Investment Management in Financial Services UK
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New investor protection rules under MiFID II are set to reshape investment managers’ product and distribution strategies in Europe. As the impact of the changes will vary across countries and distribution channels, there is no single optimal approach for firms to adopt. Investment managers distributing funds across the EU will need to think carefully about their strategy in each market. Innovative solutions around online platforms and robo-advice may offer some answers. While the final details of the rules are still pending, policymakers are considering a potential delay of the MiFID II go-live date until 2018. But firms still need to prepare now to be ready in time.
Just in time for Christmas, the EBA published its long-awaited report setting out recommendations for a review of the current prudential regime for investment firms. Produced at the request of the European Commission, and in cooperation with ESMA, the report identified a number of issues in the current application of the CRD/CRR requirements to investment firms (including a lack of adequate risk sensitivity and the complexity of the framework stemming from the current categorisation of firms based on MiFID definitions) and suggested a new approach to their categorisation. The latter would distinguish between systemic and "bank-like" investment firms, to which full CRD/CRR requirements should apply, and other investment firms namely those that are not considered ‘systemic’ or ‘interconnected’. For the ‘non-systemic’ firms, the EBA recommended that requirements should be tailored to reflect the risks specific to their activities.
Some say that technology revolutionized knowledge. Once controlled by a privileged few, knowledge is now becoming available to everybody. What if the same were about to happen with trust?
Defining vulnerability and ensuring staff understand and apply the definition has long presented a challenge to firms.
One of the Financial Conduct Authority’s (FCA’s) main observations, in its occasional paper (number eight), was an acknowledgement that vulnerability is difficult to define and that currently firms apply a range of definitions. It concluded that vulnerability itself is a very fluid, changeable state but for some individual consumers it can indeed be a permanent state. Nonetheless, it made clear that the firms need to work around these difficulties as access to services for all consumers is seen as central to core conduct.
We explore some of the challenges a firm may face when implementing a vulnerability definition across an operation.
The Financial Conduct Authority (FCA) published terms of reference on 18 November 2015 for its market study into asset management. The study will focus on: (i) how asset managers compete to deliver value for money; (ii) whether asset managers are willing and able to control costs and quality along the value chain; and (iii) the effect of investment consultants and other advisers on competition for institutional asset management. Across these topics, the FCA will also consider whether any barriers to innovation or technological improvements are preventing investors from getting better value for money.
MiFID II will have significant and wide-ranging implications for the strategy, operations, conduct and governance of a broad range of firms in Europe. It raises many important questions for the investment management industry. What are the key challenges and implications of MiFID II? How can investment managers gain a competitive advantage? And how much progress have investment managers made in implementation? We discussed these questions with 15 investment managers and two independent external experts to inform our new paper Navigating MiFID II - Strategic decisions for investment managers. The key findings are highlighted below.
On 17 September 2015, HM Revenue and Customs (HMRC) released their draft guidance on the Automatic Exchange of Financial Account Information guidance. The guidance is intended to help Financial Institutions (FIs) with the four different Automatic Exchange of Information regimes; the US Foreign Account Tax Compliance Act (FATCA), the Crown Dependencies and Overseas Territories (CDOT) and the Common Reporting Standards (CRS) and the EU Directive on Administrative Cooperating (DAC) in tax matters.
Complaint reduction should be a priority for every firm. A robust and structured complaint reduction strategy can deliver many advantages, for example:
- The customer experience is improved as issues which could have caused complaints are identified and resolved.
- The morale of front-line staff can improve if they are given the knowledge and skills to resolve customer concerns before they become complaints.
- The potential to reduce reputational risk through the identification and elimination of common complaint causes, leading to less likelihood of negative regulatory or media activity.
- A potential reduction in complaint processing costs as incoming volumes, ombudsman referrals and re-worked complaints decrease.
By 2050, the UK population is projected to grow by almost 20%, to 77 million. By contrast, the populations in Germany, Italy, and the Netherlands are projected to decline. The investment management industry stands to benefit from the long-term opportunity presented by population growth in the UK, in spite of the challenges brought on by changing regulation, the pace of innovation, and the growing demand for low-cost products and services.
In September 2015 the EU Commission is expected to bring forward a legislative proposal in on ‘high-quality’ securitisation as part of the Capital Markets Union. The Commission suggests it may be possible to incentivise the issuance of high quality securitisation through a differentiated capital charge relative to standard securitisation. This in turn could re-invigorate the European securitisation market.