Directive - Concerto Alternative Alpha Inc. (2011-08-15)

Summary

This is an enforcement action directive issued by the BVI Financial Services Commission under section 40(1)(b) of the Financial Services Commission Act, 2001, against Concerto Alternative Alpha Inc. and a group of related funds all under the management of Castlestone Management Incorporated. It imposes ongoing reporting and financial-control restrictions on the named funds while the Commission's concerns are addressed.

• Weekly reporting: The Funds must provide the Commission with full details of their activities on a weekly basis.
• Internal controls proposal: The Funds must submit to the Commission a proposal to implement more robust internal controls.
• Restriction on payments: The Funds must not make any payment of fees or expenses without the Commission's prior written consent, except for fees relating to fund administration, brokerage, custody, and audit and legal services.

The directive names eighteen specific fund entities (including Concerto Alternative Alpha Inc., the Aliquot group of funds, Porcupine funds, and others) all managed by Castlestone Management Incorporated. The matter is tracked under reference INV0811/092.

Key obligations

• The named Funds must provide the Commission with full details of their activities on a weekly basis.
• The named Funds must provide the Commission with a proposal to implement more robust internal controls.
• The named Funds must refrain from making any payment of fees or expenses without the Commission's prior written consent, except for payments relating to fund administration services, brokerage, custody services, and audit and legal services.

Applies to

Investment Business, Funds under management of Castlestone Management Incorporated, Concerto Alternative Alpha Inc., Aliquot Agriculture Fund Inc., Global Property Growth & Income REITS Fund Inc., Aliquot Commodity Fund Inc., Inflation Target Recovery Fund Inc., Aliquot Gold & Precious Metals Equities Fund Inc., Intelligent Portfolio (IQ-Asset Allocation) Inc., Aliquot Gold Bullion Inc., Next 11 Emerging Fund Inc., Aliquot Precious Metals Inc., Porcupine Absolute Return Fund Inc., Balanced Opportunity Inc., Systematic Growth Fund Inc., Collection of Modern Art Inc., World Index Growth and Income Fund Inc., Consistent Return (Cash Management) Fund Inc., Emerging Markets Growth and Income Fund Inc., Porcupine Global Macro Plus Inc.

Deadlines

• weekly: The Funds must provide the Commission with full details of their activities on a weekly basis.