Cost Transparency Initiative

COST TRANSPARENCY INITIATIVE

Welcome to the Cost Transparency Initiative. Our members share a commitment to implementing, promoting and encouraging the use of new cost transparency templates to standardise costs and charges information for institutional investors. This will improve governance and help investors make informed decisions.

Key aims

The CTI will:

  • Provide a clear voice for the interests of asset owners as we improve cost transparency. 
  • Run a pilot phase to test the new cost transparency templates and supporting technical and communications materials until January 2019.
  • Following the pilot, roll-out the templates to the asset management and pensions industries to encourage fully transparent and standardised cost and charge information for institutional investors.

OUR WORK

In November 2018 the CTI was launched and became the organisation taking forward the work of the previous Institutional Disclosure Working Group (IDWG).  

We are currently in the process of launching a pilot to test the templates with a number of schemes.  If you are interested in participating in beta testing the template please contact us.

History of the templates

The Financial Conduct Authority launched the Institutional Disclosure Working Group (IDWG) as part of the remedies package designed as a result of the asset management market study. The IDWG started work from September 2017 and made its final recommendations to the FCA in June 2018. 

The FCA wanted to see more consistent and standardised disclosure of costs and charges to institutional investors. It thought that 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.

The FCA appointed Dr Chris Sier to chair a working group of industry and investor representatives on institutional disclosure, with a view to agreeing a template. This working group, the IDWG, made recommendations that sat alongside and supported several other recent interventions which also impact the way institutional investors interact with their asset manager. 

A summary of the IDWG's recommendations can be found on the IDWG webpage, which also includes links to other relevant information, including summary minutes of IDWG meetings. 

Who we are

The CTI is partnership initiative between the Pensions and Lifetime Savings Association (PLSA), the Investment Association (IA), and the Local Government Pension Scheme (LGPS) Advisory Board.

At the launch of the initiative Mel Duffield, Chair of the Cost Transparency Initiative, said:

“I’m delighted to have been appointed as the inaugural Chair of the Cost Transparency Initiative. It hasn’t always been possible for trustees to compare costs between different services because of a lack of clarity and consistency. By introducing a robust way to define and measure the full cost of investing, we have a golden opportunity to make a real difference across the institutional investment market.

“I’d like to thank all the members of the IDWG for their hard work getting us to this point and I look forward to taking the baton forward with the other Cost Transparency Initiative members. We are looking to have an excellent mix of experience and skills in the new group which will ensure we are well placed to deliver this important piece of work.”

Julian Mund, Chief Executive of the PLSA said:

The PLSA is committed to taking forward the work of the IDWG and is pleased to be playing a key role in support of its successor body. This is a step forward for cost transparency where both schemes and providers benefit from one common, standardised way of assessing and providing costs.”

Chris Cummings, Chief Executive of the Investment Association, said:

“We welcome the launch of the Cost Transparency Initiative. Our industry is fully committed to transparency of costs and charges for all investors. We look forward to working closely with the PLSA and Local Government Pension Scheme Advisory Board to build on the progress of the IDWG, to deliver a template which will enable costs and charges to be reported in a clear and comparable manner for institutional investors."

Cllr Roger Philips, Chair of the Local Government Pension Scheme Advisory Board, said:

“The Scheme Advisory Board continues to be fully supportive of investment cost transparency initiatives as demonstrated by the introduction of its own Code of Transparency which now covers some £180bn of scheme assets. The Board is delighted to be part of taking the work forward to the wider institutional space which will enable trustees to make fully informed, value led investment decisions and further trust in the sector by embedding clarity and openness in a previously opaque market.”

Chair

The CTI is chaired by Mel Duffield. Mel has a long and dedicated history within the sector and is currently the Pensions Strategy Executive at the Universities Superannuation Scheme, the hybrid pension scheme for academics and related roles in the UK higher education sector.

Before joining USS, Mel was Deputy Director at the Pensions Policy Institute, and the Head of Research and Strategic Policy at PLSA.

Steering group and working group

We will set up a steering group and technical working group soon - further information will follow.

Templates

The IDWG template includes five templates: 

User template: summarises data from an account-level template (see below) so institutional investors can easily see the key data from their providers, as well as easily segment data along dimensions such as asset class or manager. 

Main account level template: covers most product types, capturing data from providers in one place and therefore populated through three further sub-templates where costs specific to certain asset classes are needed. 

When designing the templates the IDWG considered the investor needs for disclosures and has designed the templates with the needs of different kinds of investor in mind, in terms of the amount of detail included and the desired format of any disclosures. 

IDWG templates are shown for informational purposes only.

Report

The IDWG made its recommendations in the form of a report to the FCA. This report included the templates as well as recommendations on: 

  • What arrangements need to be in place to ensure the templates are maintained
  • How to encourage providers to offer information using the templates
  • How to encourage more users to request information in this format from their providers

Pilot 

We are in the process of launching a pilot to test the templates with a number of schemes. This includes testing of the technical and communication materials. 

If you are interested in participating in or hearing more about the pilot please contact alyshia.harrington-clark@plsa.co.uk.

What is the Cost Transparency Initiative? 

The CTI was launched to take forward and update the framework proposed to the FCA by the Institutional Disclosure Working Group (IDWG). It will ensure the effective rollout of the new cost transparency templates and make sure that they are relevant both now and in the future.  

What costs are covered by the templates? 

Within asset types, costs under consideration will be those, both direct and indirect, that draw down directly on the value of the funds of the asset owners. Broadly ‘direct’ costs include invoiced and invoiceable costs, whilst ‘indirect’ include implicit costs that are reflected in a reduced net performance figure. Costs that are borne by the P&L of a supplier are out of scope. 

By way of an example; where an asset owner is charged for research through a research payment account, this would typically be in-scope. However, where research costs are absorbed by the asset manager and are not passed on, these will be out of scope. 

Do the templates include the alternatives space? 

The IDWG has considered alternative asset classes including private equity, physical assets, cash, foreign exchange and derivatives. For example, the IDWG proposed separate private equity and physical assets templates. 

When will the members/participants of the CTI be announced? 

We anticipate providing further information on the members of an participants in the CTI imminently. 

How does the CTI differ from previous and existing work in this space? 

The IDWG – on which the CTI tools are based – had a strong commitment to consider the existing work and this was written into their Terms of Reference. 

Sub-working groups of the IDWG built on standards already proposed by organisations representing fund managers and product types, and this included proposing amendments or adding new content or fulfil the stated aims of the IDWG. For example, the templates already proposed for use by the Local Government Pension Scheme Advisory Board are a form of aggregated fund- or product-level account template, and is already comprised of information based on underlying asset classes. 

The CTI is broader in scope than earlier work by the IA, LGPS, ILPA etc. which focused on only some asset classes. The CTI approach to the fund/product level template has been expanded to cover the full market, including alternatives. 

How and when will the tools be updated in the future? 

The tools will be updated in the future on a periodic basis, or as and when needed. It is not expected that the periodicity of updates will be frequent as otherwise this could be burdensome for users of the template. 

Collaborative Partners


Get in touch


If you want to know more about the CTI or are interested in participating in our pilot scheme please contact: alyshia.harrington-clark@plsa.co.uk

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