This survey was designed and conducted by Farzin Yazdi – Head of Investor Visa at Shard Capital.
In early Feb we asked for your thoughts around proposed reforms to Tier 1 (Investor) Visa and the results have been great.
Firstly, I’d like to thank everyone who took the time to complete the survey, as well as those who gave their input in developing the questions and structure.
Following the December 5 announcement by the Immigration Minister, to temporarily suspend and reform the UK Tier 1 (Investor) Visa category, it was our understanding that there would be no consultation with stakeholders.
This prompted my move to create a survey to give my fellow industry colleagues an opportunity to have their say on what the visa reforms should include, how they feel the visa requirements and process should be structured, and then present the survey findings to key decision makers including the Home Secretary, Immigration Minister and Migration Policy.
Whilst not a great comparison, the last time this visa category called for an industry consultation was in 2014. At the time, there were just 43 respondents. With this recent survey conducted, we’ve had 160 responses. A breakdown of respondents can be viewed in the final response (Q28).
I am pleased to advise that; whilst not willing to meet, Immigration Minister, Rt Hon Caroline Nokes MP has responded to the survey being conducted, saying …the survey is of interest as it closely relates to some of our proposed reforms. Ms Nokes has also stated, the UK welcomes legitimate and genuine investors, and the reforms are aimed at protecting the UK and increasing economic benefit. Migration Policy has also reviewed the survey in detail and I have discussed points raised at great length.
There were a number of interesting observations from the survey; a few of the key highlights are noted below –
Question 8 in the survey asked – “The Home Office may require applications to demonstrate that they have been ‘in control of funds for at least two years’.” Interestingly, 40% of respondents said, ‘Not necessary’.
Question 9 in the survey asked – “Do you believe Immigration Rules should be aligned to the widely accepted anti-money laundering standard the JMLSG (Joint Money Laundering Steering Group) Guidance? 74% of all respondents said, ‘Yes, agree’.
In the recent Statement of Changes to Immigration Rules, HC 1919 states, ‘No more Government Bonds’. Question 3 of the survey asked – “Does an investment in UK government bonds benefit the UK economy?” 54% of all respondents said, ‘Yes, agree’.
Question 15 in the survey asked – “Do you believe it is fair to restrict Investor Visa applicants to invest in higher risk investments, even if the investment may not be suitable to the individual?” 54% of all respondents said, ‘Unfair – and should not be permitted’.
Question 17 in the survey asked – “Do you believe UK government bonds should remain a qualifying investment for Tier 1 (Investor) Visa applicants?” 72% of all respondents said, ‘Yes, agree’.
[ I welcome you to share and utilise the results of this survey as you see fit, however please ensure author and source are appropriately referenced.]
So what do the reforms mean? Business as usual?
Yes! Not much has changed, and in my opinion these reforms will help reach the desired outcome. Ultimately it’s a step in the right direction.
The 2 year ‘control of funds’ rule versus 90 days shift does not change much on our side, as we look into this even deeper when onboarding and opening client accounts. Additional responsibility has been placed onto financial firms such as ourselves. This is something I welcome as it emphasises that investing in the UK for the purpose of a UK Tier 1 (Investor) visa is a specialist trade. Lawyers say to me daily that clients have their own bankers, but do they have this expertise?
Whilst I don’t agree personally either way on removing government bonds, nor do I object the removal as I can see the reasoning behind the decision. From a client risk perspective, similar corporate bond portfolios can be created by increasing credit risk from AA to BBB – which is not significant considering the investment universe.
Pooled investments where you are coinvested with entities such as the British Business Bank makes a lot of sense. Whilst not for everyone, it does bring more economic benefit to the country. Please do get in touch if you wish to discuss this.
So in summary, the new rules and reforms may take a few months to be understood, although I strongly believe it will be business as usual.
If you would like more information on the Tier 1 (Investor) Visa, or would like to discuss this survey, please contact Farzin Yazdi – firstname.lastname@example.org
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