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Which managers are signed up to the Code, and thus will be required to use the system?
The list of managers that have signed up to the Code is at https://lgpsboard.org/index.php/manager-list. This is updated on a regular basis as new managers join.
Those Investment Managers who sign up to the Code will be able to use the Code logo on their marketing literature. Code signatory status demonstrates their commitment to transparent reporting of costs. Institutional investors outside of the LGPS are increasingly recognising the Code as a differentiator in requests for proposal; there is no similar equivalent Code in the UK or internationally. There is no cost to fund managers to sign up to the Code.
What should I do if my manager won’t provide the information or sign up to the Code?
There should be certain requirements as part of the Investment Management Agreement (IMA) you have with your manager on what cost information they are required to provide to you so you can complete your Accounts in line with guidance and this information should be provided to you irrespective of whether the manager has signed up to the Code.
Over time, it is expected that more managers will sign up to the Code and it is now usually a requirement for any mandate tender that applying managers are signed up to the Code. However, there is no requirement for existing managers to sign up to the Code. In these cases, it may be that the information required for the templates is being provided already and / or is provided to other clients in other jurisdictions (e.g. the ILPA template for US Private Equity firms).
It is hoped that all parties involved with the Code and the system (SAB, LGPS funds & pools, existing manager signatories) will encourage those not currently signed up to the Code and system to do so in the short and medium term.
What happens if an Investment Manager doesn’t comply with the Code?
The SAB may revoke use of the Code logo and publicly remove a fund manager from the list on its website at any time if a fund manager is reported by a pension fund (or pool) to be in breach of the Code. The introduction of the system will allow the SAB to monitor and engage with all parties to ensure that the Code is followed.
Freedom of Information Act – what impact will this system have on how we respond to FoI requests?
There is no new information being provided through this system than you will have already been receiving through the manual submission of completed templates to you by your managers. As a result, there does not need to be a change in your approach to responding to FOI requests and with the ultimate public document being the Annual Report and Statement of Accounts, those requesting information could be pointed to that.
Is it fair that the templates consider only costs – not returns or risk?
In assessing investments, LGPS funds will consider risk, return and cost. The specific purpose of the templates is to provide LGPS funds with information on costs. By design, they include very limited information on performance and no information on risk. However, in assessing those costs, funds will take into account the performance delivered and the risks taken.
What should pension funds do with this data from the templates and system?
As well as using the data from the templates in compiling the statement of accounts, clearer presentation of the cost data can be discussed with pension committees and lead to discussion and evaluation for future investment decisions. Understanding cost of ownership is fundamental to good investment governance and better decision making. An important benefit of knowing cost of ownership is an improved negotiating position.
How does the system work for LGPS investment pools?
LGPS pool companies can be both fund managers and clients and may therefore both provide information to their LGPS fund clients and receive information from their signatory underlying managers through the system.
What mandate types are covered by the templates and the system?
The templates are designed to cover all mandate types other than direct cash and directly held property.
Does a fund manager have to sign up to the Code to use the templates?
In theory, a manager could provide the templates and information without being a Code signatory but it would not be able to benefit from positive publicity associated with being a Code signatory.
What do the templates look like?
The templates that are accepted by the system are the main account template (CTI Main Account Template), the private equity sub-template (CTI Private Equity Template) and the Institutional Limited Partners Association (ILPA) template – relevant for US Private Equity mandates (https://ilpa.org/reporting-template/).
Can I adjust or amend the templates?
No – these templates are set by third parties (CTI or ILPA) and so should not be amended. The system is built to recognise and accept unamended, correctly completed templates based on the versions released by ILPA & CTI.
What currencies can the templates be completed in?
Templates can be completed in GBP, EUR, USD JPY, CHF, AUD and CAD.
Funds can then choose the FX rate for conversion based on:
- Period end: selects the rate on the end date of the period as specified by the template
- Specified date: selects the specific day the FX rate will apply
- Average rate: selects an average between two dates within the reporting period. By default, the start and end of the period as specified in the template will be selected.
How frequently will the templates be provided?
Under the Code, templates must be provided at least annually based on either the calendar year or the funds’ financial year (to 31 March). From 2023, the system will be able to accept quarterly and biannual templates to meet the funds’ need for more frequent data. Managers are encouraged to provide data on a quarterly basis wherever possible.
What information will the templates provide?
The templates provide information on three main categories of investment cost: management fees, performance fees and transaction costs.
Does a LGPS fund have to sign up to the platform?
In theory no, but managers will provide the information to funds via the system so it would be surprising if a fund did not want to benefit from the system.
How will I get access to the system?
Pension fund officers should have received an invitation email inviting them to login to the system as primary users (i.e. users who have certain user admin rights for their organisation). These primary users can then add other staff relevant to that pension fund. If you have not received an email, please contact the SAB Secretariat ([email protected]).
Contacts at the investment managers who have signed up to the Code of Transparency should also have received an invitation email inviting them to login to the system. They too will then be able to add other colleagues to the system. Fund managers will then need to set up their clients in the system together with setting out what kind of template will be used for the relevant mandate.
How do I login to the system?
Given the confidential nature and sensitivity of the data in the system, login to the system will be through three-factor authentication – email address, password and validation by third party app, PingID (https://www.pingidentity.com/en/resources/downloads/pingid.html)
Where can I go to get assistance with the system?
For Code and template related queries, please contact the SAB Secretariat. For system related queries, please contact Byhiras.
How will managers be reminded to submit cost data?
From March 2023, managers will receive e-mail reminders of their reporting obligations and the funds and pools will be notified if a manger is late in submitting data. In addition, the system will display any late submissions to managers, funds and the SAB.
How will I be notified that managers have provided data to the system?
From April 2023, funds and pools will receive an e-mail notification once per week of any new reports uploaded by a manager.
When logging in to the system, funds and pools will be able to see straight away the status of any template completion – whether due, submitted, late or submitted late. From the history menu, funds and pools will also be able to see what was submitted and when.
Is this system available for all LGPS funds across the UK?
Yes. While the Code of Transparency and procurement of the system has been run by the Scheme Advisory Board (England & Wales), LGPS funds in Scotland and Northern Ireland are also able to benefit from it through a sharing arrangement with the relevant Scheme Advisory Boards – and as allowed for in the terms of the engagement with Byhiras. There will be no further cost to the LGPS funds across the UK for use of this system over the amount they already pay to their respective scheme advisory boards.
What information will the relevant Scheme Advisory Boards be able to see?
The relevant SABs will only be able to see aggregated cost data for the UK. They will be able to see total fees per asset class, average fees per asset class and a scatter line graph of total costs per the universe of anonymised pension funds – as well as fund groupings by small (<£2.5bn), medium (£2.5bn – £5bn), large (£5bn+) and pools.
To monitor and ensure compliance with the Code, the Scheme Advisory Board (E&W) will also be able to see which managers have submitted templates on time and which are late – but critically, it will not be able to see the content of any of those templates.
By when does a manager have to provide the completed template?
The default in the system is 90 days after the relevant period end (whether this has been agreed as quarterly or annually). However, it is possible to reduce this time for upload where agreed between manager and client. A template submission will show as late if submitted after the relevant deadline.
Does the system validate and / or verify the template submissions from managers?
The system will check that fields have been completed with suitable content (i.e. fraction where fraction needed, cells cross calculate to give a number referenced elsewhere in the template). On submitting the templates, the manager is asked to confirm that the template is fair, clear and not misleading (and are directed to the FCA website for more details on that statement). For full verification, the SAB system would need to have detailed access to all fund data which is not envisaged, although the main Byhiras system can manage that if funds and managers would like to explore that outside the SAB system.
Does the system provide any benchmarking capability?
The SAB system is not intended at this stage to provide any detailed benchmarking. However, funds will be able to see some comparisons of the various cost items against their peer group (small, medium & large) on an anonymised basis – where there are more than five data points for that comparison. SAB is considering whether and how the data could be used for benchmarking purposes, including whether that’s desirable.
Can Byhiras see my data or use my data elsewhere?
In specifying the system, the SAB placed great emphasis on security and confidentiality. The template data held within the compliance system will be separate from any other database held by Byhiras and cannot be shared by Byhiras with any third parties for any purpose.
How do I get more data and more analysis?
While some funds may be doing significantly more with their cost information, the system set up by the SAB is designed to act as a base level from which all funds can develop over time. Funds will be able to share their data with other parties via the system (with their managers’ approvals) such as investment advisers. There is also a more comprehensive system operated by Byhiras which funds and managers are free to discuss separately which is beyond the current system procured by the SAB. There are of course also other service providers of whom funds will be aware.
Will managers be required to provide data to other service providers?
As signatories to the Code, fund managers are only required to provide template data through the system procured by the SAB. While they may agree to provide the data to others, they are not required to do so by the Code.
How are the asset classes in the system decided?
The asset classes in the system are based on the CIPFA classifications as set out in its guidance. The asset classes are:
- Active Listed Equity
- Passive Listed Equity
- Active Listed Fixed Income
- Passive Listed Fixed Income
- Unlisted Equity
- Private Debt
- Property
- Infrastructure
- Multi Asset Funds / Diversified
- Growth Funds
- Derivatives
- Hedge Funds
- Other
Can pension funds upload their own internal data to the system to get a combined picture for internally and externally managed positions?
This is something that will be considered as part of the next phase of development of the system.
Can errors in templates be corrected after submission?
Validation rules will apply on template upload. If incorrect information has been entered, the investment manager should re-upload the template, which will replace the version previously uploaded. A version history will record previously uploaded files..
What might the compliance system do in future?
The SAB and Byhiras are exploring the provision of further functionality to be rolled out on a phased basis.
Does the supplier, Byhiras, provide any other services?
Yes, Byhiras provides a solution to transparency and accountability in investments. As its core service, provided to a number of clients, it aggregates data at the most granular level from source, validates the data and enables users to disseminate proprietary information throughout the investment management supply chain. More information on Byhiras can be found on its website: https://byhiras.com.
