Transparency Times Edition #12 April 2017

April 2017

“IN A LECTURE I HEARD SOME YEARS AGO, A PHILOSOPHER ASSERTED THAT SCIENCE TRIES TO ANSWER THE QUESTION ‘HOW’ WHILE PHILOSOPHY TRIES TO ANSWER THE QUESTION ‘WHY’...”

This month’s contributors are: Andy Agathangelou

Founding Chair, Transparency Task Force Page 3

Saker Nusseibeh The 300 Club Page 4

Martin White

Henry Tapper

Mike Barrett

Director, UK Shareholders Association Page 12

David Hutchins

Angela Brooks

Larry Bates

Page 26

Page 28

Page 32

Lead Portfolio Manager Multi-Asset AB

Founder Pension Life

Founder, Wealth Games

Founder, Pension PlayPen, Dir. First Actuarial Page 22

Consulting Director, Lang Cat Page 36

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

...is the collaborative, campaigning community dedicated to driving up the levels of transparency in financial services, right around the world.

...is the official publication of the Transparency Task Force.

It is a great opportunity for our community to share news and views, insights and ideas, right around the world.

...is how we bring people togethor to discuss and debate the key issues and to listen to thought leaders on the vital topic of transparency in financial services.

...is awarded to one individual/organisation at each of our Transparency Symposia, in recognition of the contribution they are making to encourage greater transparency.

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EMAIL CORRESPONDENCE:

The Email reproduced below was sent to the Financial Conduct Authority on 13th April:

Dear Mr. Woolard, I am Emailing you in your capacity as Executive Director of Strategy & Competition at the Financial Conduct Authority...

You may be aware that a few weeks ago the Financial Times covered the way in which an asset management firm had reported their investment performance. I raise this with you as I believe that the way performance fees are reported is extremely important; investors need access to clear, complete

Chrostopher Woolard, Executive Director of Strategy & Competition, The Financial Conduct Authority.

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and reliable performance information.

However, there does not seem to be any mandatory requirement for standardised investment performance reporting; for example, they are sometimes reported gross of fees, sometimes net, making it difficult for investors to easily ‘compare like with like’. This makes it unnecessarily challenging for investors to determine which pensions and investment solutions may represent good value for money and which don’t. At best we have an inefficient market; at worst we have the risk of opportunistic obfuscation; perhaps even ‘gaming’ to show unjustifiably flattering results.

The Transparency Task Force would like the Financial Conduct Authority to build on the excellent work it has already undertaken on the issue of performance reporting in its Market Study, Interim Report, and take a close look at the approach taken by GIPS with a view to it, or something similar, becoming the basis of a mandatory approach to performance reporting.

Whilst the Global Investment Performance Standard (GIPS) operated by the CFA Society is full of merit there is no regulatory requirement for it to be adhered to at all times; it is essentially voluntary.

Your thoughts please.

I have cc’d Madison Marriage at the FT who has been covering this issue and also Will Goodhart, Chief Executive of CFA Society UK who would be an excellent point of contact regarding GIPS.

Kind regards, Andy Agathangelou, Founding Chair, The Transparency Task Force

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CALL TO ACTION:

INDIVIDUALS INVESTING FOR THE FUTURE: WH

by Martin White | Director | UK Shareholders Associa

Here are some IMPORTANT questions for you: • Why can’t we tackle executive pay?

• What are the consequences for workers of companies being run with a continual eye on the share price?

• Why is the investment management sector so profitable?

• Why are savers’ returns from their investments so much lower after expenses than they could be?

• Who can you trust to give you useful and affordable financial advice – where do you go to get “the truth” from someone who doesn’t expect to take an annual percentage of your wealth forever?

• Is the level of basic financial knowledge in the UK good enough? Is it in the interest of the financial sector to improve it? Who could we trust to develop the messages and education material that could help the situation?

• Why, in the years since Cadbury in the early 1990s, when the corporate governance movement really got going, have so many things got worse, not better – and is the corporate governance movement doomed to fail if it is left to establishment figures to provide leadership?

• Can regulation of the financial sector really work if a big prize for ex-regulators is a well-paid job in the financial sector?

• Why are the only people with their own money invested in companies – namely, individuals - disenfranchised and put at risk through the nominee system, leaving the effective votes and control over companies to people who are using other people’s money rather than their own?

• With the lobbying power of the financial sector, can we see the situation changing, ever? And if so, how?

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HO CAN THEY TRUST?

ation What to do? Regulation is not the answer. We believe that “Yet more regulation” directed at the financial sector and at corporate leaders just won’t work. Regulation can never beat financial incentives and deeply held beliefs within the financial and corporate sector. We believe that improvements in all of these areas are just not going to happen unless a core body of people, as consumers of financial services, savers, investors – use any term you like for us – work together on

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a voluntary basis to achieve them.

Our core message: “We believe that if a body of savers better understood the key financial principles and worked together to change the balance of power and understanding of financial issues, that would benefit our society as a whole.”

This makes transparency important. The structure

of financial services is underpinned by industry practices which, though not hidden, are sufficiently arcane to be misunderstood; and if properly explained would cause such uproar that they’d have to be changed – for the better. For example, consider the following scenarios:

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• ‘Stock lending’ describes a practice which is in fact a sale and repurchase agreement; the ‘borrower’ has all the rights of ownership – including voting rights – and is the legal shareholder.

• Most private investors have now been forced into online accounts – and why not, they are immediate, simple and efficient?

• These accounts are technically ‘pooled nominee accounts’ – the broker or an associate owns a pool of stock that matches his clients’ investments. The broker, not the investor is the shareholder.

• Shareholders earn fees by ‘lending’ their stock to others.

• The decline of active management means that a large proportion of individual and pension fund equity investment is made via ETF’s, index funds, trackers and closet trackers.

•….and the legal shareholders in these cases are……?

•…and their reaction to an opportunity to ‘lend’ their shares for a fee would be...?

•….so the statement; ‘Most shareholders are beneficial owners with their own money at risk’ is (a) true or (b) false?

•…. and the core assumption of the corporate governance codes, that directors should be accountable to their shareholders is (a) sensible or (b) myopic?

In a nutshell, the ‘ownerless

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corporation’ first defined by Lord Myners over ten years ago is upon us. But it’s even worse than that: we don’t know who does own the major corporations and we don’t know what their interests are.

What we are proposing is to mobilise the power of individuals to direct their savings in a way that forces necessary change. And to start by pointing to solutions that minimise or avoid altogether annual percentage charges on their wealth. Like any successful grass roots movement, our motivation is to help others rather than just ourselves.

We don’t want to underestimate the amount of fresh thinking that is needed in all sorts of areas. We are very much at the early stages in this project: we have a collaborative team approach, and everyone with ideas to contribute is welcome. This is an opportunity to make a real difference to people’s lives and even the way in which the whole corporate sector thinks – that’s the vision we are working to!

UK Shareholders Association (UKSA) originated in 1992 as a small group of private investors concerned at the scandal of excessive executive pay, as exemplified by the utilities sector after privatisation. We haven’t don’t too well there so far, have we? But we know from experience the potential power of a shared passion to get people working together.

We need more people to help

us tackle this project – and it would be nice to bring our average age down a bit too!

We also need more members generally – their subscriptions add up and help us keep going, and the more members we have, the more networking opportunities there are for everyone.

People do not join the UK Shareholders’ Association primarily to make money.

They get to be part of a network of individuals with a common interest in investment. The membership fee pays for a small secretarial function, maintains a web site, supports a programme of corporate visits/briefings and helps communication amongst the membership including a regular magazine. Though any additional funding support is always welcome!

If you are interested in investment, and especially if you are independent of the mainstream investment management and financial advice sectors (though you may have worked in them in the past), and have the time and interest to take part, why not join us? Membership is only £50 per annum (£25 first year). This is an opportunity to help millions of people, not just ourselves.

Join through the website, http://www.uksa.org.uk or to discuss participation email stc@uksa.org.uk

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ANOTHER VERY SPECIAL EVENT:

...on 17th May will be focused on a question of fundamental importance:

“What is the true purpose and potential of the Pensions Industry?”

The symposium will be particularly interesting to those that hope and believe that the pension capital markets could, and should, become a ‘force for good’ for our planet and society as a whole; as well as enabling the efficient provision of financial security in old age.

The idea for the event was wholly inspired by a talk given by David Pitt-Watson, Executive Fellow of the London Business School; David delivered a highly impactful and thought-provoking talk that showed so clearly the wisdom of establishing purpose as a bed-rock for thought leadership and policy-making.

This will be a not-to-be-missed event if you are in any way interested in the development of a more progresive approach to pensions policy-making and believe that Socially Responsible Investing and Environmental, Social and Governance factors are important; as well as looking at the ‘bigger picture’.

As Tracy Blackwell, Chief Executive of Pension Insurance Corporation put it so brilliantly recently:

“It’s hard to lose your way as an industry if you focus on the why!”

Perhaps it is possible for the pensions industry to formulate an over-arching vision statement articulating its purpose? Would such a vision statement help to guide and steer pensions policy?

Maybe it would to create a sense of collective purpose amongst pension professionals? We are hopeful that this event will help to galvanise support for the idea that the pensions industry could become a key driver for improvements on many fronts that are of such grave concern to so many. This conference will be used to share insights on this most-vital of all topics and if all goes to plan delegates will have the chance help build consensus on how the pensions and investments industries accept their responsibilities moving forward.

There will be fantastic presentations and panel sessions - here’s the line-up of key participants: - David Pitt-Watson, Executive Fellow, The London Business School - Leon Kamhi, Executive Director: Head of Responsibility at Hermes Investment Management - Catherine Howarth, Chief Executive, ShareAction - Nicholas Morris, Visiting Fellow at the Martin School, Oxford; Adjunct Professor, Faculty of Law, New South Wales - Hugh Wheelan, Managing Editor, Responsible Investor Magazine - Steve Conley, Managing Director, Workplace Pensions Direct - Nico Aspinall, Chair, Resource and Environment Board, Institute & Faculty of Actuaries -Tracy Blackwell, Chief Executive, Pension Insurance Corporation - Tony Greenham, Director of Economy, Enterprise & Manufacturing, the RSA. Book yourself a place swiftly; places are limited and demand for them is expected to be very high -

CLICK HERE TO BOOK YOUR PLACE When & where?

Wednesday 17th May, 9:00 to 17:00 Pension Insurance Corporation, 14 Cornhill, London EC3V 3ND Edition #12

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ARTICLE:

THE FCA’S ASSET MANAGEMENT MARKET STUD

by Martin White | Director | UK Shareholders Associa

In November last year, the Financial Conduct Authority, FCA, published a very substantial 200 page “interim” report, and the annexes are in addition and even longer. But, in spite of the length, we welcome it!

The report was the outcome of a large research project into the operation of the asset management industry, primarily from the perspective of the customers – us.The conclusions were what we already know – that the industry is massively profitable, but that the customers generally get a poor deal and, most importantly, are significantly poorer in retirement as a result. They also concluded that active management was generally not worth paying for, that investors in cheap passive vehicles did better, and the fact that the FCA had come out saying this caused consternation throughout the industry.

So well done the FCA. Using colourful language of my own, I would say they have exposed the world’s

most profitable con trick, the asset management industry, for what it is.

There was a fair bit of press coverage of the report following its publication in November, so you might have noticed the story back then.

Now before I get into more trouble, there are a few things I must say. I’m not criticising the good intentions of individuals working in the sector. And I’m not saying there is no place for employing investment managers to make decisions for you, which is what active management is. There clearly are a few investment managers who outperform the overall market. But they are few, and what happens with them is they get so much money to manage that they either stop outperforming, or they have to close their fund to new money.

Incidentally, some of us believe that it makes huge sense for us to dodge the financial sector as much as possible, make our own investment decisions, and avoid paying an annual percentage of our wealth to anyone. But the financial sector puts out the subtle message that it’s all too difficult for individuals to manage their own affairs.

And all arms of Government seem to ignore the role and importance of the individual as investor. But we are definitely not giving up on this. It was one of our criticisms of the FCA’s recent study, as you will see later in this article.

You can find the FCA’s report at https://www.fca.org.uk/ publication/market-studies/ ms15-2-2-interim-report.pdf Responses to the report were requested by 20 February 2017.

As a member of the UKSA policy team, I was the main author of UKSA’s response to the FCA’s interim report, and you can find this response in

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DY, MS15/2.2

ation

full on our web site at

http://www.uksa.org.uk/sites/ default/files/2017FebUKSA_AssetManagementStudyResponsePDF.pdf

Our response: Two parts There are two parts to our response, which I need to explain. The first takes the form of a 6 page letter signed by me as an UKSA director.

And “we” in this letter means UKSA. But as part of the response we also attached a 9 page document which I personally had submitted to the FCA before it was formally in operation and signed by me; “I” in that other document means me. I was not an UKSA director at the time, and as the entire thing was to express my personal views I was very careful to emphasise that I was not speaking on behalf of anyone else. Members’ comments to the editor would of course be very welcome!

A few words on my personal submission of December 2012 This current article would be too long if I were to say Edition #12

much on it now. Back in October 2012, the document “Journey to the FCA” was issued, all about the plans and aspirations of the notyet-live FCA (somebody must have had a sense of humour: the go-live date in 2013 was 1 April). This can still be found at

It was all well-meaning stuff, and comments were invited. On the front cover were the words “to make financial markets work well so consumers get a fair deal”.

I felt it was OK, but naïve in places and missing some important things, and I was worried that unless they had the necessary clarity of thought and courage, there was a risk of their being outmanoeuvred by the industry. So I put in a big effort and produced my submission.

I didn’t even get an acknowledgement. I was very cross. I chased them up, to be told that it had been passed to someone in PR!

Were they frightened by what I was saying? Anyway, I gave up on it at that point. I had been really keen that what I had said should get into the public domain, but none of the submissions received in response to the “Journey to the FCA” were published.

However, looking on the FCA web site more recently, I discovered that only 3 private individuals had put in responses in 2012, and it did look as if some of the points I had made were noted. And now looking at the 2016 Asset Management Study, I would argue that my 2012 response was totally vindicated and I would say that it is entirely valid today.

Hence the decision to include it with the recent UKSA submission.

I will write more about the 2012 submission, which was much more wide ranging than the 2016 Asset Management Submission, in a future edition of TPI. [UKSA’s publication].

I believe it does contain some ideas for UKSA in this David

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and Goliath world of individual savers and the financial sector.

Back to the 2016 Asset Management Study Report Here I set out significant chucks from UKSA’s recent letter in response to Report.

“First we would like to congratulate the FCA for shedding a light on both the profitability of active management today, and the poor outcomes for customers.

We welcome this Report and generally support the analysis and the conclusions.

The measured style of the published material makes the starkness of the conclusions very powerful.

The fact that journalists such as Anthony Hilton in the Evening Standard are referring to the current Report as “controversial” is a good sign that there may be a will to tilt the balance more in the interests of individual customers, or consumers.

The nature of the analysis carried out, concentrating as it has on the fund management sector, does mean that the full impact on the outcomes for ordinary savers of the way in which the financial sector works – and we mean here the total costs including advice, distribution and investment management – was not brought out in the Report. However, it is very clear from the Report that the FCA recognises this and is minded to take the issues further.

We believe that the issues identified in the Report

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are part of a wider set of problems in the ownership chain that lead to suboptimal outcomes not only for individual savers and investors but also for individuals as employees and for the economy as a whole.

For those wanting a really good understanding of these problems, we recommend two books by John Kay, Other people’s money and The long and the short of it (the subtitle of which is “a guide to finance and investment for normally intelligent people who do not work in the industry”). The way these problems manifest themselves is perhaps best captured as follows. There are three stages in the ownership chain between most individual savers and the underlying companies which they own. The first is financial advisers, the second fund managers, and the third is the senior executives and boards of the underlying companies. The way each is remunerated is effectively by taking an annual percentage of the individual savers’ wealth.

This is what the methods of “incentivising” senior executives and boards of companies now amount to, and since fund managers with the votes to control company behaviour use the same model themselves they can hardly be expected to reject the theory of incentives on which executive pay now rests.

The only way to achieve fundamental change is to tackle the basic “take an

annual percentage of the clients’ wealth” model at each stage in the ownership chain.

This model is directly contrary to the principle of stewardship, which is what acting in clients’ interests should amount to.

The scale and the scope of the underlying problems are outside the scope of the FCA to tackle alone.

But the FCA may still be the most important regulatory body here, since its scope covers both retail financial advice and financial services generally, including investment management.

Overall comments on the Report Overall, we believe this is a strong and effective analysis, and we agree with the Report’s main conclusions. In this letter we touch on both these conclusions and the Report’s proposals for the way forward.

For us, the most important conclusions of the Report are that competition is not working and that retail savers and investors in particular are getting a poor deal. It would have been helpful, however, if the Report had included at least some analysis of the opportunities available to retail investors as a whole. We believe that a “self-select” service, where you just pay the stockbroker a fixed annual charge, plus a fixed charge for each trade, and where you do not pay any fund percentages to investment advisers either, is the smart option for those with the knowledge and

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confidence to use it. Under this route, you don’t have to select individual company stocks; you can instead buy ETFs if you wish. The trick is to avoid anything that pays a commission, in other words pretty well all the funds “promoted” on the major platforms.

The big question is how to help people make sensible choices; something is needed alongside the current “advice” model.

It is our belief, given the inherent conflicts of interest between the customers and the financial sector as it currently works, that “help” is not going to come from the financial sector and it is also difficult to see how regulators can do it unaided.

We think there is scope for considering how savers and investors can help each other; it is difficult to see who else there is that they can trust to act in their best interests.

At the UK Shareholders Association, we will be directing some of our policy Edition #12

thinking in future to the theme of “savers take control of their own financial future”.

UK Shareholders’ Association: our perspective and motivations To conclude, it may help to set our own perspectives and motivations in relation to the subject matter. The UK Shareholders’ Association was founded in 1992 in recognition that there was no organisation to represent the interests of private investors. We are a voluntary body, modestly funded by members’ subscriptions. Our members tend to be relatively sophisticated investors in that they take their own investment decisions; they tend to use investment funds, especially actively managed funds, less than the general population. We exist to help our members in the investment process, and we provide a network through which people with shared interest in investment can communicate with each other and represent their

interests with outside bodies, government, etc.. However, in most of our representation activity we aim to take a more general public interest stance.

There are two themes to this.

The first theme is that we would like to see all individuals better informed and empowered in relation to their personal financial management, especially their long term financial planning. We believe that the scope for improvement here is considerable. We also believe that investing directly in shares would make sense for many more people than currently do so. This first theme is completely fundamental to the Asset Management Market Study. The second theme is the proper stewardship of companies, which is now very much in the political agenda (excessive executive pay, short termism, etc.), as reflected in the BEIS Green Paper.

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We believe that that the more people are interested, as long term investors, in the behaviour of companies, the better for society as a whole.

We believe that the operation of the asset management sector is more of a negative than a positive in relation to both of the two themes we explain above. First, it operates as a wealth extraction industry rather than as an agent working in the interests of its principals. And second, because the business model is based on taking an annual percentage of its clients’ wealth rather than being truly aligned with their long term interest, there is little by way of incentive for the asset management sector to take a real interest in the quality of stewardship achieved by the boards of the investee companies. It is very important to note that there are a number of investing institutions who are exceptions to this latter point; some focus on the identification of high quality companies and holding them for long periods. Others focus on the behaviour of companies in terms of their impact on customers, the environment, their employees etc.. So there are instances where we, representing individuals as investors, work alongside investing institutions.

As well as this letter, we also attach as part of our submission a document written in 2012 addressed to the FCA in response to the document “Journey to the FCA” that was published in October asking for comments.

Martin White, BSc, FIA Director, UK Shareholders Association 20 February2017” Stepping back for a moment, the asset management sector is only part of what the FCA is responsible for regulating. There is the financial advice sector too. Together they affect people’s lives in terms of financial outcome, but it is not sufficiently appreciated how they also affect people’s lives as employees because of the short term pressures they place on companies generally.

So I would regard addressing the many problems as potentially transformative for our society. I see the corruption inherent in commission-based (especially trail commission) sales, and indeed the whole sales-driven “how much money can we make out of x”, or “how can we achieve our high target return on capital” approach of the industry, leading not only to systematic customer detriment, but also leading to our whole ownership chain falling short of its potential to generate wealth and deliver it to the underlying owners.

The “ownerless corporation” coined by Paul Myners exists because there is self-seeking where stewardship and fiduciary duty should be. Over the next couple of months we will be determining what part we at UKSA should play in this essential transformation.

“Martin White is an actuary who worked in life insurance and pensions before settling in general insurance, where he works today. In 1988, he was the first actuary to be employed by the Corporation of Lloyd’s, where he began to realise the conflicts of interest and gaps of understanding that can occur between agent and principal. In 1992, he joined the new band of private investor volunteers that became the UK Shareholders’ Association, and has been involved with UKSA ever since. Motivation for this, as well as having a personal interest in investment, is to apply his actuarial knowledge outside his paid employment in a public interest area that attracts less attention than it deserves.”

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‘SUNLIGHT IS THE BEST DISINFECTANT’ VERY IMPORTANT: ABOUT HOW YOU CAN BECOME ‘PART OF THE SOLUTION’ If you’re completely new to our community and want to know ‘what it’s all about’ here are the basics: The Transparency Task Force is the collaborative, campaigning community dedicated to driving up the levels of 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 to deliver better outcomes and better value for money to the consumer.

Furthermore, because of the correlation bet ween transparency, truthfulness and trust worthiness, we hope and expect that our work will help to repair the self-inflicted reputational damage the sector has suffered for decades.

We believe that those of us that have the experience and expertise to know there are problems in the financial services sector and the honesty to admit it, should work togethor to put things right. Let’s stand up, not stand by; because it’s the right thing to do and because it’s in our collective interest to do so. We operate through volunteer Teams. All the Transparency Task Force Teams have a conference call on the first Tuesday of the month, so the next “Team Calls” are on Tuesday 2nd May, at the following UK times: - Banking Team: 9:00 to 10:00; for those that want to drive up the transparency and professionalism in the banking sector - Foreign Exchange Team: 10:30 to 11:30; for people that understand the opacity that exists in FX and want to put right what is very, very wrong in that market!

- Market Integrity Team: 12:00 to 13:00; get involved with this team if you want to help shine a light on the importance of ethical behaviour in the financial ser vices sector and want more of it!

- Costs & Charges Team: 13:30 to 14:30; for those that want to help all types of investors get better value for money from all types of investments; by helping to shine a light on all costs in all their various forms - Stewardship & Decision-Making Team: 15:00 to 16:00; if you understand the ‘a symmetry of information’ problem that the financial services sector is dogged by and how it can lead to poor stewardship and decision-making, please help us eliminate the opacity and obfuscation that undermines optimal outcomes - International Best Practice Team: 16:30 to 17:30 & 22:00 to 23:00; t wo times to suit different time zines - take your pick! - we have members from every continent. This Team will appeal if you want to help the nations around the world to learn more efficiently from each other - we’re working on a Global Transparency Index!

If you care about the financial services sector and want it to do a better job of looking after the needs of its customers and clients, please join the 150+ people that are operating as volunteers within the Transparency Task Force Teams.

It doesn’t matter how experienced or how senior you are. It doesn’t matter if you’re an expert or not. All that matters is that you understand the potential power of transparency in helping to drive the changes that are needed, and that you’re comfortable working collaboratively with others - the Transparency Task Force is very much a ‘team sport.’ If you or anybody you know want to become ‘part of the solution’ by being involved with one or more of these TTF teams please make contact without delay through andy.agathangelou@transparencytaskforce.org

THANK YOU VERY MUCH - YOU MIGHT MAKE THE DIFFERENCE THAT MAKE’S ALL THE DIFFERENCE!

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ARTICLE:

FUND COST DISCLOSURE, ARRIVED ON FRIDAY AND IT’S HERE TO STAY.

by Henry Tapper, Founder | Pension PlayPen; Director

We are now well in to the IGC reporting season, where Independent Governance Committees tell us how well the insurers they oversee are behaving.

I had had low expectations going into this round, 11 of the key insurers had spent much of the year collecting feedback from 15,000 of their members telling them (what they already knew), that people wanted a good investment return and good information along the way.

I had assumed that this would take care of the “value for money” debate for another year and that we’d have to await the final report from the FCA on how we established value for money in investment terms.

That was until I read the

Legal and General IGC report, which is the gamechanger we needed. The breakthrough seems small, the publication of transaction costs for a handful of passive funds used within its Worksave Pension. But L&G have let a very important rabbit out of the hat and the implication for funds governance (let alone DC governance) cannot be underestimated.

Why L&G’s publication of fund transaction costs is so important.

1. Legal and General aren’t any old fund manager, they

are Britain’s biggest and one of the largest managers (by assets under management) in the world.

2. L&G’s funds aren’t just inside the L&G Worksave pension, they are in many rival propositions including Smart, Bluesky and even NEST. 3. The costs are much higher than experts had anticipated and are material to the performance of the funds.

4. This means hidden costs must form part of a value for money assessment of investments.

5. While L&G’s charging structure means that the impact of hidden costs keeps L&G compliant with the charge cap, those providers using similar funds and with an existing AMC of around 0.75% would become uncompliant if hidden costs were included in the cap.

L&G have just thrown a unpinned hand grenade into the fish-pond.

The reporting of the value for money benchmarking carried

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Y [31ST MARCH] –

r

| First Actuarial out by IGCs had - until this point - been feeble. The results of the NMG feedback was that all providers were seen as much of a muchness by members. Even so, the providers banned the IGCs from using the results to show that their provider was giving more or less value than a competitor.

Some work on transaction costs had been done by Scottish Widows, Phoenix (and no doubt others), but to date we had only had generalised assurances that the scale of transaction costs was insufficient to ring alarms. These hidden costs were well on the way to being absorbed into some general value for money score which could be published in April 2018.

This would have kept awkward questions from DC members of fund managers with high hidden costs at bay.

Since many of these funds are used by defined benefit schemes, it would have kept awkward questions from institutional trustees and consultants at bay too.

Most importantly of all, it would have made it very easy for the Regulator to Edition #12

ignore hidden costs in the DC default charge cap (which is under debate as part of the 2017 auto-enrolment review.

Had L&G not gone and published these hidden charges, everything might have been kept under the Investment Association’s hat and the fund managers, insurers and commercial master-trust’s margins would have been maintained.

Pandora’s box.

When Pandora opened her box, winds flew out that caused chaos in the Mediterranean for years. No doubt the funds industry will turn on L&G and point this out!

For we now know, not just that hidden charges exist, but they can be quite high and that they are unpredictable.

It will be impossible, going forward, to ignore hidden charges in any thorough performance report.

The lid is off, it cannot be replaced.

Since L&G have published, the onus is now on the rest of the IGCs to publish too.

For L&G DC investors paying 0.13% for the multi-asset fund (MAF) , the news that they are paying 0.06% additionally amounts to a 50% increase in yield-drag. The numbers are quite different for equity funds prompting many of us to ask whether we want to use MAF as our default.

We are now in the fortunate position to have this debate.

The same debate cannot be had where the information is not on the table. We should remember that this is about our money, not about some

Those charges will need to be justified on a value for money basis and eventually we will want to report on those hidden charges as part of annual governance reports, manager selections and compliance reviews.

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fund that pays defined benefits which is paid for by an employer, the risk for a DC investor of over-paying in costs and charges falls firmly at his or her door.

Many of us have campaigned for years for the right to know what it is we are paying for the management of our money and now - at least with L&G- we know. The lid is offit cannot be replaced.

I now want to see the table shown re-created by every IGC so that we can compare what we are really paying for our workplace pensions not just at L&G but elsewhere. And if we cannot have this information, I would like to know why not!

Henry Tapper is a Director of First Actuarial and a Founder of Pension PlayPen. He is an activist for good governance and dedicated to restoring confidence in pensions. He has worked for some time on improving the transparency of costs and charges in DC plans in the UK and has a wider interest in “value” especially value asset managers can create through good stewardship Henry bloggs at https://www.henrytapper.com a fantastic source of often-witty insight and analysis - he sees social media as a key means to get messages out to the public. When he’s not at work he is on a boat in the summer and supporting Yeovil Town if its not.

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The Transparency Times | www.transparencytaskforce.org | April 2017 | Edition #12

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| April 2017 | www.transparencytaskforce.org | The Transparency Times

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ARTICLE:

GREATER TRANSPARENCY DELIVERS BETTER V

by David Hutchins, FIA | Portfolio Manager—Multi-A AllianceBernstein

As recent as last November the FCA’s Interim Report highlighted that asset managers need to raise standards when it comes to transparency and investment products’ ability to deliver genuine value for money.

We agree with this focus and believe that better transparency is critical in identifying value for money in DC pensions. It enables those responsible for safeguarding saver outcomes properly to recognize what constitutes value—too often, it’s assumed that the simply cheap constitutes good value.

In our view, securing genuine value for money involves defined contribution (DC) schemes taking a long hard look at their systems and processes—and doing everything they possibly can to secure the best outcomes, net of costs, for savers’ investments and ensuring that nothing gets lost along the way on cost-of-investment inefficiencies.

Will extra costs secure extra “value” for members— for instance, by including currency hedging or diversifying asset classes— or will these simply “disappear” into a convoluted

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administration system?

As a starting point, we believe it’s key to gain clear transparency on how overall pension costs break down between universally accepted administrative charges, for example communications, marketing and governance, and investment elements.

A single bundled charge for a pension, with little or no transparency on how it is spent, hardly encourages good behaviour from pension providers or buyers.

Separating out investment and administration costs would enable regulators, independent advisers and employer pension committees to hold providers to account and make sure there is a fair balance between what is spent on administration and what is spent on investment.

We believe getting this balance right can ultimately improve retirement outcomes for the vast majority of scheme members who contribute and invest in line with the plan’s default strategy.

Too often, we think the balance is wrong. As an increasing number of providers sell to plan sponsors on headline prices alone, investment budgets have decreased faster than any other item in overall cost budgets. This effectively ensures there’s a focus on those services most valued by the plan sponsor to the detriment of typical plan members. Some providers are spending as little as 10% of the costs they incur on investment as they rush towards the cheapest possible investment strategies, rather than choosing the strategies likely to deliver the best net outcomes at a particularly challenging time for markets.

Some asset classes can be marginally more costly to access, but, if used appropriately, can secure better diversification and, therefore, better member outcomes. Liquid alternatives (such as private equity, infrastructure or smart beta products) are good examples.

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VALUE

Asset Solutions | At the same time, certain pension strategies can benefit from exposure to more sophisticated risk control mechanisms, such as currency hedging overseas investments. This may seem obvious, but this inherent value is very difficult to capture if the bulk of costs are spent on administration rather than on investment budgets.

In the United States, administrative fees can be as low as single-digit basis points. There are important structural differences between the UK market and its US counterpart. But the US experience clearly shows what can be achieved when administrative cost efficiency (and transparency about how costs are incurred) are a key focus—instead of just overall costs.

In the UK, there is a lot of divergence in how pension scheme charges break-down.

Instead of focusing on “allin” costs, schemes should be clear about how much is allocated to generating investment returns and how much is spent elsewhere, especially for default strategies.

We think it’s sensible to spend around 40% of the Edition #12

pension charge on the investment-related budget (around 20-30 bps, assuming a 50-75bps charge). In our view, this would deliver a better product mix and greater diversification, thereby allowing for better riskadjusted returns that could significantly improve many peoples’ pension outcomes.

The focus on greater transparency should not, however, stop at charges.

In addition, schemes need to be held accountable for the performance they deliver. We would like to see default strategies being required to publish their historic returns, net of all costs incurred by members.

When we surveyed DC savers, 64% said that they’d welcome this kind of performance information.

Therefore, we regard annual reviews of pension schemes’ default investment strategy, and the value it provides to members, as a must.

We think that trustees and investment governance groups will need carefully to consider whether the same investment strategy could be achieved at a lower cost to members—and also whether better net outcomes could be achieved by spending more.

David Hutchins is a Senior Vice President and Head of AB’s Multi-Asset Solutions business in EMEA. He is responsible for the development and management of multi-asset portfolios for a range of clients. Hutchins joined the firm in 2008 after spending two years at UBS Investment Bank, where he was responsible for devising and delivering innovative capital markets risk-management solutions for pension schemes. Prior to that, he spent 13 years at Mercer, where he served as a European principal and scheme actuary, providing trustee and corporate advice to a range of UK pension funds and their sponsors. Hutchins holds a BSc in mathematics and a PGCE from the University of Bristol. He has chaired the Investment Management Association’s Defined Contribution Committee and formerly chaired the defined contribution industry working group for the UK government’s “defined ambition” project. Hutchins is a Fellow of the Institute and Faculty of Actuaries. Location: London.

| April 2017 | www.transparencytaskforce.org | The Transparency Times

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ARTICLE:

THE PENSIONS REGULATOR’S LESLEY TITCOMB PUBLICLY DECLARED THAT SCAMMERS ARE CR

by Angela Brooks | Pension Life

http://www.professionalpensions.com/professional-pensions/ news/3006545/tpr-releases-anti-scam-tools-to-help-savers-and-trustees This begs the urgent question: why have so few – if any – of them been prosecuted? What we need now is all of the scammers behind bars and the keys thrown away. This article is the first part of a serialised reproduction of my book; the purpose of which is to get the message out there and warn the public; the financial services industry in the UK and offshore; governments; regulators; ombudsmen; crime agencies, HMRC, and the scammers that this huge financial crime will NO LONGER BE TOLERATED. The authorities who have stood by and allowed this to happen have to snap out of their complacency, laziness and incompetence, and actually take some action to bring these criminals to justice. £11,000,000,000. That is an awfully big number.

But this is what financial fraud cost thousands of victims in 2016 according to reported statistics. How much of this is down to pension and investment scams is anybody’s guess; or whether that is an entirely separate and equally horrifying number is another possibility.

Either way, this does nobody any good and

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harms innocent, hardworking people on a huge scale. It also compromises the very principle of saving for retirement and shakes confidence in the pensions and investment industry as a whole.

Evidence suggests that in the past seven years, there have been many £ billions lost to pension and investment scams – there are no precise “official” figures.

But the dreadful fact is that the scammers who were targeting victims back in 2010, continued doing it in 2011; and 2012; and 2013; and 2014; and 2015,

and 2016. And they are still doing it today. Happily and profitably. And nobody has stopped them or brought them to account for the horrific financial damage and distress they have caused.

It is hard to decide which is worse: the vicious, greedy, cold-hearted scammers or the feeble authorities who let them get away with it.

Repeatedly. But it has to stop. A military-style, zero tolerance campaign has to be waged against all the guilty parties until every last one of them is brought to justice.

The tragic thing about these scams and the misery and financial ruin caused to so many thousands of victims is that this

The Transparency Times | www.transparencytaskforce.org | April 2017 | Edition #12

B HAS NOW OFFICIALLY AND RIMINALS. disaster was preventable.

HMRC were warned by the industry about the potential for scams if the role of compulsory professional trustee was removed pre 2006. In a letter of March 2004, Nick White, specialist pension solicitor warned: “It is essential that schemes offering selfadministration and wide investment choice should have in place an independent person who has sufficient control of scheme assets to prevent abuse and sufficient knowledge and experience to know abuse when he sees it.

That does not necessarily mean that the system of pensioneer trustees should be retained in its current form but, if it is abolished without an effective replacement, we envisage that within the next 5 years the degree of abuse of such schemes by both incompetent and dishonest individuals will:

Reputable professionals in the industry and the Government share a common aim of building a system of tax rules that is simple but is robust enough to last for a working lifetime without major overhaul. Such a system needs to contain adequate protections against abuse.”

The warning was ignored.

And precisely what Nick White predicted would happen, happened. And it will go on happening until and unless government, HMRC, regulators and police take responsibility for their failings and put in place robust measures to clean up the mess of the past and prevent future disasters.

Nick White’s warning was brought to my attention by Martin Tilley who is director of technical services at Dentons

Pension Management. Martin has written some excellent blogs and articles on the subject of pension scams and my favourite has to be this one: http://www.retirement-planner. co.uk/9344/cleaning-uppension-scams-with-soapoperas I am currently in the process of preparing a documentary series about pension and investment scams and I intend to incorporate Martin’s inspired suggestion that a scam can be acted out on screen to show the public exactly how it works. I had in mind Greg Davies to play the role of the scammer: https://www.youtube.com/ watch?v=xSQ9frm7ziA and George Osborne to play the role of the victim. If Osborne

• further stain the reputation of pensions generally; and • severely embarrass the government responsible for letting it happen.

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members of defined benefit schemes, who it is likely, will not have this flexibility.”

The police officer who lost his police defined benefit pension to Ward’s scam could play himself and comment on what Ward (who was definitely better off) meant by “flexibility”.

is too busy with all his various jobs, perhaps we could ask Cluny?

There are many victims who would be only too happy to help recreate the exact wording – both written and verbal – of the scammers’ pitch. In fact, the ideal case to reconstruct would be the police officer who was scammed out of his police pension and into Stephen Ward’s London Quantum scheme by FCA-registered Gerard Associates (456234) and introducer Viva Costa International. (London Quantum is now in the hands of Dalriada Trustees).

Ward has helpfully recorded his enthusiasm for Osborne’s disastrous pensions “freedoms” in a filmed interview. When asked who was better off as a result, he replied: “Everyone is better off, I certainly mean in relation to UK residents, and that’s because they are going to have greater freedom of choice in terms of how they provide their benefits in retirement age, if anyone is worse off its potentially

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Angela Brooks has been running Pension Life since 2013 – a series of group (or class) actions to represent victims of pension and investment scams. Based in Granada, Southern Spain, the members of the small Pension Life team handle tax appeals for victims of pension liberation fraud, and conduct litigation administration for the legal teams in London. They also make reports and complaints to regulators, ombudsmen and financial crime units in a number of different jurisdictions where pension and investment scams have operated.

Set up to deal with the £30 million Ark case, Pension Life now represents victims of Evergreen, Capita Oak, Henley, Westminster, Salmon Enterprises, Pennines, London Quantum, Headforte, Trafalgar Multi-Asset Fund, EEA Life Settlements, KJK Investments, Peak Performance and numerous other pension and investment scams. Most of the schemes involve some form of “liberation” (accessing pension funds before the age of 55 – triggering unauthorised payment tax charges).

Increasingly scammers are moving towards toxic investment scams which abuse QROPS. Angela has frequently been threatened with defamation proceedings by the scammers’ solicitors and is appalled that legal professionals will even represent such low lifes who ruin so many thousands of lives and destroy so many millions of pounds’ worth of pensions and savings. But she is equally horrified at the number of pension trustees and insurance companies who have routinely accepted business from such criminals for so many years.

The purpose of this book is to warn the public against current scams and scammers (the same ones who have been doing it since 2010) and encourage the police and regulators to criminalise all forms of scams. The Pensions Regulator’s Lesley Titcombe has clearly stated that scammers are “criminals” and it is hoped they will all be prosecuted. The victims and the ethical members of the financial services industry want to see a zero-tolerance policy and a military-style campaign to stamp out this horrendous crime wave.

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Angela has dealt with many heart-breaking cases in the past few years and knows many of the victims well. With most of them fearing losing not only their pensions but also their homes, marriages and health (and even lives), she believes it is time for a much more high-profile and hard-hitting publicity and warning campaign – including a documentary series to reach many more people both in the UK and offshore.

Eminent pension adviser Henry Tapper, the “Pension Ploughman”, published a blog on 19.3.2017, https://henrytapper.com/2017/03/19/why-we-are-all-regulators/ which highlighted the dangers of scams in the UK and offshore. Henry stated: “Sadly, we are no more likely to eliminate financial fraud than we are to win the war on terror.”

Henry concludes: “Publicity is critical, though Action Fraud would like hegemony over information, the issue is about flows of capital out of the UK pension system into overseas arrangements today! We are all regulators.”

And this is the whole point: when an ordinary crime is committed, the police often appeal for information from the public. They ask for possible witnesses or anybody with any information to come forward. The police engage with the public actively and publicly. But with pension and investment scams, neither the police nor the regulators engage. In fact they do quite the reverse – they retreat and hide behind layers of obfuscation.

“The only thing necessary for the triumph of evil is for the good men to do nothing”. (Edmund Burke). In fact, in April 2015, Angela met with Andrew Warwick-Thompson of tPR, along with two Ark victims and a professional trustee.Their agenda was to get tPR to strengthen the Scorpion warning campaign and take action on live scams. However, tPR’s agenda was quite different: it was to establish that they neither needed nor wanted any help or advice; that they were independent and worked by their own rules/standards. In fact, Warwick-Thompson (and his two solicitors in attendance) made several not-so-veiled threats about Angela getting in their way.

Equally frustrating, in the case of the London Quantum pension scam, was the plight of a police officer who lost his police pension to a known, serial scammer. He tried for many months to get the police to investigate the crime – and only after well over a year were the premises of one of the scammers searched. In the case of the Capita Oak scam, Angela and numerous victims made detailed reports to various police forces up and down the country, but no action was ever taken by any of them. Indeed, various police officers made every effort to disown the case as they bounced it from place to place. Two years later the Insolvency Service produced a detailed witness statement outlining the identities of the various scammers behind the crime, and the scheme was placed in the hands of Dalriada Trustees – nearly two and a half years after it first collapsed.This coincided with HMRC sending out the tax demands to the victims in March 2017.

The situation with the FCA is even more frustrating. Complaints against registered firms and individuals acting illegally are often simply ignored while complaints against those carrying out regulated activities without permission are not referred to the police. It is clear that evil is triumphing on a massive scale while the regulators, police and government not only do nothing, but establish that they are not even staffed by good men.

Angela is fighting, therefore, not only the scammers and those who facilitate their scams, but the authorities who take no action and send out the clear message that the scammers have “got away with it” and that they will continue to do so. Henry Tapper concludes his blog with a neat summing up of her mission: “Angie has many followers and she can count me among her fans. I do not think that tPR are such fans as they see her as a vigilante. The scope of tPR is limited and even with the co-operation of other regulators, the capacity to act against fraudsters operating outside our national boundaries is limited. Angie disrupts the fraudsters by bringing them to our attention but her focus is on the victims – and protecting them. Whether tPR likes it or not, she is more trouble to the scammers than the UK authorities can be. Without her, Trustees and ordinary members with UK rights might never know. Her website www.pension-life.com is an invaluable resource.”

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ARTICLE:

T-REX SCORES – A NEW PERSPECTIVE ON THE

by Larry Bates | Founder, Wealth Game “The miracle of compounding returns is overwhelmed by the tyranny of compounding costs” - Jack Bogle

There are two problems with investment fees: 1. The first issue is the lack of investor awareness of the amount of investment fees. Certainly in Canada, most investors do not know what they are paying.

Worse still, as mutual fund fees are quietly deducted from total fund returns rather than being invoiced and paid directly, many Canadians are under the false impression they are paying no fees whatsoever.

As in other jurisdictions around the globe, the traditional Canadian investment industry has worked hard to avoid fee transparency 2. The second issue is the impact of investment fees on ultimate outcomes.

There are some exceptions but, broadly speaking, even investors who do understand how much they are paying have no sense of the impact of fees over lengthy, but typical, investment time frames. For most of us, the relentless mathematics of compounding, whether miraculous or tyrannical, are simply not intuitive.

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The T-Rex Score is a new tool which reveals how much total return an investor actually gets to keep, after fees.

any scenario you wish. Make adjustments. See how your T-Rex Score changes. Here is how it works:

T-Rex stands for Total Return Efficiency Index. It demonstrates how efficiently total return translates into investor return. (And yes, it also fits quite nicely with Mr. Bogle’s metaphor!)

Enter the amount of your existing or contemplated investment. (Favouring simplicity over flexibility, we chose to initially allow for a one-time investment only rather than a series of investments over time)

There is, of course, absolutely nothing new about T-Rex Score mathematics. But I believe that distilling all the compounding math into a single, simple ratio may facilitate better investor understanding of the true impact of fees. If so, T-Rex Scores may enable investors to better address a critical investment question: “Am I receiving my fair share of investment returns?”

You can calculate T-Rex Scores at http://www.wealthgame.ca I would encourage you to try it out. It couldn’t be simpler!

Calculating Your T-Rex Score The T-Rex Calculator allows you to determine T-Rex Scores for an endless range of scenarios. So, start with

Investment Amount:

Time Horizon: Enter your estimated investment Time Horizon.

Example 1: A 45-year-old anticipating a long life may enter a Time Horizon of 30 or 40 years.

Example 2: A 30-year-old looking to project the value of an investment at age 65 may enter a Time Horizon of 35 years.

Example 3: A 60-year-old projecting the value of an investment at age 80 may enter a Time Horizon of 20 years.

Estimated Rate of Return: Enter an average annual return on investment be-

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IMPACT OF FEES

fore fees.

We suggest the following guidance to Canadian investors:

fees increases significantly over time. (And, of course, you also need to beat taxes and inflation to produce real

- Financial Planning Standards Council’s (“FPSC”) recommends using 6.4% as the current rate of return planning guideline for Canadian stocks. (While exhibiting lots of volatility along the way, stock indexes have produced average annual returns of 6-9% over long periods of time.

- Current yields on most bond/fixed income funds are in the 1.5-2.5% range“ - Balanced” funds comprising a mix of stocks and bonds will provide a return somewhere between stock and bond returns.

Annual Fees: Enter the total of annual fees deducted by your investment providers including your broker, investment advisor and fund managers as well as any fees paid directly by you. As discussed, the challenge here for many investors will be to get the full picture of fees and other costs they are incurring.

Results: As you know, combinations of longer time horizons, higher rates of return and reinvestment can produce astonishing total gains but the impact of Edition #12

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investment gains!)

In the illustration above, $10,000 is invested over 25 years with a total compounded average annual return of 5% producing a total gain (red curve) of $23,864. But, 1.84% annual fees (typical for a Canadian mutual funds) leave the investor with only $11,766 (yellow curve) or 49% of the total.

Q: What’s The Fee? (WTF!) A: 1.84% B: 36.8% C: 51% D: All of the above The answer is D: All of the above

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Investment fees are quoted (when they are quoted!) as a percentage of your investment. So, in this scenario, a fund with “1.84%” annual fees will cost you 36.8% of your total return in any given year and 51% of your total 25 year return!

In my view, this perspective demonstrates that the current industry method of fee quotation is highly misleading for three reasons: 1. You make an investment to earn a return, not just to get your money back. Leave your money in your bank account or stuff it in a mattress if you just want to get it back! The benefit you are seeking is to earn a return on your investment. Quoting the cost as

a percentage of that return (even if that return is a forward looking estimate) would provide a fairer representation of true “cost versus benefit”.

2. When a product will be paid for over years or decades, quoting the fee as an amount payable over an arbitrary fraction of that time frame, i.e. one year, is nonsensical.

Quoting the fee on the basis of an investment “horizon”, meaning a number of years that will be closer to the projected life of the investment, would present a much more accurate picture to investors.

3. Annual fee quotations do not reflect the “tyranny” – in other words, annual fee quotations give no indication of how the total amount lost to

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fees (the difference between the red and yellow curves) accelerates over time.

By simply revealing the portion of total return an investor actually gets to keep after fees, T-Rex Scores provides a more complete representation of investment fees.

Fee Transparency I believe true fee transparency requires the investment industry to regularly provide investors with clear, simple summaries of both:

1. The full amount of investment fees 2. The impact of investment fees over time The http://www.wealthgame. ca website is currently Canadian centric but T-Rex Scores have application everywhere.

I would be grateful for any thoughts you may have regarding T-Rex Scores! larry@wealthgame.ca

Larry Bates is the Canadian based founder of wealthgame.ca. He is an author, blogger and speaker with a focus on investor literacy. In addition to Scotiabank and Merrill Lynch, Larry spent 23 years with RBC Capital Markets in Toronto and London including as Global Head of Debt Capital Markets.

Larry believes investors would benefit greatly from a better understanding of investment basics and from higher T-Rex Scores!

HUGE thanks to...

...for being the very first organisation to agree to host a Transparency Symposium outside the UK. Come and join us in Cape Town on 24th January 2018 - we’re looking for speakers, panellists, delegates, media partners and sponsors as of now, so get in touch. If you don’t yet know about the services provided by Allan Gray you can check out their website here.

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ARTICLE:

THE FCA ASSET MANAGEMENT STUDY - A GOOD

by Mike Barrett | Consulting Director | Lang Cat

Last November’s FCA Asset Management Study Interim Report is just that, an interim report, but it already feels like it has the potential to be one of the most influential and disruptive pieces of work to come out of the regulator for a long while. There has been much speculation and comment as to how it might all play out, although the silence from the asset management sector (especially the active side) has been deafening.

At the lang cat we spend a good proportion of our time working with financial advisers, and platform providers serving the advised market. Worryingly for advisers, as the dust settles from its publication it’s difficult to know exactly what will happen next.

On one hand, it’s worth remembering that nothing has actually changed and no new regulation has been introduced, but with the regulatory direction of travel becoming more clear it’s probably dangerous for advisers to be completely ignoring the findings. We think advisers need to be paying attention to this report now, and starting to account for the findings within their existing advice process.

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There are three main areas to focus on….

Firstly, the central theme of the study was the costs paid by investors, and whether these were of value or were preventing a good outcome.

Advisers are already required to assess this whenever making a personal recommendation. COBS 6.1A.16g states that “In order to meet its responsibilities under the client’s best interests rule…a firm should consider whether the personal recommendation is likely to be of value to the retail client when the total charges the retail client is likely to be required to pay are taken into account” Exactly what level of costs are reasonable, and “of value” is not specified, so it’s up to the adviser to decide. A

good practice could be to file check anything above, say, 200bps, and reject anything above 250bps. Whatever figures you use, it’s important to focus on the total cost of ownership, factoring in all charges incurred. As the interim report says, “even small differences in charges can have a significant impact over time”, so this is certainly an area where advisers can add value.

Elsewhere, chapter 5 focusses on how intermediaries, fund rating agencies and platforms can influence the investment solutions the customer will end up invested in. There appears to be a case for further FCA work into the issues raised in this chapter, but this is also an area where

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D START, BUT NOW WHAT?

advisers have an existing regulatory responsibility.

COBS 6.1F.1 states that “A firm which uses a platform… must take reasonable steps to ensure they use a platform which presents its retail investment products without bias”. Again, exactly what that means in practice is left to advisers to decide, but it’s certainly not something that can be ignored. We wrote a lang cat guide on this very subject a couple of years ago, which you can find here if you are interested in knowing more.

FCA urgently needs to set out what the next steps of this work will be, and how their expectations of advisers might have changed.

Mike is consulting director, and sole-proprietor of the lang cat Isle of Wight office. A driver and survivor of platform mergers, migrations and RDR he held a number of senior roles at Skandia and Old Mutual Wealth, most recently Head of Platform Marketing. His favourite platform is platform 4 at Southampton.

Probably the most hard hitting, and potentially disruptive statement in the interim report comes early on in section 1.2.5, with the statement that “Overall, our evidence suggests that actively managed investments do not outperform their benchmark after costs.”

This is an area where the FCA urgently need to clarify what this means for advisers. Since the paper was published we have been hearing advisers nervously question just how they can recommend active funds considering this statement.

Such an extreme reaction is exactly that, and would be hugely disruptive to the industry as a whole, but the Edition #12

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SOME PICS FROM OUR FEBRUARY TRANSPARENCY SYMP

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POSIUM:

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AND SOME MORE PICS FROM OUR FEBRUARY TRANSPARENC

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CY SYMPOSIUM:

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AND EVEN MORE PICS FROM OUR FEBRUARY TRANSPARENC

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CY SYMPOSIUM!

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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 6 teams, with each team having a particular area of focus.

All Teams seek to utilise the power of transparency to help bring about the change that is needed. All Teams ‘meet’ by way of a conference call, always on the first Tuesday of the month.

The six Teams are below, with the times of their calls (UK times): - Market Integrity Team; 9:00 - Foreign Exchange Team; 10:30 - Banking Team; 12:00 - Costs & Charges; 13:30 - Stewardship & Decision-Making; 15:00 - International Best Practice; 19:00 We are always seeking new Team members - please enquire through andy.agathangelou@transparencytaskforce.org The following tables show the make-up of the teams; those in bold are Team Leaders:

MARKET INTEGRITY TEAM First Name

Last Name

Job Title

Organisation

Country

David Gill

Stripp Cardy

Founder Insight Consultant (Wealth Management)

David Stripp Consulting Defaqto

UK UK

JB

Beckett

UK Lead

Association of Professsional Fund Investors

UK

Lesley

James

Director & Lead Financial Adviser

Simplified Money Ltd

UK

Stephen

Conley

Managing Director

Workplace Pensions Direct

UK

First Name Peter Xavier Andrew

44

FOREIGN EXCHANGE TEAM Last Name Egglestone Porterfield Woolmer

Job Title Director Head of Research CEO

Organisation BestX New Change FX New Change FX

Country UK France UK

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First Name Steve

Last Name Conley

Markus

BANKING TEAM Job Title Managing Director

Organisation Workplace Pensions Direct

Country UK

Krebsz

Interim Chief Risk Officer

UNECE GRM

UK

Alex

Letts

Founder

U

UK

Samuel

Ghann

CEO

Greater London Mutual

UK

Heather

Buchanan

Director of Policy & Strategy

APPG on Fair Business Banking

UK

COSTS & CHARGES TEAM

First Name Adam

Last Name French

Job Title Co-founder & Managing Director

Alan Andrew Andy

Browne CEO Evans Chief Executive Officer Agathangelou Founding Chair

Andy

Tarrant

Head of Policy & Government Relations

Angie

Kirkwood

Anna

Organisation Country Scalable Capital Limited UK MyFutureNow Smart Pension Transparency Task Force B&CE The People's Pension

Ireland UK UK

Senior Manager - Industry Development

Scottish Widows

UK

Tilba

Lecturer in Strategy & Corporate Governance

Newcastle University Business School

UK

Brendan Callum Chris

Mulkern Mayor Barrow

Consultant Consultant Head of Business Development

Pen Partnership Pen Partnership Scorpeo UK Ltd.

UK UK UK

Christopher Con Craig

Squirrel Keating Rimmer

Founder and CEO Head of Research Policy and Technical Specialist

Sciurus Analytics BrightonRock Group Pensions Advisory Service

UK UK UK

Daniel

Godfrey

Non-Executive Director

Big Issue Invest Fund Management

UK

Edward Elizabeth

Bushnell Campbell-Warner

Compliance Director Managing Director

Cavendish Medical Gabriel Research & Management

UK UK

Gayle Gerry

Schumacher Wright

Retired Partner

Former MD, Coutts Smith & Williamson Investment Management LLP

UK UK

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UK

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Graham Henrik

Cook Pedersen

Portfolio Solutions Managing Partner, Co-Founder

Macquarie Securities Clerus LLP

UK UK

Henry Iain

Tapper Cowell

Founder Head of Investment Solutions, UK & Ireland

Pension PlayPen Allianz Global Investors

UK UK

Imran

Razvi

Public Policy Advisor

The Investment Association

UK

James

Monk

Aon Employee Benefits

UK

James John John Julius

Singer Simmonds Serocold Pursaill

Head of DC Investments Senior Associate Principal Principal Independent Pension and Investment Governance Consultant

P-Solve CEM Benchmarking Inc Studio Serocold

UK UK UK UK

Lucy Malcolm

Forgie Small

Policy Adviser Managing Director

ABI Lynecombe Consultancy Ltd

UK UK

Margaret

Snowdon

Chairman

Pensions Administration Standards Association

UK

Mark Markus

Proffitt Krebsz

Scorpeo UK Ltd UNECE GRM

UK UK

Martin

Palmer

Head of Sales Interim Chief Risk Officer Head of Corporate Funds Proposition

Zurich Financial Services

UK

Michelle

Baddeley

Professor of Economics and Finance

University College London

UK

Mike Natalie

Webb Winterfrost

Consultant Chair/Client Director

City Noble CFA Society, UK/Aberdeen Asset Management

UK UK

Niall Nick

Ferguson Fleming

Principal Consultant Market Development Manager

Engaging Reward British Standards Institute

UK UK

Peter Philip Richard Robin

Eggleston Miller Metcalfe Powell

Founder

Editor

BestX Pensions Focus

The Evidence-Based Investor

UK UK UK UK

Ronnie

Morgan

Strategic Insight Manager

Royal London

UK

Sam Saul

Lusty Djanogly

CEO CEO

UK UK

Shaul

David

Fin Tech Sector Specialist

Byhiras Best Interest Consultants UKTI Financial Services Organisation

Shyam

Moorjani

Partner, Financial Services Consulting

RSM Tenon

UK

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UK

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Stephen

Bowles

Head of Institutional Defined Contributions

Schroders

UK

Stephen Terence Tim

Budge Prideaux Sharp

Principal  Economic and Social Affairs Department

Mercer  TUC

UK UK UK

Tim

Walton

Manager, Data Research and Analysis

Morningstar

UK

Tim

Brown

Head of Consultant Relations

Dimensional Fund Advisors

UK

William

Jenkins

Director, Co-Head Operational Due Diligence

Amundi

UK

Chris

Connelly

Lead Business Solutions Architect

Equiniti

UK

David

Rich

CEO

UK

Iain

Clacher

Jon

Parker

Associate Professor in Accounting & Finance Director

Accurate Data WServices Leeds University Business School Jonathan Parker Consulting Ltd

UK

Ralph Stewart

Frank Bevan

CEO DC (UK) Product Manager Benchmarking

Cardano KAS BANK

UK UK

Sunil JB

Chadda Beckett

Managing Director Consulting Chief Investment Officer and Author

Cairn Consulting Ltd New Fund Order Consulting

UK UK

UK

STEWARDSHIP & DECISION-MAKING TEAM

First Name Adrian

Last Name Jackson

Andy

Job Title Director of Business Development Agathangelou Founding Chair

Anna

Tilba

Lecturer in Strategy & Corporate Governance

Anna

Walton

Principal Consultant

Energised Environments Limited

UK

Con Henry Iain

Keating Tapper Clacher

Head of Research Founder Associate Professor in Accounting & Finance

BrightonRock Group Pension PlayPen Leeds University Business School

UK UK UK

Iuliia

Shpak

PhD Researcher in Finance/ Systematic Strategies

University of East London/Sarasin & Partners

UK

Edition #12

Organisation Pzena Investment Management Ltd Transparency Task Force Newcastle University Business School

Country UK

UK UK

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Jackie

Beard

Director of Manager Re- Morningstar Europe Ltd search Services EMEA

UK

James

Meenan

CEO

JNM Investment Governance

Ireland

John Joshua Judith Julia

Belgrove Card Donnelly Dreblow

Senior Partner Chief Executive Officer Partner Founder

Aon Hewitt Kukua Squire Patton Boggs sriServices and Fund EcoMarket

UK UK UK UK

Luke

Hildyard

Policy Lead - Stewardship and Corporate Governance

PLSA

UK

Markus

Krebsz

UNECE GRM

UK

Megan Michael

Clay Kemp

Interim Chief Risk Officer Pensions Lawyer Senior Pensions Technician

ClientEarth Pinsent Masons LLP

UK UK

Neil Nick

Latham Fleming

Consultant Market Development Manager

Independent British Standards Institute

UK UK

Paul

Lee

Head of Corporate Governance

Aberdeen Asset Management

UK

Paul Philip Rob

Marsland Brown Lake

Deputy Director Head of Policy Responsible Investment Advisor

High Pay Centre LV Rob Lake Advisors

UK UK UK

Sarah Saul

Hutchinson Djanogly

Consultant CEO

UK UK

Sebastian Steve Terry Tessa Tim

Reger Cave Ritchie Page Middleton

Partner Associate Director Development Director FIA, Principal Technical Consultant

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

Valborg Alan Barry David

Lie Salamon Mack Weeks

Director Managing Director Client Director Co-Chair

Borg Consulting Corpias Muse Advisory Association of Member Nominated Trustees (AMNT)

UK UK UK UK

Emma Henrik

Craig Pedersen

Marketing Specialist Managing Partner, Co-Founder

KAS BANK N.V. Clerus LLP

UK UK

Janice Mark

Lambert Miller

Pensions Consultant Employee Benefit Consultant

Independent Barclays Corporate & Employer Solutions

UK UK

Olivia

Seddon -Daines

Senior Research Analyst

ET Index

UK

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UK UK UK UK UK

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Paul

Hewitt

Senior Development Manager

Vigeo Eiris

UK

Rachel Sarah

Haworth Wilson

Policy Officer Chief Executive

ShareAction Manifest

UK UK

INTERNATIONAL BEST PRACTICE TEAM

First Name Aaron Alan Alex Andy

Last Name Bernstein Browne Mazer Agathangelou

Job Title Editor CEO Founding Partner Founding Chair

Organisation Global Proxywatch MyFutureNow Common Wealth Transparency Task Force

Country USA Ireland Canada UK

Anna

Tilba

Lecturer in Strategy & Corporate Governance

Newcastle University Business School

UK

Chris

Tobe

Investment Consultant

USA

Con Dana

Keating Muir

Head of Research Professor

David Drago Elias

Knox Indjic Westerdahl

Senior Partner

Sustainable Business Analyst

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

The Centre for Synchronous Leadership

Eric Eric Erik Francisco

Plunkett Veldpaus Conley Gomes

Owner Strategy Director Founder Professor of Finance

Frits

Meerdink

Manager Fund Management

Graham

Wrightson

Partner

Stephenson Harwood LLP

UK

Heinz-Dietrich

Steinmeyer

Professor of Law, Director of the Institute for Labour Law, Social Law and Business Law

University of Muenster

Germany

Henk Henrik

Lindner Wolff-Petersen

Policy Advisor Director and Co-Founder

Pensioen Federatie PandaConnect

Holland Denmark

James

Meenan

CEO

JNM Investment Governance

Ireland

Janice Jerry

Lambert Moriarty

Pensions Consultant CEO

Independent Irish Association of Pension Funds

UK Ireland

Johan John Jon

Hellman Belgrove Lukomnik

Chief Operating Officer Senior Partner Executive Director

ETFmatic Aon Hewitt IRCC Institute

UK UK USA

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Redbrucke Novarca Group ZenInvestor London Business School PGGM Investments

UK USA Australia

UK UK Holland USA UK Holland

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Jonathan

Hall

Head of Financial Services

Aquila

UK

Juan

Zuluaga

USA/Columbia

Kara

Tan Bhala

President and Founder

Seven Pillars Institute for Global Finance and Ethics

USA

Karen

Volpato

Senior Policy Advisor

Australia

Marcus Mikael Natalie Nicholas

Orione Nyman Smith Morris

Editor in Chief Pensions Lawyer Visiting Fellow

Australian Institute of Superannuation Trustees

Exakt Media ClientEarth The Martin School, Oxford

Nicolas

Firzli

Director-General

Nikki

Food and Health Research Manager

Oren Pablo

Gwilliam-Beeharee Kaplan Arellano Ortiz

Preston

World Pensions Council Vigeo

Brazil Sweden UK Australia France France

Co-Founder & CEO Profesor de Derecho del Trabajo y Seguridad Socia

SharingAlpha Pontificia Universidad Católica de Valparaí so

Israel Chile

McSwain

Managing Partner & Founder

Fiduciary Wealth Partners

USA

Richard

Field

Director

Institute for Financial Transparency

USA

Roland

Meerdter

Board Member

Association of Professional Fund Investors

USA

Rosalie

Degabriele

Academic Finance Superannuation & Banking

University of Technology

Australia

Sam Stefanie Stephen

Instone zu Dohna Davis

Chief Executive Officer Client Support Officer Associate Director and Senior Fellow

AES International Dubai ETFmatic UK USA Harvard Law School Programs on Corporate Governance and Institutional Investors

Steve

Kenzie

Executive Director

UN Global Compact Network UK

UK

Steve Suzanne SV Tomas

Cronin Shatto Rangan Wijffels

Founder Retail Investor Senior Executive Policy Advisor

Wise

AIG Federation of Dutch Pension Schemes

Dubai USA UK Holland

Will

Price

Senior Finance Sector Specialist, Finance & Markets Global Practice

The World Bank

USA

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Ian Paul

Fryer Secunda

Head of Research Professor of Law and Director, Labor and Employment Law Program

Chant West Marquette University Law School

Australia USA

CALL TO ACTION PLEASE! 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

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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

Here Is a great example...

Tom Tugendhat | “I believe there ought to be higher levels of transparency in finanMember of Parliament for cial services because it is the only way that markets can function Tonbridge and Malling without distortion to the benefit of the true customer, the individual.”

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

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Helena Morrissey Chair | The Investment Association

“I believe there ought to be higher levels of transparency in financial services because it’s the very starting point for establishing trust.’

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 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.”

Arno Kitts Founder & Chief Investment Officer | Perspective Investments

“I believe there ought to be higher levels of transparency in financial services because transparency supports trust, and trust is essential”.

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

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“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”.

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JB Beckett Author #NewFundOrder | New Fund Order, Assoc. of Professional Fund Investors Dan Norman CEO | TCF Investment

"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. Unless we put the City in order, technology will obsolete us, like Godzilla looming over us.”

“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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Helena Morrissey Chair | The Investment Association David Norman | CEO | TCF Investment

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

Julia Dreblow | Founding Dirctor | sri Services

“I believe there ought to be higher levels of transparency in financial services because it is the best way to make sure people get what they want.

It also enhances trust which is desperately low in our industry to the detriment of end users i.e. individual investors.”

Steve Conley | Managing Director | Workplace Pensions Direct

“I believe there ought to be higher levels of transparency in financial services because if we can trust the integrity of the industry, the financial health of market participants can actually be improved whilst at the same time the lives of the end consumer of our products and services are significantly enhanced.”

“I believe there ought to be higher levels of transparency in financial services because consumers deserve to know what they are getting for their money.”

kay Ingram | Director | LEBC

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“I believe there ought to be higher levels of transparency in financial services because it’s the very starting point for establishing trust.’

Bernard Casey | Principal Research Fellow | London School of Economics Nigel Sycamore | Director | Clear Workplace

“I believe there ought to be higher levels of transparency in financial services because investing is really only for sophisticated people and most people aren’t.”

Richard Hulbert | Insight Analyst | Defaqto

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

Patrick Norwood | Insight Analyst | Defaqto

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

“I believe there ought to be higher levels of transparency in financial services because our clients deserve it. It’s as simple as that.”

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Noel Whiteside | Professor Emeritus (retired) | University of Warwick

“I believe there ought to be higher levels of transparency in financial services because otherwise the personal responsibility for pension saving is impossible.”

Simeon Willis | Director | KPMG

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

David Norman | CEO | TCF Investment

“I believe there ought to be higher levels of transparency in financial services because its our money, you need to tell us what you are doing with it, clearly, honestly and openly.”

Sarah Young | MD | GSAV Limited

“I believe there ought to be higher levels of transparency in financial services because the retail consumer deserves better protection and the industry should know better!”

Campbell Edgar | Head of Financial Planning | CISI

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

Larry McLaughlin | CEO | GSAV Ltd

“I believe there ought to be higher levels of transparency in financial services because retail consumers are entitled to know what they are paying for, and to have greater transparency to protect their long-term interests and financial future against diminishing returns. Transparency in all aspects of the financial industry is integral to achieving consumer confidence and trust”.

“I believe there ought to be higher levels of transparency in financial services because life is complicated enough and members deserve better”

Darren Jefferson | Director | Alius Richard Ellis | Institutional Relationship Manager | Sarasin & Partners Your details here...

“I believe there ought to be higher levels of transparency in financial services because we believe there ought to be higher levels of transparency in financial services because savers / pensioners need to be properly informed about the products they invest in; they achieve the outcomes they expect; and to help build trust in the investment industry that is lacking at present.

“I believe there ought to be higher levels of transparency in financial services because.... Would you like your Transparency Statement to be included here?

Your details here...

“I believe there ought to be higher levels of transparency in financial services because.... Would you like your Transparency Statement to be included here?

Your details here...

“I believe there ought to be higher levels of transparency in financial services because.... Would you like your Transparency Statement to be included here?

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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.”

Sophia Morrell | “I believe there ought to be higher levels of transparency in Independent Media financial services because I’m passionately committed to a fair Consultant and functioning City which benefits everyone. We have a worldclass financial services industry in London and by working together, we can ensure it serves equal purpose and value to its participants and users.”

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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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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”.

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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”.

The Transparency Times | www.transparencytaskforce.org | April 2017 | Edition #12

Juan Zuluaga | Writer, InversionesSinllusiones. com

“I believe there ought to be higher levels of transparency in financial services because it will help us to see what can be done better” “I believe there ought to be higher levels of transparency in

Erik Conley | Founder, Zen Investor

Henry Taper | Director, First Actuarial & Founder, Pension PlayPen

financial services because, as Vanguard founder John Bogle says: ‘the tyranny of compounding costs takes about two-thirds of the gains clients make. The client puts up 100% of the capital, and takes 100% of the risk, but only gets one-third of the return.’

Something is very wrong with our financial system. Investors deserve to know exactly what they’re buying and how much it will cost, today and over time.”

“I believe there ought to be higher levels of transparency in financial services because people want to know what they’re buying. We cannot be trusted. Our system depends on trust and and fiduciaries managing our money. Until people consider themselves investing in a trustworthy way - we will remain untrusted. Transparency is the only way to break this vicious circle.

Clara Durodié | “I believe there ought to be higher levels of transparency Founding Partner, in financial services because trust is the birthplace of asset Cognitive Finance Group management” Richard Ellis | Institutional Relationship Manager, Sarasin & Partners

“I believe there ought to be higher levels of transparency in financial services because savers / pensioners need to be properly informed about the products they invest in; they achieve the outcomes they expect; and to help build trust in the investment industry that is lacking at present” Margaret Snowdon OBE “I believe there ought to be higher levels of transparency in Chairman, Pensions financial services because it is the best way we can restore public Administration Standards trust in pensions” Association Lesley James Director | Simplified Money

"I believe there ought to be higher levels of transparency in financial services because none of this is our money! How can we expect clients to have trust in our services if they cannot even be sure of the price?”

Robin O’Grady Head of Business Development | Hawksmoor Investment Management Mike Stafford CFP Director | Stafford Wealth Management

“I believe there ought to be higher levels of transparency in financial services because consumers & their advisers need to regain trust in a hugely competitive market and be certain of all the facts before being able to make informed choices.”

Edition #12

“I believe there ought to be higher levels of transparency in financial services because the more informed the client is the better decisions he/she can make. So for our part we are happy to display our charges on our website for both lifestyle financial planning and for regulated investment services.”

| April 2017 | 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 #12

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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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The Transparency Times | www.transparencytaskforce.org | April 2017 | Edition #12

Evolutions in Corporate Governance In a world where the implications and consequences of corporate actions and decisions are potentially far-reaching and lasting, ethical standards - their observance and their breach - must be part of the language of business conduct, whether in the context of corporate transgressions, regulatory effectiveness, terms of engagement between business and their stakeholders, or the metrics used by investors in assessing performance and risk and understanding long-term value.

This critically important book proposes a new paradigm for understanding, developing and maintaining standards of corporate governance. Meaningful change in behaviour will only come when there is a corporate governance framework that explicitly encompasses both law and ethics.

By Alison L. Dempsey. To find out more, visit: https://www.amazon.co.uk/Evolutions-Corporate-Governance-Framework-Business-x/dp/1906093865/ref=sr_1_1?ie=UTF8&qid=1490861955&sr=8-1&keywords=evolutions+in+corporate+governance

Index Funds: The 12-Step Recovery Program for Active Investors This book reveals the potential land mines and pitfalls of active investing and educates readers on the benefits of passive investing with index funds. Hebner’s book details the possible perils associated with stock picking, mutual fund manager picking, market timing, and other wealth depleting behaviors. This 12Step Program teaches the differences between active and passive investing, explains the emotional triggers that impact investment decisions, and offers an enlightening education on science-based investing that may forever change the way an investor perceives the stock market. Hebner sets forth a sound strategy that involves risk-appropriate investing that may empower investors to lead a more profitable and relaxed life.

T. Hebner. (Author), Harry M. Markowitz (Foreword)

By Mark To find out more, visit: https://www.amazon.co.uk/Index-Funds-12-Step-Recovery-Investors-ebook/dp/B00DG8UJAY/ref=sr_1_1?ie=UTF8&qid=1490862572&sr=8-1&keywords=index+funds%3A+the+12+step

ANATOMY OF A PENSION SCAM: Multi ÂŁ Billion Pension and Investment Scams (The Victims Strike Back) Time is running out for thousands of decent, hard-working British citizens who have already lost their pensions (and who are about to do so) at the hands of heartless scammers. The stress is literally killing these people as justice and protection elude both existing and future victims. Until the scammers are prosecuted and the loopholes closed, this will just keep happening. In the time it took to type this paragraph, at least one person has lost their pension.

by Angela Brooks. To find out more visit:

https://www.amazon.co.uk/dp/B06XKQQS92/ref=sr_1_1?s=digital-text&ie=UTF8&qid=1491978263&sr=1-1&keywords=anatomy+of+a+pension+scam

Edition #12

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RECOMMENDED READING CONTINUED Rethinking Reputational Risk A company’s reputation is one of its most valuable assets, and reputational risk is high on the agenda at board level and amongst regulators. Rethinking Reputational Risk explains the hidden factors which can both cause crises and tip an otherwise survivable crisis into a reputational disaster. It uses case studies such as BP’s Deepwater Horizon oil spill, Volkswagen’s emissions rigging scandal, Tesco, AIG, EADS Airbus A380, and Mid-Staffordshire NHS Hospital Trust. Reputations are lost when the perception of an organization is damaged by its behaviour not meeting stakeholder expectations.

Rethinking Reputational Risk lays bare the actions, inactions and local ‘states of normality’ that can lead to perception-changing consequences and gives readers the insight to recognize and respond to the risks to their reputations.

By Anthony Fitzsimmons & Prof Derek Atkins

https://www.amazon.com/Rethinking-Reputational-Risk-Business-Reputation/dp/0749477369

Other People’s Money The finance sector of Western economies is too large and attracts too many of the smartest college graduates. Financialization over the past three decades has created a structure that lacks resilience and supports absurd volumes of trading. The finance sector devotes too little attention to the search for new investment opportunities and the stewardship of existing ones, and far too much to secondary-market dealing in existing assets. Regulation has contributed more to the problems than the solutions.

By John Kay

https://www.amazon.com/Other-Peoples-Money-John-Kay/dp/1781254451/ref=sr_1_2?s=books&ie=UTF8&qid=1492767789&sr=1-2&keywords=Other+people’s+money%2C+John+Kay

The End of Alchemy: Money, Banking and the Future of the Global Economy The past twenty years saw unprecedented growth and stability followed by the worst financial crisis the industrialised world has ever witnessed. In the space of little more than a year what had been seen as the age of wisdom was viewed as the age of foolishness. Almost overnight, belief turned into incredulity.

Most accounts of the recent crisis focus on the symptoms and not the underlying causes of what went wrong. But those events, vivid though they remain in our memories, comprised only the latest in a long series of financial crises since our present system of commerce became the cornerstone of modern capitalism.

By Mervyn King https://www.amazon.co.uk/d/Books/End-Alchemy-Money-Banking-Future-Global-Economy/1408706113/ref=sr_1_1?ie=UTF8&qid=1492768315&sr=8-1&keywords=The+end+of+Alchemy%2C+Mervyn+King

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The Long and the Short of It: A guide to finance and investment for normally intelligent people who aren’t in the industry This book provides a guide to the complexities of modern finance. It describes the basics of investment and the sophisticated innovations of the modern financial system.

It explains how the follies of finance have threatened the stability of the world economy, and describes an environment that is complex and sophisticated, but greedy, cynical and self-interested. This book explains how to put your finances in the only hands you can confidently trust - your own. Readers will learn everything they need to be their own investment manager. They will recognise their investment options, the institutions that try to sell them, and how to distinguish between fact and fiction in what companies say.

By John Kay

https://www.amazon.co.uk/Long-Short-investment-normally-intelligent/dp/1781256756/ref=sr_1_1?ie=UTF8&qid=1492768642&sr=8-1&keywords=The+long+and+the+short+of+it%2C+John+Kay

HUGE thanks and congratulations to...

...for putting on a superb conference in Hong Kong (24th to 26th April), covering all the key issues impacting the Asian investment sector including the increasing importance of transparency. It’s been a highly enjoyable and extremely informative conference that I was delighted to attend and participate in. If you don’t yet know about the events run by FundForum you can check out the details of their Berlin conference taking place in June through this link.

Edition #12

| April 2017 | www.transparencytaskforce.org | The Transparency Times

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THE DIRECTORY OF PRO-TRANSPARENCY ORGANISATIONS If you lead a pro-transparency organisation speak out and advertise in The Directory of Pro-Transparency Organisations 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: andy.agathangelou@transparencytaskforce.org

FIDUCIARY MANAGERS:

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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 ÂŁ120bn.

AUTO ENROLMENT

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Steve Conley | Managing Director | Workplace Pensions Direct E-mail: Steve.conley@wpd.email Website: www.workplacepensionsdirect.co.uk Telephone: 0113 457 4563 Mobile: 07850 102070

Since 2015, Workplace Pensions Direct has made auto-enrolment simpler for small businesses, enabling employers to focus on running their companies without having to worry about pension law, and the cost of poor pension decisions. Workplace Pensions Direct offers an affordable, end-to-end, auto-enrolment solution that guarantees compliance with the law. With professional expertise, a century of payroll and pensions experience, and professional indemnity insurance - Workplace Pensions Direct has removed the worry and risk of autoenrolment for thousands of small businesses and their advisers.

SALES & MARKETING

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 | April 2017 | Edition #12

INVESTMENT MANAGEMENT:

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Robin O’Grady | Head of Business Development | Hawksmoor Investment Management E-mail: robin.ogrady@hawksmoorim.co.uk Website: www.hawksmoorim.co.uk Telephone: 01392 410180 Mobile: 07468 697900

Hawksmoor specialises in providing high quality discretionary investment management services for private clients including trusts, pension schemes and charities. We are a privately owned business with no ties to a bank or any other financial institution. Our experienced and well qualified team of investment professionals is focused solely on providing clients with the best service and consistently good performance.

NOT FOR PROFIT: Dr. Kara Tan Bhala | President & founder | Seven Pillars Institute for Global Finance and Ethics E-mail: kara@sevenpillarsinstitute.org Website: sevenpillarsinstitute.org Telephone: +1(785)865-8824 (mobile)

WEALTH MANAGEMENT:

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Seven Pillars Institute (SPI) for Global Finance and Ethics is an independent, nonprofit 501(c)(3), nonpartisan, organization whose mission is to highlight and analyze issues of moral philosophy in global financial markets with a view to enhancing ethical practice and policy.

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Arno Kitts | Founder & Chief Investment Officer | Perspective Investments E-mail: Arno.Kitts@PerspectiveInvestments.com Website: www.PerspectiveInvestments.com Telephone: +44 20 3290 6486

Perspective Investments is a multi-asset multi-strategy investment manager. We invest on behalf of our clients, including our founder family. Our commitment to our clients is to help them achieve their financial objectives. We do this by aiming to deliver higher returns with lower volatility and better capital preservation than conventional equity portfolios. Of course, while our investment performance track record is consistent with this aim, past investment performance is not necessarily predictive of future results.

Mike Stafford CFP | Director | Stafford Wealth Management E-mail: mas@staffordwealth.co.uk Website: www.staffordwealth.co.uk Telephone: 01992 501601

Stafford Wealth Management was formed in 1986 to provide bespoke lifestyle financial planning and investment services to private clients.

It is one of a small number of elite firms in the UK that is accredited by the Chartered Institute for Securities and Investment..

Stafford Wealth Management is authorised and regulated by the Financial Conduct Authority for investment business.

DATA SERVICES

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Larry McLaughlin, CEO | GSAV Ltd Email: larry.mclaughlin@gsav.io Website: www.gsav.io Phone: +44 203 655 2182 M: + 44 7771 978 118 US M: +1 646 946 5272

GSAV Ltd is Reg Tech/Fin Tech company exclusively serving the BuySide and delivering pricing solutions in the Collateral Lending Market to benefit Beneficial Owners and enable Managers to meet​their Fiduciary and Regulatory obligations. GSAVr is a specialist pricing, tracking and regulatory tool and provides an independent price for collateral lending transactions that defines rate and use in a manner that the Regulators feels meets the test of both price and use. GSAVr is the only solution available today that addresses the current challenges of any form of collateralized lending, full price discovery and full price transparency.

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

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.

Edition #12

| April 2017 | www.transparencytaskforce.org | The Transparency Times

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PENSION ADMINISTRATION:

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Margaret Snowdon OBE, Chairman | Pensions Administration Standards Association

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.

E-mail: info@pasa-uk.com Website: http://www.pasa-uk.com/ Mobile: 07983 565955

ACADEMIC INSTITUTIONS:

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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

FINANCIAL PLANNING: Mike Stafford CFP | Director | Stafford Wealth Management E-mail: mas@staffordwealth.co.uk Website: www.staffordwealth.co.uk Telephone: 01992 501601

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.

Is this also the right classification for you?

Stafford Wealth Management was formed in 1986 to provide bespoke lifestyle financial planning and investment services to private clients.

It is one of a small number of elite firms in the UK that is accredited by the Chartered Institute for Securities and Investment..

Stafford Wealth Management is authorised and regulated by the Financial Conduct Authority for investment business.

INVESTMENT CONSULTANTS Marcus Whitehead | Head of Investment Consulting | Partner | Barnett Waddingham E-mail: marcus.whitehead@barnett-waddingham.co.uk Website: https://www.barnett-waddingham.co.uk/ Telephone: 0333 11 11 222

Is this the right classification for you?

Barnett Waddingham has grown to become the UK’s largest independent provider of actuarial, administration and consultancy services. Our total headcount is now over 850 – with offices in seven locations around the UK. The investment consulting practice provides bespoke, independent investment advice to over 360 pension schemes with assets from the millions to billions. We continue to provide the personal, quality, tailored approach that has made us successful and has led to high levels of client retention.

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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INDEPENDENT TRUSTEES:

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The Transparency Times | www.transparencytaskforce.org | April 2017 | Edition #12

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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INVESTMENT CONSULTANTS:

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POLITICAL PARTIES:

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DATA SERVICES:

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ACTUARIES:

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PENSION SCHEME PROVIDERS:

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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:

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TRADE BODIES:

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CAMPAIGN GROUPS:

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PENSION SCHEME COST REDUCTION CONULTANTS

CONSULTING ACTUARIES: Edition #12

Right for you?

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| April 2017 | www.transparencytaskforce.org | The Transparency Times

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The Transparency Times | www.transparencytaskforce.org | April 2017 | Edition #12