Survey results 2013: Dodd-Frank impact is starting to hit home!

May 16, 2013

The recent MoneyMate Data Management 2013 survey has some interesting insights into what is happening on the ground in 2013.

First up was a question on regulation - What regulations are impacting your firm’s operations the most in 2013?

Dodd-Frank topped the poll at 51%, which is high when you consider the respondents in the survey came from both sides of the Atlantic. Heretofore, many firms had indicated that Dodd-Frank was their chief concern – this was from a future impact perspective. The 2013 survey is indicating that this is now actually hitting home when it comes to day-to-day operations in 2013. If anything, I expect the impact of Dodd-Frank to grow and would expect next years survey to reflect that.

Another interesting finding in the survey is that 41% of the survey respondents have had an operational impact in 2013 with respect to preparing for FATCA, one can imagine what the impact will be once FATCA hits home fully. RDR was another notable hot spot  with 30% of respondents highlighting it as something that was having a real impact in 2013. UCITS IV and Solvency II polled 36% and 21% respectively indicating European regulation is still a hot topic – even if EIOPA and the EU council have delayed the full deployment of the Solvency II framework. Interestingly, I have heard on the ground that RMORSA in the US is starting to surface as an issue for institutional managers with demands for more holding level transparency, including demands for look-through in multilevel portfolios e.g. fund-of-fund like structures. It will be interesting to see if RMORSA surfaces as a key trend in 2014 and it is something I will be keeping an eye on as 2013 rolls on.


Recent webcast survey results – update #3

September 13, 2012

Following on from my previous blogs, the third question we asked in the survey during my recent webcast was “Which regulation is causing you most concern?

The result set had 5 options:

- Retail Distribution Review (UK)

- Solvency II (Europe/ Global)

- UCITS V / KID / KIID (Europe)

- FATCA (US / Global)

- Other….

As I would have expected, respondents indicated Solvency II is the regulation that is causing them most concern.

What I was a little surprised with, was that FATCA, RDR and UCITS V/KID were all equally ‘second’ the terms of concern. Specifically what surprised me was that FATCA was not the stand-out focus behind Solvency II.

I can honestly say that in my 13+ years operating in this market I have never seen a piece of regulation have such a profound impact as that which Solvency II is having today. Now clearly if your domain of focus is T/A and maintenance of share/unit holder records then FATCA is without doubt having a life changing impact on your business – but for the rest, Solvency II is a game changer.

What is most disconcerting though is that Solvency II is a piece of regulation that emanates from the European insurance industry, yet it is having a global impact on investment management businesses which are exposed to existing insurer-led mandates, or which have a specific institutional focus on attracting insurer AUM.

For many investment managers there is a lot of well-founded fear of the unknown, because while at face value their direct book of record may not indicate a large exposure to insurer investments, many are completely unaware of their indirect exposure via e.g. fund-of-fund investors which in turn have exposure to the insurance industry.

I was not surprised that RDR featured in joint second place in the response – this correlates strongly with the upcoming enforcement, same for UCITS V – this has a lot of visibility  as there have been updates from Brussels last month that elaborated on previous information updates.

There was a high percentage of ‘other’ in the response and I understand that this may relate to EMIR (European Market Infrastructure Regulation) which I will cover some other time.

In my next post I will consider the final question in the survey “What is your biggest challenge in getting your investment product data to market?

Talk soon….


Webcast available for on-demand playback…

August 10, 2012

For those of you who missed the recent webcast on regulation and its impact on data management strategies in the investment fund world, it is available for playback here


Webcast: The impact of upcoming regulation on data management

July 18, 2012

I am hosting a webcast on “The Impact of Upcoming Regulation on Data Management” on Wednesday 25th July 2012, 3pm BST, 10am EST.

Regulation is a key challenge in the industry and in an unprecedented age of openness and transparency continues to be the no. 1 driver for asset managers investing in data and reporting initiatives. Companies want to mitigate the risk of inaccurate information being in the public domain and many are embarking on data management projects – which will save time, reduce errors and automate processes. The key themes we see center on capability to deliver a systematic, repeatable and auditable data publication process for client-facing data.

This webcast will be presented by myself, and will focus on how upcoming regulations will impact the industry and how asset managers need to prepare to ensure they stay ahead in a highly competitive market. Specific topics to be covered include: the latest version of AIFMD, the final throes of the Retail Distribution Review, the latest on KIID for PRIPS, UCITS V, how being important or “SIFI” is no longer so desirable, Volcker, FATCA and last but certainly not least Pillar III of Solvency II.

Finally, I will touch on what is around the corner and run through some recommendations with respect to preparing for the swathe of upcoming regulatory change.

To register for this webcast please click here.

I look forward to welcoming you online on July 25th.


Technology in good hands

June 14, 2011

No matter how sophisticated the plane is, we trust the pilot to bring us safely to our destination. Don’t we? The same principle should apply to the management of your Product Master. No matter how good the technology, it is the people who will make data governance a success.

When selecting a partner in data management, do not underestimate the service element of their offering. Effective data governance and stewardship requires a cultural shift in the organisation that can only be nurtured through people. Technology has a key role to play but it is human interactions that will win the hearts and minds of the stakeholders and secure their buy-in. This is particularly true when data is coming from a wide range of sources with different attitudes towards data quality.

Your data quality management service provider should be focused solely on your industry. The better your service team understands your business and the business of your data sources, the sooner they will seamlessly integrate with your data supply chain and become part of the fabric of your organisation. This will generate trust and goodwill on the part of the data suppliers as they will see the data management service team as a partner that can help them improve the quality of their reporting. Knowing that the service team has an intimate understanding of their data will also generate respect and promote accountability on the provider side therefore driving them to achieve the data quality standards required by your organisation.

 Managing processes and data provider relationships is only part of the value that you should seek from your service team. Management reporting is another area that will benefit from a strong service provider with a deep understanding of your industry. The technology will generate all kinds of statistics on the reporting cycle such as data timeliness achievement rate, number of validation rules applied to the data, number of exceptions raised by such rules, number of data points resubmitted, etc. These are of little value unless analysed by a team of experts that can deliver to you meaningful content and recommendations that will empower your business to improve data quality on an ongoing basis. Your service team should report on the performance of your data providers in all four dimensions of data quality: timeliness, completeness, consistency and accuracy. You should be provided with trends for each of these Key Performance Indicators, benchmarks that you can measure against and clear recommendations on how you can exploit further the technology to drive data quality.

Technology combined with Service Excellence that is focused on your industry is the right combination to bring your data governance programme safely to where you want it to be.


Regulation.. what’s going on.

May 23, 2011

Following my last couple of blogs on the results of our survey around data management and regulation,  I said I would post some information about the various regulations in each region and how they were likely to impact..

In North America, the regulators have always been to a large extent more rules than principles-based – this is not going to change – and – in the future we can in fact expect even more rules – not less.  

The US alternatives space has seen many changes,  particularly around registration, where many hedge fund managers now required to register with the SEC would previously have been exempt – this is causing many European hedge fund operators to consider their long-term strategy in the US. The implication of registration is that full books have to be maintained. Each firm must retain all data, and be able to produce records for SEC inspection. SEC examination is a particularly onerous process – with site visits, extensive questionnaires and vast demands for data.     

The movement of the Dodd-Frank bill through the senate in summer 2010 ushered in a new era of regulation in the US, and we expect to see major changes to issues such as  corporate governance, executive compensation and levels of disclosure and transparency. What we do not know yet  is how the bill will directly impact the many rules we expect to see the SEC deliver, but we do know that the bill will allow the regulators to wield significant power and to determine the level of impact it will have on the market.

With the establishment of the Financial Stability Oversight Council and the Office of Financial Research, there is likely to be a more active approach to the management of market risk. This will manifest itself in increased reporting by asset management firms and funds on areas such as financial accounts, performance data, concentrations of risk  and exposures to third parties.  Increased demands for disclosure and transparency, including filing of full portfolios could also be seen, and there may also be  demands for SEC mandated slices and views of the portfolio breakdown. Recent changes by the SEC to Money Market funds with the updates to 2a-7 are perhaps the clearest insight we have as to what to expect for the broader investment fund market – based on what we see in 2a-7 we might expect to see more rules on post trade compliance, public information filing and risk exposures.   

Meanwhile, FINRA will be continuing to focus on maintaining market integrity, protecting investors and implementing key strands of the Consumer Protection Act within the Dodd-Frank reforms.   

In Canada,  a large segment of the industry is focussed on the new ‘Point of Sale’ fund fact documents which must be presented to investors prior to writing any investment from as early as July of this year.    

Europe

European regulators are moving toward the North American model of regulation. So what was mostly regulation by principle will become regulation by rule. Tensions and strains within the EU came to the fore with French led demands for a move away from ‘light touch’ to ‘heavy touch’ winning out. Ironically though, the UK regulatory environment is probably the most rules-based of the current batch – I think it will become even more rules oriented , especially now that the FSA comes under the remit of the Bank of England.

Most discussion in the City these days though is about RDR and how the removal of commission incentives is re-shaping the sales/advice arena , with many Asset Managers now actively looking at IFA businesses and other distribution channels to give them access to the market.  

On the cross-border front, the big news is the UCITS IV directive,  and from a data management perspective the key discussion point is the KIID – or Key Investor Information Document.  The KIID much like the CSA’s Fund Facts, is a simple 2-page document that should be delivered to the investor prior to investment. With KIID I see some serious data management challenges, in particular with the scale of the narrative data management, while the quant data should be more straightforward to deal with. To complement the rollout of the KIID initiative, Germany has passed legislation mandating the delivery of ‘product information sheets’ for investment products which are not covered by UCITS IV.

On the offshore side of things, we are already seeing change in Luxembourg and Ireland – in particular Ireland where we have seen the arrival of Matthew Elderfield, a former FSA department head.   

The rise of the ‘Newcit’ – ostensibly a hedge fund in UCITS clothing – is creating a lot of regulatory discussion – while welcoming the on-shoring of some hedge funds, it is thought that many of the ESMA regulators hope that hedge funds will migrate towards the Alternative Investment Fund Managers Directive.

That’s a quick summary of the regulations I think will impact reporting and therefore might cause data management issues. We’re still seeing regulation as the major hot topic at industry conferences – everyone is talking about it and trying to get prepared for change.


Regulation Survey Results: Part 2

May 10, 2011

This piece is a follow-up to my most recent blog posting on the results of our recent “data management and regulation” survey. I think the survey gave us a good chance to get a snapshot of what people are concerned about in terms of upcoming regulation and how it will impact their business processes.

The last posting was getting very long so I only posted some of the results. I finished up talking about the regulations that people were most concerned about in North America. The third question in our survey concerned European regulation and the topical issues there.

The question was: “in Europe, which of the following regulatory discussions concerns your organization most: RDR in the UK, UCITS IV & KIID for cross border funds, AIFM for hedge funds, the rise of Newcits, the upcoming UCITS V directive or the changeover from CESR to ESMA?

 

Not surprisingly nearly two-thirds of all respondents indicated the big discussion point in their firm was UCITS IV and KIID – if anything the surprise is that it did not have a higher response. Maybe this is because many firms have focussed so heavily on preparation that they are very confident they are well placed to deal with the upcoming requirements that UCITS IV brings as well as the ability and readiness to initiate publication of KIID documents.

Nearly 30% of respondents indicated the AIFM directive, and an additional 17% indicated Newcits were items of discussion and concern in their firm – a clear indication that alternative strategies and the hedge fund industry are key industry focus points in the years ahead.

Somewhat surprising though is the fact that UCITS V is already a discussion point for 17% of respondents – the belief here is that the depositary structures that facilitated Madoff and manager remuneration are going to be addressed – these topics will ensure this is a hot topic of conversation for years to come.

Finally 17% of respondents indicated Solvency II was a key discussion point – this will become a key topic of conversation for any asset manager that has mandates emanating from the Life and Pension sectors – the demands on risk control, asset liability, ability to be transparent and report accordingly are all hot topics in the Sol 2 world.

Next up was the question: “How prepared is your organization for dealing with upcoming changes in regulation - are you totally prepared, somewhat prepared or not at all prepared?

 

Thankfully the vast majority of respondents are at least somewhat prepared, but surprisingly only 15% or so indicated they believed their firms were totally prepared.

So it seems like the adage – a lot done, but more to do – seems prevalent here. Most firms are aware of what needs to be done, they have plans in place, but in some cases these plans have not been fully executed.

More reassuringly, we see that only 3% of respondents indicated that their firm is not prepared at all for the changes in regulation that are coming down the tracks. Overall, the responses to this question indicate that firms are struggling to prepare for the enforcement of regulatory reform, particularly in terms of their product data.

The next question in the survey was: “Do you think that new regulatory reporting requirements will change your organization’s attitude towards data management?”

The responses to this question were most interesting…… 

Nearly one-quarter (23%) of all respondents indicated that recent regulatory changes will force their firm to totally change their processes for getting their product data into the market, while only 12% of the respondents indicated that their existing processes were fully supportable, automated and left a full statement of record to facilitate audit.

The greatest number of respondents (56%) indicated that their firms only needed to make some amendments to the existing processes in their firm, for the management of product data.

The response to this question aligns with previous responses – where it would appear that in most cases firms know what they need to do, but have not fully executed their plans.

Overall, the responses to the survey questions indicate that firms are struggling to prepare for the enforcement of regulatory reform, particularly in terms of their product data.

The final question in the survey was: “What are the biggest challenges in getting your product data to market – are they manual processes, timeliness, cost, accuracy or something else?

 The big shock here is that just over half (53%) of respondents indicated that the biggest obstacle to getting their product data to market is manual processes, with a similar number indicating that timeliness was an impediment. It is not surprising that 40% indicated cost was a problem – this most likely results from having issues with manual processes.

Of most concern though should be the more than one-third of respondents that indicated accuracy was a problem for them. This is worrying indeed when you consider the considerable focus that has been placed on data management in recent years and the vast amount of IT dollars that have been spent trying to address the problem.

Finally the 6% other – commented that ability to maintain a statement of record or auditable trail of ownership was their greatest challenge – which is interesting – the inference we derive here is that these firms have automated processes and reasonable levels of accuracy, but proving this and showing a demonstrable audit trail to auditors and regulators alike is a particular concern.

So that’s it on our survey results – I thought they were worth sharing with a wider audience and it might give you an insight into how people are preparing for upcoming regulation.


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