Prudential Multi-Asset Funds. Governance Report. This is just for UK advisers it s not for use with clients.

Transcription

1 Prudential Multi-Asset Funds Governance Report This is just for UK advisers it s not for use with clients.

2 Contents 1. Size and Strength Prudential plc 3 2. How PPMG manage Multi-Asset funds 7 3. Multi-Asset Fund Options 17 The information in this document is correct as at 1 January 2018 unless otherwise stated. Further fund information, including fact sheets and performance information is available on our website pruadviser.co.uk/funds 2

3 1. Size and Strength Prudential plc Prudential plc is an international financial services group with significant operations in Asia, the US and the UK. We serve around 24 million customers and have 635 billion of assets under management (at end December 2017). We re listed on stock exchanges in London, Hong Kong, Singapore and New York. Understanding and responding to our customers needs is at the heart of our business. It s something we ve been doing for over 169 years. We generate sustainable value for our shareholders through a relentless focus on meeting our customers savings, income and protection needs and a disciplined approach to investing in the most profitable growth opportunities. The Group is structured around three main business units: Prudential Corporation Asia, Jackson National Life Insurance Company and M&G Prudential. 3

4 1. Size and Strength Prudential plc continued Prudential Portfolio Management Group Ltd Prudential Portfolio Management Group Ltd (PPMG) is one of the largest investors in the UK, managing over 180bn (at end December 2017) across a growing range of multi-asset investment solutions and annuities on behalf of Prudential UK&Europe. PPMG is a team of over 80 that includes experienced investment professionals with specialist expertise in capital markets research, manager research, investment strategy design, liability management, alternative investments and portfolio management. PPMG high level team structure: PPMG Team Key Personnel/Teams High Level Objectives CEO Jonathan Daniels Long Term Investment Strategy Parit Jakhria, Director of Long Term Investment Strategy 9 Analysts/Strategists Recommend the strategic asset allocation (SAA), asset liability matching (ALM) and hedging strategies Recommend the strategic asset allocation (SAA), asset liability matching (ALM) and hedging strategies Provide asset modelling services to the Prudential Group and advice on setting benchmarks and mandates Portfolio Management Barry Widdows, Head of Multi Asset Portfolio Management 3 Portfolio Managers/Controllers Manage the portfolios in line with the product design to achieve the performance objectives Manage portfolios within PPMG s given limits, and monitor and review performance to ensure it stays in line with the desired strategy Support relevant UK&E teams to grow their business Research David Shairp, Head of Research Economist & Senior Strategist Quantitative Analyst and Researcher Produce fundamental and quant analysis (asset-class-focused experts across all main asset classes) Views generated across short (6 months to 3 years) and medium-term (3 to 5 years) horizons The team supports both the Long Term Investment Strategy team and the Portfolio Management teams 4

5 PPMG Team Key Personnel/Teams High Level Objectives Manager Oversight Ciaran Mulligan, Head of Manager Oversight 4 Manager Oversight Analysts Head of Strategy & Governance Ensure rigorous discipline around the oversight of internal and external (non alternatives) managers Organise due diligence and quarterly manager meetings Alternatives Mike Howard, Head of Alternatives 8 Analysts/Managers Legal Counsel Management of the alternative investments portfolio Selection and ongoing monitoring of all alternative investments Business Development Andy Brown, Investment Director 3 Product Specialists Fund and product design, structuring, marketing and distribution support Fund rationalisation and restructuring New business support Risk Guy Barton, Chief Risk Officer 2 Risk Directors 6 Analysts/Associates Active oversight of key risks related to managing investments and the business. Assists in the implementation of the risk appetite and limit framework. Reviews and assesses the risk taking activities of the business, where appropriate, challenging the actions being taken to manage and control risks Operates independent risk oversight services ensuring that group governance manual and group risk framework policies for credit, market, liquidity, operational and investment risks are met 5

6 1. Size and Strength Prudential plc continued PPMG and Prudential Group fund managers: Each of our insured Multi-Asset funds has a portfolio manager who is responsible for implementing asset allocation views. PPMG ensure that each Prudential Group specialist fund manager, that manages day to day stock selection/management, has a clear mandate that they adopt to deliver performance within the relevant asset classes.* Examples of Prudential Group fund managers that PPMG work with: And other available options UK and European Equities UK and European Bonds Asian Equities Asian Bonds American Equities American Bonds UK Property International Property For example: Hedge Funds Third Party Funds Other Investment vehicles Private Finance Initiatives * Where appropriate, PPMG work with external companies to gain specialist exposure to assets or types of funds (for example Hedge funds, private equity and long-term infrastructure funds). 6

7 2. How PPMG manage Multi-Asset funds The following section aims to provide the answers to questions you may have regarding how PPMG manage money. The answers reflect the views and opinions of PPMG, as at 31 December (unless otherwise stated) and shouldn t be taken as advice. More specific information on some of the Multi-Asset funds we offer is covered in Section 3. Philosophy We believe in A long-term approach Diversification, both by asset category and geography Active management The importance of valuation Liquidity and credit premiums Sources of Value Add Strategic asset allocation Mandate design Tactical asset allocation Underlying manager alpha Efficient implementation Our portfolios have some common intended characteristics Equity portfolios have a value bias Fixed income portfolios have a credit bias Property have a bias towards high quality assets in core locations Private assets represent a sizeable proportion of our portfolios Evolving asset mix as we embrace new asset classes and opportunities 7

8 2. How PPMG manage Multi-Asset funds continued In the context of the retail multi asset market, there are several differentiators: In your opinion are there factors that differentiate the process and philosophy? Resource applied to asset allocation: core specialism is asset allocation. Stock selection decisions are outsourced to experienced fund managers in particular asset classes or markets. Long-term: being part of an insurance group allows a longer investment horizon and provides the opportunity to exploit the risk premiums offered through holding illiquid assets and access to a wide range of asset classes. Governance framework: our approach of setting and policing clear mandates, where possible over and above what would naturally happen as part of a local management structure provides an additional quality control layer between the investment managers and the adviser. The above taken together are bound up with the existence of PPMG set up specifically to manage the asset allocation, safeguard the investment philosophy, and manage the managers, on behalf of UK&E policyholders. Please provide details of any changes to the process that you have implemented or are implementing. PPMG is now a separate business unit with its own governance structure and operating model. The services undertaken in PPMG remain the same as those previously carried out by the Portfolio Management Group; but additional specialist teams and capability have been built to ensure a robust second line of defence. 8

9 Decision Making How much consideration is given to peer group when constructing the portfolios? How valid is comparison to the peer group for your Multi-Asset funds? Peer group positioning doesn t feature heavily in the day to day running of the insured Multi-Asset funds (see Section 3). Strong performance relative to the benchmark asset mix and country indices over the medium-term will lead to favourable performance relative to peers. PPMG believe that becoming too fixated on trying to match peer groups over the short-term will lead to some chasing of the tail which isn t in the interests of policyholders. Ultimately it s absolute risk and return that s the most significant thing for investors, not short-term relative performance. Investment management agreements (IMAs) govern how a strategy/mandate should be implemented by the fund managers. Managers will be given different mandates across asset classes and benchmarks and the degree of flexibility may vary. In general, how is the quality of investment decisions evaluated? Peer group review operates at all stages of the investment process. Review within the analyst teams, Fund Manager review of the analysts, and peer group review at the asset allocation level. Localised, formal, risk & portfolio monitoring, and performance attribution: there are regular processes in place at each specialist management company (including PPMG in terms of asset allocation decisions) by risk monitoring experts to analyse and feed back to the specialists and their desk heads the risks taken in underlying funds, and their effectiveness. Additional, formal examination of risks across portfolios undertaken independently by PPMG and feeding into company wide Turnbull style risk reporting. Individual appraisal individual performance is reviewed annually as part of the appraisal process carried out by line managers. How is exposure to assets in the Multi-Asset funds achieved? Exposure is largely gained by buying stocks and shares directly via segregated mandates for the large Multi-Asset funds, and for others by buying units into pre-existing internal and/or 3rd party collective investment scheme (CIS) funds. The number of different funds will depend on the geographic scope of the Multi-Asset fund in question. Within each fund (and asset class) we strongly believe in having well diversified portfolios. 9

10 2. How PPMG manage Multi-Asset funds continued Portfolio Monitoring How do you measure and analyse each fund s/portfolio s risk? PPMG carry out a full and thorough analysis of portfolios on a monthly basis using BlackRock Solutions Aladdin Platform in conjunction with their portfolio management tools. The table below lists some of the key tests, but this list isn t exhaustive: Equities Stock bet, sector bet, economic group bet, country bet (where appropriate), liquidity, turnover, statistical risk (Tracking Error), valuation metrics (e.g. P/E relative, beta), common money. Bonds Duration bet, credit bet, credit issuer diversification, curve positioning, average credit, minimum credit, industry bet, turnover. Property Liquidity, geographic bet, sector bet, geographic-sector bet, asset diversification, tenant diversification, void rates, rental yield. Asset allocation Asset bet, country bet. Total fund Total statistical risk (tracking error), tracking error risk decomposition, performance, regulatory breaches, deviations from IMA guidelines (total fund and individual disciplines). 10

11 Risk Management What internal controls exist to safeguard the funds/portfolios from taking on undue risk? All regulatory limits are monitored by Compliance and Regulatory Reporting functions, and breaches are notified to PPMG, the Actuarial Function Holder, and the risk management committee of the relevant investment management company. They are formally reviewed by a number of forums, PPMG risk committees and the Investment Subcommittee of the Prudential Assurance Company (PAC) board. In addition to the regulatory limits, each investment discipline applied to any fund has a distinct mandate that operates at the subfund level, as well as such guidelines at the asset allocation level. These, as well as standard best practice limits are monitored and any exceptions that are identified by this process are logged, investigated with the individual managers concerned, and if necessary escalated for resolution. It s important to note that these are guidelines, and deviations from the guidelines are a common occurrence in running the funds normally (for example, cash balances will be higher in the midst of an asset allocation move). This process works very well in heading off potential issues in advance, and keeping managers, funds and the mandates that govern them in line with one another. What is the policy on stock diversification in quantity and quality terms for the underlying asset class funds/portfolios? PPMG believe strongly in the benefit of diversification. Asset class portfolios are therefore characterised by being large (in terms of number of stocks) and well diversified. Within equity portfolios we stipulate a target range for number of stocks, and in bond portfolios we specify maximum exposures to a single issuer, with lower limits applying to weaker credits. Do you use derivatives? If so, how are any underlying derivative exposures taken into account and please outline the strategies pursued, the costs/benefits and the monitoring system used to maintain control. Are they marked to market? Our strategy, when using currency hedges, generally is to manage (down) the risks associated with overseas currency exposure in funds. Derivatives are to be used consistent with the PPMG Derivatives Usage Form process and the usage restrictions described in the applicable laws and regulations. 11

12 2. How PPMG manage Multi-Asset funds continued Risk Management What discretion do underlying fund/ portfolio managers have to deviate from team views and set limits, and what procedures are in place to monitor deviation from team views? Different funds have different mandates and appetite for risk and fall under different regulatory regimes (i.e. insurance versus collective investment scheme (CIS) funds). Our structure and process is based around the presence of core teams of analysts and a common way of thinking about valuation of securities. The extent to which these are then implemented in funds/portfolios will differ due to various factors. The Portfolio Manager or the Fund Manager is ultimately responsible for performance and so the final decision rests with them. Where we have managers running more than one fund but with identical mandates, the portfolios will be effectively cloned (or exposure gained via a common pooled vehicle). Asset Allocation UK Equities A degree of consistency across funds differences appearing because of different opportunity set, risk appetite or aims/mandate. High degree of consistency within Prudential funds, but low consistency between these and M&G retail funds which all have specialised mandates. US Equities High degree of consistency across all funds. European Equities As per UK consistent within the Prudential funds, but differences to the specialist M&G retail funds. Japanese Equities As per UK & Europe. Asian Equities High degree of consistency. Property Corporate Bonds Medium degree of consistency similar strategy desired, but liquidity and heterogeneity issues give rise to discrepancies. Medium degree of consistency Prudential funds fall into two groups, and will differ due to issues such as cash flow timing, etc. 12

13 Outline the process for assessing underlying fund managers? The Manager Oversight team regularly monitor internal and external managers against their benchmarks and mandate and will report any material issues. IMA s govern how a strategy/mandate should be implemented by the fund managers. Managers will be given different mandates across asset classes and the degree of flexibility may vary. The Manager Oversight team are responsible for the investment due diligence and ongoing monitoring of internal and external managers. This entails very close interaction through; Best practice monitoring (monthly) PPMG reviews the underlying managers key exposures and holdings on a monthly basis. Strategy and performance review (quarterly) PPMG has quarterly meetings with the managers, either in person for those based in London and by video conference for the managers located overseas. Each manager submits a Data Request Book prior to the quarterly meeting, which provides performance data, risk metrics and attribution for the quarter. The Data Request Book forms the basis of the meeting, enabling PPMG to pinpoint areas that require further discussion. Investment due diligence (annually) annual site visits are conducted to assess each fund manager on their suitability and alignment with PPMG strategy. Investment due diligence covers both quantitative and qualitative factors. Quantitative factors include measures of performance and holdings analysis. Qualitative analysis incorporates People, Process, Philosophy and Infrastructure. IMA review (at least annually) Manager IMA s are reviewed as part of the annual investment due diligence to ensure the mandate and guidelines remain fit for purpose. How does your firm address the issue of Key Person Risk within your asset management operation? PPMG adopt a team-run, process-based style of management. Each named Portfolio Manager or Fund Manager has a designated alternate to assume their responsibilities when needed. So, while it s important that we have good calibre people in each role, we believe the risks associated with key personnel are low. 13

14 2. How PPMG manage Multi-Asset funds continued How is the team structured in terms of research and account management responsibilities? Research and portfolio management is carried out by different teams. The multi-asset research is carried out in-house by a very experienced team. Why do research in-house? Control the quality of the research and its outputs Independence from third parties Better insights into the drivers/components Competitive advantage and/or unique insights from a proprietary process that impact decision making Control the research agenda and areas of further development Embedded in an investment process that aims at generating persistent alpha in asset allocation The CIO, Research, LTIS and portfolio management teams meet formally to discuss potential opportunities. The research team also actively interacts with the portfolio managers, manager oversight and the LTIS teams on an ad-hoc basis to share ideas and economic views. 14

15 Consistency of Investment Process and Investment Results Who is responsible for the performance review of funds/portfolios? Ultimate responsibility rests with the PAC board, which has created an investment subcommittee to formally discharge this duty. This Investment Committee is supported in this by PPMG, who produce investment reporting for the funds, and will draw to the attention of the board any matters of immediate concern. Performance of funds relative to peer group is highly visible, and there is a high degree of scrutiny applied to performance data in many areas of the business throughout the year. How do you assess performance? The primary concern is that managers perform to mandate or fund objective which may from time to time lead to positive or negative relative return when compared to either peer group or benchmarks. This is a highly complex area, and the extensive governance and control framework described previously helps achieves this. How do you ensure that a fund/portfolio possesses the appropriate structure to achieve your explicit performance objectives (target active return, target relative yield, target tracking error, etc.)? By having in place a process of clearly articulating a segregated mandate ex-ante, and measuring performance relative to that mandate ex-post, we ensure that the funds/portfolios remain fit for purpose and possess the appropriate structure to achieve the objectives. Clearly the mandate is key, and these are formally reviewed and re-agreed with the investment subcommittee of the PAC board on an annual basis. 15

16 2. How PPMG manage Multi-Asset funds continued Remuneration What is your remuneration policy as it directly relates to your portfolio managers and research analysts? Prudential has many investment professionals globally and each one has different terms and conditions associated with their employment, dependent on location, role, etc. Bonuses are generally linked to performance measurement metrics dependent again on local market convention, role, individual history, etc. Please describe the extent of integration/ automation in the operational processing chain from the time the trade is placed to the time it s integrated in the portfolio accounts (e.g. order book manager holdings tools connections front office to back office)? Day-to-day management Please describe the nature and frequency of cross-checking cash and portfolio holdings? Please note that the following is a broad overview. There are certain asset classes and funds for which the processes are different to those stated. For our Multi-Asset funds, there are essentially three types of deal: 1) Cash inflow or outflow from the fund Notification of inflows/outflows is sent by to both the Portfolio Manager and the relevant investment operations team, and also loaded on to the Aladdin system. The Portfolio Manager makes purchase and sale decisions based on the notification which then flows through Aladdin to be executed. 2) Portfolio Manager allocates between underlying Fund Managers Where the allocation is to Fund Managers running directly held portfolios, notification to the underlying Fund Manager is given by , and the movement in cash is keyed into the system. All tranches/physical allocations are processed through Aladdin for full automation. 3) Underlying Fund Managers deal The Fund Manager gets notification either by from the Portfolio Manager, or via the underlying collective investment scheme (CIS) injections/withdrawals process (which operates in the same way as 1 above). The Fund Manager uses their localised decision support system to decide on the specific deals required, and then completes a dealing request on an electronic dealing system which then interfaces with the straight-through processing (STP) back office processes. There are three key areas involved as far as stock and cash holdings are concerned: the Custodian, the Fund Administrator and the Portfolio/Fund Manager. Cash is inevitably affected by all transactions that occur in the fund, so discrepancies in cash will arise whenever there are discrepancies in cash items and stock transactions. Cash positions are reconciled daily between the Fund Administrator and the Custodian. Cash positions are also reconciled daily between the Fund Manager and the Custodian. Stock positions are reconciled monthly between the Fund Administrator and the Custodian. Stock positions are also reconciled daily between the Fund Manager and the Custodian. As an additional check stock positions are reconciled fortnightly between the Fund Manager and the Fund Administrator, and the total fund size is reconciled between these two monthly. 16

17 3. Multi-Asset Fund Options The following funds are available through a number of different product options. For information on this, plus fact sheets, daily prices, performance figures, fund guides and PPMG market commentary, please visit pruadviser.co.uk/funds PruFund Invests globally in a range of assets including equities, property and fixed interest. Diversification Pools together the money of large numbers of investors to offer excellent diversification. Invests predominantly using a range of Prudential Group fund managers. Governance PPMG monitor and manage the Prudential Group fund managers responsible for the majority of underlying funds that these Multi-Asset funds invest in. Smoothing. Special Features Financial strength. Backed by the assets of the largest With-Profits funds in the UK (end December 2017). Our PruFund Range of Funds offers different options. These have been split into two types below each offering our established PruFund smoothing process, but with some important differences. 17

18 3. Multi-Asset Fund Options continued Risk Managed PruFund These funds provide a choice of four options each offering different levels of risk and potential return. The funds each have clearly stated equity parameters to help advisers match them to the outcomes of their client risk assessments. Asset Allocation PruFund 0-30 PruFund PruFund PruFund A choice of four Risk Managed PruFund funds. The Risk Managed PruFund funds use PPMG asset allocation models to decide the high level asset allocation positions of each of the funds. The high level asset allocation positions for the Risk Managed PruFund funds are updated quarterly. Within each high level asset type (for example international equities or fixed interest) the amount held in different types of that asset is driven by the proportion held in the main With-Profits fund. 18

19 Optional Protection PruFund These funds can offer a range of optional guarantee terms which may, at an additional cost, provide some added security for clients. We also provide versions of the same funds without the optional guarantees. PruFund Protected Growth/PruFund Growth Maintaining the financial security of the fund is the overriding priority within that PPMG manage the asset allocation to help meet the funds aim of maximising growth within an acceptable risk budget over the medium to long-term. Asset Allocation PruFund Protected Cautious/PruFund Cautious These funds offer alternative asset splits to the PruFund Growth funds by offering a different allocation of real (equities, property and alternative assets) versus nominal (fixed interest and cash) assets. This is to help the funds meet their aims for providing growth over the medium to long-term through a cautious approach to investing while maintaining an acceptable level of risk to the funds. PPMG asset allocation changes in the PruFund funds will be reflected within the real and nominal assets held. The onshore PruFunds invest in the main life fund. The international PruFund funds are backed by assets in the life fund through a reinsurance agreement. Visit pruadviser.co.uk/prufund for more information. 19

20 3. Multi-Asset Fund Options continued With-Profits Including: With-Profits (referred to as Optimum Return With-Profits fund and Optimum Bonus With-Profits fund for our Onshore Bond products). Invests globally in a range of assets including equities, property, fixed interest and alternative assets. Diversification Pools together the money of large numbers of investors to offer excellent diversification. Invests predominantly using a range of Prudential Group fund managers. With-Profits (referred to as Optimum Return for our Onshore Bond products) PPMG select a wide range of assets to hold in the With-Profits fund, in line with the fund s objective. The aim is to maximise long-term investment returns while maintaining the financial security of the fund. Asset allocation The international With-Profits funds are backed by assets in the life fund through a reinsurance agreement. Onshore Bonds only Optimum Bonus The fund invests in the With-Profits fund, but offers an alternative split of real (equities, property and alternative assets) versus nominal (fixed interest and cash) assets, to help meet the fund s aim of providing medium to long-term growth and to generate income. PPMG asset allocation changes in the With-Profits fund will be reflected within the real and nominal assets held. Governance PPMG monitor and manage the Prudential Group fund managers responsible for the majority of underlying funds that these Multi-Asset funds invest in. Smoothing. Special features Guarantees. Financial strength. Asset liability management. Visit pruadviser.co.uk/with-profits for more information. 20

21 PPMG recommend the asset allocation for each LF Prudential Dynamic Focused Portfolio. M&G Investment Management Ltd, part of the Prudential Group, are the investment managers for the LF Prudential Dynamic Focused Portfolios. They make the relevant adjustments to portfolios based on PPMG s recommendations. Link Fund Solutions Limited is the Authorised Corporate Director (ACD) of the LF Prudential Dynamic Focused Portfolio OEIC funds. The term ACD is used to describe the manager of an Open Ended Investment Company (OEIC). Life and pension versions of the OEIC funds are available on Prudential and Prudential International products. LF Prudential Dynamic Focused Portfolios Including: Dynamic Focused 0-30 Portfolio, Dynamic Focused Portfolio, Dynamic Focused Portfolio, Dynamic Focused Portfolio, Dynamic Focused Portfolio. Diversification Invests globally in a range of assets including equities, property, fixed interest, alternative assets and cash. Asset allocation Invest in funds that track a range of world equity stock markets, from Legal & General, actively managed fixed interest and property funds, from M&G and alternative assets from selected specialists. These funds are not benchmarked against ABI or IA sector average asset allocations. Governance PPMG monitor the fund managers responsible for the underlying funds that these Multi-Asset funds invest in. A choice between five risk managed funds. Special features Portfolios can be matched to the outcomes from different risk tools. Quarterly reports are available for investors and advisers giving details of changes over the last quarter. Visit pruadviser.co.uk/dynamicfocusedportfolios for more information. 21

22 3. Multi-Asset Fund Options continued PPMG recommend the asset allocation for each LF Prudential Dynamic Portfolio. M&G Investment Management Ltd, part of the Prudential Group, are the investment managers for the LF Prudential Dynamic Portfolios. They make the relevant adjustments to portfolios based on PPMG s recommendations. Link Fund Solutions Limited is the Authorised Corporate Director (ACD) of the LF Prudential Dynamic/Dynamic Focused Portfolio OEIC funds. The term ACD is used to describe the manager of an Open Ended Investment Company (OIEC). Life and pension versions of the OEIC funds are available on Prudential and Prudential International products. LF Prudential Dynamic Portfolios Including: Dynamic 0-30 Portfolio, Dynamic Portfolio, Dynamic Portfolio, Dynamic Portfolio, Dynamic Portfolio. Invests globally in a range of assets including equities, property and fixed interest. Diversification Invests using a range of single asset class funds that have been independently selected and recommended by Morningstar. Investment styles of the underlying managers are blended by Morningstar to further diversify risk. Asset allocation PPMG set the asset allocation for each fund to help it meet its risk target, in line with the allowable investment parameters for each fund. These funds are not benchmarked against ABI or IA sector average asset allocations. Governance Morningstar review the performance of the underlying fund managers funds will be added or removed based on their recommendations. PPMG evaluate Morningstars processes for reviewing fund managers annually. A choice between five risk managed funds. Portfolios can be matched to the outcomes from different risk tools. Special features Quarterly reports are available for investors and advisers giving details of changes over the last quarter. There is no Prudential in-house bias to Morningstars selection and recommendation of the underlying funds being used. Visit pruadviser.co.uk/dynamicportfolios for more information. 22

23 The information in this document is correct as at 1 January 2018 unless otherwise stated. Further fund information, including fact sheets and performance information is available on our website pruadviser.co.uk/funds 23

24 pruadviser.co.uk Prudential is a trading name of The Prudential Assurance Company Limited, which is registered in England and Wales. This name is also used by other companies within the Prudential Group. Registered office at Laurence Pountney Hill, London EC4R 0HH. Registered number Authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority. INVG /2018