On November 3rd we were lucky enough to have over 250 buy and sell side people in a room that have to make MiFID II research unbundling rules work in practice. Naturally we couldn’t resist picking their brains, and some of the messages were quite surprising. Our thanks to the team at ResearchCentral for making their excellent app available for us to hijack on the day!
Question 1: In 3 years what percentage of the industry in Europe (by AUM) will be paying for research out of their P&L?
We observe extremes of opinion from the buyside here with no consensus, but both the buy and sell side think that less half the market will end up paying from their P&L. The stigma of continuing to charge clients for research is dissipating – if we had asked this in May the answer would have been very different – but that doesn’t mean the P&L option has gone away.
Question 2: From January 2018 will there be a level playing field across Europe in terms of regulatory structure?
Buy and sell side were almost identical here – two thirds said there wouldn’t be. From conversations at the conference this was driven by the perception that the UK would have stricter rules and stricter enforcement than other European markets.
Question 3: The most needed market infrastructure is:
Valuation is the priority for both the buy and sell side. (We were delighted to hear that naturally!) Although it’s not clear where the most help is required – tracking and valuing interactions, tracking alpha-generating recommendations, measuring quality and the penetration of research etc. Asset managers are creating processes that need to provide robust justifications for their research procurement, and are looking for solutions right now.
Question 4: The Buyside will pay for almost no sellside FICC research apart from discounted, high-quality loss leading work from the bulge bracket
We were envisaging a scenario where bulge bracket firms both know that their clients would pay for their FICC research, and are happy to loss-lead with it (not a given by any means). Our audience were asked if they thought the statement above was true – clear difference of opinion here, two thirds of the buyside agreed and more than half of the sellside disagreed. The takeaway here is that the buyside won’t make large new budgets for FICC research and will negotiate hard for what they need. The question is obviously simplistic – firms will make new budget available for niche areas as well, but these budgets may be tiny.
Question 5: Is a plentiful supply of external research a competitive advantage for hiring and retaining the best people?
It’s unsurprising that the sell side would largely assume that this was the case, but almost half the buy side respondents disagreed. This lines up with many commentators’ assumptions that the research market will shrink – if it doesn’t hurt then why not risk cutting too much rather than too little?
Question 6: The regulations will provoke a “day of reckoning” between providers and consumers to the benefit of:
We were hoping to learn who has the leverage in the tricky negotiations coming up. Clear message from the buyside here – it’s not them, this process will benefit the “have-to-have” providers. Over half the sellside also admit that this is the case!
We have to include a health warning with these results, some questions had a universe of under 40 respondents. However it was a directly relevant universe in terms of research unbundling implementation.
Our conclusions from these answers? In both the buy and sell side you have to be really big, or really niche otherwise research unbundling hurts you. Asset managers are sorting out their research valuation processes now, and how that works will drive their negotiations with only the highest quality or most comprehensive providers benefiting.
But what does highest quality mean when beauty is in the eye of the beholder? We have some ideas there – contact us at email@example.com with “Value” in the subject field to set up a call to look at our matching model, we’re keen for as much buyside feedback as possible!
Fixed income research has been the poor cousin in the MIFID2 unbundling consultation/legislative process. To date almost all the attention has been paid to equity research and how the new rules will apply. At our Unbundling Uncovered event on November 3, we discussed this subject in great detail with our panel of experts, from both the buy side and sell side. Here are the 7 key issues raised by that discussion.
1) Increased costs; almost impossible to pass on
Come January, 2018, there will be a new cost line item for investors, and there’s little chance fund managers will be able to claw back that cost from their end- clients. As one global fund manager told our audience, in the current low interest rate environment firms cannot bear this additional cost at a time when the fees they receive from end investors are already incredibly tight and where there is very little clarity about increasing the fees in the future. Passing on the cost of fixed income research will be almost impossible. This will be a major constraint to demand for sell side research.
2) What will still be free?
Very little, according to our panel. This hinges on the interpretation of what constitutes a ”minor-non monetary benefit” (i.e what can still be distributed for free), and what might be considered as an ”inducement” to trade (must be paid for). The latest guidance from the French financial regulator gives the impression that it will take a more benign view on this, while the FCA will be more strict in the enforcement. Some fund managers on the panel bemoaned the lack of clarity on the interpretation and how it should be applied. Consequently, these fund managers said they would prefer to take a very conservative view, and plan to consider almost all the research they receive as substantive, and therefore should be priced. Moreover, sell side banks and brokers will probably tighten/cut off the distribution of free research. Given the way the regulations are being applied across the financial industry, one fund manager argued that there would be little interest from banks in sailing close to the regulatory line and so they will probably police this policy quite strictly.
3) Surely FICC research isn’t an inducement to trade? One panelist explained that due to the poor advocacy in the lobbying process (prior to the delegated acts), there had somehow been a presumption that the inducement regime would apply to fixed income. The logic of how it applies to the equity market is well understood. Whereby, best price is ubiquitous, and where research could potentially be used to channel trading into particular venues, which might be considered an inducement to trade. Panelists agreed that this situation didn’t apply in fixed income, due to it being a principal-based market, where best price is time variant and can change at every moment. Therefore, the requirement for entities to trade on the basis of best price means that it was not possible for fixed income research to be an inducement, the panelists told delegates. So an inducement regime is being applied to a market where one isn’t required.
4) Your sales access just got very expensive
The new rules are also being extended to sales coverage. Any value-added service from sell side sales teams would be considered research, which is set to place constraints in terms of the ability of the buy side to engage with sales people at banks. So the question is not just; Are you going to pay for research? But are you going to pay for your sales coverage and the value added coverage that you require? In the equities market there are sales traders and research sales, and our panelists said the same concept will probably be adopted in FICC, where value-added sales people become part of the research team, and part of the research budget. Panelists say this will be a particular area of contention. Interestingly, said one of the panelists, the interpretation from French regulators is that sales coverage maybe exempt, but in all other jurisdictions it will not be. Some panelists expressed their concern that this could really be a major potential blockage to the level of information flow from the buy side to the sell side, with a negative impact on market liquidity.
5) What are fund managers prepared to pay for?
Hard to say, because it will depend on the asset class. Our fund manager panelists saw this in two ways. Firstly, that one said he would buy niche/specialist research that his firm didn’t cover internally, or didn’t have the expertise in, while another said that where the research was thematically strong and could be broadly applied across a range of asset classes and products, it was easier to justify the outlay. In single-name research, one panelist said that single-name sell side credit research offered little value, and that it won’t probably exist in 5-years time.
6) What’s the price?
Price discovery is cited as one a key factor creating uncertainty in the implementation process, with the banks being reticent to disclose their pricing schedules. The starting point is that budgets will be much lower for fixed income than they are for equities (which will in some cases be part-funded from CSAs). Fund managers were inclined to talk down the monetary value of sell side research, while our sell side participants emphasised the cumulative value of FICC research, arguing that value shouldn’t be assessed on a piece-by-piece basis.
7)Paying US brokers for research directly is prohibited:
At the moment you cannot pay a US broker for research directly. In order to do so banks will have to become investment advisors, but the liability of banks in doing so is enormous. For the buy side, especially large global firms, the rule causes all sorts of complications. For instance, many global asset managers have analysts spread globally who are all part of the same team. Now they will have to figure out how they can interact with each other when using the advice and information they have derived from the research they have received in areas outside of Europe.
Increased Attendance: Up to 280 from 210 last year, the conference program was expanded to a full day of six panels from last year’s four. Attendance stayed strong all day with almost 200 present for the final panel covering the detail of RPA Best Practice!
Greater engagement and participation: Whilst the range of buyside and sellside attendees was similar this year, the participation and level of engagement from within these firms was much greater. The greater attendance of buyside compliance and operations teams reflects the implementation stage firms are embarking on. That is, as firms set up their new research procurement processes (valuation, budgeting, payment and client reporting), the number of stakeholders naturally increases. The questions posed to our panels were much more detailed this year, which we think reflects the key question most firms are grappling with currently. Do they continue to charge end-investors for the research, or put that cost onto their P&L?
More explicit pricing; nothing is for free: Across our various panels of industry experts there was a general push for explicit pricing (from a compliance perspective), plus an increasing realisation that almost all FICC research will need to be priced and paid for. Whilst the minor non-monetary benefits clause seems to open the possibility for some research to be free, asset managers sounded nervous about the prospect of justifying the consumption of free research on a case-by-case basis. Many panelists agreed that Germany and France will be operating under a less strict system than the UK, which will confuse things even more.
Paying for research outside Europe: Many delegates were concerned about the uncertainty over how to pay for sell side broker research in the US, where research and commission payments remain bundled and where US brokers are prohibited from receiving a payment by law. There was some faith that a solution would be found, and differences of opinion of how likely it would come from a “no-action relief” from the SEC.
A new infrastructure fit for purpose: Can spending money on compliance also provide benefits to portfolio managers? Whilst firms will have to understand that the perfect solution isn’t immediately available given the established ways that research is bought and sold, it was clear that almost all the buyside attendees were investigating using new technology providers to get better performance and competitive advantage.
We will be sending out the results from the polls, summaries of each panel and key quotes over the next few days. To be including in the mailing list please email firstname.lastname@example.org with “mail” in the subject field and we’ll include you.
New regulations covering research procurement (taking effect on Jan. 3 2018) will change how portfolio managers and buyside analysts in Europe can access, share and value external research. Therefore we thought we’d shine some light on why your operational colleagues look so stressed and why they want you to make some tough decisions ahead about how you evaluate and consume research
Charging clients for research has become more complex for asset managers
From much of the early reaction to the FCA’s September 30th consultation paper you’d think that European asset managers were being forced into paying for research themselves. The fact is that they can continue to charge their clients for the research they use within the new Research Payment Account structure. However, a host of new transparency and governance procedures need to be put in place. This piece from Sandy Bragg at Integrity Research Associates is balanced and covers all the main points. Integrity Research Associates: UK Regulators Offer Moderate Interpretation Of MiFID II Unbundling
2. Sell side fixed income research will no longer be free
If a piece of sell side research helps you make an investment decision, then you will need to pay for it. The main issues here are that a) fund managers (and their clients) have not been charged for FICC research until now, and b) all that stuff you received for free and that is considered substantive, now has to be paid for. Not much has been written on this tricky topic. We highlight a Euromoney piece from earlier in the year, but for anything up-to-date you’ll have to come along to the FICC research panel at our November 3 conference. Euromoney: Counting the cost of research
3. Client fairness – the dealbreaker for RPAs?
Asset managers will now have to manage multiple, segregated research budgets. Unless an asset manager is confident that they won’t get sued for sharing research across those budgets, it will have to instead pay out its P&L. We write about this crucial issue here:
4. European asset managers won’t be able to pay a US broker for research.
Investment research in the US remains bundled. US brokers who want to accept direct payments for research from European asset managers would have to register as Investment Advisors, which they won’t do. The Investment Association covers this issue on page 7 of their “Approach to research under MIFID II” paper, which is accessible for members here.
5. PMs and analysts need to ”buy in” to this new process to reap the benefits
The key point in this piece from RapidKD is that without the right stakeholder support any new processes will only fulfill compliance goals. PMs need to embrace the changes in order to realise the benefits of a streamlined process. So get involved! RapidKD: MiFID I implementation in the real world
In our consultations with over 50 buyside firms since May this year it is clear that the stigma associated with continuing to charge end investors for research is dissipating. Both the AMF and the FCA consultation papers legitimised the use of CSAs. Whilst the FCA have added new controls and procedures it is clear that this is a viable funding route, at least theoretically. So what will make more firms join those already paying for research out of their P&L instead?
The areas of greatest concern vary depending on the size and business model of the asset manager you are speaking to. The largest firms talk about managing multiple research budgets, and the dynamic process of moving some of the CSAs funding those budgets to execution-only whilst others continue to allocate to research. Many small and medium size firms cite comprehensive consumption tracking as the largest potential headache.
However if there is one dealbreaker for the RPA/CSA route it is this: a lack of clarity in how much sharing of research is acceptable. Where should buyside firms draw the line and how can they implement the necessary controls?
It may sound sensible to implement a straightforward delineation between published research and any bespoke interaction with a provider. So if a PM takes a bank’s thematic publication into an investment committee meeting the other participants do not have to make the choice between shielding their eyes or passing him a tenner.
However if a PM from a desk which doesn’t contribute to a particular research providers’ bill attends an external analyst’s visit, the research budget his fund is housed within will need to contribute and the interaction will need to be valued.
That may sound terrible in practice, but even this may not work if the end investor doesn’t explicitly agree to this delineation. The legal departments of asset management firms will need absolute confidence that they are not laying themselves open to lawsuits from pension funds that feel they have paid for research that others have benefited from for free.
At Substantive Research we are embarking on a two-month consultation process with pension funds to see if a consensus can be reached on this issue. Once we’ve completed the consultations we will publish our findings as an Appendix to our existing draft RPA Code of Conduct, which will be housed on researchpaymentaccounts.com from December 10th and free to view.
Over 200 of you joined us on November 3rd 2015 for a day of high quality debate and analysis. This year the focus moves onto implementation.
Join us in London at the IoD on the 3rd November to hear industry leaders discuss their reactions to new regulations and benchmark your plans and priorities with your peers.
Attendance for verified buyside delegates is complimentary
Under the new rules fund managers need to set pre-agreed budgets for research payments, provide detailed audit trails of payments made to research providers, and also disclose transparent methodologies as to how they select and pay for research. We have now seen how regulators in France and the UK interpret the MiFID II Delegated Acts, but it’s clear that the buyside was already changing its research sourcing and consumption processes.
Unbundling Uncovered will allow asset managers to benchmark their plans and efforts to comply with the new rules, and provide end investors with the opportunity to understand how these changes will affect them. Will the enhanced-CSA payment model be the norm in 2018 or will firms begin to pay from their own resources, and will it be regulation or competitive pressure that drives that choice? Whilst much of the focus has been on equity markets, implications for FICC research are perhaps even more structurally transformational. Panels will cover the CIO perspective, RPA best practice, the likely change in business models on the supply side, charging for FICC research, and technology and platform solutions.
Confirmed Speakers include:
Robert Alster, Head of Research, Close Brothers
Romain Boscher, CIO, Equities, Amundi
Fabrice Bouland, CEO, Alphametry
Sandy Bragg, CEO, Integrity Research Associates
Chantal Brennan, CIO, Davy Asset Management
Chris Brown, CIO, IPS Capital
Jeremy Davies, Co-Founder, RSRCHX
Chris Deavin, Chairman, Euro IRP
Alberto Gallo, Head of Global Macro Strategies, Algebris Investments
Amrish Ganatra, Managing Director, Commcise
Jon Foster, Co-Founder, Smartkarma
Patrick Gill, Executive Director, Instinet
Alistair Haig, Fellow, University of Edinburgh
Gianluca Minieri, Global Head of Trading, Pioneer Investment Management
Russell Napier, Co-Founder, ERIC
Jens Nordvig, Founder and CEO, Exante Data
Jonathan Pitkanen, Head of IG Credit Research, Columbia Threadneedle
Indy Sarker, CEO, ANALEC
Neil Scarth, Principal, Frost Consulting & Advisory
Rudolf Siebel, Managing Director, German Investment Funds Association
Roland Spurr, Equities Business Manager, AllianceBernstein
We would like to take this opportunity to say thanks to the more than 200 delegates that attended our inaugural conference: Unbundling Uncovered, on November 3. We would especially like to thank our panel participants for sharing their industry insight and knowledge on this topic.
Here is a summary of the key takeaways:
1) How prepared is the buy side for regulatory change?
-Most panelists and participants agreed that it was right that regulators look at research given the size of the market and that client money was used. While not uniform across the market, some asset managers present were very confident that their current process would stand up to regulatory scrutiny. This process includes fixed budgets, reviews and an assessment process that was complemented by a voting process, that ensured that they remained flexible in what they prioritised as the research markets changes.
-The biggest growth area in the research procurement/management space is around reporting obligations. How can the buy side get as much detail as possible, build an MIS, communicate through various internal management committees?
-This requires identifying all of the inputs coming into the organisation from providers. It was noted that historically payments for research via CSAs was dealt with by the trading business, but today, portfolio managers, compliance officers, and CIOs are all interested in how research is being consumed and paid for. This was a fundamental change in thinking for the buy side; Much more attention to detail.
–Fundamental change is already underway. Indeed CSAs have been in place for years – which have largely been used to pay Independent Research Providers (IRPs), – but some buy side panelists said they intended to go fully unbundled in future. This process had slowed recently due to regulatory uncertainty. Commission payment providers note a 35% increase in the use of CSAs by fund managers over the last two-years, as well explosive growth of CSA aggregation to reduce administrative burden, which grew 5-fold in the past two years. Payments to IRPs have been incredibly stable, while sell side payments are coming down in average payment size, but frequency is increasing. This could be a sign of better goverance and fluidity in quality assessment of research. They converge somewhat.
2) How engaged are asset owners, end investors?
– Clients care about performance, not cost. So spending time and money on assessing value ex-ante can be a distraction. Some panelists and audience members thought that there was no benefit for investors to be flooded with information they don’t have the time or inclination to process. The focus perhaps should be more on enforcement and sanctions when firms don’t behave correctly
–This topic of research payment is difficult to understand and rather opaque, so many clients don’t care. But opinions differed as to whether that meant that regulation was more or less necessary. Some thought it was right that regulators assess this market and prescribe rules, because it is a market that doesn’t naturally self-regulate.
-There is a growing trend among Sovereign Wealth Funds (SWFs) to implement this burgeoning budgeting process internally What will be the implications for asset managers who they farm 80% of their funds out to? This could have consequences for the asset managers themselves.
–Some panelists argued that unbundling was ultimately being driven by the fund management industry, not the regulators. If some of the major fund managers decide to switch to a hard dollar regime, and then advertise clean fees to differentiate themselves, that will present a challenge to the rest of the industry. So in that sense, the industry is the driver of new market structure, not the regulator.
3) Will fund managers face additional costs with unbundling?
-This depends. In the unbundled world, investors have benefited from using the services of sell side firms to replicate some of the background work that is still needed by many firms. If banks stop doing that work then firms will each have to bring costs on to do it, and so the client will end up paying multiple times for the same job. If the market has to go hard dollar then it is possible it becomes less transparent for the client, and costs still will get passed on.
-The budget for IRPs is likely to rise. Panelists thought that the number of large bank relationships would decrease and there will be an increase in the number of boutiques being used and paid for.
4) What happens if fixed income research is unbundled?
-The most controversial issue of all of the unbundling rules, and one of the key reasons for the delegated acts has been delayed. Sell side panelists warned there would be unintended consequences if the proposed unbundling rules were applied to fixed income research. They argued that there was a possibility of fundamentally changing the commercial relationship between the buy side and the sell side. The bottom line is: The regulator is essentially trying to unbundle something that is notbundled, because the costs are funded by the sell side firms themselves.
-The argument goes like this: If you assume that the model for fixed income research is not paid by the customer, then you’re asserting a model on investors that is going to change their outcome. It’s going to change their outcomes by applying a cost where it does not exist today, while also narrowing the consumption options.
-Consumption options don’t just mean research, because a lot of buy side – sell side dialogue could be around derivatives, structuring ideas, trade ideas, perspectives on different parts of the curve or different parts of the product spectrum.
–There’s a real possibility that some of those dialogues are prevented because they are somehow labelled as an inducement and are banned under the proposed regime. This issue is being considered separately as part of the proposals.
-Therefore fixed income research is struggling with the twin challenge of applying the cost that doesn’t exist today and restricting the dialogue versus where the market is today. There is some hope that ESMA has taken account of these reasonable views.
-Buy side participants were less concerned about unbundling of fixed income research. They observe that more and more FI research is moving in house and will eventually leave the credit component of sell side FI research redundant. This is already in train with many sell side firms reducing their service in credit research for instance, although sell side macro strategists should remain in demand, as they are applied broadly across all asset classes. Global macro may be an even more competitive area for providers.
-There is a shift towards asset management firms creating their own intellectual property, to be able to prove that they’re adding some value, and more research is moving in house. Internal research budgets are in many cases greater than their external budgets.
Defining Best Practice in Investment Research Procurement
Join us in November 2016 to hear industry leaders discuss their reactions to the new rules and benchmark your plans and priorities with your peers
This Autumn the investment management industry will have greater clarity on the regulations for procuring and consuming external investment research.
Many of the proposed regulatory requirements are unlikely to be met with much resistance from asset managers. That’s partly due to the fact that the industry has already started to implement more robust procedures in the way it procures research.
Under the proposed new rules fund managers will need to set pre-agreed budgets for research payments, provide detailed audit trails of payments made to research providers, and also disclose transparent methodologies as to how they select and pay for research.
Unbundling Uncovered will allow asset managers to benchmark their plans and initial efforts to comply with the new rules, and provide end investors with the opportunity to understand how these changes will affect them. What best practice means within an RPA will need to be defined, and priorities set for the implementation of a practical and transparent process.
Crucially, it will be clear whether funds can charge clients for research or if research has become part of a firm’s P&L costs, and panel discussions will explore the likely implications for market participants will be.
One key area to address will be fixed income markets. It may be hard to classify any of this research as anything but an inducement to trade, and how the market categorises, values and charges for fixed income research will have market-changing ramifications.
Confirmed Speakers from 2015’s event included:
Peter Allen, Chairman, Euro IRP
Robert Alster, Head of Research, Close Brothers
Frédéric Bompaire, Head of Public Affairs, Amundi
Andrew Bowley, Head of Market Structure Strategy, Nomura
Chris Brown, Chief Investment Officer, IPS Capital
Mark Burgess, Chief Investment Officer, Columbia Threadneedle
Tom Conigliaro, Global Head of Investment Services, Markit
The European Association of Independent Research Providers (Euro IRP) has established a searchable directory for independent research providers to help investment firms locate a wide array of independent research providers while also helping research firms reach a potentially wider audience for their services.
The directory allows investors to search for providers based on sector or geographic coverage, asset class, type of research and business model, among other factors. The current directory is made up of 56 research providers that are currently members of Euro IRP, but the association hopes to expand this to more than 500 providers globally.
‘’This is an important first step for the whole independent sector,’’ says Peter Allen, chairman of Euro IRP. ‘’To date, there has never been a venue that allows investors to search for independent providers, whilst for the IRPs – many of whom have small operations that are producing high-quality research – it provides a useful way for them to reach a wider audience.’’
Currently listing in the directory is restricted to full members, but Substantive Research understands a separate category of IRPs who will just wish to list on the directory is under consideration, although they will still need to meet Euro IRP’s requirements as far as independence is concerned, as posted on their web site here.
The initiative is also important in the wider context of the new regulations for the investment research market, set to be implemented in 2017 under MIFID 2. The proposed regulations will require fund managers to set annual budgets for investment research spending, which will also probably need to be funded from their own account rather than passing the cost on to their clients. This is likely to lead to a more cost-conscious approach from investment firms on research spending, which could place IRPs at a competitive advantage because they operate on a lower cost base than typical bank research departments.
“As investment managers increasingly focus on the value of their research spend, this initiative will provide a valuable resource for identifying and sourcing the best possible independent analysis for their clients,’’ says Allen.