Dowgate Wealth Limited · DRN-6108123

The complaint Mr A’s complaint, in essence, is that Dowgate Wealth Limited (“Dowgate”) didn’t manage his portfolio in line with the agreed mandate. His complaint includes that the portfolio management was reckless, negligent, not properly supervised, commission driven and not in line with his initial strategy. He says excessive and unwanted trades resulted in inappropriate risk and a portfolio with two thirds in low quality small-cap shares. He also criticises holdings in energy and mining stocks and in companies with which Dowgate had corporate links and of which it alluded to having inside information. Mr A also complains Dowgate didn’t keep him properly informed. This includes that the reporting was generally inadequate and he didn’t receive daily contract notes which he says were agreed but supressed to conceal the activity on the portfolio. He also says Dowgate failed to answer his information requests, and a subject access request he made didn’t contain key transcripts from two online meetings in June 2023 or mention his key issues. What happened Mr A held a portfolio with another investment firm. Staff from that firm moved to Dowgate and Dowgate was in touch with Mr A in September 2020 with some very general information about the firm. Staff who moved included the investment manager who would later manage Mr A’s Dowgate portfolio and manage a Dowgate smaller companies fund. Mr A says that manager had, under supervision of a superior, managed his portfolio for around 15 years at the former provider. Mr A says that manager after leaving for Dowgate contacted him with past performance figures and social invitations to get him to move to Dowgate and also offered the prospect of borrowing facilities, which was a major inducement for him to move. An email of 9 May 2021 from the manager said, of Dowgate: “We have built a strong team and culture that can give great personal service and index beating returns, like the old [firm initial] days. We are meeting between 60 and 90 companies each month and over the last couple of months we have seen a lot of new issues and placing… of which recent highlights have been….” The email then listed company names with the ‘in’ price and the price at May 2021, showing price growth ranging from 12% to 60%. The companies listed included two that were later included in Mr A’s Dowgate portfolio and whose share prices then reduced by 45% and 54% from purchase for Mr A to July 2023. The email continued: “Besides these a lot of our old favourite stocks have been really recovered well in the last 12 months showing the importance of good stock picking. We also have a few issues coming in the next few weeks that we like. Perhaps we could have a chat…” Mr A joined Dowgate and signed an onboarding form on 30 November 2021 to apply for a discretionary account, meaning Dowgate would “manage on a discretionary basis your portfolio of cash and investment via a dedicated portfolio manager.” Mr A ticked the form to declare over 10 years investment experience, with experience of shares, derivatives/options, futures, bonds, AIM and unit trusts and he strongly agreed his knowledge of investing was excellent.

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In risk tolerance questions, Mr A strongly disagreed with preferring capital safety over ‘huge returns’ and strongly agreed he was more afraid of missing out on exciting opportunities than of what he could potentially lose. The form pointed out that “Some smaller companies have limited track records, are highly illiquid and are at greater risk of failure” and Mr A strongly agreed he would be happy to invest in this type of company to achieve larger returns. Mr A indicated he might feel the need to cut his losses if his investment fell by 31% to 49% and strongly disagreed with preferring investments with little or no fluctuation in value and with being willing to accept lower returns for reduced risk. Our investigator noted that when Mr A jointed Dowgate: ▪ He was retired with a £4m investment portfolio. He agreed “large losses would have a low impact on my future standard of living” with a percentage range of 50-70% in reply to being asked: “How much of your investments with Dowgate do you think that you are able to lose without having a significant impact on your future standard of living”? He owned properties with mortgages but substantial equity. ▪ He stated he’d worked in the financial industry. ▪ Information about the discretionary service said: “If you elect for this service, DC will manage, on a discretionary basis your portfolio of cash and investments. Subject to any instructions from you, DC will have full authority at its discretion, with prior reference to you, to execute any type of transaction or arrangement for your account. Using this discretion will be in accordance with your investment objectives as prescribed by the applicable FCA rules and in a manner that we believe to be suitable for you..” ▪ Mr A requested that he be categorised as a high risk client. In December 2021 Dowgate explained its high risk category as follows: ▪ “By adopting this strategy, you are prepared to place your investment at a high risk of loss in return for the potential of high rewards. You accept that this strategy requires a high degree of exposure to equity investments (up to a maximum of 100% of your portfolio) that will include exposure to a wide range of equity investments, including exposure to worldwide and developing economies, and may include investments in specialist funds and products. This type of portfolio can invest up to 100% in high risk AIM stocks and a maximum of 10% in unlisted securities. You understand the performance of such investments may be volatile, with potentially high fluctuations in the value of your capital. There is no capital guarantee. You also appreciate that certain high-risk investments may not carry the protection of the regulatory bodies. Such investments may not be readily realisable as markets may be limited. Access to reliable data for valuing such investments may be restricted.” Mr A confirmed he agreed to being categorised as a high risk client in December 2021. His stated objective was to maximise growth. The discretionary investment mandate – which set out the high risk definition above, said of the portfolio overview: “Your account will be invested for Capital Growth based on a high risk profile, meaning the majority of the portfolio will be invested in small-cap companies with some exposure to collectives and alternative assets where appropriate.” Mr A says a core-satellite approach was agreed for the portfolio so that half would be in a ‘core’ of three holdings (two broad US indexes and a large investment conglomerate) that were not to be sold. He says this was agreed in person at a meeting on 30 November 2021. So he says Dowgate had discretion but there was recognition that it didn’t have discretion as regards those holdings. He says the other half of the portfolio was to follow approaches the

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manager had “learned from his mentor” including that stocks selected would be of top quality and retained for a long duration. Mr A says an unsolicited 25 April 2022 email from Dowgate cast doubt on the stock market direction and indirectly prompted him to reconsider his core investments, which he says is what Dowgate intended. The email said: “Do you want to have a quick call this morning. Markets and in particular tech are selling off so I want to check you are happy with your exposure in the short term.” Mr A believes Dowgate’s purpose was to facilitate the selling of core holdings as it would make little in commission from trades on those. Mr A also says 300 trades took place on his portfolio over nearly one and a half years and this high level of dealing and switching was unsuitable and detrimental to him. He also says holdings in a large US tech company he had personally chosen were also sold by Dowgate. Mr A says his portfolio closely resembled Dowgate’s own smaller companies fund, in which his portfolio also held a stake directly. He says duplication of holdings due to overlaps raises issues about diversification and excess exposure to sector or company specific risks within subsets of the market. He says this also raises concerns about potential charging and about share selections being influenced by third party interests (to boost the smaller companies fund). He says a lack of internal oversight and external auditing contributed to this risk. With regard to investment in companies with which Dowgate of its associates had corporate relationships, Mr A asks whether Dowgate appropriately separated and managed conflicts of interest between its corporate finance activity and its selection of stocks for client portfolios or whether Dowgate advisers were directed, incentivised or pressured towards the use of “house shares” to support corporate finance objectives and whether this emerged in other client portfolios. He says his concerns were prompted by the Dowgate manager at a social event introducing him to someone from Dowgate’s corporate associate who encouraged them to expect “good times ahead” for a company (“B”) the associate was corporate broker for. Mr A says Dowgate told him during a June 2023 online call that the sale of shares in ‘B’ was being delayed as Dowgate was awaiting information regarding a fundraising that would positively impact the share price. He says this indicates ethical, regulatory and conflict of interest concerns related to trading with privileged information. As regards being kept informed, Mr A says it was agreed that he would receive daily email contract notes after each transaction – and that this was essential for him to stay updated. But he says contract notes were deliberately withheld, potentially to hide unauthorised transactions. He also says the quarterly valuation and reports he was given were “woefully inadequate, completely devoid of any pertinent specifics or insightful details” of the holdings. He is also dissatisfied with the records provided to him in response to his data subject access request – in particular the lack of records of the video calls which he says are crucial to an understanding of the situation. Mr A also says he wasn’t told his investment manager had left Dowgate and the industry and his portfolio was neglected after his investment manager resigned. Dowgate’s response to Mr A’s complaint said: ▪ Mr A agreed a high risk approach for his investment portfolio and the portfolio was managed to the parameters of this profile and his objective to maximise growth. So it had exposure to up to 100% equity including AIM, global equity, developing markets, specialist funds and up to 10% in unlisted securities. ▪ Mr A was informed that he could access all contract notes through the client portal and he received email alerts when a new contract note was created.

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▪ Dowgate doesn’t have records of the discussions about the sale of ‘B’, but the fund raising in question became public knowledge on 1 June 2023. ▪ Mr A’s portfolio performance was -11.7% to 30 June 2023 when his portfolio was moved to an execution only basis. An index for private client portfolios with a high risk mandate (and high exposure to global equities) showed a return of -7.99% over the same period. ▪ Dowgate had provided all calls and emails that it had in its systems in response to his data subject access request, and he could complain to the Information Commissioner’s Office if he was dissatisfied with this. Before Dowgate’s response to Mr A’s complaint, it sent a 16 June 2023 email to Mr A from its investment manager. It told Mr A his portfolio had been moved to execution only due to the disagreements as to how it should be run. It said Mr A’s portfolio at that time (June 2023) was down 10.9% since the start or £455,000 of which it said Mr A’s “selections” accounted for £197,000. The email said the portfolio turnover the year before was 1.69 times and the total cost including commissions was 0.74% of the portfolio. It said withdrawals of £621,000 by Mr A in the first year and a half meant it had sold positions it might otherwise not have sold, and so the 0.74% cost figure was higher than it might otherwise have been. It said the sale of a technology stock chosen by Mr A was done to raise cash and at Dowgate’s discretion due to its view that the portfolio was overweight with technology stocks like this. Dowgate also said that after its April 2022 email to Mr A, he had asked Dowgate to raise 33% cash within a week. Our investigator considered Mr A’s complaint and thought: ▪ Mr A had a wide and extensive background in diverse assets of which some were complex and high risk. His industry experience supported an understanding of sophisticated investments and knowledge of markets. ▪ Mr A wanted to be a high risk investor and it was reasonable for Dowgate to permit this and likely Mr A understood how this would impact the portfolio. ▪ She had seen no mandate which dictated purchases or retention of specific assets, like Mr A has said. Mr A had mentioned a mandate like this in calls with Dowgate, but these were after the sale of the holdings in question and Dowgate didn’t agree such a mandate had existed – it instead referred to having discussed sales with Mr A before releasing cash. She had seen nothing to document the in person discussion Mr A had said there had been about this. ▪ Mr A’s aim was to achieve maximum growth, he had the financial capacity to take the risk of higher risk investments, including small cap companies. The transition of the portfolio to higher risk investments wasn’t out of line with this strategy. ▪ Mr A would still have considerable financial security if he suffered investment losses. ▪ On balance, Dowgate acted fairly in its capacity as discretionary portfolio manager. Mr A may not have been happy with the sale of some assets but there wasn’t evidence of an instruction to retain those assets. Overall Dowgate had acted reasonably. The regularity of trades suggests it was monitoring markets and managing the portfolio. It reached out to Mr A to discuss new investments. ▪ Contract notes weren’t sent daily, but it wasn’t clear Dowgate had agreed to provide that level of service. Mr A had access to a portal, which he accessed at times, which offered

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a contemporaneous overview of the portfolio. There were emails discussing trades and the emails and calls suggest Mr A was actively following market events and making suggestions, so he was either actively involved in the portfolio decisions or aware of what Dowgate was doing. The evidence didn’t support the idea that Dowgate had intentionally kept Mr A uninformed or hidden what it was doing. ▪ Entities associated with Dowgate were linked to some investments bought for Mr A, but this was either disclosed to Mr A or public and Dowgate didn’t mislead Mr A about it. ▪ She wasn’t persuaded the correspondence between Mr A’s portfolio and other portfolios arose in order to double-charge Mr A. Nor was she persuaded that the portfolio was excessively traded in order to earn commission. Rather Mr A’s investment strategy meant there would inevitably be a greater number of transactions given it was higher risk investing in smaller companies and less established assets. ▪ It appeared that Mr A had requested information of various kinds from Dowgate, and Dowgate had responded, but if there were specific requests Mr A considered were still outstanding, she would pass these on so Dowgate could respond. ▪ There were occasions when Dowgate could have handled matters better. There was also a blurring of the professional and personal relationships between the parties (such as advising Mr A on professional exams to take). But the cause of Mr A’s losses was the type of investing he was engaged in and the significant risks this carried. Mr A didn’t agree with our investigator’s conclusions and asked for a reconsideration by an ombudsman. He said the issues of mandate breaches, concealment of contract notes and updates, conflicts of interest and repeated failures to provide information, hadn’t been addressed and we had relied too heavily on Dowgate’s records rather than independent verification. As the matter remained unresolved, it has been passed to me to decide. What I’ve decided – and why I’ve considered all the available evidence and arguments to decide what’s fair and reasonable in the circumstances of this complaint. Having done so I’ve arrived at the same conclusion as our investigator and for broadly the same reasons. I’ll explain my reasoning briefly. Mr A agreed to a high risk portfolio and to discretionary management by Dowgate. The meaning of high risk as defined by Dowgate and agreed by Mr A, gave Dowgate wide discretion as to how to invest his funds. This discretion did not preclude a high level of investment in smaller companies. It is apparent that it contemplated unlisted companies too. Also information about how it was likely to implement the mandate specifically referred to investing in smaller companies. Risk questions Mr A answered likewise asked about his willingness to be invested in smaller companies and flagged the risk this might involve. Also the email from Dowgate before Mr A joined promoted its investment in small and early stage companies as a feature and benefit and a reason to join Dowgate. So I’m not persuaded the high exposure to small companies Mr A describes shows Dowgate wasn’t managing the portfolio within the parameters of the mandate agreed with him. In saying this, I bear in mind I’ve not seen anything to show that it had been agreed there was a core holding that couldn’t be sold. Also what I’ve seen, including what Mr A has told

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us about being prompted to reconsider his core holdings, doesn’t persuade me that Mr A was either unaware or not in agreement with the changes to existing holdings – changes which Dowgate was entitled to make using the discretionary power Mr A had granted it. There are of course different levels of high risk investment, and the profile Mr A agreed to was potentially at the more speculative end – but I’ve seen nothing to suggest to me that Mr A wasn’t aware of this when he signed up. Rather I think he was aware and was willing to and wanting to take a high risk approach to maximise growth how ever Dowgate considered this might be done, so long of course as it was within the remits of the mandate. Given the mandate, the portfolio was likely to be very volatile indeed. But I’ve seen nothing to suggest Mr A wasn’t willing or prepared to accept a very high level of volatility. Indeed significant drawdowns were contemplated in his risk question answers. I’ve noted already that the fact smaller company investment carries higher risks, was highlighted in the risk questions put to Mr A. But there’s no suggestion that Mr A wouldn’t have been aware of this anyway. There was allocation to energy and mining stocks but I don’t see that the allocation to such investments was outside the mandate Dowgate had or the agreed risk parameters. A 2020 portfolio report from Mr A’s previous portfolio indicates Mr A had adopted the highest risk profile available from that provider, that his level of knowledge was considered to be high and that the portfolio management by that manager was to be unconstrained in terms of its use of investments or asset classes approved by that firm. I note also that a substantial part of that portfolio – and a very substantial part of the capital growth it had experienced - was the result of investment in two funds that focussed on micro-cap and smaller companies (the former includes a focus on AIM listed shares). A sum of around £423,000 had grown to around £976,000 while invested in such funds with Mr A’s former investment firm, according to a June 2020 portfolio statement. So this tends to reinforce the notion that Mr A was someone willing to take a high risk approach focussed on smaller companies such as that which was contemplated in what Dowgate told him about its high risk mandate. I note what Mr A says about overlap between the companies selected for his portfolio and a ‘Dowgate’ fund ran focussing on smaller companies. But I don’t see that this is suggestive of inappropriate investment management. Given its investment mandate’s focus on smaller companies, it isn’t surprising that Dowgate chose to use a Dowgate smaller companies fund to provide some of this exposure. I don’t find this unreasonable, given that this fund was made up of companies Mr A’s Dowgate manager selected as being worthwhile investments. Likewise, if Dowgate decided Mr A might benefit from greater exposure to some companies within one of its funds or to similar companies or sectors, then I don’t see why it shouldn’t have given effect to that by adding exposure individually within Mr A’s portfolio. I note Mr A’s portfolio had holdings in well over 50 different companies or collective funds as at July 2023, of which the Dowgate smaller companies fund was one. So I don’t see that this exposure or the sum invested in that fund, meant the portfolio lacked diversification overall. I don’t see that Dowgate funds were used in order to gain commissions. Modest use of Dowgate funds to provide wanted investment exposure wasn’t unreasonable. I’d add that such exposure wasn’t out of line with anything Dowgate had given Mr A to expect, from what I’ve seen. In saying this I also take into account that Mr A’s portfolio while managed by his previous provider, contained small cap collective funds I’ve mentioned above which Mr A says were managed by a manager at that firm who also supervised Mr A’s portfolio. So in that respect Mr A describes an arrangement that is very similar to that which existed for him at Dowgate. Turning to the portfolio churn Mr A has described – in terms of the number of transactions he says took place during 18 months - there is nothing in the mandate that suggested Dowgate

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wouldn’t manage the portfolio actively and transact with the frequency Mr A complains of. I’ve not seen anything to persuade me Mr A was promised a different or particular approach that Dowgate then failed to deliver. Also, given the portfolio focus on smaller companies, which tend to be more volatile, a larger number of different shareholdings was needed to provide diversification and mitigate excess risk. This necessarily increases the number of transactions that might be expected. Also higher risk approaches can encompass a higher rate of portfolio turnover and Mr A wanted a high risk approach that maximised growth. With all this in mind, I don’t see that the portfolio churn was excessive. This would be my view even if some of the transactions hadn’t been to raise funds or for reasons not specific to investment management decisions of Dowgate. I reach my view here bearing in mind that the rate at which investments should be traded or turned over within a portfolio over time, is an investment decision made at the discretion of the fund manager and there can be a wide range of legitimate approaches. So to find Dowgate’s approach to have been illegitimate or negligent, I would need to conclude that the rate at which it turned over the portfolio exceeded a rate that could reasonably be used by a competent manager. I don’t see that it did, bearing in mind all I’ve said about the nature of the holdings within the portfolio and the mandate Dowgate had. I’d add that the loss or underperformance Mr A complains of doesn’t appear to me to have resulted from costs arising from trading or from excessive or commission driven trading of the portfolio, bearing in mind what Dowgate has said about the overall portfolio cost. I turn now to consider whether Dowgate’s investment selection for Mr A was compromised by relationships or interests it or its associates had with companies it invested in. I should be clear that my role is to consider Mr A’s position in particular rather than to audit Dowgate’s processes in general. The latter would be a matter for the FCA as regulator. Also I note that in seeking to attract Mr A to Dowgate, its May 2021 email emphasised its engagement with companies who were seeking capital investment. So Dowgate in part promoted itself to Mr A on the basis of relationships it had with potential investee companies – and its proximity to companies involved in capital raising processes. Some companies mentioned in that email as highlights of its approach, were later included in Mr A’s portfolio. But it seems to me this was what Mr A might reasonably have expected, given that access to such investments was presented as a potential benefit to sell Dowgate’s services to him. Mr A points to the holding in company ‘B’, for which a Dowgate associate was a corporate broker. So I’ve considered whether there is evidence indicating the selection of this holding for the portfolio, or its management thereafter, was organised to benefit Dowgate rather than because Dowgate considered the company to be an investment with prospects. I’ve not seen evidence to indicate this. B’s share price in July 2021 was 50p. When a holding of 20,000 was bought for Mr A’s portfolio on 15 December 2021 the price had risen to 117p. There were positive trading updates leading up to December 2021, like an announcement in November 2021 of increased production capacity to meet expected demand. Mr A’s portfolio added 10,000 to its holding on 4 January 2022 at 121p. The price rose to around 140p later in January 2022. It fell to 95p in March 2022 but rose to 120p on 7 April 2022. On its face, this performance doesn’t in my view indicate that the investment was one Dowgate should not have made or made primarily because of the relationship its associate had with the business. The share price fell in April 2022 and was then consistently below the level Mr A’s portfolio had paid for it. But the IA UK smaller company index suggests smaller companies had elevated values in December 2021 and January 2022 but fell away substantially after that. So the performance of ‘B’ held up better for a time.

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Also the nature of its business was medical device innovation, so the chances of volatility were likely to be elevated. But I don’t see that the nature of the company was out of line with the sort of investments contemplated for Mr A’s high risk portfolio. The sum placed into ‘B’ by Dowgate for Mr A wasn’t out of keeping with other holdings within his portfolio. Overall, from what I’ve seen, the investment in ‘B’ doesn’t appear to have been unreasonable. Also I don’t see that vague but broadly encouraging comments of the kind Mr A has reported being said about the stock by Dowgate’s associate, points to a conclusion that Dowgate’s purchase of the stock for Mr A’s portfolio was negligent or made without due regard for his interests. Likewise what Mr A recalls Dowgate telling him about holding on to the shares in or around June 2023 doesn’t in my view show Dowgate was using information it should not have had access to or acting against Mr A’s interests. The result of a proposed share placing was announced on 25 May 2023 with other announcements published on 1 June 2023. So some information was public before Mr A’s meetings in June. Overall I’m not persuaded what Mr A has said about the conversations about the stock in or around June 2023 point to wrongdoing or to anything for which I could award Mr A redress. The price of the shares trended up in the period June to September 2023, so at first the effect of Dowgate’s decision to hold the shares rather than sell them benefited the portfolio at that time. But even the price had fallen instead, the decision was within the discretion Dowgate had as portfolio manager to decide when to sell particular holdings. I note that many of Mr A’s other holdings made substantial losses. But I note also that the two small cap funds he had held in his previous portfolio also fell in value during the period. The micro-cap fund was up 20% in September 2021 from March 2021 but was down 36% from the March 2021 levels by October 2023 – a fall from September 2021 to October 2023 of about 50%. The smaller companies fund he’d previously had performed similarly. It seems to me that this helps to illustrate that the period was one in which investment in smaller and more speculative companies was difficult and significant losses could be expected. It seems to me that this is the main reason for Mr A’s losses. Mr A says the Dowgate manager offered him inducements to invest with Dowgate. I understand this included a suggestion that a third party might loan against the portfolio. An email from Dowgate in 2022 refers to the possibility of such lending, so I don’t doubt that there were discussions of the kind Mr A says. But Mr A’s complaint is about the results of the investment management rather than losses arising from the provision or denial of any loan facilities. What Mr A says about inducements from Dowgate or a promise of lending facilities doesn’t make me think Dowgate’s investment management was negligent. It appears that contract notes weren’t sent to Mr A but notifications were sent by email. I’m not persuaded Mr A was unaware of the investment approach being undertaken by Dowgate or denied knowledge of particular transactions it was carrying out. Nor am I persuaded that the approach taken went outside the bounds of parameters set by the high risk mandate description agreed with him. In my view Mr A’s losses arose as a result of Dowgate making investments in line with Mr A’s agreed mandate. With that in mind, I’ve not identified fair and reasonable grounds for awarding Mr A redress for those losses. Mr A says what he was sent wasn’t sufficiently informative. But Mr A was a knowledgeable investor capable of asking for more if he wanted more. I don’t see that this can be linked to the investment losses on his portfolio. From what I’ve seen it seems Dowgate was willing to discuss investment matters with Mr A and to consult him from time to time and accepted instructions on occasion, but it was for Dowgate to make the investment decisions. It wasn’t obliged to only make investment decisions it had already explained to Mr A or for which it had given Mr A sufficient detail for him to make his own evaluation.

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With regard to Mr A’s information requests and requests for his data, Dowgate says it provided what it has. Our investigator offered to request more for Mr A. I don’t see that there is more I can usefully add or that this is relevant to Mr A’s financial loss or to his complaint here about Dowgate’s portfolio management. I’d add that complaint handling isn’t itself a financial service, and so isn’t itself something we can look into a complaint about. I note that Dowgate informed Mr A that his account was being placed on an execution only basis. This meant it wouldn’t trade existing assets and it would be for Mr A to decide how the portfolio should be managed in future. In my view this wasn’t an unreasonable approach given that Mr A wasn’t happy with the results Dowgate had achieved or with the investment decisions it had been making for him. In conclusion, I acknowledge Mr A suffered significant losses that have had a significant impact on his financial wellbeing - so I appreciate my outcome here will disappoint him. I’m grateful to him for his courtesy and assistance he has given us throughout our consideration of these matters, and I thank him for his patience. But I’ve been unable to identify grounds on which to award Mr A redress. So, for the reasons I’ve given and discussed above, I do not uphold this complaint. My final decision For the reasons I’ve given, and in light of all I’ve said above, I do not uphold this complaint. Under the rules of the Financial Ombudsman Service, I’m required to ask Mr A to accept or reject my decision before 24 April 2026. Richard Sheridan Ombudsman

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