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TCFD Reporting: How to Win Over Climate-Conscious Clients

A heightened awareness of ESG and an unprecedented generational wealth transfer presents the perfect opportunity for wealth managers to get serious about climate reporting.

In 2015, a group of financial experts came together under the Financial Stability Board (FSB) to form the Task Force on Climate-Related Financial Disclosures (TCFD).

Its mission? To create clear and transparent climate reporting standards. Why? So financial market participants could make more empowered decisions about how capital is allocated.

Following the TCFD’s disbandment after its final report in October 2023, the responsibility for monitoring companies’ climate reporting transitioned to the International Financial Reporting Standards (IFRS), as previously agreed.

While the benefits and end results of TCFD reporting will differ for asset managers and wealth managers, the recommendations themselves are the same.

What are the TCFD Reporting Requirements?

The TCFD recommendations highlight four thematic areas that should be included as part of climate reporting best practices. These four areas are:

  1. Governance: how organisations oversee climate-related risks and opportunities;
    2. Strategy: the impact of climate-related risks (both real and hypothetical) on an organisation’s overall business, strategy, and financial planning, and how these risks and opportunities are communicated and accounted for;
    3. Risk Management: how organisations identify, assess, and manage climate-related risks;
    4. Metrics and Targets: How climate-related risks and opportunities are measured and tracked, such as the international goal of “below 2°C” or physical risks like damages due to losses.

How TCFD Reporting Can Help Wealth Managers

Concerned about the devasting impact of climate change, end investors are increasingly turning to their finances and portfolios as a way to mitigate the effects of the climate crisis. The demand for climate-focused funds resulted in the number of assets in Europe-domiciled climate funds reaching a peak of USD 453 billion in 2023.

Assets in European Climate Funds (USD Billions)

Assets have been increasing dramatically since 2018, but increased transparency requirements are now upping the ante

Chart: Ollie Smith Source: Morningstar Direct, Morningstar Manager Research

It’s essential that wealth managers respond to shifting client demands. As ESG awareness grows, more and more clients will want to align their investments with their values. Climate change is the most prominent and pressing sustainability issue for many consumers, and this is especially true for younger generations.

It’s here that climate-conscious wealth managers have two distinct advantages. First, those who can develop and articulate a climate-focused strategy will be better positioned to appeal to and acquire new Millennial and Gen Z clients – the next generation of investors with a much stronger inclination towards impact investing and sustainable financial goals.

Second, beyond expanding their client base, wealth managers also have the unique opportunity to retain existing clients, or at least, their wealth. As the world prepares for a seismic transfer of generational wealth, with capital and assets set to be transferred from so-called boomers to their children, wealth managers who bolster their strategies with ESG and climate-focused solutions may avoid losing clients (and their sizable portfolios).

For wealth managers, adhering to the TCFD recommendations can only be a benefit. By equipping their clients with high-quality and transparent data on climate risks (which will continue to improve as more information becomes available), wealth managers can empower them to make informed decisions about their finances, whether their focus is combatting greenwashing or aligning their portfolios with their sustainability goals and objectives.

Those who demonstrate best-in-class TCFD reporting practices will foster better relationships with their climate-savvy clients, ultimately leaving them better off in the long term. From highlighting disclosures around Scope 1 and Scope 2, to metrics around Scope 3 greenhouse gas (GHG) emissions, wealth managers who are transparent and proactive in their climate reporting are well-positioned for success.

Impactful TCFD Reporting for Wealth Managers

The TCFD reporting requirements consist of a framework built on four thematic areas. Within these four core areas are seven recommended principles that wealth managers must consider when making meaningful disclosures to their clients.

To be effective, disclosures must be:

  • Relevant;
    • Specific and complete;
    • Clear, balanced, and understandable;
    • Consistent;
    • Comparable across companies within a sector, industry, or portfolio;
    • Reliable, verifiable, and objective;
    • Provided in a timely manner.

TCFD Reporting: Navigating the Landscape for Your Clients

While TCFD reporting requirements may vary depending on your jurisdiction, it’s essential to be aware of the growing trend. Major world economies, including the UK, Canada, Japan, and the EU, have either implemented mandates or are strongly considering them.

Additionally, large asset owners are increasingly requesting TCFD disclosures from their investment managers.

Importantly, even if it’s not currently mandated in your jurisdiction, incorporating TCFD principles in your reporting can position you as a leader in this ever-growing area.

How Morningstar Can Support Wealth Managers

Evolving regulations paired with ever-changing client demands means wealth managers are under tremendous pressure. However, navigating regulatory requirements while also giving your clients the metrics that matter can be an overwhelming, confusing, and time-consuming process.

That’s where Morningstar comes in. We’ve compiled an extensive suite of holistic solutions to help financial market participants adapt.

To learn more, download our Guide to Climate Reporting, a free guide developed for both asset and wealth managers designed to help you explore Morningstar’s solutions.

Accelerating capital deployment within a multi-sleeve private markets programme

For wealth managers venturing into private markets, it’s vital to realise that commitment doesn’t directly translate to exposure.

Typically, investors set an annual capital deployment goal to private markets. This is often grounded in an investment-pacing model. Throughout the year, they partner with various fund managers to hit this allocation. But after committing, limited partners (LPs) relinquish control over when and how much capital gets called — this is a discretion held by the general partner (GP). It is important to remember that during times of high economic uncertainty, GPs call capital less quickly. Notably, even three years post commitment, capital calls can vary considerably.

The operation of private markets is therefore unlike that of many asset classes that allow swift capital deployment post-allocation. Capital drawdowns fluctuate based on the fund manager’s sector and strategy. Sectors such as early-stage venture capital and biotech typically make minimal starting investments and earmark significant capital for subsequent financing rounds of their chosen companies (if they prosper). If ventures don’t pan out, this reserved capital redirects to other investments. Consequently, a manager might seem to be lagging in the pace of their investments since the reserved capital has not been called. The reality is that they could be leading, especially if they have a high “winner” count. This is a situation LPs can appreciate. Even within a single sector, variances exist.

For example, a buyout fund focused on add-on investments might reserve more capital than one emphasising operational enhancement. Predicting individual GP capital drawdowns remains challenging due to fluctuating market conditions and deal-closure success rates. However, given that most private market funds maintain compact portfolios (between 15 and 25 companies), a manager can swiftly shift from a lagging investment pace to a leading one if they seal more deals than anticipated.

In light of the above Mercer suggest that wealth managers take into account the following considerations:

  • Strategic blueprint: Craft a resilient long-term portfolio strategy. Meeting risk and return goals while accommodating unique scenarios can help things sail smoothly, even during economic downturns.
  • Employ a quality pacing plan: Due to the long-term nature of private markets, Mercer believe it is important to employ a quality cash-flow pacing model. This should allow for the testing of assumptions and for the determination of sensitivities. It will enable managers to anticipate liquidity needs and offset potential challenges, especially for newly established programmes.
  • Vehicle consideration: Private market vehicles have evolved over the years, with some GPs now offering evergreen structures that can deploy capital immediately and reduce the J-curve effect. Additionally, interval fund structures have also seen considerable growth. These can reduce the complexities associated with pacing in closed-end fund structures.
  • Liquidity lifeline: Bridge the gap between commitment and deployment by ensuring liquidity for unpredictable capital calls. Newer programmes may struggle more, whereas mature ones can balance calls with distributions. Stay agile during periods of high deal flows in order to manage liquidity adeptly. Consider allocations to secondaries and co-investments that offer benefits such as mitigation of the J-curve effect, reduction of “blind pool” risk, increased diversification and accelerated exposure buildup.
  • Develop a robust manager selection process: Manager selection in private markets is critical. Elite managers recognise potential pitfalls and strategise to diminish their effects. For instance, many elite managers have deep experience across various market cycles and have developed toolsets that allow them to generate attractive returns even in poor markets.
  • Balance discipline with adaptability: In tough times, seize the chance to partner with top-tier managers that have previously been out of reach. This could improve the lag between allocation and exposure while also improving the quality of the investor’s portfolio.
  • Establish strong communication with managers: Engage proactively with private market managers. Although they aren’t bound by public disclosure norms, many are open to sharing insights, helping you gauge portfolio prospects more accurately.

Read our important notices

Contact Sebastian Maciocia, Director of Wealth Management at Mercer, if you would like to discuss these issues further.

Email: mailto:sebastian.maciocia@mercer.com

Enhancing Operational Resilience through Data-Centric Supply Chain Solutions

The Importance of Operational Resilience

Operational resilience refers to an organisation’s ability to prevent, adapt to, and recover from disruptions that could impact its operations. In the financial services sector, where the stakes are high, disruptions can lead to significant financial loss, reputational damage, and regulatory scrutiny. The COVID-19 pandemic, cyberattacks, and geopolitical tensions have all underscored the importance of having resilient systems in place.

Traditional approaches to managing supply chain risks often fall short in today’s environment. They tend to be reactive, addressing issues only after they have occurred. In contrast, data-centric solutions offer a proactive approach, enabling firms to anticipate potential disruptions and mitigate risks before they materialise.

Leveraging Data-Centric Solutions for Resilience

Data-centric solutions place data at the heart of an organisation’s operations. By aggregating and analysing vast amounts of data from multiple sources, these solutions provide a comprehensive view of the supply chain, highlighting potential vulnerabilities and opportunities for improvement. Here’s how data-centric solutions enhance operational resilience:

  1. Real-Time Monitoring and Alerts
    Continuous monitoring of supply chain activities allows firms to detect anomalies as they happen. Real-time alerts enable swift responses to potential issues, whether they involve a supplier’s financial instability, regulatory breaches, or cyber threats. This immediacy is crucial for maintaining the integrity of operations and avoiding costly disruptions.
  2. Predictive Analytics
    By leveraging AI and machine learning, data-centric platforms can predict future risks based on historical data and current trends. For example, they can identify patterns that suggest a supplier may face liquidity issues or that certain regions may be prone to regulatory changes. This foresight enables firms to take pre-emptive action, such as diversifying suppliers or renegotiating contracts, to safeguard their operations.
  3. Enhanced Compliance Management
    Regulatory compliance is a major concern for financial services firms. Data-centric solutions ensure that all aspects of the supply chain are monitored for compliance with applicable laws and regulations. Automated compliance checks and reporting streamline the process, reducing the burden on internal teams and ensuring that no critical detail is overlooked.
  4. Improved Decision-Making
    With access to comprehensive, real-time data, decision-makers can make more informed choices. Whether it’s assessing the risk profile of a new supplier, determining the impact of geopolitical events on the supply chain, or identifying opportunities for cost savings, data-centric solutions provide the insights needed to make strategic decisions with confidence.

Real-World Application: Strengthening Financial Supply Chains

Consider the example of a financial institution that relies on a network of third-party vendors for critical services such as IT support, payment processing, and compliance management. Each of these vendors represents a potential point of failure that could disrupt the institution’s operations.

By implementing a data-centric solution, the institution gains real-time visibility into the health and performance of its vendors. It receives alerts if a vendor’s financial stability is in question or if a regulatory change in a vendor’s jurisdiction could impact operations. With predictive analytics, the institution can anticipate these issues and take action to prevent them from escalating into full-blown crises.

Ensuring Compliance and Resilience

Moreover, the institution can ensure that its vendors are compliant with all relevant regulations, reducing the risk of fines and reputational damage. This proactive approach to vendor management not only strengthens the institution’s operational resilience but also enhances its ability to serve its clients without interruption.

VENDOR iQ is an example of a platform that embodies these data-centric principles, offering financial institutions the tools they need to monitor, manage, and optimise their supply chains with precision and confidence.

Building a Resilient Future with Data-Centric Solutions

As financial institutions navigate an increasingly complex and uncertain world, operational resilience has never been more important. Data-centric solutions offer a powerful way to enhance resilience by providing real-time insights, predictive analytics, and robust compliance management. By embracing these solutions, firms can ensure that they are prepared to face the challenges of today and tomorrow, safeguarding their operations and maintaining their competitive edge.

Antony Bream | Chief Revenue Officer | VENDOR iQ

Email: info@vendoriq.co.uk | Linkedin

Regulatory Updates: Blueprint for Success

Staying compliant is crucial to avoid legal penalties, fines, and reputational damage.

Join us in our upcoming live webinar, where we look at how to be proactive in compliance and enhance your firm’s ability to compete in the marketplace, by fostering trust and reliability.

In Ruleguard’s latest live event, we will delve into identifying your compliance universe before dipping into horizon scanning and tips for keeping on top of regulatory developments.

Our upcoming session will cover the following areas:

Defining the compliance universe
Linking obligations and activities
Managing regulatory developments
Evidencing compliance

Whether you’re a risk or compliance professional, this session is perfect if you’re looking to enhance and transform your existing compliance model.

To learn more about our regulatory updates solution visit https://www.ruleguard.com/solutions/regulatory-updates-software.

PIMFA’s Under 40 Committee – Infographic 2024

SDR – The Devil’s in the Timeline

Whilst supportive of the intended purpose and spirit of the regulator’s proposals, PIMFA’s response highlights significant concerns regarding some of the details and practicalities of the proposals put forward, which do not seem to take into account the unique requirements of the portfolio management market and, more generally, of retail investors.

Particularly, our members argue that the implementation timeline, as currently proposed, puts too heavy a regulatory burden on firms to complete the structural work necessary to meet the deadline, given that finalised rules will only be published around six weeks before the implementation deadline, and feel strongly that a 12-month delay is necessary.

Transition to compliance will be far from seamless and will take time to properly plan and implement, particularly in the new Consumer Duty age. We don’t believe that it is reasonable to expect firms to comply with such significant regulatory change in such a short period of time. Even medium- size firms in our sector do not have the capacity or resources to put the necessary infrastructure in place to meet this proposed timeline.

Further, before extending the SDR regime to portfolio managements, it would be helpful to see first how the rules work with funds. As the existing rules regulate funds that portfolio managers use in their solutions, it would surely be wiser to allow time for portfolio managers to align their propositions with how fund managers are re-positioning their own funds. There is a direct connection between how fund managers will apply the new rules, including whether labels will apply, and, in turn, how this will impact portfolio managers in deciding how to align their offerings with the proposed new rules.

Also, until there is more clarity around the inclusion of overseas funds, which are currently out of scope of the SDR regime, and the role of portfolio managers, it would be prudent to provide leniency and flexibility where solutions have offshore/non-UK funds. Otherwise, portfolio managers are being set a difficult, if not impossible, task in assessing and classifying these funds according to SDR rules when these funds are not designed or modified for this purpose.

The proposed rules represent a significant regulatory change with various complexities and dependencies involved. The short timeframe does not allow enough time for firms to plan and communicate changes for clients properly. Delaying the timeline for portfolio managers by 12 months after the publication of final rules will enable firms to ensure they can build a detailed and robust body of evidence to back up any label they decide to use and ensure the consumer-facing and pre-contractual disclosures are clear, high quality and valuable for their investors.

Firms have recently completed demanding work on TCFD reporting, and this has required significant time and resources from across their business. At a time when the industry is making moves to improve outcomes relating to consumer understanding, it would be a disservice to the sector to rush with the extension of SDR to portfolio management.

It is unlikely that the available investment universe of labelled products from which to construct portfolios will be sufficient by December 2024, and this adds weight to our members’ argument that the FCA should first allow for the implementation of SDR rules for funds before extending the regime to portfolio management.

 

First published in FT Adviser

A Deep Dive into Deepfakes

As cyber criminals adopt this technology to exploit vulnerabilities, businesses must understand its implications and strengthen their defences.

What are Deepfakes?

Deepfakes involve the use of AI algorithms to create convincing forgeries of individuals’ likenesses. This technology can fabricate realistic images, videos, and audio recordings, making it increasingly difficult to distinguish between authentic and fake content. Initially developed for entertainment and artistic purposes, deepfakes have quickly been acquired by cyber criminals for malicious activities.

Cyber security implications for deepfakes

The adoption of deepfake technology by cyber criminals presents several alarming implications:

  1. Sophistication of Attacks: AI enables a higher level of sophistication in cyber attacks. Deepfakes can be used to create realistic phishing emails, voice messages, or video calls, making it harder for individuals to identify scams.
  2. Enhanced Social Engineering: Deepfakes take social engineering to a new level. Cyber criminals can impersonate senior executives or trusted colleagues to deceive employees into divulging sensitive information or authorising large financial transactions. For instance, an employee at a multinational firm was tricked into transferring $25 million to fraudsters who used deepfake technology to impersonate the company’s CFO in a video call.
  3. Bypassing Security Measures: Deepfakes can bypass traditional security controls. For example, AI-generated voice deepfakes can fool voice recognition systems, and AI-manipulated images can deceive facial recognition software.
  4. Rapid Development: The speed at which AI technology evolves means that deepfakes will become even more convincing and harder to detect. Cyber criminals can continually improve their methods, making it essential for businesses to stay ahead of these developments.

Deepfakes in the real world

Several high-profile cases highlight the real-world impact of deepfake technology:

  • In the financial sector, deepfake incidents surged by 700% in 2023. Criminals are using AI to imitate vocal patterns, successfully issuing fraudulent instructions over the phone.
  • The legal sector has also been targeted, with the Solicitors Regulation Authority (SRA) warning lawyers about the risks of using video calls for client identification due to the threat of deepfakes.
  • The CEO of a leading advertising firm narrowly avoided falling victim to a deepfake scam. Cybercriminals used a fake WhatsApp account, voice cloning, and doctored YouTube footage to create a convincing virtual meeting. Thanks to the vigilance of the firm’s staff, the attack was unsuccessful.
  • Popular culture has not been spared either, with manipulated videos of celebrities like Taylor Swift being used to spread misinformation. These videos are widely shared on social media, illustrating the challenges in moderating such content.
  • A deepfake video of Ukrainian President Volodymyr Zelenskyy was circulated, showing him supposedly telling Ukrainian troops to surrender. Zelenskyy quickly debunked the video, but the incident highlighted the potential use of deepfakes in war propaganda.

 Strengthening Defences Against Deepfakes

To combat the threat of deepfakes, businesses must adopt a multi-faceted approach:

  1. Staff training: Train your staff to stay vigilant to enable them to recognise and react appropriately to suspected attacks.
  2. Frequent Simulated Attacks: Test your training by conducting regular simulated attacks that mimic techniques used by cyber criminals. This helps in identifying vulnerabilities and improving response strategies.
  3. Enhanced Authentication: Implement stronger authentication measures, such as multi-factor authentication and conditional access, to reduce the risk of unauthorised access using stolen credentials.
  4. Layered Defence Strategy: Establish multiple layers of protection. If one control is breached, ensure that there are additional safeguarding measures and alerting mechanisms to prevent further progression of an attack.
  5. Assessment and Assurance: Regularly assess and audit security measures to ensure their effectiveness. Engage independent experts to provide an unbiased evaluation of your security posture.

 Conclusion

Deepfake technology represents a considerable challenge in the realm of cyber security. However, by understanding the implications and adopting proactive measures, businesses can better protect themselves against the sophisticated threats posed by deepfakes. Staying informed and vigilant, coupled with robust security practices, will be crucial in safeguarding against the evolving landscape.

Lindsay Hill, CEO, Mitigo Cybersecurity

 

PIMFA has partnered with Mitigo to offer member firms a trusted cybersecurity solution to help them protect against cyber-attacks and business disruption. Mitigo offers a free no-obligation consultation for PIMFA members.

Take a look at Mitigo’s full service offer or, for more information, contact Mitigo on 0208 191 9913, email pimfa@mitigogroup.com or fill out our contact form.

 

PIMFA Groups Infographic

Addressing structural trends within wealth management portfolios

To generate long-term investment returns and help protect client wealth, it is important to consider structural trends.

By identifying and avoiding the risks that emerge from these structural trends, such as climate change, resource transition, and biodiversity loss, wealth managers can help minimise the impact on client portfolios.

To assist wealth managers in addressing structural trends and emerging risks, Mercer have developed a set of principles. These principles can be considered when setting objectives, constructing portfolios, managing risks, and establishing a governance framework. By following these principles, wealth managers can navigate the challenges and opportunities presented by structural trends.

Structural trends and emerging risks investing principles

  1. The importance of time horizon is often underappreciated during objective setting, even though it impacts every aspect of the investment process.

Key metrics related to return drivers, risk factors, and correlations should be assessed over the client’s investment time horizon.

2, Wealth managers should integrate structural trends into their broader client risk management process.

The longer the time horizon, the more influential structural trends become, making it essential to build portfolios that can withstand different future scenarios. However, structural trends should not be thought of as solely long-term considerations, as they can manifest in shorter-term periods and have a variety of impacts across multiple timeframes. For example, there may be shorter-term climate regulation risks as well as longer-term physical impact risks.

3, Structural trends should be managed at the total portfolio level.

Risks and opportunities related to structural trends, in particular systemic risks, exist across asset classes and sectors. They should be measured and managed at the total portfolio level, via look-through portfolio analysis and long-term scenario testing.

 

  1. Assigning a formal risk budget across a portfolio of long-term thematic investments facilitates a holistic management of the overall exposure.

By assigning a total portfolio risk budget for structural trend-oriented investments and understanding the interaction between those exposures and the broader portfolio, wealth managers can better accommodate the perceived benchmark-relative ‘risk’ associated with these investments.

2. Diversifying exposures across multiple trends will likely deliver more robust outcomes and a lower total portfolio risk contribution.

The future is unknown, so risk may be reduced by spreading exposure across multiple, diversified themes. Furthermore, many long-term structural trends are interconnected, so outcomes may be improved further by targeting strategies that are expected to benefit from or manage the risks of multiple trends at the same time.

3. Many structural trends, such as climate and energy transition, are specialist areas requiring specialist asset management.

Structural trends tend to be highly dynamic – new opportunity sets often emerge, and early disruptors can be disrupted themselves. Specialist managers are best placed to navigate this dynamic. Furthermore, allocations to thematic exposures in broad-based strategies tend to be smaller, and possibly negligible at the total portfolio level.

4.Focus should be on long-term structural trends where they are deemed material and investable.

It is not enough for a trend to be real; it must also be investable – there must be an opportunity to target, or a manageable risk.

5. Performance of long-term oriented strategies should only be assessed over long time periods.

The short-term nature of listed markets means they struggle to value structural trends, which creates opportunities for disciplined, informed investors. Those who seek ‘proof of concept’ in past performance by definition miss out on the returns that may result from a structural shift in conditions.

Read our important notices

Contact Sebastian Maciocia, Director of Wealth Management at Mercer, if you would like to discuss these issues further.

Email: sebastian.maciocia@mercer.com

PIMFA WealthTech – Tech Sprint findings: ESG and sustainable finance reporting, verification and disclosure

Virtual Event: Understanding Customer Vulnerability – A Guide for Firms Launch

There is currently a significant industry and regulatory spotlight on consumer vulnerability, and it is paramount that firms are able to identify, support and achieve good outcomes for vulnerable customers. The data requests of the wealth management industry and subsequent Dear CEO letters since November 2023 have shown this as a high priority and the expectation from the FCA that this is led from the top.

PIMFA has been working closely with the regulator and member firms this year to understand better the extent and range of vulnerabilities that customers may face and to ensure that firms can correctly identify and support those customers.

As part of our work, we will be launching a PIMFA Guide on Understanding Customer Vulnerability’, which will be a valuable reference aid and tool for firms to use. The Guide, based on our first version published in 2021, will assist firms with creating vulnerability strategies and implementing processes and procedures that will not only help to meet regulatory obligations but also identify opportunities to enhance how firms serve all their customers.

To mark the publication of the Guide, we will be holding an event on the 24th of October 2024, where we will hear from the FCA and a range of industry CEOs and practitioners to discuss the importance of this topic and to share views and best practices and we would like to invite you to attend this event as our guest. Please see details below:

Date: 24 October 2024
Time: 14:00 – 17:30
Venue: Online

Please note this is a virtual event which will be live-streamed. For further information please contact events@pimfa.co.uk 

If you are a PIMFA Member- Please ensure you are logged in to your account first before adding a ticket to your basket to access the member discounts.

 

The Secret to Successful Product Governance

Product governance is a critical aspect of business management. Firms need to ensure that products are developed, launched, and maintained to meet regulatory standards, customer expectations, as well as business objectives. Getting the balance just right is vital to your firm’s success.

Join our upcoming webinar where we delve into the following areas:

Product governance requirements
Implementing a product governance framework
Risk management considerations
Management information

In this session we will provide you with practical steps to help you track your entire product life cycle.

To learn more about Ruleguard visit https://www.ruleguard.com/solutions/product-governance-solution

PIMFA Live Online Learning: Mastering Your Ongoing Compliance with Consumer Duty

The FCA review of Consumer Duty implementation within payment firms published in October 2024 found that just over half were satisfactory, while nearly half were categorised as needing “significant work” to meet the Duty’s requirements. In yet another reminder, the FCA expects your firm to identify gaps in your compliance with the Duty and “act immediately, putting plans in place to address shortcomings.”

In this live, tutor-led online training masterclass, led by consultancy firm Square 4, our tutors will help you demonstrate that the FCA’s latest guidance has been considered, identifying gaps, shortfalls, and actions required to evidence that your firm is meeting their ongoing obligations with the Duty.

By the end of this masterclass, you’ll be able to:

  • Assess and prioritise the tasks your firm’s needs to undertake to ensure alignment with FCA’s ongoing Consumer Duty expectations.
  • Rectify and remediate the gaps in your MI and data to ensure you meet the regulatory expectations.
  • Enhance processes and controls to monitor customer outcomes across your customers, including those with vulnerability.
  • Implement processes to amend and adapt products and communications where risks of potential harm are identified.
  • Overcome common challenges, weaknesses and failings Square 4 has observed in firms’ approach to outcomes monitoring and testing.
  • Assure your Consumer Duty champion and senior managers that your firms’ policies, process and people are in line with industry best practices.
  • Ensure that your firm has effective Consumer Duty centric reporting and governance arrangements in place.
  • Ensure that your firm is able to effectively identify and proactively remediate and crystallised or potential consumer harm.

In this masterclass you’ll cover:

  • An effective 3LOD model to ensure Consumer Duty compliance
  • The importance of clear roles, accountabilities and responsibilities
  • Effective outcomes monitoring / testing frameworks
  • Consumer Duty MI and data requirements
  • Effective governance, reporting and remediation practices

Who should attend:

  • C-level officers concerned about their firm’s ability to create and maintain the Consumer Duty cultural shift.
  • Consumer Duty champions seeking to understand what good ongoing compliance practice looks like and benchmark their firm.
  • Compliance leaders who are not content with standing still are looking to undertake a range of activities to address identified poor outcomes as well as improve the testing methodology and processes.
  • Regulatory risk professionals and in-house auditors who want a better understanding of what processes, reporting, governance and controls should be in place.

Please use early bird coupon JDJNEGB5 at checkout for 50% off 2 Tickets

If you are a PIMFA Member- Please ensure you are logged in to your account first before adding a ticket to your basket to access the member discounts.

PIMFA Live Online Training: Mastering Fair Value Assessments: Aligning with Consumer Duty Standards

One of the most challenging outcomes of the Consumer Duty for firms to meet is that of fair price and value. In the opinion of the FCA, “many of the fair value assessments we [FCA] have seen do not rely on solid data and other credible evidence to justify the products’ value to retail customers. [Sheldon Mills quote Feb 2024]

The regulator’s information request to 20 of the largest firms asking about their delivery of ongoing advice services highlights the need for PIMFA members to test whether their value framework are fit for purpose and challenge whether they are capturing the appropriate data and metrics to evidence their products and services are delivering fair value.

In this live, tutor led online training course experts Alpha, show you how you can stay ahead of FCA expectations, identifying and addressing the regulators most recent concerns in assessing fair value and ongoing advice fees, so that you can take swift action to address any shortcomings in your approach.

By the end of this masterclass, you’ll be able to:

  • Refine and improve your ongoing advice annual review process in light of recent FCA concerns.
  • Confidently anticipate and respond, with evidence, to FCA questions and queries on your approach value assessments.
  • Pinpoint areas of immediate improvement to fair value assessment, ensuring it is aligned with industry good practice.
  • Map, with greater clarity, the critical data metrics required to identify consumer harm across different customer groups, (particularly vulnerable or potentially vulnerable customers)
  • Critically assess if your firm’s ongoing services are fairly priced

Who should attend?

• Compliance heads and leaders seeking to avoid foreseeable harm by enhancing and refining their fair value framework.
• Internal auditors keen to address shortcomings in their approach who now seek a more robust, data-driven approach for assessing fair value.
• Risk leaders who want to ensure that fair value outliers can be effectively identified and rectified with appropriate accountability mechanisms.
• Consumer Duty project leads who recognise the need for improvements, want to know how leading firms use data and MI to monitor fair value on an ongoing basis.
• Consumer Duty champions seeking to ensure their fair value analysis provide the board with a sufficient understanding of outcomes received across different customer groups.

 

Bring you colleague along for free!

Please use coupon 7SX5YB2X at checkout for 50% off 2 Tickets

 

If you experience any issues please email learning@pimfa.co.uk

New Technology and Client Expectations in the Wealth Management Industry: A Focus on Client Analytics and Onboarding – An EY & PIMFA WealthTech report

The PIMFA M&A Roundtable Dinner

The PIMFA Mergers and Acquisitions dinner is an opportunity for PIMFA members to gain valuable insight into the current M&A landscape impacting and effecting the sector. M&A experts from Farrer & Co. and Thistle Initiatives provide firm’s with an update on the current deal environment and what we can expect to see over the coming year.

Benefits for attending:

1. Hear insights into M&A trends, how they have changed and what’s expected to drive M&A activity this year.
2. Learn how to successfully navigate a deal process in the current environment.
3. Further your knowledge on the key due diligence activities in a merger and acquisition transaction.
4. Learn why some mergers and acquisitions fail and how to avoid the pitfalls.

Who should attend:

This is an invite only roundtable of PIMFA member firms with the following job titles:

• CEOs, managing directors and owners
• Finance directors and senior managers
• Finance and commercial team leaders

PIMFA sets out 5-year agenda for government to create a UK Culture of Thriving Financial Health

16 July 2024

 

PIMFA sets out 5-year agenda for government to create a UK Culture of Thriving Financial Health

 

PIMFA, the trade association for wealth management, investment services and the personal investment and financial advice industry, has set out its agenda for government over the course of this Parliament.

PIMFA’s agenda: ‘Creating a UK Culture of Thriving Financial Health’ builds on and supports the policy priorities set out by this Labour government as it seeks to create wealth within the UK and ultimately deliver economic growth.

Whilst PIMFA agrees that there is significant scope to drive investment and growth in partnership with the financial services sector, we believe that more focus should be given to the important role that retail investors will play in delivering this outcome. PIMFA believes that this can be done primarily by equipping retail investors with the tools and incentives necessary to save and invest for their financial futures.

In doing this, PIMFA believes that we will create a culture of thriving financial health and promote long-term investments that benefit not only individuals but also the broader UK economy. This approach will, in turn, drive growth in productive assets and create a robust foundation for sustained economic prosperity.

To achieve this culture of thriving financial health, PIMFA believes the government and regulators should focus on three overarching aims:

–    Giving consumers the tools and incentives to save and invest for their financial futures

–    Maintaining and growing the UK as a destination of choice for investors and investment

–    Providing regulatory and legislative clarity for firms to invest and grow

Liz Field, Chief Executive, PIMFA said: “The start of a new Parliament earmarks a natural reset point for industries to consider how they align with government policy programs and identify where they can work with government to transform policy ambitions into positive tangible outcomes.”

“As this government will look to utilise the financial services sector to drive growth, investment and wealth, I believe that there is significant scope at this crucial early stage for the government to look across the full spectrum of the financial services sector. This means looking to properly utilise the retail investment market, in addition to its traditional focus on capital provided by larger institutions.”

“The wealth management and financial planning industry provides access for UK individuals to take a real stake in the economy through their investments as well as safeguard their own financial health. This principle of ownership should be a key consideration for the government as it returns to its missions of wealth creation and growth. In setting out our agenda for government today, we aim to show how elements of these government missions can be delivered through harnessing a combination of change, and in some cases, stability.”

“We look forward to working closely with the new government and wish them every success in delivering upon their priorities for this sector across the term of this Parliament.”

<ENDS>

 

NOTES TO EDITORS

About PIMFA – the Personal Investment Management & Financial Advice Association

Read PIMFA’s agenda: ‘Creating a UK Culture of Thriving Financial Health’ here.

• PIMFA is the trade association for firms that provide wealth management, investment services and the investment and financial advice to everyone from individuals and families to charities, pension funds, trusts and companies.

• The sector currently looks after £1.65 trillion in private savings and investments and employs over 63,000 people.

• PIMFA represents both full and associate member firms. Full members provide a range of financial solutions including financial advice, portfolio management, as well as investment and execution services. They assist everyone from individuals and families to charities and pension funds, all the way to trusts and companies.  Associate members provide professional services to the PIMFA community.

• PIMFA  leads the debate on policy and regulatory recommendations to ensure that the UK remains a global centre of excellence in the wealth management, investment advice and financial planning arena. Our mission is to create an optimal operating environment so that its member firms can focus on delivering the best service to clients, providing responsible stewardship for their long-term savings and investments.

• PIMFA was created in 2017 as the outcome of a merger between the Association of Professional Financial Advisers (APFA) and the Wealth Management Association (WMA) with a history as a trade association since 1991.
Further information can be found at pimfa.co.uk

• Visit PIMFA’s public affairs web area here.

ETF industry divided on biggest challenges facing primary market servicing

Automation critical to service ballooning in the European ETF ecosystem

The European ETF ecosystem is divided on the biggest challenges facing primary market processes amid concerns asset servicers will be unable to adapt to the growing market.

According to a recent survey conducted by ETF Stream and Calastone, some 40% of asset servicers highlighted the growing complexity of products as the challenge that will require further improvements in primary market servicing and technology, the most across all options.

ETF issuers are no longer launching just plain vanilla core exposures that track indices such as the S&P 500 or MSCI World. To differentiate from the competition, they are focusing on more esoteric strategies across active, crypto, defined outcome and thematics.

This has created an extra burden for custodians that are required to spend more time servicing niche ETFs. All the while, assets in European ETFs have skyrocketed past the $2trn mark which means more orders are being processed daily.

However, this is not the view of APs, with 0% of respondents highlighting the growing complexity of products as their number one priority.

Instead, they are most concerned about the impact of the Central Securities Depository Regime (CSDR) which has introduced cash penalties for failure to settle on time since its introduction in February 2022.

Last December, the European Securities and Markets Authority (ESMA) issued a consultation to address settlement fails which included proposals to raise penalties in line with the duration of the failed settlement.

However, market participants are concerned the proposals could introduce higher costs for end investors amid more pressure on APs to source liquidity in a timely manner.

CSDR was the top concern of 44% of APs followed by connectivity (22%) and the move to T+1 settlement (22%).

In response to whether they have confidence asset servicers will adapt to these challenges, one AP said: “In my experience, asset servicers do not change quickly.”

For ETF issuers, T+1 settlement is the key development that will require improvements in primary market servicing, with 38% of respondents highlighting this.

Interestingly, just 14% of respondents highlighted the growing complexity of products as the biggest challenge while 21% pointed to CSDR.

The US’s move to a T+1 settlement cycle in May has created extra pressure on primary market processes.

The move is designed to drive more efficient use of capital across markets by reducing credit, market and liquidity risks, however, it creates operational challenges for the ETF industry.

Automation

Asset servicers, APs and ETF issuers did agree on greater automation and standardisation in primary market servicing to help tackle these challenges.

Some 93% of asset servicers, 100% of APs and 93% of ETF issuers said the need for standardisation in European ETFs was either “more important” or “equally important” than it was a decade ago.

In response, Thomas Stephens, global co-head of ETF capital markets at JP Morgan Asset Management, pointed to the need for automation to ensure more timely settlement in the primary market.

“As ETF industry growth and client adoption of ETFs increases, automation through API connectivity in areas such as order taking will become the norm,” Stephens stressed.

“Automating in areas such as contract note processing will lead to more timely settlement in the primary market and better utilisation of data available for issuers. This is particularly important given changes to settlement timeframes in several countries and costs arising due to CSDR.”

One solution that is helping to streamline the ETF creation-redemption process is the introduction of Financial Information eXchange (FIX) connectivity.

DWS was the first ETF issuer to launch FIX connectivity for its AP portal in September 2023, a move that is designed to reduce operational risks and offer front-to-back automation across primary and secondary markets.

While it has been available in the US for several years, this is a relatively new development for the European ETF market and means APs will not be required to log into every issuer portal to place an order.

According to ETF Stream and Calastone’s survey, 67% of asset servicers, 78% of APs and 43% of ETF issuers believe FIX will be the dominant means of primary market connectivity between APs, asset servicers and ETF issuers.

“Primary market automation is key for the industry to continue to evolve,” Jim Goldie, head of ETF capital markets, EMEA, at Invesco, told ETF Stream. “Recent innovation such as FIX/API connectivity for primary order placement will be key to ensure we can make the process as automated and as scalable as possible.”

Download the full report here.

ETF Stream is the home of European ETFs. For more information on ETFs, asset allocation and portfolio construction strategies visit etfstream.com.

Tom Eckett

tom.eckett@etfstream.com.

The professional indemnity market for financial advisers in the UK: A decade of change and the path ahead

Read on for an overview of the past, current, and future state of this critical market, shedding light on the challenges and opportunities that have emerged, including the impact of increased Financial Ombudsman Service (FOS) limits.

Past: 2014-2022, a period of adjustment

The period between 2014 and 2022 was marked by significant regulatory changes and evolving market conditions.

The introduction of pension freedoms in 2015 stands out as a landmark reform, granting individuals aged 55 and older greater access to their pension savings. While this offered unprecedented flexibility to consumers, it also introduced complex advisory challenges and heightened risks for financial advisers. This, in turn, lead to increased scrutiny from insurers.

The aftermath of pension freedoms saw a surge in demand for advice on pension withdrawals and investments. This was accompanied by a corresponding increase in the complexity and liability associated with such advice.

The period also witnessed a crucial regulatory adjustment with the increase in Financial Ombudsman Service (FOS) compensation limits in 2019. Since consumers could now claim higher amounts for misadvice, this change increased the potential liability for financial advisers, impacting the cost and terms of PII cover.

Insurers responded with caution, tightening underwriting criteria and raising premiums to mitigate the heightened risk exposure.

This era also saw some insurers exit the market, further straining capacity and complicating the quest for adequate and affordable PII cover for financial advisers.

Present: 2022-2024, navigating through stability and strain

From 2022 to 2024, the professional indemnity market for financial advisers has been navigating a phase of cautious stability, tempered by ongoing challenges.

The effects of pension freedoms continue to reverberate, with a steady flow of claims related to pension advice underscoring the need for stringent risk management and robust advice processes.

Despite these pressures, there are signs of market adaptation.

Insurers and financial advisers alike have developed a more nuanced understanding of the risks associated with pension freedoms and the increased FOS limits, leading to more sophisticated risk assessment and management practices.

Premiums, while still on the higher side, have begun to stabilise, reflecting a gradual balancing of risk perceptions with the realities of the advisory landscape.

The regulatory framework has also evolved, with the Financial Conduct Authority (FCA) tightening standards around pension advice and PII requirements.

This regulatory push towards higher professional standards and better consumer protection is fostering a more resilient insurance market, albeit with the expectation that financial advisers maintain rigorous compliance and advisory protocols.

Future: Towards a new equilibrium

Looking forward, the professional indemnity market for financial advisers in the UK is poised to enter a phase of recalibration, as stakeholders continue to adapt to the long-term implications of pension freedoms, regulatory changes, and the impact of increased FOS compensation limits.

Technological advancements and insurtech innovations are expected to play a crucial role in shaping the future, offering more tailored and flexible insurance solutions that align with the specific needs and risk profiles of financial advisers.

The emphasis on continuous professional development, enhanced risk management strategies, and the adoption of technology in advisory processes will be pivotal in navigating the future landscape.

These elements are expected to contribute to a more stable and sustainable market, where the availability and affordability of PII cover reflect a balanced assessment of the risks and rewards inherent in providing financial advice.

In this evolving environment, the successful navigation of the professional indemnity market will require financial advisers to remain agile, informed, and proactive in their approaches to risk management and client service.

By doing so, they can secure their position in the market, ensuring their ability to provide valuable advice while managing the risks associated with pension freedoms, regulatory complexities, and the heightened liabilities introduced by increased FOS limits.

For those prepared to adapt and evolve, the future looks bright

While the professional indemnity insurance market for financial advisers has faced its share of challenges in the wake of pension freedoms, regulatory changes, and increased FOS compensation limits, the future holds promise for those prepared to adapt and evolve.

The journey from 2014 onwards has been a testament to the resilience and adaptability of the UK’s financial advisory sector, setting the stage for a future where the market not only recovers but thrives, underpinned by higher standards of professionalism and consumer protection.

Richard McGrath

Get in touch

This guest post was bought to you by Onyx – an independently owned Lloyd’s of London Insurance broker.

With more than 150 years’ experience, our clients benefit from the highest level of service and expert advice. If you’d like to find out more about how Onyx could help you, please contact Dan Kelly.

Email dan.kelly@onyxinsurance.co.uk, or call 020 3841 5571.

ASG Meeting Notes 23 May 2024

Avoiding CASS Complacency

Your firm has received another clean CASS audit, so what’s the issue? Just because past breaches have not impacted your firm, can you really afford to get by without changing a thing?

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