DALBAR Due Diligence: Trust, but Verify

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1 BEST INTEREST INVESTMENT RECOMMENDATIONS Advisr Rle under Best Interest Regulatins January 27, 2016 In the era when the cntractual bligatin is t act in the client s best interest, investment decisins can n lnger be based n the judgement f the individual advisr r a plicy f the advisr s firm. In the case f the advisr s judgement, an enrmus business risk is intrduced if tw clients with similar circumstances receive cntradictry recmmendatins frm advisrs f the same firm. Hwever, the use f a firm-wide plicy fr recmmendatins wuld be a vilatin f the best interest cntract that requires cnsideratin f each client s needs, circumstances and situatin. The cnsequences f failing t cmply with the best interest cntract are severe but can be avided by adpting practices that are prudent, lyal, and untainted by cnflicts f interest, based n the client s best interest. These practices, hwever, must be unifrm and cnsistently used in rder t ffer any prtectin. Prudence requires that the advisr and financial institutin making the recmmendatin act with the care, skill, prudence, and diligence under the circumstances then prevailing that a prudent persn wuld exercise based n the investment bjectives, risk tlerance, financial circumstances and needs f the client, withut regard t the financial r ther interests f the advisr r financial institutin. Almst as imprtant as cmplying with the best interest cntract is the need t prve that cmpliance. The diagnsis that leads t each recmmendatin is a permanent recrd f what facts were knwn at the time f the recmmendatin and prevents claims f miscnduct when future lsses ccur. A further requirement f a best interest cntract is that recmmendatins cannt be subject t cnflicts f interest. Cmplying with the n cnflict requirement requires that the advisr and financial institutin is able t shw that recmmendatins were nt influenced by payments r ther cmpensatin derived frm the recmmended investment. It is therefre necessary t define hw best interest is determined and then later prven. Practices t cmply with best interest cntract requirements can then be put in place. Discarded Cnsideratins Several factrs that may have influenced investment recmmendatins in the past must be abandned because they fail t meet best interest standards. A new set f decisin-making standards must replace these existing practices. 1

2 Befre discussing standards that will meet the new requirements it is necessary t identify practices that can n lnger be cnsidered in presenting a recmmendatin t a client. These practices fall int tw categries: Expert Only Practices are thse that rely n expertise but d nt invlve the client s specific situatin, needs r desires. BICE recmmendatins require taking prudent steps in an attempt t determine what the client s best interests are. These are unlike existing practices with the requirements f knwing the client and nt making unsuitable recmmendatins. Incentive Driven Practices are thse that are based n paying sme frm f cmpensatin t the advisr r financial institutin. These prhibited practices are likely t be identified in plicies r in patterns f recmmendatins. Expert Only Practices While an advisr s and a firm s expertise is an expected cmpnent in making investment recmmendatins, the requirement t act in the client s best interest means that the expertise cannt be the nly basis. Reliance n training, licenses, certificatins r experience are insufficient t meet BICE requirements. The recmmendatin must include cnsideratins abut the client. Withut the client element, the recmmendatin cannt be in that client s best interest. Other Expert Only Practices include financial institutin s wn plicies, sales agreements, research pinins and fcus prducts. Investment recmmendatins made withut prudently cnsidering the client s needs are a vilatin f a best interest cntract. Incentive Driven Practices While BICE permits varius frms f incentive cmpensatin t advisrs and financial institutins, it is required that such cmpensatin des nt influence which investments are recmmended. Examples f prhibitins are making recmmendatin based n the expectatin f: Cmmissins 12-1 fees Finders fees Revenue sharing arrangements Bnuses r ther payment Nn-cash incentives Changes fr Rllvers Rllvers are ptentially the largest grwth areas and are subject t the mst rigrus changes. 2

3 The new regulatins treat recmmendatins t rll assets ut f an ERISA plan t be a fiduciary act, requiring the investr prtectin f a best interest cntract. There is, hwever, an educatinal exclusin prvided that: Infrmatin and materials d nt include recmmendatins with respect t specific investment prducts r specific plan r IRA alternatives, r recmmendatins n investment, management, r value f a particular security r securities, r ther prperty. N reference is made t the apprpriateness f any individual investment alternative r any individual benefit distributin ptin fr the plan r IRA, r a particular participant r beneficiary r IRA wner. If adpted, these prvisins prevent the advisr frm adding value fr the client in tday s largest ptential market. Success in the rllver market will almst certainly require BICE. Required Cnsideratins BICE requires either that the fllwing be taken int accunt in making investment recmmendatins r that a statement be presented t the client t cnsider them. The way in which these items are weighed and interpreted is left t the judgment and expertise f the advisr. The advisr must be prepared t demnstrate that the interpretatin f these items is reasnable: Other assets Incme and investments such as: Equity in a hme Scial security benefits Individual retirement accunt/annuity investments Savings accunts Interests in ther qualified and nn-qualified plans Additinal Client Cnsideratins Advisrs need t find ways t add value t their clients s as t avid excessive cmpensatin vilatins. The best way t avid excessive cmpensatin vilatins is t bradly cnsider what is in the client s best interest. Fr example, if an advisr establishes that the client s best interest is t have lifetime incme and recmmends an annuity, there is very little value added and cmpensatin shuld be very lw. If best interest cnsideratins fr the same client includes the items n the list belw and thers, the value and allwable cmpensatin is greatly increased. Best practices suggest that investment recmmendatins als include the fllwing cnsideratins fr and abut the client: 3

4 Purpse and financial gals fr the funds invlved Define each majr purpse f funds and a minimum and ptimum financial gal (dllars needed t accmplish that purpse) fr each. The purpses can be generic (make a lt f mney) r specific such as a purchase, incme r cmmitment. Arrange purpses in rder f imprtance, taking each minimum and maximum separately s minimum retirement incme may be mre imprtant than minimum educatin but ptimum retirement may nt be. The client s tlerance fr risk in pursuing each purpse r gal Clients are willing t take greater risks in pursuing ne purpse ver anther. Each gal is examined t assess the current tlerance fr risk. It shuld als be nted that the tlerance fr risk changes when circumstances r market cnditins change and as the time fr achieving the gal appraches. Time hrizn fr achieving the gal The timeframe fr when the funds will be used fr each specific purpse is established. The time hrizn can be a single event such as a purchase r cntinuus incme. Likely behavir during times f market stress Histry has shwn that clients fail t achieve ptential returns frm their investments primarily due t their wn behavir. This leakage f returns can be abated by investment recmmendatins that set reasnable expectatins and revisiting recmmendatins in times f market and ther stresses. The behavirs causing the greatest leakage are lss aversin during high vlatility, delaying investments due t hesitatin and attempts at market timing. Expected utcmes Expectatins that clients have fr investment returns, vlatility and ptential lsses are determined and addressed befre making recmmendatins. Expectatins shuld be aligned with the investments the client hlds. Misalignments are a frequent cause f client dissatisfactin and lss f business. Investment preferences, restrictins r exclusins desired by the client Clients ften have pre-dispsitins abut which investments are desirable and which are nt. Understanding these individual preferences is essential t acting in the client s best interest. Fees and expenses While n client desires t pay high fees, clients recgnize different values and are willing t pay extra fr thse values. The mst frequent example is paying fr active management. Clients wh understand that circumstances arise where a prescribed passive investment may nt be the best alternative are willing t pay higher fees fr active management. 4

5 Service and cnvenience Individual client s service requirements als vary greatly, frm cntinuus mnitring f investments t thse wh prefer a hands ff apprach. The investment recmmendatin shuld reflect the preference fr service. Clients wh expect cntinuus mnitring are best served by investments that prvide extensive high quality supprt. Investment Menus and Prprietary Funds Best interest cntracts d permit the use f pre-selected menus and prprietary funds as investment chices but there are cnditins that must be met. Cnditins wuld apply t firms that limit the prducts that their advisers can recmmend based n the receipt f third party payments r the prprietary nature f the prducts (i.e., prducts ffered r managed by the firm r its affiliates) r fr ther reasns. The cnditins require that such firms prvide: Ntice f the limitatins t plans, participants and beneficiaries and IRA wners. It is insufficient fr the ntice merely t state that the financial institutin may limit investment recmmendatins, withut specifically disclsing the extent t which the financial institutin in fact des s. A written finding that the limitatins d nt prevent advisers frm prviding advice in thse investrs' best interest r frm therwise adhering t Impartial Cnduct Standards. Ensure that any additinal cmpensatin received in cnnectin with the advice are fr specific services Recrd Keeping Requirements There are six critical activities that must be recrded t satisfy the BICE requirements and t prtect the advisr and financial institutin frm excessive risk and liability: Discver: Client s best interests, updated peridically as circumstances change. Cntract: Executed by client and meeting regulatry requirements and specifying the services that the advisr prvides. Interpret: Explanatin f the factrs used and hw thse factrs led t investment requirements that are used t develp recmmendatins. (This is the functin f tday s investment plicy statement.) Recmmend: Investments recmmended and the ratinale fr hw they meet the investment requirements. Implement: Client apprval and executin f required transactins. 5

6 Mnitr: Results f mnitring client s perfrmance in relatin t gals and any necessary changes. Cmputer Mdels Current practice f manual versight is nt feasible under a best interest arrangement. The basic reasn fr this is that: Current practice f versight ccurs after the client agrees t execute a transactin. Best interest requires versight f the recmmendatins t the client, which ccur befre client agrees t execute the transactin. This basic difference in additin t the cmplexities and time cnsuming nature f the best interest versight make reliance n manual prcedures unfeasible. The practical alternative is the use f ne r mre cmputer mdels t capture and interpret the best interest infrmatin in a way that can be shwn t be prudent. Cmputer mdels must: Prvide a cnsistent basis fr making recmmendatins. Eliminate risk f human errr. Interact with separately cntrlled investment mdels fr recmmendatins t meet investment requirements. Handle changes t decisin rules and recrd them when they ccur. Permanently recrd facts as they were knwn at the time f every recmmendatin. Includes histrical data, current infrmatin and prjectins. Entirely eliminate any respnsibility fr events that ccur after recmmendatins are made. Facilitate fllw-up t identify changes. 6

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