Ed Conway on ‘The Material World’ – Spring Drinks 2026
Hosking Partners is a London boutique founded in 2013 by Jeremy Hosking, a portfolio manager at Marathon Asset Management for over 25 years. It runs a single global equity strategy built on the capital-cycle, supply-side approach — contrarian, long-term, and unusually diversified (350+ holdings) under a multi-counsellor model, managing around $5.5bn.
In plain words
This report explains that Hosking Partners, an asset manager, is legally registered in the UK, US, South Africa, and Australia, but only serves professional clients (like wealthy institutions or individuals), not the general public. For ordinary investors, this means you shouldn't rely on its advice unless you qualify as a 'professional client' or 'accredited investor' (terms for financially sophisticated investors). It also notes that non-US clients aren't protected by US SEC rules, so legal recourse differs. Worth reading to understand these compliance rules and avoid misusing the information.
Hosking Partners LLP publishes a regulatory and legal disclosure statement, clarifying that it is authorized and regulated by the UK Financial Conduct Authority (FCA) (registration number OC382151), registered with the U.S. Securities and Exchange Commission (SEC) as an investment adviser under the
Theme and Background
This chapter primarily introduces the legal entity identity, regulatory registration status, and the restricted scope of clients of Hosking Partners LLP, providing a foundation for readers to understand whether the institution has official endorsement and operates in compliance. The report notes that investors should confirm in advance whether they meet the qualified client criteria in their jurisdiction, and should not act based on this material otherwise.
Core Thesis
The report’s core judgment is that Hosking Partners is a professional asset management institution that has obtained authorization or exemption qualifications in several major financial regulatory jurisdictions globally (UK, US, South Africa, Australia). The core access standard for its services is that they are only available to "professional clients," "qualified investors," "qualified purchasers," or "wholesale clients", and are not open to the retail public. This strict restriction reflects the institution’s prudent approach to regulatory compliance and client risk suitability.
Counterintuitive judgment: Although Hosking Partners is registered as an investment adviser with the US SEC, it has not yet complied with the provisions of the Investment Advisers Act concerning non-US clients, and the Act’s provisions also do not apply to non-US clients — meaning that clients with non-US status are not entitled to the same protection under US SEC in legal relationships, and the legal recourse pathways differ.
Key Arguments and Data
- UK FCA: Authorized and regulated, registration number OC382151, VAT number 167151705.
- US SEC: Registered as an investment adviser under the Investment Advisers Act of 1940, but does not apply to its non-US clients; US clients must simultaneously meet the conditions of a "qualified investor" (Securities Act of 1933 Rule 501(a)) and a "qualified purchaser" (Investment Company Act Section 3(c)(7)).
- South Africa FSCA: Registered as a financial services provider under the Financial Advisory and Intermediary Services Act (FAIS Act), FSP No. 45612.
- Australia: Exempt from holding an Australian financial services license under ASIC Class Order [CO 03/1099], services only available to "wholesale clients" as defined in the Corporations Act.
Companies/Assets Involved
The text does not mention any specific investment targets or listed companies. The entities involved are only:
- Hosking Partners LLP: The issuer of this report, a fund manager licensed/registered in multiple jurisdictions, bullish on its compliance framework.
- FCA, SEC, FSCA, ASIC: The identity backgrounds of various regulators, serving as endorsements of the institution’s legitimacy.
Investment Implications
- Investors must first assess their own client type: Only individuals or institutions that meet the definitions of "professional clients" in the UK, "qualified investors + qualified purchasers" in the US, "financial services provider clients" in South Africa, or "wholesale clients" in Australia can legally receive the institution’s services.
- Compliance itself does not constitute a guarantee of returns: Registration/exemption status in multiple jurisdictions indicates that the institution has a compliance review system, but investment value will still increase or decrease due to market fluctuations, exchange rates, and changes in underlying assets.
- The scope of legal protection varies across regions: Non-US clients are not entitled to the same protection under US SEC investor protection provisions, and should understand the impact of local legal jurisdiction on their rights and interests.