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September 2016

The Transarency Task Force is the campaigning community dedicated to driving up the levels of transparency in financial services, right around the world. This month’s contributors include: Richard Field

Director, Institute for Financial Transparency

Dr. Kara Tan Bhala

Seven Pillars Institute for Global Finance & Ethics

Chris Tobe

Principal, Stable Value Consultants

Louise Sivyer

Policy Directorate, The Pensions Regulator

The official publication of The Transparency Task Force. FREE to members of the Transparency Task Force, membership of which is also FREE


CONTENTS: | SEPTEMBER 2016

THE OFFICIAL PUBLICATION OF

Andy Agathangelou

Founding Chair, The Transparency Task Force “Why the Work & Pensions Committee really matters!” Page 3

Louise Sivyer

Policy Lead, Policy Directorate, The Pensions Regulator “Tenacious trustees get the best for pension savers” Page 10

Richard Field

Director, Institute for Financial Transparency “What is the Transparency Label InitiativeTM?” Page 14

Chris Tobe

Page 26

All you need to know about: Transparency Statements Page 36

Principal, Stable Value Consultants “How CFA Standards can enhance transparency and ethics in public pensions” Page 18

Recommended reading

Dr. Kara Tan Bhala

All you need to know about: The Directory of Pro-Transparency Organisations

President and Founder, Seven Pillars Institute for Global Finance & Ethics “Ethics and Transparency” Page 22

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All you need to know about: The Transparency Task Force Teams & Ambassadors

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The Transparency Times | www.transparencytaskforce.org | September 2016 | Edition #5


COMMENT FROM THE EDITOR

Why the Work & Pensions Committee really matters! by Andy Agathangelou, Founding Chair | The Transparency Task Force Andy Agathangelou, Founding Chair of the Transparency Task Force comments on the great work of the UK’s Work & Pensions Committee and proposes the opening of an Enquiry into Pension Charges I, like many, am a fan of the Work & Pensions Committee. They have had a particularly busy year this year, investigating a wide range of issues effecting the UK’s pension system including auto enrolment, inter-generational fairness and the demise of the BHS pension scheme. I like what they do and how they do it, for many reasons: - They work in a very transparent manner; correspondence with witnesses gets published promptly on their website and anybody can watch their committee meetings live or on catch-up through Parliament TV

- Their enquiries result in detailed, well-considered and balanced reports full of sensible suggestions that must surely be an excellent resource for the Department for Work & Pensions, The Pensions Regulator, HM Treasury, the Financial Conduct Authority and other Government Departments to make good use of

to the bottom of whatever it is they want to get to the bottom of; even if that means witnesses having to make a second visit

- They are a cross-party group that work well as a team, and there is almost never any hint of party politics coming into the proceedings

- They are willing and able to be constructively challenging of Government Departments, but to my knowledge they have never been personal in their criticism; they know the difficulties and challenges that Government officials and Civil Servants have to deal with and they are very realistic about that. There’s never a sense of them wanting to be critical just for the sake of it - they seem to be guided by the overall objective of wanting to understand what has happened and making sure lessons are learned but not repeated, for everybody’s benefit

- They are tenacious; we saw that in the BHS inquiry. They are perfectly willing and able to keep digging until they get

- They are collaborative, as demonstrated by the way they teamed up extremely well with the Business Innovation and Skills Committee for the BHS enquiry

- They are motivated, focused and business-like; you get the feeling that they have a genuine sense of purpose in wantEdition #5

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ing to get things sorted - They do a great job in bringing together the various Government Departments that are involved in the pensions market – they help to ‘join up the dots’ and see things in the round. That’s extremely im-

portant given how fragmented, silo’d and complex the topic of pensions and investments can be - They have some great pensions and investments subject-matter expertise amongst them but more importantly

they know where to find technical ‘nitty-gritty’ when they need it My reason for writing this piece is that I can’t think of anything better for the cause of wanting greater transparency in the UK’s pensions and investment system, particularly in relation to costs and charges, than if the Work & Pensions Committee were to open an inquiry into the matter. I think they’d do a very good job. I think the public interest in such an inquiry would be substantial enough to warrant the time, effort and expense that would be involved and it would represent a very good use of government resources. I say this because a 20-yearold, saving £100 per month into a pension until age 65 will lose 24.6% of the value of the fund in charges if the total charges amount to 1% per annum and the gross market return is 5% per annum; and at 2% per annum total charges the pensions saver will lose 42.55% of the value in their

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The Transparency Times | www.transparencytaskforce.org | September 2016 | Edition #5


fund as charges. That’s a lot and in some situations charges can be even higher than that. Equally, charges can sometimes be much, much lower than 1% so we need to understand better what does and doesn’t drive value for money for the consumer, because costs and charges are such a significant determinant in the overall outcomes achieved. I’m not suggesting ‘cheap is good,’ but the consumer should at least know what he or she is paying. Without that knowledge the market just can’t work properly and there is the risk that the consumer is not being treated fairly. Could the pensions and investment market be more efficient and more competitive and as such provide more cost-effective offerings to the market? I think so. Is there a collective interest that transcends all party politics and all market perspectives in the UK having a healthy, competitive and trusted pensions and investment market? I think so. Many of us had the fortune to hear from key people about the topic of costs and charges in pensions at the Transparency Strategy Summit held at the House of Commons on the 12th September. Amongst many others, we heard from: - Shirin Taghizadeh, Head of Pension Charges, The Department for Work & Pensions - Becky Young, Manager, Wholesale and Investment Competition, The Financial Conduct Authority - Robin Finer, Head of Department, Competition, The Financial Conduct Authority - Louise Sivyer, Policy Edition #5

Lead, Regulatory Policy Directorate, The Pensions Regulator They and their colleagues are doing a great job in improving matters for the UK’s pensions saver and I’m absolutely convinced that the Work & Pensions Committee can do a great job to ‘join up all the regulatory dots and bring it all togethor’. This will augment the work being done by DWP, TPR and the FCA; it’s a win/win all round and it would make the work being done complete and thorough. I also think the Work & Pensions Committee can go about their investigations in a manner that is more robust, direct, tenacious and transparent than any other part of Government; and given the level of opacity and obfuscation in this whole area that’s a key point. Such an inquiry would be great news for all of us that care about the consumer and care about helping to fix what’s wrong in the system, for the sake of the long-term reputation of the sector and to help get the market to work more efficiently. Above all else it will help the consumer get the value for money they deserve. With all that in mind, and as announced at the Transparency Strategy Summit held on 12th September and also as covered at the Transparency Symposium on 21st September, I’m going to be writing an open letter to the Chair of the Work & Pensions Committee, asking his Committee give thought to opening an inquiry into the costs and charges issue effecting pensions and investments in the UK. It’s an important letter and I’m keen to get it spot on. I have already had some suggestions on how it can be improved and I would be most grateful

please for you to help me improve it too; we need the letter to be as good as it can be. The original version of the draft letter (i.e. without any suggestions I’ve received so far) follows. Let me know please if there is anything you feel I should change. Also, let me know if you would be happy to be listed as a supporter of the letter. The more people listed the better. This initiative is getting good support - I’m hoping we’ll have a good list of supporters; not just in terms of the length of the list of supporters but also in the diversity of the people and organisations that want the Work & Pensions Committee to open inquiry into the costs and charges in pensions and investments. Please do get involved, even if you’re outside the UK because in a post-Brexit world the UK has many reasons to want to be a world-leader in financial services transparency and if the UK becomes more transparent that will encourage other countries to follow suit. The UK’s Work & Pensions Committee investigating this matter would be good news for everybody that is a consumer of financials services pensions and investment products, right around the world; our International Best Practice Team who are working on the Global Transparency Index will help to make sure of that.

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1ST Draft of text for letter to the Chair of the Work & Pensions Committee: We are a coalition of interested parties looking to help protect the interests of the UK’s pensions-saving public through full disclosure on all the costs and charges they are paying. Hidden costs are damaging because they:1. Reduce the net amount pension savers are able to accumulate. Auto enrolment has created an even greater burden of responsibility to treat pension savers fairly and openly. This is a social justice issue. 2. Prevent the market working efficiently; markets need to know true costs to be efficient. The ‘invisible hand’ is ‘being kept in its pocket’ as it were, stopping the public getting the value for money they deserve 3. Inhibit pension scheme trustees and IGCs from carrying out their duties efficiently, because ‘you can’t manage what you can’t measure; and you can’t measure what you can’t see’. This is a governance failure. 4. Lead to adverse publicity. The public’s confidence in the pensions sector is falling; it needs to stop falling ‘below the point of no return’. There is a serious and systemic risk of this happening Pension scheme costs are surrounded by complexity, opacity and obfuscation. This is morally wrong, wholly unjustified and of great concern to all saver-centric market participants. Your Committee is uniquely placed to look into the matter in a constructive and inclusive way that will ‘join up all the regulatory dots’’. In so doing your Committee will encourage the UK’s pensions and investment sector to move out of denial (where that’s necessary) and work supportively with all regulatory bodies to find a sensible set of sustainable solutions that help protect the interests of the UK’s pensions-saving public. We look forward to hearing from you. Yours sincerely, [Names of all individuals, with job title and name of organisation, that opt-in to the initiative, listed alphabetically by organisation name. Anybody can be included]

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POLITE CALL TO ACTION!

PLEASE PROVIDE FEEDBACK ON THE DRAFT LETTER AND LET ME KNOW IF YOU WANT TO BE LISTED AS A SUPPORTER ON IT ASAP The Transparency Times | www.transparencytaskforce.org | September 2016 | Edition #5


WHAT’S HAPPENNING ON THE 12th OCTOBER?

WE HAVE ANOTHER GREAT LINE-UP OF SPEAKERS: Louise Sivyer, Policy Lead, Policy Directorate, The Pensions Regulator Janice Turner & David Weeks, Co-Chairs, The AMNT Shazia Afghan, Litigation and Contentious Regulatory Lawyer Alex Letts, Chief UnBanking Officer, UAccount Neil Sellstrom FCPFA, Treasury Management & Pensions Adviser, CIPFA Sophia Morrell, Independent Media Consultant

The event will include what is bound to be a lively discussion and debate, on what risks trustees might be exposed to in relation to the costs and charges being applied to the pension schemes they are responsible for. Where is it? Squire Patton Boggs, 7 Devonshire Square, London EC2M 4YH When is it? Wednesday 12th October, 10:30 registration for an 11:00 start, to 17:00

To book click

HERE!

Edition #5

| September 2016 | www.transparencytaskforce.org | The Transparency Times

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The Transparency Times | www.transparencytaskforce.org | September 2016 | Edition #5


If you missed May’s Launch Edition, not to worry, just click here! If you missed June’s Edition, not to worry, just click here! If you missed July’s Edition, not to worry, just click here! If you missed August’s Edition, not to worry, just click here! Edition #5

| September 2016 | www.transparencytaskforce.org | The Transparency Times

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ARTICLE: LOUISE SIVYER

TENACIOUS TRUSTEES GET THE BEST

by Louise Sivyer, Policy Lead, Policy Directorate | T Millions of people are now being auto enrolled into defined contribution (DC) schemes so it’s more important than ever that these schemes are being run to a high standard. To get the best value for members we are urging trustees to assume the role of a demanding consumer in their relationship with their asset manager or provider, and to make use of advisers where necessary. Our recently published new DC code clearly sets out what we expect of trustees when complying with their duties in law. In revising the code, we have responded to calls from the pensions industry to shorten and simplify it, with an increased focus on legislative requirements. We have also supported this with a suite of practical

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guides to further help trustees. In the guides we aim to provide trustees with practical information, examples of approaches they could take, and factors to consider. The guides are not intended to be prescriptive, although in some instances they state what we consider to be best practice.

VALUE FOR MEMBERS One of the six areas we focus on in the guides is value for members, where we explain, amongst other things, how trustees should be tenacious in obtaining information they need with regards to costs. Most members of money purchase schemes rely on

The Transparency Times | www.transparencytaskforce.org | September 2016 | Edition #5


T FOR PENSION SAVERS

The Pensions Regulator others to make the important decisions about their fund and to deliver and assess value on their behalf. All members should receive good value from their pension scheme, regardless of whether trustees have a legal duty to assess and report on value for members annually. There is no single approach to an assessment of value and trustees should develop their own policy which reflects the circumstances of their scheme and its members. Trustees also need to use their judgement to determine whether the scheme offers good value. Ultimately, trustees should strive to ensure that their scheme continues to provide good value for the full period that they are responsible for their members’ funds.

other options available in the market. Improvements in the transparency of costs are crucial to enable trustees to do this properly. TRANSACTION COSTS Transaction costs, incurred as a result of buying, selling, lending or borrowing investments, are a particular area where lack of transparency is a problem for trustees. Our guide aims to assist them in dealing with their investment managers and encourages them to be tenacious in their demands for information. Given the complex nature of transaction cost disclosure, trustees

should contact their asset managers and product providers well ahead of their scheme’s year end to ensure the information can be collated on a timely basis and that the costs are appropriate. If their asset manager or provider is unable to give the information they ask for, they should ask them why and record this in the chair’s statement. This should include any steps they have agreed with them to get this information in future years.

To do this, trustees should consider the quality and scope of scheme provision as well as the cost. This means thinking about the extent to which scheme provision is suitable for, relevant to and valued by members as well as assessing how well particular services to the scheme have performed. They also need to try to understand how their costs, and what is provided for those costs, compare with Edition #5

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make a point of including transaction cost disclosure both as part of their selection criteria and as a contractual term.

Where trustees are provided with only limited information, they may wish to engage with the relevant party to enable them to take a view on certain transaction costs and whether unidentified or unquantified costs are justified by the return they generate. When opportunities arise to review investment mandates trustees should

WHAT CAN MEMBERS EXPECT TO RECEIVE FOR THER MONEY? We have produced a tool to help trustees to assess their scheme against the standards in the code, so that they can identify areas requiring improvement. Here are some of the elements that members might expect to be provided by their scheme - delivered on their behalf by trustees. Scheme governance and

management: - Remunerated trustee oversight and risk management - Scheme secretarial services - Professional advice to trustees - Scheme audit Investment: - Clear investment objectives and good design and management of investment strategies, including the default strategy - An appropriate number and type of investment options, including the default arrangement(s) - Information on investment returns delivered and expected, net of fees - A suitable investment risk profile – tailored to the needs of members, and monitored and maintained within acceptable limits - Flexibilities, including the ability to switch funds Administration: - Handling of member contributions - Maintenance of member records - Customer service, including complaint handling - Efficient and easy access to benefits from pension age - Preparation of scheme financial statements Communications: - A suitable range of communication channels used, such as face-to-face, post, email, website - Tailored communications - Online access to view fund and make changes to account - Online tools such as retirement modelling

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but trustees of all schemes, regardless of size, should use our guidance to help ensure their members receive good outcomes from their pension saving.

- Help with decision-making around investment option - General guidance and support for accessing benefits - Financial guidance and information. Trustees’ duties are wide-ranging - from the collection of contributions to the investment of assets and payment of benefits. Scheme members look to them to make sure that their pension benefits are secure and they receive the benefits they are entitled to and expect. Trustees need to focus on a number of areas to help them meet their legal obligations and ensure their scheme is well run and more likely to deliver good member outcomes. Often, the methods trustees choose to adopt will depend on the nature of their scheme and its membership, Louise Sivyer is a policy lead in The Pension Regulator’s Policy Directorate. Louise joined the Regulator in 2007, and has worked in both policy and operational teams, across issues relating to both DB and DC. In her current role Louise is responsible for developing policy relating to the regulation of standards primarily in DC pension schemes, and leads on the development of a number of regulatory policy initiatives in relation to those schemes. She is currently leading on the development of the regulator’s updated DC Code of practice.   Before joining the Regulator, Louise had spent 12 years working in the pensions industry in technical roles ranging across the pension mis-selling review, third party pension administration, and TPAS (The Pensions Advisory Service). Louise continues to volunteer as a TPAS adviser. Edition #5

| September 2016 | www.transparencytaskforce.org | The Transparency Times

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ARTICLE: RICHARD FIELD

WHAT IS THE TRANSPARENCY LABEL

by Richard Field, Director | Institute for Financial Tra

In the first article in this series, A Brief History of Transparency, I explained how the global financial system came to be based on disclosure and the idea investors should know what they own or are thinking of buying. The responsibility for ensuring disclosure equivalent to valuing the contents of a clear plastic bag and not a brown paper bag was given to regulators. As shown by our recent financial crisis, this was a design flaw. Why did the financial regulators fail to require disclosure so investors could have the transparency of a clear plastic bag in every corner of the global financial system? While we will never know exactly why, one fact sticks out. Wall Street dominates the financial regulators’ process for setting disclosure requirements. Wall Street dominates the process for setting disclosure requirements because it is willing to spend much more time and money lobbying for opacity than investors are willing to spend lobbying for transparency. Wall

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Street is willing to spend the time and money because the benefits from opacity are concentrated in a few firms while the harm from opacity is spread across many investors. In the second article in this series, Asset Managers as a Barrier to Transparency, I explained why asset managers are willing to invest in opaque securities where the buying and selling of these securities is nothing more than blindly gambling. Asset managers assume investors want exposure to these securities and understand the asset managers are blindly gambling with

the investors’ money. Of course, this isn’t true as the asset managers are hired for their expertise. Furthermore, the asset managers aren’t going to demand more disclosure as doing so points out they are blindly gambling and puts their high paying jobs at risk. So if the regulators aren’t up to the task and asset managers aren’t going to demand the transparency of a clear plastic bag, how can investors get the disclosure they need so they can know what they own or are thinking of buying? This is where the Transparency Label InitiativeTM comes in.

The Transparency Times | www.transparencytaskforce.org | September 2016 | Edition #5


L INITIATIVETM?

ansparency The Initiative uses a label to divide the global financial system between transparent and opaque. Where there is a label there is adequate disclosure so an investor can know what they own or are thinking of buying. Where there is not a label there is insufficient disclosure and investors are effectively blindly gambling in a rigged market. By concentrating their investments where there

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is transparency, investors effectively force the issuers to disclose all the information necessary to know what they own. Why are issuers forced to disclose? It is the only way they can access the cheaper, more abundant source of funds made available by investors. Otherwise, the issuers have to compete with other issuers of opaque securities for the more expensive, limited amount of capital

held for blindly gambling. But what about the asset managers who invest in opaque securities? In the same way investors should concentrate their investments in securities having the Initiative’s label, they should concentrate their money with

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2. Understanding what information is currently being made available and when; 3. Comparing what is needed and when it is needed to know what you own with the actual disclosure provided. asset managers who are restricted to only investing in securities with the Initiative’s label. How does a security get a label from the Initiative? There are three main steps

in the process for determining if a label is merited: 1. Independently determining what information is needed and when is it needed to know what you own or are thinking of buying;

If the information disclosed and the frequency of disclosure meets or exceeds the requirements to know what you own determined in Step 1, a Label is awarded. If not, no label is awarded.

Richard Field is the Director of the Institute for Financial Transparency, an organization focused on bringing valuation transparency to all the opaque corners of the financial system and the sponsor of the Transparency Label InitiativeTM. Since the mid-90s, he has been a leader in defining and implementing transparency in the structured finance industry. Mr. Field designed, developed and patented a low cost information system to handle all of the complexity involved in making each structured finance security transparent. His solution uses a data warehouse to provide all market participants with easily accessible, standardized collateral level data on an observable event basis over the life of each deal. In April 2008, Mr. Field wrote a Learning Curve column for Total Securitization that described the gold standard for transparency for structured finance securities. Subsequently, he consulted with the National Association of Insurance Commissioners on their July 2012 white paper on financing home ownership. In both of these widely read publications, he discussed the need for both timely disclosure of the underlying collateral performance information and the use of a data warehouse to capture, standardize and disseminate this data. Apparently, while his call for timely disclosure was ignored, his call for the use of a data warehouse was heard. In Europe, the European Central Bank championed the creation of the EU Data Warehouse to provide transparency into structured finance securities. in the U.S., Fannie Mae and Freddie Mac are in the process of building this data warehouse for residential mortgage-backed securities. It is called the Common Securitization Solutions LLC. About these two data warehouses, Mr. Field remarked, as the beaver said to the rabbit looking down on the Hoover Dam, “I didn’t build it all by myself, but it is based on an idea of mine.” Earlier in his career, he worked as an Assistant Vice President for First Bank System and as a Research Assistant at the Federal Reserve Board. Mr. Field has an MBA from the J.L. Kellogg Graduate School of Management at Northwestern University and a B.A. in Economics and Political Science from Yale University.

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To independently determine what information is needed and when is it needed, the Initiative blends its own in-house expertise with input it solicits from buy-side participants including investors and independent third party valuation experts. As issuers and different types of securities or global financial benchmarks and commodity prices are reviewed, the results will be published at www.instituteforfinancialtransparency.com. The Initiative will not officially announce the awarding of any labels for some time. The Initiative recognizes it is not fair to issuers of securities not to give them a chance to adjust their disclosure practices so they provide the transparency necessary so investors can know what they own or are thinking of buying. To date, the Initiative has reviewed a number of different securities issuers

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across the global financial system. There have been a number of findings. 1. The Initiative has found that there are large areas of the financial system that currently provide transparency. An example of one of these areas is biotechnology. 2. The Initiative has found that unless they change their disclosure practices, none of the largest global financial institutions (banks and investment banks) currently merit the awarding of a label. 3 The Initiative has also reviewed many structured finance securities. With the exception of the mortgage-backed securities guaranteed by government-sponsored agencies, none of the structured finance securities currently merit the awarding of a label. In the absence of the explicit or implicit government guarantee, the gov-

ernment-sponsored agency mortgage-backed securities would also not merit the awarding of a label. The Initiative is hopeful that before it officially announces the awarding of its labels, both the financial institutions and the structured finance security issuers will adjust their disclosure so a label will be merited. To date, the Initiative has also reviewed many of the global financial benchmarks and commodity prices. The Initiative has found these global financial benchmarks and commodity prices also do not currently merit the awarding of a label. The Initiative is hopeful that before it officially announces the awarding of its labels, the global financial benchmarks and commodity prices will change the basis on which they are constructed so they will merit a label.

| September 2016 | www.transparencytaskforce.org | The Transparency Times

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ARTICLE: CHRIS TOBE, CFA, CAIA

HOW CFA STANDARDS CAN ENHANCE ETHICS IN PUBLIC PENSIONS by Chris Tobe, Pricncipal | Stable Value Consultants

The CFA institute has 3 major standards that can enhance transparency. The oldest is the Code of Ethics and Standards of Professional Conduct known as the Code and Standard developed in the 1960’s that says all CFA members each year sign a statement that they adhere to this code. The code has a number of standards including that to “Place the integrity of the investment profession and the interests of clients above their own personal interests.” Global Investment Performance Standards (GIPS) standards are a set of industry-wide principles that guide investment firms on how to calculate and report their investment results to prospective clients and were created in 1993. The Asset Manager Code of Professional Conduct was formally created in 2009 as a voluntary code of conduct to help asset managers practice ethical principles that put client interests first. CFA standards have had a

long term positive effect on public pensions from 1990 to 2005. This was caused by the huge increase in CFA charter holders on public pension staff, as well as some like myself on public pension boards who adhered to the CFA Code and Standards. Also the majority of major money managers in public plans accepted and adopted CFA Global Performance Presentation Standards (GIPS). Public pensions, many led

by CFA charter holders, created systems where by having the vast majority of the assets held at one central custodian, received independent 3rd party valuation from the custodian, and had total transparency in fees and commissions. The hiring of managers was done like other government services using competitive bidding primarily by issuing Requests for Proposals (RFP), and choosing typically 3 top candidates based on RFP to present to the board. While there were some investment scandals at public plans from 1990 to 2005, the vast majority were with real estate and other especially local private funds that were outside these custodial controls, and did not follow any CFA standards. However probably starting around 2005 but taking over by 2010 was a backward migration away from

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E TRANSPARENCY AND

transparency and toward secrecy as the entire competitive bidding mechanism was circumvented. Instead of issuing RFP’s and going through a public process, consultants and staffs behind closed doors starting picking managers, and presenting to board, here is your manager take it or leave it, giving them no alternatives. Investment Committees essentially became rubber stamps approving 99% of staff and/ or consultant recommendations. Public plans started buying billions in alternative assets in basically secret no-bid contracts, namely hedge funds and private equity, but some real estate. It has been my observation that these hedge funds, private equity, and real estate funds have very few if any CFA charter holders on staff. None of these assets were held at the custodian so there was no transparency in fees or 3rd party valuation. Few if any of these hedge funds or private equity firms were GIPS compliant, so despite being selected behind closed doors, there were no assurances that their outperformance was valid. Fees paid to outside money managers doubled to quadrupled with Edition #5

many public pensions as they have ramped up their purchases of hedge funds and private equity in no-bid contracts. States trying to get more transparency laws have been fought back by the private equity and hedge fund industry. 1 I believe that it is no coincidence that this move toward secret no-bid contracts gained huge momentum after the US Supreme Court Decision - Citizens United that allowed almost unlimited secret political donations. This also coincided with an explosion of growth in US State specific dark money entities that could take secret donations, and who were controlled by politicians with power at public pensions. These investments in secret no-bid contracts are for the most part outside the protection of CFA Standards.

Getting Back to Transparency through CFA standards: The adoption and enforcement of CFA standards can lead us back to the transparency and lower fees that we had 10 years in ago in U.S. public pensions. The Code of Ethics and Standards of Professional Conduct is sworn to by the 135,000 investment professionals with the CFA designation. The more CFA charter holders a firm has I believe leads to a more ethical firm. It still astonishes me that public pensions hire hedge fund managers, private equity managers and real estate managers who have few if

| September 2016 | www.transparencytaskforce.org | The Transparency Times

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any CFA charter holders on staff. Kentucky State law has a provision for the Teachers Retirement Systems (KTRS) that all staff and managers must follow the Code and Standards. However it is not enforced since I believe that many of the KTRS Private Equity managers do not follow Section IIIA of the Code and Standards which is putting clients first – basically fiduciary duty,which they avoid in their contracts. While GIPS is almost universally a standard for most stock and bond managers, public pension plans have not enforced this standard on alternative managers. Only the Ohio Public Employees plan, of major state plans has publicly stated that they require CFA GIPS compliance for all managers.2 Most private equity and hedge fund managers do not provide GIPS compliant numbers. There are specific GIPS rules for alternative managers that ensure full transparency of performance and fees, but these managers for the most

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part seem to be running from them. The CFA Institute staffer in charge of GIPS said “Alternative investment managers have been slower to adopt global standards than managers in traditional asset classes,….Mr.Boersma said he has “lots of concerns” about those managers.“GIPS standards don’t require things that most managers that are worth their salt aren’t doing already,” he said. “I would be concerned why a manager would not be compliant.” “There’s not a lot of mischievousness that can happen there,”.3 Public pension boards should insist that all of their managers follow GIPS Standards. The Asset Manager Code of Professional Conduct designed in 2009 may be the best standard to jump start transparency in public pension plans. It has been adopted by over 1,300 ethical investment managers. If you comply you are on the list, if not you do not comply so it is simple to enforce. 4

The following large public plans have adopted the Asset Manager Code of Conduct in 2016 as a broad guideline: State of Florida Board of Administration, California Public Retirement System, California Teachers Retirement Systems, Caisse du Quebec, Illinois Municipal, Virginia Retirement, Massachusetts PRIM , & Washington State Board of Investments. 5 However, these plans are not requiring all of the managers they hire to be compliant, at least not right away. In the Asset Manager Code they must swear to put investors first, which is many times referred to as Fiduciary duty. Many hedge funds and private equity funds in their sometimes 100 page secret contracts allow themselves the General Partners or GP’s to trade in front of the Limited Partners LPs. They can give preferential treatment in performance and fees to themselves over

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LP’s. Needless to say firms like this do not want to comply with the total transparency required to claim the CFA Asset Manager Code of Conduct. Asset Manager Code also requires them to fully disclose all fees and expenses. The SEC did a survey of 200 limited partnerships which included both hedge funds and private equity. They found that over 100 50% overcharged the LP’s. 6 Some hedge fund and private equity funds charges millions in hidden expenses for jets travel etc for GP’s. 7 Most of these firms refuse to fully disclose fees and expenses and thus refuse to adhere to the CFA Asset Manager Code of Conduct. Kentucky attempted to add the Asset Manager Code of Conduct into Senate Bill 2 in March 2016. It passed the Senate unanimously with bipartisan support and had the votes in the House, but it was blocked from coming to a vote in a procedural move by the Speaker of the House. 8 The Governor by executive order made the Asset Manager Code of Conduct the law for the Kentucky Retire-

ment System in June 2016 and a judge confirmed this in August 2016. However the Kentucky Retirement system has defied this law by buying private equity partnerships and hedge funds that do not adhere to the code. The Regulatory Compliance Association (RCA) has created a 2 step, quantitative process, which independently validates a firm’s (managers) compliance program.9 The first step is for compliance officers to adopt the RCA’s Compliance Officer Professional Code of Conduct, and the second step is for the firm to adopt the CFA Institute Asset Manager Professional Code of Conduct® (AMC)10 The CFA Institute has 3 excellent standards of transparency. The issue is whether plans and governments have the will to take on powerful interests and use them. End notes: 1 http://mobile.nytimes. com/2016/07/03/business/private-equity-funds-balk-at-disclosure-and-public-risk-grows. html   2 http://www.pionline.

com/article/20130801/ONLINE/130809997/alts-managers-slow-to-go-with-gips 3 http://www.pionline.com/ article/20130801/ONLINE/130809997/alts-managers-slow-to-go-with-gips 4 https://www.cfainstitute.org/ ethics/codes/assetmanager/ Pages/firms_claiming_compliance.aspx 5 https://www.cfainstitute.org/ Site%20Art/Open_Letter_ to_the_Investment_Management_Profession.jpg 6 SEC finds Bogus Privatge Equity Fees” Bloomberg April 7, 2014 http://www.bloomberg. com/news/2014-04-07/bogusprivate-equity-fees-said-foundat-200-firms-by-sec.html 7 http://www.wsj.com/articles/ sec-probes-silver-lake-overfees-1471646427 8 http://mobile.nytimes. com/2016/07/03/business/private-equity-funds-balk-at-disclosure-and-public-risk-grows. html   9 https://www.rcaonline.org/ compliance-program-transparency-series-session-1/ 10 https://www.cfainstitute.org/ ethics/codes/assetmanager/ Pages/index.aspx

CHRIS TOBE, CFA, CAIA has worked for over 15 years with Public Pension plans and is the author of “Kentucky Fried Pensions”. With the Hackett Group 2009-2016 he provided project consulting to public pensions in MD, TX, and UT. From 2008-2012 he served as a Trustee and on the Investment and Audit Committees for the $14 billion Kentucky Retirement Systems. From 2008-2009 he was a Sr. Consultant with NEPC out of the Detroit office and worked with a number of public pension plans in Oklahoma, Missouri, Michigan and the District of Columbia. From 1997-1999 with the Kentucky State Auditor he published a 40 page report on the investments of both major Kentucky Pension plans. National Public pension speaking engagements include January 2013 at the Public Pension forum at the Ohio State Law School, October 2013 at DePauw University in Chicago, and at the National Press Club for Governing Magazine in February 2014. As a public pension trustee he completed the Program for Advanced Trustee Studies at Harvard Law School and Fiduciary College held at the Stanford University. Edition #5

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ARTICLE: Dr. KARA TAN BHALA

ETHICS AND TRANSPARENCY

by Dr, Kara Tan Bhala, President and Founder | Seven Pillars Institute for Global Finance and Et Not wasting a crisis: The 2008 Global Financial Crisis (GFC) was quite the last straw and I decided to act. Two years later, Seven Pillars Institute for Global Finance and Ethics (SPI) came into existence. The Institute is headquartered in Kansas City, Missouri and affiliated with the University of London (Queen Mary College) and IntegTree (Saint Louis), and its Fellows and Interns work from around the globe. SPI’s mission is to highlight and analyze moral issues in finance with a view to enhancing practice and policy. This mission involves investigation and research into financial activities in diverse spheres of human endeavor to determine if financial transactions, instruments or actors are ethical and if not, why not. Thus, SPI produces handy case studies, a bi-annual journal called Moral Cents, financial ethics training vid-

22

eos, books, and podcasts to promote and educate on financial ethics. This work constitutes our daily enterprise. SPI also has a quest, which, compared to the mission is more heroic, purposively world changing and less corporate: to make ethics an integral part of finance theory and practice. In way of explanation, over the period of a half-century, we have slowly stripped ethics from finance. There was no need and hence, no place for ethics in modern finance theory (MFT) (comprising the efficient market hypothesis, the capital asset pricing model and options pricing theory). Ethics is discursive and relativistic while finance is empirical

and scientific. The two are incompatible. That thought permeated the academy, industry and large portions of society for most of the twentieth century. But times and thinking change. Because of the GFC, previously dominant finance theories are no longer unassailable and the old financial practices are questionable. We need theories that incorporate ethics into their very structure. Where theory goes, there follows practice. It is imperative we change finance at the fundamental level of theory, in order to alter finance at the level of practice. At this point in time, there are three conceptual systems of finance: (1) modern finance theory (2) behavioral finance theory, and (3) Islamic finance theory. MFT is the conventional, dominant theory taught

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thics around the world. Indeed, it has served modernity well because it is quantitative and systematic. Behavioral finance is nascent and needs further theory building. The body of work explains empirical anomalies that counter predictions of MFT. Yet, it still works within the latter’s conceptual framework. Behavioral finance theory accounts for human behavior and psychology, elements absent in MFT. Islamic finance is inchoate, unsystematic and lacks a fundamental quantitative basis. The theory’s most imaginative, vital contribution is its unapologetic inclusion of moral principles to guide action in financial activities. A workable finance theory that synthesizes without syncretism the three elements of mathematics, psychology and ethics is within reach. While working towards this quest, SPI will continue ever more boldly as the world’s only independent think tank for research, education, and promotion of the new field of financial ethics. In this endeavor, SPI collaborates with partners and like-minded organizations such as the Transparency Task Force Edition #5

(TTF). Transparency and Ethics: There is much overlap in the work of SPI and the TTF and several ways transparency is tied to ethics. Indeed, transparency is a crucial basis for ethics. Transparency may not be an ethical principle in itself but it certainly is a pro-ethical condition for enabling or impairing other ethical practices or principles.1 When we think transparency, we naturally think “light!” because both allow us to see more clearly and therefore, to approach truth. According to the ancient Greeks, light is the domain of Apollo and he also is the god of reason, a faculty necessary to, again, encounter truth. The 1 Turilli, M. and Floridi, L. “The Ethics of Information Transparency” in Ethics and Information Technology. June 2009, Volume 11, Issue 2, pp 105-112.

importance of light emerges as early as the first chapter, third verse, of the Bible when God commands it to be light (He found it to be good.) To this day, humanity associates light with reason and truth. Both factors are foundational to assessing and making ethical choices. In ethics, one can think of three specific moral virtues connected to transparency. To be transparent and open to examination requires the virtues of honesty and courage. As early as 2,500 years ago, Aristotle, a first among ‘thought leaders’ and the founder of virtue ethics, labeled these dispositions as moral virtues. We need to be honest to defend transparency and not hide information we think may diminish per-

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sonal or institutional profits. Churchill remarked that courage underlies all virtues and to be sure, it takes courage to be honest and to reveal all pertinent information to the public, the customer, and the consumer. We hold nothing back. Why should we? Do we fear allowing the public to know what we do and how much we actually charge for it? We have the courage of conviction and courage in our integrity of action. Finally, transparency engenders the virtue of trust. When a client associates a financial service provider with reliable, transparent disclosure, surely she will be more likely to use its services. Constant transparency will yield continuing trust. Even as transparency requires virtue, it also is what we need to do to meet our ethical obligations. Transparency is linked to fiduciary duty. According to the theory of deontology, a term which stems form the Greek word deon, meaning duty, we are obligated to act in accordance to a set of principles. In finance, the primary principle attached to the notion of fiduciary duty is that the financial agent acts in the best interest of the client. Money managers should recognize this duty to clients and act in light of it. To discharge her fiduciary duty, a financial agent must be trans-

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parent and disclose, among other things, fees pertaining to any relevant services provided to a client. Transparency is closely aligned with the Kantian duty of acting in ways that respect an individual’s rational capacity and free will to exercise that rationality. In sum, by being transparent we respect the human dignity of individuals. The practice of transparency results ultimately in the common good. Opaqueness benefits only those who seek to hide in the shadows. The rational choice of financial firms is to act on behalf of the common good and to uphold principles such as justice, accountability and transparency. The financial ecosystem prior to 2008 was strewn with examples where a lack of transparency resulted in great harm to the common good.2 1. Had investors been aware of the rampant speculation and growth in the credit default swaps (CDS) market, and how knowledgeable people were betting against Mortgage Backed Securities (MBS) and Collateralized Debt Obligations (CDO), there might 2 Flynn, E.P., Ethical Lessons of the Financial Crisis. Routledge (London), 2012.

have been a chilling effect on the market. Instead, because of a lack of transparency, the vast majority of investors were unaware of the defects of MBS-CDOs. 2. In the absence of oversight and transparency, few had information on CDSs in regards to the amount outstanding, who had to pay off these securities, how many firms were in jeopardy, and how much wealth would be destroyed. The lack of this critically important information led to fear and uncertainty in financial markets and ultimately contributed to the GFC. 3. To the extent financial firms took advantage of the ignorance of investors and profited from markets that lacked transparency, they acted unethically. 4. Analysts say the Securities and Exchange Commission (SEC) should have required more disclosure and transparency from financial institutions that were undercapitalized and engaged in dangerous risk taking.

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5. By taking derivatives off the books of investment banks and large commercial banks, these banks appeared to be in better shape than was the case. Lack of transparency in regards to MBS-CDO exposure was an accounting ploy that contributed significantly to the economic meltdown. These instances of opaqueness and concealment in financial services did not serve the market or public well. As we observed in 2008, market failures occur and markets do require regulations and oversight. Financial institutions should not only be honest and open with their customers but also engage openly with regulators to institute transparent procedures

and enact legislation against egregious practices that bring harm to investors and the broader community. Finally, commutative justice demands transparency. This form of justice belongs in the sphere of transactions and is most relevant to finance and business. Commutative justice refers to fairness in exchange of goods or services. Sellers are expected to set fair prices for their goods and not gouge the customer. Therefore, there must first be full informational disclosure to both buyer and seller. Each must enter the transaction freely and in possession of all relevant information.

In sum, for the sake of justice, duty and the common good, transparency in financial markets is ethically and pragmatically a worthy goal.

Dr. Kara Tan Bhala is the President and founder of Seven Pillars Institute for Global Finance and Ethics, the world’s only independent think tank for research, education, and promotion of financial ethics. She also is a Visiting Research Fellow at Queen Mary University of London and an Advisor for IntegTree Compliance Consulting. Dr. Tan Bhala has over twenty-three years of experience in global finance, much of which was gained through working on Wall Street. She has worked on almost all sides of finance and has been a sell-side equity analyst, a sellside sales person, a buy side equity analyst and a senior portfolio manager. Dr. Tan Bhala was Managing Director and Senior Portfolio Manager of the Merrill Lynch Dragon Fund and Emerging Tigers Fund responsible for roughly US$2 billion in assets. Prior to running the Dragon Fund, Dr. Tan Bhala was a portfolio manager with Fiduciary Trust International. Following her adventures in finance, Dr. Tan Bhala was invited to lecture at the University of Kansas School of Business where she taught financial ethics. She moved on from her work in the academy to found Seven Pillars Institute. She is the lead author of International Investment Management: Theory, Ethics and Practice (Routledge, 2016) and a contributor of a chapter, “The Decline and Rise of Financial Ethics� to The Business of Ethics (Asian Institute of Finance, 2016). Dr. Tan Bhala has five degrees across three disciplines: a Bachelors (City University of London) and Masters (Oxford University) in Business, a Masters in Liberal Studies (New York University), and a Masters and PhD in Philosophy (University of Kansas). She is a member of the Council on Foreign Relations (US) and the Royal Society of Asian Affairs (UK). Dr. Tan Bhala has lived and worked in London, Oxford, Singapore, Hong Kong, New York, and Washington, D.C. and currently resides in Kansas City, Missouri. Edition #5

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T E A M S Rapid progress has been made since our first meeting on 6th May 2015. It is perfectly clear that there are many motivated and highly capable people who are dissatisfied with the status quo and, very importantly, are willing and able to work together to make a difference. These individuals are organised into 3 teams, with each team having a particular area of focus. The three teams are: - Costs & Charges - Stewardship & Decision-Making - International Best Practice The following tables show the make-up of the teams; those in bold red are Team Leaders: First Name

Last Name

Job Title

Organisation Country

Costs&Charges Team?

Adam

French

Scalable UK Capital Limited

Yes

Andrew

Evans

Co-founder & Managing Director

Yes

Andy

Tarrant

Andy

Chief Executive Smart Pension UK Officer Head of Policy B&CE The UK & Government People's Relations Pension

Agathangelou Founding Chair Transparency Task Force Scottish Kirkwood Senior Manager Widows - Industry Development Tilba Lecturer in Newcastle Strategy & University Business Corporate Governance School

Angie

Anna

Brendan

Mulkern

Consultant

Callum

Mayor

Consultant

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Pen Partnership Pen Partnership

Yes

UK

Yes

UK

Yes

UK

Yes

UK

Yes

UK

Yes

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Chris

Barrow

Christopher

Squirrel

Con

Keating

Craig

Rimmer

Daniel

Godfrey

Elizabeth

Scorpeo UK Ltd.

UK

Yes

Founder and CEO Head of Research Policy and Technical Specialist

Sciurus Analytics BrightonRock Group Pensions Advisory Service

UK

Yes

UK

Yes

UK

Yes

UK

Yes

CampbellWarner

Managing Director

UK

Yes

Gayle

Schumacher

Retired

Gabriel Research & Management

UK

Yes

Gerry

Wright

Partner

UK

Yes

Graham

Cook

UK

Yes

Henrik

Pedersen

UK

Yes

Henry

Tapper

Portfolio Solutions Managing Partner, CoFounder

Founder

Yes

Iain

Cowell

Head of Investment Solutions, UK & Ireland

Pension UK PlayPen Allianz Global UK Investors

Imran

Razvi

James

Monk

James

Singer

John

Simmonds

Public Policy Advisor Head of DC Investments Senior Associate Principal

John

Serocold

Principal

Edition #5

Head of Business Development

Non-Executive Big Issue Director Invest Fund Management

Former MD, Coutts Smith & Williamson Investment Management LLP Macquarie Securities Clerus LLP

The Investment UK Association Aon Employee UK Benefits P-Solve UK CEM UK Benchmarking Inc

Studio SerocoldUK

Yes

Yes Yes Yes Yes Yes

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Julius

Pursaill

Independent Pension and Investment Governance Consultant

UK

Yes

Lucy Malcolm

Forgie Small

Yes Yes

Margaret

Snowdon

Policy Adviser ABI UK Managing Lynecombe UK Director Consultancy Ltd Chairman Pensions UK Administration Standards Association

Mark

Proffitt

Markus

Krebsz

Martin

Palmer

Michelle

Baddeley

Mike Natalie

Webb Winterfrost

Niall Nick

Ferguson Fleming

Nils

Johnson

Peter Philip

Eggleston Miller

Richard Robin

Metcalfe Powell

Ronnie

Morgan

Saul

Djanogly

Shaul

David

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Head of Sales Scorpeo UK UK Ltd Interim Chief UNECE GRM UK Risk Officer Zurich Financial UK Head of Corporate Services Funds Proposition Professor of University UK Economics and College London Finance

Consultant Chair/Client Director

Market Development Manager

Co-Founder and Director Founder Editor Strategic Insight Manager CEO

City Noble CFA Society, UK/Aberdeen Asset Management

Yes

Yes Yes Yes

Yes

UK UK

Yes Yes

UK UK

Yes Yes

UK

Yes

UK UK

Yes Yes

UK The Evidence- UK Based Investor Royal London UK

Yes Yes

British Standards Institute

Spence Johnson Limited BestX Pensions Focus

Best Interest UK Consultants Fin Tech Sector UKTI Financial UK Specialist Services Organisation

Yes Yes Yes

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Shyam

Moorjani

Partner, Financial Services Consulting

RSM Tenon

UK

Yes

Stephen Stephen

Budge Bowles

Principal Head of Institutional Defined Contributions

Mercer Schroders

UK UK

Yes Yes

Terence Tim

Prideaux Brown

UK UK

Yes Yes

Tim

Walton

UK

Yes

Tim

Sharp

UK

Yes

William

Jenkins

Amundi Director, Co-Head Operational Due Diligence

UK

Yes

Chris

Connelly

David

Rich

Principal Consultant CEO

Iain

Clacher

Associate Professor in Accounting & Finance

Jon

Parker

Director

Neil

Morgan

Ralph Stewart

Frank Bevan

Sunil

Chadda

Senior Pension Capita Asset Trustee Services CEO DC (UK) Cardano Product KAS BANK Manager Benchmarking

JB

Beckett

Edition #5

Head of Consultant Relations

Dimensional Fund Advisors

Manager, Data Morningstar Research and Analysis

Economic and TUC Social Affairs Department

AquilaHeywoodUK

Yes, leader

Accurate Data UK Services LeedsUniversity UK BusinessSchool

Yes, leader

JonathanParker UK Consulting Ltd

Yes, leader

Yes, leader

UK

Yes, leader

UK UK

Yes, leader Yes, leader

Managing CairnConsulting UK Director Ltd ConsultingChief NewFundOrder UK Investment Consulting Officer and Author

Yes, leader Yes. leader

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First Name

Last Name

Andy Anna

Agathangelou Founding Chair Transparency Task Force Tilba Lecturer in Newcastle Strategy & University Corporate Business Governance School

Anna

Walton

Principal Consultant

Con

Keating

Henry

Tapper

Head of Research Founder

Iain

Clacher

Associate Professor in Accounting & Finance

Iuliia

Shpak

Jackie

Beard

PhD University of East London/ Researcher Sarasin & in Finance/ Partners Systematic Strategies Director of Morningstar Manager Europe Ltd Research Services EMEA

James

Meenan

CEO

John Joshua

Belgrove Card

Judith

Donnelly

Julia

Dreblow

Luke

Hildyard

Senior Partner Aon Hewitt Chief Executive Kukua Officer Partner Squire Patton Boggs Founder sriServices and Fund EcoMarket

Policy Lead - PLSA Stewardship and Corporate Governance

Markus

Krebsz

Michael

Kemp

Interim Chief Risk Officer Senior Pensions Technician

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Job Title

Organisation Country

Stewardship & Decision-Making Team?

UK

Yes

UK

Yes

Energised UK Environments Limited

Yes

BrightonRock Group Pension PlayPen Leeds University Business School

UK

Yes

UK

Yes

UK

Yes

UK

Yes

UK

Yes

Ireland

Yes

UK

Yes Yes

UK

Yes

UK

Yes

UK

Yes

UNECE GRM UK

Yes

Pinsent Masons LLP

Yes

JNM Investment Governance

UK

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Neil

Morgan

Neil Nick

Latham Fleming

Paul

Lee

Paul

Marsland

Philip Rob

Brown Lake

Sarah

Hutchinson

Consultant

Saul

Djanogly

CEO

Sebastian Steve

Reger Cave

Terry

Ritchie

Tessa Tim

Page Middleton

Partner Associate Director Development Director FIA, Principal Technical Consultant

Valborg

Lie

Director

Alan

Salamon

Barry David

Mack Weeks

Managing UK Director Client Director Muse AdvisoryUK Co-Chair Association UK of Member Nominated Trustees(AMNT)

Emma

Craig

Henrik

Pedersen

Janice

Lambert

Edition #5

Senior Pension Capita Asset Trustee Services Consultant Independent Market British Development Standards Manager Institute

Head of Corporate Governance

UK

Yes

UK UK

Yes Yes

Aberdeen Asset UK Management

Yes

Deputy Director High Pay Centre Head of Policy LV Responsible Rob Lake Investment Advisors Advisor

Marketing Specialist Managing Partner, CoFounder

Pensions Consultant

SJ Hutchinson Ltd Best Interest Consultants Sackers Smith & Williamson Trustee Solutions Ltd Mercer Pensions Management Institute

Borg Consulting Corpias

UK

Yes

UK UK

Yes Yes

UK

Yes

UK

Yes

UK UK

Yes Yes

UK

Yes

UK UK

Yes Yes

UK

Yes Yes, Leader Yes, leader Yes, leader

KAS BANK N.V.UK

Yes, leader

Clerus LLP

UK

Yes, leader

Independent

UK

Yes, leader

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Mark

Miller

Olivia

UK

Yes, leader

Seddon-DainesSeniorResearch ET Index Analyst

UK

Yes, leader

Paul

Hewitt

UK

Yes, leader

Rachel Sarah

Haworth Wilson

Policy Officer ShareAction ChiefExecutiveManifest

UK UK

Yes, leader Yes, leader

First Name

Last Name

Job Title

Organisation Country

Alex

Mazer

Amy

Auster

Founding Partner Executive Director

Common Wealth Australian Centre for Financial Services

Andy Anna

Agathangelou Founding Chair Transparency Task Force Tilba Lecturer in Newcastle Strategy & University Corporate Business Governance School

Chris

Tobe

Con

Keating

Dana

Muir

David Elias

Knox Westerdahl

Eric

Veldpaus

Eric Erik Felix

Plunkett Conley Mezzanotte

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Employee Benefit Consultant

Barclays Corporate & Employer Solutions

Senior Vigeo Eiris Development Manager

International Best Practice Team?

Canada

Yes

Australia

Yes

UK

Yes

UK

Yes

Investment Consultant Head of Research Professor

Stable Value USA Consultants BrightonRock UK Group USA University of Michigan's Ross School of Business

Senior Partner Sustainable Business Analyst

Mercer Australia The Centre for UK Synchronous Leadership

Strategy Novarca Group Holland Director Owner Redbrucke UK Founder ZenInvestor USA Assistant The Hong Kong Hong Kong ProfessorCo- Polytechnic Team Leader of University Acct. & La

Yes Yes Yes

Yes Yes Yes Yes Yes Yes

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Francisco

Gomes

Frits

Meerdink

Graham

Wrightson

Heinz-Dietrich Steinmeyer

Henrik

Professor of Finance

London Business School Manager Fund PGGM Management Investments Partner Stephenson Harwood LLP Professor of University of Law, Director Muenster of the Institute for Labour Law, Social Law and Business Law

James

Wolff-Petersen Director and Co-Founder Meenan CEO

Janice

Lambert

Jerry

Moriarty

John Jon

Belgrove Lukomnik

Jonathan

Hall

Juan Kara

Zuluaga Tan Bhala

Marcus Mikael Nicholas

Orione Nyman Morris

Nicolas

Firzli

Nikki

GwilliamBeeharee

Richard

Field

Edition #5

Pensions Consultant CEO

UK

Yes

Holland

Yes

UK

Yes

Germany

Yes

PandaConnect Denmark

Yes

JNM Investment Governance

Ireland

Yes

UK

Yes

Independent

Irish Ireland Association of Pension Funds

Senior Partner Aon Hewitt Executive IRCC Institute USA Director Head of Aquila UK Financial Services President and Seven Pillars Founder Institute for Global Finance and Ethics

Editor in Chief Exakt Media Visiting Fellow The Martin School, Oxford DirectorWorld Pensions France General Council Food and Vigeo France Health Research Manager Institute for Financial Transparency

Yes Yes Yes

USA/Columbia Yes USA Yes

Brazil Sweden Australia

Director

Yes

USA

Yes Yes Yes Yes Yes

Yes

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Rosalie

Degabriele

Academic Finance

University of Technology

Australia

Stephen

Davis

Associate Director and Senior Fellow

Harvard UK Law School Programs on Corporate Governance and Institutional Investors

Yes

Steve

Kenzie

Executive Director

Yes

Suzanne SV

Shatto Rangan

UN Global Compact Network UK

Tomas

Wijffels

Ian

Fryer

Retail Investor USA Senior AIG UK Executive Policy Advisor Federation of Holland Dutch Pension Schemes

Paul

Secunda

UK

Head of Chant West Australia Research ProfessorofLaw Marquette USA and Director, University Law Labor and School Employment Law Program

Yes

Yes Yes Yes Yes, leader Yes, leader

We are seeking new members in all of our teams. To learn more about each team’s focus and to express interest in getting involved please email andy.agathangelou@transparencytaskforce.org

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A M B A S S A D O RS Some of our campaigning community are Ambassadors; individuals that are particularly aligned to what we are doing and why we are doing it; and as such are a profoundly impactful force for the positive change we are all collectively striving to achieve. Our Ambassadors are listed below: First Name

Last Name

Job Title

Organisation Country

Ambassador?

Anna

Tilba

Lecturer in Strategy & Corporate Governance

Newcastle University Business School

UK

Yes

Catherine Con

Howarth Keating

UK UK

Yes Yes

Daniel

Godfrey

UK

Yes

David

Pitt-Watson

Chief Executive ShareAction Head of BrightonRock Research Group Non-Executive Big Issue Director Invest Fund Management

Consultant

UK

Yes

Jackie

Beard

Director of Manager Research Services EMEA

UK

Yes

JB

Beckett

Consulting Chief Investment Officer and Author

UK

Yes

Ralph Robin

Frank Powell

CEO DC (UK) Cardano UK Editor The Evidence- UK Based Investor

Yes Yes

Edition #5

London Business School Morningstar Europe Ltd

New Fund Order Consulting

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ABOUT TRANSPARENCY STATEMENTS Transparency Statements are a great way to show your support for our international campaign and to align your organisation with our intention to encourage greater transparency in financial services, right around the world. We believe that higher levels of transparency are a pre-requisite for fairer, safer and more efficient markets that deliver better value for money and better outcomes for consumers. Furthermore, because of the correlation between transparency and trustworthiness we believe our work will also have a positive impact on the reputation of the financial services market as a whole.

“I believe there ought to be higher levels of transparency in financial services because..........................................................”

That’s good news for all market participants and all governments, because the world needs a financial services sector that is trustworthy.

and email it to

To provide your transparency statement please complete the sentence:

Thank you very much indeed

andy.agathangelou@ transparencytaskforce.org

POLITE CALL TO ACTION! PLEASE BE SURE TO PROVIDE YOUR TRANSPARENCY STATEMENT AS SOON AS POSSIBLE. WEBSITE COMING SOON! 36

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Helena Morrissey Chair | The Investment Association Dr. Kara Tan Bhala | President and Founder, Seven Pillars Institute for Global Finance and Ethics

“I believe there ought to be higher levels of transparency in financial services because it’s the very starting point for establishing trust.’ “I believe there ought to be higher levels of transparency in financial services because transparency is a pro-ethical condition that enables us to fulfill our fiduciary duty and to achieve justice and the common good. Assiduous transparency yields continuous trust.”

Tom Tugendhat “I believe there ought to be higher levels of transparency in finan| Member of Parliament cial services because it is the only way that markets can function for Tonbridge and Malling without distortion to the benefit of the true customer, the individual.” Angela Rayner | Former Shadow Pensions Minister, now Shadow Secretary of State for Education and Shadow Minister for Women and Equalities Frank Whiffen Head of Strategic Business Development | Ferrier Pearce

“I believe there ought to be higher levels of transparency in financial services because pension funds should be run with a constant eye on efficiency – every penny should be accounted for therefore costs must be transparent and easy to understand – they must be explainable without jargon. The duty is to pay pensions and ensure that the sponsoring employers enjoy the benefits of reduced costs, we must avoid funds entering the Pension Protection Fund, it should be the last option”. “I believe there ought to be higher levels of transparency in financial services because this will enable better decision making. In turn, this should be communicated in an engaging way so that sensible and informal decisions can be made.”

Phil Ninness Business Development Manager | Accurate Data Services

“I believe there ought to be higher levels of transparency in financial services because consumers are obtaining different views and news and there is a trust issue. People need honesty in plain english.”

Iain Cowell Head of Investment Solutions, UK & Ireland | Allianz Global Investors

“I believe there ought to be higher levels of transparency in financial services because sharing clear and understandable disclosures will drive positive innovation and can empower the customers of the industry to improve their long-term outcomes.

Martin Campbell Director | Beacon Strategic  

Steve Conley Business Development Director | Workplace Pensions Direct

Edition #5

“I believe there ought to be higher levels of transparency in financial services because for decades the industry has systematically ripped off the customer, while hiding behind deliberate and unnecessary opacity, to become wealthy at the customer’s direct expense.” “I believe there ought to be higher levels of transparency in financial services because Transparency is a means to an end, where the end game is greater accountability, good decision-making and trustworthiness … which leads to better commercial outcomes for members, sponsors, markets through investment, and in the long-run - via improved reputation, public engagement and a reduced savings deficit - for the asset managers themselves and the financial services industry as an whole”.

| September 2016 | www.transparencytaskforce.org | The Transparency Times

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JB Beckett Author #NewFundOrder | New Fund Order, Assoc. of Professional Fund Investors

"I believe there ought to be higher levels of transparency in financial services because optimum economic value has become remote and distorted and by virtue active fund management and professional fund buyers fragile to digitalisation”

Dan Norman CEO | TCF Investment

“I believe there ought to be higher levels of transparency in financial services because the money belongs to the consumer and they need to be given the best chance of making their money work harder so they don’t have to.”

Pauline Skypala Journalist | Freelance

“I believe there ought to be higher levels of transparency in financial services because it is impossible to make competent investment decisions and fund manager choices without being in full possesion of all the relevant information. Costs are foremost in this as future investment performance is unknown.”

Julia Dreblow Founding Director | SRI Services

“I believe there ought to be higher levels of transparency in financial services because it is the best way to make sure that people get what they want through enhancing trust; an aspect that is desperately low in our industry.”

Judith Donnelly Partner | Squire Patton Boggs

“I believe there ought to be higher levels of transparency in financial services because pension funds and other institutional investors can only comply with their legal obligations to make informed decisions if they are able to access all relevant information”.

David Clark Director and Chairman Executive Committee | The Institute for Global Financial Integrity

“I believe there ought to be higher levels of transparency in financial services because without transparency investors lack the confidence to invest and markets fail to fulfil their true function of allocating capital efficiently”.

Angie Kirkwood Senior Manager Industry Development | Scottish Widows Chris Connelly Principal Consultant | Aquila Heywood

“I believe there ought to be higher levels of transparency in financial services because that is the only way we are going to gain the trust of our customers and allow us to simplify the way we talk to and engage those customers in making the decisions which will give them the best outcomes in their financial planning” “I believe there ought to be higher levels of transparency in financial services because we look after other people’s money and therefore their futures. It’s as simple as that”.

Robin Powell Editor | The Evidence-Based Investor

“I believe there ought to be higher levels of transparency in financial services because without it investors are unable to work out how much they’re paying and how much (or more to the point how little) value fund managers are adding to the investment process”.

Terence Prideaux Managing Director | Morley Hall

“I believe there ought to be higher levels of transparency in financial services because the aspirations of savers and their advisors will not be met if managers take more than headline fees and trust in the financial system will not be won”.

Richard Metcalfe | Principal, Richard Metcalfe Consulting

“I believe there ought to be higher levels of transparency in financial services, and particularly in pensions, because we cannot afford for people not to save for retirement”

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The Transparency Times | www.transparencytaskforce.org | September 2016 | Edition #5


Elizabeth Campbell-Warner Co-Founding Director, Gabriel Research & Management John Greenwood Editor | Corporate Adviser

“I believe there ought to be higher levels of transparency in financial services because transparency is a prerequisite to building trust and trust is essential to the development of a healthy, sustainable financial services industry and the consumers it serves”

“I believe there ought to be higher levels of transparency in financial services because opacity is to journalists what a red rag is to a bull. As long as things are hidden, trust in the industry will remain low.”

Martin Palmer Head of Corporate Funds Proposition | Zurich

“I believe there ought to be higher levels of transparency in financial services because it will help to provide a level playing field as well as helping to restore trust and confidence amongst consumers that they are receiving value for money. This is particularly important at a time when increasing consumer engagement and understanding is so critical”. Bryan Beeston “I believe there ought to be higher levels of transparency in Director | financial services because transparency builds trust, and all ITM Limited consumers and market participants will benefit from improved clarity and thereby increased levels of understanding enjoyed by the end customer”. Olivia Seddon-Daines “I believe there ought to be higher levels of transparency in finanSenior Research Analyst | cial services because I am concerned that the everyday pension ET Index saver is embroiled in a system which charges fees at every turn, which invests in volatile markets that do not price in carbon risk, and, most importantly, that has proven itself unable/unwilling to accept ownership of endemic risks to the system, and the knockon effects to the real economy”. Jon Parker “I believe there ought to be higher levels of transparency in CEO | financial services because without it, customers will simply Jonathan Parker continue to mistrust the industry and lose out financially. However, Consulting we would be wise to remember that more information and data can itself be a hindrance to improving outcomes”. Nicholas Morris “I believe there ought to be higher levels of transparency in finanAcademic Visitor | cial services because financial services are key to our economy St Anthony’s College, and society, and transparency is necessary to encourage trustworOxford thy behaviour by financial services professionals. It is important that we define their obligations and responsibilities clearly, and then hold the industry and those who work within it to account.” Shyam Moorjani “I believe there ought to be higher levels of transparency in Partner | financial services because pension scheme members are entitled RSM to know the full cost, including all transactions, for the administration and investment of their money. Transparency will also allow benchmarking and informed comparisons to allow investors to make informed and better investing decisions and to enable them to improve outcomes to reach their financial goals.”

Edition #5

| September 2016 | www.transparencytaskforce.org | The Transparency Times

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Matthijs Verweij BD Mgr, Pensions | KAS BANK N.V.

“I believe there ought to be higher levels of transparency in financial services because more transparency leads to better governance and in control management of pension schemes in all aspects”.

Ralph Frank CEO - DC (UK) | Cardano

“I believe there ought to be higher levels of transparency in financial services because users of our services should be able to understand what is being done for them and the corresponding charges being levied”.

Sunil Chadda Managing Director | Cairn Consulting Ltd William Goodhart Chief Executive | CFA Society of the UK

Stewart Bevan UK Product Manager | KAS BANK N.V. Iuliia Shpak PhD Candidate Financial Economics/ Asset Pricing | University of East London Colin Meech National Officer | UNISON - Capital Stewardship Programme Anita Skipper Senior Analyst Corporate Governance | Aviva Investors

“I believe there ought to be higher levels of transparency in financial services because every customer has the right to know exactly how much goods and services cost at the point of purchase” “I believe there ought to be higher levels of transparency in financial services because it contributes to the establishment of trust which can improve consumer outcomes. To date, the focus has been on costs and performance, but the investment profession and its stakeholders would also benefit from an improved understanding of the purpose of investment and from the processes employed on their behalf.” “I believe there ought to be higher levels of transparency in financial services because stakeholders deserve to have access to the right information, to inform the best levels of decision-making and improve outcomes”. “I believe there ought to be higher levels of transparency in financial services because Transparency is critical for investor confidence and trust in financial markets” “I believe there ought to be higher levels of transparency in financial services because Pension scheme members should know how much it costs to be a member of their scheme. The full cost, including all transactions, for the administration and investment of their money”. “I believe there ought to be higher levels of transparency in financial services because it is only through transparency that we can gain the trust required to succeed.”

Rachel Haworth Policy Officer | ShareAction

“I believe there ought to be higher levels of transparency in financial services because ensuring institutional investors are directly accountable to the people whose money they look after is the only way to transform the system into one that serves savers, society and the environment”. Henrik Wolff-Petersen “I believe there ought to be higher levels of transparency in finanDirector and Co-Founder | cial services because for being able to take rational decisions we Panda Connect need to have control of our data; independantly, timely and complete.”

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The Transparency Times | www.transparencytaskforce.org | September 2016 | Edition #5


Stephanie Baxter News Editor | Professional Pensions

“I believe there ought to be higher levels of transparency in financial services because we need to tackle unnecessarily high charges and ensure investors get value for money. This is integral to giving people the best possible retirement outcomes.”

Nils Johnson “I believe there ought to be higher levels of transparency in Co-Founder and Director | financial services because it is good for business. Confidence, Spence Johnson Ltd efficiency, growth and profitability are all enhanced – over the long term – by greater transparency”. Andy Agathangelou “I believe there ought to be higher levels of transparency in finanFounding Chair | cial services because it holds the key to regaining the trust of the Transparency Task Force consumer, delivering value-for-money and operating a competitive market”. Jonny Paul “I believe there ought to be higher levels of transparency in Freelance Journalist financial services because financial advice is still generally seen as the preserve of the wealthy and post-crisis there is still much distrust. So I believe that a campaign from within that homes in on greater transparency, focusing more on consumer outcomes, that does not stem from the regulators is a powerful way to show intent”. Henrik Pedersen “I believe there ought to be higher levels of transparency in finanManaging Partner, cial services because it will be good for everyone. Consumers will Co-Founder | be able to compare and demand better value for money and the CLERUS LLP financial services industry itself will benefit from becoming more competitive, lean and effective”. John Belgrove “I believe there ought to be higher levels of transparency in finanSenior Partner | cial services because consumers and clients need to trust the Aon Hewitt industry through having access to clear, open, honest, jargon-free information in order to make informed choices to meet their financial objectives.” Alexander Adamou “I believe there ought to be higher levels of transparency in finanFellow | cial services because financial markets are social constructs and London financial services are a public good” Mathematical Laboratory Anthony Filbin “I believe there ought to be higher levels of transparency in finanChairman | cial services because it will have such a beneficial impact upon Capital Cranfield Trustees incomes in retirement”. Adrian Holliday Reporter | Freelance

“I believe there ought to be higher levels of transparency in financial services because millions of consumers are reliant on it for their longterm savings future.”

David Weeks Co-Chair | AMNT

“I believe there ought to be higher levels of transparency in financial services because in times ahead, we must encourage people to save more in their working lives. We want them to be able to fund themselves for increasing numbers of retirement years. To do this, we must deliver, and be seen to deliver, prudent and open costs and charges”.

Edition #5

| September 2016 | www.transparencytaskforce.org | The Transparency Times

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RECOMMENDED READING This section is for academics and authors to advertise (without cost) their relevant books, white papers, academic articles, research findings and so on, so that all our members can know about the thought-leadership, considered opinion and analysis that is available through their work. If you would like to submit a piece of your own work, or the work of another that you would recommend to our members, please get in touch through: andy.agathangelou@transparencytaskforce.org

“What They Do With Your Money; How the Financial System Fails Us and How to Fix It”

Each year we pay billions in fees to those who run our financial system. The money comes from our bank accounts, our pensions, our borrowing, and often we aren’t told that the money has been taken. These billions may be justified if the finance industry does a good job, but as this book shows, it too often fails us. Financial institutions regularly place their business interests first, charging for advice that does nothing to improve performance, employing short-term buying strategies that are corrosive to building long-term value, and sometimes even concealing both their practices and their investment strategies from investors. In their previous prizewinning book, The New Capitalists, the authors demonstrated how ordinary people are working together to demand accountability from even the most powerful corporations. Here they explain how a tyranny of errant expertise, naive regulation, and a misreading of economics combine to impose a huge stealth tax on our savings and our economies.

By David Pitt-Watson, Stephen Davis and Jon Lukomnik. To find out more, visit: http://yalebooks.co.uk/display.asp?K=9780300194418

“Swimming with Sharks: My Journey into the World of the Bankers” Joris Luyendijk, an investigative journalist, knew as much about banking as the average person: almost nothing. Bankers, he thought, were ruthless, competitive, bonus-obsessed sharks, irrelevant to his life. And then he was assigned to investigate the financial sector. Joris immersed himself in the City for a few years, speaking to over 200 people - from the competitive investment bankers and elite hedge-fund managers to downtrodden back-office staff, reviled HR managers and those made redundant in the regular ‘culls’. Breaking the strictly imposed code of secrecy and silence, these insiders talked to Joris about what they actually do all day, how they see themselves and what makes them tick. They opened up about the toxic hiring and firing culture. They confessed to being overwhelmed by technological and mathematical opacity. They admitted that when Lehman Brothers went down in 2008 they hoarded food, put their money in gold and prepared to evacuate their children to the countryside. They agreed that nothing has changed since the crash. Joris had a chilling realisation. What if the bankers themselves aren’t the real enemy? What if the truth about global finance is more sinister than that?

By Joris Luyendijk. To find out more, visit: https://www.amazon.co.uk/Swimming-Sharks-Journey-World-Bankers/dp/1783350644?ie=UTF8&*Version*=1&*entries*=0

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“Capital Failure: Rebuilding Trust in Financial Services” Adam Smith’s ‘invisible hand’ relied on the self-interest of individuals to produce good outcomes. Economists’ belief in efficient markets took this idea further by assuming that all individuals are selfish. This belief underpinned financial deregulation, and the theories on incentives and performance which supported it. However, although Adam Smith argued that although individuals may be self-interested, he argued that they also have otherregarding motivations, including a desire for the approbation of others. This book argues that the trust-intensive nature of financial services makes it essential to cultivate such other-regarding motivations, and it provides proposals on how this might be done.

By Nicholas Morris and David Vines.To find out more, visit: https://www.amazon.co.uk/Capital-Failure-Rebuilding-Financial-Services/dp/0198712227

“#New Fund Order - A Digital Death For Fund Selection?” Safe within its bubble, the City’s asset management industry has existed largely unchanged for over 20 years but no longer. A new digital threat lurks in the shadows. Target assigned, Jon Beckett (‘JB’) hunts down the value chain between fund buyers and fund managers and tackles the difficult issues head-on. Get inside the head of one of the UK’s most controversial investment gatekeepers. Think differently about buying funds, multi-manager and the way the industry works. A digital survival guide (of sorts) for anyone working in the fund and wealth industry. Wet work, it’s a dirty business!

By JB Beckett. To find out more, visit: http://www.amazon.com/NEW-FUND-ORDER-JB-Beckett/dp/1320639259

“Towards a New Pension Settlement” This volume presents the recent experiences of pension reform in seven countries: Australia, Canada, Germany, Netherlands, Poland, Sweden and the United Kingdom. Faced with common problems of ageing societies and constraints on taxation levels, all are increasingly passing responsibility for saving for retirement to citizens. However, there is enormous variety between countries in the degree to which the state intervenes to mitigate the risks which the individual can face in saving for a pension.

By Gregg McClymont and Andy Tarrant. To find out more, visit:

https://www.amazon.co.uk/Towards-New-Pensions-Settlement-International-ebook/dp/B01EYRKJCS/ref=sr_1_1?ie=UTF8&qid=1462913044&sr=8-1&keywords=gregg+mcclymont Edition #5

| September 2016 | www.transparencytaskforce.org | The Transparency Times

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RECOMMENDED READING CONTINUED Transparency Games: How bankers rig the world of finance This is the story of how bankers with help from the members of Wall Street’s Opacity Protection Team (this includes politicians, economists, think-tanks, rating firms, investment charter constrained asset managers and the financial regulators) undermined the global financial system by reintroducing opacity. The result of reintroducing opacity was the worse financial crisis since the Great Depression and the slowest economic recovery. Transparency Games is about the bankers of Wall Street and the City of London creating and maintaining a veil of opacity to hide behind as they rig the global financial markets for their benefit. Their bad behavior isn’t constrained to simply misrepresenting financial products like toxic subprime mortgage-backed securities, but includes rigging the global interest rate, foreign exchange, commodity and equity markets so the bankers’ bets pay off.

By Richard G. Field. To find out more, visit: https://www.amazon.com/Transparency-Games-bankers-world-finance/dp/0990396819

International Investment Management: Theory, ethics and practice International Investment Management: Theory, Practice, and Ethics synthesizes investment principles, Asian financial practice, and ethics reflecting the realities of modern international finance. These topics are studied within the Asian context, first through the medium of case studies and then via the particular conditions common in those markets including issues of religion and philosophy. This book has a three part structure beginning with the core principles behind the business of investments including securities analysis, asset allocation and a comprehensive analysis of modern finance theory. This book is an essential text for business and law school students who wish to have a thorough understanding of investment management.

By Dr. Kara Tan Bhala. To find out more, visit: https://www.amazon.co.uk/International-Investment-Management-Theory-practice-ebook/dp/ B01EAI17WW/ref=dp_kinw_strp_1

Kentucky Fried Pensions: Worse Than Detroit Edition

Kentucky Fried Pensions follows my journey as the first public SEC whistleblower as I attempt to use the new Dodd-Frank law to clean up the culture of coverup and corruption in Kentucky Pensions. It explores the national links between corruption in investments via placement agents and corruption in underfunding that plague states like Illinois and Kentucky. It explores the Kentucky Employee Retirement System (KERS) for State Workers the worst funded state plan in the country (worse than any single IL plan) and how others can learn from its current death spiral. It also discusses the need for a Federal Bailout which is currently being discussed for Detroit and Chicago. It looks into the lack of transparency as evidenced by no disclosure of holdings in SAC Capital buried in a Blackstone fund for nearly a year after the scandal broke.

By Christopher Tobe. To find out more, visit: https://www.amazon.co.uk/Kentucky-Fried-Pensions-Worse-Detroit-ebook/dp/B00GCTHPFG/ref=sr_1_1?s=digital-text&ie=UTF8&qid=1474870687&sr=1-1&keywords=kentucky+fried+pensions

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WHAT’S HAPPENNING ON THE 12th OCTOBER?

WE HAVE ANOTHER GREAT LINE-UP OF SPEAKERS: Louise Sivyer, Policy Lead, Policy Directorate, The Pensions Regulator Janice Turner & David Weeks, Co-Chairs, The AMNT Shazia Afghan, Litigation and Contentious Regulatory Lawyer Alex Letts, Chief UnBanking Officer, UAccount Neil Sellstrom FCPFA, Treasury Management & Pensions Adviser, CIPFA Sophia Morrell, Independent Media Consultant Dan Brocklebank, Director, Orbis Investment Advisory Ltd

The event will include what is bound to be a lively discussion and debate, on what risks trustees might be exposed to in relation to the costs and charges being applied to the pension schemes they are responsible for. Where is it? Squire Patton Boggs, 7 Devonshire Square, London EC2M 4YH When is it? Wednesday 12th October, 10:30 registration for an 11:00 start, to 17:00

To book click

HERE!

Edition #5

| September 2016 | www.transparencytaskforce.org | The Transparency Times

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THE DIRECTORY OF PRO-TRANSPARENCY ORGANISATIONS If you lead a pro-transparency organisation you can speak out and advertise in The Directory of Pro-Transparency Organisations. This is an important initiative because the market needs to know that there are many organisations that see transparency as a commercial virtue, and do not fear it as a threat. We are happy to consider different classifications to those shown. All enquiries about advertising in the Directory to: Transparency Task Force Ltd, andy.agathangelou@transparencytaskforce.org +44 (0) 7501 460308

FIDUCIARY MANAGERS: Ralph Frank, CEO DC (UK) | Cardano E-mail: info@cardano.com Website: www.cardano.com Telephone: +44 (0)20 3170 5910

Cardano was founded in 2000 and now has over 150 staff with backgrounds in the areas of risk management, investment management, research, actuarial and investment advisory. Cardano studies the causes and impact of risk and costs in order to significantly improve financial performance and resilience. We currently provide Investment Advisory or Fiduciary Management services to over 1.3m pension fund beneficiaries with assets totalling over £120bn.

PENSION ADMINISTRATION: Margaret Snowdon OBE, Chairman | Pensions Administration Standards Association E-mail: info@pasa-uk.com Website: http://www.pasa-uk.com/ Mobile: 07983 565955

Is this also the right classification for you?

Is this also the right classification for you? The Pensions Administration Standards Association (PASA) is a not-for-profit organisation which acts as a focal point to engage with industry and government on pensions administration matters. It was created to provide an independent infrastructure to set, develop, and provide guidance on pensions administration standards. It is an independent accreditation body, assessing the achievement of good pension administration standards by schemes and providers.

ACADEMIC INSTITUTIONS: Prof. Dr. Heinz-Dietrich Steinmeyer University of Muenster / Germany School of Law Universitätsstrasse 14-16D-48143 Muenster Phone 49-251-8329744 Mobile 49-171-8384816 Mail: steinmeyer@uni-muenster.de

Is this also the right classification for you? I am a professor for Social Security Law, Labour Law and Civil Law at the University of Muenster Law School. My special field is pensions – occupational/ supplementary pensions as well as public pensions. I am doing consulting work nationally and internationally including international organizations (EU etc.). I am the Chairman of the European Network for Research on Supplementary Pensions.

INVESTMENT GOVERNANCE CONSULTANTS:

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Also right for you?

Henrik Pedersen, Managing Partner & Co-Founder | Clerus LLP E-mail: henrik.pedersen@clerus.co.uk Website: http://www.clerus.co.uk/ Telephone: +44 20 3356 2845 Mobile: +44 7767 656234

We partner with pension schemes and other asset owners to review and improve investment decisions, governance and value-for-money, through independent and informed investment analysis. As a result, investment outcomes can be improved without the need to change service providers or taking on more investment risk. We offer a free initial assessment, so why not try us out?

James N Meenan, Principal | JNM Investment Governance E-mail: james@jnmresearch.com Website: www.jnmresearch.com Telephone: +353 (0)1 687 1027 Mobile: +353 (0)86 257 2646

JNM Investment Governance gives trustees independent coaching and support to develop strategies and techniques to stem the overwhelming resource handicap they face in discussions with investment professionals. JNM’s objective is to facilitate a constructive two way dialogue with attendant benefits for all parties.

The Transparency Times | www.transparencytaskforce.org | September 2016 | Edition #5


DATA SERVICES: David Rich MIod, CEO | Accurate Data Services E-mail: david.rich@accuratedata.co.uk Website: http://www.accuratedata.co.uk/ Telephone: 01603 813366w Mobile: 07919918623

Is this the right classification for you? David is Chief Executive of Accurate Data Services, a specialist data quality and positive people tracing business that is focused on unclaimed assets in the financial service sectors. ADS traces lost members, clients and policy holders for a variety of organisations including Life and Pensions funds, Banks and Asset Managers. The goal is to help businesses reunite their customers / members with their assets and deliver positive consumer outcomes. David is an active campaigner for transparency and action around the large unclaimed assets issues present in the UK.

INVESTMENT CONSULTANTS:

FINANCIAL PLANNERS:

WEALTH MANAGERS:

Is this the right classification for you?

ACTUARIES:

Is this the right classification for you?

PENSION SCHEME PROVIDERS:

PENSION SCHEME SELECTION EXPERTS:

ASSET MANAGERS:

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PENSION SCHEME CONSULTANTS

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RESEARCH ORGANISATIONS:

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INSURANCE COMPANIES:

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BANKS:

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REGULATORS AND GOVERNMENT DEPARTMENTS:

TRADE UNIONS:

Is this the right classification for you?

TRADE BODIES:

Is this the right classification for you?

CAMPAIGN GROUPS:

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PENSION SCHEME COST REDUCTION CONULTANTS

CONSULTING ACTUARIES: Edition #5

Is this the right classification for you? Is this the right classification for you?

Is this the right classification for you? Right for you?

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| September 2016 | www.transparencytaskforce.org | The Transparency Times

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ANALYTICS ORGANISATIONS:

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PR FIRMS:

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EMPLOYEE BENEFIT CONSULTANTS:

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BENCHMARKING CONSULTANTS:

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INDEX PROVIDERS:

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HEDGE FUNDS:

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PRIVATE EQUITY:

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PUBLISHERS AND PUBLICATIONS:

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INDEPENDENT TRUSTEES:

EMPLOYER COVENANT CONSULTANTS:

POLITICAL PARTIES:

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DATA SERVICES:

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BUILDING SOCIETIES:

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COMMUNICATION CONSULTANCIES:

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CUSTODIANS:

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LAWYERS:

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GOVERNANCE CONSULTANTS:

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Is this the right classification for you?

The Transparency Times | www.transparencytaskforce.org | September 2016 | Edition #5

The Transparency Times Edition #5 September 2016  

The Transparency Times is the official publication of the Transparency Task Force, the campaigning community dedicated to driving up the lev...