Cost Transparency Initiative

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Pensions and lifetime savings association | The Investment Association | LGPS Advisory Board

Cost Transparency Initiative

The new industry standard for institutional investment cost data.

Pensions and lifetime savings association | The Investment Association | LGPS Advisory Board

Cost Transparency Initiative

The new industry standard for institutional investment cost data.

Welcome to the Cost Transparency Initiative, a new industry standard for institutional investment cost data. The availability of comprehensive and transparent information on costs and charges is important in helping investors to decide whether investments represent value for money. We've created a set of templates and tools which together form a framework investors can use to receive standardised cost and charges information from asset managers.

Along with the templates, which are open source and free to download, we also provide guidance for pension schemes and their advisers on how to make use of cost information, and for asset managers on how to provide cost information to their clients.

These templates and tools are free to download and use. Some of the tools are intended for use by investors and others are intended for use by asset managers. 

The fiduciary Management Template

The Fiduciary Management Template is a cost disclosure template which may be completed by fiduciary managers. 


The user summary

The User Summary can be used by pension schemes, and their advisers, to provide a summary of key information. It is an illustration of the categories of costs and charges information which you will receive from your asset manager, through the standards. 

This format is for illustrative purposes only. Investors should discuss with their asset managers, their consultants or advisers, or third party information providers, the format in which they would like cost information to be provided. 



Q. Who completes the User Summary?
A. Generally, you or your adviser can use the information provided in the other templates to create User Summaries.

Q. Can I see all of my costs in one total? 
A. For those mandates which you have the data you could combine the same labelled funds into a total.

Q. Can the user template summarise more than one account template?
A. Yes - the user template can provide summaries across as many account templates as relevant to your circumstances.

The main account templaTE

The Account Template is the main cost disclosure template to be completed by asset managers. It covers the majority of assets and product types. It can also collect data in one place from other sub-templates, for specific asset classes, such as private equity.

The Account Template has been designed to be ‘machine readable’. This means that providers of data can ensure the fields are consistent and compatible across different internal systems, and data can be easily extracted and processed. This also incorporates technical guidance and definitions for asset managers to use as an aid during completion.  

  • You should discuss with your asset manager how your cost data can be provided.
  • We expect most managers will seek to automate reporting but this may not be available immediately.



Q. Who completes the main Account Template?
A. Asset managers or relevant service providers.

Q. What is a machine readable template?
A. This is a format that a computer can understand. 

The Private Markets SUB-template

The Private Markets Sub-template is a cost disclosure template to be completed by asset managers of closed-ended private equity, private debt and real estate (property) funds. 

The information provided in the Private Markets Sub-template may be used to populate the Account Template, or it may be used as a standalone template. 



Q. Who should complete the Private Markets Sub-template? 
A. The sub-template has been designed for some closed-ended funds, investing in private equity, private debt and real estate (property) or real estate (property) debt. These are typically limited partnership structures with a fixed, finite life.  

This was previously known as the ‘Private Equity Template’ which has now been archived.

Q. If firms use the ILPA reporting template, do they need to complete the CTI Private Equity Sub-template?
A. You should discuss with your manager whether you would like your costs disclosed in the CTI format, even where you currently receive the ILPA format. This is because the ILPA template includes the items covered by the CTI Private Markets Sub-template. Investors may wish to request data in the CTI format, particularly because the CTI Private Markets Sub-template uses terminology that is more familiar in the UK (and Europe) and follows the level of granularity included in the CTI Main Account Template. The CTI Private Markets Sub-template also has the advantage that it is based on the Invest Europe Investor Reporting Guidelines and this will aid consistency in reporting to investors in private equity funds.

The CTI provides a mapping the two templates to help users identify the relevant line items. We hope that the mapping exercise can reduce the amount of duplicative reporting requests. 

Q. Is there additional guidance for property funds?
A. Additional guidance can be found in the Investor’s Private Markets Glossary of Terms and on the dedicated Association of Real Estate Funds FAQs page

Liability Driven Investments Template (Preliminary)

This template is intended to be used by managers reporting costs associated with Liability Driven Investments (LDI). 

The template is in preliminary form, for consultation, and we welcome your views and comments on how it could be improved. Download supporting notes to the preliminary template here

Please send your feedback to: [email protected]

Theses guides are designed to help you use the CTI templates and tools. 

CTI Top Tips

Our top tips for understanding and using the CTI tools and templates.

Fiduciary Management Template GLOSSARY OF TERMS

This document provides a glossary of terms used in the fiduciary management template for investors and their advisers.

Investor’s ‘How To’ Guide

This document provides guidance for investors on how to use CTI templates and tools. It contains a step by step guide, an explanation of the data investors can expect to receive, and how this relates to value for money. 

Investor’s Glossary of Terms

This document provides definitions of the fields within the User Summary and it provides illustrative examples of typical content.

ACCOUNT TEMPLATE Glossary of terms

This document provides guidance for asset managers on how to complete the Main Account Template.

Investor’s Private Markets Sub-template Glossary of Terms

This document provides definitions of the fields within the Private Markets Sub-template and it provides illustrative examples of typical content. This document was previously known as the Glossary of Terms: Private Equity Sub-Template which has now been archived.


This document provides mapping between the ILPA template and the CTI Private Markets Sub-template to help users idenitfy the relevant line items. We hope that the mapping can reduce the amount of duplicative reporting requests, given that the ILPA template includes the items covered by the CTI template.


Links to more Cost Transparency resources

Trustee toolkit – The Pensions Regulator (TPR) 

TPR produces a trustee toolkit which contains modules on a number of relevant topics:

  1. Core learning: An introduction to investment – reviewing investments
  2. Defined Contribution (DC): How a DC scheme works
  3. Defined Benefit (DB): Investment in a DB scheme

Visit TPR trustee toolkit.


The IA website hosts guidance and materials on cost transparency.


The AREF website hosts FAQs as a result of participation in the CTI Technical Expert Panel and an AREF working group which has prepared guidance for AREF members using the template.  

Cost Transparency: Made Simple Guide –  The PLSA

The PLSA produces its own guidance on cost transparency. See Cost Transparency ‘Made Simple’ and the webinar archive.

The LGPS Transparency Code – LGPS Advisory Board

The LGPS Transparency Code will make use of the CTI framework (following a transition period). Further information and guidance, local government investors and their asset managers, is available on the LGPS website



Q. Is the intention for the CTI approach to be adopted by the industry as a whole?
A. Yes. The CTI provides an industry standard for transaction cost reporting. Full coverage of the voluntary standard will however depend on strong engagement by investors, asset managers and intermediaries.

Many asset managers who manage public funds are already signatories to the LGPS Transparency Code and have therefore transferred to the CTI templates by 2020.  

Q. What are the CTI’s expectations on timing of take-up?
A. We expect trustees and advisors to regularly engage with their managers about obtaining information. 
In the year following launch of the standards we  expect managers to be able to report against the published templates by no later than their scheme’s reporting year end after initial launch (i.e. from either December 2019 or April 2020). We expect future reporting years to follow, as a minimum, a similar reporting cycle.

We will continuously review take-up, by investors, intermediaries and managers, following the end of the April 2020 reporting period. If it’s below what we expect, we’ll talk to the FCA and TPR (and other market participants) about how we can increase it. 

Scope of the CTI

Q. What costs are covered by the CTI templates? 
A. The CTI framework provides a suite of open-access templates which provide a standardised way for asset managers to report costs and charges to investors (asset owners).  
The templates cover costs which draw down directly on the value of the funds of the asset owners. This includes direct costs (costs which can be invoiced) and indirect costs (implicit costs that are reflected in a reduced net performance figure). Costs that are borne by the manager or service provider are not included in the templates.  

Further details of definitions of the fields of costs are in the templates and guidance.  

Q. Will the CTI hold any cost and charges data?    
A. The CTI does not gather or hold cost data. The cost and charges information gathered through the templates is reported directly to investors (or via third party information services or consultants).  

Q. Does this framework extend to retail consumers and should charges information be passed on to savers?
A. The CTI framework is aimed at institutional investors and the information is not likely to be of direct interest to retail consumers. It may be appropriate, however, to include summaries of some of the information in member communications or publications such as a Chair's statement. 

Q. Does the framework cover DC?
A. The CTI framework is intended to be compatible with any regulatory or governance structure for all institutional investors, as it focuses on the costs and charges of investment and not on the structure of the management/governance. 

Q. What is the jurisdictional scope of CTI?
A. The CTI scope covers all UK institutional investors. It does not, for example, rely on UK domicile.  

Q. Which template should I use for a segregated mandate or a pooled fund?
A. The account template can be used for either pooled or segregated mandate types, for any vehicle.  

Disclosing information using CTI and completing CTI template requests

Q. Who completes the main Account Template?
A. Asset managers or relevant service providers.  

Q. Which template is for which asset class?
A. The Account Template covers listed asset classes, including pooled property. The Private Markets template covers closed-ended private equity and real estate funds, typically limited partnership structures with a fixed, finite life. 

Further templates covering other asset classes are in development.  

Q. Should costs be rounded?    
A. No. Actual figures/costs should be used rather than rounded amounts. 

Q. How frequently should the templates be created?
A. Unless you have specifically agreed otherwise, expect to receive the templates once a year. You or your manager may wish to agree to a more regular reporting schedule, though please bear in mind that the CTI is designed for annualised reporting.  

Q. Over what reporting period should the templates be completed?
A. Figures should be annualised – unless specifically noted otherwise, or unless your client has requested a different reporting period. The reporting period should be marked clearly in the relevant fields. If the client has been invested for less than one year discuss your approach directly with your client.  

Q. Do the disclosed figures need to be audited? 
Clients may expect the completed templates before the accounts have been audited. In this case firms could put a note in the comment box explaining that information provided is provisional. Figures should be adjusted and resent to clients if the auditors subsequently request a significant adjustment to the financial accounts.

Q. Can the templates be modified for different investors?
A. Additional notes and/or detail may be helpful to aid recipients’ understanding of the information contained in the template, or to add further information where specific agreements are in place with certain investors. We do not recommend that the template is changed, as this would then require additional notes to explain these changes. For example, certain cells have been protected/locked to ensure formulae are not overridden or accidentally altered.  

Q. How long do I have to complete the template for my client, following receipt?
A. Timelines should be agreed between the client and provider in advance. If your firm is adapting systems to complete the templates you should notify your client as soon as possible and seek to provide relevant information on a best endeavours basis. 

Q. What implicit transaction cost calculation methodology should I use?
A. Your asset manager or service provider may choose to include a reference to the calculation methodology they have used to, for example, disclose their transaction costs. These could include:  

  • Regulatory methodologies (for example, PRIIPS slippage)
  • Industry standard methodologies (for example, GIPS performance data) 

Your manager will be ready to provide further information if you have any detailed questions on methodology.  

CTI does not define Implicit Transaction Cost methodology. Your approach should reflect your firms’ wider approach to MiFID.  

Q. How do I complete the template if I have a single annual charge?
A.  If your fees structure is a single annual charge then you will not need to break down this fee into its component parts (i.e. you should not retrospectively ‘allocate’ costs to different fields artificially). However, if certain fields listed in the template are not components of your annual charge and may still be charged to the client these fields should be completed. It is best practice to make clear to your client which fields are included in the single annual charge to aid their understanding. 

Q. When should I complete those templates released in 2020?
Investors can begin to work with managers to deliver information included in the 2020 release templates and extensions (LDI, fiduciary management and real estate). Investors should understand that managers may need to complete development work in order to deliver completed templates. 

Managers should be ready to deliver these templates for the 2020/21 reporting year at the latest. 

Interpreting information provided in the CTI format

Q. What skills and knowledge do investors need to use the CTI framework?
A. The CTI framework is designed to sit alongside existing regulatory requirements and, therefore, investors should be well equipped to use this information to help discharge their duties. An important part of what investors do is consider the value for money of the asset management services they make use of. Having access to readily available and standardised costs and charges information will help them assess this. The CTI provides guidance on the tools they create and there is already guidance and advice available in the market for investors.  

Q. What should I do with the information I receive from my manager?
A. The Investor's 'How To' Guide sets out several steps to make best use of the information, including in relation to wider value for money assessment. You can also discuss with your adviser how best to make use of information.  

Q. Can I share/publish the cost information I receive from my manager?
A. You must discuss with your manager what, if any, information it may be appropriate to share or publish.  

Q. How long will it take my asset manager to complete the template once requested?
A. Discuss the timelines with your service providers to understand what a reasonable expectation is in your circumstances. This will highly depend on the processes, procedures and technology that your asset manager has. Some managers may be able to provide the information very quickly after you have requested it. Other asset managers may want to undertake additional data checking, be dependent on third party data providers or any number of other complexities.  

Q. What will the information look like when I receive it from my manager?
A. You should discuss format in advance with your manager, and your adviser or third-party information provider if you have one. An illustration of how the information could be provided is available in the User Summary, which can be downloaded from the CTI website.  

Q. Who completes the User Summary?
A. Generally, you or your adviser can use the information provided in the other templates to create User Summaries.  

Q. Why can I not see everyone else's costs? Where is the central database?
A. The CTI does not currently collect or retain cost or charges data itself - it is intended only to facilitate information requests and the collection of data from asset managers according to an industry standard. However, you may wish to speak to third party information providers who may offer data presented at aggregate level and/or benchmarking against other service providers. 

Q. What is a machine-readable template?
A. This is a format that a computer can understand and use to automate data reporting.  

Q. If my manager/service provider uses the machine-readable format, what will I receive from them?
A. The machine-readable format of the main Account Template is available to make it easier for firms to provide data in a way which is compatible with their systems and to allow computers to easily extract and process the information. Your asset manager should be able to provide this data to your adviser or information provider in a way which can be easily translated into a readily understandable (e.g. visual) format. Alternatively, you or your asset manager may be able to map this information directly into a format similar to the User Summary (available on the CTI website). 

Q. Not all fields are completed - is this correct?
A. In some cases, only a few fields (for example, in the Account Template rows 25-40) will need to be completed. Incomplete fields do not necessarily indicate an error. First, consider whether your provider charges a single annual charge. If this is the case, the headline figure disclosed (for example, in Ongoing Charges, will include all the relevant cost information). Secondly, consider whether any of the charges will not apply to your investment due to, for example, asset class, structure or the business model of your asset manager. Finally, the top level charges may have been completed leaving additional, optional fields blank. If in doubt speak to your asset manager. 

Q. Where is the guidance for the old (2019) templates? 
A. The changes to the private markets template (previously the private equity template) were an evolution. Additional fields are those relating to property funds. Otherwise, existing guidance for private equity funds has remained largely unchanged. Please, therefore, refer to the current guidance.  


Q. How does it interact with LGPS Code of Transparency?
A. Existing Code signatories will be encouraged to make use of the new templates as soon as possible but will have a transition period of up to 12 months (which expired in 2020) to ensure they can adapt systems without interrupting the current flows of data. New signatories, including those real estate and private markets managers who can take advantage of the new templates will be expected to use them immediately. 

Q. What is the system for the LGPS funds and pools (Byhiras)? 
A. The system, procured by the Local Government Pension Scheme Advisory Board, developed by Byhiras and launched on 1 April 2020, provides data validation and aggregates data about fees in line with the CTI framework. The system enables the reporting and comparison of investment costs and also provides information about whether a template submission is on time or late. 

LGPS funds across the UK can benefit to the system either directly or through a sharing arrangement with the relevant Scheme Advisory Board. There will be no further cost to the LGPS funds across the UK for use of this system over the amount they already pay to their respective scheme advisory boards. 

Further information can be found on the FAQs section entitled ‘System’. 

Q. What is the system for managers with LGPS clients (Byhiras)? 
A. Managers who have signed up to the LGPS Code of Transparency should already have processes in place to submit the template data in line with other reporting practices. The manager has a default of 90 days after the relevant period end to submit completed templates, though if there is an existing shorter time period agreed then you should continue to comply with this. 
For Code related queries managers should contact the SAB secretariat, for template queries either the SAB Secretariat or the CTI and for system related queries they should contact Byhiras.

Q. Who can use the LGPS system/Byhiras system? 
The system was designed for the LGPS Advisory Board and provides each fund and pool to access to information about costs.

CTI history and next steps

Q. How does the CTI relate to the IDWG and the draft templates it published?
A. The FCA released the IDWG’s final report in November 2018, which included draft reporting templates. This set the conceptual framework for what information investors need and what information asset managers should provide. 

The CTI has had the responsibility since then to operationalise this. It has overseen a significant process of testing and development, including a pilot which was concluded in March 2019.  Further details of the background to CTI are available on the website. 

Q. What will the CTI Board do next?
A. The CTI Board will keep the templates and the reporting process under a process of review and continual improvement. This will include extending the framework to cover new areas.
It is also the Board’s responsibility to promote the CTI amongst the pensions industry and to monitor take-up.  

Q. What is the CTI’s approach to the COVID-19 pandemic? 
A. The CTI Board discussed COVID-19 in their meeting on the 25th March 2020. At a high level the Board agreed to continue to continue to operate in line with their agreed 2020/21 plan, with some caution and with more regular review points given the emerging circumstances. Generally the Board are positive that, though there may be some operational issues that may limit the scope and speed of both engaging with and adopting new standards, existing CTI templates are considered to be embedding well and are not anticipated to be materially impacted by COVID-19. 

Investors and providers should discuss pragmatic approaches to dealing with challenges to delivering in line with the CTI templates as they arise. 

The CTI Board welcomes further feedback on COVID-19-related issues. 

Q. How do I provide feedback on the templates, or get involved in their development?
A. Please contact [email protected] in the first instance. 

The CTI Framework: Three years on

Since we launched the CTI framework online, in May 2019, the CTI Board has been working to encourage wide adoption of the CTI framework, right across the pensions industry. 

The CTI framework has now been very widely adopted by investment management firms and we expect adoption will continue to increase. 

In the CTI Board’s Perceptions of the CTI Framework – a survey of schemes and advisers that took place between October 2020 and January 2021 – we found that 74% of respondents said they have a good level of awareness of the CTI framework. Over half of respondents said they have already used the CTI framework either directly or using third-party information providers or intermediaries.

Utilities (third party information providers)

The CTI Board welcomes industry innovation to help deliver transparency and third party information providers, or ‘utilities’, can play an important role in this, working alongside other intermediaries. We have worked closely with utilities over the course of the year and their positive feedback demonstrates that there are good levels of take up of the CTI framework. 

Regulatory and reporting alignment

The CTI framework is not a regulatory requirement. However, over the course of the year, the CTI Board and secretariat has kept in close, ongoing contact with the Government, regulators (Financial Conduct Authority (FCA) and the Pension Regulator (TPR)) and other external organisations, to ensure the CTI framework is kept current and in step with any policy or statutory developments. Additionally, the Department of Work and Pensions (DWP), FCA, TPR and Trades Union Congress (TUC) continue to hold ‘observer’ status on the Board. 

The CTI Board also set up a Technical Expert Panel (TEP) in September 2019, composed of a range of technical experts from across industry, to help provide feedback and testing of new tools and guidance with expert practitioners. 

The CTI Board responded to the Competition and Markets Authority (CMA)’s Investment Consultancy and Fiduciary Management Market Investigation Order 2019, which led us to publish earlier this year a bespoke fiduciary management reporting template (see tools and guidance).  

Additionally, we have sought to ensure that the CTI framework is compatible with other regulatory and costs reporting regimes, recognising that firms often have multiple reporting or compliance demands upon them. With the assistance of the British Private Equity and Venture Capital Association (BVCA), we have reconciled how the Institutional Limited Partners Association (ILPA) Fee Reporting Template with the CTI templates, and we provide specific guidance on this. We have also coordinated with the Association of British Insurers (ABI) to ensure appropriate alignment with the DC Workplace Pension Template. 

Educational and promotional initiatives

As well as providing the training and guidance materials, CTI Board members and the partner organisations (Pensions and Lifetime Savings Association (PLSA), Investment Association (IA) and LGPS SAB) continue to take part in a range of educational and promotional activities, including conferences and events, webinars and educational partnerships with utilities. 

New tools and guidance

The CTI framework continues to follow an ongoing process of development and improvement. Since the framework was published online last year, we have developed additional tools and guidance:

  • A new Fiduciary Management Template
  • Additional reporting fields on the Liability Driven Investments (LDI) Template
  • Real estate investments guidance on completing the templates
  • ILPA/CTI mapping guidance for private equity investments
  • Additional FAQs and guidance, including on timeline and expectations
  • Additional case study and webinar resources

Over the rest of this year, the CTI Board will continue to take forward and develop any additional templates/datafields and guidance, according to the needs of the industry. 

Who we are Who we are

The CTI is a partnership initiative between the Pensions and Lifetime Savings Association (PLSA), the Investment Association (IA) and the Local Government Pension Scheme (LGPS) Advisory Board. These organisations, representing different interests within the pensions industry have come together with a commitment to:

  • promote understanding, raise awareness, and encourage full transparency and standardisation of costs and charges information for institutional investor
  • co-operate in creating a new body (the CTI Board) to curate, test and update the framework set out in the final Institutional Disclosure Working Group’s (IDWG) report (see below)
  • deliver industry standards on cost disclosure

Find out about our board Find out about our board

The CTI Board governs the initiative. Amongst its objectives, the Board:

  • Provides a clear voice for the interests of asset owners, as it improves cost transparency, raising awareness and supporting institutional investor education
  • Takes forward, tests and updates cost transparency templates, tools and other materials
  • Roll outs templates and tools to the asset management and pensions industries to encourage fully transparent and standardised cost and charges information for institutional investors
  • Supports related efforts through the advocacy, engagement and capability related measures in the institutional cost disclosure and investor space

Board members

Mel Duffield (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.

Jenny Condron

Jenny is Chair of the Association of Consulting Actuaries. 

She joined Mercer’s Edinburgh office in 1991 as an actuarial student and has spent the following years working with a broad range of clients and their pension arrangements as both a Scheme Actuary and corporate actuary.  She transferred to Mercer’s Glasgow office in 1998 and then moved to their Windsor office as the Retirement Business and Local Market Leader in 2007.  She became a Mercer Partner in 2012 and was appointed as Mercer’s Chief Actuarial Officer in 2017.  She led Mercer’s DB Wealth businesses in Woking and London in 2017 and is a member Mercer’s DB Wealth leadership team. 

Added to these appointments, Jenny has been an Officer of the Association of Consulting Actuaries, acting as Honorary Treasurer from 2016-2018.  She also chaired the ACA's Professional Affairs Committee until end 2017. Jenny Condron graduated from Oxford University in 1991 with an MA in Mathematics.  She qualified as a Fellow of the Institute and Faculty of Actuaries (IFoA) in 1994.

Joe Dabrowski    

Joe is the Head of DB, LGPS and Standards at the Pensions and Lifetime Savings Association (PLSA). The PLSA is the voice for pensions and lifetime savings in the UK, representing over 1,300 pension schemes with just over £1 trillion in assets under management. Its mission is to help everyone achieve a better income in retirement.

He was formerly a member of the Institutional Disclosure Working Group, and at the PLSA is responsible for policy areas including defined benefit provision, pension scheme governance, corporate governance, the Pension Quality Mark and institutional investment issues. Joe is an advisor to the Local Government Pension Scheme Advisory Board, and in recent years led major projects for the PLSA including its DB Taskforce. 

Jason Fletcher    

Jason is Chief Investment Officer at LGPS Central Limited, which he joined in October 2017 at its inception. He is Chair of the LGPS Central Investment Committee and is a Member of the LGPS Central Executive Committee. He has over 28 years’ experience working as an active portfolio manager, asset allocator, Deputy CIO and CIO. He has previously worked at British Airways Pension Fund, Universities Superannuation Scheme and West Midlands Pension Fund. Jason holds a degree in Economics from the London School of Economics and is an Associate Member of the CFA Society.

Adam Henley 

Adam is Head of European Product Development for JPMorgan Asset Management.  His team is responsible for developing and managing the documentation of JPMorgan Asset Management's Pan-European domiciled open-ended fund ranges.  An employee since 2000, Adam was previously Head of Product Development for the Americas and prior to that was responsible for project and business management with the U.S. Managed Accounts business, focusing on the development of the platform and infrastructure.  Adam holds a B.S. in Finance from Boston College.

Jane Ivinson      

Jane was appointed as General Counsel of Insight in November 2011 and is responsible for managing the compliance function and legal risk of Insight. Jane joined the Executive Management Committee in May 2016. Before joining Insight, Jane worked at BlackRock (and its predecessor companies) as Head of the Legal Team for all issues in EMEA. She has also worked as a solicitor at Lloyds of London and started her career in 1990 at Kingsley Napley. Jane has a first class LLB degree in Law from the University of Warwick and a BCL degree in law from the University of Oxford. She is a member of the Law Society and holds the Investment Management Certificate from the CFA Society of the UK. 

Jonathan Lipkin

Jonathan joined the IA in 2005, becoming Director of Public Policy and a member of the IA Executive Committee in 2012.  His current role focuses on policy and regulatory issues affecting the investment management industry, particularly competition, disclosure and governance.  He is also responsible for IA market insight and research, and broader strategic positioning. Jonathan is a Board Member of the Cost Transparency Initiative and Chair of the EFAMA Pensions Group.  Jonathan is a member of the Advisory Board of the Centre for Asset Management Research at Cass Business School.

Gupreet Manku    

Gurpreet Manku is the BVCA’s Deputy Director General and Director of Policy. She is responsible for leading the BVCA’s response to a wide range of issues and challenges facing the industry from a legal, tax and regulatory perspective, both in the UK and Europe. She is also the executive liaison to the Private Equity Reporting Group, the body responsible for monitoring the industry’s compliance with the Walker Guidelines on Transparency and Disclosure. Before joining the BVCA she worked at Deloitte LLP and specialised in advising and auditing private equity funds and their managers. Gurpreet studied at the London School of Economics and is a Chartered Accountant and a fellow of the Institute of Chartered Accountants in England & Wales.

Robert Waugh    

Robert has over 30 years’ experience of managing pension funds, both as a fund manager and as an asset owner.  Robert is CEO and Co- CIO of The Royal Bank of Scotland Group Pension Fund, responsible for the assets in the Group Pension Fund (c. £44bn). He joined RBS in January 2010. Robert was a Trustee and Chair of Trustees of the RBS DC scheme from 2010 to 2017. Robert was a Non-Executive for the investment committee of DFID from 2012 to 2015.  He spent 6 years as Head of UK Equities at Scottish Widows Investment Partnership between 2003 and 2009 responsible for managing segregated and pooled mandates for clients and performance of the UK equity desk of 12 investment professionals and £15bn of assets.  

Robert started his career in London with Phillips & Drew fund managers (latterly UBS Asset Management) in 1986, remaining with the firm for 15 years, managing pension fund assets on behalf of corporates and public bodies.  He moved to Scotland in 2001 to head up UK equities at Edinburgh Fund Managers before moving to Scottish Widows Investment Partnership in 2003.  

Find out about the background of the CTI Find out about the background of the CTI

The pensions industry has benefited from an ongoing trend towards greater transparency of costs and charges over recent years – the CTI helps to consolidate this trend.  

LGPS Code of Transparency

One of the first developments was in relation to local government pension funds. During 2016 the IA worked closely with the LGPS Advisory Board on the development of a cost disclosure template which was subsequently adopted by the LGPS Code of Transparency. This template was issued as part of the LGPS Code in May 2017 and it will be replaced by the CTI templates, following a transitional period. 

The Financial Conduct Authority’s (FCA) Asset Management Market Study

Duuring this period the FCA also undertook a market study of the asset management industry and published its final report in June 2017. The report concluded that there was weak price competition in a number of areas of the asset management industry. 

The FCA found that some institutional investors find it difficult to obtain cost information on a consistent basis and this is likely to limit their ability to drive competition and obtain value for money. 

The FCA subsequently convened the IDWG, with the objective ‘to gain agreement on standardised templates of costs and charges for both mainstream and alternative asset classes’.  

Institutional Disclosure Working Group (IDWG) recommendations

The IDWG included a range of independent experts, institutional investors and advisers, asset managers, and a secretariat provided by the FCA. It held its first meeting in September 2017 and met regularly, before reporting its findings to the FCA in June 2018.  

The IDWG made a series of recommendations, the key recommendation being to set up a new body or group to curate, test and update the framework (representative of a wide range of stakeholders). This led to the establishment of the CTI Board. 

The IDWG also recommended that the FCA should consider writing rules if: 

  • There is poor adoption of the rules by institutional investors or their providers
  • Institutional investors report difficulties in obtaining cost data to the level proposed in the templates from their providers, or; 
  • Providers are found to have misrepresented data via the templates to clients. 

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


Perceptions of the CTI Framework

Between October 2020 and January 2021, the CTI Board conducted a survey to understand how the industry has utilized the CTI Framework since its inception in 2019. Check out our 2021 report, Perceptions of the CTI Framework, to understand the framework’s usage and effectiveness in supporting the industry in understanding institutional investment cost data – plus, the CTI Board’s continued commitment to improving this tool.


Getting value from the CTI

The Cost Transparency Initiative has brought a close focus and real results on investment costs for pension funds. You can make the CTI tools work for your scheme or Local Authority fund too and get the most value from your consultants and utilities. DB and DC schemes, LGPS funds and consultants will benefit from this view of the CTI in action.

In this webinar the PLSA team present case studies demonstrating how the CTI delivers value, and answer questions about how to understand your investment costs.

Cost Transparency Initiative Chair Mel Duffield is available for interviews upon request. For more information about the Cost Transparency Initiative and biographies of Board members, see the About CTI section. 

Press releases

12 May 2021: Cost Transparency Initiative delivering tangible benefits as take up increases
24 June 2020: PLSA comments on review of the default fund charge cap and standardised cost disclosure
19 June 2020: Cost Transparency Initiative launches additional tools following strong industry take up
5 September 2019: Top pension schemes commit to Cost Transparency Initiative
5 August 2019: Cost Transparency Initiative responds to Work and Pensions Select Committee report on pension costs and transparency
21 May 2019: New tools allow pensions schemes to deliver greater value for savers
14 Jan 2019: Cost Transparency Initiative welcomes new board members
7 Nov 2018: Launch of Cost Transparency Initiative will be a step forward for pension schemes

Press contacts

Mark Smith, Senior PR Manager
 020 7601 1726 | [email protected]

Cali Sullivan, PR Manager
 020 7601 1761 | [email protected]

CTI Case Studies

National Grid UK Pension Scheme CTI Case Study

RPMI Railpen CTI Case Study

RBS CTI Case Study

West Midlands Pension Fund CTI Case Study

Quotes about the CTI

High fees can eat into savers’ pension pots and add to employers’ costs. This initiative will help pension schemes take a holistic view of costs and charges as they strive to ensure their members get value for money. I’d strongly encourage trustees and investment managers to embrace the Cost Transparency Initiative and adopt the new templates.

Guy Opperman, Minister for Pensions and Financial Inclusion


As part of our role to protect pension savers, we welcome the CTI’s work to help trustees be clearer on the transparency of costs and charges levied on members. We will be working with trustees to highlight the benefits of these new standards, including how they can help with member engagement activities. The standards should be particularly helpful for defined contribution schemes as they have a duty to publish costs and charges information from their annual chair’s statements. The ability to obtain costs and charges in this standardised way will also enable trustees and scheme managers of defined benefit and public service schemes to strike better deals with their providers.

The Pensions Regulator (TPR)


This was a key remedy of the FCA’s asset management market study and is a positive final step completing the work of the Institutional Disclosure Working Group (IDWG). Institutional investors are now provided with the tools to give them a clearer and more detailed understanding of the charges of their investments. It is good to see investors working with industry to design a framework that can be a success for all. We are keen to see the positive momentum on greater transparency continue. We will be watching to see asset manager and service provider uptake which should ultimately lead to better investor outcomes. We are also pleased with the CTI’s ambition and welcome their intention to extend the standards into asset classes and service types not yet tackled. We would like to thank all of those who have participated in the Initiative to get it to the point of launch. The FCA continues in its role as an observer on the CTI Board. 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 the CTI.

Christopher Woolard, Executive Director of Strategy and Competition, The FCA


 It’s a testament to the desire and commitment of all those involved in the Cost Transparency Initiative that we can now welcome these new standards into the marketplace. The PLSA remains committed to helping pension scheme trustees deliver greater value for money for millions of savers. By doing this we can help those savers achieve a better income in their retirements.

Julian Mund, Chief Executive of the PLSA


As a founder member of the Cost Transparency Initiative, the Investment Association welcomes today’s launch. Our industry is fully committed to transparency of costs and charges, and we are pleased to see the work of the Institutional Disclosure Working Group come to fruition. As the framework rolls out, pension scheme trustees will have a better view of all costs, from both investment managers and other suppliers, and will be able to evaluate their delivery accordingly.

Jonathan Lipkin, Director for Policy, Strategy and Research of the Investment Association


The Panel welcomes the progress of the work of the CTI and its predecessor, the IDWG, to improve cost transparency. We hope there will be wide-spread industry take up of the CTI templates and that they become the market standard as part of the tools supporting value for money assessments by pension fund trustees, IGCs and other institutional investors. It's imperative that institutional investors insist on clear sight of costs and charges in order to protect the long-term savings of consumers.

Financial Services Consumer Panel


RPMI Railpen welcome the new cost templates being promoted by the Cost Transparency Initiative.  Having participated in the pilot of the templates we found they made our annual exercise of collecting full cost information for our investments much easier, as some investment managers were familiar with the request and all information was received in the same format.  Once the templates are used by a wider audience they will greatly assist in improving fee transparency in the industry, something both the Trustee of the Railways Pension Schemes and RPMI remain committed to.

RPMI Railpen


The now industry-wide standard for reporting costs transparently puts us all in a good place to deliver better outcomes for our members.  It’s been great to be part of the journey, which for West Midlands, has already delivered material savings without compromising return.

West Midlands Pension Fund


I’m delighted to see the release of the templates and guidance today by the CTI. They’ve done a great job in a short space of time and I fully support their work and ambitions. I will always be there to help, and look forward to continuing to work with the Board to deliver cost transparency across the market.

ClearGlass Chairman, Dr Christopher Sier


We commend the great work of the CTI through the launch of templates and guidance, that facilitates a standardised way for the UK pension industry to collect cost data. We have also welcomed the opportunity to consult on the new templates since the inception of the IDWG group, and in contributing to the CTI pilot ahead of the launch today.

Pat Sharman, UK Managing Director of KAS BANK 


Hermes GPE has always been an advocate of transparency and cost exposure - all clients should know exactly how the risk reward ratio of any investment strategy works. A common, consistent way of reporting costs that becomes an industry standard is therefore something we have been delighted to work on with the CTI. I’m really looking forward to seeing how quickly the private equity industry gets behind this initiative and universally adopts the new templates.

Karen Sands, COO/CFO, Hermes GPE LLP


Baillie Gifford supports the work of both the IDWG and the CTI. These new templates will give asset owners clear visibility of all the costs that managers incur to help them determine if they are getting value for money.

Baillie Gifford


The BVCA worked with private equity firms and their investors to create a template and guidance that provides clear information on the costs in private equity funds. We support the CTI’s efforts to promote this toolkit and hope our contribution as a board member demonstrates the private equity industry’s commitment to transparency.



Providing the necessary tools to easily allow our clients to make informed investment decisions has always been a priority for us. We welcome the CTI and recognise the importance in working together as an industry to provide a unified and transparent approach to the reporting of investment costs. This is why we have been extremely happy to take part in the template pilot, working closely with the PLSA, ensuring we continue to offer the best services to our clients.

Fidelity International

Get in touch

If you want to know more about the CTI or have any questions about our templates please contact: [email protected]

CTI Partners