Pursuant to § 14 para. 1 no. 2 in conjunction with Annex 3 of the BFSG, we are required to make information about the functioning of the securities services we offer accessible to the public in an accessible format. This information must also explain how we meet the legal accessibility requirements with respect to the securities services we offer. All consumers should have easy access to the services offered and should not have to rely on external assistance. The information must not exceed language level B2 of the Common European Framework of Reference for Languages of the Council of Europe. This means that it can be assumed that the essential content of even complex texts on concrete and abstract topics can be understood.
We offer the following securities services:
Financial portfolio management (asset management)
Investment advice
Investment brokerage
Contract brokerage
In everyday language, asset management is commonly used, whereas in legal provisions it is referred to as “financial portfolio management”. For this service, we provide the following information and use only the everyday term asset management.
As part of asset management, we independently decide—without prior consultation with you—which financial instruments to buy or sell for your securities account and at what time. We are not required to obtain your approval beforehand. A securities account is a special type of bank account in which securities are recorded.
To carry out asset management, you need both a securities account and a settlement account. The settlement account records the funds used to purchase securities. Proceeds from sales, returns generated within the asset management mandate, and costs are also credited or debited to this account. In addition to a settlement account in euros, there may be one or more accounts in foreign currencies. The securities account and settlement accounts are not managed by us but by a bank. Together, they form the so-called “portfolio”.
Asset management is considered “independent” when the asset manager is not tied to the products or services of a bank or an insurance company. The selection of investments should therefore be as free as possible from the sales interests of banks or insurance companies.
Asset management relates to investment opportunities in the form of “financial instruments”. Financial instruments include:
Securities such as stocks, bonds, certificates, and warrants
Units of investment funds
Derivatives
Real estate, precious metals (e.g., gold), classic cars, works of art, and crypto assets (e.g., Bitcoin) are not financial instruments and are therefore not part of asset management.
In asset management, your assets should be invested in your best interest and according to your individual needs. For this purpose, we must collect certain personal data and information about your preferences (= investor profile) as follows:
Your financial situation (your assets, ongoing income, expenses, other obligations, and the amount available for investment)
Your investment objectives (e.g., long-term asset generation or retirement provision)
Your investment horizon (how long you want to invest your money; long-term or short-term; when you will need your money back)
Your risk tolerance (the extent of fluctuations or losses in the managed portfolio you are willing to accept)
Your sustainability preferences (e.g., whether ecological or social criteria should be considered; exclusions of certain industries; promotion of environmental or social objectives)
Your knowledge and experience (your understanding of risks associated with investments)
Based on this information, we recommend suitable investment guidelines. These guidelines must ensure that your portfolio corresponds to your interests and needs. They form part of the asset management agreement and are binding for us in ongoing investment decisions.
To carry out asset management, we require a bank authorization from you. This authorization allows us only to initiate purchases and sales in your bank-held securities account. It does not allow us to transfer your assets to our own accounts or to third parties.
Before entering into the asset management agreement, we also inform you about the expected costs.
After the agreement has been signed, the securities account and settlement account have been opened, and the authorization has been granted, we begin asset management. From that moment, we act independently and buy or sell financial instruments for you, following the agreed investment guidelines.
We provide you with regular reports containing specific information about the execution of asset management. These reports generally relate to a past reporting period of 3 or 12 months. Some information refers to a specific date, usually the last business day of the reporting period.
Reports may include:
Composition and valuation of your portfolio (= Which financial instruments were included in your portfolio on the reporting date? How much were the individual financial instruments worth on the reporting date?)
Performance of your portfolio and the benchmark (e.g., an index), if agreed with you, during the reporting period (= How did the value of your financial instruments and the benchmark develop during the reporting period?)
Fees and costs (= How high were the costs for asset management during the reporting period?)
Balance of your settlement account at the beginning and at the end of the reporting period
Incoming payments, e.g., dividends and interest
Individual transactions, meaning purchases and sales of financial instruments, provided that you do not already receive regular information about these from the custodian bank.
Suitability explanation, meaning an explanation of how the initiated purchases and sales complied with the agreed investment guidelines.
We inform you quarterly about the composition and performance of your portfolio.
We also notify you if your portfolio experiences losses exceeding certain thresholds. By law, the threshold is 10%. Each time the value drops by an additional 10%, another notification is required. Lower thresholds may be agreed in the contract.
The asset management agreement does not have a fixed term. You may terminate the agreement at any time and without giving notice. Termination cannot be declared orally; it must be made in text form (for example by email).
By contrast, we ourselves may only terminate the agreement by observing a notice period defined in the asset management agreement.
You receive separate information about the costs of asset management at the outset. For performing asset management, we receive a regular fee. This amounts to a certain percentage of the volume that we manage for you (the so-called fixed fee).
The costs for maintaining the securities account and the settlement accounts by the bank are charged separately by the bank. This also applies to the costs for the purchase or sale of financial instruments. Instead of charging the various items separately, the bank may also agree on a flat cost rate with you (the so-called “all-in fee”).
A right of withdrawal exists only if the asset management agreement has not been concluded on our business premises, but for example via the internet or by telephone. In that case, you may withdraw from the asset management agreement within two weeks. In such a case, you receive separate statutory information from us in the form of a withdrawal notice. This informs you about all further details of the withdrawal. The withdrawal period of two weeks does not start until the agreement has been concluded and we have duly provided you with the withdrawal notice.
Note: Even if you withdraw from the asset management agreement, the financial instruments purchased or sold for you remain unaffected. This means that the purchases or sales made by us up to the time of withdrawal are not reversed despite the withdrawal.
The statutory provisions require us to meet certain accessibility requirements when providing our securities services. We ensure this as follows:
We provide this information to you using various sensory means of access. These are:
Personal delivery in paper form on our business premises
Reading aloud by our employees
Retrieval from our company website
The content of this information is formulated in understandable language. The B2 language level of the Common European Framework of Reference for Languages is not exceeded.
The B2 language level does not apply to the contract and the associated pre-contractual information.
You can find information about our company and the services we offer on our website. The content of our website complies with the general principles for accessible web content. These are:
Perceivability: As many users as possible should be able to perceive the information and other functions. To this end, we ensure that explanatory alternative texts are available for images, graphics, and videos.
Operability: As many users as possible should be able to operate the functions. To this end, we ensure that the web content can be operated using a keyboard.
Understandability: We design the web content to be readable and, as far as possible, to use plain language for as many users as possible.
Robustness: The web content is compatible with assistive technologies. This means that it is suitable for programs that read text aloud, enlarge text, or convert speech to text.
The asset management agreement is concluded in text form with your personal signature. Other documents are also usually provided in text form. Descriptions are added to graphic depictions in the documents. All documents in text form can be read aloud and explained in detail.
After the asset management agreement has been concluded, asset management generally takes place without further personal communication. We make the individual investment decisions without consulting you.
The competent authority for monitoring compliance with the accessibility requirements is:
Marktüberwachungsstelle der Länder für die Barrierefreiheit von Produkten und Dienstleistungen (MLBF, under establishment)
c/o Ministerium für Arbeit, Soziales, Gesundheit und Gleichstellung Sachsen-Anhalt
Postfach 39 11 55
39135 Magdeburg
Telephone: 0391 567 6970
Email: ed.tlahna-neshcas.sm@FBLM.
Status as of: 28.06.2025
Important: Please note that the asset management and investment advisory services of Gerd Kommer Invest GmbH are provided solely in the German language.
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