Transparency Times Edition #13 May 2017

May 2017

This very special edition is dedicated wholly and exclusively to the Transparency Task Force’s response to the Investment Association’s Draft Cost Disclosure Code.

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The Transparency Times | www.transparencytaskforce.org | May 2017 | Edition #13

This very special edition is dedicated wholly and exclusively to the Transparency Task Force’s response to the Investment Association’s Draft Cost Disclosure Code.

1. The purpose and status of this document This document has been put together by members of the Transparency Task Force (TTF) to provide comment on the Draft Cost Disclosure Code that has been produced by the Investment Association (IA).

The IA’s Draft Cost Disclosure Code has been of great interest to our community because the lack of transparency on costs and charges in investments is considered a major problem area, for all the reasons expressed by the Financial Conduct Authority (FCA) in their work on Transaction Costs in Workplace Pensions (CP 16/30) and their Asset Management Market Study.

2. About the Transparency Task Force

the benefit of the reputation of the sector. Fortunately, there are many individuals within the sector who are not only honest enough to admit that the status quo is far from satisfactory; they are also willing and able to put time and effort into finding solutions to known problems.

Trust needs to be earned but the financial services industry routinely fails to earn it. This is a systemic problem with far-reaching consequences for all societies and all governments around the world.

In under 2 years we have developed eight teams of volunteers, each team focused on a set of transparency-related issues and desired outcomes; and each working on a project that will help to make a positive difference:

The lack of transparency in financial services clearly contributes to this state of un-trustworthiness. By driving up transparency we will increase truthfulness; which in turn will improve trustworthiness.

Committed campaigners

Introduction The TTF is a 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 that deliver better value for money and better outcomes to the consumer.

Furthermore, because of the correlation between transparEdition #13

ency, truthfulness and trustworthiness, we expect our work will help to repair the self-inflicted reputational damage the Financial Services sector has suffered for decades. We seek to effect the change that the financial services sector needs and the consumer deserves.

We believe that those of us who care about the sector and the people it serves can, and should, work together to help put things right. Let’s stand up, not stand by; and let’s take heart from the famous quote by Margaret Mead: “Never doubt that a small group of thoughtful, committed citizens can change the world; indeed, it’s the only thing that ever has”.

Market reaction has been extremely responsive to our clarion call for collaboration for the benefit of the consumer and

· The Banking Team · The Market Integrity Team · The Foreign Exchange Team · The Costs & Charges Team · The Stewardship & Decision-Making Team · The International Best Practice Team · The Scams & Scandals Team · The PISCES Team The TTF Teams seek to operate in a collaborative, collegiate and consensus-building way; focusing on solutions not blame.

Free of commercial conflicts The TTF is free to consider

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sion & purpose’ about what needs to be done – such as ethically-minded financial services professionals, enlightened market participants, thought leaders, pro-consumer campaigners and leading academics;

what is ultimately best for the consumer without commercial conflicts and we are perhaps unique in being made up of a truly pan-industry cross-section of individuals that includes market participants, researchers, academics, legal professionals and those formally representing trade bodies and professional associations. As such we are well-placed to establish consensus that does not merely reflect the wishes of one particular “tribe” or another. As such we are able to work to one simple and straightforward guiding principle: ‘What’s best for the consumer?’

3. Should the IA be carrying out this work at all?

‘Sunlight is the best disinfectant’

This is a question of fundamental importance.

That beautifully simple phrase sums up what the TTF is all about. We believe that financial services market behaviour is improved when it is visible; and conversely, that behaviour happening ‘in the shadows’ tends to be at the expense of the consumer.

If you come at this question from the position of ‘What is the best way for the asset management industry to defend its commercial interests from the ever-strengthening demands for transparency on costs and charges?’ the answer is yes. In essence the IA’s Draft Disclosure Code could be perceived as a damage limitation exercise for the IA and its members.

This is because the financial services sector has been notoriously opportunistic with obfuscation and opacity; it has profited from things being kept hidden from the consumer; sometimes deliberately, sometimes not – things like the true costs of investing, the true performance of products and sometimes the true risks to the consumer of the products they buy.

This is having terrible consequences on two fronts: it completely undermines the efficient workings of the market and it also jeopardises social justice.

This is a state of affairs that must not be allowed to continue.

Our strategy for driving the change that is needed Our strategy for driving the change that is needed is to bring together two types of people: 1, Those with a sense of ‘pas-

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2, Those with the ‘power & position’ to make it happen – such as regulators, politicians, financial services leaders, trade bodies and professional associations.

But if you come at the issue from the position of ‘How can we provide investors with the best possible outcomes?’ the answer is ‘No’.

Why? – because the IA is a trade body. Understandably, trade bodies have a primary duty of care for the commercial interests of their members; they are clearly too conflicted to be responsible for the development of a costs disclosure code. The overall purpose of greater transparency on costs and charges is to improve the efficiency of the market and enable investors to get the best possible value for money.

As a trade body the IA works for its members, not for consumers; there is a seri-

ous conflict of interest as evidenced by the IA’s unwillingness to wholeheartedly support the idea of putting the investors’ interests first – an issue of such concern to the IA and its members that a clear majority of IA members were unwilling to sign up to a code that included the requirement to put the interests of the consumer first.

This is exactly the kind of behaviour that results in the Financial Services sector routinely being at the bottom of consumer trust ratings.

Furthermore, the reputational damage this kind of behaviour causes must contribute to the UK’s appallingly low savings ratio – just 3.8%, which is the worst it has been since 1963.

This is a huge problem for our economy and society as a whole today and it has the potential to drive serious social unrest in decades to come - a systemic risk that must not be ignored.

In short: · We do not think that the IA can objectively introduce a Code that binds the asset management industry.

· We do not support the FCA adopting the fund industry’s trade body code i.e. we reject that the IA Draft Code should be recognised in the FCA’s Rule Book.

· We encourage the FCA to issue its own draft code following consultation and the Asset Management Market Study.

We believe that it is far better if the sector as a whole works together to produce a ‘blanket’ solution that covers the entire value chain rather than a ‘patchwork quilt of protocols’.

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A market-wide framework that captures the entire value chain is necessary to prevent manipulation of charges from transparent to opaque parts of the value chain. Moreover, only a ‘blanket’ solution lends itself to efficient monitoring and regulation; otherwise there will be rampant regulatory arbitrage.’

There is much work to be done and it should all be properly conceived, initiated and led by the FCA; not a highly conflicted trade body. Turkeys don’t vote for Christmas.

Regulators are best placed to regulate and to lead the industry on behalf of consumers.

It is absolutely vital for the public to have confidence in the financial services sector and they are more likely to have confidence in the financial services sector if the sector’s Regulator leads activity and does not outsource key themes to trade bodies – it must not allow itself to be sold the idea that highly conflicted trade bodies might do their job for them.

The IA will always be pre-disposed to help show the asset management industry in a good light and to support the interests of the firms’ owners; that is why it exists. Given the motive of the shareholders of many asset managers, any disclosure activities which impact the profitability of industry participants, will be resisted by the organisations themselves; clearly creating a conflict of interest.

We only need to go back to last August to see how highly motivated the IA is to show its members in a good light. The TTF and many others were highly critical of research carried out by the IA that was published in August 2016. The ‘research’ attempted to suggest that there was no evidence of significant hidden costs damaging investor outcomes. The IA challenged the suspicion that funds carry hidden fees which hurt returns, claiming it had found ‘zero eviEdition #13

dence’ of such a trend.

The IA released a report announced by a press release entitled ‘Hidden fund fees: The Loch Ness monster of investments?’.

The Loch Ness monster theme ran through the rest of its press release, referring to ‘hidden-fees hysteria’ and suggesting ‘hidden fund fees’ may in reality be the ‘Loch Ness Monster of investments’.

However, this view was seen to be in direct conflict with mountains of highly respected academic research into the topic that had been built over decades and by numerous unconnected parties from all over the world. As a consequence, it is worth considering if the research and the churlish press release accompanying it seriously undermined the credibility of the IA and jeopardised good market relations.

In response to the mountains of well-founded and totally justified criticism from right across the industry, the IA stated that it was looking to ‘press the reset button’ after it had ‘inadvertently upset people’.

Even the IA’s own Independent Advisory Board on cost disclosure was unwilling to support the validity of the research; so much so that its Chair wrote a letter to the editors of several news publications stating that the Independent Advisory Board had not been consulted on the matter, and that it did not endorse the report. One headline read ‘Inhouse advisory board turns on IA over ‘Loch Ness’ costs report.’

Given this background and conflict of interest, our view is that the IA is the very least

suitable organisation to be entrusted with writing a costs disclosure code that has the potential to become part of the regulatory framework.

Similarly, the FCA should not allow other trade Bodies to write the costs disclosure rules for their aspect the market; they will be invariably conflicted for similar reasons to those given above and secondly, the fragmentation will result in inefficient practices.

We believe this ‘Patchwork Quilt’ approach will result in inconsistency, confusion and even the potential for ‘gaming’; issues so serious that they have the potential to undermine the efficacy of a robust regulatory framework and consumer confidence in the sector. The “Patchwork Quilt’ approach has the potential to become a systemic risk.

So while we believe it is critical that the IA’s draft code is NOT adopted as the rule book, we have answered the questions in an effort to make the draft code as good as it can be from an investors perspective whilst continuing to argue that it should be the FCA itself that leads regulatory and guidance activity in this space; and that they should look at the entire value chain, not just the asset management sector.

We believe this is the only way market confidence can be restored and we must not under-estimate the importance of general confidence in the market for investors, particularly pensions investors being automatically enrolled. The last thing the Government’s flagship pensions policy success needs is to have its success jeopardised by a collapse in confidence in pensions savings which would manifest in rocketing opt-out rates. The Government must not gamble with the success of automatic enrolment and must therefore insist that the FCA takes full responsibility for leading the development of a robust cost

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disclosure framework.

Unfortunately, it seems we could be heading for exactly the kind of ‘patchwork quilt of protocols’ that will result in weak, inconsistent and virtually unenforceable regulation that has prevailed for decades; unless of course the FCA conclude that it should not be the trade body to the asset management sector that writes the rules. Codes that do not have any data verification process, which are voluntary in nature and only address one part of the market are an invitation for the kind of “Regulatory Whack-A Mole”, “Gaming” and “Regulatory Arbitrage” that distorts an already distorted market. More ‘kicking the can down the road’, which is the last thing investors need.

Furthermore, it must be remembered that this is not the first time the IA has attempted to introduce a Disclosure Code.

Does the IA simply lack credibility in this space?

With all that in mind we will now turn attention to responding to the Draft Code itself.

4. Responses to specific questions asked Q1.

Will the information contained in the templates along with the associated disclosures in Part IV of the Code provide pension scheme trustees and IGCs with the cost information they need to facilitate ‘value for money’ judgements? · We do not think that the information contained in the templates is sufficient to provide pension scheme trustees and IGCs with the cost information they

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need to facilitate ‘value for money’ judgements.

· Our view is based on the fact that few costs are identified within the templates, with the majority of known costs left to be included in the three ‘other’ lines.

· This lack of prescription will lead to a lack of consistent disclosure as well as open the disclosures up to gaming.

· Trustees and IGCs will not be able to assess the nature of the services that are being paid for by the funds entrusted to their care nor will they be able to determine whether the aggregate represents value.

· The inclusion of implicit transaction costs in the overall transaction cost figures will serve to distort, and likely render meaningless, these aggregate numbers as there is no consistent definition of implicit transaction costs.

· We note that the IA intends to use the definition of implicit costs to be determined by regulators later this year. However, we strongly suggest that these implicit costs be separated from the other transaction costs so that a consistent assessment can be made of the transaction costs that

can be controlled.

· The templates also contain, in our opinion, too much non-core information. We propose that the data related to investment returns and investment activity be removed from the main template and be provided as supplementary information.

· The presence of these two sets of information serves to distract from the primary task at hand, namely the quantification of charges and transaction costs.

· The format of the disclosure templates themselves are potentially confusing. Is it the case that the use of templates is designed to be such that the segregated template is in monetary terms while the pooled fund template includes specific fields converting the percentage costs at fund level into monetary costs at client level?

Q2: Does the information in the Code provide MiFID distributors with the information they need to meet their cost disclosure obligations to clients? · This is not assured pending level 3 guidance for MiFID II and cannot be assumed or inferred.

Q3: Does the information in the Code provide PRIIP manufac-

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turers with the cost information necessary to create the KID? · This is not assured pending level 3 guidance for PRIIPs and cannot be assumed or inferred.

Q4.

Is the approach within the template proportionate?

Should there be further granularity in relation to asset classes and implicit costs? · The approach within the template is too high-level when it comes to fees, costs and charges. We feel that greater granularity is required in order to achieve consistent and relatively complete coverage.

· Leaving managers to capture most of the fees, costs and charges within the three ‘other’ categorisations creates the opportunity for the template to be gamed and for the end result to be inconsistent across managers.

· Any fees and/or costs that are explicitly deducted should be explicitly disclosed. · An insight into the number of fees not clearly and/or explicitly mentioned can be gained looking at the management fees section for segregated funds. It is not clear what ‘invoiced fees’ covers – is this the managers’ fee or more?

· Potential fees that do Edition #13

not seem to be explicitly mentioned on the template include: portfolio valuation, fund accounting, audit, performance reporting, monitoring for corporate actions, engagement and proxy voting services, bank account, credit facility, fees on committed but not drawn capital, own research (as distinct from payment to third parties for research), conferences, administration, benchmark licensing and prime brokerage to name a few. It is difficult to ascertain how complete the proposed template is and we therefore suggest the Code includes a list of all costs and charges that it does not include.

· We recognise that a complication is that some charges are paid at a business level (say between asset manager, ACD, custodian and counterparties) which may cover a number of funds, general business, rather than be deducted accurately and explicitly from each fund. Currently it is difficult to identify which costs are levied and reported against a firm’s balance sheet, which against the fund and which are internally charged by the firm to the fund.

· The lists of potential fees, costs and charges not detailed is even more extensive for transaction costs and auxiliary services.

· The template currently explicitly excludes hedge

funds and private equity yet many institutional, and some individual, investors invest in these categories. Consequently, we propose that the template be extended to cover these categories, and their related charges, too. There are other fee disclosure initiatives related to these categories that the IA might want to co-ordinate with, for example the ILPA reporting template for private equity, to ensure the creation of a single, consistent template.

Q6.

Are there specific areas of cost disclosure that require additional consideration? · We propose that implicit transaction costs be separated into its own section of the template. This separation will allow the balance of the figures to be used for comparison without the distortion of implicit transaction costs.

· Similarly, any items required by one (regulatory) body/region but not others can then be easily added for the purposes of that comparison without disturbing the core disclosures. · All forms of trading costs, slippage costs and derivative costs need to be properly accounted for Q7.

What would be the framework for ongoing development and maintenance of the Code?

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· We feel the any costs disclosure code needs to be conceived, initiated and owned by regulators rather than industry participants. Market participants can, and should provide input into the regulator’s work.

· The nature of the disclosures contained in the code impacts the profitability of industry participants, creating a conflict of interest.

· The cost disclosures are intended to protect investors from detriment and should, consequently, be the property of bodies charged to protect investors.

· The levels of distrust towards the Asset Management industry are simply too high for the market to have confidence in entrusting such work to a conflicted trade body (See the FCA’s Asset Management Market Study for many reasons why trust in the sector has been undermined).

5. Other reasons why this Draft Code should be rejected 1. It is absolutely vital that the interests of Retail Investors are properly protected as well as Institutional but the IA’s Code does not look after the interests of Retail Investors. Failure to do so will seriously undermine consumer

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confidence even further. This is a major flaw in the Code that will create Regulatory Arbitrage and distort an already distorted market even further.

2. We are concerned that the IA’s proposal of oversight is tantamount to self-regulation: “During the consultation period, the IA will also be discussing with regulators and the Advisory Board how to put in place an ongoing governance structure that allows industry, client groups and regulators to monitor its success and identify areas for further evolution over time. The IA would welcome feedback on this as part of the consultation.”

3. P18: The proposed methodology would need to ensure both the turnover costs of underlying assets and of the fund of funds structures would need to be captured rather than simply aggregating the underlying fund turnover costs. “Fund of funds: transaction costs and Portfolio Turnover Rate (PTR). Aggregate reporting will pick up all transaction costs in a given strategy.”

4. We disagree that transactions cost should be viewed differently to other costs, whilst variable they are a reduction on the net return to the investor albeit deducted before the Net Asset Value of the fund is priced. “Unlike charges, transaction costs should

always be viewed in the context of the return they generate and the investment approach followed.

Transaction costs do not have a linear relationship to overall return as the OCF does. Two fund managers could incur considerably different transaction costs, but deliver the same return before fees. The level of the charge will determine the net outcome.” The impact of trading is frequency multiplied by the size and riskiness of each trade.

5. As many fund managers including passives may have proprietary trading versus those who use brokers or dark liquidity pools and MTFs then an investor will find it difficult to discern trading cost from portfolio management. We suggest an encompassing figure is needed. One that removes offsetting income such as stock lending, selling research and Reverse Repo actions

6. We disagree with this statement as while implicit costs are variable and difficult to identify, they are certain. “Implicit costs, on the other hand, cover a variety of impacts, not all of which are measureable with any high degree of certainty.”

7. We disagree with this definition since most trades are identifiable on an order driven system like SETS and centrally cleared, even if the identity of respective parties are not necessarily disclosed. “Implicit costs are

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those that do not result from any fees being paid as a separately identifiable amount by one party to another.”

8. ‘Table 1: Main costs of trading’: We note that earnings from stock lending operations, not passed to the investor is not specifically noted. We believe any retained revenue is a net charge to the investor.

9. We generally agree with the data points listed but welcome the inclusion of other data points identified. E.g. Costs relating to transfer agency and in-specie transfers.

10. Segregated Mandate and Pooled Fund template, we seek clarification that any reduction in Gross Income from Stock-lending is captured as a cost to the end Investor; rather than Net Income offsetting costs. This would appear consistent with the IA’s statement on page 49 “Any earnings from securities-lending (more generally any efficient portfolio management technique) not paid to a unit-linked fund is to be treated as a cost and disclosed as such; as should any other payments to securities lending agents.”

11. There is a risk that the IA Code undershoots the final Template used for MiFID II / PRIIPs etc. This is serious a risk and generally an unwelcome outcome so consideration needs to Edition #13

the data. This is a major failing of the Code that will lead to inconsistency, confusion and ‘gaming of the system’.

be given to whether the IA template is sufficiently defined to captures all relevant costs. The final code must be fully MiFID II and PRIIPS compliant.

17. In section “Granularity of Reporting”: “Areas of cost that may be outside mainstream services” We disagree that any costs are identified purely as ‘other costs’ and believe there should be a standard template for each asset class if necessary so cost categories exclusive to any asset type can be catered for as standard. This is a major failing of the Code that will lead to inconsistency, confusion and ‘gaming of the system’.

12. PTR calculation - typically assumes half purchases & sales. Every transaction incurs a cost on both sides of the trade. The model shown is inadequate and there are better approaches to determining PTR.

13. Costs for pooled funds are based on percentage at fund level. Share class level may identify variances (higher and lower) and we suggest reported figures should be in monetary amounts.

We suggest the Fund Manager should present the cost specific to the share class and note the highest cost share class.

14. The Code lacks an explicit library of costs captured. Some cost items are in scope but apply to areas such as private equity and hedge funds (which are not in scope).

15. Definitions section: the definitions are not sufficiently comprehensive and lack legal precision. This is a major failing of the Code that will lead to inconsistency, confusion and ‘gaming of the system’.

16. There is no control framework in place to validate the quality of

6. Comments on the Independent Advisory Board Background

As explained, we do not agree that the IA should be producing a Disclosure Code. Not only has that point been made in this Consultation Response it was also made to the IA at a meeting on 19th April 2016, when the TTF argued that rather than the IA developing its own Code for its members and its part of the market, the IA should instead work collaboratively with all interested stakeholders, to create a comprehensive solution for the industry as a whole.

Unfortunately, the IA decided against a truly collaborative, pan-market approach and decided to push forward with its own Code. The IA then invited the TTF to be on its Independent Advisory Board on Costs

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Disclosure. The decision to be involved, or not, wasn’t straightforward. On the basis that the IA were to be pushing ahead with the development of a unilateral Code for their members anyway, it was decided on balance that, subject to reassurances, it made sense for the TTF to be represented on the Independent Advisory Board with a view to positively influencing the outcome as best as possible on behalf of the end-investor.

The TTF were reassured that the Independent Advisory Board would provide truly independent oversight of the development of the Disclosure Code and that the whole exercise was not merely just part of a PR exercise for the IA. At no time in making the decision to be involved were the TTF made aware that the Advisory Board would operate ‘in secret’.

Off to a bad start On the morning of Monday 4th July the IA informed the TTF that the work of the Independent Advisory Board would operate without members of the Advisory Board being able to comment on developments until after the Draft Disclosure Code had been published, i.e. that its meetings would be ‘closed’. Note, it was the IA and not the Chair of the Advisory Board that stated the proceedings would take place on a completely closed basis.

That decision was relayed by telephone call between the IA and the TTF just minutes before the start of the first meeting, well after the TTF had accepted the invitation to be involved.

That was a particularly difficult telephone conversation as much of it was spent discussing the fact that the IA were very unhappy with an article that had been published by the Financial Times (FT) the preceding Friday, on 1st July. The title of the FT article being discussed was: Fund

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chiefs ‘seek meal expenses from pension savers’.

The FT’s article had been written as a result of the publication by the TTF of its research on costs and charges on 1st July. That research was presented at a meeting to numerous industry bodies, journalists, market participants and various Regulatory officials.

The IA had been in dialogue with the FT prior to the FT’s article being published on the Friday evening ahead of the article being published online. The IA were unhappy about the FT’s planned article, claiming that it was inaccurate, sensationalist and damaging. Our understanding is that the IA were encouraging the FT to change the article prior to it appearing in print the next day. The FT, however, concluded that the article was factually correct and would be publish it regardless of how the IA felt about it, because it was factually correct.

Similarly, the TTF’s view was that if the proposed article was factually correct it should not be altered regardless of whether the IA found it unhelpful; that was the thrust of the TTF’s comments to the IA the following Monday, minutes ahead of the first meeting of the Advisory Board.

The decision that the Independent Advisory Board on Costs Disclosure be made to operate without disclosing its activity until after the Draft Code had been published may, or may not have been connected in some way to the FT’s Fund chiefs ‘seek meal expenses from pension savers’ article; for it is perfectly possible that the timing of the two developments were completely coincidental.

Given the very nature and purpose of the TTF, it was then profoundly bizarre to be involved with an Independent Adviso-

ry Board on Costs Disclosure without being allowed to disclose any of its activity; the situation couldn’t really be more ironic.

Unsurprisingly, some within the TTF felt that the best thing to do would be to leave the Advisory Board and that certainly would have been the easiest thing to do, for sure. So, another difficult decision was to be made, and one that on balance concluded with the idea that if the TTF were not involved it could not have any influence for the benefit of the consumer; nor could it eventually report on the workings of the Independent Advisory Board, for the sake of transparency.

To make matters worse, various articles appeared in the press that seemed to indicate that the Independent Advisory Board members including the TTF had in some way been involved with the decision to hold meetings in secret i.e. as if some inclusive, consultative process had been followed; but that was not the case at all. In fact, it seems as though the non-disclosure decision had been made following discussions between the IA itself and either just the Chair of the Independent Advisory Board or the Chair of the Independent Advisory Board plus a very small number of Independent Advisory Board members. One thing is for certain - the TTF had not been party to any such discussion and were wholly against the idea of meetings being held in secret.

The decision had been made; and was presented to the TTF as a fait accompli.

Interestingly, the TTF had to stop a misleading letter being sent to Professional Pensions on the ‘secret meetings’ matter; the original version of that letter (from the Chair of the Advisory Board but who was writing in his capacity as the Chief Investment officer at NEST as opposed to his capacity as Chair of the Independent Advisory Board) to Professional Pensions in-

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ferred that all members of the Advisory Board had agreed to holding closed meetings, which was not the case at all and had it been published would have perpetuated the misunderstanding that was developing in the market that the TTF had willingly agreed to ‘secret meetings’.

That misunderstanding was undermining the integrity of the TTF and causing a totally unfair but completely understandable backlash against it. Fortunately, when challenged, The Chair of the Independent Advisory Board agreed to correct the misleading point that he would have otherwise made; the final version of the letter to Professional Pensions showed that it was only the Chair of the Independent Advisory Board who had been involved with the ‘meetings in secret’ decision and not the other members of the Independent Advisory Board.

From bad to worse In general terms, the TTF’s experience of the Independent Advisory Board thus far has been wholly unsatisfactory and extremely disappointing.

In our view it would have been better if: 1. The Independent Advisory Board had operated as if it were fully independent

2. The meetings had not been held on a closed basis

3. The first draft of the Terms of Reference for the Independent Advisory Board had not been written by the IA

4. The Terms of Reference had been far more robust Edition #13

and challenging; i.e. more in line with what the IA’s publicity about the Independent Advisory Board had conveyed. For example, despite being pressed on the matter extensively by the TTF, the Chair of the Advisory Board rejected the inclusion of the phrase ‘fully comprehensive costs disclosure’ being included in the Terms of Reference, despite the fact that the IA’s own publicity about the Advisory Board had inferred that the Independent Advisory Board would be looking to ensure fully comprehensive and complete costs disclosure by asset managers. The relevent parts of the 4th July press release about the Independent Advisory Board issued by the IA are:

…The Board will ensure the project delivers on its aim to create a standardised, fully Comprehensive Disclosure Code for asset managers to disclose investment costs. …Mark Fawcett, Chair of the Disclosure Code Advisory Board, said: “This initiative has the potential to help the investment and pension industry take significant steps towards greater transparency of investment transaction costs.

“It’s vital that as an industry we’re able to create a consistent disclosure framework if we’re to make progress reaching this goal. “I look forward to collaborating with a talented team to shape a comprehensive disclosure code.” …Jonathan Lipkin, Director of Public Policy at the Investment Association, said: “In line

with previous commitments, we are building a framework that can provide consistent and complete information about charges and transaction costs…

5. Similarly, it would have been better if the Terms of Reference required the disclosure of any actual or potential conflicts of interest amongst Independent Advisory Board members (another suggestion by the TTF that was rejected).

6. The minutes of the Independent Advisory Board meetings had been written up by the Independent Advisory Board, not the IA

7. The minutes of the Advisory Board meetings had been produced in a timely manner, because there was often an unsatisfactory interval between meetings and when the first draft of the minutes were produced by the IA – several weeks in some cases. This made it difficult to verify whether the minutes were accurate; and that’s particularly problematic if ever there was disagreement about whether the minutes reflected what actually occurred in meetings

8. The IA had not acted as secretariat to the Independent Advisory Board

9. The Independent Advisory Board and/or the

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IA properly publicised the fact that minutes of the meetings were being published; especially as it had been a hardfought concession to gain agreement for the minutes to be published; as had been the decision to publish the Terms of Reference itself

10. The Independent Advisory Board had ensured that the IA’s Draft Code looked after the needs of retail consumers. It is a major flaw that is does not.

11. The Advisory Board had agreed to allow known costs and charges experts who were not on the Advisory Board to be seconded on to it for their valuable expert input.

The TTF established that key individuals with a wealth of knowledge and experience on costs and charges (some of whom had been campaigning for greater transparency on costs & charges for approaching ten years) were willing to provide their input at no cost. But, despite being pressed to make use of this obviously useful resource the suggestion was repeatedly rejected.

12. The Independent Advisory Board had made an appropriately critical comment about the IA’s ‘Loch Ness Monster’ research in its own Report on the process that led up to the publication of the Draft Code (a Report that the TTF decided it could not endorse), despite the fact that the

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Independent Advisory Board had decided it would not endorse the ‘Loch Ness Monster’ research and despite the fact that the Chair of the Independent Advisory Board had publicly commented that the Independent Advisory Board would ‘not pull its punches’ when producing its Report

13. The IA had made a public apology to costs transparency campaigners about the infamous ‘Loch Ness Monster’ research. They were asked to make a public apology (by the TTF) because the IA’s press release suggested that people looking for hidden fees were foolish. The IA chose not to make a public apology, which turned an already awkward relationship between the IA and the TTF into a very awkward relationship between the IA and the TTF

14. The TTF had been allowed to liaise with more than just 6 of its members when seeking opinion and input on the Disclosure Code; and if those individuals had not been forbidden to speak to any other party about what they were told outside that group of 6. Given the fact that the whole exercise was about the development of a disclosure framework the amount of secrecy and general lack of openness and transparency being displayed was simply absurd.

15. Meetings of the Advisory

Board were planned well ahead. Because they weren’t, many individuals were unable to attend all the meetings; even the Chair of the Advisory Board was unable to attend two of his own meetings.

16. The Advisory Board had been able to consider more than just one proposal for the Disclosure Code. The expectation had been set that we would be free to consider several approaches but in the end we were just asked to provide comment on what was essentially the LGPS Code.

17. The IA had not responded in a defensive manner when challenged; for example, when challenged on whether the Draft Code was actually as fully comprehensive as it was described to be

18. The Independent Advisory Board had pressed for the IA to include a list of all the costs and charges not covered by the Code within the Code.

19. The IA had answered all questions put to it. For example, the IA failed to answer questions (despite being chased in writing on numerous occasions) on whether

any communication between Advisory Board members that excluded members of the IA had been shared with the IA; and also which

The Transparency Times | www.transparencytaskforce.org | May 2017 | Edition #13

member of the Advisory Board had allegedly (according to the IA) briefed the FT ahead of the FT publishing their Fund chiefs ‘seek meal expenses from pension savers’ article; and also whether the Independent Advisory Board was actually independent

20. The Advisory Board had properly concluded discussions on the question ‘what is the true purpose of the Advisory Board?’

This so-called ‘existential’ issue had been discussed at length but not concluded. In fact, during those discussions one member of the Advisory Board (not representing the TTF by the way) had even mentioned the possibility that that perhaps the real purpose of the Advisory Board was to ‘give the IA air cover for when the Draft Code is published’.

7. Conclusion The Transparency Task Force is a collaborative, campaigning community dedicated to driving up the levels of transparency in financial services. We believe that greater levels of transparen-

Edition #13

cy are a pre-requisite for fairer, safer and more efficient markets that will deliver better outcomes and better value for consumers.

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

Our conclusion is that the IA cannot objectively introduce a Costs Disclosure Code.

We do not support the FCA adopting the fund industry’s trade body code i.e. we reject that the IA Draft Code should be recognised in the FCA’s Rule Book.

shortcomings of the Independent Advisory Board as we see them are all taken in the spirit in which they are meant – fair, reasoned and balanced constructive criticisms intended to encourage the IA and the Independent Advisory Board to raise their game.

(E&OE) All enquiries please to: Andy Agathangelou, Founding Chair, the Transparency Task Force andy.agathangelou@transparencytaskforce.org +44 (0) 7501 460308

We encourage the FCA to issue its own draft code following industry-wide consultation and the Asset Management Market Study.

We believe that the Independent Advisory Board has failed to perform adequately as an independent Advisory Board. As a consequence, a golden opportunity has been missed to help rebuild trust and credibility for the asset management sector, which is so desperately needed.

Our firmly held belief is that ‘sunlight is the best disinfectant’ and as such we hope that this response to the IA’s Draft Code and our observations about the

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

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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 monthly conference calls, get in touch if you want to be included in the call..

- Banking Team: For those that want to drive up the transparency and professionalism in the banking sector - Foreign Exchange Team: 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: 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: 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 right across the value chain - Stewardship & Decision-Making Team: If you understand the ‘a symmetry of information’ problem that the sector is dogged by join this Team to help eliminate the opacity and obfuscation that prevents good outcomes - Scams & Scandals Team: Join this Team if you want to raise awareness of the scams and scandals going on that are cheating people out of their savings, investments and pension funds. Please help, it’s an important battle - International Best Practice Team; we have members from every continent. This Team will appeal if you want to help develop the Global Transparency Index!

- PISCES Team (Purpose, Impact Investing, Sustainability, Corporate Social Responsibility, Environmental Social & Governance, Socially Responsible Investing) 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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GENERAL INFORMATION:

Is brought to you FREE by: Dan Agathangelou

Events, Marketing and Production Manager Transparency Task Force

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Assistant to The Events, Marketing and Production Manager; Cheeef Prooof Reeeder!

Transparency Task Force

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To submit an article, request an advertising rate card, provide feedback or for any general enquiry please get in touch through:andy.agathangelou@transparencytaskforce.org or +44 (0) 7501 460308 Transparency Task Force Ltd, Registered in England, Company No. 09698368

If you want to download a PDF of the Transparency Times here’s what to do: 1. Click on the link to it, which will take you to a view of the front page 2. See the icon close to the top left of the front page that looks like this: 3. Click on that icon, and then select the Download option.

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

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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

Edition #13

“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

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

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

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.”

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“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...

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“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?

The Transparency Times | www.transparencytaskforce.org | May 2017 | Edition #13

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”.

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”.

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Juan Zuluaga | Writer, InversionesSinllusiones. com Erik Conley | Founder, Zen Investor

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

“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

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.”

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“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.”

The Transparency Times | www.transparencytaskforce.org | May 2017 | Edition #13

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 Edition #13

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RECOMMENDED READING CONTINUED “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

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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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RECOMMENDED READING CONTINUED

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

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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

Phishing for Phools: The Economics of Manipulation and Deception Ever since Adam Smith, the central teaching of economics has been that free markets provide us with material well-being, as if by an invisible hand. In Phishing for Phools, Nobel Prize-winning economists George Akerlof and Robert Shiller deliver a fundamental challenge to this insight, arguing that markets harm as well as help us. As long as there is profit to be made, sellers will systematically exploit our psychological weaknesses and our ignorance through manipulation and deception. Rather than being essentially benign and always creating the greater good, markets are inherently filled with tricks and traps and will “phish” us as “phools.”

By George A. Akerlof (Author), Robert J. Shiller (Author), Bronson Pinchot (Reader) https://www.amazon.com/Phishing-Phools-Economics-Manipulation-Deception/dp/1522635009

Upcoming Event: Mini-conference: “Towards Smarter Regulation through building Trust” 13 June pm – London “An economy that works for everyone is one where everyone plays by the same rules.”

Theresa May, Prime Minister, 5th May 2016 Professor Christopher Hodges, author of Law and Corporate Behaviour, gives the keynote showing the limitations of incentives and deterrence, and setting out the need for Ethical Business Regulation drawing on behavioural economics. A panel of experts discuss promoting institutions that build trust and there

will be breakout group presentations and discussions on case studies in water, food and finance sectors.

See here for more information and to book -- http://bit.ly/2nVYqPR.

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The Transparency Times | www.transparencytaskforce.org | May 2017 | Edition #13

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.

Edition #13

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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 £120bn.

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.

Gavin Perera-Betts | Chief customer officer | NEST E-Mail: Gavin.Perera-Betts@nestcorporation.org.uk Website: www.nestpensions.org.uk Telephone: 020 3056 3719

NEST places a high value on transparency and we publish our costs and charges on our website. We believe the most important purpose of clarity and transparency around costs is for scheme trustees and governance bodies to be able to understand the costs they’re taking on and ensure they’re getting best value for members. This due diligence must be done and be seen to be done by those who’re acting in members’ interests. It mustn’t fall to members to have to interrogate large amounts of complex data, which is unlikely to lead to better decision making and outcomes.

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 | May 2017 | Edition #13

INVESTMENT MANAGEMENT:

Is this also the right classification for you?

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:

Is this also the right classification for you?

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.

Is this also the right classification for you?

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

Is this also the right classification for you?

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.

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PENSION ADMINISTRATION:

Is this also the right classification for you?

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:

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.

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

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

Communications Consultant: Lesley Alexander | Managing Director | Ferrier Pearce E-mail: hello@ferrierpearce.com Website: www.ferrierpearce.com Telephone: 020 3772 5360

clas-

SALES

sification for you?

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

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.

Is this the right classification for you?

Transparency - clarity, straightforwardness, honesty. As communications consultants, we support transparency in financial products, especially long-term savings. This applies not just to charges, but to the way we describe the products and their benefits to consumers.

We believe the language we use should be clear, unambiguous and direct, helping people to make the most out of their money.

& MARKETING

Is this also the right

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The Transparency Times | www.transparencytaskforce.org | May 2017 | Edition #13

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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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:

Is this the right classification for you?

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: Edition #13

Right for you?

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

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BANKS:

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:

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Is this the right classification for you?

The Transparency Times | www.transparencytaskforce.org | May 2017 | Edition #13

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