2018年-FCA英国金融行为监管局_ms17_1_2_110页_1mb

Investment Platforms Market Study Summary

Core Content

The Investment Platforms Market Study by the Financial Conduct Authority (FCA) examines the growth, structure, and competitive dynamics of the investment platform market in the UK. The study focuses on how platforms affect consumer choices, the level of competition among platforms, and the transparency and complexity of fees and charges. It also highlights issues such as switching difficulties, pricing opacity, and the treatment of "orphan clients" (investors who no longer have an adviser relationship).

Main Findings

Market Growth and Structure

• The platform market has grown significantly, doubling in assets under administration (AUA) from £250bn in 2013 to £500bn in 2017.
• There are two main types of platforms: Direct to Consumer (D2C) and Adviser platforms.
  • D2C platforms manage £189bn AUA and are used by investors without the help of a financial adviser.
  • Adviser platforms manage £311bn AUA and are chosen by advisers but paid for by consumers.
• The D2C market remains highly concentrated, with one platform holding over 40% of the market share.
• In the adviser market, the top four platforms each have less than 20% market share, and these shares have changed over time.

Consumer Behavior and Satisfaction

• Consumers using platforms value price, product range, and ease of use.
• Higher fees on platforms often correspond to greater functionality.
• Customer satisfaction is currently high, but there are concerns about complexity and lack of transparency in fees and charges.
• Only 39% of non-advised consumers base their platform choice on price, and 29% of consumers are unaware of whether they are paying charges.

Switching Challenges

• Switching between platforms is difficult and time-consuming, with 7% of consumers attempting to switch but failing due to complexity, time, and exit fees.
• Advisers rarely switch existing investments between platforms, even if they offer better options for new clients.
• Advisers often charge extra fees for switching, which can negate the benefits of lower platform fees.

Model Portfolios and Risk Transparency

• Around 17% of non-advised consumers use model portfolios, which are often associated with less active investors, younger, and less affluent individuals.
• Model portfolios with similar risk labels can have very different underlying assets and returns.
• Fees for model portfolios vary significantly, and higher fees can lead to lower risk-adjusted returns.

Cash Holding and Investment Returns

• D2C platform users tend to hold large amounts of cash balances, which may result in missed investment returns and additional charges.
• Only 3.9% of AUA on adviser platforms are in cash, compared to 8.8% on D2C platforms.

Orphan Clients

• There are over 400,000 orphan clients with £10bn in assets on platforms.
• These clients face higher charges and lower service compared to those with active adviser relationships.
• Some platforms charge extra fees on orphan clients, up to 0.5%.

Fund Discounts and Competition

• Fund discounts are beneficial for consumers but are concentrated on larger platforms.
• Some platforms and asset managers have arrangements that may limit competition on fund discounts.
• The FCA is considering whether these arrangements comply with inducement rules.

Transparency and Disclosure

• The MiFID II cost disclosure provisions are intended to help consumers compare investment costs.
• However, transparency and clarity in presenting charges are still lacking.
• Platforms should improve the way they present fund charges to both consumers and advisers to enhance competition and informed decision-making.

Key Issues and Proposed Remedies

Improving Switching Processes

• The FCA is working with the Transfers and Re-registration Industry Group to improve the switching process and reduce transfer times.
• Potential measures include:
  • Setting end-to-end standards for transfer times.
  • Requiring clear communication to customers about the transfer process and timelines.
  • Publishing transfer time data to allow comparison.
  • Considering banning exit fees and improving share class switching.

Enhancing Price Transparency

• The FCA is seeking stakeholder feedback on how to improve price transparency and consumer choice.
• They are open to innovation in presenting MiFID II cost data, including interactive tools for customers to calculate and personalise charges.

Addressing Orphan Clients

• The FCA is considering measures to help orphan clients, including:
  • Tackling price discrimination.
  • Requiring platforms to have processes for switching.
  • Ensuring adviser platforms check if customers are still receiving advice after a year of inactivity.

Enhancing Model Portfolio Transparency

• The FCA is exploring disclosure requirements for model portfolios, including:
  • Standard terminology for strategy and asset allocation.
  • Comparability of model portfolios with similar risk labels.

Addressing Non-Compliance

• The FCA is concerned about non-monetary benefits provided by platforms that may violate inducement rules.
• They are also assessing whether best execution standards are being met, particularly for direct stockbroking.

Next Steps

• The FCA is seeking comments on the interim report by 21 September 2018.
• Feedback should be sent to investmentplatformsmarketstudy@fca.org.uk.
• The FCA will publish the final report in the first quarter of 2019 after evaluating stakeholder input and industry developments.

Conclusion

The study highlights both the benefits and challenges of the investment platform market. While platforms are generally working well and competition is effective in some areas, there are significant barriers to switching, complexity in fee structures, and issues with transparency and fairness for certain consumer groups. The FCA is open to industry innovation and regulatory improvements to ensure platforms deliver value for money and fair treatment to all consumers.