The Model Office Blog

BREXIT Fray Bentos and Ice Cream Vans

[fa icon="calendar"] Nov 30, 2018 12:15:59 PM / by Chris Davies

Like you, I get most of my Brexit updates from the @Coldwar_Steve twitter account. Based on this, Boris Johnson is currently panic buying Fray Bentos tins from a reconditioned ice cream van.

A no deal Brexit has looked possible for some time. What to do about it, once you’ve bought your Fray Bentos and waded through the rehashed pre-budget/election/referendum advice to tell your clients not to worry about short term volatility because blah-de-blah?

All you can do is weigh up the size of the problem.

  1. Do you advise clients or operate in the EEA?

If not, and most advice firms don’t, that’s a big help.

  1. Are your clients invested in an EEA based businesses, headquartered in Dublin or Luxemburg for example? 

If not, then no issue.

If they are, then ask what plans the investment managers have to adjust and relocate if necessary. Do you get comfort from their reply - have they even considered it? Some fund managers have well considered responses that will give you a high degree of confidence that they will do their utmost to avoid disruption. Others don’t.

It’s worth remembering that 29th March is not the cut-off date for financial services. Temporary regulations will apply from that date to extend until the end of 2020. To quote the FCA:

‘The UK is currently due to leave the EU on 29 March 2019. Earlier this year, the UK and EU agreed the terms of an implementation period which would apply from the end of March 2019 until the end of December 2020. During this time, EU law would still apply in the UK. Firms and funds would continue to benefit from passporting between the UK and EEA. However, the implementation period is part of the withdrawal agreement, and the agreement will be part of further negotiations between the UK and EU before it is finalised.’

This means they have a reasonable time period to sort themselves out if they plan for it now.

  1. What are the implications if you are in an EU fund? The honest answer is nobody knows what the implications are, but there could be more costs for your clients and worst-case scenario they would be best off finding UK based alternatives.

Is the fund easily replaceable by another? If it’s a common or garden fund with plenty of alternatives, for example one of the many risk-rated multi-managers available, you might conclude this is no big deal and the only consequence might be an earlier than expected CGT hit on the unwrapped part of a portfolio if you need to switch from one fund to another. If it’s a complex and hard to exit investment, then a stiffer early warning for clients with those investments may be advisable.

If you’re using a DFM or outsourced model portfolio provider they should be answering these questions also. They should have the answers ready and the resources available to select alternatives, albeit certain sectors may have a limited range of attractive options.

Who knows how it will all pan out and whilst there’s bugger all you can do about most of it, you can size up the potential problem and this should be in your board or investment committee discussions right now. It’s a good test of your MI. Frankly, if you don’t know where your client’s money is invested you have a bigger problem.

The answer to all this might still be that there’s little to worry about and even less to do, but if your client does face a number of portfolio or product changes, with consequent inconvenience and cost, as a result of a no deal Brexit, it might influence the tone of your communication to them on the matter.

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Topics: Financial regulation, Financial business development, fintech, regtech, Risk management, practice management, FCA, advice, HMT, suitability, FAWG, FAMR, MiFIDII, Data, GDPR, Chatbot, Culture, Enforcement, supervision, audit, Conduct, AI, Risk,, Accountability, Platforms, PROD, Product governance, Modeldrivenmachineexecutablerporting, digital,, Regulatory, Reporting, BREXIT

Chris Davies

Written by Chris Davies

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