On 15 June 2018 we received the report of recommendations from the Institutional Disclosure Working Group (IDWG). The IDWG has now also published a summary of their recommendations.
We would like to thank the members of the Group, including the Chair Dr Chris Sier and the co-deputy Chairs Jeff Houston and Gregg McClymont. We would also like to thank all of those stakeholders who participated in their work.
We welcome the recommendations and the FCA will continue to work with investors and industry to play our part in the next steps as recommended in the IDWG report.
Our response to the recommendations and next steps
We welcome the recommendations made by the IDWG. We believe that the group has made significant progress in tackling the issues we found in relation to institutional disclosure as part of the Asset Management Market Study.
We will now work with interested parties to begin the process of supporting these recommendations. We will continue to work with investor and industry representatives as well as other regulators with an interest in this space.
As part of the recommendations the IDWG has encouraged the formation of a group to own the outputs of the work so far and be able to answer questions and monitor the use of the templates. We are working with interested bodies and anticipate the new group will be formed over the summer with launch planned for autumn. The full IDWG report, including the templates, will be released once the new group has been convened.
We will reconsider the issue of disclosure to institutional investors in the future if we have any reason to be concerned about the effectiveness of how the IDWG recommendations have played out in the market.
The IDWG has provided us with a full report of their recommendations, and the supporting tools, documents and templates. The IDWG also provided us with their views on how to maximise the effectiveness of the recommendations, how to encourage providers to use the templates and how to encourage more users to request information on costs and charges from their providers using the templates. The report also represents how discussion on key issues evolved.
A summary of the IDWG recommendations can be found on the IDWG webpage, which also includes links to other relevant information, including summary minutes from IDWG meetings.
We launched the IDWG as part of the Asset Management Market Study remedies package.
We want to see more consistent and standardised disclosure of costs and charges to institutional investors. We think a standardised disclosure template should provide institutional investors with a clearer understanding of the costs and charges for a given fund or mandate. This should allow investors to compare charges between providers and give them a clear expectation of the disclosure they can expect. We appointed Dr Chris Sier to chair a working group of industry and investor representatives on institutional disclosure, with a view to agreeing a template. The IDWG recommendations to us sit alongside and support several other recent interventions which should also impact the way institutional investors interact with their asset manager.
The main focus of the IDWG has been on the provision of helpful information to assist institutional investors by detailing what costs they are paying. It has not focused specifically on creating a method of delivering compliance with MiFID and other requirements. However the IDWG templates have been designed to be aligned with the relevant disclosure obligations in MiFID II. So while firms must continue to ensure that they individually meet all relevant regulatory requirements, if these templates are completed in a comprehensive and accurate way, including all costs and associated charges, the information in the templates should assist firms in meeting those requirements.