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Disclosure Code

The IA recently consulted upon a new Disclosure Code. More detail can be found here. We have been assisted in our work to date by an Independent Advisory Board.

IA Disclosure Code and FCA Asset Management Market Study

The FCA has been kept fully informed of the IA’s work on the Disclosure Code, the activity of its Independent Advisory Board and the collaboration with the LGPS Advisory Board. However, the Market Study Final Report (see pages 88-89) signals a desire to create a new working group of industry and investor representatives, chaired by an independent person. The chair has since been confirmed as Dr Chris Sier.

The new group, which starts work in September, will take forward the work of designing a standard template for disclosure of costs and charges to institutional investors. The FCA has also now stated that by the end of the year, the group will aim to achieve consensus on the following areas:

• Agreeing a standardised disclosure template for mainstream asset management services, building on the work already done by the IA, LGPS and others
• Agreeing how use of the template will be promoted, and accuracy of the information presented will be ensured
• Agreeing how the disclosure template should evolve over time

In light of this, the IA is reviewing the timetable and process of its disclosure work while it seeks clarity from the FCA over how the regulator intends to proceed with its final recommendations. We will keep members updated on next steps. The IA’s aim remains delivery of a machine-readable template consistent with the European PRIIPs and MiFID Templates (EPT and EMT) that also delivers more granular UK institutional disclosure.

In the meantime, the LGPS Code – which contains a common set of data points with the IA Code – remains in place, with firms able to sign up to the Code. The LGPS Code is outside the FCA’s jurisdiction and will not be affected by the FCA process. The IA will continue to work with the LGPS Advisory Board to ensure that the LGPS Code reflects ongoing regulatory developments.