Link to system

SAB Cost Transparency, Compliance and Validation System link to system and log in page

Background

As part of the Code, investment managers are required to complete and submit the template for the relevant mandate (without request) to their LGPS clients on either an annual or quarterly basis as agreed with their client. In order to streamline the process and make it more widely available, the SAB procured a system (through an OJEU process) from Byhiras which will take the form of online facility intended to:

  • Be capable of accepting and storing template data
  • Check the timeliness of data submission and report late returns
  • Ensure that template data is signed off by managers as ‘fair, clear and not misleading’
  • Provide a check against the MiFID II total cost amount submitted separately by managers to their LGPS clients

 

As well as ensuring compliance with the Code the system could be used by LGPS clients to:

  • Replace the existing excel format templates provided to them by managers
  • View a useful but limited set of onscreen reporting and comparison tools
  • Give permission to other LGPS clients or trusted third parties (e.g. their investment advisor) to access and export their template data
  • Provide advanced reporting facilities under a phase 2 development subject to the agreement of Code clients

 

In specifying the system, the Scheme Advisory Board 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.

The Board may publish aggregate totals or averages from the system as part of the scheme annual report. Such reporting will not identify any data at the fund, pool, manager or mandate level. This system went live on 1 April 2020.

Purpose of the Compliance System

The purpose of the compliance system is to provide cost effective template data collection and LGPS Code compliance checking, it includes useful but limited reporting and data comparison facilities.

The system is paid for from within the Board budget and funded by the levy. LGPS clients and investment managers will be provided access to the system free of any further charge.

The procurement process included in its specification the potential for a further phases of system development including detailed and customisable reporting and comparison tools plus facilities for LGPS asset pools to produce template data for clients and LGPS fund accounts to link with annual reports.

The Board will consider whether procuring further additions to the system to provide potentially costly and specialist analytical, data manipulation and benchmarking services from the Byhiras system is appropriate and with enough demand from LGPS clients to do so. While it may be that centrally procuring such facilities would provide the more cost-effective solution, the Board recognises that it may not be the wish of all LGPS clients to have such a service procured centrally but rather procured individually or collectively in groups of funds or pools.

To facilitate either option, the system has been specified to industry standards, therefore whichever supplier is selected by the Board it will be possible for LGPS clients to appoint their own providers who will be able, with the necessary manager permissions, to extract their template data from the compliance system for further analysis, reporting and benchmarking without the need for an additional collection exercise.

Engagement with users

Since Autumn 2019, the secretariat of the Scheme Advisory Board, together with Byhiras, have met with LGPS funds, LGPS pools and fund managers as widely as possible – both to explain the rationale and background to the system as well as to provide initial training on the use of the system.

As a result of these discussions, some Frequently Asked Questions (and responses) are available.