MIFID II – HOW? WOW?

Yesterday I had the pleasure of taking part in the latest Paraplanner Howwow; a fun packed hour (no, really) discussing MIFID II costs and charges disclosure with Richard Allum and Benjamin Fabi. If you missed it live you can catch up at your leisure here https://www.crowdcast.io/e/howwow-jan19

If you’ve never seen a Howwow before, you’re missing out. Richard has quietly built a hugely impressive community of geeks professionals who really want to engage in the nitty-gritty detail. The driving purpose of this group is to share best practice and help the industry improve how it goes about things, to provide better customer experiences. I really admire them and always learn a huge amount whenever I’m with them.

Yesterday was no exception. The full hour was devoted to looking at how platforms, but more importantly paraplanners and advisers, are approaching the imminent MIFID II ex-post reporting. If you haven’t seen our research on this already (where have you been!), jump back a week to see what we are talking about and then come back here once you are up to speed. Also, it’s worth noting that Transact has supplied its answers to our research, so we’re now covering 16 platforms. (thanks Transact!).

*STOP THE PRESSES – Big thanks to Fundsnetwork as it has also now supplied answers. We’ll include them asap.*

So, what were the main conclusions from the webinar?

Firstly, the audience gave a big thumbs up to the platforms (that represent the vast majority of the industry) who have helped us compile this research. The steps they are taking to be transparent with their plans is hugely helpful to advisers and paraplanners.

At the top of our wish list sits the need for additional detailed information on the calculation methodologies being used in the various reports. Some providers are using the approach recommended by TISA in their 2017 guidance, however a number appear to be adopting different methodologies. We reckon it would be extremely helpful if platforms could produce a guide for advisers/paraplanners setting out exactly how the figures are sourced and calculated.

These guides would help (but not solve) what is likely to be the biggest problem for paraplanners and advisers. We had several questions along the lines of “what can advisers do if we have a client with assets across a few platforms, direct with a DFM, maybe a bit of EIS on the side?”. The answer is that no-one knows, so it’s likely to be a very difficult exercise to communicate all this stuff consistently and transparently. Good luck.

There was some debate about whether the fact platforms are sending statements directly to the client is enough for advisers to be compliant. Honestly, we don’t really know. However, even if adviser firms are comfortable that is the case, if clients have assets across more than one provider, advisers are almost certainly going to need to do something to meet their own regulatory responsibilities. Remember the whole COBs bit about “clear, fair and not misleading”. That’s still A Thing.

FCA rules in this respect are reasonably clear, however it’s obvious, to us at least, there is a need for good and poor practice examples to be shared amongst the advice community. We would encourage the regulator to do exactly that and would equally encourage platforms and other providers to carry on giving advisers and paraplanners the support they need.