However the recent decision by HM Revenue & Customs that rebates will be taxed in the hands of investors has actually signalled the end of rebates in my view and I cannot see many, if any, platforms implementing unit rebates.
One platform has tested this with its adviser firms and the feedback is unanimous: the future lies in clean share classes and that unit rebates would cause mass confusion and potential capital gains tax liabilities on the end investor so therefore are not wanted. The de-minimis rule allowing cash rebates for distributions under £1, while welcome as it shows that the FCA does listen to the industry, will be redundant. I have always taken the view that rebates can, and do, lead to conflicts of interest and that clean share classes are in the best interests of investors and this paper will see that become reality. From a consumer point of view clean share classes are the only way to enable transparency.
The next topic is what payments from fund managers to platforms will be allowed? Some payments are still allowed including, for example, payments to pay for pricing errors. All of this seems reasonable but the one which is likely to be open to criticism and potential abuse is to allow payments for advertising. The FCA has said that it is aware of this potential abuse and that it expects such payments to be “reasonable and proportionate” or it will consider banning them. It is hard to see how a fund manager would pay more than what he sees as fair for a commercial return – at least until you get into the realms of guided architecture where the place on a best-buy list becomes (implicitly) dependent on payments for advertising. We will have to wait and see how this plays out.
