On 17 July 2017, the FCA published the terms of reference of a market study into the investment platform market (MS17/1.1).
The plan is to check whether platforms help clients, or just serve as useful means of extracting cash from them. The FCA want to see how platforms compete, or perhaps why they don’t compete as they might.
The FCA will aim to publish an interim report by summer 2018, and initially asks feedback on the scope by 8 September 2017.
This is a big one, and combined with the FCA asset management study it is fair to say “there is a lot going on at the moment.”
The FCA survey mentions the word “value” 49 times in the paper. But how do the FCA propose to measure the value that all the money spent on platforms brings? And how will they set about intervening? IFAs are the jam in the sandwich, because they take more and more, and yet more and more of their work is automated by platforms. We believe that FCA may force more IFAs to justify their fees – time per hour etc.
Equally the IFA is under pressure from the Asset Management Study. Once again the IFA takes between half and a third of the TER and once again, history tells us that IFA s are the go to punchbag in financial services. History also tells us that every time the IFAs get hit with more regulation, their incomes rise and customers pay more.
MiFiD 2 and the policy statement's 4-digit page count!
In relation to the FCA's inducement rules there are changes coming in from Mifid 2.
The general RDR ban on advisers from accepting inducements continues. However there are much more subtle implications. This is currently in relation to advice on retail investment products to retail clients only.
The ban will be extended to DFM which hitherto has escaped from the ban, and has continued to accept inducements from fund managers.These DFMs sometimes rebated the money back to their clients, but this will be banned.
A new rule states that only non-monetary benefits will be accepted in relation to advice on retail investment products.
However there is some relief from the relentless pursuit of conflicts of interest.
Firstly, the FCA will consult again on the proposal to apply the inducements ban more widely to a firm's business of providing advice (and not just in relation to specific personal recommendations) and secondly the ban on professional clients receiving and rebating monetary benefits will not now be introduced.