# BCP launches a leveraged Quadruple Growth Bond



## Brendan Burgess (1 Dec 2003)

For those of you who are not satisfied with quadrupling your losses, you can now magnify them even further, by borrowing to invest in the Quadruple Growth Fund.

The interest rate is fixed at 4.5% and you can borrow up to three times your capital. 

The new brochure gives illustrations based on capital of €100,000. The illustrations show potential dramatic losses. If you have €100k and borrow €300k, you can lose up to €90k or 90% of your investment. 

There is no note on the brochure that IFSRA has warned of the dangers of borrowing to invest in these trackers.

Brendan


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## Seven of Nine (1 Dec 2003)

*Above*

Brendan, this is just bloody shocking. IFSRA is beginning to look like a sick joke.


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## Benny (1 Dec 2003)

*Quadruple Losses*

Saw this mentioned in the Sindo also, which actually said that you're MORE LIKELY to end up with Quadruple Losses. 

How can you have Quadruple Losses with a 90% capital guarantee?

If these things go unchallenged, they will simply become accepted as fact. 

Benny


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## Warf (1 Dec 2003)

*IFSRA*

It appears awfully like IFSRA has ground to a halt and has already lost its way. Based on media interviews on RTE its main thrust is going to be on consumer information/ education.

But where is the intervention badly sought ? Here is a dramatic example but nothing from IFSRA.

Before IFSRA were we better off? At least then media  acted as watchdog because there wasn't any. Now we have a watchdog that looks like one, but up close you can see it's a poodle with no teeth, and it clearly can't bark.


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## Brendan Burgess (2 Dec 2003)

Hi Benny

It is completely misleading to describe this as a Quadruple Growth Bond. It never ever quadruples your growth. I have tried to create artificial scenarios and even still I cannot come up with one, no matter how unlikely, where you will receive quadruple the growth.

However, in one particular setting, it does actually quadruple your losses. If the basket of stocks drops between 0% and 2.5%, your losses will be quadrupled. 

In addition, your losses on any individual share will be quadrupled without limit in calculating the overall average, whereas the maximum growth on any individual share which will be quadrupled will be limited to 17.5%. 

But if the average losses are say 10%, the total loss will not be quadrupled to 40%. It will be limited to 10%. 

Brendan


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## Benny (2 Dec 2003)

*Quadruple Bond*

Hi Brendan,

I don't disagree with anything in your post above. 

However, the notion that you are "more likely" to quadruple your losses" (Eoghan Williams in the Sindo) needs to be challenged. 

It's little more than inaccurate scaremongereing. 

Benny


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## Dearg Doom (2 Dec 2003)

*Re: Quadruple Bond*

Pqg, Probability of quadruple growth: 0 (it can never happen)
Pql, Probability of quadruple losses:  Some small probability, but definitely greater than 0 (it can happen)

Pql > Pqg

=> you are more likely to quadruple the losses than to quadruple the growth

It'll be difficult to challenge...


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## Benny (2 Dec 2003)

*Cut to the Chase*

OK.

While there are many vaild criticisms of the BCP Quadruple Growth Bond, I happen to like it - provided all the caveats etc are made explicitly clear to any potential investor - as per Brendan's argument. 

I just did a valuation for an investor in the 2nd last Quad Growth Bond (started May 2003).

20,000 invested in 8th May 2003 has a value of 25,200 at the end of November - up over 25%.  

The ISEQ Overall Index of Irish shares is up 9%.  The FTSE is up 12%; the S & P 500 is up 15% (not if invested in from Ireland with the way the dollar has been). .   

While 25% is clearly not four times 9, 12 or 15, it's still an attractive proposition to be able to achieve more than the growth in world markets - about twice the growth.  I know there's a cap on each share.       

My summary: 

In a rising market the Quad Bond will do very nicely - as witnessed by the figures above.  If markets slide over the next 3 years, the investor will lose 10% of the original investment.  This sits comfortably with many. 

Does anyone disagree with this summary?  And please don't go into another long spiel about the problems with the product - I'm well aware of them. 

Benny


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## Carla (3 Dec 2003)

*Hiya*

Hiya Benny baby- you employed by BCP by any chance. Like do you have your own money invested in this stuff?


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## Brendan Burgess (3 Dec 2003)

*Re: Quadruple Bond*

Hi Benny

The Quad Bond provides a multiple of the growth in a very narrow range - probably somewhere between 0% and 10%. 

If the index rises by say 30% over the 3 years, you will be better off in a unit linked fund. 

To reach this 30% figure, they must go through a period when the Quad Bond has the advantage. 

So even at the figures you are quoting, the Quad Bond isn't a whole lot better than the Index. But the potential for an index investor is so much higher.

Brendan


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## Head Scratcher (3 Dec 2003)

*Eoghan Williams*

If he disliked the product so much, why did he give it four stars out of ten ?? I have long ago given up paying any heed to the views of this prat. I recall he gave Irish Life's Scope funds (a decent product, if a bit overpriced) one out of ten ... essentially because the markets had fallen since they created the funds. Then he lambastes trackers because they charge for providing a guarantee. The guy's a joke.


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## benny (3 Dec 2003)

Carla Baby,

I do not work for BCP, but am one of the Authorised Advisers supposedly doesn't understand this product. 

Brendan,

I thought you understood this product perfectly, but from your last posting it seems you don't.

If the Index rises by 30% over the three years, you will NOT do better in the index.  In the Quadruple Growth Bond, you will receive a receive a return of 60%.  How can 30% gross return be better than  60% gross return. 

How can you possibly say that the BCP figures presented above are not a whole lot better then the index - they're TWICE as good as the index.

Regards, 

Benny


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## Brendan Burgess (4 Dec 2003)

*Re: Eoghan Williams*

Hi Benny

I was trying to simplify the explanation to make a point.

This Bond has fooled most people, including most authorised advisors. It does not track an index. It tracks a basket  of stocks. 

It's very difficult to convey the implications of this. But if the index rises by 30%, the 17.5% limit on the growth of any share in the index probably reduces the effective growth to around 10%. In most examples I did, I found it very hard to find a situation where investing in the bond was better than investing in the index. The only realistic exception was where the index falls by over 20%. If this happens, then you are better off in the Quad Growth Bond than in the index. 

Brendan


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## Benny (4 Dec 2003)

*Quad Bond*

Brendan,

I've been using the trems "index" and "basket of shares" as the same thing, also for simplicity's sake.  It is reasonable enough to assume that the basket of shares we're concerned with will broadly reflect movement in world equity matrkets over the next three years.

If the basket of shares grows by 30% over the three years, an investor in an index will achieve in or around this gross return.  

The same investor in the Quad Bond will receive a gross return of 60%.  This is the effect of the multiplier.  17.5% X 4 - 10 - 60%.  

Do you disagree with this contention? 

Similarly, if the basket of shares rises by 10% on average over the three years, the return will be as follows:

10 x 4 = 40 - 10 = 30% 

So the index tracking investor will get a gross return of 10%. whereas the Quad Bond investor will achieve 30% gross return. 

If the basket of shares grows by more than 60% over the three years, you will have done better in gh index.   

You say the only example you can find where the Quad Bond would beat an index is where there's a fall of more than 20%.  I've just provided two more examples above. 

General rule: The Quad Bond will win out over a index in the event of ANY positive growth in the basket of shares - from 3.33% gross up to 60% gross. 

Why 3.33%?

3.33 x 4 - 10 - 3.33%

Whereas 5% X 4 - 10 = double the growth of the index. 

Rgds, 

Benny


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## daltonr (4 Dec 2003)

*Quad Bond*

Brendan,

There's a point your making that I have yet to address - probably because it strengthens your arguement and weakens mine. 

It's to do with the 17.5% cap.  I agree with you that the cap on each individual share will mean that the average performance will be lower in the BCP bond as opposed to an index. 

So the final return is indeed unlikely to be twice the return of the basket. 

It may not be far off though.  I suspect, although there's clealry no way of knowing, that your 10% valuation is under the mark.  So you might get in or around the same as the index, possibly more.  And this comes with a 90% capital guarantee, whereas the index is a bottomless pit.

In any event, I'm sticking by the product and look forward to the final outcome in 3 years. 

The performance of the fund so far, as outlined in a previous post, shows that it's not all bad news with this product.   

Benny  
(Name changed by Rd)


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## Brendan Burgess (5 Dec 2003)

Hi Benny

Most people just do not understand the huge impact of this 17.5% cap, which as I must point out again, is a cap on gains only. Losses on individual shares are not capped. 

Check out my examples in  to see the full impact. 

You can be quite sure that the financial engineers who sell the derivatives have done much more sophisticated models and have designed them at a price where BCP and the financial institution win while the customer loses.

*So why are previous bonds doing so well?*

Benny,

My last explanation of this was very poor. Let me simplify it even further.

Let's say that I invest in a simple ISEQ tracker fund. I will get whatever gains or losses occur over the period of my investment. No guarantees, no baskets, no keeping the dividends. Just a simple fund.

Now you invest in the Benny 5 year Double Growth ISEQ tracker fund. This is the same fund with only two differences. You will get double the growth up to a maximum return of 20%. You must keep it for 5 years and then cash it. 

You will be able to point out to me for the first year or two, or maybe even longer, thay your investment is well ahead of mine. The design of this product is such, that you must have a window where you will be ahead of me. 

So there is nothing extraordinary about the BCP bond being ahead of a direct investment. It had to happen during this stage of growth. But at the end of the 3.5 year period, who will be ahead? We don't know yet, but you can be quite sure that the financial engineers have stacked the odds in their favour.

Benny, the BCP bond has not closed yet. You should try to get your money and your clients money out of it.

Brendan


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## Benny (5 Dec 2003)

*Quad Bond*

Hi Brendan,

The focus to date has been comparing the BCP bond with an index tracking fund.  Whereas the debate with real investors tends to be between the BCP bond and a deposit-style instrument. 

This bond will perform not far away from an index tracking fund over the three years. I suspect it will actually out-perform - let's review the Quad Bond 2 in April 2007.  The multiplier effect is adequate compensation for the loss of dividends.  Crucially it has a 90% capital guarantee. 

I personally don't see a very signifcant value in this capital guarantee, but a good number of my clients do.  Rightly or wrongly, many will not even consider shifting away from deposits unless there is a capital guarantee. 

As a result, I am happy with the product as stands, while accepting your criticisms about the misleading title of the bond, literature etc., and will therefore not be advising clients to reconsider.   

I think we're simply going to have to agree to disagree. 

Regards,

Benny


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## daltonr (8 Dec 2003)

*Re: Quad Bond*

interesting piece on Morning Ireland this morning (I think it was Standard Life, someone might correct me), saying that the cost of capital guarentees are excessive at the moment, and people would be better off in a straightforward equities investment with a 6 to 10 year horizon.

See you in a few years Benny.  I'll be definitiely watching the this one with interest.  

BTW, I hope you've informed the clients that it is not possible to get quadruple growth.  They might still agree with you that it's a good product, but they deserve to know what you know, which is that the title and the literature is misleading.

Do they know that the guides to past peformance in the literature are not even for the same type of product?

Perhaps people don't want the subtleties and just want your opinion, but your opinion should be "This is a good product but not as good as the name might suggest".

-Rd


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## Skinflint (8 Dec 2003)

*.*

Or for really naive customers: "it doesn't do exactly what it says on the tin".


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## Benny (9 Dec 2003)

*Quad Bond*

Daltonr,

I don't need to be told how to do my job thanks.  

Any and all investors into this contract need to be made aware of its positive and negative aspects, as with all investment products.  I agree it's title is misleading.  Certainly any investors who has come through this office has been presented with a "warts and all" interpretation.        

Benny


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## Dynamo (17 Dec 2003)

*Trackers - Here We Go Again*

Hi Daltonr,

First of all, let me say I am not a proponent of the BCP Quad Bond, and this reply is more about trackers in general than that Bond in particular.

I am amazed how often this topic comes up on AAM, and how it is never understood. It's great that Nigel Dunne of Standard Life (for it was he) thinks the cost of guarantees in the capital markets is currently too high. I am perplexed as to how he knows whether it is too high for me, or Benny, or Benny's clients, or you, or Brendan, or indeed anyone else for that matter.

The point about trackers is that they are aimed almost exclusively at clients for whom capital guarantees are paramount. Were it not for trackers, most of these people would leave their money on deposit, losing the real value of it to inflation. Trackers (provided the proposition is fair) give them a low-risk way of potentially keeping pace with or beating inflation by a bit.

Over most periods, you'll do better by investing directly in equities. On a purely personal basis, I happen to agree with Nigel Dunne. But to invest directly in equities you have to be prepared to put your capital at risk - occasionally, as the past three years have shown, lots of risk. It's hardly shocking that a higher than normal proportion of investors have become more risk-averse given that recent experience, no matter what Nigel Dunne may think about it.


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## daltonr (17 Dec 2003)

*Re: Trackers - Here We Go Again*



> I am perplexed as to how he knows whether it is too high for me, or Benny, or Benny's clients, or you, or Brendan, or indeed anyone else for that matter.



I agree with you.  He can't know that.

But I think he was offering an opinion of the value of a product in the same way that we might offer an opinion on whether a particular share was underpriced or overpriced.  Obviously there's a range of opinions on the value of anything and one mans bargain is another mans ripoff.

If it's not fair for him to offer this opinion, then we might as well shut down the whole pundit profession.   Actually.....hmm.

Incidently the problem I see with the Quad Growth product is not whether it's good or bad value, but whether it's honest or dishonest.  Brendan has some issues with the product itself, upper and lower limits etc.  I have no issue with those issues,  I'd be happy to let them promote it and see who buys it.  

I just don't like consumers being misled. 

In any case it isn't something that I'd be interested in.  But then, I'm not 7 years from retirement and getting jittery.

-Rd


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## Dynamo (17 Dec 2003)

*Nigel Dunne*

Hi Daltonr,

That's the problem ... he wasn't (as I understand it, anyway - I didn't hear the radio interview, but read a newspaper piece) commenting on the BCP Bond specifically, but on the cost of guarantees generally. Trackers are the main vehicle for passing those guarantees on to clients. As you agree, there's no way Nigel Dunne can know what value anyone else places on a guarantee. The market for guarantees (if you know what I mean) operates like any other market - supply and demand. If lots of people want them, then the price generally goes up. But hey, that's how markets work.

I agree with you about misleading products - that's why I said provided the proposition is fair. If it *is* fair, then I have no problem with trackers being marketed to suitable customers, who can make their own minds up about the value of the guarantee. In the good old days {sigh} it used to be simple - you got 70% participation or whatever, so it was easy enough to see what you were giving up. I know things are more complex now, but I don't interpret that as meaning the whole tracker market is compromised.


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## darag (18 Dec 2003)

*Re: Trackers - Here We Go Again*

dynamo, you may be sighing but i don't see how trackers are anything but
a mug's game.  the cost of guaranteeing a return is the same as the cost
of putting money on deposit;  in both cases your capital is guaranteed
but you suffer the effect of inflation.  i do it myself by leaving some
money on deposit in case of a rainy day.  in the case of trackers, the
value of your interest goes in to a long-shot gamble.  i don't see any
value in putting money into gambling that the stock market will move in
a particular way over a particular period of time.  personally i feel i
know more about rugby; as a result i'd feel more comfortable trying to
out-guess paddy power's team of actuarial sports experts over the next
european cup season than trying to out-guess the financial derivatives
markets which are closely monitored by the brainiest people in the
world.  attempting to outguess the latter can not be considered to be a
legitimate investment exercise.


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## daltonr (18 Dec 2003)

*Re: Trackers - Here We Go Again*

Nigel Dunne's interview on the radio didn't contain anything startling.  Be basically said Bonds were expensive.  But when interest rates are as low as they currently are you'd expect Bonds to be expensive.

Also, given the fact that a significant number of people seem to think that equities are more likely to move up than down, guarentees are not considered AS IMPORTANT as they might be.  The combination of High Cost and Low Importance is what he was referring to.  Or at least that's how I interpreted what I heard.

Now, of course there are people who've been burned recently in equities, or whose friends/relatives have been burned, and who are wary about equities.  For these people the importance of a guarentee is high, and Nigel Dunne's comments don't apply (as much).

I have no strong opinion one way or the other on trackers.  I take each product as it comes, but given my attidude to risk, I don't find them attractive.  That's not to say that when I'm 50 I won't be seeking out expensive guarentees.  Maybe I will.

I think we agree on one thing. the greatest problem with investment products today is not whether they are good or bad, but whether they can be understaood by the investor.
Whenever I see complicated products I wonder what that complexity is trying to hide, and my usual conclusion is, lower returns for the investor, higher profits for the institution.

If I see dishonesty on top of complexity then I run a mile, I don't care how good someone tells me the deal is.

But I'm a cynical old fool.    

-Rd


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## Benny (18 Feb 2004)

*Latest*

Hi all,

Latest valuations I have to hand for the BCP Quad Bond launched in May 2003 shows growth of 36.65% to end Dec 2003 versus the MSCI World Free Index of +23%.

I have been communicating this with clients and needless to say there's been positive feedback across the board.   

I wish we had taken bets on this product with its AAM critics. 

Regards, 

Benny


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## <A HREF=http://pub145.ezboard.com/baskaboutmoney.s (18 Feb 2004)

*Re: Trackers - Here We Go Again*



> Latest valuations I have to hand for the BCP Quad Bond launched in May 2003 shows growth of 36.65% to end Dec 2003 versus the MSCI World Free Index of +23%.



So what is that 36.65% four times of? It's not four times the index that you mentioned anyway. Surely the "quadruple" issue was the kernel of this discussion and nobody ever said that the product would necessarily make no returns or a loss?


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## daltonr (18 Feb 2004)

*Re: Latest*



> I wish we had taken bets on this product with its AAM critics.




I'm still open to bets.  Do you want to open negotiations?

-Rd


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## darag (19 Feb 2004)

*Re: Trackers - Here We Go Again*

hi benny. how exactly do you break this news to your clients?
"hi, you know that 3 1/2 year product you invested in? if it
had been a six months product you would have been up 
36%!! also if my aunt had balls...."

the gain is purely theoretical and it is makes no sense to 
communicate this notional value to your clients given that
they cannot realise any gain.  that's the nature of these
products given how they're constructed using bonds and 
derivatives.  it's like a bookie telling a punter that they're up 
100 quid a mile into a three mile race.

by the way if you are laying odds, what odds would you offer
if i wanted to bet that this bond will underperform a 
reasonable fixed term deposit rate - 3% for example?


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## Brendan Burgess (19 Feb 2004)

*Re: Latest*

darag said:


> it's like a bookie telling a punter that they're up
> 100 quid a mile into a three mile race.



darag - that's a great comparison. I wish I had thought of it when I was making my submission to IFSRA on the advertising of the product.

If BCP reports these figures to their customers, then the customers should be allowed to cash them in at the quoted values.

Brendan


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## Benny (19 Feb 2004)

*BCP*

You guys really are a pig-headed bunch.

The not-an-inch form of discourse is truly depressing. 

Any give? From anyone?  Any remote possibility that isn't as bad a deal for the investor than has been made out heretofore?

If it ends up doing well over the nest 3 years I've no doubt there'll still be no give.   

So an investor who has a long-term horizon of say 10 years in Quinn Life Index Tracking fund or a basket of 10 leading Irish shares couldn't care less if the investment has grown during the first 8 months or not?  

"Hello Mr. Client, your investment is down 36% since last May"

Or 

"Hello Mr. Client, your fund is up 36% since last May"

Who is going to be happier? 

What does it matter if the fund can be accessed or not? 

In the same way the punter mentioned above has no notion of cashing in for 10 years, BCP investors have no notion of cashing in for 3.5.  This was made VERY clear at the outset.  

Valuations sent our from this office also made it very clear that there's no way of knowing future market directions.  It also made clear that the maximum return is 60%, but that having achieved 36% in the first year, it's over half way there.      

The 4 times debate has been accepted before & I've no intention of covering this again. 

I've little doubt this bond will significantly beat prevailing depodit returns.  

I am utterly bored by this conversation & have no intention of looking at it again until I post the final results in three years.

Good luck!

Benny


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## darag (20 Feb 2004)

*Re: Latest*

hi benny, i don't feel i'm one of "the guys".  i'm not involved
in the industry and have a completely amateur interest in 
personal finance.  however, i also have an amateur have an 
interest in gambling and the stock market and i've studied
how these products are constructed by the industry.

i dunno whether you deliberately ignored the point of my 
previous message or whether you're too stubborn to even argue against my claim that it is disingenuous to say the 
least to quote your "36% gain".  it is not a gain by any 
interpretation of the word.  

if you don't understand the difference between someone 
owning units in a fund which are worth 36% more than they 
were when they bought them and your "good news" then i'd 
suggest you don't understand the fundamental difference 
between a forward contract and an index tracker.  do you
understand that your clients have effectively bet that some 
financial indicator will be at a certain level at a particular 
point in time?   the fact that the financial indicator is at
a particular level at this point of time has no relevance to
to your clients.

anyway, why not put your money where your mouth is?
i have nothing to do with the industry at all - i'm a consumer
- but i enjoy the odd flutter.  i'd be more than happy to bet 
you 500 quid if you offer me 3-1 against the fund 
under performing a decent deposit return - say 3%? given 
that it's already "up 36%", i feel i'm probably being over 
generous. you should be delighted to lay these odds.


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## <A HREF=http://pub145.ezboard.com/baskaboutmoney.s (20 Feb 2004)

*Re: BCP*

Benny sounds like Laser already... :rolleyes  



> So an investor who has a long-term horizon of say 10 years in Quinn Life Index Tracking fund or a basket of 10 leading Irish shares couldn't care less if the investment has grown during the first 8 months or not?
> 
> "Hello Mr. Client, your investment is down 36% since last May"
> 
> ...



Comparing an open ended, low charges, index tracking fund with a technically convoluted, high charges (and no dividends), fixed term tracker bond is like comparing apples with oranges. I'm also an amateur but even I know that....


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## rainyday (20 Feb 2004)

*Re: Latest*



> Quinn Life Index Tracking fund ..."Hello Mr. Client, your investment is down 36% since last May"



This is pure fiction. Almost all equity funds are up over the last year. My QL Celtic fund is up about 12%


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## Merlin (1 Apr 2004)

*Pure Sorcery*



> it's like a bookie telling a punter that they're up
> 100 quid a mile into a three mile race.


Our Founder has already commended the aptness of this analogy.  But I think it is even more apt than either its originator or B realise.

You see the very nature of this beast is that with a strong gallop (i.e. bull markets) BCP Quad gets off to a flying start.  Think about it.  Let's say a week after launch markets have in general risen by say 2% well BCP Quad is almost certain to be up around 8%, well clear of the field _(ignoring that it is starting 10% behind the rest, which BCP are wont to do)_.   That's because his two main handicaps don't kick in until the second and third circuits of the marathon.

First handicap - a cap of 17.5%.  Very unlikely that this will kick in until well into the race.

Second handicap - individual capping - even if a basket is up say 10% its individual stocks will diverge over time which as B has pointed out will mean an individually capped basket will tend to underperform the index or basket capped in aggregate.  Again, think about it, this bit of sorcery can't possibly kick in until well into the race, you have to give the stocks time to diverge.

BCP Quad is currently well out in front (ignoring the 10% headstart he gave the field) but he is certain to blow up in the next two circuits, not to mention the final hill when the averaging will slow him down further on top of his two welter handicaps.

What is so terribly disturbing about this is that the trainers of BCP Quad are openly flouting it's current race position to encourage more punters to plunge in.  

The Jockey Club (IFSRA) should be stood down.


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## Brendan Burgess (1 Apr 2004)

*Re: Latest*

Merlin

Brilliant. Will you be using that in a submission to IFSRA on tracker bonds? If not, I will use it.

Brendan


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## Merlin (1 Apr 2004)

*BCP Quad*

Oh Founder,

The BCP angle is all yours. 

Almost all your criticisms have been valid and IFSRA's dismissal of them reflects poorly on them.

Just one I would caution you on.  The 10% capital at risk is not really a charge - it is part of the overall engineering.  To know the charge one would need to know what was paid to the bank after they laid off the deal in the derivatives market.  It may well be of the order of 10% - this is one of the problems with Trackers - you just can't tell.


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## <A HREF=http://pub145.ezboard.com/baskaboutmoney.s (1 Apr 2004)

*Re: Latest*

If I recall correctly either BCP or Liberty are currently running radio advertisements which make great play of the fact that their tracker bonds are showing such and such a level of gains since inception regardless of the caveats raised above with this sort of snapshot treatment of such fixed term investments! :\


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## Merlin (11 Jun 2004)

*Bloody Cheeky Pups*

Oh Founder, I saw on another topic that BCP had made an outrageous defence of their promotion in the submission to IFSRA.

I checked and it is true.  Let me repeat.

Thay are against backtesting - what? aren't they the worst offenders.

Oh no, what BCP show is how previously designed Trackers from their stable have performed.  By definition this isn't backtesting as none of those previous Trackers is quite the same.  It is showing how skilfull they are in designing these products - it sort of a CV.

This is cynical nonsense - thay have turned a clearly misrepresentation into a virtue.

If IFSRA buy any of that, they should ditch this consultation mullarkey.


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