Donny Hay discusses the impact and reasons for transparency on transaction costs
In line with the growing regulatory pressure on trustees and governance committees to deliver value for money for their members, the issue of cost transparency has been an area of increased focus for UK pension funds and their providers in 2017.
The FCA's Asset Management Market Study, which was published in June 2017, broadly criticised the investment industry for being uncompetitive and providing low levels of transparency. Since then, the FCA has established a working group tasked with standardising the disclosure of all costs and charges.
In parallel, the Local Government Pension Schemes launched a code of transparency in May 2017, outlining a standard method for all asset managers to report investment costs. In Europe, new regulations – in the form of MiFID II and PRIIPS – are increasing disclosure standards around investment costs from January 2018.
Why is this happening?
The FCA report highlighted uncompetitive pricing practices and opaque cost structures across the asset management industry, and announced its intention to address these shortcomings. Improving reporting standards is one strand of this process.
Auto enrolment has brought a greater fiduciary responsibility to workplace pensions, and the government is clearly keen to avoid any miss-selling scandals. Increased litigation in the USA around costs may also have heightened this fear, and the UK is therefore following Europe in terms of raising standards in this area.
Where is the spotlight falling and what is it going to reveal?
Since April 2015, trustees and independent governance committees of workplace pensions have been required to assess and report, through their Chair's Annual Statements, whether transaction costs and administration charges offer value for money. However, there was no corresponding imperative for asset managers to provide the transaction cost data required, nor a standardised calculation methodology, until the FCA ruled on this in September 2017.
Moving forward, investment firms managing funds on behalf of DC pension schemes must, from 3 January 2018, provide data on their funds' transaction costs, using the 'slippage cost' methodology. This is effectively a measure of the market impact – often referred to as the hidden costs – of buying and selling securities. Historically, this has been absorbed by the fund and not been reported separately.
The problem for asset managers is being able to accurately calculate and report transaction costs, and 'slippage costs' in particular. The challenge for trustees will be to interpret and assess this information, not least because of the variable results that are likely to arise from using the 'slippage cost' method.
These obstacles aside, the new disclosure standards will undoubtedly shine a light on many of the variable practices that exist in the asset management industry, ranging across the costs and revenues incurred in trading, such as broker commission and research, stock lending and box profits, to name a few.
What will be the likely outcome?
These new disclosure standards will help investors better understand the incidence and nature of transaction costs in their funds. It will also highlight the impact of higher portfolio turnover and poor capacity management – including in expensive asset classes – and point to the true cost of investing in popular multi-asset fund-of-fund structures.
Ultimately, it will show who pays for what. Competitive pressures will likely mean that fund costs will fall as managers cap fund expenses or pay more of these costs themselves, such as broker's research, for example. At the end of the day, while comparing a fund's net-of-fees performance to its investment benchmark is an appropriate long-term measure of success, over the short term investors also need to assess whether the costs they are paying represent good value for money.
Donny Hay, Client Director, PTL
