Exchange as defined by the HMRC. That means assets listed on these Exchanges are not allowed to be held in a Stocks & Shares ISA (there are exceptions and a few technically complex caveats to this but they do not apply in the case of ZIVO)

Hargreaves Lansdown may not have affected clients - we can not know. Any client that is holding ZIVO on HL should be removed from the ISA wrapper. HL should then report any breach of the rules and any client impact. But by still allowing the asset within the ISA wrapper HL are exposing themselves to greater risk of regulatory fines and demostrating they do not have 100% grip on their instrument data and critical processes that should prevent issues such as this.

Clarity around costs has been atthe centre of numerous Regulatory changes for many years. Showing retail clients what they will pay has been emphasised many times by many regualtors.

Clients might be surprised to find they paid 2x the stamp duty they were quoted pre-sale

Clarity around costs has been at the centre of numerous Regulatory changes for many years. Showing retail clients what they will pay has been emphasised many times by many regualtors.

Also, not charging and/or not paying your regulatory mandated fees to various Worldwide Governments is not a good look!

It is unclear whether AJBell do charge 0.3% French FTT or not. Regardless, the website is at best misleading and (if they do not charge) and worst non-compliant

Holding Ineligible assets in your ISA can invalidate your ISA. The manager can undertake a 'repair'. Although rules state how this should be done, in relaity we have seen different practices applied to resolving these issues. So compliant. So not so compliant. The non-Qualifying asset should be removed from the ISA, the ISA subscriptions rebalanced and the asset moved to the clients GIA exposing it to Capital Gains. The breach should also be reported to the HMRC. All-in-all : not a nice situation for clients or brokers to be in !

We will never know if ii have any clients holding this asset in their ISA. Maybe they do. Maybe they don't. However it does not inspire confidence that their procedures do not pick this up.

See various issues with ISA Eligibility above

We will never know if Lloyds have any clients holding this asset in their ISA. Maybe they do. Maybe they don't. However it does not inspire confidence that their procedures do not pick this up.

Again, already written about above. The basic principle is simple : disclose these costs to clients before purchase.

It seems incredibly lazy to use the 'typical transaction cost' calculation and blanketly apply it to every ETF on your platform when the actual transaction costs of each differ considerably.

Noted at various points above. Cost disclosure and understanding of the asset risks is very much at the forefront of the Regulators minds when mandating these rules. To not comply with them - intentially or unintentionally - potential exposes your client to trading an asset they neither understand the characteristics of nor the price of.

Yes, we agree this is harsh. But a rule is a rule. No likely got hurt. But that's not really the point. The completely wrong documents across the entire platform suggests minimal attention is paid.