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Posts Tagged ‘client’

Disclosure, fun and games for 2012 and the run up to RDR

Friday, October 21st, 2011

As long ago as February this year the FSA published its consultation paper CP 11/09 which encapsulated the changes needed in retail investments product disclosure to reflect RDR adviser charging and to improve pension scheme disclosure. Consultation closed on this back in May. We still await final rules. This was followed in August by a Policy Statement PS 11/09 linked to CP10/29 which is focused on implementing RDR within platforms and nominee-related services. It is worth looking at the Disclosure requirements of each in turn as they will collectively create a significant extra burden for the market. The reasoning for CP11/09 is as follows: consumers need more information about products’ charges, risk levels and the main product features so they can make informed decisions. From the point of view of providers many have been crying out for more practical flesh on the bones of RDR changes which CP11/09 delivered in several key areas.

Specific disclosure requirements are as follows:
1. Where Reduction in Yield figures are shown they must be shown for both product charges and for overall charges from all parties
2. Disclosure of bank interest on cash held in a SIPP and provide clarity on how much interest is being retained (this becomes a requirement by April 2012)
3. There is also a need for proper reflection of inflation in SMPIs (7% less 2.5% inflation for example). Inflation adjusted projections are to become mandatory
4. More descriptive table headings are required for projections
5. The length of projection tables needs to be reduced so that rows will only be required for chosen year of retirement and for the first 5 years of the pension. Both changes must be implemented for in-force illustrations as well as new ones.
6. SIPPs will take on a wider definition of any pension product that allows fund or asset class choice
7. Product providers that facilitate payment of adviser charges will be required to describe product and adviser charges separately (i.e. unbundled). New format will need to show the effect of each type of charge in the ‘effect of charges’ table and ‘reduction in yield’ information. RDR already bans payment of commission for advised sales of investments and personal pensions including SIPPs
8. In addition, when adviser charges are changed a new Key Features Illustration (KFI) must be issued.
The main criticism levied at the FSA is how little time is being left to providers to make all these changes. Some providers had already issued requirements for adviser charging solutions and have had to make adjustments to these since the arrival of CP11/09. Cost and complexity has definitely been added.

A more significant concern is the future requirement for a new KFI to be created every time an adviser makes a new charge. This stipulation does not take into consideration the new way that advisers will be engaging and charging for that engagement with customers as a result of RDR. In short, advisers will be charging variable amounts according to the value they are delivering and charges will not necessarily be linked to specific products unlike commission payments today.

A routine financial planning session is clearly delivering less value than specialist estate planning and advice session. Fees will inevitably be subject to negotiation between adviser and client. Sometimes fees will be paid upfront or paid in instalments. Some advisers may want to adjust charges to reflect the value of the overall portfolio of a client. The client may want to facilitate the charge from a particular product for tax reasons. So providers need to calculate a charge based on the value of multiple products whilst deducting it from a single prescribed product.

Modifying provider systems to deal with all this extra complexity will almost certainly require new adviser charging components to be implemented. Substantial change to illustrations and a great deal of integration between the two will need to follow as provider systems will need to make these adjustments and pay charges accurately and promptly much as they do commission payments today.

But if providers think the new disclosure demands being placed on them are onerous then they can at least be satisfied that their new administrative burden does not fall on them alone. The demands placed on platforms and IFA firms also look heavy from a reading of PS11/9 which contains final rules from CP10/29 entitled ‘Delivering the RDR and other issues for platforms and nominee-related services’.

Specific requirements are:
1. Cash rebates by platforms will be banned by 31st December 2012 (indeed no rules will be enforced until this point)
2. Execution-only platforms will be caught up in the same requirements for increased transparency and unbundling of pricing as other wrap platforms. They will need to disclose fees or commissions received from third parties
3. Payment of fees from platform users’ cash accounts rather than via unit rebates is favoured by the FSA but no ruling has been declared in this area yet
4. More positively for IFAs, they will be saved from having to artificially spread their customers’ assets across a range of platforms to meet the independence rule
5. But they must assess whether being on a platform is in each client’s best interests
6. Advisers must be able to demonstrate why a particular platform is suitable, in other words choice of platforms and off platform solutions need to be considered alongside each other for all clients
7. So although, in theory, a firm may be able to use a single platform for the majority of clients; in reality IFAs need to consider carefully whether one single platform is definitely in the best interests of all clients. So suddenly, client asset migration onto platform does not look necessarily as quick and easy a process as it initially sounds.
A reading of this Policy Statement does leave you asking the question is the FSA dithering in too many contentious areas and putting off final decision-making until next year? This may be because the institution is going through wide scale change itself as the FSA splits into The Financial Conduct Authority (FCA) and the Prudential Regulatory Authority (PRA) and the harder focus of the body that will regulate IFAs on product-specific regulation.

No doubt further Disclosure updates will follow in the near future as slowly but surely all corners of the industry get clarity on what RDR really means in terms of what types of communication customers will need to receive and what safeguards will need to be applied to ensure they are treated fairly. Let’s hope the new FCA leaves enough time for providers and platform operators to make the necessary changes before the RDR comes into force.

Imago administration service proves key to SIPP success

Wednesday, June 30th, 2010

Hargreave Hale’s selection of Dunstan Thomas Imago administration service proves key to SIPP success for the stockbroker

Leading stockbroker and investment manager Hargreave Hale Limited has attributed the rapid entry and success of its SIPP, launched in April 2009, in part to its decision to strategically outsource SIPP administration to pensions administrator Dunstan Thomas.

(more…)

Legacy asset migration to platforns – Treating Customers Fairly (TCF)

Tuesday, February 3rd, 2009

The current economic downturn has presented real challenges to the retail financial services industry as much as any other industry. Confidence as well as fund performance has taken a real beating. We know that there is not a great deal of new money coming into the market and a good deal is flowing out into cash accounts. With falling portfolio valuations and nightmare economic scenarios being played out in the media daily it is hardly surprising that some IFAs are feeling a little gloomy right now.

Nevertheless, there are two opportunities currently conspiring with the stock market performance shock to create a massive opportunity for the IFA industry in 2009: untapped legacy assets and the emergence of now mature wrap platforms after eight years of trial and error since the first was launched. The first element is a massive book of untapped, not actively managed legacy assets. We know there are literally billions of pounds of customers’ money lying in ageing personal pension plans and other products which are not being actively managed for the client at this point and are stuck in failing ‘buy and hold’ equity strategies, including traditional ‘balanced managed funds’ run by many life assurers. Advisers with old filing cabinets full of these cases gradually growing mildew in their basements will need a particularly good action plan when the annual reports and valuations start to land on the doormats of these clients this year…….but one is available.

The total UK retail investment market, life company funds, mutual funds and quoted investments (excluding what’s left of the defined benefit/final salary pensions market) is still valued at several trillion pounds. Much of this is still sitting in underperforming, largely unmanaged portfolios which are having their worst run in nearly 20 years. Clients will be looking for new answers to make their money work harder, IFAs who can offer this will be the winners.

The second element is the emergence of maturing wrap platforms. Wrap has moved from theory to reality through a sometimes painful learning curve experienced by the pioneers and pioneer users who have sorted out the ‘how to’ from the ‘how not to’. The mature wraps now offer a genuine opportunity for IFAs to define and deliver much more impressive and sophisticated combined service and investment proposition to their clients. These propositions can include meeting clients more regularly; defining their risk profiles; actively and regularly rebalancing portfolios; offering dynamic, even daily, valuations, and offering a wider range of asset classes and investment opportunities..
The mature platforms now offer much more transparency around pricing than was previously offered. The ‘unbundling’ of pricing which some of the more mature platforms offer is firmly in line with FSA proposals for independent Adviser Charging and offers IFAs a clear break with commissions dependency. For the first time fees can be linked to the amount and complexity of advice being given and are transparently assigned to parties involved. For example one major platform charges 0.25% of total assets under direction (AUD) as an annual management charge. The IFA advising on these assets may charge 0.5% of AUD by agreement with the client. With this sort of level of charging it is possible for the platform to pass on rebates, given by the fund manager involved, to the client. Fund managers typically charge 1.5% Annual Management Charge for a direct investor, but through a wrap platform this can be cut to 0.75% by rebating the difference. Although some platforms are still pocketing the difference, the more enlightened ones are passing these on and charge separately for their services.
If you are thinking that typical wrap costs are still significantly more than your average customer who has less than £100,000 in liquid assets is comfortable to pay; you may be right for a percentage of your customer-base. But for those above a certain threshold (which could now be as low as £60,000 in reality) it is surely worth identifying potential wrap platform providers; reviewing the services they offer; and then sharing the results of that exploration with some of your more active customers, even if their asset base is below this notional threshold.
Some clients may have less than £100,000 with you now but they often have more assets currently only vaguely recorded on your last fact find but not within the scope of your advice today. They may have funds in poorly performing deposit accounts or shares (inheritance, or denationalisation or demutalisation issues from the 80’s and 90’s). They may even have bought into funds directly (perhaps having succumbed to a third party ISA mailing or offer), paying unnecessarily high charges for this direct access. Some IFAs have experienced an average ‘wrap uplift’ of as much as a third when they transfer existing clients through the addition of these other assets, now all earning a fee for the adviser.
In researching emerging attitudes towards wraps, we interviewed a number of IFAs that are already actively migrating customers onto a range wraps. Our discussions revealed the take-up from clients they had offered it to has been nearly universal. Most expect to complete their discussions about the opportunities offered by migrating portfolios onto wraps with their entire client-base within two years of starting the process. The minimum percentage of customers that our straw poll of IFAs expected to migrate was 50 per cent.
So for the wrap converts what are the key advantages? The ability to offer higher quality service, without necessarily increasing charges to clients, comes through loud and clear.
James Roberts at Partners Wealth goes further: “Wrap platform migration has enabled us to lay down and communicate our service proposition to clients very clearly. We now guarantee an annual review meeting for all wrap clients. We also offer six monthly reviews, combined with clearly defining all clients’ risk profiles and offering continuous, even daily, valuations via our website which is powered by one of the platforms.”
Others say that transparency around the ‘unbundling’ of charges is a key benefit which is transforming their relationships with clients.
Andy Jervis of Chesterton House explains: “Wraps have enabled us to pre-agree Client Remuneration based on a simple and understandable charging structure and to only charge for service and expertise rather than to execute a transaction. We get a formal audit trail of charges from our wrap provider which tells the client exactly what percentage of AUM they are paying us, the wrap and the fund manager, annually and per transaction. This kind of transparency also enables us to be both more flexible and more consistent with our charging.”
It is becoming clear that some early adopter companies are transforming their businesses and re-energising the relationships they have with their clients through migrating them onto wrap platforms.
Other key benefits, according to the IFAs we spoke to, include an ability to offer a broader range of investments to clients on a wrap platform. They said they had been able to broaden their portfolio advice to include ETFs, investment trusts, FSA-approved offshore funds, even commodities and ground rent funds. Others said that wraps offer a consolidated position which makes it much easier to assess income levels for those already in retirement that need to create a stable income from their savings and investments.
What is clear from our investigations is that the benefits of wrap migration for IFAs genuinely committed to remaining independent (and not going down the guided advice route) are multitudinous and heavily outweigh any initial costs and time involved in transferring assets. The vast legacy asset pool must give all IFAs, even those which have not yet embraced wraps, an opportunity to investigate a number of the mature wrap offerings that are now competing with each other for IFAs’ business. Frankly if they don’t, they may well be staring at a problem that could affect the growth of their firm not only this year but for many years to come.

Comparitive illustrations

Wednesday, September 26th, 2007

The FSA said that the review indicated some potential concerns with Sipp advice – it urged that advisers should be able to demonstrate that a client actually needs that potentially greater investment choice, flexibility and control offered by Sipps.

It said: ‘Our review highlighted the potential risk that Sipp recommendations may be based on access to a broader range of packaged investment funds than under their previous arrangements, rather than because the Sipp provides self-selection of actual investment assets. Under these circumstances, a stakeholder pension or personal pension may equally satisfy a customer’s needs, potentially at a lower cost. Sipp providers operate a variety of charging structures and advisers need to ensure that they carry out proper cost comparisons with the alternative personal pension and stakeholder arrangements.’


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