irish funds toronto seminar 2018 · 2018. 3. 13. · regulator under aifmd, with subsequent signing...
TRANSCRIPT
2
irishfunds.ie
12 March 2018
Irish Funds Toronto Seminar 2018
irishfunds.ie
Premium Sponsors
irishfunds.ie
Event Partners
irishfunds.ie
Tara Doyle
Chairperson, Irish Funds
Head of Asset Management, Matheson
Welcome Address
irishfunds.ie
Irish Funds Industry Overview
irishfunds.ie
A Global Funds Centre…
irishfunds.ie
For Global Distribution
irishfunds.ie9
Total Assets under Administration
- split between Irish domiciled & Non-Irish funds
Source: Central Bank of Ireland December 2017
irishfunds.ie10
Irish Domiciled Assets
• UCITS represent 75% of
Irish Domiciled Assets
• 88 UCITS Man Cos
• 161 AIFMs Registered or
Authorised
• 642 AIFMs operating in Ireland on
cross border basis
• 410 ICAVs established
(since 18 March 2015)
Source: Central Bank of Ireland
2018
irishfunds.ie
Growth of Largest European Fund Domiciles
Source: EFAMA Statistics
0%
20%
40%
60%
80%
100%
120%
140%
2011 2012 2013 2014 2015 2016 2017
% G
row
th
2011 2012 2013 2014 2015 2016 2017
Europe 0% 13% 23% 42% 58% 78% 97%
Luxembourg 0% 14% 25% 48% 67% 77% 98%
Ireland 0% 16% 27% 57% 80% 98% 126%
France 0% 9% 10% 14% 21% 29% 37%
Germany 0% 13% 24% 40% 53% 66% 80%
UK 0% 17% 35% 59% 79% 77% 99%
Europe Luxembourg Ireland France Germany UK
1212 irishfunds.ie
Net Sales into Irish Domiciled Funds
Source: Central Bank of Ireland 2018
• > 30% of net sales
into all European
funds in 2017
irishfunds.ie
Other Developments….
• Updating of Ireland’s Investment Limited Partnership Legislation
• Legislative amendments approved by Irish Government.
• Entering legislative process
• Will provide additional scope for private equity and real asset funds.
• European Commission ESAs Proposals
• While there are aspects to the European Supervisory Authorities (ESAs) proposals we welcome, there are a number of
areas which are of significant concern. We have shared our views in Ireland and in Europe.
• Strong advocates of delegation to globally based experts.
• Loan Origination
• New enhancements have been made to the L-QIAIF.
• Tax Transparency
• OECD has awarded Ireland the highest international rating on tax transparency and exchange of information.
• EU Cross Border Distribution
• Consultation on removing barriers to Cross Border Distribution submitted 2016 and follow-up questionnaire completed
2017.
• We have subsequently met with the European Commission.
• Expected Q1 2018
irishfunds.ie
Other Developments….
• Pan European Personal Pension Plan (PEPP)
• Industry white paper published on PEPP.
• We have subsequently met with the European Commission.
• Financial Action Task Force (FATF) Mutual Evaluation Report (MER) of Ireland
• FATF’s assessment of Irelands anti-money laundering and counter terrorist financing concluded that “Ireland has a
sound and substantially effective regime to tackle money laundering and terrorist financing….” In addition the
Report highlights “National coordination mechanisms… and the Private Sector Consultative Forum (PSCF) were
fruitful in broadening the understanding of its ML and TF risks across all relevant agencies and with the private
sector.”
• CBI engagement re Exchange Traded Funds (ETF)
• Responded to Central Bank of Ireland (CBI) ETF discussion paper and engaged with the CBI throughout the
process.
• Consultation paper on CIS Liquidity Risk Management
• Response provided to the International Organization of Securities Commission (IOSCO) Consultation paper.
irishfunds.ie
Conclusion
• EU Member & Strategically Positioned
+
• International Hub for Globally Distributed Investment Funds
+
• Unrivalled Experience and Expertise in the Widest Range of Fund Structures
Moderator:
Panellists:
irishfunds.ie
Panel Discussion: Setting up Products for
Global Distribution
Paddy Walsh, CACEIS
Terri Troy
Stuart Alexander, Gemini Capital
Krish Karunakaran, AGF
irishfunds.ie
For Global Distribution
1818 irishfunds.ie
Net Sales into Irish Domiciled Funds
Source: Central Bank of Ireland 2018
• > 30% of net sales
into all European
funds in 2017
irishfunds.ie
David Walsh, Dillon Eustace
Update on Brexit
2020 irishfunds.ie
Brexit: three interdependent themes
Distribution
Management
Models
(‘Delegation’)
Growth
OVER 2,400 IRISH
FUNDS SOLD TO UK
INVESTORS
$636bn
IN IRISH FUND ASSETS
MANAGED BY 175+ UK
FIRMS IN IRELAND
Continuity in UK investor
access to Irish funds
Continuity in
UK firm
management
of Irish funds
Increase Ireland’s growth
trajectory as an
international asset
management centre
SOURCE: Lipper IM Dec 2016
Monterey Ireland Fund Report 2017
Current context Target outcome
2121 irishfunds.ie
Brexit Timeline
Possible Transition Period
Indicative Deadline
for SMIC &
Delegating Super
ManCo Authorisation
August 2018Indicative Deadline
for MiFID & ManCo
with Add On
Authorisation
June 2018
2222 irishfunds.ie
International asset management centre
Growth
‘The Basics’
•Predictability / efficiency of regulatory process
•12.5% corporate tax rate
•Common law system
•Only English-speaking country in the Eurozone
•Less expensive than Zurich, Paris & Luxembourg1
Asset Manager Activity
Infra-structure
Reaffirmation of Ireland’s attractiveness as
an international asset management centreOpportunity
Benefits
SolutionProvide managers with options to support the
establishment of a physical presence in Ireland
NOTES:
1. Source PwC
2. http://www.iaim.ie/why-ireland (STEM = Science, Technology, Engineering &
Mathematics) & http://www.hea.ie/sites/default/files/awards_-
_all_undergraduate_by_level_and_field.xlsx
3. IFS 2020 Action Plan 2017 (http://finance.gov.ie) & IDA Ireland
4. MiFID firms, UCITS ManCos, Irish AIFMs & Non-Irish AIFMs - CBI
• Space for 100K new employees by 2020, 100K new houses3
• Leading global tech centre & fintech location
• London-Dublin: Most flight options in Europe
• 35K+ employed in international financial services in Ireland, 16K in funds industry
• 130K degree-level graduates across business, law and STEM w/ 20K new grads p.a.2
• 800+ investment firms active in Ireland4
• Increased presence of front office activities
• 18 of the top 20 global AMs have Irish funds
• €4trn total AuA, €300bn managed from Ireland2
• AM counterparties already in transit from UK
2323 irishfunds.ie
Brexit: key points to pursue
• Encourage UK Treasury & FCA to recognise
Irish funds as eligible investments for UK
investors post-Brexit
• Encourage CBI to confirm that the provisions
of the 1998 MoU with the FCA enable
continuity for delegation of UCITS
management.
• Encourage ESMA to negotiate a cooperation
agreement with the FCA as a 3rd country
regulator under AIFMD, with subsequent
signing by CBI.
• Encourage the Irish Government to support
growth in employment, diversifying skill sets
and infrastructure to assist businesses
relocating to Ireland due to Brexit.
Distribution
Management Models
Management Models
Growth
“Our three key
themes are
interdependent.”
DistributionManagement
Models(‘Delegation’)
Growth
2424 irishfunds.ie
Structuring options: Management models
DEFINITIONS:
• ‘MiFID Firm’: Investment firms authorised under Markets in Financial Instruments Directive (2007, to be replaced by MiFID 2 / MiFIR in January 2018)
• ‘Super ManCo’: authorised to provide services to UCITS and AIFs w/ the option of add-on authorisations for segregated mandates
• ‘SMIC’: Self-Managed Investment Company
MiFID Firm
Super ManCo w/ Add-on Authorisations (‘v2’)
Super ManCo w/ Delegates (‘v1)
SMIC• Simple option for single umbrella fund
• ‘v1’: widely used standard model w/ delegation option
• ‘v2’: ‘add-ons’ enable management w/out MiFID manager as delegate, including mandates
• Wider range of permissions availableGlobal
Asset
Managers
Regional
Asset
Managers
Multiple Asset
Manager types
Management
Models (‘Delegation’)
2525 irishfunds.ie
Structuring options: detail
SMIC Super ManCo w/
Delegates (‘v1’)
Super ManCo w/ Add-on
Authorisations (‘v2’)
MiFID Firm
Authorisation indicative
timeline
Allow 6 to 8 months during high
volume periods
Allow 6 to 8 months during
high volume periods
Allow 8 to 9 months during high
volume periods
Allow 9 to 10 months during
high volume periods
Activities (PM = portfolio
management, RM = risk management)
Retain oversight of PM & RM but
delegate day to day activities
Retain oversight of PM &
RM but delegate day to day
activities
Performs day-to-day PM & RM Full range of services
Manage other fund umbrellas? No Yes Yes Yes
Manage/advise Segregated
Mandates?
No No Yes, via add-on licenses without need
for MiFID delegate
Yes
Substance requirements • 2 Irish-resident directors
• 2-3 Designated Persons1
• 2-3 Irish-resident
directors1
• 2-3 Designated
Persons1&2
• 2-3 Irish-resident directors
• 2-3 Designated Persons1
• Chief Investment Officer / Managing
Director
• Head of Risk/Compliance and
Finance, internal audit.2
• Substantive presence
required in Ireland3
• Specific roles based in
Ireland2:
• Legal & compliance
• Financial control
• Risk Management
Delegation / Outsourcing CBI permits delegation of day-
to-day PM and/or RM activities
CBI permits delegation of
day-to-day PM and/or RM
activities
CBI permits delegation of day-to-day
PM and/or RM activities
Outsourcing allowed (including
to other EEA states or 3rd
countries) if in line with
applicable law and best practice
1. Designated persons not all required to be Irish resident and can be directors or employees of the Investment Manager. For ‘low’ PRISM rated firms, half of the directors and at least 2 Designated Persons performing half of the
managerial functions are required to be EEA-resident. For ‘medium’ PRISM rating firms, 3 directors or 2 directors plus 1 designated person should be Irish resident.
2. The need for specific roles may differ on a case-by-case basis, depending on complexity and number of branches.
3. ‘Substantive presence’ for MiFID: the firm’s board and management run the firm from Ireland and make decisions in Ireland with sufficient staff and resources to manage the risks.
2626 irishfunds.ie
SMIC Super ManCo w/ Delegates (‘v1’) Super ManCo w/ Add-on Authorisations
(‘v2’)
MiFID Firm
Capital
Required
€300,000 initial capital (which
can be met using shareholder
funds)
One quarter of its total expenditure in
its most recent annual accounts and
€125,000 plus an additional amount
of up to 0.02% of any AUM
exceeding €250m whichever is
greater, subject to a maximum
amount of €10million
One quarter of its total expenditure in its
most recent annual accounts and
€125,000 plus an additional amount of up
to 0.02% of any AUM exceeding €250m
whichever is greater, subject to a
maximum amount of €10million
Will be calculated in accordance with
CRD IV / CRR requirements
Pros • Works well if no other funds
managed
• Less staff on the ground
• Can manage multiple fund
umbrellas
• Can passport to other EEA
jurisdictions
• Less staff on the ground than v2 or
MiFID option
• Can perform full PM activities or
delegate
• Can manage multiple fund umbrellas &
mandates
• Can passport to other EEA jurisdictions
• Less staff on the ground than MiFID
option
• Wide range of
permissions/potential business
lines available
• Can passport throughout EEA
without seeking additional
authorisations
Cons • Cannot perform all PM
activities
• Cannot manage or advise
mandates
• Must delegate to regulated
investment manager
• Cannot perform all PM activities
• Cannot manage mandates
• More staff on the ground than SMIC or
v1 option
• Add-on authorisations possible, which
may be subject to local review when
passporting to other EEA jurisdictions
• More staff on the ground
• Subject to CRD IV / CRR
requirements
• MiFID 2 changes in Jan-2018
Structuring options: pros & cons
Moderator:
Panellists:
irishfunds.ie
Panel Discussion: Regulatory Hot Topics
for 2018 and Beyond
Philip Lovegrove, Matheson
Andrea Horton, RBC
Tony Spratt, McCann FitzGerald
Harvey Kalman, EQT
irishfunds.ie
Cormac Dinan, Deloitte
FinTech and Disruptive Innovation in
Investment Management
29 29
FinTech and Disruptive Innovation in
Investment Management
30
FinTech and Investment Management
31
Eight forces have the potential to shift the competitive landscapeof the financial ecosystem
DISRUPTIVE FORCES
Cost Commoditization: Financial institutions will accelerate the commoditization of their cost bases, removing them as points of competition and creating new grounds for differentiation1
Profit Redistribution: Technology and new partnerships will enable organizations to bypass traditional value chains, thereby redistributing profit pools2
Experience Ownership: Power will transfer to the owner of the customer interface; pure manufacturers must therefore become hyper-scaled or hyper-focused3
Platforms Rising: Platforms that offer the ability to engage with different financial institutions from a single channel will become the dominant model for the delivery of financial services4
Financial Regionalization: Diverging regulatory priorities and customer needs will lead financial services in different regions of the world down distinct paths8
Systemically Important Techs: Financial institutions increasingly resemble, and are dependent on, large tech firms to acquire critical infrastructure and differentiating technologies 7
Bionic Workforce: As the ability of machines to replicate the behaviors of humans continues to evolve, financial institutions will need to manage labor and capital as a single set of capabilities6
Data Monetization: Data will become increasingly important for differentiation, but static data sets will be enriched by flows of data from multiple sources combined and used in real time5
Source: Beyond FinTech: A pragmatic assessment of disruptive potential in financial services, Deloitte & World Economic Forum Report
32
FinTechs have changed how financial services are structured, provisioned and consumed, but have not successfully established themselves as dominant players
WHERE FINTECHS HAVE SUCCEEDED WHERE FINTECHS HAVE FALLEN SHORT
FinTechs have materially changed the basis of competition in financial services, but have not yet materially changed the competitive landscape.
CONCLUSION
FinTechs have defined the
direction, shape and pace of
innovation across almost every
subsector of financial services
Customer willingness to switch
away from incumbents has been
overestimated
FinTechs have struggled to
create new infrastructure and
establish new financial services
ecosystems
FinTechs have reshaped
customer expectations, setting
new and higher bars for user
experience
Source: Beyond FinTech: A pragmatic assessment of disruptive potential in financial services, Deloitte & World Economic Forum Report
33
• FinTech formations are in decline with a sharp decline in start-up activity since 2015, and a dramatic dive taking place in the first three quarters of 2017
• Since 2008, the Investment Management industry has seen the lowest level of activity across the Financial Services sector
• Venture Scanner data show that acquisitions are up significantly in the past four years in Investment Management
Deloitte Center for Financial Services recent report* (“FinTech by the Numbers”) confirms that robo-advice
and Direct 2 Consumer distribution is the FinTech largest growth area within Investment Management
*Deloitte Center for Financial Services: FinTech by the Numbers
FinTech formations are in decline, however the level of acquisitions of FinTechs has increased in Investment Management
34
Emerging Toolkit for Investment Management firms
Robotic & Cognitive Automation Cognitive Analytics Blockchain Technology Robo Advisory
Automate high volume, rules based processes
Interpret human judgement & behavior
Provides an avenue to connect and interact securely across entities
Backbone technology behind Bitcoin
Apply analytics and cognitive computing technologies to help humans make smarter decisions
“Mimics Human Actions”
“Augments Quantitative Human Judgement”
“Digital ledger system that enables secure peer to peer
transfer of value”
“Makes Sense of Unstructured Data”
Sample Technology Vendors & Tools
Algorithm based adjustments & rebalancing proposals following pre-defined investment rule-sets
“Augments Human Intelligence”
Examples:
Software referred to as “bots”
Natural Language Processing
Natural Language Generation
Examples:
KYC
Transfer Agency
Regulatory reporting
Cash/ Collateral Availability
Examples:
Predictive analytics and decision-making support
Cognitive Automation / Machine Learning for Analytics
Examples:
Automated portfolio construction / rebalancing
Advisor-led solution with integrated investor and advisor workflows
35
Leverage technology to enable an efficient, differentiated customer journey
36
As individuals assume more responsibility for their investments, robo-distribution has become
the most compelling way to work with them.
What does this mean for Investment Management firms?
FinTechs have changed how financial services are structured, provisioned and consumed, but have not successfully established themselves as dominant players
Differentiation of offerings:Middle and back-office automation, combined with the growing ubiquity of robo-advisors,are turning investment into a commodity.
As a result, leading firms will look for other ways to stand out from the competition—especially through more personalised customer offerings
Level of disruption is increasing:There is no end in sight when it comes to the increasing level and availability of new emerging technologies in the areas of data, automation and DLT. Clear strategy is required to harness the benefits.
Role of human advisers:Human advisers will still be crucial to differentiate products, especially for customers with high net wealth. But the role of such advisers will shift from product selection to customer engagement, emotional intelligence, and decision support.
Key Takeaways
Where
disruption has
occurred
Where it
hasn’t?
It takes fewer resources to deliver more investment advice, as middle and back office
functions are increasingly automated.
New entrants to investment management have struggled to gain market share as customers
stick to existing providers and the cost of enticing them away remains high.
irishfunds.ie
Kieran Fox, Irish Funds
Closing Remarks
irishfunds.ie
Annual Global Funds Conference 2018
Now in its 20th year, the Irish Funds
Annual Global Funds Conference is a
highlight of the international funds industry
calendar.
The conference brings together prominent
industry speakers to discuss current
issues and challenges facing the global
funds industry.
For further information on registration,
sponsorship and exhibition please visit
irishfunds.ie/conference2018.
irishfunds.ie
Premium Sponsors
irishfunds.ie
Event Partners
irishfunds.ie
Drinks Reception Kindly Sponsored by