By Minerva Fund Management Solutions
For a number of years, financial advisory firms have operated in an environment that is ever changing and bringing increased challenges to their business model. One challenge is managing a range of client portfolios across a range of clients and asset classes.
As a financial advisory firm, it is an expectation that the suite of products offered will be broad, flexible and potentially encompass a range of investment options that meets a varied set of client needs, particularly for firms holding themselves out as independent.
PROD has resulted in financial advisory firms offering their clients solutions based on client lifecycles (the ‘target market’), that can contain a variety of investment solutions including active, passive, blended options, bespoke investment management and the ability to meet a client’s ESG preferences.
Needless to say, Consumer Duty is a piece of FCA regulation that brings another challenge, which requires a financial advisory firm to scrutinise their business and formally document how they meet the four client outcomes, taking into consideration a number of requirements such as client needs and the associated costs aligned to a level of service or tariff that represents fair value.
This has led financial advisory firms to explore opportunities to simplify their processes, and one opportunity that is generating more interest is unitising existing client investment solutions within their Centralised Investment Proposition (CIP).
The rationale for this is due to a variety of reasons, so there is no ‘one size fits all’ approach but to give you an example; under the Consumer Duty, good client outcomes for all clients is one of the core principles, if a financial advisory firm is managing a CIP across multiple platforms and each platform trades with a different modus operandi, then investment outcomes will inevitably be varied across their client base. Firms will need to think through the implications of this under their Consumer Duty procedures.
A unitised fund solution can enable a financial advisory firm and its clients to access the same investment solution and have similar investment outcomes. In addition, there are a number of other factors that could lead a financial advisory firm to consider unitisation as an option for their business. It has the potential to provide:
- Greater transparency in terms of cost, performance, and volatility
- All client portfolios with access to the same investment strategy at the same cost, regardless of their asset value
- More efficient and lower cost portfolio rebalancing
- An additional layer of governance and investment oversight, through the ACD and the fund’s Depositary
- Access to a greater asset universe
- Scalability of client solutions and investment proposition
- Different tax treatment – a fund will be taxed differently from an MPS
In addition to the above, in our view, a unitised fund solution may help a financial advisory firm satisfy two of the four outcomes under Consumer Duty, namely Products and Services and Price and Value. This is because under the Consumer Duty, products that already comply with the Product Governance Rules in PROD and the Collective Investment Scheme Assessment of Value Rules in COLL, can satisfy these two Consumer Duty Outcomes. As a result, the use of FCA regulated unitised funds could achieve these two outcomes.
So, there are a number of fundamentals as to why a financial advisory firm could consider this option to augment their CIP. However, before a financial advisory firm reaches a conclusion that a unitised offering is a good move for their business, there are other factors that need to be considered before they can press the start button.
As a starting point, a financial advisory firm will need to compare a client’s current proposition with the potential unitised investment offering. Prior to undertaking this comparison, there is perhaps a perception that a fund offering may increase the ongoing charges figure (‘OCF’). However, this is not always the case and before making this assumption, it is always worth having an in-depth discussion with potential providers. Of course, one key factor in an overall OCF is fund size, and in our experience, making a unitised solution as part of a CIP viable requires AuM of at least £50m per fund.
Another aspect to consider is client reporting. A client using a Model Portfolio Service for example, can have the added benefit of a client viewing individual holdings in a quarterly valuation and take comfort their portfolio is diversified; compared to a unitised solution with just one or two fund holdings. Having said that, there are technology solutions that are available and will offer a ‘look through’ service.
In essence, there is no overriding rationale as to why a financial advisory firm should, or should not, offer a unitised investment solution to their clients. The most optimal outcome will, of course depend on their business model, client requirements and what is most suitable for their clients.
Find out more. Contact Mark Catmull, Sales and Marketing Director, Minerva Fund Management Solutions.