2018年-FCA英国金融行为监管局_ms17_1_2_annex_6_22页_961kb

Summary of MS17/1.2: Annex 6 - Investment Platforms Market Study

Core Content

This annex provides an analysis of the non-price features and fee structures of Direct to Consumer (D2C) and adviser platforms in the investment market. The objective is to assess how platforms differentiate themselves and whether these differences justify the price variations.

Main Points

1. Non-Price Features

• Key Features Analyzed:

  • Customer support (telephone and online)
  • Usability (website look and feel, mobile app availability)
  • Investment decision tools (research, risk profilers, ready-made portfolios)
  • Tools to manage existing investments (performance reports, tax calculators)
  • Product range (wrappers like ISA, SIPP, GIA; investment products like funds, shares)

• Variation Across Platforms:

  • Some features (e.g., customer support) were widely available across D2C platforms.
  • Others (e.g., asset allocation tools, CGT calculators) were less common.
  • Adviser platforms generally provided more tools for investment planning and management, but less variation in their offerings.

• Consumer Preferences:

  • The breadth of investment choices was the most important feature for consumers when choosing a platform.
  • The look and feel of the platform was also highly valued.
  • Online tools to manage investments and guide decision-making were consistently important.

• Platform Categorisation:

  • D2C platforms were grouped into Basic, Standard, and Extensive categories based on non-price features and consumer preferences.
  • Extensive platforms offer comprehensive tools and support, including detailed research and multiple customer support channels.
  • Standard platforms provide a balanced mix of features and support.
  • Basic platforms have limited features and support, primarily telephone and email.

2. Platform Fees

a. Types of Platform Fees

• Headline Platform Fee:

  • Usually ad valorem, but some platforms charge flat fees.
  • Tiered structures are common, typically ranging from 0.2% to 0.4% for the first £250,000 of AUA.
  • Fixed percentage fees and per-trade fees also exist.

• Wrapper Fees:

  • ISA, SIPP, and GIA fees vary depending on the product held.
  • These fees are typically separate from the headline platform fee.

• Dealing Charges:

  • These are fees for buying or selling investment products.
  • They can be:
    • Fixed per trade (from £3 to £27)
    • Tiered based on trade frequency (starting at £11 per trade)
    • Percentage-based (from 0.1% to 0.9% of trade value)
  • Tiered structures may benefit frequent traders.

• Cash Interest:

  • Platforms pay interest on cash balances held.
  • This is subtracted from the total fee calculation.
  • Can be fixed or tiered based on AUA.

3. Price Simulation Analysis

• Methodology:

  • Simulated total fees for 9 consumer profiles based on investment size, wrappers, and trading activity.
  • Compared simulated fees with actual revenue per AUA to assess price competitiveness.

• Scope:

  • Only D2C platforms were included due to lack of data on adviser platform discounts.
  • The analysis focused on the headline platform fee, wrapper fees, and dealing charges.

• Findings:

  • Platforms with Extensive non-price features tend to have higher fees but offer more comprehensive services.
  • Standard and Basic platforms have lower fees but fewer features.
  • The fee structures vary significantly across platforms, making direct comparisons difficult.

4. Key Differences Between D2C and Adviser Platforms

• D2C Platforms:

  • Focus on non-advised consumers.
  • Provide more online support and basic functional tools.
  • Less variation in non-price features compared to adviser platforms.

• Adviser Platforms:

  • Offer more planning and management tools (e.g., risk profiling, retirement planning).
  • Provide more frequent and detailed research.
  • Less variation in features, but more extensive functionality for advised consumers.

5. Consumer Preferences and Weighting

• Consumer Preferences:

  • The breadth of investment choices and look and feel were the top priorities.
  • Tools to manage investments and online support were also highly valued.

• Weighting Approach:

  • Consumer preferences were used to weight non-price features in platform categorisation.
  • This helped to assess the value proposition of platforms relative to their fees.

6. Conclusion

• There is significant variation in non-price features across D2C platforms.
• Consumer preferences play a crucial role in determining which features are more valuable.
• Price structures are complex and vary by platform, with tiered and fixed fee models.
• Adviser platforms offer more advanced tools and research, while D2C platforms focus on basic functionality and online support.
• The relationship between price and non-price features is important for understanding value for money and consumer choice.

Key Figures and Tables

• Figure 6.1: Highlights the availability of non-price features across D2C platforms.
• Figure 6.2-6.5: Provide criteria for grading performance reports, look and feel, research provision, and online support.
• Figure 6.6: Shows non-price features offered by adviser platforms.
• Figure 6.7: Displays consumer preferences for non-price features.

Limitations

• Horizontal differentiation (specific needs of consumers) was not considered.
• Adviser platform data on discounts was limited, so their fee structures were not included in the analysis.
• Lang Cat scorecard provided a simplified view of non-price features, which may not fully reflect consumer preferences.