Mackay signed to Arsenal FC - The FSA's Consultation Paper on Platforms

Holly29th June 2012

So the big news this week is the FSA's Consultation Paper reviewing payments to platforms and cash rebates. The main theme discussed in the rags is the ban on platforms being funded by product providers i.e. for platforms to charge no 'explicit' fee but retain the 25bps or so from the fund manager. This was thought to provide a mechanism for commission to continue being paid. I don’t see this myself but see no point in arguing the toss anymore. The regulator has been very clear about its intent to ban cash rebates. It is as likely to change its mind as I am to score the winning goal for Arsenal in next year's FA Cup Final. I thought Ascentric's press release on this point (rebates, not my football prowess) was resigned yet elegant.

The regulator observes that these payments make price comparison between platforms difficult AND lead to product bias for those supplying products with no rebate i.e. passives, ETFs, investment trusts. Both of these observations are true.

But as for the price comparison issue, I'm not convinced that this will be cleared up by the rebate ban. Banning cash rebates will not really make platform comparisons that much easier. We live in an era of confusion pricing and I see no catalyst for change either in the advised or non-advised markets. Think of mobile phone providers or Ryan Air charging people for a pee. Platform pricing models are varied and complex.

In this paper, I think that we hear what is really driving the agenda in a louder voice than ever. The FSA, in my opinion, want great fat headlines about how they have brought down fund manager charges, especially for those who underperform. Hooray, cry the crowds, as the regulator smote the greedy underperforming dragons. "We would be surprised and disappointed if permitting unit rebates did not lead to fund prices falling..." This is largely driven by an agenda to reduce charges and encourage price competition. And I suspect it probably will.

Surprising though that the FSA cite specific numbers and prices in the report...." a clean share class of around 75bps..." Let's not forget the rules of a free market and I think we will see better fund managers reject this spurious price tag of 75bps rather randomly allocated 12 years ago (when Egg and Fidelity popped their platformy heads up) and charge what they think they are worth. Of course, for others, this means they can probably only get away with charging something embarrassingly low. Viva competition and I think this will be a healthy outcome for us all.

Of course it was generally tough news for the direct platforms as the FSA rightly observe how prices charged (or rebates kept) by these guys are typically higher than the advised platforms. 75bps (and the rest) instead of an advised platform's 25bps (and the rest). OK there’s a loyalty discount sometimes but still….Some comments from direct platforms that this is not the case feel partisan. The paper also rightly observes that consumers' buying decisions are -or can be- influenced by direct platforms. I think extending the ban to direct platforms is fair. However I also think those direct platforms which have built service propositions based on more than simply offering a discount on a fund will be OK. I have about 15 accounts with direct platforms and I think some of them would be, and are, worth paying for - were I not just a sad, nosey geek.

Now we get to what I think could be an exciting outcome for the industry. When we actively have to pay for something, we are fussier about what it does. The impact across both advised and non-advised platforms of consumers needing to 'write a cheque' to a platform provider will lead, I think, to a greater focus on making these platforms great solutions not just for advisers, but also for consumers. The adviser platform market development agenda has been dictated by IFAs and these have been a service firstly for the IFA, and secondly for the end-client. I hope we see a re-focus from the platforms away from principally IT infrastructure to digital customer support and engagement – this would be a good outcome for IFAs and their clients alike. Margin pressure on platforms is a challenge but could we see the emergence of 2 IT teams - one focussing on administrative and regulatory requirements and one focussing on making the experience great for customers? Those who don’t will lose customers.

Another outcome of removing bundled pricing structures is to make the terms fund supermarket and wrap obsolete in the future. They’ll just be platforms. I'd really like to see them competing simply on how good they are, not on what their heritage is. Enough of the inter-camp sniping.

The 2 supporting research documents from NMG and Deloitte make for very interesting reading and are thorough, good pieces of work. I'm not sure that they really made the case for banning cash rebates though - but interesting reading for platform gonks like me. Sobering analysis on the fixed costs to run a 'fund supermarket' and also on revenue numbers and profit margins. An average implied cost of 29bps is high and there are a lot of bodies being thrown at this.

A huge amount of data in the Deloitte report was from The Platforum. Whilst we're obviously deeply flattered that the FSA and Deloitte have chosen to use our work so extensively, it would have been nice for Deloitte to ask permission. Or even to buy a copy of some of the research used!

Over and out. Back from Fund Forum in Monaco at the start of the week and after 3 days in Daddy's care, the pigz have gone feral. Bee vaulted her cot last night and Hamish is obsessed with bottoms. Oh the joy.

Have a good weekend everyone

Holly

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