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SECOND DISCUSSION DOCUMENT ON INVESTMENT RELATED MATTERS
The general investment landscape
• Regulatory intervention is needed
Defining and understanding different activities performed under a discretionary investment mandate
Defining and understanding different activities performed under a discretionary investment mandate
Asset management
Multi-management
Alternative investment management
Discretionary investment management comprising manager selection (including management style and asset class selection)
Discretionary investment management comprising asset selection (including asset class selection)
To include hedge fund management, private equity management, and potentially other alternative investment strategies. This category would in effect be an appropriately expanded version of the current FAIS Category IIA license category.
Defining and understanding different activities performed under a discretionary investment mandate
Defining and understanding different activities performed under a discretionary investment mandate
FSCA invites suggestions on possible naming:
CATEGORIZING INVESTMENT ADVISERS WITHIN AN RDR FRAMEWORK
• Goes hand in hand with RDR – Categorization of Advisers Paper
• 2 types of advisers
• Same entity may not operate as both PSA and RFA
PSA’s of LISPs
PSA of CIS management companies
PSA of investment manager
PSA may recommend / offer the following
Investment Manager
Advice
LISP Services
Independence of advice in 3rd party co-branded arrangement
Responsibility for use of LISP’s in 3rd party co-branded models
Investment Manager
Implications for remuneration and charging structures
Cost disclosure
Mitigating the risk of duplication of charges
Mitigating the risk of conflicted advice in vertically integrated models
Facilitating and monitoring advice and other fees
Remuneration for automated advice
Remuneration for non-advice distribution
Feedback received:
Additional risk measurements include the following:
Proposal: Ensuring the relevant relationships are clear through common branding, advertising and marketing.
Stakeholder feedback:
FSCA’s updated position
Proposal: Requiring advice and investment management in groups to be provided through separate legal entities.
Stakeholder feedback:
FSCA’s updated position
Stakeholder feedback
FSCA’s updated thinking