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Published byNora Bond Modified over 9 years ago
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Global Buy Side Trading Consultants Ltd Unbundling Commission 0
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Background The FSA Rules Implications and Implementation 1
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An initiative from the UK regulator following a government report by Paul Myners in 2001 Underlying themes Commission is client money Lack of transparency Conflicts of interest Market failure Value for money Accountability 2
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Apply to firms in the UK regardless of client location Only execution and research Disclosure to clients of the respective costs of execution and research (unbundled). IMA level 2 disclosure Based on an ex-ante agreement between investment managers and brokers Soft commission banned, but commission sharing allowed in Europe, and Asia ex Japan (on shore clients), third party research agreements / soft in the USA 3
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Response To split the cost of execution and research Negotiate commission sharing arrangements with brokers in Europe and Asia. Third party research agreement in the US Change our trading process New broker review process 4
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Research Commission Execution Commission Bundled Commission Phase 1 Client pays broker Phase 2 Broker divides commission Phase 3 Broker pays to third party Broker retains Paid to Third parties Execution Commission 5
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Execution Services Demonstrably linked to the arranging and conclusion of a specific transaction (or series of related transactions) and That arise between the point at which a fund manager makes an investment decision and the point at which the transaction is concluded Research Services Capable of adding value to the investment or trading decisions by providing new insights that inform the investment manager when making investment decisions Represent original thought - that is the critical and careful consideration and assessment of new and existing facts Has intellectual rigour and does not merely state what is commonplace and self-evident Involves analysis and manipulation of data to reach meaningful conclusions 6
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The old system Could only reward brokers through execution Targets set by broker vote and applied on a ‘best endeavours’ basis (best execution comes first) Voting according to execution venue was complex The new system Traders do not have to work to targets Brokers rewarded separately from execution Fund management teams get to allocate their own clients’ commission 7
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First Stage : Pan-European Implemented Commission allocated according to broker vote Commission given to Fund Manager and Research teams to allocate on the new basis Second Stage : Australia, Asia (ex-Japan) and EMEA started commission sharing Third Stage : US and Latam to start under third party research agreements Japan to follow depending on regulatory progress. ( Possibility to under take CSA for offshore accounts). 8
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Global Buy Side Trading Consultants Ltd. 9
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