Mifid II  

What advisers should have learned about Mifid II so far

  • Identify the main objectives of Mifid II
  • Describe how portfolio reporting works
  • Identify what advisers should be doing on fee disclosure
CPD
Approx.30min

I think there was some initial confusion around the ongoing charge figure (OCF) including or excluding transaction costs. 

I hope this confusion has now gone away. All should be clear that the OCF does not include transaction costs and that both need to be provided to clients.

With that clarified, the additional confusion of negative transaction costs has needed some work, when it comes to communicating with clients. 

How can a fund have negative transaction costs of say, 1 per cent?

I won’t patronise readers by going through the detail but it’s all to do with ‘slippage’ costs (another new bit of jargon) and the process a fund managers goes through in pricing trades. 

The movement of the price during the trade can result in positive or negative slippage costs. 

As a part of this process, we also get introduced to different pricing methods (more jargon coming up) including ‘arrival’, ‘opening’ and ‘closing’ pricing methods.

Client disclosure

So, where are we today in terms of what needs to be disclosed to clients?  

I’ll end this piece with a brief summary of what advisers need to be telling clients and should have been doing since the beginning of 2018, although virtually no one was.

Pre-sale reporting:

  • Product (fund), service (DFM, Platform, Isa) and adviser costs need to be aggregated in annualised percentage terms as well as pounds and pence, based upon the proposed investment
  • Cost and charging information needs to be given to the client in ‘good time’ before they provide the relevant service to the client
  • One-off costs (entry and/or exit, for example)
  • Ongoing costs (OCF)
  • Transaction costs
  • Incidental costs, including performance fees
  • Total fees related to funds should be quoted as ‘estimated’ (ex-ante) and include:
  • If more than one fund is being recommended then the above fees should be provided at both an individual fund level and aggregated to illustrate the total recommendation.

Post-sale reporting:

Ongoing reporting is a bit more detailed, as one might expect, and should cover the following:

  • The total fees should be reported once per annum
  • The fees are those detailed as part of the pre-sale reporting, based on a client’s portfolio, on an ‘actual’ (ex-post) basis
  • These should be provided in percentage terms as well as pounds and pence
  • Reports can be sent to all clients at the same time ‘bulk’ or on an individual basis
  • There's a requirement to report a 10 per cent drop in performance and multiples of 10 per cent in the quarterly reporting period by end of the business day - only for discretionary portfolios

Looking ahead, it is by no means clear as to our ongoing adherence to EU regulation once we actually depart the Union. 

But UK financial services regulators have clearly stated that there will be no immediate disruption and no thought of tearing up the current directives and replacing them with something else, anytime soon.  

For an industry that often feels under constant regulatory bombardment, this is probably good news – a little bit of breathing space for us all to get comfortable with Mifid II and all that it demands.

Mifid III anyone?

Paul Tinkler is insight development manager at Defaqto

CPD
Approx.30min

Please answer the six multiple choice questions below in order to bank your CPD. Multiple attempts are available until all questions are correctly answered.

  1. What was the aim of Mifid I?

  2. Pick the odd one out. Mifid II focuses on the following European Commission objectives:

  3. Which product does Mifid II not apply to?

  4. True or false, product (fund), service (DFM, platform, Isa) and adviser costs need to be aggregated in annualised percentage terms as well as pounds and pence, based upon the proposed investment?

  5. Does OCF include transaction costs?

  6. According to Paul Tinkler, why does he believe that platforms are the only ones who have the capability to effectively and efficiently produce the required reporting if a managed portfolio falls?

Nearly There…

You have successfully answered all the questions correctly, well done!

You should now know…

  • Identify the main objectives of Mifid II
  • Describe how portfolio reporting works
  • Identify what advisers should be doing on fee disclosure

I completed this CPD in

To bank your CPD please complete the form below.

Were the stated learning objectives met?

Why weren't they met?

What did you learn from undertaking this CPD exercise?

Why did you undertake this piece of learning?

Any comments about this article or FTAdviser's CPD in general?

Banked!

Congratulations, you have successfully completed and banked this piece of CPD

Already Banked!

You have already banked for this article.

To bank your CPD you must or

Register

One or more questions have been incorrectly answered,
 please review your answers and try again.

Please complete all the above text fields to bank your CPD.

More Investments CPDSee my completed CPDSee all CPD