Join us on November 13th at Unbundling Uncovered..

Defining Best Practice In Research Procurement

See the full agenda here

300 of you joined us in November 2017 for a day of high quality debate and analysis. Now that MiFID II is in effect, come to hear industry leaders debate and discuss how their approaches to research budgeting, valuation and compliance worked out in practice and what needs to change now.

Join us on the 13th November at the IoD to hear how the industry is adapting to the new regulations so you can benchmark your plans and priorities with peers.

Attendance for confirmed buyside delegates is complimentary. Discounted early bird tickets available if booked by October 26th here.

Speakers include:


  • Robert Alster, Head of Research, Close Brothers Asset Management
  • Mark Artherton, Head of Research Content, Smartkarma
  • Travis Barker, Business Manager, HSBC GAM
  • Ross Barret, Capital Markets Specialist, The Investment Association
  • Chris Brown, CIO, IPS Capital
  • Tom Caddick, CIO, Santander Asset Management UK
  • Kevin Coleman, CEO, Coleman Research
  • Chris Deavin, Chairman, Euro IRP
  • Paul Durno, Executive Director, Institutional Equities, Morgan Stanley
  • Simon Edwards, Head of Business Development, BlueMatrix
  • Peter Elwin, Head of Research, Universities Superannuation Scheme Investment Management
  • Amrish Ganatra – CEO, Commcise
  • Roberta Howett, Research Manager, Man GLG
  • Howell Jackson, James S. Reid, Jr. Professor of Law, Harvard University
  • Nicholas Mather, CEO, TS Lombard
  • Michael Mayhew, Chairman, Integrity Research Associates
  • John McGough, MD U.S. Institutional Equities, INTL FCStone
  • Robert Miller, Head of Research, Redburn
  • Oliver Pratley, Operations Manager, Invesco Perpetual
  • Henry Price, CEO, Red Deer
  • Cath Rawcliffe, VP, Singletrack
  • Daren Riley, Head of Business Development, ERIC (Electronic Research Interchange)
  • Scott Rosen, CEO, Visible Alpha
  • Vicky Sanders, Co-Founder, RSRCHX
  • Indy Sarker, CEO, ANALEC
  • Joe Sluys, CEO, SquareBook
  • Alex Stewart, Head of Global Sales and Product Strategy, CorpAxe
  • Christopher Tiscornia, CEO, Westminster Research
  • Lucas Wurfbain, Founder, Feedstock
  • Adam Wreglesworth, Markets Policy Department, FCA
  • Karen Zachary, COO, CRUX Asset Management
  • Richard Ziegler, CEO, CLSA (UK)
    See the full agenda here

Join us in New York on June 12th at Unbundling Uncovered USA

Defining Best Practice in Research Procurement

See Agenda here

The investment research industry has undergone a revolution in Europe. Many changes have been good for market efficiency but asset managers also point to negative consequences for the end investor and the industry. How can the US market benefit from the positive trends while ensuring it avoids the pitfalls? Will a global standard of best practice emerge?

According to Integrity Research Associates, 38% of asset managers not subject to MiFID II plan to use CSAs as the primary research payment vehicle while 19% will pay for research out of their P&L’s or a research charge alongside executions. The recent no-action relief letter from the SEC allows US brokers to take cash payments for research from Europe until mid-2020.

The changes are already happening, what’s unclear is where we are headed.  

300 buy and sellside delegates joined us in London in November 2017 for a day of high quality debate and analysis. We now move to New York to focus on best practices for the buy and sellside – and what the American end investor should make of it all. If US-based asset managers adopt a transparent approach to research procurement will they avoid the European shift to paying for research out of their own resources? What does a transparent process look like?

Join us on the 12th June at the Metropolitan Club, New York, to hear industry leaders from the US and Europe discuss the direction and pace of change for the US investment research industry. Panels will cover the CIO perspective, research valuation and budgeting, the changes in provider business models, best practice in managing CCAs, and technology and platform solutions.


Speakers include:

Radek Barnert, CEO, WeConvene

Ross Barrett, Senior Policy Advisor, The Investment Association

Richard Bove, Chief Strategist, Financial Opportunities Strategy, Hilton Capital Management

Elen Callahan, COO Global Debt Research, Deutsche Bank

Sean C. Davy, Managing Director Capital Markets, SIFMA

Scott Douglass, Executive Director, Instinet LLC

Evan Fire, Chief Information & Operations Officer, Pzena Investment Management

Amrish Ganatra, CEO, Commcise

Jason Glazer, COO, Cornerstone Macro

Francois Gour, Senior Advisor, Frost Consulting

Marc Harris, Head of US Research, RBC Capital Markets

Robin Hodgkins, President, Castine LLC

Stuart Howard, Head of Investment Management Operations, Invesco Perpetual

Michael Hufton, Founder & Managing Director, ingage

Michael Mayhew, Chairman, Integrity Research Associates

Oliver Pratley, Operations Manager, Invesco Perpetual

Henry Price, CCO, Red Deer

Daren Riley, Head of Business Development, ERIC

Vicky Sanders, Co-Founder, RSRCHX

Terence Sinclair, Global Franchise Director, Citi Research

Warren Yeh, Head of US, Smartkarma

Adam Wreglesworth, Wholesale Conduct Policy, FCA

See Agenda here – register here or email us at

Join us on November 2nd at Unbundling Uncovered..

Defining Best Practice In Research Procurement

See the full agenda here

300 of you joined us in November 2016 for a day of high quality debate and analysis. With weeks to go before the MiFID II deadline, Unbundling Uncovered 2017 will identify where are you ahead (or behind!) in your preparations, and ensure that your implementation meets the requirements.

Join us on the 2nd November at the IoD to hear industry leaders discuss their reactions to new regulations and benchmark your plans and priorities with peers.

Attendance for confirmed buyside delegates is complimentary if booked by September 8th here, early booking discounts for all other delegates also apply.

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, assess quality and pay for research. Unbundling Uncovered will allow asset managers to benchmark their plans to comply with the new rules, and provide end investors with the opportunity to understand how the changes will affect them. Will the enhanced-CSA payment model be the norm in 2018 or will firms pay from their own resources, and will it be regulation or competitive pressure that drives the choice? Panels will cover the CIO perspective, RPA best practice, the changes in provider business models, charging for FICC research, and technology and platform solutions.

Speakers include:

  • Julian Allen-Ellis, Director, AFME

  • Robert Alster, Director of Research, Close Brothers AM

  • Travis Barker, Business Manager, HSBC GAM

  • Ross Barret – Capital Markets Specialist, The Investment Association

  • Romain Boscher – CIO Equities, Amundi

  • Andrew Bowley, Head of Regulatory Response & Market Structure Strategy, Nomura

  • Chris Brown, CIO, IPS Capital

  • Amrish Ganatra – CEO, Commcise

  • Patrick Gill – Executive Director, Instinet

  • Shai Hill, Head of European Research, Macquarie Group

  • Dan James, Global head of Fixed Income, Aviva Investors

  • Philippe Lespinard, Co-Head of Fixed Income, Schroders

  • Vicky Sanders, Co-Founder, RSRCHX

  • Rudolf Siebel, Managing Director, BVI German Fund Association

  • Roland Spurr – Equities Business Manager – AllianceBernstein

  • Richard Taylor, Head of EMEA Equity Research, Jefferies

See the full agenda here

6 Key Takeaways from our Research Unbundling Poll

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.

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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.

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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.

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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.

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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?

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Question 6: The regulations will provoke a “day of reckoning” between providers and consumers to the benefit of:

Quality providers

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.

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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 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!

FICC Research: Our Panel’s 7 Key Takeaways

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.

5 Key Takeaways from Unbundling Uncovered ‘16:

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 with “mail” in the subject field and we’ll include you.

5 things You Need to Know About Regulatory Change in the Research Market

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

  1. 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

If you have any comments, questions or suggestions please email us on

Client Fairness – the dealbreaker for RPAs?

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 from December 10th and free to view.

If you have any comments, questions or suggestions please email us on

Credit and macro research amid regulatory change (video)

How will research unbundling impacting credit markets and research coverage

Substantive Research interviews leading executive from credit research firm, CreditSights

on how research unbundling will impact the business of credit research.