TCFD: helping the wealth industry make its mark on climate change

TCFD

TCFD (Task Force on Climate-Related Financial Disclosures) reporting will be a challenge for many firms. While the initial requirements relate to larger institutions and certain client portfolios, firms with GB£5 billion-plus Assets Under Management (AUM) will also have to report with comparisons to data collected in 2023, meaning careful planning is needed now. This historic comparison data will add further to the complexity of the 100-plus data points in the Investment Association TCFD report template. In addition, this data will need to be aggregated across client portfolios for entity reporting. Lastly, there is clear direction from the regulator that on-demand reporting is expected to be made available to all clients in due course. So, there are significant challenges in TCFD reporting.

The UK’s Financial Conduct Authority helped set the pace for the global adoption of Environmental, Social and Governance standards in financial services when at the end of 2021 it became the first securities regulator to introduce mandatory TCFD-aligned disclosure requirements for asset managers and asset owners. This is already having a huge impact which will only grow.

The report content, in line with other sustainability-related regulatory required reports, has been proscriptive, which removes ambiguity, but does not necessarily make it easy. The Investment Association has published helpful templates for segregated and pooled fund portfolios. The first set of reports for institutions with over GB£50 billion in AUM will need to be submitted by the end of June 2023, to cover the 2022 calendar year; those with GB£5 billion-plus in AUM will be subject to the rules from 1 January 2023, with their first reports due end-June 2024. By that point, a full 98% of the UK’s asset management industry will need to comply with the Task Force on Climate-Related Financial Disclosures’ rules. Part of the challenge will be the requirement to provide a year-on-year comparison of the portfolio metrics reported.

A good deal of voluntary reporting has also been taking place, and pressure both top-down from regulators and bottom-up from investors will likely mean that most firms will want to get their TCFD house in order well ahead of the second-tier deadlines kicking in. This yoking together of compliance and client demands is a very welcome development for those who care about environmental action as we all should.

The TCFD report focuses on the investment organisation’s governance-related arrangements through a climate change lens and provides a consistent way of reporting the risks and opportunities faced in a portfolio as a result of it. It is safe to assume that most end-investors do very much want to be apprised of the climate impact of their financial holdings today, and it is certain that providing such insights will be a hygiene factor for tomorrow’s core client base. Research recently conducted by Compeer found that 80% of clients want access to ESG-compliant investments in their portfolio, with this figure rising to 94% for clients under the age of 40. With wildfires and floods making the impacts of climate change clear for all to see, the “E” reigns supreme among the Environmental, Social and Governance concerns investors want to see reflected in their portfolios now.

Thought leadership through technology
Whether a firm provides a sustainable investment offering – and an expanded TCFD report offers an opportunity to demonstrate this to clients – or not, the key to efficient reporting and avoiding issues will be a systematic approach. This brings the benefit of information and analysis across the client base, uncovering risks, providing calls to action, and giving insight to the investment manager and central investment teams alike.

At BITA Risk, we have always prided ourselves on having a finger on the pulse of both domestic and global regulatory change and cultivating a deep understanding of where the rule books might be heading – in light of both the spirit and the letter of the law. This has served us extremely well in developing our products to help keep institutions ahead of compliance changes, rather than just reacting to them. The range of institutions we work with has also enabled us to become something of a thought-leader and conduit for conveying best practices as the industry grapples with ever-changing regulatory regimes. As such, more and more we have a highly consultative role.

No doubt conscious that the UK’s institutions are having to cope with a barrage of new rules, not least its sweeping new Consumer Duty regime, the FCA is currently asking only for fairly limited TCFD reporting to clients. However, the expectation is clearly that all investors will have climate impact information at their fingertips in short order. Clients’ expectations for ever more personalisation being as they are, we can further predict that firms will need to be able to drill into these metrics in any number of ways too.

Having considered the requirements to provide year-on-year metrics at a portfolio level and to be able to aggregate metrics across client segments, we have suggested using this data to identify stranded assets, portfolios with climate risk exposure and to demonstrate a firm’s changing exposure through time.

With a structured data approach, communicating to clients the investment firm’s stewardship activity and mitigating reasons for holding carbon-heavy stocks, not only becomes easy, but drives a demonstration of the firm’s worth to the client.

How to make climate impact information relevant and readily comprehensible is not just a matter of client satisfaction, although it certainly is that; helping people to make investment decisions which reflect their priorities in the widest sense is what the disclosure rules are all about.

The TCFD rules aim to serve the most high-minded of principles, but as we help to steer capital to more sustainable deployment, the industry must stay firmly in the realm of their practical application too. We have been delighted to offer institutions guidance on firm, product and ad-hoc reporting requirements, metrics definitions, reporting templates and more. Personally, my work has never been more interesting, or more valuable in a societal sense.

Another portfolio monitoring lens
While climate impact disclosures are important from humanitarian and environmental perspectives, there is a regulatory drive to report soon. We like to emphasise to firms which may feel daunted, that this is just another lens through which to view portfolios – and therein arguably lies our particular strength. We have spent decades now enabling firms to master their metrics on performance, risk, suitability, and costs, meaning that we have abundant transferable insights on how to make TCFD reporting work optimally in everyday operations too.

Firms’ first concern will undoubtedly be how to avoid manual processes and being dragged back to “Excel hell”; then, relatedly, they will want to know which processes need to be in place to facilitate portfolio analysis and change. With profitability remaining under pressure, adviser productivity has to remain a top concern. Running analysis for individual portfolios and collating historic data will take time, as will aggregating across groups of clients for entity reporting. Creating structured data and an automated framework will alleviate pressure on the adviser and give the client a better experience.

These are undeniably challenging times for business leaders, but we see a gratifying proportion keeping the competitive advantages available from these pioneering reporting requirements front of mind. Here, we have been assisting institutions to develop trend reports to demonstrate progress on positive investment practices at both the client and entity levels to great effect. Helping the individual know the impact they are making will be a very powerful thing for both client satisfaction and retention. Being able to demonstrate the difference the firm as a whole is contributing is, in my view, a ready-made marketing campaign. I know that many Chief Marketing Officers agree.

In all, the TCFD requirements represent a particularly novel kind of compliance challenge, but one which we are seen leading firms rapidly embrace as an important differentiating factor. Sophisticated clients can already see that espousing ESG credentials is one thing, but that evidencing them robustly and acting on them is quite another. We look forward to working with even more firms in the latter camp as the industry moves to make its mark on climate change.

As leaders in portfolio monitoring and governance, BITA Risk analyses circa GB£180 billion of wealth management assets every night for a range of Wealth management firms. At our core is the quick, efficient analysis and aggregation of data, with seamless and efficient workflows for governance and client managers alike. We have extended our solutions to deliver what firms need now for TCFD, together with significant added benefits for the firm, following the IA (Investment Association) template as a base and then adding analysis and client-facing interpretations.

By Daryl Roxburgh, President and Global Head BITA Risk® part of the corfinancial® Group

If you would like to discuss the points raised, please email me at BITARisk@corfinancialgroup.com.

In the next two reviews, we will look at the monitoring of ESG and Ethical Restrictions and then Consumer Duty. Sign-up here to receive these directly.

For more information please visit https://www.corfinancialgroup.com/financial-software-products/bita-risk/ or contact us at BITARisk@corfinancialgroup.com.

Time is money: the hidden challenges of T+1

Man squeezed

Man squeezedThe Securities Industry and Financial Markets Association (SIFMA), the Investment Company Institute (ICI), and The Depository Trust & Clearing Corporation (DTCC) last year published a report targeting the first half of 2024 to shorten the US securities settlement cycle from trade date plus 2 days (T+2) to trade date plus one day (T+1).

Perhaps this will be a first step toward broader coverage in other currencies, regions and exchanges. Proponents suggest that the immediate benefits of moving to a T+1 settlement cycle include reduced market risk and lower margin requirements, as well as significant cost savings.

A move to T+1 will certainly have its challenges: industry participants will have to align and implement the necessary operational and business changes. T+1 will pressurise the industry to get things right on trade date, which means more straight-through processing and less cumbersome or customised processes. In a T+1 settlement cycle, if a trade is executed today, the confirmation or affirmation process should occur on trade date – mostly at the close of business in the region – for the trade to settle the following day. There’s very little time for the firm to identify a mistake that could lead to failed trade settlement.

When industry executives consider T+1, a natural starting point for the conversation is from the US perspective. Most firms perceive the main challenges impacting asset managers based in the US, who are dealing directly with the DTCC locally. The truth is that the impacts of this truncation of the settlement cycle are actually far greater due to multiple factors stemming from the differences in time-zones for participants trading outside of the US. This article looks at some the operational problems of T+1 from outside of the US footprint.

 

Across the time zones
For a firm located outside the US, T+1 automatically becomes extremely difficult. For example, currently with a typical UK investment management firm its staff have ended their working day well before the markets close in the US. In a T+2 environment, many traders don’t complete the deal records until the morning of T+1. Occasionally they might log in at around 11pm to sweep up any unbooked trades, but if they don’t match perfectly with a broker the trade will remain unmatched until the operational team returns the following morning.

Under T+2 that firm would have an entire day to correct and instruct the settlement of the trade, so there would be little or no issue, although if the counterparty is a US broker, it will be early afternoon in the UK before they can fix it. If we put this scenario into a T+1 context, the firm has effectively lost a day. While a trade is in an unmatched status, the parties can’t confirm the net settlement amount for the cash component of the trade, impacting funding processes.

 

Stock lending, custodians and FX
There are additional complications if a party is participating in stock lending. A custodian, for example, will not know about a requirement to recall stock until an asset manager sends the trade instruction to sell. If an asset manager sends an instruction after markets close, there is little or no chance to recall stock on the same day.

This scenario will have an impact on the number of failed trades because there’s not enough time to facilitate settlement. The net result when the settlement cycle decreases will be that custodians may impose earlier instruction receipt deadlines. Furthermore, if stock is not readily available, then trades are going to fail. Service level agreements may also have to be revisited, as each party wants to protect their position and not be responsible for failed trade fees.

Many custodians allow UK-based asset managers to instruct on settlement day for US equities, but that’s because the US market is still open when the UK market has closed. Deadlines for asset managers in Asia may become even tighter as their day is ending before the US market opens.

In India, T+1 has already been introduced and many UK firms already feel the pinch because the market there closes around 11am GMT and some custodians are looking for instructions by or before 9:30am. As this new trading lifecycle is established, many UK asset managers may struggle to meet these deadlines, resulting in pre-funding issues and foreign exchange challenges.

Similarly, there have been discussions on the impacts in the broader Euro markets of moving to T+1. From experience we often see that if the US markets introduce change, the tendency is that other regions follow suit. With new Central Securities Depository Regulation (CSDR) impacting processes, there are potentially going to be more failing trades, therefore more penalties incurred. All creating additional headaches for asset management firms.

 

Changing working practices
At this stage, many asset managers will be establishing forums or working groups to understand their custodians’ requirements under T+1, to then formulate internal procedures to support T+1 when it does go live in the US markets. This might involve testing their operational team presence in the local market time for executed trades, so perhaps trialling support in US market hours to see how that might work in practice. Team shift-work, accommodating a much longer working day may well be the necessary endgame.

Indeed, the imperative to adapt operating models is an interesting yet challenging area for discussion. Changing local working hours is an easy statement to make, but every firm has a finite number of resources in their operational teams. Getting an even split between staff members would be key so that the workload naturally flows, requiring careful analysis and staff commitment to change. For example, if US hours are typically 2pm to 11pm GMT, then there is likely to be a trade processing bottleneck around 4pm when all euro and UK trades are often still being booked. However, UK based asset managers are anticipating very low volume activities between 6pm and 10pm, adding to the challenges of balanced resourcing in a lengthy window of inactivity.

 

Conclusion
When firms look at a move to T+1, it is essential that they fully comprehend required changes to the post-trade environment. This is even more crucial for firms that have not re-engineered legacy systems.

As operational efficiency and regulations bring technology to the fore, now is the time to overhaul dated technology and systems and move away from practices like batch processing, which is still common in a great number of companies around the world.

The many operational problems associated with T+1 can be alleviated by corfinancial’s Salerio® software. Salerio deals with confirmation, matching and settlement instructions management, helping the middle office deal with high volumes of trades that must be processed on trade date. Salerio achieves this through complex matching automation leaving users to only deal with exceptions, thus enabling firms to process high volumes of transactions in the most time-efficient manner. Our software takes control, because as soon as the firm can send an instruction to a custodian, the custodian can issue notifications on the matching and settlement status of trades that Salerio centrally manages.

Facing the new monitoring challenges in wealth management: going beyond drift and minding the gap

Wealth Mosaic

Daryl Roxburgh – President & Global Head BITA Risk® part of the corfinancial® Group

Wealth Management

Living through 2022 is underscoring an eternal truism: that life’s challenges are seldom episodic and often come piling on top of each other in a way that is most challenging. This is very true for those managing portfolios in the wealth management space.

Long gone are the days where asset allocation drift, and possibly asset class risk, were enough to satisfy suitability and ongoing portfolio monitoring requirements. These are just one slice of a large – and growing – portfolio monitoring “pie”, and there are several portions I fear firms will find hard to digest without modern technology designed for the purpose. These coalesce around two core themes: sustainability and the highly tricky business of not just doing right by clients but proving one has done so. Spreadsheets and manual data manipulation are just too time consuming, labour intensive and risky to be fit for purpose.

So, the challenge of properly monitoring portfolios has become multifaceted, requiring the checking of numerous metrics, both individually and across your entire client base – and all of the time. These metrics can often be client or proposition specific and at both asset and portfolio levels adding further complexity. This requires automation and exception management if it’s not to become a drain on the front office’s time.

The acknowledgement of change is supported by recent research carried out by Compeer which found that 46% of firms are now reviewing suitability on a continuous rather than an annual basis. From a compliance perspective, but more importantly from that of clients themselves, this is no small thing, although the industry as a whole clearly has some way to go still.

Consumer Duty

Putting the customer first is a movement which has been gathering pace globally for some years building on TCF and which will reach something of an apotheosis in the UK when, at the end of July, the FCA publishes its final “Consumer Duty” rules. The regulatory focus is now on firms tracking and measuring the investment journey to ensure both consistency of outcomes and how these are best achieved. We will need to map and document such that even if clients choose slightly different paths and different vehicles (pun intended), those with similar objectives still arrive at the same place or it is clearly documented as to why not.

You may think that this is solved by Centralised Investment Propositions (CIPs), but research has shown that this is not always the case. Firms must be able to ensure and demonstrate that Centralised Investment Propositions are working as intended for each client’s objectives, and alert and document where not. Being able to identify early on and rectify reasons why performance, and yields, aren’t quite meeting an individual’s expectations and needs will help head off all manner of risks apart from those related to compliance – not least that of losing the client.

ESG and Ethics

It is in the sustainability sphere, however, that things are getting really thorny in portfolio monitoring. Our research with Compeer found that 80% of clients now request some access to ESG-compliant investments in their portfolio, with this figure rising to 94% for clients under the age of 40. Demand, in the purest sense of the word, is most certainly there and will only grow to ubiquity. It is just as strong (if not stronger) from regulators, with SFDR and TCFD headlining an alphabet soup of frameworks, rules and regulations requiring carbon, ethical and other non-financial metrics also be part of what institutions monitor, measure and report on. This starts to become complex, as not only does the ESG (in the broadest sense) data need to be managed and applied to portfolio positions in et context of client preferences and restrictions, but a number of metrics need to be looked at through time.

Compeer found that a lack of personalised reporting and portfolio updates are a deal-breaker for two-thirds of clients and firms clearly see that ESG reporting is shaping up to be a real differentiator in these conscientious times: 43% already report on ESG metrics to clients and the remainder are working hard to catch up. Ethical restrictions have been simplistically applied for years, but now that there is detailed data on companies and funds, there is the opportunity to apply these automatically both pre-and post-trade. No longer does the front office have to spend time manually checking each month, this along with sustainability metrics can be constantly monitored.
 

Multifaceted Solutions to Multifaceted Challenges

These slices of the monitoring pie may seem to be largely compliance, but the reality is that more and more of it takes up front-office resource. Indeed, Compeer tells us that for a quarter of firms as much as 80% of a compliance project is performed outside of the compliance department – and this at a time when margin pressures mean front-office efficiency is more important than ever. The more automation in portfolio construction, monitoring and reporting which can be achieved, the better both direct and indirect compliance costs can be kept down – and high standards of provision kept up. These tools provide managers with decision support as well as calls to action in investment management Managers must be freed up to manage and build their client bases.

All of this is to say that when faced with multiple challenges, wealth and asset managers need to be seeking truly multifaceted solutions. That way, multiple problems which threaten to become an entangled mess can actually be solved pretty much at a stroke. Future-proofing can then also come into scope. Once you have a cutting-edge portfolio monitoring solution in place, then it doesn’t much matter what regulators, clients, senior management, or anyone else requires you to measure and report upon. You could even choose to break with the pack and look at portfolios through an entirely new lens. I know some of our clients are already thinking about this.

Our BITA Wealth® solution has consistently stayed ahead of the market and encompasses a wide range of risk, portfolio analytics and decision support tools to monitor suitability and outcome meeting today’s challenges. Now servicing over £180bn in client AuM, we can confidently say that we’ve helped get a large part of the sector to a position where proper guardrails are always on.

That, I would argue, has to be the spirit in times like these: you can seek resilience in the face of a regulatory onslaught and wring business benefits from compliance challenges. Our client stories give ample evidence for how that’s already been done. If you would like to receive our updates on Consumer Duty, please subscribe here.

For more information please visit https://www.corfinancialgroup.com/financial-software-products/bita-risk/ or contact us at Info@corfinancialgroroup.com.

Archer turns to Salerio to add retail trade processing

Archer logo

Boston, May 3, 2022 – corfinancial®, a leading provider of specialist software and services to the financial services sector, announces that Archer, a leading technology enabled service provider for investment managers, has extended their use of corfinancial’s  Salerio® Post-Trade Execution solution to commence trade processing for their retail services.

Headquartered in the Philadelphia region, Archer provides a robust ecosystem of technology and services to the asset management industry. An early adopter of Robotic Processing Automation, Archer continues to deploy advanced technology like Salerio to streamline processes for investment manager clients and their brokers.

“As more investment managers launch new products specifically for retail investors, we’re continuing to invest in technology that creates powerful operational efficiencies for our clients,” said Bob Lage, EVP, Global Head of Product and Technology at Archer. “At Archer, we’re always looking to upgrade our tools in ways that allow our clients to grow their businesses. By integrating Salerio into our trade settlement process, we are adding automation that creates significant efficiencies in matching trades across our clients’ counterparties.”

Archer used Salerio to migrate its institutional clients away from DTCC’s OASYSTM utility in December 2021 and began moving its retail clients in March 2022. This latest move with the retail application of the technology enables asset managers to match trades more rapidly through a centralized service. Specifically, Salerio facilitates enhanced connectivity to banks and brokers via DTCC’s CTMTM utility, including SWIFT messaging – all highly automated and fully integrated into the Archer IBOR, dashboards and reporting.

David Veal, Senior Executive for Client Solutions at corfinancial added: “Archer’s confidence in our Salerio solution is well-received and this recent change reflects the flexibility of our product to adapt to different operational processes, creating a comprehensive, centralized solution that can scale as our clients’ businesses grow.”

BITA Risk wins innovation award for its ‘ESG Manager’ private client solution

Wealth Briefing - Award-2022-Winner

London, 31st March 2022 – BITA Risk® (part of the corfinancial® group) announces that it won the coveted ‘Best Innovative WealthTech Solution B2B’ award at the Tenth Annual WealthBriefing European Awards 2022 for its BITA Wealth® ESG Manager private client solution.

Showcasing ‘best of breed’ services and solutions in the European region, the awards were designed to recognise outstanding organisations grouped by specialism and geography which the prestigious panel of independent judges deemed to have ‘demonstrated innovation and excellence during the last year’.

ClearView Financial Media’s CEO, and Publisher of WealthBriefing, Stephen Harris said: “The organisations and individuals who triumphed in these awards are all worthy winners, and I would like to extend my heartiest congratulations to the winners.”

BITA Wealth ESG Manager supports evolving ESG strategies by helping firms to understand, manage and monitor portfolio ESG exposures, enabling the integration of ESG analysis and reporting within a firm’s investment proposition.  Climate, impact, and ethical restrictions dovetail with investment policies to deliver analysis and governance to compliance teams and the wealth managers. This key differentiator enables client managers to deliver a better service to clients in the world of sustainable investing.

Commenting on the firm’s triumph, Daryl Roxburgh, President and Global Head of BITA Risk, said: “We are delighted to have won this award in recognition of our innovative approach to managing the complexities of ESG investments for private clients. While many firms have built sustainability into their central process, only a few can embody it in day-to-day portfolio management and demonstrate this clearly to a client while monitoring that they are in line with the client’s preferences and restrictions. This is what our innovation delivers.”

Wealth Briefing - Award-2022-Winner

corfinancial launches penalty fee management for failing trades under CSDR

SureVu helps buy-side firms manage failed trades under forthcoming changes to the Central Securities Depositories Regulation (CSDR)

London, January 19, 2022 – corfinancial®, a leading provider of specialist software and services to the financial services sector, announces the launch of SureVu® Penalty Fees Processing and Management. 

SureVu® helps buy-side firms manage failed trades under forthcoming changes to the Central Securities Depositories Regulation (CSDR), which requires trading venues and investment firms established in the EU to improve settlement discipline by 1 February 2022. These enhancements, known as the Settlement Discipline Regime (SDR), state that where a settlement failure occurs, depositories must impose cash penalties on failing participants.

SureVu supports complex processes associated with penalty fees management, with a set of management information dashboards that summarise data and priorities. SureVu reflects accumulating net fees, in multiple currencies throughout the penalty fee lifecycle. Furthermore, users can lodge and manage appeals against fees that are in dispute. Firms are adopting these new features to ensure they have a comprehensive solution and are ready to go live on 1 February 2022.

“Now that the European Commission has postponed the implementation of the Central Securities Depositories Regulation mandatory buy-in provisions following months of speculation, there are no further reasons to delay the deployment of a solution that supports failing trades. The postponement has created an opportunity for the industry to move forward and the time for action has come,” says Bruce Hobson, CEO at corfinancial. “A comprehensive solution like SureVu will ease the many additional operational burdens that are causing such industry-wide consternation. We suspect that these concerns essentially stem from the fact that many firms are still a long way away from having a tried and tested solution that is simple and quick to deploy.”

SureVu – CSDR introduction – gaining competitive edge

CSDR Trade Settlement

Lower risk, higher efficiency: gaining competitive edge in CSDR trade settlement.

The Central Securities Depositories Regulation (CSDR) has been in force since September 2014 and introduces regulatory change on a regular basis. There are a number of rules and industry changes being introduced in the near future by the CSDR, one of which is the new Settlement Discipline Regime (SDR), expected to come into force on 1 February 2022. It introduces several major changes to the settlement of financial instruments that will have a major impact on all market participants, not least the operations of buy- and sell-side firms.

CSDR Trade Settlement