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. This group will take forward the work of designing a standard template for disclosure of costs and charges to institutional investors.
In light of this, the IA is reviewing the timetable and process of the Disclosure Code work while it seeks clarity from the FCA over how the regulator intends to proceed with its recommendations. As soon as the FCA provides more detail about the terms of reference and timetable for the new working group – which the IA will seek a seat on – we will be in a position to update members 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.