This report presents the findings of our review of conflicts of interest arising from wealth management and private banking firms’ use of in-house investment products (IHPs) in retail discretionary and advisory investment portfolios.
We set out in our Business Plan that we intended to look at this issue in the wealth management and private banking sector in respect of the use of IHPs. Identifying and managing conflicts of interest is a fundamental obligation on firms and, as such, we would expect all firms to have an embedded approach to deal with conflicts of interest.
We conducted the review to assess whether wealth management firms and private banks identified and managed conflicts of interest that might arise when providing investment products manufactured within the same group/firm and put customer outcomes at risk.
Generally, the review found that firms recognised the potential risks to their customers from conflicts of interest when using in-house investment products and had taken steps to manage them.
The review is relevant to all firms that provide IHPs to retail customers through their discretionary and advisory services. This document is relevant to both the distributing entities and the manufacturing (asset management) entities.
It will be of interest to different parts of the business including boards, senior management, compliance, risk, heads of distribution and front office staff.
We shall be giving individual feedback to the firms that we looked at in detail and shall expect them to address any issues we raise with them. Other firms that were not involved in this review, which have access to IHPs, are expected to consider how their own arrangements meet the standards as set out in this report. The industry should keep under review the arrangements they have in place in in this area.
In view of the generally positive findings in this review, we are not proposing to undertake further thematic work within the wealth management and private banking sector on conflicts of interest in relation to IHPs.
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