Distributor Advisory Group
The Findel Distributor Advisory Group “DAG” is Chaired by Paul Witham at Fidelity and consists of a sub-set of Findel members and selected Distributors, with a primarily goal to improve levels of service and remove common pain points between Asset Managers, Distributors, and Platforms for the benefit of our members underlying investors.
The Findel DAG have compiled the attached guidance document in respect of standard KPIs to supplement ongoing due diligence: –
November 2023 Update
The DAG working group are progressing with an explainer document to outline and clarify the different requirements of Distributor Due diligence performed by the Investment Fund Manager/Management Company, as well the AML/KYC performed by the Transfer Agent. A draft paper has been produced for DAG members review and will be available on the Findel website shortly.
The FCA’s Consumer Duty is a set of new rules and guidance designed to increase the protection for retail financial services market. Due diligence questionnaires have been extended for UK distributors. Members discussed the impact the feedback required in the distributor feedback template (DFT) and the potential challenges in collecting and assessing large volumes of information. Discussions ongoing ahead of the entry into force date of 31st July 2024.
Members recapped on the recent meeting with a large fund distribution platform. In addition to an overview of the platforms business strategy the group discussed feedback concerning the due diligence questionnaires requested from Investment Fund Managers (IFMs)/ Management Companies, the feedback was this generally works fine. Members also discussed the appointment of sub-distributors by the platform, then the requirement of Ongoing Monitoring and the need for platforms/Intermediaries/Distributors to provide Key Performance Indicators to Investment Fund Managers (IFMs)/ Management Companies as part of their Ongoing Monitoring.
The link to Findel’s KPI guidance can be found here Ongoing Monitoring of Marketing Intermediaries. Finally members discussed the lack of automation for Transfer processing, the Findel support SWIFT transfers as a way of automating these instructions.
Next DAG meeting topics: to include ;
- Platform meeting updates
- UK Consumer duty ongoing
August 2023 Update
Following DAG working group meeting with several US brokers outlining issues and inconsistencies in approaches the DAG working group will clarify the differing requirements of Distributor Due diligence performed by the Investment Fund Manager and the AML/KYC onboarding performed by Transfer Agents. To be shared soon.
European Platform meetings:
Following good discussions with platforms in 2021 & 2022, the DAG working group will again invite platforms to meet with the DAG to discuss progress of different topics such as KPI’s, Transfer Automation and Distributor due diligence and highlight other improvement areas. The DAG will use this to help identify what they will prioritise in 2024.
CBDF Marketing Communication:
The DAG working group discussed the requirements to comply with when producing and issuing Marketing Communications. Subsequently & following the testing of Marketing Communications by the CSSF, on the 23rd August the CSSF has issued their General Findings and Observations to the industry. The link can be found below