2015 Star Ratings Platforms Discussion Paper

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1 2015 Star Ratings Platforms Discussion Paper Defaqto Limited All rights reserved. No parts of this publication may be reproduced in any form by any means, whether electronic, mechanical, optical or any other, or be stored in a retrieval system without the express written permission of the publisher. The publisher has taken all reasonable measures to ensure the accuracy of the information and Ratings in this document and cannot accept responsibility or liability for errors in or omission from any information given and for any consequences arising.

2 About this document This document outlines the key developments and trends that will inform the criteria we use for the 2015 Star Ratings for Platforms and, based on these, sets out the areas where we would like to consult the industry as part of ensuring that our ratings process remains robust and transparent. 2

3 Key developments and trends The market The last year has seen every provider review their proposition and fine tune their fund options in light of clean share prices, super clean and unit rebates. At the same time, financial relationships with partners and client fee structures have needed to be refined. This fast rate of evolution will continue for those providers wishing to operate in the retirement and drawdown arenas as the new rules on pension access are finalised. The most recent 9,000 reports run with our Engage adviser research software have had 156 different features that have been sorted on by advisers. The top 10 are as follows: 3 Ranking Criteria 1 AKG Financial Strength 2 ISA 3 Online Valuations 4 UTs and OEICs 5 ISA Transfer 6 Online Transaction History 7 Cash Account 8 CGT Report 9 GIA 10 Fund Rebates Nearly half of all research reports ran by advisers contained the same five platforms. Legislation and regulation It seems that there has been little regulatory guidance or financial services legislation change that has not impacted on platform providers. This is not the forum to discuss all of these changes, but some key influencers on the industry going forward are: FG13/8 - A guide for Self-Invested Personal Pensions (SIPP) operators FG14/1 - Supervising retail investment advice: inducements and conflicts of interest FG14/4 - Changing customers to post-rdr unit classes Budget Pension freedom The main thrust of guidance and legislation seems to be directed at pricing and ensuring customers know what they are paying for and what they can expect in return. The question of clean share prices and super clean shares will rumble around the industry for many more years. The issue for advisers now is whether the fund selection should come before the platform selection and just how do they find out who has the best deal on the fund(s) required, and whether a saving of, say, 0.05% is sufficient. If rebates are being received and are taxable resulting in the client needing to complete a tax return, how should this be factored into the solution and overall cost and administration assessment? Providers We currently monitor 25 platform providers offering 35 platform solutions. We have seen a small increase in niche providers and, with pension freedom becoming more popular, we expect those providers offering the different forms of drawdown to become more attractive to advisers.

4 We see product innovation as critical in this area and platforms potentially at the heart of this activity, particularly where a SIPP, Personal Pension or Drawdown Plan is integrated with a particular platform. Consolidation of many retirement income sources is going to be key here we would like to engage with you on this. Products/Propositions Advisers continue to utilise our research tool. Over the last year the top three wrappers as measured by the capital investment value were ISA, GIA and SIPP. DFM relationships The use of a DFM is becoming seemingly more common in this post-rdr landscape and therefore advisers may be looking more and more for platforms to provide them with such a route. Our figures show however that the number of platforms with a panel of DFMs for use and those offering open market access to any DFM has not changed from last year. These figures are particularly relevant because of the evolution and growth of investment outsourcing by advisers as more and more decide to outsource asset allocation and fund selection Adviser Platforms DFM Open Market DFM Panel 2013 Retirement Options With the significant changes to pensions legislation and in particular, liberation of pension funds, we have proposed that we have added a new feature for Income Review Frequency Allowed given the increasing importance of this going forwards. We are now keeping a watchful eye on the growth of retirement income facilities as the need inevitably increases and will be assessing impact against our criteria. Phased retirement and drawdown are becoming more prevalent subjects. Currently 89% of platforms offer capped drawdown and 80% flexible drawdown and we anticipate these numbers increasing over the coming year. We know that there is a difference in the number of income reviews that platforms offer their clients and the charges associated with these reviews. Interestingly, there are providers still unable to facilitate 150% of GAD requests and we wait to see how this will affect their business going forward. 4

5 Key implications for the 2015 ratings process Product area weightings By making the changes with regards to introducing three new criteria and removing four as set out in the appendix, this will slightly alter the share of product features in some of the themed ratings areas as shown below. Rating area No. of features 2014 % share of features 2015 % share of features Product % 15.4% Tools % 19.2% Investments % 30.8% Reporting % 19.2% Administration % 15.4% Total % 100% 15.4% Product 19.2% Tools 30.8% Investments 19.2% Reporting 15.4% Administration What does good look like? We are not proposing any changes to the core criteria from last year, but welcome feedback and dialogue. Feature or Benefit 4 Star 5 Star AKG Financial strength ~ AKG Rating of B- or better Products Range At least 3 At least 3 Investment Vehicles ~ Collectives (Collectives) Re-Registration Off platform Off platform Reporting ~ CGT report Reporting Consolidated Tax Voucher Consolidated Tax Voucher Reporting Online Transaction History Online Transaction History 5

6 Areas for discussion These are the areas where Defaqto would like to engage in discussion with you based upon both the material in the preceding sections and upon our criteria proposals. Currency Clean Share Prices Charging Cash ISA Transfers DFMs Outsourcing Is currency flexibility for investment and/or income payments a demand? If so are US Dollars and Euros sufficient? Does the clean share price really exist (i.e. without unit rebate implications)? Are taxable rebates acceptable from the client s perspective? What options should be available regarding the funds into which rebates can be facilitated/directed and how do client mandates affect this? Is there a shift in a desire to facilitate charging through the GIA rather than the individual tax wrappers? Is important to advisers. What steps have you taken with regards to interest rates on cash? We are interested in exploring further whether we should be assessing rates and/or client share. Is important to advisers. What steps have you taken in this area? How well do you feel the platforms facilitate Discretionary Fund Management Managed Services and what, if any, are the differentiators? Are outsourced model portfolios listed? Can outsourced model portfolios be rebalanced? 6

7 Appendix: Proposed 2015 criteria Based on the above analysis, we propose including the following criteria in our assessment process for the 2015 ratings (core criteria are in bold text; new criteria are highlighted in green). Proposed criteria AKG Financial Strength Risk Profiling Tool Product Range Asset Allocation Tool Pension Flexibility Portfolio Rebalancing Interest Bearing Account Automatic Withdrawals Trust Availability Panel DFM Linked Accounts Open Market DFM Investment Vehicles (Stocks and Shares) Bulk Trading Investment Vehicles (Collectives) CGT Report Investment Vehicles (Other) Consolidated Tax Voucher On Platform Re-registration White Labelling Facility Off Platform Re-registration Back Office Integration Legacy Assets Online Transaction History Online Subscriptions Income Review Frequency Allowed The table below sets out the 2014 criteria that we are planning to remove for Criteria planned for removal Term Account Electronic Re-registration Gross & Net Nominee Automatic Income Options /% 7

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