ETF Q&A
We have recently shared the news that ETFs are now available on Mintos. If you have any questions about ETFs on Mintos, here’s your chance to ask away. Representatives from Mintos will answer your questions.
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Thanks for this Q&A
First question :
Will you try to steal money with ETF like you do with the Notes ?1 -
What have you done to make individual ETF investing less advantageous than ETF Core?
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Will you try to steal money with ETF like you do with the Notes ?
@Vincent Merlino, Mintos is the middleman between us and the loan originators. You can accuse Mintos of bad management or bad execution, or not defending our interests well enough, but they're not stealing from investors, so please don't call it like that. Keep the forum discussions polite.
We can see that some loan operators are "stealing", e.g. Wowwo (current status: "The lending company has been unwilling to cooperate with us and pay what they owe to our investors"), but this isn't Mintos stealing, this is Wowwo.With ETFs, Mintos has a less active role in managing the shares, so I expect there's less possibility of mistakes. The "ETF originators" are well-known companies like Amundi, iShares (BlackRock), Vanguard, etc. that won't crash or refuse to pay money back like some loan originators do.
There could still be problems due to Mintos interference. E.g. if one day Mintos decides to change the internal composition of an existing "ETF core" portfolio you own, without your consent, and causing losses that you don't want, or increasing the risk. Imagine they decide to include an ETF you don't like and they force you into mandatory rebalances that move money to that unwanted ETF.Mintos: I would like to ask how often (if ever) Mintos wants to change the specific ETFs inside an "ETF core" portfolio or the % weight of the ETFs inside the portfolio. And would the investor have the option to reject the proposed change and keep the existing portfolio, without being forced to sell.
I understand that some changes may be mandatory, e.g. if an individual ETF stops existing; will Mintos then replace it with a similar ETF?3 -
Danielsc Thank you for your contribution and for emphasizing the importance of maintaining a polite and constructive atmosphere. We appreciate your commitment to fostering respectful discussions.
In response to your question about Mintos ETF Core Portfolio Changes, we periodically review all portfolios several times a year to ensure they align with market trends and investment objectives. Should there be a need for changes, whether, in the specific ETFs or their weightings within the 'ETF core' portfolio, we commit to informing our investors well in advance. This allows ample time for investors to review and respond to these updates. In the rare event of an ETF ceasing, we will strive to replace it with a similar ETF to maintain the portfolio's integrity and objectives.Ondrej Bobek Thank you for your question. Our approach at Mintos focuses on maximizing the benefits of diversification, a key advantage of our 'ETF core' portfolio over individual ETF investing. For a more in-depth understanding of how our core portfolio stands out, we highly recommend our detailed blog article, in which we dissect and compare the management of single ETFs and Mintos Core ETF portfolio. You can read more about it here: Mintos Blog: ETFs vs. Mintos Core ETF.
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Lucja (Mintos) what approach would you recommend to invest in ETFs? Let's say that you have 1000 euro, would it be best to spread them over time (like 100 each week, over 10 weeks) or invest them all together? The reasoning would be to not potentially be affected by a particular market situation, but spreading the risk of entering over multiple weeks. Would it make sense? Would it be best once per week (100/week) or per month (400/month) or all together (1000/once)?
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Eric Slan I don't think Mintos can advise you on that specific question, as it would step probably to close to investment advise. That said, for instance Vanguard regularly updates their research where they compare lump-sum (LS) investing versus cost averaging (CA). In their April 2023 publication they show:
Using MSCI World Index returns for 1976–2022, Finlay and Zorn calculated that LS outperformed CA 68% of the time across global markets measured after one year. However, CA was still better than remaining completely in cash; it outperformed cash 69% of the time.
While in 2/3rd of the cases LS outperforms CA, in 1/3rd of the cases CA outperforms LS. In the end it will depend on the actual market conditions and fluctuations in the future, but with LS you have a better chance for out performance. However personal preferences are important as well, in case you have a large sum to invest. You might feel more comfortable to do this in smaller steps, even if that means you might under perform during the starting period. At the moment you are fully invested (either in one lump sum or multiple smaller cost averaging deposits) it no longer makes a difference.
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Lucja (Mintos), another question or comment about ETFs: who actually owns what in an ETF account. I've seen https://help.mintos.com/hc/en-us/articles/21709307917073-Will-I-be-the-holder-of-the-ETF but it's not enough and I think the ownership matters should be explained in detail in the user agreement, not just in a help section or in the forum.
The user agreement, in version 15.1 part 18 (The Financial Instruments Account and safekeeping of Financial Instruments), is short and mentions that Mintos will keep track of ownership and will not 'hold' any 'Note'. But it doesn't say who's the owner or the owner's rights and limitations. And that's the only time that investment ownership is mentioned in the user agreement.
I'm not a lawyer but I see a few questions like:
- who owns the ETFs
- what does it mean 'co-owning that fractional ETF unit with other investors'? (as seen in the last link). Can all these co-owners get together and vote and decide what to do with it? (independently of Mintos)
- does it mean that the investor co-owns it with other investors and with Mintos too?
- is that co-ownership a real ownership, or just a private agreement between investors and Mintos (while Mintos keeps the real and sole ownership). The terms might be direct vs. indirect ownership, see https://en.wikipedia.org/wiki/Indirect_holding_system . In an indirect holding system, the investor ownership is just an entry in Mintos's accounting system
- the co-ownership is justified by Mintos because Mintos offers fractional ETFs, parts of ETF. But if an investor accumulates enough fractions to hold full portions of ETFs, does the ownership change?
- how does ownership affect tax reporting. If the investor owns the 5 ETFs in your current portfolio he can declare income from 5 ISINs. But if the ownership is indirect and the ETFs are owned by Mintos (not by the investor), then the investor owns just 1 product (Mintos) and must report income from that 1 source
- etc. This topic seems difficult. But having and understanding ownership of the investments is important. By the way, I realize that some investment banks offer similar services (buying fractional funds and fractional ETFs, sometimes though an omnibus account, where they are the actual owners) -- I'm not implying that Mintos is doing anything out of the ordinary; I'm just saying it's not fully explained yet.
Thanks
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Hi Danielsc
Thank you for reaching out with your questions. We've forwarded them to the appropriate team for further review and will ensure you receive a detailed response as soon as possible. In the meantime, we truly appreciate your patience and understanding.0 -
Dear Danielsc,
Thank you for your patience.
Terms and Conditions of Mintos Investment Platform (Terms and Conditions) do not include every applicable provision of the laws and regulations as these provisions are implied by the nature of the laws, which does not require replicating law provisions in a contract unless it is required so by the law.
Therefore, Terms and Conditions should be read and interpreted together with the applicable laws.
According to the provisions of Section 125 (1) of the Financial Instrument Market Law of the Republic of Latvia “Financial instruments belong to the acquirer thereof from the moment they are registered in the financial instrument account of such acquirer”.
This essentially means that, as soon as ETFs and/or their fractions are registered on a Financial Instruments Account as per Terms and Conditions, these ETFs and/or their fractions belong to the Investor.
Also, when choosing to invest in an ETF portfolio with Mintos, there are Terms and Conditions of ETF Portfolio Management which are an integral part of the Terms and Conditions. These Terms and Conditions of ETF Portfolio Management provide that “Investors, by activating the ETF Portfolio acknowledge being aware that ETF Portfolios will consist of fractions of ETFs, which are just portions of single ETF units and that they will not hold a legal title (actual ownership) of an ETF unit in their Portfolios unless they have invested enough funds so that fractions of a particular ETF together form a full ETF unit. Also, Investors are allowed to invest or withdraw money from their ETF Portfolios, but they are not allowed to trade respective ETF units (fractions of ETFs) or request to transfer ETF units (fractions of ETFs) outside the Platform''.
Thus, to sum it all up, when you invest in a fractional ETF unit on Mintos, you are co-owning that unit with other investors on Mintos. The custodians (banks or other regulated third-party institutions) that hold the ETFs on your behalf keep track of the ownership of each ETF unit (actual legal title to the whole ETF unit), and Mintos keeps track of the ownership of each fraction of those ETFs.
Mintos Investors are the owners of ETFs and/or ETF fractions that are registered in the Financial Instruments Account with Mintos, but ETF fractions have no actual legal title to a full ETF unit, which is conjointly owned with other Mintos Investors and is held in custody with Mintos custodians.
As regarding taxes, please refer to the Terms and Conditions and in particular to paragraph 10.12 which states that “Mintos, when providing services under these Terms and Conditions, does not act as a financial, tax, legal, or investment adviser”, and, therefore, in accordance with paragraph 9.4 of the Terms and Conditions “the Investor is responsible for duly declaring and paying all taxes arising from the use of the Platform by the Investor pursuant to the laws of the Republic of Latvia and/or any other regulation applicable to the Investor. Mintos will deduct taxes, duties, and other mandatory payments, which have to be withheld by Mintos pursuant to the laws of the Republic of Latvia from the funds to be disbursed to the Investor.”
We hope this helps you understand ETF ownership better.0
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