PIMFA Winter Journal 2020

The Personal Investment Management & Financial Advice Association

JOURNAL WINTER 2020 COULD NEGATIVE INTEREST RATES AFFECT YOUR BUSINESS? What business owners need to consider to safeguard their firms against the potential rate cuts being discussed at the Bank of England

EMPOWERING RETAIL INVESTORS WITH TECHNOLOGY Retail-focused digital investment products such as free trading apps and robo-advisers continue to capture headlines

COVID-19 AND CULTURE IN THE WORKPLACE COVID-19 has led to significant challenges for employers across all sectors

CROSS-BORDER TRENDS - A BRAVE NEW WORLD FOR UK FIRMS We are all aware that the access arrangements which UK firms have with clients in the EEA will change next year

BUILDING PERSONAL FINANICAL FUTURES

CONTENT PAGE

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Could negative interest rates affect your business?

Finding the silver lining in cloud data

The risks of homeworking

Empowering retail investors with technology

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COVID-19 and culture in Financial Crimes the workplace Enforcement Network (FinCEN) Reform

Cyber Doctor

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Cross-Border Trends A Brave New World for UK Firms

Cybersecurity in a year of crisis

M&A takes centre stage for UK asset and wealth management

Why Wealth Managers will find it increasingly difficult to differentiate and control their costs unless they embrace a more flexible, collaborative model

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PIMFA JOURNAL

WINTER 2020

COULD NEGATIVE INTEREST RATES AFFECT YOUR BUSINESS?

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ith global growth slowing and the impacts of the pandemic being felt across many economies, the Bank of England has begun having discussions around introducing negative interest rates in the UK. As the subject matter continues to pick up momentum, we discuss what business owners may need to consider to safeguard their business against the potential rate cuts.

WHAT IS THE PURPOSE OF LOWERING INTEREST RATES? Since the great recession, many advanced economies have experienced low growth and low levels of investment and inflation. In an attempt to boost growth, we’ve seen central banks taking on increasingly forceful monetary measures, which often include negative interest rates. The European Central Bank deployed negative rates in June 2014 and Japan did the same in 2016. Switzerland is currently the most negative with rates as low as minus 0.75%. So, negative interest rates are more common than you might think.

While negative rates in the UK are by no means certain, they are certainly possible. Financial market futures and UK Gilts have been trading with negative yields in some maturities for some time. Setting the Base Rate is one method used by the Bank of England to implement monetary policy. Since the significant impact of COVID-19 on both the Global and the UK economy, central banks around the world have been working

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to stimulate economic activity in what was already a low interest rate environment following weak growth post the 2008 financial crisis.

One of the COVID-19 specific dynamics are the plethora of loan programmes put in by Government to help business get through the crisis. Many of these programmes carry an initial period of zero interest and have been understandably well utilised. As of mid-October, the Coronavirus Business Interruption Loan Scheme, CIBILS and Bounce Back Loan scheme have a combined drawdown of £61.93bn according to Government data.

liquidity, or in other words, more cash than they can lend at reasonable charge. This excess is then placed with the Bank of England at the Base Rate. This has the effect of lowering the NIM they earn and, if the base rate is lower than the rate they paid depositors for the cash in the first place, can actually generate a negative return for the bank.

One mitigant for a bank is to reduce the rate it pays depositors for their savings, hence the rapid drop in savings rates we have witnessed since the early part of the year.

I BARELY GET PAID ANYTHING ON MY SME ACCOUNT ANYWAY – WHY SHOULD I CARE? A few reasons –

The objective of negative interest rates is to encourage the population to spend rather than save, thereby stimulating economic growth. Negative rates, however, go that step further, since in theory any savers with money in deposit accounts will see the value of their savings slowly decrease.

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HOW WILL NEGATIVE INTEREST RATES

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EFFECT MY BUSINESS DEPOSITS?

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A key source of income for any bank is Net Interest Margin (NIM). This is the difference between the interest rate it pays depositors for their savings vs. the interest rates it charges to make a loan.

In an environment where there is plenty of loan liquidity, particularly for SME’s, banks may end up carrying excess

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Businesses tend to have their accounts with the biggest banks in the UK – these banks often carry the most excess cash as they have the most customers. Banks have been known to ask firms with large deposits to withdraw the funds and place them elsewhere.

If the Base Rate becomes negative and the Bank of England start charging banks for those excess deposits, the banks will need to recoup that cost by potentially passing that cost forward to account holders. This might mean paying savers back less that they originally deposited. Alternatively, banks may increase fees of banking services such as payments, statements, and account maintenance.

There are plenty of SME deposit accounts in the market that pay interest. At time of writing, there are banks paying 0.5% in Easy access and as much as 1% for 1-year term all covered by FSCS protection*.

HOW CASH MANAGEMENT PLATFORMS CAN PROTECT BUSINESSES AGAINST NEGATIVE IMPACT RATES As any business owner knows, it is important to evaluate financial risk to your company. The continuous management of cash deposits and constant review of the bank interest rates to ensure that the cash is always making the most of the better banking rates available is vital for businesses.

Yet, the hassle involved in opening one new account, let alone multiple accounts, is often too time consuming and brings administrative burdens. An efficient solution to these problems is provided by cash solutions platforms such as Insignis Cash Solutions. Insignis provides secure, online access to dozens of banks and products all with just a single account opening procedure, helping to decrease the potential effects of negative interest rates and inflation. This in turn enables you to make the most of the highest interest rates that are currently on offer.

The figures used in this article were correct as of 17th November 2020.* Nick Lacey, Head of Sales.

Insignis Cash Solutions www.insigniscash.com

PIMFA Plus Partner

PIMFA has partnered with select product and service providers to offer member firms a suite of membership enhancements. Find out more at www.pimfa.co.uk/becomea-member/pimfa-plus-promo

@PIMFA_UK

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WINTER 2020

FINDING THE SILVER LINING IN CLOUD DATA

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ata is, unquestionably, the new frontier for financial institutions. Much like in the space race which dominated during the 1950s 1970s, when global superpowers competed to become the first to capitalise on the final frontier, financial institutions are now competing against each other in the race to capitalise on data. Firms across the globe are looking to explore this new source, racing to make the most of the opportunities it presents and utilising it to beat their competition.

Right now, firms should be asking themselves if their current operations and technology allow for speedy onboarding of new data types and if they can efficiently shape, aggregate, and make sense of data sources faster than their competitors. Having the capabilities to do so will not only enable them to mitigate risks, especially crucial in the current macroeconomic climate we find ourselves in, but also to take advantage of the future of finance now.

One technology which financial institutions have been increasingly integrating into their systems is the cloud data.

Weighed down by the same old issues surrounding legacy infrastructure, the cloud is an effective solution for firms unable to rip out and replace existing systems during costconscious times. This article will explore what the role of the cloud is when it comes to financial data, what it is that financial institutions are putting into the cloud and if the cloud has the potential to drive the future of finance.

DATA IN THE CLOUD The cloud has many benefits for all users. In short, it is convenient, cost-efficient, facilitates easy sharing of information and has wide-reaching usability and accessibility. It is an adaptable data delivery and data management solution that can be catered to meet the requirements of different firms. For companies weighed down and restricted by the effects of legacy infrastructure, cloud technology is an effective solution to meet the changing needs of their own clients and the industry landscape.

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Financial institutions are increasingly using the cloud for various functions. Banks have adopted new digital channels and leveraged the prevalence of data to ensure that customers have frictionless and personalised ways of using products and services. For capital markets firms, the cloud is crucial in driving a reduction in fees and an increase in the sophistication of the tools available to clients. As such, the types of data hosted on the cloud have become increasingly more complex. From historical to time series data to reference and pricing data and, most importantly, data analytics, firms are looking for increasingly sophisticated but useable cloud data solutions that meet the demands of their increasingly sophisticated client-base and help them navigate a heavily regulated environment.

THE FUTURE OF FINANCE With the cloud, there are many opportunities for data provision, aggregation and analytics. If electric cars are the future of driving and the combustion engine is the motor equivalent of legacy technology, there is an argument that positions the cloud as a driving force for the future of finance. At SIX we are analysing methods and processes to bring our clients’ in-house applications into the cloud and systematically make full use of the technical possibilities here. Data in the cloud can be developed into cloud data as a service and potentially an overarching cloud data marketplace. By doing so, assisted by our partnerships with the likes of Crux and Xignite, we are bringing all types of relevant data (historical, time series, reference, pricing) and data analytics into one platform. Doing so will create a self-service data model that reduces administrative and delivery costs for financial institutions and offers rapid onboarding of new data and content. Most importantly, the data will be aggregated, normalized and structured for advanced analytics. Clients will, in turn, be able to demonstrate the benefits of data insights through improved workflow and the enablement of cloud-based data processing.

Data is unquestionably the new oil of the financial industry, but oil still has to be refined. This takes both money and infrastructure before it becomes the data equivalent of gasoline. Through our Google Product Cloud offering, we have refined the process to ensure that data is the new frontier of the financial industry.

Cloud is the foundation on which firms can use the latest Machine Learning and AI tools to do something with the data that potentially results in the increased alpha that investment managers are seeking. As the possibilities for the role of cloud data in the future of finance continue to evolve, those that are able to seek alpha generating opportunities will be the ones to benefit most.

Tamsin Hobley, Head Atlantic Region, Financial Information, SIX www.six-group.com

SIX SIX operates and develops infrastructure services in the Securities & Exchanges, Banking Services and Financial Information business units with the aim of raising efficiency, quality and innovative capacity across the entire value chain of the Swiss financial center. The company is owned by its users (122 banks). With a workforce of some 2,600 employees and a presence in 20 countries, it generated operating income of CHF 1.13 billion and Group net profit of CHF 120.5 million in 2019.

@PIMFA_UK

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THE RISKS OF HOMEWORKING W

ith 69.6% of people employed in professional occupations now homeworking ¹, the cultural, operational and risk impacts on consumer investment firms is considerable - especially so when the ability to physically interact with clients is an essential part of building, and strengthening, client relationships. The homeworking trend also brings about privacy, security and health challenges that may be new to a number of organisations. Based on our experience in working alongside a number of Risk managers, Head of business and front-line teams, we’d like to share with you three of the less obvious risks that may arise as a result of homeworking (and offer a few suggestions to mitigate against them).

PHYSICAL SECURITY IT security is commonplace. Data monitoring can easily be achieved to compliment remote working. But what about what can’t be easily monitored or secured? Consider the physical environment. How certain are you that someone your employee is sharing a residence with may accidently, or otherwise, read a piece of paper that’s been left lying around containing confidential information about a client’s financial affairs? How certain are you that, when an employee walks away from the computer for a break, that a curious child won’t mistake the company computer for a whiteboard? Or a frisbee? Maybe an employee shares their flat with other young professionals. How can you ensure that, during confidential meetings or phone calls, that someone doesn’t overhear sensitive information? Our suggested steps for mitigating the risks associated with physical security are:

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Ensuring that there is a comprehensive policy and procedure that is readily accessible, up-to-date and attestable by employees,

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Ensure that all employees conduct their own individual risk assessments, and provide evidence, of their working environment - and are required to review that assessment on a periodic basis, and

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Employees have an easy to utilise mechanism to report on actual, or near miss, physical security events.

Whilst a proportion of investment and advisory employees may not be office bound during ‘normal’ business practice, they typically still physically interact with others - be they clients, managers or other employees. This physical interaction provides an opportunity to have a discussion, observe body language and assess, in simple terms, the mental outlook of an employee. However, with COVID, the identification and management of stress, mental exhaustion or drug and alcohol abuse may prove much more difficult if an employee is not inclined to self report - especially during times of lockdown. Identification, and mitigation, are key.

Steps that your organisation could take include:

Homeworking, obviously, restricts the accessibility you might usually have to your colleagues. A challenge, or question, that would usually be discussed, and often solved, with a short walk to another employee’s desk now has to be dealt with via virtual meetings, phone calls or e-mails - none of which are necessarily conducive to a ‘quick chat’. The lack of physical presence also increases the risk of ambiguity in terms of task and role responsibilities. By way of example, it is common amongst risk, compliance and business managers to discuss, ‘around the table’, upcoming changes to clients, markets and regulation, how those changes are going to be addressed collaboratively and who owns the responsibility for identifying, implementing and mitigating against the risks.

These collaborative opportunities for discussion, coupled with clear lines of accountability, become even more critical during times of crisis or challenge such as COVID-19.

The key, based on what we’ve seen, is to remove the ambiguity without losing the collaborative approach. Our suggestions include:

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ACCESSIBILITY AND ACCOUNTABILITY

Periodic surveys, that tie directly into risk metrics, to better understand the work habits of employees,

Well defined, and easily trackable, measurement of hours and times of work, and

Policies that the employee feels comfortable accessing should assistance be required.

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A centralised ‘point’ within the business where all relevant market, regulation and industry data is stored and can be easily commented upon and discussed, A clear business process in terms of who is responsible for identifying, and actioning, specific types of changes and their impacts on your organisation, and Exception based management, and reporting, capabilities to ensure accountability is being maintained.

THE WAY FORWARD Talking about ways in which to mitigate risk is easy - managing the implementation and maintenance workload of mitigation tasks is difficult. Any structure that your organisation puts in place to mitigate against these risks should minimise manual maintenance, automate repetitive activities and easily provide real world, real time, data. GRC Technology can help your organisation to transform a complex and time consuming obligation into something comprehensive, intuitive and simple to manage. Visit our website trilinegrc.com for more information.

Ian Wilson, Director – Sales (UK & Europe) | TriLine GRC https://trilinegrc.com, the complete solution for Governance, Risk and Compliance

1 Coronavirus and home working in the UK: April 2020, Office for National Statistics.

Source: https://www.ons.gov.uk/employmentandlabourmarket/peopleinwork/

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employmentandemployeety pes/bulletins/coronavirusandhomeworkingintheuk/ april2020#homeworking-by-occupation. Accessed 17/11/20.

@PIMFA_UK

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WINTER 2020

EMPOWERING RETAIL INVESTORS WITH TECHNOLOGY R

etail-focused digital investment products such as free trading apps and roboadvisers continue to capture headlines, if not significant investment flows. Less glamorously, upgraded technology in adviser platforms is providing better distribution and client management tools for advisers. Going ‘digital’ has become a wealth management imperative and, though the journey can be a bumpy one, the promise of better outcomes at lower cost sits at the heart of FinTech’s promise.

COVID-19: A 2020 SPRING CLEAN The sharp market sell-off in March - and the relief rally that has followed the U.S. election and announcement of possible vaccines from Pfizer, Moderna and Oxford University/AstraZeneca – has renewed investors’ focus on portfolio composition and risk profile. Dividend cancellations by U.K. PLCs have been particularly painful to ‘income’ seeking investors. A decade of quantitative easing and the rising tide of equity values was always going to lead to a reckoning, or at least a revaluation.

The news hasn’t been all bad, of course. Many investors and their advisers have taken the opportunity to invest at much lower valuations. Data from stock exchanges globally reports that retail investors comprised the majority of ‘BUY’ orders during the market sell-off.

But advisers shouldn’t focus on opportunities in the secondary markets alone. The primary markets – where companies raise new capital from investors – can be valuable sources of returns and outperformance too.

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PRIMARY ISSUANCE: FIRST STEPS

PUTTING THE PUBLIC BACK INTO PUBLIC MARKETS

Until recently the primary markets were largely off-limits to retail investors. Retail investors would occasionally be invited to participate in IPOs, and formal ‘rights-issue’ processes remain a mainstay of U.K. corporate governance that many shareholders will be familiar with. But dwarfing both of these in size and frequency is the ‘follow-on’ market in which companies use investment banks to raise new capital, often in a narrow time frame and normally outside of trading hours. Over 250 such deals have taken place since March, raising over £25 billion from institutional investors as U.K. PLCs have rebuilt their balance sheets after a reassessment of funding needs.

In April an Open Letter (www.allinvestors.co.uk) to the boards and management teams of the U.K.’s listed companies, leading figures from the UK’s financial services sector made the case for including smaller investors in primary market deals. The letter noted that new technology services, such as that offered

by London Stock Exchange partner PrimaryBid, now allow retail investors and intermediaries to take part in primary deals alongside bigger institutions, and that on corporate governance grounds these deals should be open to the public.

In a recent report by the QCA, 48% of retail investors surveyed said that they would like to be able to invest in these off-market ‘placings’. It’s easy to see why: in addition to being dilutive, these deals are typically done at a discount to the prevailing secondary market price.

Typically, though not always, the market responds positively to news that a business has raised additional capital. This was certainly the case during the summer when investors worried that some of the U.K.’s best known listed companies would struggle to stay afloat as demand for their services collapsed.

The City responded. As a result of the letter and the press traction that accompanied it, the Boards of some fifty companies have since included retail investors on their deals ranging from established FTSE issuers like Compass Group and Ocado, to growth names in the AIM market such as Velocycs and Frontier IP. Thousands of investors have participated in these deals, either directly or through broker and adviser platforms connecting to PrimaryBid. For advisers, these deals can be a great conversation starter: they attract a significant amount of press coverage, and demonstrate to clients that an adviser is being proactive and understands any individual stock holdings that accompany fund investments – many of which may be the legacy of privatizations or employment.

EMBRACING A DIGITAL ECOSYSTEM July 2020 saw the launch of a Government review into the U.K.’s financial technology industry. Its brief is to ascertain what is required to create a financial services ecosystem that is sustainable, inclusive and world leading. Meanwhile, in November Chancellor Rishi Sunak announced a review of the listing rules for London’s stock market, tasking Lord Hill with examining its attractiveness to the fastest growing companies and promoting the U.K.’s standing as the capital market of choice. Retail investors, powered by new technologies, will form an important part of this agenda. Advisers can play a key role in supporting them and taking advantage of emerging opportunities.

Mike Coombes Head of External Affairs, PrimaryBid www.primarybid.com

@PIMFA_UK

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COVID-19 AND CULTURE IN THE WORKPLACE

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OVID-19 has led to significant challenges for employers across all sectors, including financial services, but what does it mean for workplace culture? Will it encourage a shift towards a stronger and more inclusive culture, or will it simply uncover problems that already existed? What should employers do about workplace culture as we emerge from the pandemic?

HOME-WORKING Perhaps the greatest challenge has been the sudden shift to home-working for many employees, in line with government guidance. The FCA and PRA recently published statements emphasising that firms should follow relevant government guidance on home-working, and recommended that the chief executive office senior management function (SMF1) is accountable for ensuring adequate processes for following the guidance. Prior to COVID-19, it was generally accepted that home-working was possible but that it didn't work for many jobs on a regular basis. Has this crisis led to a change in approach on a more permanent (outside COVID) basis?

Employers may have already seen the benefits of homeworking through increased productivity or the potential for cost savings by reducing office space. Employees may have enjoyed a better work-life balance or greater flexibility around childcare. Some employers in financial services are already actively considering more permanent flexibility in working arrangements and how much office space they need.

HEALTH AND WELLBEING The shift to home-working means it is much more difficult to "see" if employees are struggling with work generally, and also with their mental health. Staff turnover, sickness and lost productivity resulting from poor mental health cost UK employers up to £42 billion last year - in addition to clear legal and moralistic reasons for looking after employees’ health and wellbeing, there is also a strong financial incentive.

Even before COVID-19, mental health related disability discrimination cases had been increasing, and we expect this to continue. Raising awareness of mental health issues, and giving managers the skills and tools to properly support and manage mental health issues (for example, through training) is key in reducing the risk of claims and enabling proactive management of issues.

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BULLYING AND HARASSMENT Remote working has its risk profile for bullying and harassment issues as employees may feel they are in a less formal workplace environment, or that virtual communication provides them with a degree of anonymity. The reduction of face to face contact perhaps increases a risk of resorting to written communications which lose the texture and "human nature" of oral communications and increase the risk of depersonalisation. Significantly for employers, it is also more difficult to spot online bullying and harassment than issues which may arise in an office environment where others may observe, moderate, and report behaviour. The importance of focusing on bullying and harassment, and having measures in place to both deal with it and prevent it, is part of the FCA's continued focus on non-financial misconduct. Ensuring that employees are aware of what constitutes inappropriate behaviour and highlighting a zero tolerance policy is essential.

Covert recordings: •

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Evidence and information: • •

MANAGING PROCEDURES REMOTELY Prior to COVID-19, investigation meetings and disciplinary and grievance hearings were almost always held in person.

Remote hearings are now likely to continue for some time, even once employees start to return to the workplace. Faced with additional pressures and a lack of equipment and resources to hand physically (such as printers), shortcuts may creep in – perhaps key evidence is at the office or not shared in adequate time before a meeting, an important witness may have left the organisation, be absent ill, or unavailable due to pressures on their time, or individuals may not be able to attend remote hearings at certain times due to caring responsibilities.

However, the fairness of the process must not be impacted.

Some practical points to consider are:

Effective use of technology: • • • •

ensure that remote procedures are as aligned to usual procedures as possible; use video rather than audio-only platforms; consider reasonable adjustments; make sure technology is secure – for example, using password protection.

recording meetings is generally not allowed unless all parties are aware of those recordings, and an employee covertly recording may constitute misconduct – check that this is covered in policies; recordings made secretly may still be admissible in an Employment Tribunal if they are relevant to the issues being considered.

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circulate documentation in advance electronically (and possibly in hard copy); consider if more time is needed to review information than would ordinarily be the case; consider using the "share screen" function or ensure that pages are numbered for ease of reference so that you can jointly refer to documentation in the meeting as you would if you were in the same room.

That is an important element, but it is only one of them. The Black Lives Matter movement has led to an increased focus on implementing lasting change to increase the representation of black workers in more senior positions and also generally within the financial services sector where there is a wider representation issue. Most recently, the Commission on Race and Ethnic Disparities has issued a call for evidence regarding disparities and inequality in the UK and asks for suggestions on addressing racial and ethnic disparities in the UK . The FCA recently published an article looking at how organisations might improve diversity objectively, through identifying unwanted imbalance and allowing changes in diversity to be monitored over time. The article also highlights the benefits of considering less "traditional" aspects of diversity, such as socioeconomic background and neurodiversity. These elements also inter-relate and cross over. Without a focus on socioeconomic background, it is unlikely that any focus on certain other aspects of diversity will work as well as they could.

DIVERSITY AND INCLUSION

WHERE DO WE GO FROM HERE?

Employers in financial services should consider their diversity and inclusion programmes, and areas where diversity and inclusion are at risk during the pandemic so that steps can be taken to continue to move programmes forward. The economic crisis that has arisen has had, as a statistical fact, a disproportionate impact on women, who are more likely than men to have lost work and experienced a fall in their earnings. It is apparent that additional childcare responsibilities (which have arisen as a result of school closures, school children being required to isolate, and childcare provided by more elderly family members reducing) have fallen more on women than on men. As we emerge from COVID-19, employers should ensure they have tools in place so that they can identify where the pandemic may have caused disadvantages for certain employees so that this can be understood, and appropriate allowances can be considered and made to prevent an ongoing impact on careers.

This is a time of change and progression for employers, much of which has been forced on them as a result of this pandemic. However, these changes have actually shown how certain "non-traditional" methods of working, or arranging work, or carrying out work, within financial services can produce results. If these changes can be properly reviewed and continued in a non-COVID world, that represents a real opportunity to implement changes which provide more flexibility for employees, and improve workplace culture, and that should assist in relation to diversity and inclusion.

It is also very important to remember that a focus on diversity and inclusion does not start or end with a focus on gender diversity.

If you have any questions or would like advice on any of the issues raised here, please get in touch with Chris Holme Partner Clyde & Co LLP www.clydeco.com

@PIMFA_UK

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FINANCIAL CRIMES ENFORCEMENT NETWORK (FINCEN) REFORM Recently, US financial crime regulator FinCEN has been the recipient of media attention due to the “FinCEN files” news story and the rather complex world of Suspicious Activities Reports (SARs). These recent incidents raise numerous considerations, not least how we could enhance our overall approach to financial crime risk by improving the way we interact and share information with the relevant authorities.

An interesting point in all this is that, at the time the FinCEN files news was published, the US was already looking into reform of their economic crime infrastructure.

An even more interesting point, if you are reading from the UK, is that the UK government is exploring similar concepts.

In this article I will provide an outline of the proposed US reform and give some thoughts about how the UK government is exploring this reform and trying to adapt it to the UK environment.

The US regulator proposes to amend national legislation and require firms to have in place “an effective Anti-Money Laundering (AML) program”.

What is an “effective AML program”?

FinCEN proposes to define an effective and reasonably designed AML program as one that: •

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identifies, assesses and reasonably mitigates financial crime risks in a way that is consistent with the firm’s risk profile and with the national AML priorities set by the competent authorities – a risk based approach is not mandatory in the US, so mandating firms to perform a risk assessment is definitely a step in that direction. assures and monitors compliance with recordkeeping and reporting requirements provides to government authorities information with a “high level of usefulness”

This is accompanied by a guidance package that sets the regulator’s expectation in terms of “effectiveness”, the national AML priorities and what information is deemed having a “high degree of usefulness”.

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What is the perceived benefit of focusing on effectiveness?

The idea is that if a firm deploys an “effective AML program” – one that performs risk assessment that includes national priorities and that shares information useful to the competent authorities – the firm will be able (and allowed, if not encouraged, by the regulator) to reallocate their resources to those activities that do enhance the effectiveness of their AML program.

This creates a virtuous circle where the firm allocates the resources where they are most needed (high risk areas and national priorities), then in turn this higher concentration in resources results in the provision of information that is more useful to the regulator.

However, this setup has a limitation: the resource reallocation is only allowed for those activities that are not mandated by law or regulation. This really means that if the rules are prescriptive and take up all the budget there will be no reallocation possible, especially for smaller institutions. The regulator has plans to review its rules and guidance with an eye to achieving effectiveness – which begs the following questions: •

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Does this represent a shift from a prescriptive, rulesbased approach to a more agile, principle-based one (or maybe something in between)?

Will the regulator’s review realistically result in rules that are formulated to require less compliance budget, allowing firms to reallocate resources more effectively?

Which rules will the regulator be able to touch up to achieve this without compromising on overall compliance and on the country’s ability of adequately managing ML/TF risk?

Information sharing is the other item of interest – it is an integral part of the approach – without useful information the regulator is not in the position to update national AML priorities. That is why FinCEN stresses the fact that information must have a high degree of usefulness – otherwise, the national priorities may not reflect the real threats.

How does this process work?

As explained above, “high level of usefulness” will need to be defined by the regulator – including guidance on which information is deemed useful and how it is to be provided (if via a SAR or otherwise). On the other hand, the national priorities are set through a public-private working group and updated every two years. This sets up a “circular” process (also known as “continuous improvement process”) where useful information gathered from firms is used to assess and determine the national priorities, which then in turn are used to determine what information is useful. And so on.

What about the UK? The UK’s economic crime plan is heading in a similar direction to the US, in that the focus on effectiveness is present in the UK work too. The hope is that a more effective economic crime infrastructure will provide a better flow of information and ultimately be conducive to better outcomes in the asset recovery space – which at the moment stands at a rather unflattering 1% (source: Home Office, 2020).

There is also a focus on better information sharing.

Government and stakeholders from the public and private sector are exploring ways to improve the quality of information being shared and how this can be done.

With regard to the “continuous improvement” point, there are talks about creating a similar one for the UK, where an independent working group is tasked with suggesting ways of improving the SAR process.

The resourcing point is also interesting – it’s all very well to theorise on how more effective information sharing can result in more criminality being avoided or pursued, but this will remain academic if firms do not have the resources to

engage with other stakeholders and share the information.

Resourcing may not be an issue for larger institutions, but it certainly is an issue for smaller entities which are operating at capacity now. It is still being explored what, if anything, can be done to allow smaller businesses to free up resources and operate more effectively.

As we saw above, the US proposal is for resource reallocation to only be allowed for those activities that are above those mandated by law/regulation. If a similar approach is taken in the UK, what does this mean? If the UK does reform, will this be the same?

If the government is serious about enabling as many firms as possible to reallocate resources and create efficiencies, there needs to be a review of how current obligations are structured, and work needs to be done in exploring whether these can be streamlined without lowering standards.

For example, feedback shows that a firm cannot file “connected” SARs to competent authorities – every SAR needs to be self-contained. This means that if additional information arises on one specific matter that already has a SAR on it, this information needs to be submitted from scratch, as it’s not possible for a SAR to build upon information from previous SARs. This is time consuming for firms, and locks in resources that could be otherwise employed. So, for example, if it was made possible to amend SARs and add information to them, avoiding the necessity to resubmit the same details over and over, this would make the whole process less frustrating and also provide a better picture to law enforcement who could follow the development of the matter step by step and act quickly if they feel that something is not right.

If you are interested in these topics and would like to get involved please do get in touch with Giulia Lupato Senior Adviser PIMFA www.pimfa.co.uk

@PIMFA_UK

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Cyber Doctor Powered by

LIKE MANY FINANCIAL ADVISERS, WE CONTINUE TO HAVE STAFF WORKING FROM HOME. WHY DOES THAT INCREASE OUR RISK OF A CYBER BREACH? There are a number of reasons. First, staff tend to behave differently in a home-based environment, and may let their guard down. Cyber criminals know this, and are actively creating new phishing attacks to exploit a lack of training or inadequate policies and procedures.

In addition, there are important technical controls which would normally be run centrally from your office, which do not operate effectively when staff are remote working.

Also, laptops and other devices used remotely, require a change in their technical configuration which, if not done correctly, leaves them vulnerable. Finally and crucially, remote connections back to the office network are rarely configured securely, and this has become a common achilles heel.

2 SO HOW CAN OUR STAFF HELP TO KEEP US SAFE? One of the biggest vulnerabilities lies in the day to day practices of people.

But they can become an important line of defence. Make sure everyone receives cyber awareness training to help them recognise fraudulent emails, infected videos (usually on social media) and other phishing attacks. Undertake simulated phishing exercises. This is a great way to identify the individuals who may be vulnerable, and for whom more training is required. You should also have the right policies in place to fit the way you are working with checks and controls to ensure that staff are complying with the rules.

HOW SHOULD WE SECURE REMOTE DEVICES? There is a whole host of things to consider here. Make sure your antivirus application is completely up to date and configured proactively to scan the device, attachments, and downloads. Re-configure machines to update operating systems independently (in the absence of central management). Think about whether your remote working has altered the effectiveness of your backups, and reconfigure them accordingly. Carefully review and limit administration rights and access management, so that you limit the access and damage that any “intruder� can do. Enable encryption (without exception) to protect in the instance of a lost machine, and think carefully about where to keep the encryption recovery keys.

4 HOW DO WE SECURE THE CONNECTIONS FROM HOME WORKERS BACK TO THE OFFICE? This can go horribly wrong if done incorrectly. Our advice will vary dramatically depending on your business processes, your IT set up and the third party software you rely on. It is a complex area but points to consider include: remote connection software must be brought up to the latest version to protect against known vulnerabilities; where possible, only allow work devices to connect and only after they have been correctly configured. Allowing home and personal computers to connect to your secure network massively increases risk; and strong authentication is absolutely crucial e.g. multi-factor on Office 365. Applications where you log on via a web page, should have something that is stronger than just a password. If you must rely on a password, make sure it is strong and unique (not shared or reused), and definitely do not store it in plain sight.

CYBER DOCTOR POWERED BY MITIGO To get your question featured in the next edition of Cyber Doctor email your questions to cyberdoctor@mitigogroup.com.

Mitigo provides specialist cybersecurity services to the financial services sector, covering technology testing, people training and governance, and ensuring legal and regulatory compliance. All for an affordable monthly fixed fee. http://www.mitigogroup.com/pimfa

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WHY WEALTH MANAGERS WILL FIND IT INCREASINGLY DIFFICULT TO DIFFERENTIATE AND CONTROL THEIR COSTS UNLESS THEY EMBRACE A MORE FLEXIBLE, COLLABORATIVE MODEL

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e have seen how COVID-19 has accelerated the need for digital technologies within the Wealth Manager market as firms are being challenged to step up and meet rising client expectations. The current situation has also made it much harder for firms to differentiate themselves, which is increasing competition in the market, and pushing them to be more open, agile and collaborative in order to maintain business levels and retain client relationships.

Whilst ways of doing business are changing, the need for firms to control their operating costs, protect margins, and stay compliant remains constant, so how they respond during this pandemic will have a longer term impact on their position in the market.

Tactical decisions made at the start of this pandemic will need to be backed up with longer term business strategies that ensure their operating model and end-to-end technology are fit for purpose coming out of the pandemic.

In doing so, organisations will need to reassess what it takes to offer clients a differentiating experience and embrace change as the new normal. The ones that continue to operate across disparate systems, or are constrained by legacy platforms, will struggle to offer these enhanced levels of service in a sustainable and profitable way.

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DIFFERENTIATION

4&5) Change & Control

Fundamentals of differentiation - “The 5 Cs”; Customer, Connectivity, Collaboration, Change, Control.

One thing is certain, things will change, and institutions need to be more flexible and agile than ever to deal with the level of change required in a digital world. Business models that embrace change, whether that is client, regulatory or market driven change, will be the ones that can plan change proactively whilst being able to respond quickly to gain market advantage.

1) Customer As the needs of the wealthy continue to change, Wealth Managers need to evolve their value proposition too. Today’s wealthy clients demand services that empower them to monitor and manage their investments in real-time whilst on the move. In contrast, many institutions have retained traditional service structures and business models, which makes it difficult to adapt to the wider needs and preferences of their target clients.

In reality, clients no longer need to rely on a single advisor, often supplementing advisor insights with market data from across their own networks. Differentiation comes from those who collaborate across the market, offering a wider set of investment services and insights to their clients.

2&3) Connectivity & Collaboration However, a Wealth Manager’s ability to deliver differentiating services and insights greatly depends on their level of connectivity and the ease with which they can integrate new value-add services into their own value proposition.

Organisations that focus on improving their connectivity, both front to back through their operations and into the wider market ecosystem, will be best placed to serve their clients future needs, delivering a balance of differentiation and cost efficiency.

Through collaboration, they will be able to open up new channels of engagement, attracting new wealthy clients, extending the breadth of services they can offer them, whilst maintaining the flexibility to outsource selected services for cost control or differentiation purposes.

Ongoing change is often the hidden cost when it comes to transforming the business, and firms need to better understand the true cost of ownership, the level of control they will need to deliver change at a pace their clients demand, and the capabilities of existing technology to connect internally and with the outside world as part of a modern service oriented architecture.

Firms that choose to outsource change to service providers will still need to maintain oversight and a level of control, and will be pushed to consider the cost benefits if changes cannot be delivered quickly enough or at all.

COST CONTROL Collaboration drives business growth and efficiency.

The cost pressures on Wealth Managers are well understood and particularly relevant right now, with rising client expectations, lower margins, and an increasingly complex regulatory environment.

Meeting this challenge alone is not easy, and many organisations have historically chosen to outsource large parts of their service model in order to share the costs and reduce the risk and complexity of managing these changes.

However, firms that outsource their service model often have to compromise on client experience and differentiation, and it is these factors that will be key to sustaining business success in a post-pandemic world.

SUMMARY Adopting a more collaborative and connected service model, enables firms to maintain control of their client experience, with greater flexibility to offer services that differentiate them in the market, and a broader reach to attract new clients across a wider ecosystem.

Traditional service models often constrain change and connectivity, limiting opportunities for firms to differentiate with their target clients. Firms that embrace change, extend their boundaries, and take control of their own value proposition, will be best placed to deliver value to their clients, attract new clients, and drive operational efficiencies from end-to-end across their business.

Paul Driver Sales Manager UK&I ERI Bancaire www.olympicbankingsystem.com

@PIMFA_UK

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BRP: CROSS-BORDER TRENDS - A BRAVE NEW WORLD FOR UK FIRMS

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e are all aware that the access arrangements which UK firms have with clients in the EEA will change next year and, for retail clients, firms will have to assess the various national regulatory regimes to see if it is worth obtaining a license if they have a particular target market in mind. Even for non-retail clients it seems unlikely that the third country regime under MiFIR will be up and running soon. Whether the UK will be granted equivalence for investment services seems to be a political decision tied up in the Brexit process. Should the UK and EU agree a mutually beneficial trade deal it is possible that equivalence could be granted, but this would not be until well into 2021 or later.

So, in Europe, the trend seems to be towards market fragmentation and more onerous information and reporting requirements for non-EEA firms. Reliance on reverse solicitation and contractual continuity arrangements may suffice for existing clients, but is not a great model for new business.

There are of course many other countries in the world, all with varying ease of access for foreign financial institutions. Even Switzerland, which has been historically one of the more liberal countries, has moved towards the EU model with the implementation of the Financial Market Infrastructure Act, as well as the Federal Act on Financial Services ("FinSA") and the Federal Act on Financial Institutions ("FinIA"). The latter two, together with implementing Ordinances, entered into force on 1 January 2020, subject to two- to three-year transitional periods. Foreign providers that pursue their Swiss business on a cross-border basis only will now be subject to Swiss regulation and in an unusual wrinkle, client advisers from

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foreign financial service providers carrying out their activity in Switzerland have to be included on a register of advisers. This requirement applies to client advisers of foreign financial intermediaries providing cross-border investment services in or into Switzerland, unless targeting exclusively professional or institutional clients or acting solely on a reverse solicitation basis. Some Swiss training and competence standards will apply.

Staying with Switzerland, back in 2010 it was one of the first countries where the regulator made financial services institutions adopt a comprehensive and focussed approach to cross-border activity and this lead to the genesis of BRP Bizzozero & Partners, as we realised there was a market for cross-border material. Regulators in other countries are also now focussing more on such activity and Israel in particular has adopted a tough approach. The Bank of Israel wants local Israeli firms to, in particular, consider the provision of banking and investment services to EU residents and take into account EU regulation such as MiFID II, MiFIR and PRIIPS. Uruguay is another country where the regulator requires service providers to take measures to ensure compliance with applicable foreign laws and regulations when providing cross-border financial services out of Uruguay. Here in the UK the regulators have not been so explicit, but this could change.

China has been a market of interest for some UK firms. It amended its Securities Law at the end of 2019 to further regulate marketing of financial services and it is now clear that marketing financial products or services onsite in China requires prior licensing. The situation with respect to marketing from overseas into China is not so clear, but a cautious approach should be adopted.

The SFC in Hong Kong has taken action against local firms that have not complied with its standards when undertaking cross-border activities out of Hong Kong.

however, arrangements under the Foreign Related Corporations Framework which give those financial services groups with an entity in Singapore an option to offer services via group entities in Singapore.

UK firms should be aware that the same high standards set by the SFC for locally licensed entities can be reasonably expected to be applied to foreign banks, financial intermediaries and their employees undertaking cross-border activities in or into Hong Kong.

Overall the trend seems to be towards more restrictive practices and it is more important than ever to conduct a detailed informed country-specific analysis when considering new business outside the UK.

Another Asian country, Singapore, is generally taking a rather restrictive approach vis-Ă -vis cross-border financial services, implementing a territorial approach with a solicitation test. There are

Richard McGrand CEO BRP Bizzozero & Partners UK rmc@brpsa.com

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CYBERSECURITY IN A YEAR OF CRISIS T he emergence of new and disturbingly effective methods of cyberattack during the last 12 months demonstrate the ingenuity of the criminal gangs, and why your cyber risk controls may well no longer be secure. Methods of attack continue to evolve –so must our defences.

A doubling of opportunities for ransomware Ransomware can leave firms operationally crippled, waste senior management time, and seriously damage or even destroy client relationships.

Previously, the malware usually got into your system when someone clicked on a link, letting in the ransomware that automatically found data and files to encrypt. Now, criminals can automatically scan firewalls, looking for ports and vulnerabilities to gain access. And with so many people currently working remotely on poorly configured connections and devices, they are hitting the jackpot.

Worse still, the way the attack progresses has also changed.

Once you’ve been breached, the bad guys no longer just go straight to the encryption stage. They often take their time examining confidential client and proprietary data.

Then they steal the material they think will cause you maximum pain if it’s made public. Which gives them two ransom opportunities. First, they demand payment for the decryption key. Next, they threaten to release publicly, piece by piece, the confidential data they’ve stolen about you and your clients. Unless you pay up.

So, even perfectly configured backups (which we rarely see), will not protect you and your clients. No surprise, then, that amounts demanded as ransom, and the amounts actually being paid out, have shot up.

Multi factor faking Another development is how easily people can sign into and misuse your email account.

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A while ago, crooks would usually get hold of your email address and password via phishing attacks or by buying your credentials on the dark web. Then they could login, send and receive emails as if they were you, spy on your mail, steal information, divert payments and so on.

Office 365 Multi factor authentication (MFA) was designed to put a stop to this, preventing anyone else from logging into your account unless they had second factor authentication, usually a code sent by text to your mobile phone. But not anymore.

Lower ranking criminals, using the Raas model, function as ‘lead generators’, to earn a cut by passing on the opportunity to the big boys, who will be better able to fully exploit the financial blackmail potential of the breach.

2020 has seen new ways of getting around MFA. Notably, fraudsters can accurately mimic the 365 login page. So, you think you’re typing into Office 365, but in fact, it’s a fake cover page. Which automatically inputs your credentials into the real Office 365 page, except on the fraudster’s computer.

The cost of ignoring the problem

When the text with the code comes through to your mobile, you do the same. And the criminals have successfully logged in as you. Free to do what they want. And when they’ve enabled the optional 60-day validity period, they’ve given themselves 60 days’ access.

This is no surprise: the crippling business disruption, combined with the exfiltration of high value data (the ‘steal then encrypt’ model), results in criminals having much greater negotiating power over their victims, so that firms feel under greater pressure to give way to ransom demands to prevent confidential data from public release, even when system recovery from backups is possible.

The growth of the criminal ecosystem Of all the many routes there are to cyber attack businesses, the exponential growth of ransomware is arguably the most telling. So why the rapid growth? Well, it’s becoming more easily achievable. It can be hugely profitable. And the chances of criminals being brought to book are almost non-existent.

Attack tools are now freely available, as are low-cost Ransomware as a service (Raas) kits. So aspiring cyber crooks no longer need high levels of technical knowledge.

Affiliate ransomware platforms offering Raas provide easy market entry, and especially with more remote working, ample opportunity for good returns.

At the same time, there has been an increase in so called ‘big game hunting’, where more thoughtful, focussed attacking gangs closely examine the opportunities that successful breaches provide for financial gain, whether by theft of money or by high value ransom.

Research suggests that by Autumn 2020, the average ransom being paid was $233,000, rising sharply for larger organisations.

From the attacker’s business perspective, the ransomware to payment ‘conversion rate’ has gone up substantially, including for the smaller Raas players who are also now seeking higher ransom returns.

A market that’s here to stay Given the amounts of money involved, the sophistication of organised cybercrime gangs shouldn’t come as a shock.

These operators now have their own PR machines, with websites and press releases announcing breaches, naming names, and the theft of data – threatening to make it public, if ransoms aren’t paid.

This market has its own dynamics. Analysis shows that the ‘market share’ of different ransomware players and affiliate programmes has changed throughout the year. Big players

like Sodinokibi (aka REvil), Maze and Phobos saw their share of total attacks go down due to the incursion of smaller players and the emergence of new entrants to the market.

The critical concerns of the FCA A large proportion of all incidents reported to the FCA now relate to cyber-attacks, with disruption from cybersecurity incidents one of the biggest challenges to operational resilience. This is of increasing concern to the FCA. This is not just a technology issue. The biggest vulnerability lies in the day-to-day practices of people. So effective configuration of technology must be accompanied by proper training and effective policies and controls.

Firms should question their reliance on third party IT providers to provide security. Some firms are still not taking the right steps to test or audit their policies, processes and systems, which should be reviewed regularly, by someone independent.

Firms are expected to have appropriate cyber risk management in place and a “security culture” from the Board down. Ultimately, responsibility rests with the firm’s CEO/ Partners.

Lindsay Hill Chief Executive Mitigo https://www.pimfa.co.uk/firm/mitigo/ PIMFA Plus Partner PIMFA has partnered with select product and service providers to offer member firms a suite of membership enhancements. Find out more at www.pimfa.co.uk/ become-a-member/pimfa-plus-promo

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M&A TAKES CENTRE STAGE FOR UK ASSET AND WEALTH MANAGEMENT THE PANDEMIC: THRIVE OR SURVIVE

WHAT ARE THE CHALLENGES?

2020 has demonstrated the resilience and flexibility of the wealth management industry. Wealth managers were hit with new front office channel requirements, a distributed operational workforce, extreme market volatility and volumes all at the same time. The industry has proven more resilient in its move to a fully remote model than many predicted, but we have witnessed a divergence between those wealth managers who have thrived during the pandemic and those who are merely surviving it.

Margin pressures continue to intensify across the industry in a post-crisis world and the immediate revenue outlook looks more challenging. This is creating a more urgent need to differentiate, acquire capability and/or build scale.

Due to this divergence, M&A activity has remained strong across the UK with over 65 deals announced between January and September this year. Thriving firms are investing in technology, new capabilities (including ESG) and are capitalising on the opportunity to acquire smaller providers that are struggling with the expenditure required to compete. We expect these trends to accelerate as this year has demonstrated that new ways of working are effective and clients have embraced them.

A need to differentiate:

We have just experienced a ten-year bull run, the longest in history. This year, we have seen a loss of fee income from falling markets and a more uncertain short-tomedium term outlook. The next decade is likely to pose new challenges - firms will therefore need to be more nimble in devising strategies to deliver enhanced returns, diversify their earnings streams and/or invest in differentiated investment capability. We have already witnessed many managers acquiring or bringing in alternative asset or ESG expertise - we expect this trend to continue as firms look to drive returns in higher growth asset classes.

Digitising for the future:

The industry has been known for years as a digital technology laggard, with more talk than action. The pandemic has accelerated a focus on technology and in particular ensuring adequate digital channels of client communication. We have seen a huge uptick in Direct-toConsumer (D2C) investing in recent months and now expect managers to invest to ensure they have a digital proposition fit for the future. These capabilities can be bought from technology vendors, but also acquired through take over.

A need for scale:

The UK remains a highly fragmented market which we expect to consolidate further over the coming years as scale becomes ever more critical in an environment of continued margin erosion.

Achieving a critical mass of AuM is essential. Furthermore, many smaller providers are struggling with increasing regulatory pressures - this is creating a new flow of acquisition opportunities.

120 100 80

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The industry is littered with legacy systems, products, services and processes. There has never been a more important time to tackle these inefficiencies and invest to build a more streamlined and robust back / middle office infrastructure.

INVESTMENT IN TECHNOLOGY IS CRUCIAL For two decades the industry has been talking about making a move to digital adoption, while action has been relatively slow. The pandemic has forced overnight digital adoption, with wealth managers largely falling into two buckets, those who were ready to switch to a front-to-back digital model and those who were unable to do so.

Those firms who were able to move overnight to front to back digital operations were able to continue to prospect, onboard, service and retain clients while those in the second category turned internally to focus on keeping processes and procedures running, often neglecting the client relationship when those same clients were asking for the highest levels of service during extreme market volatility and uncertainty.

Number of non -disclosed deals

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The divergence between those who thrived and those who survived was not simply who was able to implement front office video conferencing with clients, but fundamentally down to the digital connection between client, front office and operations. For survivors, key areas of operational failure were evident in physical documentation requirements, reliance on the post and manual processing of transitions.

This divergence of experiences has led to the winners being able to take business from those firms that were struggling, with valuations of these firms a direct reflection of their performance during the period.

While the pandemic has had some immediate impacts on the use of technology and valuations, a longer term trend in wealth M&A has been a focus on the cost of replatforming.

The industry has several examples of failed and costly replatforming exercises. Simply put, it is the most complex, costly and time consuming activity a CIO and COO can undertake. As such it is something many firms try to avoid and delay until the legacy platform becomes too unstable, too costly to maintain and no longer suited to the business requirements. Replacement is inevitable.

Faced with such a high-risk and costly activity, we are seeing a number of firms choosing to combine with others, often to gain the benefit of superior technology where the time, effort and expenditure has already taken place. With contemporary technology platforms offering high Straight Through Processing rates, operational teams are smaller and do not need to scale alongside AUM. Running a combined business with twice the AUM, does not cost twice as much.

FUTURE OUTLOOK The pandemic is being seen as a catalyst for long-term, positive change within the asset and wealth industry, change that has been long overdue.

Uncertainty and volatility in markets are increasing the trend of margin pressure, one that the industry has been experiencing for many years. Building scale has never been more important. The current crisis is also likely to provide the kick-start the industry needs to invest in digitisation and to transform operating models.

We expect M&A to take centre stage as firms seek to modernise, build scale, acquire technology or new capability, and as business owners are able to secure value and security for the businesses they have grown, in a changing and more competitive landscape.

Rick Chana Director, M&A Lead Advisory, PWC I provide advice to clients on acquisitions, disposals and fund-raising and specialise in Asset & Wealth Management and Asset Servicing

A HIGHLY RESILIENT INDUSTRY The wealth industry has proved remarkably resilient through this pandemic. Whilst most managers have suffered a direct hit to earnings, markets have thus far rebounded well.

Businesses have a strong base of recurring revenues, tend to be cash generative and managers typically boast strong and capital light balance sheets.

The outlook for the industry is certainly positive, with strong demand for money to be well managed, particularly during more uncertain times. Pension reforms (including increases in direct contribution pensions), reduced buy-to-let activity and rising life expectancies are driving greater flows into the industry with individuals staying invested for longer.

The result of the above is considerable investment appetite for the industry from a large pool of external capital (over $1.7trn of private equity dry powder). We have seen nine private equity buy-outs within the industry over the past three years and a wave of recent PE-fuelled consolidation activity, particularly within wealth distribution (financial advice and wealth management). We expect this trend to continue for many years.

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Would you like to contribute an article?

Alongside updates from PIMFA, the Journal includes several useful inputs from our associate member firms. These articles are an excellent opportunity to gain interesting insights into the wider industry and to learn more about PIMFA associate members. If you are an associate member who is interested in contributing to future editions of the Journal then please contact: Richard Adler, Director of Strategic Partnerships (richarda@pimfa.co.uk) or Sheena Gillett, PR & Communications Director (sheenag@pimfa.co.uk)

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