Yeah, OK so he’s got our entire economic future held in his Coke-addicted (as opposed to coke-addicted, let’s make that clear) hands, but has he got 500 words on MiFID II negative target market definition and disconnects in MI between manufacturers and distributors of retail investment products? NO HE DOES NOT. So that’s a win for the Update right there, probably, and we don’t need a five minute promo to prove it.

We will do a brief Update today because in all seriousness there are more important things going on; not least keeping track of how many times Sunak says ‘hard-working families’ – because we have to take a drink each time he does and there’s a good chance a stretcher may be required by the end.

MiFID II, then. It’s been a while since we’ve heard anything from the embattled regulator, whose top brass are now facing a future with a bit less brass in it. We could organise a whipround? Or a crowdfunder? Or buy them a coffee on Ko-Fi? No? Anyone?

Well, some work has been going on, and we got a look at some of it on Friday past. This is interesting stuff – just a small check in on how manufacturers (asset managers) and distributors (you) are rubbing along in a post MiFID II environment. That link is worth a read; it’s not too painful.

The upshot of it is that trying to ensure product suitability at a manufacturing level is going straight into the ‘too hard’ box. Manufacturers can’t get good data on who’s using their products, and distributors have little or no incentive or mechanism to share back data. The report says:

“The reliance on intermediated services in the UK investment market also means manufacturers commonly rely on those who distribute their products to give them relevant information on the end consumer. We found that distributors rarely pass this information on to asset managers, hindering firms’ ability to effectively meet best practice on product governance. Asset managers and product distributors need to prioritise effective cooperation and information sharing to address the potential harm to consumers from poor product design and distribution processes.”

In this world a distributor could be a platform or an adviser firm or both. Interestingly, the report also highlights that asset managers should be doing due diligence on distributors to check that the cut of their jib is appropriate. Who’s up for that? Anyone?

There’s more – particularly around one of my favourite expressions, ‘negative target market’ which is regulatorese for ‘folk who shouldnae be buying this hingmy over here’ and isn’t being done right, and costs disclosures which are still a mess.

But for me the report generally is interesting for the post-MiFID II dynamic between distributors and manufacturers that it exposes. The burden of product governance and suitability is shared between both groups – that’s good news if you’re an adviser firm because there are others in the firing line with you (this reminds me of the famous Billy Connolly joke about the wildlife photographers and the lion). But with that sharing of the burden comes a new set of responsibilities to share data on your business back with manufacturers, and I’m not sure how aware, well set up or even willing adviser firms are for this. Not to mention that there will be people very happy to sit in the middle and make a buck from monetising that data. All that might be fine with you, but it’s a new world out there and it takes some thinking about.


  • How much is cashflow planning worth? The answer, it turns out, is $145m, which is what US-based TAMP provider Assetmark is paying for Voyant. Looks like the little bars on the chart will be green for Voyant’s current owners right up to age 99 and beyond.
  • Talking of cashflow, Intelliflo has been busy uniting all its businesses including cashflow system i4c under one master brand. I’m interested to see how its new ‘intelliflo portfolio’ management system shapes up in particular – this will be based on the Redblack system and is a big sign on how intelliflo (we have to do lower case now) isn’t content to stay in its box.
  • We’ve been busy on the technology front too. If you want to see the latest updates to Platform Analyser, then pop along to our free demo tomorrow at 11am. All welcome.
  • And if you’re into fintech, you need to read the Kalifa report. It’s OK to just read the summary…12 pages instead of 108, though there are pictures.
  • Deep white-labelling of platforms continues to be a trend. This time it’s Asset Intelligence Research with Fundment behind the scenes. We’re going to see a lot of this over the next couple of years and challengers like Fundment, Hubwise and others should do well out of it.
  • No HomeGames this week because Rishi, but if you don’t want to watch him then why not delve into the HomeGames archive and pick a past episode? This one was good. Next week we’re back with David Ricketts on the Woodford saga, and a new presenter in the form of the very lovely Craig Rickman. Register here.
  • And your music choice this week is from the new record by Nick Cave and Warren Ellis, because of course it is. The record is called Carnage and it’s great – because of course it is. Here’s White Elephant and you are very welcome.

See you next week