DFM Market Update 2016

October 2016

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Contents Introduction 3 Learning objectives

4

Market news

5

Market trends

6

Why outsource?

9

Outsourcing options

11

Due diligence – getting it right first time

16

Pension freedoms

27

Service 29 Test yourself for CPD

32

Appendix 34 About Defaqto Acronyms The most common acronyms used in this paper are: AIM

Alternative Investment Market

AMC

Annual Management Charge

AUM

Assets Under Management

BPR

Business Property Relief

CGT

Capital Gains Tax

CIO

Chief Investment Officer

CIP

Centralised Investment Proposition

ETF

Exchange Traded Funds

IHT

Inheritance Tax

MPS

Managed Portfolio Services

NURS

Non-UCITS Retail Schemes

SMPS Services managed portfolio services UCITS III Undertakings for Collective Investments in Transferable Securities

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Introduction This market update is designed to help advisers keep up to date with this evolving market. It is still a relatively new area to many, where investment choice is growing and regulatory demands, particularly around due diligence, are also increasing. As is often the case in the financial services industry, evolution rather than revolution is the key. We have not seen huge changes in the market, but there are some interesting trends. Platforms are at the heart of most adviser businesses now. The days of wrangling over who should hold custody of client assets are over, with discretionary firms understanding that to play in the retail adviser market, more often than not custody needs to be conceded to the platforms. The last couple of years have also witnessed a change in mind-set of both adviser and discretionary firms, hopefully to the benefit of all. For the most part, discretionary managers have learnt quickly that advisers require information to help make their selections, and there is a regulatory imperative to do so. It has become much easier to collect like for like information on costs, performance and portfolio structure, and we will share some of this data with you.

Fraser Donaldson

Insight Analyst (Funds and DFM) [email protected] 01844 295 432

The advent of new pension freedoms means that adviser requirements around investment choice and retirement income management have increased. This review will take a look at what additional elements should be added to an adviser’s typical due diligence process. At the turn of the year, Defaqto undertook its first DFM service review. We will share some of the results in this guide, in particular what advisers see as the most important facets of the service they receive and where DFMs are failing to meet expectations. Finally, this guide will take a wider look at the market and perhaps serve as a refresher on what is now considered to be good due diligence.

3

Learning objectives Reading this DFM market update will enable you to:

4



Understand the direction the discretionary market is taking and be able to factor in potential future changes when monitoring existing solutions and selecting new solutions



Adjust your client recommendations and selection due diligence based on recent activity and trends in the market



Be clear about the different types of discretionary solutions on offer



Describe the different discretionary solutions, relating them to client needs and suitability and as a result make better and more robust selection decisions



Achieve some clarity on what the regulators expectations are in terms of due diligence



Understand that outsourcing changes the client/adviser dynamic. Rather than the adviser providing the solution and having to defend all investment decisions, both will be working together to find the best third-party solution

Market news Month/Year

News

2016 June

Old Mutual to list wealth management arm

June

Charles Stanley announces expansion of its financial planning arm

May

Parmenion announces addition of exchange traded funds (ETF) model portfolios to the platform

May

Ingenious Asset Management rebranded Tilney Asset Management following regulatory approval

May

JM Finn plan to launch a managed portfolio service (MPS) aimed at the intermediary market. It will offer five risk graded portfolios. (Launched in July)

April

Tilney Bestinvest announces the acquisition of national advisory firm Towry for £600m

March

Former Prudential Insurance Chief Investment Officer (CIO), John Betteridge, appointed CIO at Rowan Dartington

March

Cofunds announced the launch of a discretionary management service

March

Whitechurch Securities announces the launch of a range of ethical portfolios. Also available on a bespoke basis for higher net worth clients

March

Momentum acquires London & Capital advisory business

March

Old Mutual announces the separation of its four main businesses: Emerging Markets, Wealth, Nedbank Group and Asset Management in the US

January

True Potential launches a new range of 10 multi-manager portfolios, covering 5 risk profiles

January

Former Sanlam private client head, Charles Cohen, appointed Senior Investment Director at Canaccord Genuity Wealth for the London team

January

Canaccord Genuity Wealth renames REMAP portfolio service to GPS Optimised Portfolios

January

Church House Investment Management has launched an MPS offering six portfolios spread across different risk profiles

2015 Walker Crips introduces a new MPS range Alpha:r2. Includes five risk/return portfolios available either in collectives or direct equities and bonds. Also available are two higher income portfolios and an ethical portfolio St James’s Place Wealth acquires discretionary fund managers Rowan Dartington in a deal reported to be £34m Charles Dixon, former Head of Brooks Macdonald London office, joins Mountstone Partners Towry acquires Ashcourt Rowan for £97m Robin O’Grady joins Hawksmoor from Saltus as New Business Development director Aberdeen Asset Management completes the purchase of platform and discretionary managers Parmenion Individually, a relatively quiet year, but in one or two of the stories we can see firms positioning themselves to take more control over the distribution chain. 5

Market trends As we mentioned in the introduction, on the surface it doesn’t seem like there is much change going on in the market, especially if you look at it over short periods of time. However, there does seem to be a significant shift over time in the dominant avenue of distribution, and there is no coincidence that this has happened in the lead up to and just after the Retail Distribution Review (RDR).

These propositions are split: • 71 Bespoke • 50 MPS direct with the DFM • 62 MPS on a platform It is interesting to note that there are now more MPS solutions available through a platform than there are direct with a DFM. Defaqto has looked at new launches over the last 10 years or so, which reveals the following:

Defaqto currently cover some 183 propositions, from 84 discretionary firms. By no means whole of market, but an overwhelming majority of those firms looking to play in the advised retail space. Discretionary launches

Number of new launches

20

15

MPS on platform

10

MPS direct 5

0

Bespoke Pre 2008

2008

2009

2010

2011

2012

2013

2014

2015

Year of launch

Chart 1: Discretionary launches, source: Defaqto

Note: Pre 2008 launches of bespoke go off the scale, numbering 48. New launches do seem to be tailing off, indicating that most DFMs have already positioned themselves for the post-RDR market. What is noticeable though is that, for a number of years now, launches of MPS on platform have heavily outweighed launches of MPS through the discretionary firm. So, what has brought us to this point? It is true that DFMs have had to accept that to successfully break into the retail market their propositions would have to be made available on adviser platforms. The reason? Well, a significant amount of adviser client 6

assets had already been moved to platforms long before the DFM industry decided to market seriously to the adviser. The platform market was well established pre RDR and as advisers re-assessed their client offerings in anticipation of the new distribution era, for many the platform was already at the heart of advisory businesses. DFMs quickly realised this and from about 2010 on, the priority for most was to establish distribution through these platforms.

Today there are still DFM firms that steadfastly refuse to offer their solutions on a platform, reluctant to give up custody of assets. Equally, there are those that only make their discretionary solutions available through a platform. This latter category is the fastest growing with 32 out of the 61 we cover only available through a platform. And what difference does this make? Well, the differences between solutions available direct from a DFM and those from a platform are well

documented, and we will touch on that in more detail later. However, the primary difference is that if the solution is designed specifically for a platform, platform restrictions will have been taken into account when designing the structure of the solution and there should be much fewer compromises on investments compared to those offerings that are trying to mirror existing direct ones. The MPS solutions that are only available on platform, with no obvious equivalent, are as follows:

Provider

Product

Apollo Multi Asset Management

Athena Controlled Risk Discretionary – Platform

Beaufort Investment Management

Discretionary Portfolio Management – Platform

Brewin Dolphin

Managed Portfolio Service

Brown Shipley

Platform Model Portfolio Service

Charles Stanley Pan Asset

PanASSET Model Portfolio

Charles Stanley Pan Asset

PanDYNAMIC Model Portfolio

City Asset Management

Platform Based Model Portfolios

Clarion Investment Management Limited

Discretionary Investment Management

European Investment Management Ltd

Model Portfolio Service – MOSAIC Platform

Hawksmoor Investment Management Limited

The Model Portfolio Service

IPS Capital LLP

IPS Managed Portfolio Service

King & Shaxson Capital Limited

Platform Ethical Portfolios

Kleinwort Benson

Managed Portfolio Strategies

London & Capital

Discretionary Managed Portfolios

London & Capital

Global Model Portfolio Service

Morningstar Investment Management Europe

Morningstar Managed Portfolios

Myddleton Croft

Model Portfolio Service – Platform

Newscape Capital Group

Model Portfolio Service

Novia Financial plc*

Copia Capital Management

Parallel Investment Management

Model Portfolio Service

Parmenion Capital Partners LLP*

Discretionary Management Service

Price Bailey Financial Planning

Portfolio Management Service – Platform

Richmond House Investment Services Ltd

Discretionary Management Services

Sarasin & Partners

Sarasin Model Portfolios

Shipman Investment Managers

Managed Portfolio Service

Smith & Williamson

Managed Portfolio Service 7

Provider

Product

Standard Life Wealth*

Managed Portfolio Service

Tatton Investment Management

Tatton Strategic Managed Portfolio Service (SMPS)

Tavistock Wealth

Central Investment Proposition – Partner Profiles

Tavistock Wealth

Central Investment Proposition – Tavistock Profiles

Thomas Miller Investment Ltd

Model Portfolio Service

Waverton Investment Management Ltd

Model Portfolios based on Platform

* Not normally classified by Defaqto as MPS on platform, but in this instance the principle applies that the solutions will have been designed with their own platforms in mind.

It took some time for DFMs to accept that handing over custody of assets to platforms was essential to success in the adviser market. With some platforms now saying that up to 80% of their new assets acquired are invested in model portfolios, whether that be advised or discretionary, we can conclude that we are in a position where both platform and DFM need each other equally.

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Why outsource? The reasons for outsourcing investment to a third party have been well documented, but it is worth reminding ourselves, in brief, of the key reasons. All adviser firms went through a period of self-examination leading up to RDR implementation in order to be able to provide a robust, suitable service proposition to clients. The decision to outsource is, fundamentally, based on three key elements: • Client outcomes – What is best for the client? • Resource – What is available and what is required to run portfolios internally? • Strategic considerations

Client outcomes Regardless of what the adviser feels they should be doing for their clients in terms of justifying a fee, many have taken a step back and questioned whether they were best placed to be managing, monitoring and making investment decisions on behalf of their clients. With uncertain, volatile markets, many concluded that they did not have the skill, experience and time required to manage client portfolios. In other words, the prospect of good client outcomes would be enhanced if, through outsourcing, investment specialists were brought in to manage client portfolios.

Resource As we have touched on above, there are some fundamental requirements for running an investment proposition, and advisers will have examined whether they have all the elements in order to achieve the best outcomes for their clients. These would include: •

Having investment expertise across a wide range of investment types, coupled with long- and short-term market views – ie a tactical and strategic approach



Having sufficient time to dedicate to building, maintaining and monitoring portfolios regularly and consistently



Having the correct permissions, particularly if adviser-run discretionary services are employed (even if the investment decision making is undertaken by a third party)



Defending, explaining and taking responsibility for all investment decisions including those connected to asset allocation and asset class selection

Strategic considerations •

Constructing a centralised investment proposition (CIP) will lead to consistency of advice to similar groups of clients, assuming client segmentation has been done thoroughly



Using third parties to undertake the investment decision making will de-risk the adviser business. Responsibility for the right advice, suitability and due diligence on the selected outsource partner(s) still lies with the adviser, but other responsibilities (those that the third party has been commissioned to undertake) can be delegated 9



It may simply be a cheaper, less complex alternative to use the expertise of third parties rather than building a proposition internally



Some advisers will see the outsourcing of investment as an opportunity to re-focus on applying the core skills of financial planning



Client relations are likely to improve if the adviser is on the ‘same side of the table’ as the client as they work together to select the most appropriate investment solution. Adviser/client relations can get more strained if the adviser finds themselves having to defend their own investment decisions. Perhaps a subtlety, but could be an important one

So, having made the decision to outsource, where do we look?

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Outsourcing options Having made the decision to outsource, the selection of thirdparty investment managers to partner with becomes the next step. Essentially, advisers will be looking at multi-asset funds or discretionary managed portfolios, or more likely a selection of both catering for different client segments. In 2012, the Financial Services Authority laid out what they believed to be a good practice structure for a CIP (centralised investment proposition). It read as follows: ‘Several firms segmented their client bank effectively and designed appropriate solutions to cater for each segment. This included: •

A preferred fund panel for transactional clients



A suite of low-cost managed funds for clients with modest asset levels who required a low-cost ongoing service



A model portfolio service for clients with a higher level of assets and investment experience, where the additional costs were appropriate



Discretionary fund management for clients who required bespoke investment management solutions’

Source: Financial Services Authority, July 2012. Assessing suitability: Replacement business and centralised investment propositions (FG 12/16)

In our experience, many advisory firms have based their propositions on this structure. Four years on, the regulators may replace ‘low-cost’ with ‘value for money’, and the emphasis may not be so much on the level of investable assets, but the structure still holds, providing investment choice for a wide range of clients and circumstances. In pictorial terms, advisers will be constructing a matrix of solutions that covers the following:

Outsourced investment solutions

Discretionary fund management

Managed portfolio service

Direct with the DFM

Bespoke portfolios

Multi-asset funds

Multi-manager

Bespoke portfolios

Through a third-party platform 11

Vive la difference So, many advisers have established a CIP, featuring multi-asset portfolios, whether they are funds or discretionary. It is worth reminding ourselves what the fundamental differences are between these options. The main differences are summarised in the table below:

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Service aspect (feature/benefit)

Managed funds Discretionary (multi-manager/ (bespoke) multi-asset)

Discretionary (managed portfolio service from the DFM)

Discretionary (managed portfolio service through a platform)

Suitability responsibility

The adviser

Usually the discretionary manager

Usually the adviser

The adviser

Investment mandate

Set by the fund manager

Set in discussion Set by the with the client and/ discretionary or adviser manager

Minimum investment

From £1,000 and monthly investment usually available

Generally £200,000 and above depending on level of service and assets employed

Generally £20,000 Can be as low as to £50,000 upwards £1,000. Usually the same as the platform minimum. Competitive with fund entry levels

Charges

Standard charges usually quoted within terms and conditions. OCFs ranging mostly between 0.5% and 0.75%

Often by negotiation dependent on level of investment and level of service required. Tiered levels of charging often apply

Standard charges usually quoted within terms and conditions. Can sometimes be negotiated lower dependent on level of investment of the client or level of investment overall through the adviser. Generally in region of 0.5% to 1%

Considerably lower than direct with DFM as most service, administration and custody is undertaken by the platform. Generally in region of 0.25% to 0.5%. Do not forget to factor in additional platform charges

Customisation opportunity

None

Yes, portfolio and service built to client needs and goals

Yes, but generally limited

None

Set by the discretionary manager

Service aspect (feature/benefit)

Managed funds Discretionary (multi-manager/ (bespoke) multi-asset)

Discretionary (managed portfolio service from the DFM)

Discretionary (managed portfolio service through a platform)

Investment manager

Management team published and often held up as a selling point. Probably familiar to adviser

Usually an investment manager is appointed to look after each client. The amount of autonomy the investment manager has varies considerably. In reality in the retail space most portfolios are built around a core model portfolio. Few investment managers will be known to the adviser market

Some services will introduce advisers to portfolio managers, but most will manage relationship via business development teams. Client will rarely have access to the investment managers

Potentially no contact at all with either client or adviser. Some services will introduce advisers to portfolio managers, but most will manage relationship via business development teams

Client influence

None

Client led

None

None

Personal service

None

Yes, but to highly Fundamental variable degrees to bespoke management. Portfolio management representatives are almost always available, and often both the adviser and the end client will have full access to the portfolio manager or members of the portfolio management team. DFMs are increasingly leaving the final decision on the end client’s access to managers with the adviser to further protect that relationship

None, as client usually not known to discretionary managers. Service aspects down to the platform

13

Service aspect (feature/benefit)

Managed funds Discretionary (multi-manager/ (bespoke) multi-asset)

Discretionary (managed portfolio service from the DFM)

Discretionary (managed portfolio service through a platform)

Transparency

Easy to assess both past performance and costs

Availability and complexity of this data varies considerably from company to company

Better than bespoke DFM but still variable. Dependent on firm, but as an industry improving all the time

Better than bespoke DFM but still variable. Dependent on firm, but as an industry improving all the time

Taxation

Capital Gains Tax (CGT) liable on exit from the fund

CGT liable after each sale. Part of bespoke service can be CGT management

CGT liable after each sale but less relevant as models often deal in smaller values of investment. Usually down to adviser to monitor and manage this

CGT liable after each sale but less relevant as models often deal in smaller values of investment. Usually down to adviser to monitor and manage this

Asset types

Most used thanks Dependent on to Non-UCITS Retail service but most Schemes (NURS) can be employed and Undertakings for Collective Investments in Transferable Securities (UCITS III) regulations

Most MPS solutions tend to use collectives as the base for portfolios. This permits sufficient diversification for smaller investors. Some will use direct holdings and alternatives

Most MPS solutions tend to use collectives as the base for portfolios. Will depend on what asset types the platform has access to

Existing assets

Not accommodated Can almost always be accommodated within service

Not accommodated Yes, if facilitated by except in very rare the platform circumstances

Reporting

Usually standard final and interim reports for the funds

Units are usually Valuations (outside of regular priced daily and will be reports) published (either on manager’s website or possibly in a national newspaper)

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Standard half yearly or quarterly. More frequent reporting can sometimes be arranged

Usually standard half yearly reports

Usually standard half yearly reports

Access to portfolio manager when required. May have online view facility. May be a charge for additional valuations

May have online view facility, otherwise adviser can request from account manager. May be a charge for additional valuations

Online views of valuations and transactions are a given on a platform

Service aspect (feature/benefit)

Managed funds Discretionary (multi-manager/ (bespoke) multi-asset)

Discretionary (managed portfolio service from the DFM)

Discretionary (managed portfolio service through a platform)

Change of manager/fund

Relatively straight forward sell and buy

As with bespoke

As long as staying with the same platform, this should be relatively straightforward, perhaps as simple as a fund switch. The platform is the custodian for all hosted MPS

Administratively a bit trickier. Some holdings may not need to be sold so transfers need organising to new managers (if permitted by old managers)

So, once the adviser has a clear idea of which proposition types will make up their CIP, this leads us nicely into the selection process and the section on due diligence.

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Due diligence – getting it right first time We have had the UK regulators issuing guidance on due diligence and endless speculation and scepticism in the financial press about what MiFid ll will bring to the table in terms of what will be required from all parties to satisfy regulation and more importantly to achieve the highest possible likelihood of good client outcomes. There is no such thing as good due diligence or deep due diligence. All due diligence should be good and in depth enough to make sound decisions on behalf of clients. This has never changed. All the regulators are trying to do is to remind us all what is required and to ensure that rules, practices and processes are in place to make this possible. We should always have it in mind that inadequate due diligence can lead to unsuitable advice to clients, and in some circumstances poor client outcomes. Due diligence should always start with knowing your client or knowing your client segments. At its simplest, due diligence is finding out about the firm providing the product or service and then finding out about the proposition itself. It is then a matter of exercising professional judgement as to whether the findings are acceptable to the client. Without knowing your client or client segments, due diligence will inevitably be flawed. There are of course various ways to undertake these exercises, but the first step would usually be to narrow down the universe, create a short list and then look at what is on the short list in more depth.

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The fundamentals Many of our adviser panel clients take the approach of breaking down the due diligence into two stages. Firstly, to narrow down the universe they will have some fundamental criteria in mind that any prospective DFM must pass. What these fundamentals are will depend on the adviser and what they believe are the most appropriate ones for their clients. An example of criteria selected may include: • Launch date • Discretionary assets under management (AUM) • Range of portfolio options • Fees • Assets vehicles used in portfolios • Specialisms eg ethical

Preferred In addition, there will be a selection of criteria that may not be game-changers, but would be considered ‘good to have’. Advisers would exercise their professional judgement here. Several DFM options could be chosen to cover all bases. It is also worth asking the DFM if they are flexible enough to provide a particular feature that would not normally be in their terms. The answer to this is likely to depend on future asset commitment.

Due diligence – what does good look like? There is of course no standard, right answer to this. The answer is likely to be individual to each adviser firm, and in some cases to individual clients. In terms of what good due diligence looks like, it should be common sense. Adviser businesses will have certain questions about firms they are considering doing business with, and clients will have certain questions about what is going to happen to their invested capital and what their expectations should be from initial investment, through the investment journey and finally in terms of expected outcomes.

The basics We have had formal guidance from the regulators on what should constitute minimum due diligence. Their final guidance paper FG 12/16 (Assessing suitability: Replacement business and centralised investment propositions) helpfully outlines some of the fundamental due diligence that is expected.

This includes: • Terms and conditions • Charges • Provider’s reputation and financial standing • Range of tax wrappers that can invest in the CIP • Type of underlying assets in which the CIP invests • Flexibility and whether it can be adapted to meet individual client’s needs and objectives • CIP provider’s approach to undertaking due diligence on the underlying investments

The CIP refers to a range of available investment propositions that may include funds as well as discretionary solutions. However, it is logical that the above can refer to either the CIP as a whole, or individual elements of it when viewing as an option for client segments. 17

Deeper due diligence Since publication of the final guidance paper in 2011, the regulators have been encouraging advisers to go further in their analysis. There may be some overlap with the basics as listed above, but a good foundation for decision making should also include: Financials Advisers may wish to satisfy themselves that the firm is financially strong, here to stay and committed to the adviser market. A combination of factors can be considered here including group assets under management, discretionary assets under management, growth in discretionary assets under management and the percentage of business that is received from the adviser market.

Investment style There are fundamentally two investment styles:



Return focused – aims to outperform a stated benchmark, over time. Management of risk and volatility would not be a priority, although awareness of risk would be expected



Risk targeted – managing volatility within a target range is the priority here, but we would also expect to see reasonable returns for the risk undertaken

Assets employed The type of portfolio building blocks can have an effect on cost, whereas some esoteric strategies may be too complex for some clients:



Traditional – portfolios use cash, equities, property and bonds. For less sophisticated clients, this may be a more cautious route which provides adequate asset diversification, mitigating concentration risk



Alternative – portfolios use non-traditional, uncorrelated assets, such as private equity, infrastructure and absolute return, in addition to traditional assets. In severe market conditions, this may provide additional diversification

Investment methodology There may be a preference for accessing markets through active or passive vehicles. Most DFMs will utilise a combination of both, though some may offer a wholly passive option. Considerations should include:

18



Cost – a drag on performance, so using cheaper passives may appeal. Active investing requires more resource for analysis and research but potentially provides higher returns



Risk – the use of passive funds (index trackers) removes stock specific risk. Active managers would argue that, factoring in tactical and strategic asset allocations, it gives them the opportunity to avoid underperforming stocks and markets



Adviser understanding – Advisers are required to articulate the appropriateness of any investment solution to their client. A complex solution may make this difficult

Management approach Most discretionary services will utilise collectives at some level, however this is more costly than investing in direct securities. Collectives have the benefit of a certain level of built in diversification.



Collectives – select managers to run specific mandates within the portfolio (multi-manager)



Direct stocks – select individual stocks and holdings to construct portfolios

There are pros and cons to both approaches, but the key in the due diligence exercise is to be in a position to manage the client’s expectations. Clients would not want to look at their portfolio and be surprised and perhaps worried about what the portfolio is containing, such as a portfolio of derivatives and alternatives instead of the expected recognisable shares and collectives. The research required, as outlined above, can best be summarised by the graphic below:

Risk targeted

Return focused

Traditional assets Asset type

Alternative (and traditional assets)

Investment solution

Investment method

Investment style Passive

Active (and blend)

Management approach Multi-manager/ Multi-asset

Direct securities

There are many variants of MPS solutions, and finding the ones that best fit with the adviser’s own philosophy and thinking is their challenge and responsibility. Get this right and there is a very good chance that the partners selected will be a good fit for both client and adviser. There is of course more to consider, including: Management structure Due diligence should uncover whether there is stability and consistency in management. Senior investment professionals at any firm should be able to exhibit a good record in the industry, and ideally the team behind them should be well established. The management team should be able to articulate their commitment to the adviser market and enable their firm to provide information and support that is attuned to the adviser.

19

Operations Discretionary management is a service based solution and the more service required, the more it costs. While due diligence should take into account cost and fees, and outliers from the norm should be a flag for further investigation, look at value for money rather than absolute cost.

Contractual Another important aspect of due diligence is to be clear about the contractual arrangements. This must detail each party’s responsibilities within the service, most importantly where the responsibility for suitability lies. Some discretionary managers will insist on this, arguing that they cannot construct a portfolio for a client without full knowledge of all the client’s circumstances. Other discretionary managers recognise that some advisers do not want to hand over all the responsibility to the discretionary manager and will defer responsibility for the suitability to the adviser. Whichever model, it is essential that the client is informed, in writing, where all responsibilities lie.

Risk management This can cover several areas, but what we would suggest are key areas for examination are:

• • • • •

Conflicts of interest Good governance around all areas of the firm, preferably with independent oversight Good strategy for growth Sensible pricing Sticking to investment methods and styles that suit the expertise and resource of the firm

There are of course many other aspects to a good due diligence process, some of which will not have been mentioned here, but the key is to answer all your own questions as well as putting yourself in the client’s shoes and answering all of theirs.

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Due diligence – the pitfalls It is only a few years since many discretionary firms were genuinely baffled as to why they were getting requests for details of performance and/or costs from advisers. While things have moved on since then, we are still a long way from any kind of standardised data delivery. Gathering information is no longer the issue, it is more a case of being confident in the data received and on what basis it is provided. Approach with care would be the mantra. Just to help focus the mind on any due diligence undertaken here are some items that are perhaps not as straightforward as they first appear:

Category

Comment

Thinking

Performance for bespoke

By its nature will be indicative

Many discretionary managers are, unlike the fund world, more concerned about achieving client outcomes than being top of the pops in terms of performance. Always combine performance with a risk measure to get a complete picture

Performance for MPS

Should be more straightforward but there is not a common standard

May be gross of all or some charges. Be clear on what charges and fees are included and excluded from performance

Cost (MPS and bespoke)

Headline annual management fee All-inclusive fee (no additional may be all inclusive or may be one of charges such as transaction, many charges dividend collection, money transfer etc) is likely to be higher In many cases, annual fee is than unbundled charge structure. negotiable. Usually dependent on However, the higher the AUM, potential volume of assets the more insignificant additional fees become as a percentage of For bespoke portfolios, fees are portfolio value often tiered in that the more AUM the lower the cost becomes

Cost (MPS and bespoke)

Underlying funds

You would expect to pay a bit more for use of externally managed funds (paying for manager’s expertise). Internally run funds usually form the building blocks of portfolios. Some DFMs do not charge an explicit DFM fee, rather they take a cut of the AMC on the internally run funds. There are VAT savings using this structure. Ensure all costs are taken into account, especially if propositions make shortlists on the basis of zero DFM fee claims

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Category

Comment

Thinking

Flexibility

Really only applies to bespoke. MPS is commoditised and features and benefits are usually standard for all clients

In theory all aspects of bespoke DFM have flexibility built in, but this will at some level have an additional cost. Flexibility of service may be variable, dependent on AUM

Expectations of structure

Most DFMs will claim expertise and potential use of most investment vehicles in portfolios

In reality, most portfolios whether bespoke or MPS will only use a certain amount of investment vehicles. More specialist or esoteric vehicles may only be considered for inclusion when requested. Important to be clear about what is possible and what is likely to form client portfolios, as sophistication and client understanding are important regulatory issues

Investment style

Most DFMs are reluctant to label themselves with any one approach

That being said, questioning will usually elicit what type of approach is being taken (risk targeted, risk focused, benchmark driven growth). With bespoke portfolios it should be possible to dictate the approach

Investment management

Who is running the money?

Investment managers in the discretionary world are not as well known as those in the fund world. However, most will have a track record at recognisable firms. Ask for and be comfortable with the main investment influencers

Financial standing (and reputation)

There is little in the way of financial strength analysis of DFMs (unless part of bigger financially strong groups)

AUM, growth of AUM, Group AUM (as opposed to just discretionary) will all help paint a picture of financial strength, potential longevity and resource

Ease of doing business

May tick all boxes but just not compatible with adviser business or awkward to deal with for client and adviser

Softer issues are very important. Defaqto always recommends a certain amount of engagement, electronic and face to face, before coming to a selection decision. If possible, involve paraplanners who are likely to be main points of contact

This table by no means represents all the due diligence hurdles to overcome, but does give a flavour of the kind of thinking and analysis that has to be undertaken to achieve robust due diligence.

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The specialist Not all clients are the same, and there may be occasions where some investment specialisms are required. For instance: •

Ethical/socially responsible investing



Sharia



Alternative Investment Market (AIM) portfolios for Inheritance Tax (IHT) planning (utilising business property relief)



Taking on US clients

The first three in this list relate to investment approach and may require additional due diligence on the firm’s capabilities. The last requires specialist skills and knowledge.

Ethical A portfolio option within a managed portfolio service is likely to have been designed to appeal to those clients that feel they should do something, but do not necessarily have a specific cause in mind. These portfolios are likely to be a bit generic in nature and take a negative criteria approach ie avoiding as much as possible areas that are generally considered to be ‘unethical’ (eg arms, tobacco, alcohol, animal testing).

These solutions may well be termed ‘light green’. For those clients that are going to be more specific about their beliefs and requirements, a bespoke portfolio would be the route to take. Discussion with the investment manager would elicit what types of investment to accept and what to avoid. Adviser and discretionary manager ought to be mindful that the client may well know more about the subject than they do.

These portfolios may not avoid these investments altogether, but may set a limit as a percentage of turnover.

23

Sharia While many bespoke portfolio managers will be able to turn their hands to running an ethical portfolio, the rules on running a Sharia portfolio will have no different shades of acceptability at all. Sharia law is very specific and there is no room for compromises (although interpretation of Sharia Law can vary). There is no doubt that a specialist manager would be required to run a portfolio of this nature. Unsurprisingly, only two of the discretionary firms that we cover run Sharia portfolios.

AIM portfolios for business property relief Quite apart from requiring a specialist knowledge of, and the resources to research, the smaller company end of the market there are several rules to obey for holdings to qualify for business property relief. It is clear that a specialist knowledge of the market is required. When advisers undertake due diligence in this area, in addition to client specific questions, there are six fundamental areas that should be considered:

• The firm: history of success including record of business property relief qualifying failures • Research resource • Experience of the investment team in the relevant market • Performance history (in terms of following mandate rather than absolute as many have low

growth expectations in return for lower risk). This would include payment and level of income if this is important

• Diversification: sector, themes, number of stocks • Cost You may find our guide to Business Property Relief of interest, published in September 2014: defaqto.com/advisers/resources/publications-list/case-study-business-property-relief-an-essentialfinancial-planning-solution/

Knowledge is King With more information, advisers are able to make sounder and more confident decisions on which propositions are most suitable for their clients. Not only that, with certainty of information, it will give the adviser a feel for whether the investment manager holds similar investment beliefs and therefore whether the relationship is likely to be a strong one. Defaqto has been collecting such information on managed portfolio services for the last year or so and some of the information can be quite revealing. 24

Asset allocation What assets are held where has come into focus after Brexit, with real property assets being a particular issue presently. Pre-Brexit, it is interesting to note the asset class allocations for those most likely to be affected by the result (Property, UK Equity, European Equity (excl UK)) compared to post-Brexit levels. For the 390 or so managed portfolios that are available on platform, for which we have collected information, we see the following:

Pre-Brexit

Post-Brexit

Lowest

Highest

Average exposure

Lowest

Highest

Average exposure

Property

0%

20%

5%

0%

15%

4.5%

Cash

0%

54%

7%

0%

31%

8.5%

UK Equity

0%

63%

20%

0%

63%

19%

Of course, our sample of 390 portfolios will contain some that are perhaps ultra-cautious or ultraadventurous, so we would expect to see some very high or very low allocations as a matter of course. However, just from the point of view of knowledge and finding what is most suitable for the client, allocations beyond the norm should be identified. As an example, most investors will already be invested in property through their main residence or perhaps even work premises, so an additional 20% in a portfolio may be considered too much. On the flip side, some investors may be renting and have no exposure to property, so the 20% figure may seem less extreme.

Most of us in the industry exhibit some home bias. Familiarity may appeal to some investors, but not others, especially if at the expense of a balanced and well diversified portfolio. Without information like this, it is difficult to assess whether you are in tune with the investment managers and the risk appetite of the client.

Fees Sticking with portfolios available through platforms, Defaqto has collected information that shows published fees ranging from 0.2% up to 1%. How these fees will sit with clients will depend on adviser judgements of value for money. However, once you take into account other costs, such as those of underlying funds, we find the range varies from 0.31% up to 1.8%, and don’t forget you still have to add in the platform fee and adviser charges.

Although not explicit, the level of activity within portfolios will also affect the overall costs. We have found that portfolio turnover rates vary significantly. They range from 0% up to 133%. At either end of this scale, the right tactical moves may have been taken, but without this information it is difficult to make a sound judgement and get a feel for the investment manager’s approach to portfolio management.

Once in possession of all the information, only then will a sound value for money judgement be possible.

25

The portfolios Advisers will have different views on portfolio size. Some will argue that smaller is more flexible and it is easier to make quick short-term tactical changes. However, there are some 47 portfolios on platforms that we are aware of that have no investment in them at all. Not necessarily a bad thing, but good to know.

26

Any one of these pieces of information may or may not be game-changers in terms of selecting a proposition, but together they help build a clearer picture of the proposition as a whole, which can only help in the process of ‘getting it right first time’.

Pension freedoms Criteria related to managing retirement income have become increasingly important to advisers over the last year or so as they look to discretionary firms to provide sufficient investment choice and administrative capabilities to cater for clients investing post retirement pension monies. We have seen some innovative investment strategies employed by bespoke discretionary managers, designed specifically for pension drawdown, and these would need to be investigated and understood by both adviser and client. These can be assessed on an individual client basis. For their part, as demand for ‘natural income’ paying portfolios appears to be growing, we are seeing more portfolios being launched with income as a priority. Perhaps only a trickle of launches at the moment, with most ranges only offering one or two income portfolio options, usually at the cautious end of the risk scale, we would expect this choice to grow quite quickly. Management of income in retirement has become a key issue of due diligence for many advisers.Questions asked should elicit whether the DFM firm is able to provide the client with income when and how they want it. The key issue is cash management:

• Is there a central cash account into which income is paid, consolidated (from all tax wrappers) and then paid out?

• Is the dividend income earned ‘ring-fenced’ or could it be used to offset fees? In this era of low

income, fee deduction could have a significant impact on what is distributed to clients. Clients may prefer that all income is paid out with fees being deducted from, say, a capital account that maintains a minimum cash level

• Is the income earned also ring-fenced from all transactions that are going on? • In an environment where income is a priority, DFMs should be questioned on their interest rates on cash held. In our experience, very few even beat high street current account rates

• When is income paid out? Are there sufficient options for frequency of payment? Clients will obviously differ in their preferences, but monthly as an option is likely to be popular

• How do DFMs deal with the period of time post investment, but prior to the portfolio earning

any income? This is where some of the bespoke strategies come into their own. For MPS portfolios, advisers are likely to be involved in managing this period of time and ensuring the client has sufficient funds to tide them over the initial period

• Can the income be automatically paid direct to the client’s bank account? Is there an additional cost attached to this facility?

27

MPS on platform Regardless of distribution channel, the same questions should arise. It is important to note that most of the flexibility around cash management and provision of retirement income for portfolios held on an adviser platform, are provided by that platform. The DFM’s duties start and finish with ensuring they are running portfolios to mandate and earning the right level of income. That being said, the importance of this cash management functionality should mean that DFMs, and advisers for that matter, should be putting pressure on the platforms to up their game in this area. Pension investing is, for most, by far the

28

largest investment pot a client will own. Weak cash management facilities may grow quickly as a reason for switching platforms or not selecting them in the first place. We know that some DFMs are frustrated at the inadequate systems in place on some platforms, and an additional knock-on effect is that some DFMs may not make their propositions available on certain platforms. There is some patience being exercised here as there is a realisation that implementing any changes in platform can be a long and expensive process, but there are limits to this patience.

Service We would hope that the due diligence undertaken in the discretionary selection process will lead to partnering with the right discretionary managers to deliver the right client outcomes. It is of course likely that several firms will fit the bill. In order to provide some additional differentiation between propositions, Defaqto launched their first set of DFM Service Ratings at the beginning of the year. Although it is early days, and only a handful of DFMs qualified for a rating, part of the survey discovered what was most important to advisers. Of the advisers that used DFMs, 173 contributed to this part of the survey. The following table lists the different aspects of service that are usually associated with discretionary management and how important each aspect was to advisers in relation to each other, together with their ranking. The table also indicates which of the service aspects were not meeting adviser expectations. These aspects should demand specific attention when undertaking due diligence.

Importance ranking and satisfaction discipline

Meeting industry expectations

Quality of staff – investment

Investment managers or account Meets managers are able to respond to any investment queries with knowledge and conviction, accurately reflecting any current portfolio positions or market views. Able to support the adviser firm in promoting the service

Service

Flexibility in service to client and adviser eg client meetings (frequency, depth, location), reporting frequency, reporting structure, CGT management, legacy holding approach, access to investment managers

Meets

Quality of staff – administration

DFM staff are available and able to deal with a range of enquiries in a timely manner and bring enquiry to a satisfactory conclusion

Below

Ease of doing business

The ease of doing business with the DFM firm over all aspects of the relationship

Meets

Investment flexibility – range of options

For bespoke – confidence in investment managers to run a wide range of different investment portfolio types (eg risk targeted, income, ethical, cash plus). For MPS – sufficient range of portfolio options to appeal to client base

Below

1

2

3

4

5

Discipline description

29

Importance ranking and satisfaction discipline

Discipline description

Meeting industry expectations

Existing business administration

Report delivery, payment of income, issue of contract notes, CGT reporting

Below

Investment flexibility – range of assets

The range of assets used in portfolios (eg funds, individual securities, structured products) is sufficient to meet client needs

Exceeds

Online facilities

Availability of up to date portfolio information to adviser and/or client (eg valuations, transactions, market views, previous reports)

Below

Client on-boarding

Efficiency and ease of signing up new clients with cash to invest or those with existing holdings

Exceeds

Provider financial strength and resource

As indicated by growth in discretionary assets, group AUM, discretionary AUM. Confidence in firm to run a variety of portfolio types, with the resources to do so

Exceeds

Quality of literature

Clear, easy to understand literature and terms, which give adviser and client a fair representation of the service they should expect

Below

Remuneration

Adviser charging facilities are compatible with preferred method of fee remuneration

Exceeds

Accessibility

Availability of DFM service through third-party platforms and other tax wrappers (eg SIPP, offshore bond) is compatible with current ‘buy list’

Meets

Provider brand

Perception of brand quality. Additional confidence in certain brands. For example, based on reputation, size, visibility

Exceeds

6

7

8

9

10

11

12

13

14

While it should be noted that all service aspects scored quite highly, it is worthy of note that two of the top ranked service aspects relate to administration and fail to meet adviser expectations. It may be worth advisers considering asking for a service level agreement, particularly if a considerable amount of client assets could be placed with the DFM. Food for thought.

The platform dynamic The above satisfaction survey only relates to those advisers/clients outsourcing direct to DFMs. If accessing DFM through a platform, the majority of the service aspects are provided by the platform. That being said, there are many DFMs that still provide a good supporting service to advisers, even though individual clients are likely to be unknown to the DFM and should be investigated. Separate due diligence needs to be undertaken on platforms, taking into account the provision of investment choices and tax wrappers. 30

Learning objectives Having read this discretionary market update, you should be able to: •

Understand the direction the discretionary market is taking and be able to factor in potential future changes when monitoring existing solutions and selecting new solutions



Adjust your client recommendations and selection due diligence based on recent activity and trends in the market



Be clear about the different types of discretionary solutions on offer



Describe the different discretionary solutions, relating them to client needs and suitability and as a result make better and more robust selection decisions



Achieve some clarity on what the regulators expectations are in terms of due diligence



Understand that outsourcing changes the client/adviser dynamic. Rather than the adviser providing the solution and having to defend all investment decisions, both will be working together to find the best 3rd party solution

31

Test yourself for CPD In order to assess your knowledge following completion of this publication, why not work your way through the following questions? All the answers can be found within the content of this publication. 1

What type of discretionary solution has seen the most launches since RDR implementation? a. MPS direct b. MPS on a platform c. Bespoke

2

What type of discretionary solution saw the most launches prior to 2010, yet the least since then? a. MPS direct b. MPS on a platform c. Bespoke

3

4

5

Give two fundamental reasons why an adviser firm would outsource to a third-party discretionary manager?

According to the Financial Services Authority (now FCA), in their final guidance paper FG12/16, what would they consider as good practice for the structure of a CIP (Centralised Investment Proposition)?

From the same Final Guidance paper, name five of the seven criteria that the FSA (as was) would consider minimum due diligence for analysis of a CIP component.

List five further areas of analysis that may be considered as ‘deeper due diligence’.

6

What is the common factor to two of the top three most important service attributes according to advisers surveyed? 7

This case study is accredited by the CII/PFS and CISI for up to 60 minutes of structured continuing professional development (CPD).

32

Name

Date

Signature

CPD time recorded

Send us your feedback Your feedback is extremely important to us and we would be grateful if, after reading this publication, you would take a few minutes to complete a short survey. Your answers will be treated in the strictest confidence and the results of this will help the development of future publications. The survey can be accessed at www.snapsurveys.com/wh/s.asp?k=144610976149

33

Appendix

34

Provider

Product

Suitability responsible

Ethical option

Svce fee pa £250k inv %

Min investment £

Albert E Sharp

Bespoke Portfolio Service

ns

ns

ns

£-

Alpha Portfolio Management

Bespoke Portfolio Service – Charging Option 1

no

yes

1

£100,000.00

Alpha Portfolio Management

Bespoke Portfolio Service – Charging Option 2

no

yes

0.25

£100,000.00

Bordier & Cie (UK) PLC

Wealth Management Service

no

no

1.2

£250,000.00

Brewin Dolphin

Discretionary Service

no

yes

1

£150,000.00

Brooks Macdonald

Bespoke Portfolio Service – Option 1

no

yes

0.75

£200,000.00

Brooks Macdonald

Bespoke Portfolio Service – Option 2

no

yes

1

£200,000.00

Brown Shipley

Premium Portfolio Service – Fee plus commission

yes

yes

0.75

£250,000.00

Canaccord Genuity Wealth Management

Discretionary Portfolio Management

no

yes

0.75

£250,000.00

Cazenove Capital Management

Discretionary Service

no

yes

0.85

£200,000.00

Charles Stanley & Co Ltd

Bespoke Discretionary Management - Standard Fee

no

yes

0.85

£80,000.00

Church House Investment Management

Discretionary Management Service

yes

no

1

£250,000.00

City Asset Management

Bespoke Discretionary Management

no

yes

0.65

£150,000.00

Close Brothers Asset Management

Bespoke Portfolios Option 1 (Clean Fee)

no

yes

1 (at £1m)

£1,000,000.00

Close Brothers Asset Management

Bespoke Portfolios Option 2 (Fee + Dealing)

no

yes

0.75 (at £1m)

£1,000,000.00

Cornelian Asset Managers Ltd

Discretionary Investment Management Services

yes

yes

0.75 (at £500K)

£300,000.00

European Investment Management Ltd

Bespoke Discretionary Management

yes

yes

1

£100,000.00

Fieldings

Bespoke Discretionary Management – Option 1

ns

ns

ns

£-

Fieldings

Bespoke Discretionary Management – Option 2

ns

ns

ns

£-

GHC Capital Markets

Bespoke Portfolio Service (BPS)

yes

yes

0.75

£100,000.00

Groupe Financiere Hottinger & Co Ltd

Discretionary Fund Management

ns

ns

ns

£-

Hargreave Hale

Discretionary Investment Management

no

no

0.75

£-

Provider

Product

Suitability responsible

Ethical option

Svce fee pa £250k inv %

Min investment £

Hawksmoor Investment Management Limited

Bespoke Discretionary Portfolio Management Service

no

yes

0.75

£-

Investec Wealth & Investment Limited

Discretionary Fund Management Fee + Commission

no

yes

0.75

£150,000.00

Investec Wealth & Investment Limited

Discretionary Fund Management Fee Only

no

yes

1

£150,000.00

IPS Capital LLP

IPS Discretionary Investment Management Service

yes

yes

1 (at £500K)

£500,000.00

James Brearley & Sons

Portfolio Management Service-(1)Inclusive Bespoke

yes

yes

1

£50,000.00

James Brearley & Sons

Portfolio Management Srvc-(2) Transaction Bespoke

yes

yes

0.6

£50,000.00

James Hambro & Partners LLP

Bespoke Portfolio - Fee Only

yes

yes

1.15 (at £500K)

£500,000.00

James Hambro & Partners LLP

Bespoke Portfolio - Fee plus Commission

yes

yes

1 (at £500K)

£500,000.00

JM Finn & Co

Discretionary Management Service Fee & Commission

yes

no

0.75

£100,000.00

JM Finn & Co

Discretionary Management Service Fee only

yes

no

1.2

£100,000.00

King & Shaxson Capital Limited

Personal Discretionary Service

no

yes

0.65

£250,000.00

Kleinwort Benson

Bespoke Portfolio Service

no

yes

1 (at £5m)

£3,000,000.00

Kleinwort Benson

Discretionary Portfolio Service

no

yes

1

£250,000.00

LGT Vestra LLP

Discretionary Investment Management Services

yes

yes

0.75

£250,000.00

London and Capital

Discretionary Investment Management

yes

yes

1.25 (at £1m)

£1,000,000.00

McInroy & Wood

Discretionary Investment Management Service

yes

no

1

£-

MitonOptimal Portfolio Management (CI)

Bespoke Portfolio Service

no

yes

1

£250,000.00

Mole Valley Asset Management

Bespoke Discretionary Portfolios

yes

no

0.6

£15,240.00

Mountstone Partners Ltd

Bespoke Portfolio Management

yes

yes

1 (at £500K)

£500,000.00

Myddleton Croft Investment Managers

Bespoke Portfolio Service

no

yes

0.75

£60,000.00

OCM Asset Management

Discretionary Fund Management - Bespoke

yes

yes

0.49

£5,000.00

Pilling & Co Stockbrokers Ltd

Discretionary Management Service

ns

ns

ns

£-

Psigma Investment Management

Bespoke Portfolio

yes

no

1

£250,000.00

35

36

Provider

Product

Suitability responsible

Ethical option

Svce fee pa £250k inv %

Min investment £

Quartet Capital Partners LLP

Bespoke Discretionary Service

yes

yes

0.9

£200,000.00

Quilter Cheviot

Discretionary Investment Management – Option 1

yes

yes

0.75

£200,000.00

Quilter Cheviot

Discretionary Investment Management – Option 2

yes

yes

1

£200,000.00

Rathbone Investment Management

Individual Portfolio Service

yes

yes

1.2

£100,000.00

RC Brown Investment Management Plc

Bespoke Portfolio Service – Conventional Fee

no

yes

1.25

£15,000.00

RC Brown Investment Management Plc

Bespoke Portfolio Service – Performance Fee

no

yes

0.625

£15,000.00

Redmayne-Bentley

Bespoke Discretionary – Fee + Commission

yes

yes

0.5

£50,000.00

Redmayne-Bentley

Bespoke Discretionary – Fee only

yes

yes

0.95

£50,000.00

Rowan Dartington & Co Limited

RD Signature Bespoke Portfolio Service Fee + comm

no

yes

0

£100,000.00

Rowan Dartington & Co Limited

RD Signature Bespoke Portfolio Service Fee only

no

yes

0.75

£100,000.00

Ruffer LLP

Bespoke Discretionary Portfolio Management

ns

ns

ns

£-

S C Davies & Co

Bespoke Management Service

ns

ns

ns

£-

Sanlam Private Wealth

High Net Worth Service

no

yes

1

£250,000.00

Seven Investment Management

Discretionary Management Service

no

yes

0.25

£200,000.00

Smith & Williamson

Portfolio Investment Account - Option 1

yes

yes

1

£100,000.00

Smith & Williamson

Portfolio Investment Account - Option 2

yes

yes

0.75

£100,000.00

Standard Life Wealth

Bespoke Portfolio Management

yes

yes

0.975 (at £500K)

£500,000.00

TAM Asset Management

Premier Full Discretionary Service

no

yes

1

£100,000.00

Thesis Asset Management

Personal Investment Portfolio Service – (Fee only)

yes

yes

0.9

£150,000.00

Thomas Miller Investment Ltd

Discretionary Investment Management

yes

yes

1

£250,000.00

Tilney for Intermediaries

Investment Management Service

yes

yes

0.75

£200,000.00

Vertem Asset Management

Bespoke Portfolio Solution

yes

yes

1

£50,000.00

Walker Crips

Walker Crips Bespoke Portfolios

yes

yes

0.8

£100,000.00

Waverton Investment Management Ltd

Discretionary Management Services

yes

yes

1 (at £500K)

£500,000.00

Provider

Product

Suitability responsible

Ethical option

Svce fee pa £250k inv %

Min investment £

WHIreland

Bespoke Portfolio Service - Fee Only

yes

yes

1

£100,000.00

WHIreland

Bespoke Portfolio Service - Fee plus commission

yes

yes

0.5

£100,000.00

Whitechurch Securities Ltd

Prestige Investment Management Service

no

yes

0.45

£50,000.00

Provider

Product

Dist channel

Num of Ethical EMB portfolio option income options portfolio options

Svce fee Platform partners pa £250k inv %

Albert E Sharp

Model Portfolio Service Direct

direct

ns

ns

ns

ns

ns

Albert E Sharp

Model Portfolio Service Platform

platform

ns

ns

ns

ns

ns

Alpha Portfolio Management

Managed Portfolio Service – Collectives – Platform

platform

10

yes

2

0.4

Cofunds, Novia, Nucleus, Transact

Alpha Portfolio Management

Managed Portfolio Service - Collectives only

direct

12

yes

2

0.65

Cofunds, Novia, Nucleus, Transact

Alpha Portfolio Management

Managed Portfolio Service – Direct Equity + Collective

direct

8

no

2

0.8

none

Apollo Multi Asset Management

Athena Controlled Risk Discretionary – Platform

platform

10

no

1

0.51

7IM, Aegon, Ascentric, Aviva, Axa, Novia, Nucleus, Transact, Zurich

Arbuthnot Latham & Co Ltd

Collective Investment Services

direct

10

yes

1

1 (at £500K)

none

Arbuthnot Latham & Co Ltd

Direct Investment Services

direct

8

yes

1

1 (at £500K)

none

Beaufort Investment Management

Discretionary Portfolio Management – Platform

platform

42

yes

2

0.3

7IM, Axa, Standard Life, Transact

Bordier & Cie (UK) PLC

Bordier (UK) Managed Portfolio Service

direct

5

no

0

0.75

Ascentric, Aviva, Axa, Fusion, Novia, Nucleus, Praemium, Standard Life, Transact, Zurich

Bordier & Cie (UK) PLC

Platform Managed Portfolio Service

platform

5

no

0

0.3

Ascentric, Aviva, Axa, Fusion, Novia, Nucleus, Praemium, Standard Life, Transact, Zurich

Brewin Dolphin

Managed Portfolio Service

platform

5

no

1

0.3

Aegon, Ascentric, Aviva, Axa, Fusion, James Hay, Novia, Nucleus, Standard Life, Zurich

37

38

Provider

Product

Dist channel

Num of Ethical EMB portfolio option income options portfolio options

Svce fee Platform partners pa £250k inv %

Brooks Macdonald

Managed Portfolio Service

direct

10

no

6

0.75

Ascentric, Aviva, Axa, Fusion, Novia, Nucleus, Standard Life, Succession, Transact

Brooks Macdonald

Platform Managed Portfolio Service

platform

8

no

6

0.4

Ascentric, Aviva, Axa, Fusion, Novia, Nucleus, Standard Life, Succession, Transact

Brown Shipley

Platform Model Portfolio Service

platform

12

no

2

0.3

Ascentric, Novia, Standard Life, Transact

Canaccord Genuity Wealth Management

GPS Optimized Portfolio - Direct

direct

5

no

ns

0.8

Ascentric, Axa, Fusion, Novia, Nucleus, Transact

Canaccord Genuity Wealth Management

GPS Optimized Portfolio – Platform

platform

5

no

ns

0.5

Ascentric, Axa, Fusion, Novia, Nucleus, Transact

Canaccord Genuity Wealth Management

MPS (Managed Portfolio Service)

direct

7

no

1

0.75

Ascentric, Axa, Fusion, Novia, Nucleus, Transact

Canaccord Genuity Wealth Management

MPS (Managed Portfolio Service) – Platform

platform

7

no

1

0.5

Ascentric, Axa, Fusion, Novia, Nucleus, Transact

Cazenove Capital Management

Managed Portfolio Service – Platform

platform

6

no

1

0.3

Standard Life

Charles Stanley & Co Ltd

Collectives Portfolio Service

direct

12

no

4

0.75

Aegon, Ascentric, Aviva, Fusion, Novia, Nucleus, Standard Life, Transact, Zurich

Charles Stanley & Co Ltd

Collectives Portfolio Service – Platform

platform

12

no

4

0.3

Aegon, Ascentric, Aviva, Fusion, Novia, Nucleus, Standard Life, Transact, Zurich

Charles Stanley & Co Ltd

DFM Model Portfolio Service

direct

3

no

1

0.75

Fusion

Charles Stanley Pan Asset

PanASSET Model Portfolio

platform

6

no

ns

0.2

Aegon, Ascentric, Aviva, Novia, Nucleus, Standard Life, Transact, Zurich

Charles Stanley Pan Asset

PanDYNAMIC Model Portfolio

platform

7

no

1

0.2

Ascentric, Aviva, Novia, Nucleus, Standard Life, Transact

Church House Investment Management

Church House Advantage Managed Portfolio Service

direct

6

no

4

0.25

Parmenion

City Asset Management

Platform Based Model Portfolios

platform

6

no

1

0.25

Aviva, Axa, Novia, Transact

Clarion Investment Management Limited

Discretionary Investment Management

platform

13

no

ns

0.75

Axa, Raymond James

Close Brothers Asset Management

Discretionary Managed Services

direct

5

yes

2

1

none

Provider

Product

Dist channel

Num of Ethical EMB portfolio option income options portfolio options

Svce fee Platform partners pa £250k inv %

Close Brothers Asset Management

Managed Portfolio Service

direct

4

no

1

0.3

Ascentric, Novia, Nucleus, Standard Life

Close Brothers Asset Management

Managed Portfolio Service – Platform

platform

4

no

1

0.3

Ascentric, Novia, Nucleus, Standard Life

Cornelian Asset Managers Ltd

Managed Portfolio Service

direct

6

no

1

0.87

Novia

Cornelian Asset Managers Ltd

Managed Portfolio Service – Platform

platform

5

no

ns

0.3

Novia

EQ Investors

Absolute Return Portfolios

platform

1

no

0

0.35

Novia

EQ Investors

Positive Impact Portfolios

platform

7

yes

ns

0.35

Novia

European Investment Management Ltd

Model Portfolio Service – MOSAIC Platform

platform

5

no

ns

0.6

Nucleus

Fairstone Private Wealth Ltd

Managed Portfolio Service

direct

13

no

2

0.4

in-house platform

Fairstone Private Wealth Ltd

Managed Portfolio Service – Platform

platform

13

no

2

0.4

Aegon, Ascentric, Aviva, Cofunds, James Hay, Novia, Nucleus, Old Mutual Wealth, Standard Life, Transact, Zurich

GAM London Limited

Discretionary Fund Management

direct

5

no

0

0.7

7IM, Ascentric, Novia

GAM London Limited

Managed Portfolios Service – Platform

platform

5

no

0

0.25

7IM, Ascentric, Novia

GHC Capital Markets

Dynamic Core Satellite (DCS)

direct

6

no

ns

0.75

none

GHC Capital Markets

Optimised Portfolio Service (OPS)

direct

7

no

ns

0.75

none

Hawksmoor Investment Management Limited

The Model Portfolio Service

platform

6

no

1

0.3

Ascentric, Aviva, Novia, Standard Life, Transact

Heartwood Investment Management

Discretionary Portfolio Management

direct

8

yes

0

1 (at £1m)

none

Heartwood Investment Management

Platform Model Portfolios – Ascentric

platform

4

no

0

0.4

Ascentric, Fusion, Novia

Heartwood Investment Management

Platform Model Portfolios – Fusion and Novia

platform

4

no

2

0.3

Ascentric, Fusion, Novia

Investec Wealth & Investment Limited

Master Portfolio Service

direct

6

no

1

0.85

none

39

40

Provider

Product

Dist channel

Num of Ethical EMB portfolio option income options portfolio options

Svce fee Platform partners pa £250k inv %

IPS Capital LLP

IPS Managed Portfolio Service

platform

3

no

0

0.3

Ascentric, James Hay, Novia, Standard Life, Transact

James Brearley & Sons

Portfolio Management Service – (1) Inclusive Model

direct

7

yes

1

1

James Brearley & Sons

James Brearley & Sons

Portfolio Management Service – (2) Transaction Model

direct

7

yes

1

0.6

James Brearley & Sons

King & Shaxson Capital Limited

Platform Ethical Portfolios

platform

5

yes

1

0.5

Ascentric, Aviva, Novia, Nucleus, Succession, Transact

Kleinwort Benson

Managed Portfolio Strategies

platform

6

no

2

0.35

Ascentric, Aviva, Axa, Novia, Nucleus, Standard Life, Transact

LGT Vestra LLP

Model Portfolio Service

direct

6

no

1

0.25

7IM, Aegon, Alliance Trust,Ascentric, Aviva, Axa, Cofunds, Funds Network, James Hay, Novia, Nucleus, Old Mutual Wealth, Platform One, Praemium, Standard Life, Succession, Transact, Zurich

LGT Vestra LLP

Platform Model Portfolio Service

platform

6

no

1

0.25

7IM, Aegon, Alliance Trust, Ascentric, Aviva, Axa, Cofunds, Funds Network, James Hay, Novia, Nucleus, Old Mutual Wealth, Platform One, Praemium, Standard Life, Succession, Transact,Z urich

Liontrust Investment Solutions Ltd

Managed Portfolio Service – Platform

platform

22

no

6

0.3

Aegon, Aviva, Novia, Standard Life, Transact, Zurich

Liontrust Investment Solutions Ltd

Wealth Solutions Service

direct

27

no

6

0.32

none

London and Capital

Discretionary Managed Portfolios

platform

10

no

3

0.25

7IM, Aegon, Ascentric, Aviva, Novia, Nucleus, Standard Life, Transact, True Potential, Zurich

London and Capital

Global Model Portfolio Service

platform

5

no

0

1

7IM, Aegon, Ascentric, Aviva, Novia, Nucleus, Standard Life, Transact, True Potential, Zurich

Morningstar Investment Management Europe

Governed Portfolios (Aviva)

platform

5

no

1

0.15

Aviva

Provider

Product

Dist channel

Num of Ethical EMB portfolio option income options portfolio options

Svce fee Platform partners pa £250k inv %

Morningstar Investment Management Europe

Morningstar Managed Portfolios

platform

16

no

2

0.3

7IM, Aegon, Alliance Trust, Ascentric, Aviva, Cofunds, Funds Network, James Hay, Novia, Nucleus, Old Mutual Wealth, Standard Life, Transact, Zurich

Myddleton Croft Investment Managers

Model Portfolio Service – Platform

platform

8

no

0

0.6

Ascentric, Novia, Nucleus, True Potential

Nedbank Private Wealth

Discretionary Investment Management Service

direct

4

no

1

0.75 (at £500K)

none

Newscape Capital Group

Model Portfolio Service

platform

11

no

1

0.35

Ascentric, Aviva, Cofunds, Funds Network, Novia, Praemium, Succession, Transact

Novia Financial plc

Copia Capital Management

direct

10

no

0.3

Novia

OCM Asset Management

Discretionary Fund Management – Model

direct

4

no

0

0.35

Ascentric, Avalon, Aviva, Axa, Novia, Nucleus, Standard Life, Transact

OCM Asset Management

Discretionary Fund Management – Model – Platform

platform

4

no

0

0.35

Ascentric, Avalon, Aviva, Axa, Novia, Nucleus, Standard Life, Transact

Octopus Investments

Octopus Portfolio Manager (OPM) Direct

direct

10

no

0

0.65

7IM, Ascentric, Aviva, Axa, Fusion, Novia, Nucleus, Standard Life, Transact, Zurich

Octopus Investments

Octopus Portfolio Manager (OPM) Platform

platform

8

no

0

0

7IM, Ascentric, Aviva, Axa, Fusion, Novia, Nucleus, Standard Life, Transact, Zurich

Old Mutual Wealth

WealthSelect Managed Portfolio Service

direct

16

no

ns

0

Old Mutual Wealth

Old Mutual Wealth

WealthSelect Managed Portfolio Service – Platform

platform

16

no

ns

0

Old Mutual Wealth

Parallel Investment Management

Model Portfolio Service

platform

9

yes

2

0.3

Ascentric, Axa, Fusion, Standard Life

Parmenion Capital Partners LLP

Discretionary Management Service

direct

130

yes

10

0.3

Parmenion

Pilling & Co Stockbrokers Ltd

Pilling Ideal Portfolio

direct

ns

ns

ns

ns

ns

41

42

Provider

Product

Dist channel

Num of Ethical EMB portfolio option income options portfolio options

Svce fee Platform partners pa £250k inv %

Premier Asset Management

Premier Portfolio Management Service - Model

direct

11

no

3

1

Ascentric, James Hay, Novia

Premier Asset Management

Premier Portfolio Management Service – Platform

platform

11

no

3

0

Ascentric, James Hay, Novia

Price Bailey Financial Planning

Portfolio Management Service

direct

9

no

2

0.35

Praemium

Prospect Wealth Model Portfolio Management Service

direct

6

yes

0

0.75

none

Psigma Investment Management

Managed Portfolio Service

direct

6

no

2

0.5

Ascentric, Aviva,Funds Network, Fusion, Standard Life, Transact

Psigma Investment Management

Psigma Platform Portfolios

platform

5

no

2

0.35

Ascentric, Aviva, Funds Network, Fusion, Standard Life, Transact

Quilter Cheviot

Managed Portfolio Service

direct

11

no

3

0.85

Ascentric, Aviva, Fusion, Novia, Nucleus, Old Mutual Wealth, Standard Life

Quilter Cheviot

Managed Portfolio Service – Platform

platform

6

no

2

0.3

Ascentric, Aviva, Fusion, Novia, Nucleus, Old Mutual Wealth, Standard Life

Richmond House Investment Services Ltd

Discretionary Management Services

platform

7

no

1

0.5

Ascentric, Axa, Cofunds, James Hay, Standard Life, Transact

Rowan Dartington & Co Limited

RD Signature Collective Port Service – Platform

platform

7

yes

2

0.35

Ascentric, Aviva, Axa, Fusion, Novia, Nucleus, Standard Life, Transact

Rowan Dartington & Co Limited

RD Signature Collective Portfolio Service

direct

7

yes

2

0.35

Ascentric, Aviva, Axa, Fusion, Novia, Nucleus, Standard Life, Transact

Saltus Investment Managers

DFM-on-Wrap

platform

3

no

0

1

Ascentric, Axa, Novia, Nucleus, Praemium, Transact, True Potential

Saltus Investment Managers

Direct DFM

direct

3

no

0

1

in-house platform

Sanlam FOUR Investments UK Limited

Sanlam Model Portfolios

platform

12

yes

0

0.3

Ascentric, Novia, Nucleus, Sanlam, Succession, Transact

Sanlam Private Wealth

Managed Funds Portfolio Service

direct

11

yes

2

1

none

Sarasin & Partners

Sarasin Model Portfolios

platform

5

no

0

0.25

Aegon, Ascentric, Standard Life

Seven Investment Management

Model Portfolio Service

direct

6

no

1

0.25

7IM, Aegon, Ascentric, Aviva, Fusion, James Hay, Novia, Nucleus, Standard Life, Transact

Provider

Product

Dist channel

Num of Ethical EMB portfolio option income options portfolio options

Svce fee Platform partners pa £250k inv %

Seven Investment Management

Model Portfolio Service Platform

platform

6

no

1

0.25

7IM, Aegon, Ascentric, Aviva, Fusion, James Hay, Novia, Nucleus, Standard Life, Transact

Shipman Investment Managers

Managed Portfolio Service

platform

6

yes

1

0.6

Praemium

Smith & Williamson

Managed Portfolio Service (MPS)

platform

6

no

0

0.3

Ascentric, Aviva, James Hay, Novia, Transact

Standard Life Wealth

Managed Portfolio Service

direct

10

no

2

0.3

Standard Life

Strand Capital

Model Portfolio Service

direct

5

no

ns

0.7

Novia

TAM Asset Management

Focus Model Portfolio

direct

4

no

0

0.5

Aviva

TAM Asset Management

TAM Ethical Portfolio

direct

5

yes

0

0.65

Aviva

TAM Asset Management

TAM Ethical Portfolio Platform

platform

5

yes

0

0.4

Aviva

TAM Asset Management

TAM Sharia Portfolio

direct

5

no

0

1

Aviva

Tatton Investment Management

Tatton Strategic Managed Portfolio Service (SMPS)

platform

24

yes

6

0.2

Aegon, Amber, Aviva, Novia, Nucleus, Standard Life, Transact

Tavistock Wealth

Central Investment Proposition – Partner Profiles

platform

ns

ns

ns

ns

ns

Tavistock Wealth

Central Investment Proposition – Tavistock Profiles

platform

ns

ns

ns

ns

ns

Thesis Asset Management

Thesis Model Portfolio Service

direct

19

no

0

0.75

Ascentric, Aviva, Fusion, Novia, Nucleus, Standard Life, Transact

Thesis Asset Management

Thesis Model Portfolio Service – Platform

platform

19

no

0

0.4

Ascentric, Aviva, Fusion, Novia, Nucleus, Standard Life, Transact

Thomas Miller Investment Ltd

Model Portfolio Service

platform

6

no

0

0.3

Ascentric, Transact

Tilney for Intermediaries

Managed Portfolio Service – Direct

direct

9

no

4

0.5

James Hay, Standard Life

Tilney for Intermediaries

Managed Portfolio Service – Platform

platform

9

no

4

0.3

James Hay, Standard Life

Walker Crips

Actively Managed Portfolio Service – RTI

direct

10

no

5

0.8

Aviva, Novia, Transact

43

44

Provider

Product

Dist channel

Num of Ethical EMB portfolio option income options portfolio options

Svce fee Platform partners pa £250k inv %

Walker Crips

Actively Managed Portfolio Service – RTIP

platform

5

no

ns

0.3

Aviva, Novia, Transact

Walker Crips

Alpha:r2

direct

8

yes

4

0.7

Aviva, Novia

Walker Crips

Alpha:r2 Platform

platform

8

yes

4

0.3

Aviva, Novia

Waverton Investment Management Ltd

Model Portfolios based on Platform

platform

6

no

0

0.4

7IM, Alliance Trust, Ascentric, Aviva, Axa, Fusion, Novia, Nucleus, Standard Life, Transact

Wellian Investment Solutions

Investment Solutions Portfolio – Model

direct

9

yes

2

0.75

7IM, Ascentric, Aviva, Axa, Novia, Nucleus, Standard Life, Transact, True Potential, Wealthtime

Wellian Investment Solutions

Investment Solutions Portfolio – Platform

platform

9

yes

3

0.35

7IM, Ascentric, Aviva, Axa, Novia, Nucleus, Standard Life, Transact, True Potential, Wealthtime

Whitechurch Securities Ltd

Portfolio Management Service – Direct

direct

9

yes

0

0.75

Axa, Novia, Standard Life, Transact

Whitechurch Securities Ltd

Portfolio Management Service – Platform

platform

4

yes

2

0.5

Axa, Novia, Standard Life, Transact

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