MIFID2 and Brexit. Where are we now, and a look into the crystal bal. October 2017
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1 MIFID2 and Brexit Where are we now, and a look into the crystal bal October 2017
2 Unbundling research: What s the way forward? Pros and cons of your payment options RPA transactional method RPA accounting method Pay out of own P&L Views from the market 70% of Asset Managers say they ll pay for research themselves (1) Is the market prepared for MiFID II? Battle over research costs Implications on coverage / number of providers Economic and fixed income research free lunch? Challenge to viability of some business models Source: (1) FTfm as at 1/9/17 2
3 What wil MIFID2 mean for distribution? A reshaped market landscape Sub-scale firms exit and subpar firms close Shift to outsourced investment / PM Platforms increasingly prevalent and a reality check for the industry KPMG LLP, a UK limited liability partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative 3
4 Lessons fromrdr: What might come next? Lower costs, more transparency Better advice A new advice gap? Need for more market research, and better understanding of the customer Inducements rules Pricing model innovation Vertical integration 4
5 Whatcould the world look like on 2 October 2019? Here s what might happen to research & execution a year on from MiFID II coming into force: Decrease in buy-side research spend Number of bulge brackets pull out of equity research Less sell-side coverage, shift to issuer paying for research Big asset managers build multiple internal research desks 5
6 Whatcould the world look like on 2 October 2019? Here s what might happen to distribution a year on from MiFID II coming into force: Regulatory fragmentation already happening, with more on the way Fee transparency drives fees lower: The sell-side slims in response Investment outsourcing becomes more prevalent More direct portfolios and bigger research teams Consolidation with both vertical and horizontal integration 6
7 Brexit: what happens next?
8 Firms leaving UKcould reshape capital markets Movers and stayers 19 banks and 7 large asset managers have announced plans to beef up operations elsewhere in the EU Frankfurt, Luxembourg and Dublin early winners in the battle for movers Movers could reshape investment landscape Capital markets, liquidity and trading venues all impacted, at same time as MII disrupts market structure Asset manager s front office operations have to adapt Regulatory impact will also hit stayers Contract law, employment law, tax law issues GDPR: Extraterritoriality issues 8
9 Passporting no easy answers The biggest risk is temporal Could be (or feel) a long time between Brexit and equivalence Diversity of thirdcountry provisions complicate things Equivalence is not a point in time consideration Impact on IM services to EU professional clients could be limited Impact on IM services to EU retail clients may be fatal No common approach to equivalence Equivalence Passporting Judgement made for each new legislation Judgement subject to review at any time but only if UK is adjudged as equivalent and even then firms could face restrictions Policy to retail cross-border IM services likely to be more restrictive this state of affairs could well be permanent 9
10 Delegation: Care needed ESMA focused on avoiding regulatory arbitrage Changing interpretations of substance Letterboxing will be more scrutinised Future regulatory reviews may cause more change Firms need to make contingency plans and communicate Impact of the various 3 rd party provisions Impact of client / counterparty restrictions Optionality offered by operating model 10
11 Restricted freedomof movement: Complex, costly Raises questions around talent management A B C EU existing talent UK existing talent Future EU & global talent and loss of talent impacts economy plc 25% Of UK business will be negatively impacted by restrictions on EU migration (2) Need to invest more in training Source: (1) KPMG survey of 2000 EU nationals; (2) NIESR/CIPD. 11
12 What could the world look on 2 October 2020? Equivalence agreed UK regulation deemed not equivalent Existing delegation rules maintained No passporting Limited passporting Much stricter rules on delegation for UK, US, Asian managers Shift of portfolio managers to EU or: Give up on Europe as a market 12
13 Thank you
14 kpmg.com/uk The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavour to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation KPMG LLP, a UK limited liability partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative The KPMG name and logo are registered trademarks or trademarks of KPMG International. CREATE: CRT087441A
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