TISA: THE INDUSTRY AGENTS FOR · PDF filemembers’ determination that what is best for...

TISA: THE INDUSTRYAGENTS FOR CHANGE

ANNUAL REVIEW 2014

WHILST IT IS NOT SHEER NUMBERS that define the quality and relevance of our output, there are some important statistics that do show this clearly:

¡TISA membership continued to increase to 147, demonstrating the strength of our appeal;

¡We maintained a record number of initiatives – 11 new councils, committees and working groups were established with over 110 member organisations and 520 individuals actively involved in our work;

¡TISA events were attended by over 1,200 people and are an important source of CPD across the industry.

Our mission is straightforward – we seek to work with all relevant stakeholders to review, develop and implement effective policies, regulations, products, advice and services; thereby encouraging individuals to have the appropriate savings and investments to support them, and their families, throughout their lives.

Drawing members from right across the financial services sector, TISA transcends the interests of other more narrowly focused organisations. This, coupled with our members’ determination that what is best for the consumer and the nation ultimately leads to a stronger industry, is what sets TISA apart – and it is this distinction that helps support our excellent standing with government and regulators alike.

These important characteristics are leading us to make important contributions in policy, operations and in more technical fields. TISA is capable of tackling difficult cross-industry issues, and our broad membership enables us to achieve a consensus that might otherwise be impossible in other forums. The reports from our policy

councils and key projects that follow in this review will provide more detail on the specifics of work undertaken and underway. In the meantime I would like to highlight some of our many successes during the year.

POLICYTISA continues to lobby actively on a wide range of issues. We have responded to a broad range of discussion papers and guidance consultations and it is pleasing to see our ideas feature in the Chancellor’s Budget and Autumn Statement.

One of our greatest strengths is the ability to develop policies and present these effectively to government, regulators and opinion formers. This lobbying is often done away from the public eye and in many cases over a number of years. Government announcements in 2014 reflected our efforts on a number of fronts. On ISAs, enhancements to the flexibility of the regime with the ability to transfer from Stocks & Shares to Cash, the consultation on the inclusion of peer to peer lending as a qualifying investment, along with the transfer of ISA assets to spouses and civil partners on death were particularly welcome. Government support for The Savings & Investments Policy project (TSIP) theme to develop a ‘pensions will’ to allow the transfer of pension assets on death without the current tax penalties is another example of a change that will bring considerable benefit to consumers, and reflects the best interests of TISA members. à

2013/14 was another record year for TISA as our organisation has continued to extend both the scope and scale of our activities in response to feedback from our members.

CHAIRMAN’S REVIEWANOTHER RECORD YEAR

2 TISA Annual Review 2014

TISA: Delivering Value to our Members

Developing policy to encourage saving, deliver good consumer

outcomes and support a successful UK financial services industry

Continuing to provide practical help to our members around tax incentivised products

Delivering solutions to improve the efficiency

of operations and infrastructure

KeyFocusAreas

The Chancellor has done much in recent years to make saving in ISAs and pensions more attractive, and TISA has been a keen supporter of many of the reforms introduced. At the same time, there is much more to be done if we are to change the culture of consumption and debt to something more balanced with saving.

This has been a key policy focus during the year and will remain so during 2015. The TISA-initiated TSIP project identified the difficulties facing the majority of the UK population who do not have even the resources to meet short-term emergencies without recourse to debt. At the same time, responsibility for saving for a comfortable old age has passed from the State and corporations to the shoulders of each individual, while longevity and rising care costs make this an increasingly difficult task.

In this environment, the challenge is how we can both encourage those who are saving to save more, and for those who could, but are not, to make a start. TSIP is addressing these issues and will be announcing the first of its policy recommendations in early 2015.

INFRASTRUCTUREAt the same time, TISA has also continued to work on infrastructural initiatives designed to reduce cost and risk across the industry. The TeX initiative to speed asset transfers between platforms has been a great success and the FCA recently noted a significant fall in complaints related to transfers. We are now working to extend TeX’s application to pension transfers – in fact, the first such transfer has already taken place and we are looking to build this out in the coming year.

TECHNICAL SUPPORTTISA has also made important contributions on technical matters that will have had significant benefits to the industry and consumers. These have included detailed discussions with the FCA on topics such as Direct to Consumer (D2C) suitability, and HM Treasury and HMRC on the application of VAT in various contexts. We have tackled issues as diverse as client assets, data quality, FATCA and share class conversions – the list is long. à

TISA Annual Review 2014 3

Tony SolwayChairman, TISA

All of this good work depends on our member organisations, on whose financial support we rely. I am also grateful for all the hard work put in by those individuals on our policy councils, committees and working groups, in particular.

I would further highlight the contribution of our executive management team and the staff of TISA who work tirelessly on behalf of our members. After nearly 13 years our Director General, Tony Vine-Lott stood down in 2014. I would like to thank Tony once again for all the excellent work he has done for TISA and the industry as a whole. TISA has achieved much over the years of his tenure to improve policy, process and products in our industry, and especially the ISA – the most successful savings vehicle of modern times.

A rigorous selection process was undertaken by the Board, involving the help of specialist recruitment consultants, to identify and appoint the new Director General. The number of exceptional, high calibre candidates who put themselves forward for consideration is testament to the high regard that TISA is held in. All candidates outlined compelling visions for the future direction of TISA and our choice was a difficult one. I would like to thank each candidate for their interest in the role.

I am delighted that David Dalton-Brown has been appointed as TISA’s new Director General and very much

look forward to working with him in the coming years. David brings a number of important qualities to TISA and he is committed to making a positive difference to UK savers and investors. TISA is financially strong, with a capable executive team in place and a membership that is highly engaged. This is an excellent platform on which David can build.

TISA’s work is guided by a strong and capable Board, and I would thank all my fellow directors who give of their scarce availability so freely in support of our aims. We have been pleased to welcome three new non-executives this year:

¡ Elissa Bayer, Senior Investment Director at Investec Wealth & Management Ltd;

¡ Mary-Anne McIntyre, CEO at Openwork; and

¡Tony Stenning, Managing Director UK Retail at BlackRock.

Our Board now has a good cross section of leaders spanning our industry and we will remain focussed in 2015 on the big issues that face our members, looking to support change in the best national interest – that of both our industry and of savers – in policy, infrastructure and technical matters. We are going through a period of major change, particularly in pensions and workplace savings, and I am sure that, working together, we can make a positive difference to UK savings and outcomes for British savers. n


INTRODUCING THE NEW DIRECTOR GENERAL

FOLLOWING THREE YEARS as a non-executive Director of TISA I have seen at first hand how it has become a successful and highly trusted industry body. Through its approach, as summarised by our Chairman at the start of this annual review, TISA has achieved an excellent standing with its members, regulators, government bodies, trade associations, consumer bodies and other major industry stakeholders. These excellent relationships, coupled with a clear focus on the development of policies, standards and industry infrastructure, have led to positive outcomes for consumers and, importantly, the UK financial services industry.

I therefore feel honoured to have been asked to take the position as Director General and to lead the future development of TISA.

My immediate priorities will be to:

¡Promote the policy ideas developed by The Savings & Investments Policy project (TSIP) and ensure that the work of our policy councils is aligned with that of this project;

¡Build on our existing strong membership engagement to seek input from our members on the key areas for further development for TISA;

David Dalton-Brown, TISA’s new Director General, has been a non-executive Director of TISA for three years and holds a number of non-executive posts at Barclays, where he was Director of Barclays Funds until 2013. Prior to that, David has held senior positions at Fidelity, KPMG, Norwich Union and Prudential.

David Dalton-BrownDirector General, TISA

¡Secure the delivery of the major new areas of policy and industry infrastructure development that are already being driven by our members through our growing number of policy councils and the emerging proposals from TSIP;

¡Support improvements to the industry’s infrastructure that are being driven by TISA members and TeX;

¡Further develop TISA’s productive working relationship with regulators, government bodies, trade associations and consumer groups.

I look forward to this new challenge very much and to working with the TISA members, TISA executive and staff in the coming years. n


THE SAVINGS & INVESTMENTS POLICY PROJECT

THE PROJECT MEMBERS REPRESENT building societies, banking, asset management, insurance, platforms, administrators, advisers, key trade bodies, professional services and consumer groups.

The first phase of the project focused on developing a comprehensive report on the challenges to UK savers, using the outputs to prioritise and develop an initial set of policy proposals that address key areas to help increase saving in the UK. The second phase of the project is engaging with government and regulatory bodies to promote our policy proposals, driving these forward in terms of translating ideas into action and creating additional policy proposals that will enhance and compliment the original proposals.

The project’s first major output was delivered in Q1 2014, a detailed report on consumer savings –‘Our Financial Future’. The scope of the report was both broad and ambitious and sought to understand the challenges impacting consumers and their savings behaviour across income, savings, debt, wealth, housing, pensions and long-term care. The report also added a time dimension to identify how culture and behaviours had changed over the past 50 years. The results point towards a nation that has progressively shifted towards a focus on today’s needs rather than planning for the medium or long-term. Easy access to credit has replaced saving. A third of the population has less than £250 in savings and half have less than £1,500 – equivalent to just 3 weeks’ salary for the average household. Savings into occupational pensions has slipped from 65% of the population in work to less than 30% today.

The report concludes that we face a ‘tipping point’ in 2035 when the generations entering retirement will be worse off than their parents for the first time in over 50 years. This trend accelerates from 2045 and beyond as the

The Savings & Investments Policy project (TSIP) was established in September 2013 to develop strategic policy proposals that increase the level of consumer savings, create financial resilience during a lifetime and provide for income needs in retirement.

effects of student loans and ever increasing house prices further impacts the generations that follow. The challenge of addressing the underlying issues is significant and requires a cohesive programme of joined up government and industry initiatives.

The project spent the remainder of 2014 considering potential solutions and filtering these down to a small number of recommendations that form the initial set of policies. By Q4 2014 TSIP had broad consensus on direction of the proposals and was finalising draft proposals ahead of making them public in early 2015. In parallel, the project team has been engaging with HM Treasury, HMRC, the FCA and the DWP plus key individuals across all the major political parties to both share our ideas and to get guidance and feedback on the potential political appetite. We have had a positive response to the project’s objectives and progress made to date plus recognition that we bring a unique perspective that incorporates a pan-industry view and has consumer interests embedded at the heart of all proposals. n

LOOKING AHEAD

In addition to the launch of the initial proposals early in 2015, the project is increasing the levels of activity to promote awareness of the issues and support for the solutions with those with the power to bring about change. TSIP will build upon the initial suite of proposals to develop additional policies that further contribute to strengthening the savings culture in the UK. The project will be also driving progress on its proposals by creating working groups that are tasked with turning ideas into action.

Charles McCready, Programme Director, TSIP


OVER 120,000 AUTOMATED TRANSFERS take place each month whilst the volume of transfer messages has risen from 5,000 in January 2013 to one million in 2014 – an increase of 166%. Transfer times of as little as two minutes have been reported by TeX members where all the processes have been fully automated and integrated.

We have achieved our core goal of substantially reducing the time taken to transfer a customer’s portfolio of assets, and have been informed that there has been a marked reduction in the number of complaints by customers. By improving the automated re-registration times between providers, TeX has cut costs for its members and in the process delivers real benefits for customers.

Membership has increased to now represent 97% of all UK platform assets and 95% of all UK funds under management. TeX annual membership fees cover operational running costs and we continue to build a contingency to ensure there is no future call on members for any additional cash injection in the event of a regulation change.

The TeX councils and project groups are continually developing and reviewing the standards, and accompanying legal documentation, in addition to making inter-operability improvements. In particular the TeX MI member forum has been working hard on new MI requirements which will come in to effect from June 2015, with reporting from July 2015, which will provide a more granular level of detail to identify issues and corresponding resolutions.

In April 2014, TeX introduced a new member category for pension providers based on a set of open standards together with supporting contracts and services that facilitate the automated, rapid and secure transfer of a client’s pension assets between providers. As a result, pension transfers between members who sign up to the new category will be subject to a maximum of a six business day service agreement. TeX was in the fortunate position to work alongside service providers such as Actuare, Altus, Calastone, Euroclear and Origo to ensure these standards are rigorous, transparent for consumers and practical to

implement. As an open industry facility, consumers and companies can benefit from faster transfers of pension assets with standards approved by regulators and the government. This facility is perfectly suited to the requirements of automatic enrolment and ‘pot follows member’.

The first pension transfer took place through TeX in June 2014, however there is still much to be done. Currently around half a million pension transfers are made per year and the number is forecast to rise to over one and a half million in 2015 as a result of more SIPP transfers, pension consolidations and ‘pot follows member’ activity. TeX estimates that industry costs from pension transfers and consolidation will amount to tens of millions of pounds during 2015. We believe that the current system, which is form-based, can be streamlined to significantly reduce the cost of transfers. n

LOOKING AHEAD

TeX will be focusing on the following goals throughout 2015:

Undertake a pensions pilot in 2015 to demonstrate the use of TeX pension transfers and drive membership to include pension providers who are yet to join TeX

Encourage the UK financial services industry to adopt electronic pension cash transfers and improve transfer times

Work with TeX members to identify other operational areas which could benefit from the use of electronic messaging and extend the current standards, SLAs, associated contracts and the required operational infrastructure to support those activities

Extend our scope to wealth and boutique managers to ensure they also benefit from the advantages of our open standards.

2014 has seen TISA Exchange Limited – TeX – go from strength to strength. In the two years since launch, TeX has enabled member firms to reduce transfer times, delivering significantly better service to customers.

Carol Knight, Operations Director, TISA and Director of TeX


TECHNICAL AND POLICY UPDATE

TISA STARTED THE YEAR working with HM Treasury on technical issues relating to the inclusion of peer to peer loans in ISAs, something for which TISA has lobbied for several years. We were thrilled that the Budget announced their inclusion and have been working to make this a reality since the announcement. We expect final details by the end of 2015.

TISA finished the year working with members and trade associations to deliver on the government’s welcome promise to permit surviving spouses and civil partners to inherit their deceased spouses ISA tax advantages. This means a great deal to people, and represents a triumph for TISA’s years of lobbying on the topic. There is a lot of detail to be sorted, but given the help of HMRC we are sure it can be delivered with the minimum of inconvenience to firms.

We have also continued to lobby for Workplace ISAs. TISA believes that where a good case for liberalisation can be made, the government will listen, as we have demonstrated with AIM stocks into ISAs, peer to peer lending and the transfer of ISAs on the death of a spouse. These government announcements followed years of persistent lobbying by TISA, mostly behind closed doors, and aptly demonstrates TISA’s continued success and leadership in the development of policy in line with government strategy for the benefit of our members, the wider financial services industry and client alike.

In between there was the announcement of:

¡an increase in the annual ISA allowance to £15,000, and permitting Stocks & Shares ISAs to be switched into Cash ISAs, together with some associated welcome improvements;

¡new pension freedoms, the abolition of the so-called death tax and the promise of free impartial guidance to people at the point of retirement.

This latter promise, built on what TISA regards as a healthy instinct to trust people with their own money, can be the springboard to a wider conversation with savers, whether in ISAs or through pensions, or wherever they have savings. Instead of people at retirement making a once in a lifetime decision about their retirement income – and we

know that most people who don’t take advice didn’t choose the best annuity option – they can be engaged in investment and savings decisions at critical life stages, say at 50 and 75, rather than just at 65. And firms’ view of customers will change if they believe that instead of pensions savings disappearing into an annuity at 65, customers could continue to be saving and investing with them until much later in life.

This fits very well with TISA’s goals within The Savings & Investments Policy project (TSIP), of encouraging a savings culture in the UK and of making it easier to save. Guidance and its application to savings decisions, not just at retirement, is now an important policy theme for all TISA policy councils.

The ramifications of the changes are still being worked through, and some were discussed in the retirement seminar TISA held in December. It was exciting to see how the market was coming up with innovative new products to meet customers’ needs.

TISA believes that trusting people with their own money together with encouraging competition is the best way to deliver lasting benefits to customers and the firms that serve them.

The other welcome change in the Budget was the increase in the annual ISA allowance, coupled with a new freedom to switch from stocks and shares to cash. These were changes we had lobbied for.

This increase and the new freedom opens up opportunities for Stocks & Shares ISA managers to offer cash products, both to protect their own customer base as well as to seek new customers. TISA’s Client Assets Technical Committee has been lobbying the FCA to update the client money rules and those on unbreakable term deposits to enable firms to compete in this area. We have also taken the opportunity of the consultation on peer to peer lending to ask that rules on cash switching should be liberalised to enable non-banks to compete in this area.

TISA has worked with the policy councils and technical committees to ensure that policy goals are up to date and that members are enabled to properly consider the à

2014 was a year to remember for people saving for retirement, whether through pensions or ISAs.

Jeffrey Mushens, Technical Director, TISA


implications of announcements from the FCA, HMRC and DWP. We have continued to work closely with them during the course of the year and been pleased that officials from DWP, HM Treasury, HMRC and the FCA have been willing to speak at TISA events and work with us on technical and policy issues.

Within the Retirement Policy Council, and corresponding technical committees and working groups, we will be working through the implications of the recent changes as well as with DWP on the implementation of automatic transfer of pension pots (the so-called ‘pot follows member’). We are very pleased, along with a number of members, to be part of the DWP working groups. The DWP’s proposed federated model for automatic transfers shares the TeX model of open standards with suppliers offering competing solutions. We believe this model of open standards with competition, rather than a single mandated solution, with all the risks of monopoly and lack of technical innovation, is a model with wide applicability in financial services. We shall be urging this vision on the new Payment Systems Regulator, together with a mechanism to permit stakeholders a voice.

The Wrap and Platform and Distribution Policy Councils are working through the implications of the ‘Guidance Guarantee’ and what that means for simplified advice, for advice more generally as well as the implications for a Direct to Consumer (D2C) model. There has been a great deal of interest in the implications of European legislation and a realisation that the industry should not be waiting until the FCA starts consulting. It is likely that TISA will start a policy council to consider EU and regulatory matters in the coming year to give greater intelligence and guidance to member firms, particularly for planning purposes.

As far as client assets is concerned, the FCA introduced a far reaching revision of the client money and client asset rules for investment firms. This involves changes to DVP for authorised fund managers, as well as new rules relating to funding for ISA and wealth managers, and a host of other rules, particularly in relation to cash.

Although we’re delighted that so many member firms get involved in TISA policy councils, we would like to see more. Their knowledge and understanding gives weight to us and, as we’ve seen some welcome changes following lobbying, they should be pleased to know that they can and do make a difference to government policy.

Later in 2015, TISA plans to publish a ‘Policy Manifesto’ for each of our policy councils which will set out the proactive range of policy developments in key areas of the market currently undergoing major changes. These manifestos will clarify the scope covered by each policy council, their areas of focus over the short-term and reinforce the relationship, and purpose, between the councils and their corresponding technical committees and working groups.

In addition, the policy councils will further evolve through the integration of TSIP worksteams. We anticipate that TSIP’s current format, as a separate project, will come to an end by December 2015, with each council assuming the responsibility to develop the specific TSIP policy proposals relating to their areas of expertise.

It’s been a busy and successful year. We expect 2015 to be even busier, particularly with a General Election taking place in May. n


CHILDREN’S SAVINGS POLICY COUNCIL

Changes to allow the transfer of a Child Trust Fund to a Junior ISA have once again been a key focus of our agenda. The government has taken steps towards introducing the legislation to facilitate this and the aim is to have the legislation given royal assent sometime in early 2015. At the end of November it had gone through its third reading. It is, however, being rolled up as part of other legislation and is therefore subject to its progress through Parliament too.

One result of the discussions was the announcement of a consultation on the lifestyling element that is contained within the CTF requirements. This was due to be implemented in 2015 and would have required development by the firms who sold the product. The council supported a delay of lifestyling until age 15 (implementation on 1st September 2017) in order to give time for HM Treasury to seek feedback from the industry and consumers on whether lifestyling should be a feature of CTFs going forward. Lifestyling is not a requirement of JISAs.

The council has continued to be a representative in discussions with HM Treasury over the specifics of the legislation in order to strike the balance between the needs of the process for transferring CTFs into JISAs and the capability of the industry to meet those needs. In addition, the BBA has hosted a wider industry discussion to cover both this legislation and the more detailed HMRC rules à

The Children’s Savings Policy Council continued to be dominated by the changes to allow Child Trust Funds (CTF) to be transferred to a Junior ISA (JISA).

Nigel BanfieldChairman, Children’s Savings Policy Council


that will need to follow. The council has representation in this group and will continue to support it through to the guidelines being produced. One aim is to update the ISA transfer processes currently in place, to include CTF to JISA.

A sub-group of the council is currently looking at how the industry can support the education programme and the recent changes to the National Curriculum. In addition, we are working alongside The Savings & Investments Policy project (TSIP) to ensure our aims dovetail.

A revision of the council’s ‘Terms of Reference’ and corresponding policy lines have been completed giving the council a renewed focus going forward. n

LOOKING AHEAD

The policy council will continue to provide support to the CTF/JISA legislation’s path and the HMRC rules to support its introduction in 2015. We will additionally support the consultation HM Treasury will carry out in early 2015. We will also continue to develop an approach for the industry to support the education of young children and their parents.

“Currently focussed on ensuring we have effective processes in place for the CTF to JISA transfers, the year ahead provides new challenges as we look for ways to extend and improve financial education for children.

Carol Knight, Operations Director, TISA


DISTRIBUTION POLICY COUNCIL

A CONSISTENT TOPIC THROUGHOUT THE YEAR was the end of trail commission payments to distributors, and greater clarity developed as the year progessed. Other strong themes were Direct to Consumer (D2C), the advice gap and in the second half of the year the new rules on pension liberation became a hot topic of discussion.

We entered 2014 with a good feeling about markets – they were quite buoyant and this seemed to be bringing private investors back to the equity market – although we did wonder if there would ever come a time when private investors would buy at the bottom and sell at the top, rather than the other way round! This optimism was tempered by the concerns about the end of trail payments and the uncertainty around the practicalities of share class conversion. TISA was able to provide guidance on this subject as we went through the year to clarify the issue.

Our Spring seminar, ‘Evolution of Distribution’, was well attended and the feedback was excellent. Comments from the attendees revealed they had particularly enjoyed the panel debate at the end of the seminar, perhaps something to do with the line up of ‘big hitters’ we were able to assemble. “Excellent, interesting, intriguing content. Felt like I learnt a lot” was one pleasing comment that stood out from the very positive response we received following the event.

In June we discussed The Savings & Investments Policy project (TSIP). The council felt that helping government to develop a more coordinated approach to savings was important, expressing some concern that loans are easier than ever to obtain and gambling is now the second biggest leisure activity in the UK. Suitability, D2C and simplified advice all got an airing and the council was able to give input to the forthcoming discussions with HM Treasury. We were also able to alert members to the TISA guidelines on share class conversions.

By September, it became clear that further clarification of the issues surrounding share class conversions was needed – what about off-platform products? What if there was no ‘clean’ share class available? What about CGT? These questions, and more, helped to inform a further meeting between TISA and HM Treasury to discuss these issues.

It also became clear that the distribution landscape was changing with banks and product providers (re)entering advice with technology driven propositions. We also noted the increasing attractiveness of vertically integrated business models and the move by a number of firms in this direction. Both are areas we are keen to continue to explore through the coming year. à

With the Retail Distribution Review (RDR) firmly in the rear view mirror, the Distribution Policy Council was able to focus on the future of distribution, in particular how the mass market might be served in the new world and how new forms of distribution would develop.

David HazeltonChairman, Distribution Policy Council


We noted that the FCA had raised concerns about disclosure of adviser charges – we felt that this was less of an issue for members, but is something that smaller IFAs need to be aware of.

The November meeting featured a presentation from BNY Mellon, based on a study they conducted with Oxford University, called the ‘Generation Game’ – a global study to research how millennials are engaging with financial services. It is clear that providers will need to approach this market quite differently as this group has a very different approach to savings.

We discussed the new guidance rules and the approach being taken by the TISA Retirement Policy Council’s working group, the Retirement New Guidance Executive Committee. We discussed default investment options and potential price capping and agreed with the general TISA view that we are in favour of transparency and free markets, but not price capping. Alongside this we discussed the concerns that have been raised in respect of fund manager charges and concluded that greater transparency of these charges is necessary.

Whilst there were a range of views concerning the business environment, pensions liberation was seen as positive in the long-term, with some disruption and potential risks in the short-term. Whilst there are lingering concerns about the advice gap and the end of trail commission, the council is optimistic about the state of distribution of financial services in the UK. n

LOOKING AHEAD

As 2015 gets underway, we recognise the need for increased long-term savings and support for the government and regulatory initiatives to increase savings for current retirees and future generations. However, we believe there are areas for significant consumer detriment that need to be mitigated. Distribution models need to continue to evolve to service the mass market, with technology being a key enabler. Consumer confidence in the industry is crucial and we believe further transparency is needed. Although we support the general thrust of regulation, the FCA should ensure that there is a clear distinction between advice and guidance, whilst ensuring that regulation does not inhibit a wider range of engagement by investors.

“The distribution landscape is still evolving well after RDR and the council has dealt with a number of key issues. It is gratifying to see attendance numbers rising within the council, demonstrating the importance of the issues dealt with. The 2015 ‘Policy Manifesto’, due to be published later in 2015, has identified some key industry drivers which will fully occupy the council’s mind and activity in the coming year to improve infrastructure in the market.

Peter Smith, Head of Distribution Engagement, TISA


RETIREMENT POLICY COUNCIL

FURTHER ANNOUNCEMENTS FROM BOTH the government and regulator followed, which kept the Retirement Policy Council busy throughout the year. Very few people could have foreseen the pension Budget bombshell that was announced by George Osborne in March 2014. The pension freedom changes were radical and had a drastic effect that was felt across the industry. It impacted heavily on share prices, business values, business models, operational capability and propositions.

The Budget changes set the scene for the year as more announcements kept coming throughout 2014. Trying to stay current between regulatory and government announcements, Steve Webb’s published intentions, consultation papers, research papers and expert opinion, the Retirement Policy Council and Retirement Technical Committee did a fantastic job by responding quickly and assisting the industry and government.

While the policy council and technical committee largely support the changes, the practicalities and consequences of some of these had to be considered carefully to ensure that the industry would be ready, that some of the proposed changes could realistically be made and most importantly that consumers would benefit from the new freedoms. The council had great support from TISA with the continuous work from Jeremy Lee and Steven Coe, supported heavily by Jeffrey Mushens and Peter Smith. à

2014 saw unprecedented change in the pensions world following the Chancellor’s announcement in the Budget that savers were to be given greater freedom in their personal pension choices.

Natanje Holt Chair, Retirement Policy Council


The supporting working groups and executive committees supported the overall workload. TISA reacted quickly to the Budget announcements by putting together the Retirement New Guidance Executive Committee. The committee, led by Kenn Taylor, responded to the ‘Guidance Guarantee’ consultation papers and implementation details. The aim for 2015 is that this group and the good work they’ve done to date will continue and convert into the Pension Engagement Working Group, which will in turn feed their outputs into the policy council’s objectives and policy lines. Specific objectives will include effective disclosure, increasing contribution levels, early access recommendations for emergencies or specific life events and focussing on improving consumer engagement for improved retirement outcomes.

The Retirement Technical Committee, chaired by Rob Reid, also had a very productive year responding to a number of key technical issues including the handling of SIPP assets that have lost all value, the proposed pension charge cap, the tax implication on taking benefits post-April 2015 and the prevention of pension liberation schemes exploiting the new rules. The council also hosted a well attended seminar in December discussing the forthcoming changes.

The Pension Tax Working Group, led by Adrian Boulding, combined and worked with the The Savings & Investments Policy project (TSIP) to deliver a new proposal for pension tax relief incorporating three-for-one matching and a bonus based on contribution levels. A key driver in 2015 will be to gain further industry and government support for the great work that was put into the proposals.

The Retirement and Later Life Working Group, chaired by Tom McPhail, is working towards creating policy lines and guidance on how to best integrate pensions and non-pension investments into a holistic retirement planning process. In addition the group is to consider the role of an evolving ‘Guidance Guarantee’ and if it should incorporate non-retirement products. Lastly the group is also looking at the need to improve knowledge, understanding and trust of the basic state pension to people’s retirement planning. n

LOOKING AHEAD

For consumers, pensions have suddenly become interesting and, dare I say, even exciting. Pensions are now the hottest dinner party topic and everyone is eager to share their opinions and views. Age 55 has become a desirable retirement age and April 2015 the date many people are anticipating with eagerness and others with dread. Nevertheless, it is fair to say there is great anticipation. There have been as many predictions on what will happen, but as an industry we are no doubt all very interested in the outcome. Will it be a tsunami of pension fund withdrawals and Lamborghini purchases, or will it be a year 2000 moment where nothing happens? It will probably be something in between, but it will certainly captivate the attention of the pensions industry and members of the Retirement Policy Council for the coming months.

“The Retirement Policy Council and its supporting committees will throughout 2015 continue to focus its efforts towards the successful implementation of the pension reforms, supporting the remaining automatic enrolment programme and start work on some of the exciting initiatives contained within our ‘Policy Manifesto’, which will be published later this year.

Jeremy Lee, Manager (Retirement & Technical), TISA


TOTAL INVESTMENTS HELD THROUGH advised UK platforms increased from £248bn to £302bn in the year to end September 20141 and now account for over 80% of all new retail fund flow and nearly 40% of all mutual fund assets held in the UK. Against this background, the Wrap and Platform Policy Council continues to act as the central discussion and co-ordination forum for platforms, fund managers, consultants, the FCA and HM Treasury/HMRC.

The main Wrap and Platform Policy Council meets on a quarterly basis whilst the Wrap and Platform Technical Committee, chaired by Stuart Wright, meets as required to examine issues in greater detail than is possible in the full council. In addition to our regular meetings, we also organised a very well attended seminar in May.

In recent years, much of the agenda for the council has been dominated by regulatory change and the need to digest and respond to the various FSA/FCA consultation papers, specifically their impact on platforms. This culminated in FCA Policy Statement 13/1 – ‘Payment to platform service providers and rebates from providers to consumers’ – setting out a number of changes through until April 2016. With the regulatory landscape for UK platforms

being more clearly defined for the next three years, the council has been keen to adopt a more proactive stance and sought to focus on a number of wider policy, taxation and operational issues, namely:

1. MOVE TO CLEAN SHARE CLASSESOne of the key PS13/1 requirements is the removal of payments from fund managers to platforms on all new business from April 2014 and on all legacy business by April 2016. Building on the 2013 workstream on re-registration and share class conversion, much work was done this year by TISA in interpreting and guiding platforms on best industry practice in handling individual client and bulk migrations to clean share classes.

2. PLATFORM RE-REGISTRATIONThe council continues to work closely with TeX and industry participants to improve processing times and reduce costs where clients move assets between platforms. A particular focus this year has been on clearing hurdles to STP (straight through processing) electronic re-registration, particularly around standardising nominee naming conventions. à

While growth rates are now beginning to slow to a more sustainable level, 2014 saw investment platforms further extend their dominance as the central connection between the long-term savings and advice industries and the asset management community.

WRAP AND PLATFORMPOLICY COUNCIL

David Moffat Chairman, Wrap and Platform Policy Council

1 Platforum – November 2014


3. CASS CLIENT MONEY CHANGESChanges proposed in CP13/5 and then finalised by the FCA under PS14/9, while primarily focused on the enhancing the safekeeping and segregation of client assets in collective investment schemes, also had a number of knock-on implications for platforms in the areas of bank account structures, settlement models and nominee custody structures. The council worked closely with the FCA and interested parties to clarify these requirements and held a well-attended industry wide conference in June to brief all concerned on the necessary changes well ahead of the June 2015 implementation.

4. PLATFORM VATFollowing much work in 2013, in Q1 2014 we received confirmation from HMRC that they had determined at a policy level that core platform administration functions be treated as exempt for VAT purposes. While only reconfirming the ad hoc agreements between most individual platforms and their local HMRC offices, establishing this at a policy level codifies this decision and establishes a level playing field for all UK platforms going forward.

Building on the increasingly strong relationship with HMRC, TISA continues to work to ensure platform services are not included in the EU e-services directive that would otherwise require platforms to adopt local country VAT treatment for clients who invested from or moved to another EU country.

5. SETTLEMENT AND PAYMENTSWith fund managers and platforms keen to increase efficiency and reduce the settlement time for funds, one of the major impediments to making progress in the retail market is the cost and delays imposed by the UK banking system. TISA has been asked by the FCA to engage with the major banks, the Payments Council, BACS and others in the hope an industry solution might be found.

“2014 saw the council working with the industry, government and regulators to provide best industry practice guides and support on many issues such as clean share classes, re-registration and CASS client money changes. The council will continue its proactive approach throughout 2015 to support platforms through the myriad of industry and regulatory changes likely to affect them this year.

6. PEER TO PEER LENDING AND ISASWith nearly 98% of new Stocks & Shares ISA business now conducted via platforms, TISA and the council have been at the forefront in discussions with HM Treasury in their desire to see peer to peer lending included as an admissible ISA asset. Having a concern not to undermine the simplicity and transparency of the core ISA ‘brand’, TISA remains convinced that any move to include peer to peer lending should be done under a completely new ISA category. n

LOOKING AHEAD

Looking forward to 2015, the work of the policy council and technical committee will continue to be dominated by issues arising from platforms moving to new commercial models and migrating legacy clients and adviser relationships ahead of the April 2016 deadline. In addition, with a number of new D2C (Direct to Consumer) propositions coming to market, it seems inevitable platforms will find themselves on the front line of the guidance versus advice debate.

Beyond this, the changes to pension regulations announced in the 2014 Budget play strongly to the strength of platforms and we would anticipate increasingly strong post-retirement propositions being developed and rolled out through the coming year, taking platforms into market spaces traditionally the preserve of traditional life insurance providers.

Jeffrey Mushens, Technical Director, TISA


THE FORUM CONSIDERED TECHNOLOGY trends emerging from other geographies or industries and how these are, or could be, applied to financial services in the UK. Driven in part from a key TISA project – The Savings & Investments Policy project (TSIP) – the underlying essence of this study examined the challenges of a UK consumer debt problem and the lack of a sustained asset based saving culture. TIF is considering cradle-to-grave behavioural patterns and trends, overlaying this with technology. The group will give a view on why innovation currently fails consumers and how TISA members can benefit from the insights revealed by the group. TIF is represented by a broad spectrum of professionals representing the breadth of financial services (banks, software, insurance, funds, child savings, pensions and consumer advice firms).

OBJECTIVESThe main objectives for TIF are as follows:

1. Report on how technology can support the different stages and savings opportunities in a consumer life cycle;

2. Report on how to help the consumer to feel empowered to enact financial decisions in a more user-friendly manner;

3. Report on the latest trends in the global technology delivery of financial services products;

4. Report on the adoption of this technology within the UK;

5. Highlight latest innovative technology examples in the UK financial services market place;

6. Provide a brief update on any regulatory impact of technology usage or other perceived disruptors;

7. Progress the forum into a full TISA policy council, open to TISA members only, for the ongoing review of technology and innovation across the UK financial services industry and the impact this may have on regulatory and policy decisions. à

TECHNOLOGY INNOVATION FORUM

TISA created the Technology Innovation Forum (TIF) in 2014 with the purpose of providing insight into how innovation, ideas and the deployment of technology within the global financial services world influence consumption and behaviours from a financial services perspective across the range of age demographics.

Bill Wrest, Chairman, Technology Innovation Forum


Initial workstreams focused on the following key demographics:

¡‘Can’t save’ – those that do not have enough disposable income to save. This group is interesting given that 30% of the UK population is one month, or £1,000 or less, away from financial crisis;

¡‘Won’t save’ – this group does have disposable income but chooses not to save for a variety of reasons – for example instant consumerism, wrong products etc.

Throughout the year, the forum proceeded to review a number of key factors pertinent to the savings sector, specifically technology, inhibitors/disruptors and demographics.

TECHNOLOGY Is the current use of technology fit for purpose? And why does the market still trade on a T+4 basis – with such a heavy reliance on cheques – when every other internet-driven purchase we make is a ‘3-click experience’? Does technology target different demographics and adapt to their changing life cycles, e.g. from child savers and those who follow elements of ‘gamification’ to more mature and focused investors?

The emergence of the internet allows us instant purchase, instant access and instant gratification; however, financial services are slow to embrace this trend. In addition, the sector faces wider issues around what constitutes online advice or guidance. In the future, will we see emerging financial players offer new savings products – as we have already seen with alternative payments providers challenging traditional banking such as Apple, Google and Facebook. It will be interesting to see who wins and who loses in the emergence of payments providers. The market seeks value-added differentiation and it is not enough to be digitally empowered – operating as simply another payment channel – with no compelling reason for consumers to use it.

Clearly, the technology exists to enable change – we can send instant, irrevocable digital payments – and yet adding a digital passport identity and completing the investment cycle is still hugely problematic. Digital payment providers – and banks in particular – may have a key role to play in this, if they can share client validation at the front end of the transaction.

INHIBITORS/DISRUPTORSThis workstream was established to look specifically at regulation, new technology and legacy products. Does a post-RDR (Retail Distribution Review) environment help to promote or inhibit a digitally-led savings strategy? One key challenge that the forum seeks to address is the ease with which customers can access funds, e.g. getting a loan instantly approved by telephone, opening a betting account and operating it immediately, in comparison to the problems faced when attempting to instantly invest and identify oneself.

DEMOGRAPHICSThe current model follows a cradle-to-grave savings culture that reacts to customers’ major life decisions and changing needs. One element of this problem is the fact that the UK’s investment advice and products are almost exclusively the domain of the ‘silver-surfer’, 50-year plus professionals while other demographics – including generations X/Y and females – are seemingly ignored.

The forum also identified the need to respond to the recent pension reform, which has played a disruptive role for savings (due to the change in cash and annuities), as well as the ‘pot follows member’ structure which emerged during the year. This structure is particularly beneficial to younger demographics that, on average, will change jobs every 4.4 years during their working lives. This is in addition to the premise of a digital passport, whereby savers can transfer their pensions between jobs and is likely to be the cornerstone of future digital savings strategies.

SUPPORTING A SAVINGS CULTUREThe points considered by TIF during 2014 will be published in a report in 2015. While the digital revolution will be quick, the cultural shift needed to influence savings across all demographics in the UK will take generations. The TIF group will continue to function within TISA and promote technology-led industry change. n

LOOKING AHEAD

My sincere thanks to the entire forum for having collectively achieved so much in our first year. I believe that the forum provides a real opportunity for the financial services industry to step back and consider innovative technologies that could transform the way people engage with the sector, and I look forward to a busy 2015 as we continue to focus our efforts on helping the industry innovate and encourage a savings culture across all demographics.


SAVINGS SCHEMES REVIEW

ISA SUBSCRIPTION LIMITS For a number of years, the ISA subscription limits have been increased in line with the rate of inflation as measured by the Consumer Prices Index (CPI). As we approached 2014/15, we prepared for an overall limit of £11,880 with correspondingly lower limits of £5,940 for Cash ISAs and £3,840 for Junior ISAs (JISAs) and Child Trust Funds (CTFs). However a major revamp of the ISA scheme was about to make its appearance in the March 2014 Budget.

The Budget changes were largely unexpected and almost universally welcomed across the industry. Following years of lobbying, with effect from 1st July 2014, the Cash ISA subscription limit was doubled from 50% of the overall annual limit to a welcome 100% so that, for the first time since ISAs began in 1999, investors could now put their full annual subscription entitlement into a Cash ISA and, to the unanimous delight of all concerned, the overall subscription limit was significantly raised to £15,000. It remained to be seen whether the previous policy of applying annual index linked increases would be continued but any doubts were removed when the Chancellor announced on 3 December 2014 in his Autumn Statement that the ISA limit for 2015/16 would be increased to £15,240 and the JISA/CTF limit to £4,080.

Although the changes did not create a single ISA component in which both cash and stocks & shares could be held in the same ISA (the CTF model) as some would like, the restrictions on ISA transfers, which had previously prevented transfers from Stocks & Shares ISAs to Cash ISAs, were removed so that investors now have the freedom to move to and from each type of ISA as they believe appropriate for their particular financial circumstances at the time. The administration of Stocks & Shares ISAs was also simplified with the removal of the ‘cash-like’ tests for qualifying investments bought on or after 1 July 2014.

It was unfortunate that, in their efforts to draw attention to the significant improvements being made in the ISA

scheme, the government chose to refer to them as New ISAs (NISAs) and produce supporting explanations that could be misinterpreted by the layman. This led to enquiries as to how to transfer an existing ISA into a NISA etc. However, many providers have explained the changes more accurately in their ISA literature and it seems that most people now understand that the NISA is a most welcome improvement to the existing ISA scheme, not a new savings scheme.

ISA STATISTICSFigures published by HMRC at the end of August showed that the total amount subscribed to ISAs during 2013/142 remained virtually static, although this figure on its own masks the fact that amounts subscribed to Stocks & Shares ISAs3 went up 12.0% with a corresponding 5.09% drop in amounts subscribed to Cash ISAs4.The average subscription to a Stocks & Shares ISA increased by 9.5% to £6,1635 whilst the average subscription to a Cash ISA rose 5.8% to £3,704.6

The number of JISAs subscribed to in 2013/14, the second full year since they were launched, increased by 46.4% with 432,000 JISAs7 receiving a total of £578m, an increase of 47.4% on the first full year8. Whilst the overall average subscription to JISAs remained fairly static at £1,3409, the average subscription to Stocks & Shares JISAs rose 12.0% to £1,20810 whilst the average subscription to Cash ISAs fell 3.7% to £1,39111.

HMRC have also published market value statistics for ISAs as at 5 April 2014. The value of Stocks & Shares ISAs was £241.091bn, an increase of 8.5% compared with the previous year12. The mix of qualifying investments saw a slight fall in the proportion held in collectives13 (79.6%) as opposed to directly held investments14 (17.7%) and uninvested cash (2.7%). The split by value between Stocks & Shares ISAs and Cash ISAs was 51:49 with the value of Cash ISAs at £228.525bn, an increase of 3.6% on the previous year 15.à

Peter Shipp, Technical Director of Savings Schemes, TISA


OTHER ISA AND CTF DEVELOPMENTSIn October, the government published a consultation on how best to include peer to peer loans within the ISA scheme. TISA has lobbied for this for some time now and we were pleased to see the government announce their intention on this matter in the Budget. TISA submitted a detailed response in December and has been working on the logistics of making this policy a reality following the announcement. In the meantime, we await with interest the results of this process.

Following the 2013 consultation on the transfer of savings from CTFs to JISAs, in November HMRC published draft amendments to both CTF and ISA regulations for comment. Again TISA has been very much involved and this opportunity to comment closed at the turn of the year. These amendments cannot be laid until HM Treasury receive the necessary powers which require changes to the Child Trust Funds Act 2004, changes which are included in the Deregulation Bill, currently still passing through Parliament. However, HMRC expect this legislative process to be completed in sufficient time to enable transfers from CTFs to JISAs to take place from the start of the 2015/16 tax year.

In the December Autumn Statement, the Chancellor announced a consultation on whether to extend ISA eligibility to lenders using crowdfunded, debt-based securities. At the time of writing, no further details have emerged.

The Statement also announced that, from 3 December 2014, if an ISA saver in a marriage or civil partnership dies, their spouse or civil partner ‘will inherit their ISA tax advantages’. This has been widely misunderstood. It is not

a transfer of the deceased’s ISA to the surviving spouse/partner, nor does it give them a double allowance of £30,000 for the rest of their life. The proposal will allow the survivor to put cash and, in some circumstances, assets into their own ISA to the same value as the deceased’s ISA held at the date of death. The actual assets previously held in the deceased’s ISA will, as at present, lose their ISA wrapper and form part of the estate. Depending on the terms of any Will (or, where appropriate, intestacy legislation) the assets may or may not be distributed to the surviving spouse/partner. Representatives of TISA and other organisations met with HM Treasury & HMRC officials before Christmas to look at the technical issues this raises, prior to a technical consultation process after draft amendments to the ISA Regulations and corresponding draft guidance were published by HMRC towards the end of January 16.

TISA will, of course, keep members informed of progress on all these technical issues with the issue of appropriate Technical Bulletins on our website from time to time. n

2 £57.260bn (2012/13: £57.359bn – this figure has been slightly adjusted by

HMRC since first publication a year ago)

3 £18.439bn (2012/13: £16.459bn)

4 £38.821bn (2012/13: £40.901bn)

5 2012/13: £5,629

6 2012/13: £3,501

7 2012/13: 296,000

8 2012/13: £393m

9 2012/13: £1,327

10 2012/13: £1,075

11 2012/13: £1,442

12 2012/13: £222.199bn

13 Unit trusts, OEICs, UCITS, Investment Trusts and Insurance

14 Shares, Securities (Bonds) and Gilts

15 2012/13: £220.636bn

16 HMRC ISA Bulletin 64 issued 20 Jan 2015, responses by 20 Feb 2015


ENGAGEMENT

TISA HAS EXPANDED THE BREADTH and depth of its activity in response to an increasingly diverse membership. The Engagement Team has similarly evolved throughout 2014 to ensure that we continue to meet our member’s needs.

The Engagement Team was instrumental in establishing the Technology Innovation Forum (TIF) in early 2014. The group includes broad representation from across financial services with clear objectives to review the trends in technology and examine ways in which these can be adapted to suit the needs of the financial services industry and their clients, with an emphasis on encouraging the UK consumer to save. The TIF group have been working hard throughout 2014 examining the barriers to saving and how technology can be used to help encourage better levels of financial health in the UK, culminating in a seminar on 15 January and corresponding report due for launch in 2015. As the use of technology is continuing to grow in importance across our membership, we are pleased to announce that TIF will become a formal TISA policy council open to all members in 2015 to continue the good work conducted by the project during its primary stage.

We have examined how TISA runs its seminars and have implemented a change to our policy council events for 2015. In previous years the policy councils held single events which centred on the most pressing issues faced by that particular council’s corner of the financial services industry. From 2015, the councils will now host joint bi-annual summit events which will continue to provide our members with relevant output from the appropriate speakers alongside interactive Q&A sessions. Members will be able to select which of the council sessions are most appropriate to them and attend as many sessions as they feel will best suit their needs. TISA will also be looking to offer sponsorship at some of our events, providing an opportunity for member firms to establish new contacts and clients through the wide variety of delegates who typically attend our events.

In October 2014, we launched ‘engage’, a new regular newsletter which aims to inform members on the most recent key activities undertaken by TISA, both through our member forums and events.

We are of course on hand to listen to member feedback. In response to comments from members, TISA breakfast briefings were introduced in November to deepen our engagement with members and focus on the issues and topics that are most relevant throughout the industry. These are separate to TISA’s usual programme of regular events throughout the year which cater for the wider audience. The briefings are intimate 90 minute sessions designed to provide delegates with short, consolidated updates on the key developments relevant to the topic under discussion. Three briefing sessions were held during November and December, focusing on pensions, regulation and digital passports. These small informal events received excellent feedback with participants particularly welcoming the opportunity to chat over coffee with their industry peers. n

LOOKING AHEAD

We will be examining how best to streamline our communication strategies to ensure our members receive information from TISA that is most appropriate to them. We are working on the programme of events for 2015, including the breakfast briefings, and will keep you updated and aware of what is coming up.

There is much change ahead for the industry in 2015 – Engagement will be on hand to listen, assist and of course engage with you throughout the year.

One of the Engagement Team’s main responsibilities is to facilitate effective communication with our members by ensuring that they are fully aware of TISA’s activities so we can assist members who wish to be better informed about, or get involved in, our member forums and programme of events.

Kim Holloway, Director of Engagement, TISA


TISA MEMBERS

A J Bell Securities Ltd

Aberdeen Asset Management Ltd

Actuare Ltd

Al Rayan Bank Plc

Alliance Trust Savings Ltd

Altus Ltd

Annuity Direct Ltd

Ascentric

Aviva

AXA Portfolio Services

Baillie Gifford Savings Management Ltd

Banfield Business Solutions

Bank of Cyprus

Barclays Private Clients

Barclays Wealth

Barratt & Cooke

BlackRock Investment Management (UK) Ltd

Blankstone Sington Ltd

BNP Paribas

BNY Mellon

Bravura Solutions

Brewin Dolphin Ltd

Brooks MacDonald Asset Management

Brown Shipley & Co Ltd

Calastone Ltd

Capita Plc

Cashfac Plc

Charles Stanley & Co Ltd

Citibank NA London Branch

Close Brothers Asset Management

Clydesdale Bank Plc

Cofunds Ltd

Coutts & Co

Coventry Building Society

Covington & Burling LLP

Credit Suisse (UK) Ltd

CWC Research

Danske Bank

Defaqto

Deutsche Bank Wealth Management

DST Systems Inc

Dunstan Thomas Holdings Ltd

EFG Harris Allday

Elston Consulting

Engage Insight

EPML

Equiniti

Euroclear UK & Ireland

F & C Management

Family Investments

Fidelity Worldwide Investments

FNZ UK Ltd

Forester Life

Franklin Templeton Fund Management Ltd

Friends Life

Fundscape

FusionExperience

GBST Wealth Management Ltd

GLG Partners Investment Funds Ltd

Grant Thornton UK LLP

Hargreave Hale Ltd

Hargreaves Lansdown

Henderson Global Investors Ltd

Hoares Bank Nominees Ltd

HSBC Group

IG Markets Ltd

Ignis Asset Management

Interactive Investor Trading Ltd

International Financial Data Services

Intrisic Financial Services

INVESCO Perpetual UK Ltd

Investec Asset Management Ltd

Investec Wealth & Investment Ltd

Ipipeline

IRESS Ltd

James Hay Partnership

JHC Plc

JM Finn & Co

JP Morgan Asset Management (UK) Ltd

Jupiter Unit Trust Managers Ltd

Kinetic Partners LLP

Legal & General Plc

Lloyds Banking Group

Lynne Hill Consulting Ltd

M&G/Prudential

Marks & Spencer Financial Services

McInroy Wood

Microsoft

MorningStar UK Ltd

Multrees Investor Services

N W Brown Investment Management Ltd

Nationwide Building Society

Northern Trust

Nucleus Financial Group Ltd

Old Mutual Wealth

Openwork Limited

Orbis Investment Advisory Ltd

Origo Services Ltd

Parmenion Capital Partners LLP

Pershing

Praemium (UK) Ltd

Psigma Investment Management

Quilter Cheviot

Rathbone Brothers plc

Raymond James Investment Services Ltd

Redmayne Bentley LLP

Reyker Securities Plc

Royal Bank of Scotland

Royal London Asset Management

Santander ISA Managers

Santander Sharedealing

Schroders Plc

Scottish Friendly Asset Managers Ltd

SEI Investments (Europe) Ltd

Selftrade

Seven Investment Management

Shawbrook Bank Ltd

Simplybiz Plc

SIT Savings Ltd

Smith & Williamson Investment Services Ltd

Speirs & Jeffrey Ltd

St James’s Place Wealth Management

Standard Life Investments

State Street

Succession Advisory Services

Target Servicing Ltd

TD Direct Investing


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Triodos Bank NV

Triplea Advisory Group

Vanguard Investments UK

Vestra Wealth LLP

Walbrook Partners Ltd

Walker Crips Stockbrokers Ltd

Wealthtime Ltd

Weselyan Assurance Society

WH Ireland

Winterflood Securities Ltd

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