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Funds Regulation:A brighter distribution future?
funds europe
IntroductionThree pending pieces of regulation canaffect fund managers and their business
OverviewIt’s time to brush up on the upcomingregulatory changes
UCITS IV DirectiveThis European directive aims to bringmore harmonisaton across the continent
AIFM DirectiveThe most controversial piece of legislationseeks to add a greater level of supervision
Retail Distribution ReviewA UK initiative that will increaseprotection for retail investors
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contents
For more informationPenelope Biggs, head of asset servicing
business development, [email protected]
+44 (0)20 7982 2200
Karen Hamilton, head of fundadministration product development
[email protected]+44 (0)20 7982 2234
northerntrust.com
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INTRO
An industry takes note: Three is the magic numberUndertakings for Collective Investment in Transferable Securities IVDirective, the Alternative Investment Fund Managers Directive and theUK’s Retail Distribution Review, are all pending pieces of legislationthat can affect a fund manager’s order of business.
If you did not know that institutions couldachieve a 50 basis points reduction in taxdrag by investing in a master feeder fundwhen the Undertakings for CollectiveInvestment in Transferable Securities(UCITS) IV Directive goes live, then it istime to brush up on regulation.Rarely, if ever, has the fund management
industry faced such a barrage of regulationas it does at present.The UCITS IV Directive looms over the
industry, as does that other European-wideproposal, the Alternative Investment FundManagers Directive (AIFM). Then, in theUK, there is also the Retail DistributionReview (RDR), which will affect manymanagers from Europe with business there.The number of major regulatory initiatives
affecting fund management firms – three –may seem small on the surface, but each ofthem is set to converge in the same year,2012. They affect a fund manager’s businessfrom the front office right through middle, to
the back. They even affect a fund manager’sexternal providers.These third-party investor service firms are
often looked to for thought-leadership orguidance on regulatory matters andNorthern Trust, a major asset servicer, herepresents a synthesis of these three regulatory
challenges and how fund managers shouldprepare for them.“We have a watching brief where we look
at all regulatory issues,” says KarenHamilton, head of fund administrationproduct development at Northern Trust.“Our clients’ businesses are being impactedby all three of these developments.”Each body of regulation cannot be looked
at in isolation, she says. “There are synergiesbetween the three although from aregulatory point of view they may not seemvery joined up.”And the rules affect more firms than they
may appear to at first glance. Do not forgetthat the AIFM Directive is not just abouthedge funds. As Hamilton says: “Any fundthat is not a UCITS fund is affected.”The Northern Trust guide describes
how these pieces of legislation willaffect them and discusses appropriateresponses. 2012 is not that far ahead, so anearly start is advised.
‘We have a watchingbrief where we look atall regulatory issues.
Our clients’ businessesare being impacted by
all three of thesedevelopments’
OVERVIEW
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Why change means opportunity
The European funds industry faces a barrageof new regulations over the next two years.Northern Trust explores three significantregulatory initiatives: The Undertakings forCollective Investment in Transferable Securities(UCITS) IV Directive, the UK’s RetailDistribution Review (RDR) and the EuropeanUnion’s Alternative Investment FundManagers (AIFM) Directive. The initiatives allhave one thing in common: they are all due toconverge throughout 2012 so investmentmanagers should be considering implicationson their business model.Although all three initiatives share similar
overriding goals – increased investorprotection, greater transparency and a moreharmonised European investment landscape –they each have their own means of reachingthese goals. They are all at different stages ofdevelopment; they all have different timetables;they have different industry drivers; and theywill impact different businesses in differentways depending on the distribution of andnature of their investments. “Investment
managers must understand the implication ofeach regulation, recognise the potentialopportunities that exist as well as overcome thesignificant challenges they present,” saysWilson Leech, head of Northern Trust’sGlobal Fund Services business.“The key opportunity for investment
managers will be an increased ease ofdistribution across Europe. Europe’s supervisorsare looking for ways to get more investorsinvesting in the markets and to keep theminvolved while providing a framework forimproved governance. The challenge for theregulators is to ascertain the appropriate levelof oversight so that the market becomes moreand not less efficient. The challenge forinvestment managers is understanding theimpact the regulations will have on theirbusiness and their investor base and theoverhead required to support and implementthese. Whether they are based in Europe, theUnited States or Asia-Pacific, these regulationsmay impact how they do business so they needto be prepared.”
‘Investment managersmust understand theimplication of each
regulation, recognise thepotential opportunities
that exist as well asovercome the significantchallenges they present’
Gerry Brady Karen Hamilton Wilson Leech Mark Schoen Revel Wood
The Directive comprises five keyelements:• The ability to create a master feeder fund• A simplified notification process (SNP)• The ability to merge cross-border funds• Simplification of the key investordocumentation (KID)• Passporting of a fund managementcompanyIn terms of the regulatory timetable forUCITS IV, the Committee of EuropeanSecurities Regulators (CESR) will be providingits advice to the EU Commission who will thenlook to adopt implementing measures by July2010. Member states will then be required toimplement the directive into national law byJuly 2011. Historically, it is at this stage – thehandover of the rulebook from the EuropeanUnion (EU) supervisors to individual statesupervisors – that inconsistencies can emergeand the threat of regulatory arbitrage mayloom large. For new funds it is clear that fromJuly 2011, the UCITS IV Directive will apply,however, clarity is still required on theconversion process and timeline for existingfunds. Regardless, investment managers shouldalready be looking at the Directive and thepotential opportunities and challenges itpresents for their business.
Ability to create a master feeder fundThe master feeder fund stands out as the mostsignificant opportunity under UCITS IV forinvestment managers. “For the first time underthe UCITS banner, managers will have theopportunity to rationalise and consolidate theirasset management activities. At the same timethis structure will facilitate their distributionstrategies by supporting a range of feeder fundsto meet different investor requirements,therefore the establishment of a master feeder
fund should be a key consideration for mostinvestment managers who distribute theirfunds cross-border,” says Karen Hamilton,head of fund administration productdevelopment, Northern Trust.The choice of vehicle for the master fund willbe a key decision. As a pioneer of cross-borderpooling for multinationals and investmentmanagers, Northern Trust has seen how theuse of the Irish Common Contractual Fund(CCF), the Luxembourg Fond Commun dePlacement (FCP) and the Dutch Fonds voorGemene Rekening (FGR) can not only providefund management consolidation but can alsomitigate the tax drag of investing in a fund witha heavy equities bias.The end result would be a win-win forinvestors and investment managers alike. “Byusing a tax-transparent structure the feederfunds would remain tax neutral and thereforeretail investors would continue to benefit fromtheir local tax regime. Institutional investorsinvesting directly into a master fund couldbenefit from a 20 to 50 basis point reduction intax drag. For example, a UK corporate pensionplan will eliminate 42 basis points in tax dragon its returns by investing in a tax-transparentCCF fund benchmarked to the MSCI World
Index, as opposed to the same investment viaan Irish Variable Capital Company (an opaquevehicle). This calculation is based on NorthernTrust’s experience applying withholding taxrates for investors under these two differentscenarios. Meanwhile investment managerswould enjoy economies of scale fromconsolidating their activities on a singleoperating model,” says Hamilton.The example in Figure 1 overleaf shows howthis may work in practice.Finalised level two guidelines due at the endof June will provide greater clarity around theimplementation of a master feeder fund, whichwill be essential for any fund managerconsidering this structure.The Directive sets out detailed rules inrelation to UCITS master feeder structuresthat are designed to ensure a consistentgovernance structure applies to both masterand feeder fund. This will involve additionallegal agreements between the master andfeeder fund as well as their depositaries andauditors. Additionally, it will be vital to ensurethe master feeder structures work on a day-to-day basis and there is consistency on matterssuch as:
• Pricing policy• Pricing error policy• Depositary notification, dealing andsettlement policy• Fund distributions and year-end process• Reporting required for all investors andwho is responsible: the master or thefeeder fund.
What is clear is that careful consideration andplanning will be required in order to maximisethe potential opportunities available through amaster feeder fund.
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UCITS IV
UCITS IV– a moreharmonised Europe?The UCITS brand has been a resounding success for Europe’s funds industry,particularly in its most recent guise. However, there is always room for improvementand UCITS IV aims to address the limitations of its predecessors and to take theprinciple of harmonisation further across the European landscape.
The master feeder fundstands out as the mostsignificant opportunity
under UCITS IV forinvestment managers
UCITS IV
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Simplified notification processThe aim of the SNP is to increaseharmonisation and reduce bureaucracy byintroducing a regulator-to-regulator processwhich will significantly reduce the time takento launch an existing fund in a new market.Once a UCITS fund is registered in one EUcountry it must be recognised as an authorisedfund in any other EU jurisdiction, therebyremoving any administrative obstacle to itbecoming active across different EU markets.“The SNP should facilitate pan-Europeandistribution by removing some of thesignificant local regulatory roadblocksencountered under UCITS III,” saysHamilton. Managers who have historicallyonly targeted their home market fordistribution may now consider branching outas it should be easier to launch into a newmarket, with the only true additionalrequirement being the production of the KID
in the local language. However, it remains to beseen if the initiative is as successful in practiceas it would seem to be in theory,” saysHamilton. “Europe is a continent with multiplecultures and we will have to wait and see ifthese cultures and their regulators cancooperate to the extent outlined in theserevised regulations. If they do then investmentmanagers may well find it considerably easierto distribute their funds into another Europeancountry.”
Ability to merge cross-border funds Although there is potential opportunity underUCITS IV for investment managers to mergetheir funds cross-border – with the aim ofmaking the funds industry more efficient andcost effective – the benefits are limited. Thereality is that UCITS IV brings with it moreregulation in terms of notifying investors andannouncing any mergers but without taking
into account the lack of tax harmonisation thatexists between the European communities.
Under current legislation an investmentmanager only has to notify the investors of thefunds that are to be merged to another fund,whereas under UCITS IV managers are alsorequired to notify the investors of the entityinto which those funds are being merged. Inthe majority of cases investment managers willbe merging to larger funds so there would bemany investors requiring notification. “Untilthe key issues are addressed then it is unlikelythat the fund merger procedures will result insignificantly fewer funds in Europe. In themeantime we are seeing many managersconduct a comprehensive funds review with aview to completing some mergers before theDirective is implemented in July 2012.Consequently there may be somerationalisation of funds in the next couple ofyears prior to implementation,” says Hamilton.
Simplification of the key investordocumentation The abridgement of the KID should be goodfor investors in that it enables them to comparelike-for-like investment opportunities through atransparent and standardised document. It hasto be produced in the local language of anymarket in which the fund is distributed andshould be easy to understand. According to theDirective, the document should be clear aboutthe fund’s strategy, its performance, thecharges, the risk appetite of the fund and anyother information which should be consideredkey.
However, by reducing the document to onlytwo pages, its success will depend on howinvestment managers use the limited space theyare given. Investors may find they need aglossary to understand the various terms usedas there may not be enough room to explainthem all. While it is clear that a 20 page KID istoo long, two pages may be too short.
Passporting of a fund managementcompany UCITS III achieved many positive things but itdid not deliver the ability to passport a fundmanagement company. UCITS IV aims toaddress this through its management companypassport which will give managers theopportunity to have one pan-EuropeanUCITS management company rather thanone in every jurisdiction. To truly capitalise onthis opportunity, investment managers willneed to take a number of steps. “They need to
In this example, the investment manager has three separate management companies inthe UK, Luxembourg and Ireland as well as an authorised corporate director in theUK. The fund range includes a UK open-ended investment company, UK unit trust,Irish unit trust and a Luxembourg Société d'Investissement à Capital Variable (SICAV).Under UCITS IV, the manager could rationalise the fund range into a master feederstructure and also consolidate the three current management companies into one. Thechoice of jurisdiction for the single management company will be dependent on anumber of factors: tax is the main consideration, however, location of the assetmanagement head office, the domicile of the master fund, and the working relationshipwith the local market regulator will all have to be taken into account.
FIGURE 1: Example master feeder fund structure
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carefully consider the tax and businessimplications of such a move and undertakedetailed analysis of their fund range,jurisdictions, distribution channels and locationof investors,” says Hamilton. “Managers alsoneed to understand that the additionalgovernance requirements laid out underUCITS IV will apply to all fund managementcompanies, including self-managed funds andnot just those that are looking to avail of thecross-border opportunities.”
Overall, there are lots of opportunitiespresented by UCITS IV but the twomandatory elements are the implementationof the KID and the adoption of the additionalgovernance rules regarding the managementcompany passport.
What will be the funds domicile ofchoice?One implication of UCITS IV is the potentialconsolidation of funds and their administratorto one jurisdiction. Ireland and Luxembourgwill be the two most active jurisdictions butone cannot discount markets with stronginvestment management such as France,Germany and the UK.“The low tax fund domiciles such as Maltamay also have some appeal but I expect that itwill be the more established markets that willdominate because clients will want to alignthemselves with strong regulatory regimes firstand foremost,” says Hamilton. “We’re alreadyseeing a strong trend of funds re-domiciling tomore regulated onshore environments anduntil this trend stops it will prove highlychallenging for domiciles like Malta tocompete with more regulated centres. Overall,
this development is to be welcomed byinvestors as different jurisdictions compete fortheir business. From a Northern Trustperspective we are looking to support ourclients in making these kinds of decisions. Wehave extensive experience in the major fundmarkets and proven expertise and robustprocesses in supporting pooled vehiclestructures.”According to Gerry Brady, managingdirector, Northern Trust Ireland, any fundscentre in Europe could become the domicile ofchoice for UCITS funds but such is thegroundswell that has built up in Ireland andLuxembourg over the last few years that it isdifficult to imagine the likes of the UK orFrance becoming more dominant. “In Irelandand Luxembourg there is already the politicalwill and much simpler economies making iteasier to present a more accommodating taxregime for fund promoters and serviceproviders, as well as investors.”Brady refers to the recent clarificationcontained in the Irish Finance Act, 2010 whichconfirmed that non-Irish resident funds thatare managed by an Irish managementcompany will not be deemed to be tax residentin Ireland. “This clarity is helpful and showsIreland’s appetite to position itself as adomicile of choice for UCITS IV master fundsand their management companies. And if wecontinue to have the Finance Minister, BrianLenihan making positive statements andbuilding partnerships between governmentand business, then I think Ireland can do verywell in the UCITS IV market given its strongregulatory regimes with a proven track recordand well developed financial servicesinfrastructure.”It is a similar tale in Luxembourg accordingto Revel Wood, head of client service andbusiness development, Northern TrustLuxembourg. “The Association of theLuxembourg Fund Industry (ALFI) has beenheavily involved in the formation of UCITSIV and has been very active in the consultationprocess. There has also been significant inputfrom local accounting and law firms in advisinginvestment managers on what they should bedoing in preparation for UCITS IV.”In concurrence with his Ireland counterpart,Wood believes that Luxembourg and Irelandwill continue to prosper under UCITS IV dueto the well established infrastructure in thesejurisdictions. “These jurisdictions complementeach other: Ireland tends to cater for theAnglo-Saxon managers, while Luxembourg
remains attractive to managers looking todistribute across mainland Europe and Asia,owing to the multilingual capabilities andcentral location in Europe. Luxembourg willremain an attractive location in the longerterm as it has a stable and business-friendlypolitical environment, combined with aneconomy heavily reliant on the funds industry.The industry associations like ALFI work veryclosely with the Commission de Surveillancedu Secteur Financier and business leadersallowing the industry to adapt quickly to thechanging regulation and needs of managers, asevidenced by the success of the introduction ofthe Specialised Investment Funds law foralternative funds.”The competition between Ireland andLuxembourg need not mean one domicilesucceeds at the expense of the other, accordingto Brady – therefore the important issue forservice providers is that they continue to offera credible support service in both Luxembourgand Ireland. “I don’t think it will be a straightforward win or lose situation with wholesalemigration of business to one or other of thetwo jurisdictions. And I think the end-investorsare not too concerned with what goes onbehind the scenes as long as they receive theright quality of service, get value for moneyand can speak to someone knowledgeable intheir domicile of choice when they need to.Therefore it is important that there is acredible and knowledgeable presence in all ofthe feeder jurisdictions.”For every investment manager the potentialimpact of UCITS IV is different and onlytime will tell whether the Directive trulyachieves its goals of a genuinely open pan-European market. However, depending ontheir business, managers also need to assess theimpact of and opportunities presented by theAIFM Directive as well as the RetailDistribution Review in the UK.
Other key considerations forinvestment managers include:• The cost of such a move• Whether to merge existing UCITSmanagement companies into one or toset up a new pan-Europeanmanagement company• Which jurisdictions would best suittheir existing distribution and investorbase• What their existing relationship is likewith their proposed home regulator• How they will address the increasedgovernance requirements, for examplethe Markets in Financial InstrumentsDirective (MiFID) rules and thecompliance function
The low tax funddomiciles such as Malta
may also have someappeal but I expect that
it will be the moreestablished markets that
will dominate
AIFM DIRECTIVE
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The Alternative Investment FundManagers Directive – a greater level ofEU supervision
The AIFM Directive isthe newest piece oflegislation facing thefunds industry and isperhaps the mostcontroversial.
The AIFM Directive was drafted by the EU inresponse to a series of high-profile scandals,including Lehman Brothers and Madoff andaims to provide a framework for directregulation and supervision of the alternativefund industry. The political nature of theDirective’s origin creates a challenge forEurope’s supervisors – they must be seen to beresponding to recent, highly publicevents but any Directive that emerges must alsobe practical and implementable for marketparticipants.According to some of the Directive’s critics,
the whole project resembles a bar-room brawl inthat the people being hit are not necessarily theones who started the fight, or even threw the lastpunch. They say the legislation has been rushedthrough in an emotionally and politicallycharged atmosphere and this kind of approachtends to polarise opinions, particularly betweendifferent regions. Although there are aspects ofthe draft Directive that have been welcomed bythe alternatives industry, there are some keyareas where the industry is still seeking greaterclarification.
Depositary requirementsThe first of these concerns is the depositaryrequirements. The AIFMDirective significantlyincreases the scope and potential magnitude ofthe depositary’s liability in respect to a fund,particularly in relation to its sub-custodians.This creates a substantial systemic risk in thecase of sub-custodian failure. The additionalliability will also increase the depositary’s costs,which would have to be passed onto investmentmanagers and investors. The industry has
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suggested that a better approach would be tomake the AIFM Directive depositary rulesconsistent with existing UCITS rules.
ValuationValuation is another area where overlap existsbetween UCITS and the AIFM draft Directive.The valuation function should be segregatedfrom the investment management function toensure independence and may be delegated bythe alternative investment manager to anadministrator for example, in line with theAlternative Investment ManagementAssociation’s recommendations on best practice.Critics argue that one of the major failings of
the AIFM Directive is that it does not recognisethe existence and responsibility of the board ofdirectors for alternative investment funds (AIFs).The Directive seems to have been drafted on thepremise that all AIFs are quasi-managedaccounts where the investment manager is allpowerful. In the majority of cases it is thedirectors who have responsibility for makingsure a valuation policy is in place. To assign thisresponsibility to an undefined third-party – thevaluator – assumed to be the administrator inpractice, and to place unlimited liability with theadministrator for this new responsibility isclearly questionable.
Delegation and marketingpassport/private placementFurther clarification is also required on thedelegation of activities. The Commission hasproposed that portfolio management and riskmanagement can only be delegated to anotherAIF manager and sub-delegation should beprohibited. Although some of the newersuggestions appear to improve the originalproposal, this area remains unclear. This is asimilar situation to the area of marketingpassport/private placement where, despitesignificant progress greater clarity is stillrequired concerning scope and governance.The latest draft of the Directive was circulated
in March with Spain, the current holder of theEU’s rotating presidency, pushing for aresolution before the end of its term at the endof June. During this period the EU CouncilWorking Group and the Spanish presidency arecontinuing to meet and liaise with theParliament’s rapportuer to establish agreementon the Parliament text. A trialogue phasebetween the Commission, Parliament andCouncil is set to take place between May andJune with a possible plenary vote and adoptionto take place in July.
“Northern Trust has studied the draftproposal in depth and is closely monitoring anyfurther developments and their implications forthe market and its participants. This includesparticipating in a number of industry workinggroups such as the Association of GlobalCustodians, the Irish Funds IndustryAssociation, the European Fund ManagementAssociation and the Alternative InvestmentFund Managers Association,” says MarkSchoen, head of product development EMEAat Northern Trust.The immediate reaction to the Directive from
the alternatives world was that hedge fundscould be forced to operate from outside ofthe EU to either off-shore domiciles orSwitzerland. However, given the current trendof hedge funds to seek greater and moretransparent regulation and the potentialoverlap between the draft Directive and theUCITS model, there could be an even greatertake-up of the UCITS funds structure byalternative managers.This could mean yet more business for
Luxembourg and Ireland as well as an increasein convergence, says Schoen. “We are alreadyseeing AIF managers hedging their bets andsetting up products in EU domiciles in thewake of the proposed legislation. Quite rightlythere has been a lot of focus on the productrange which can be accommodated within aUCITS III wrapper (which also takes the fundout of the AIFM Directive) but Northern Trustis also working with clients on non-UCITSproducts available in the EU regulatedjurisdictions such as Ireland’s QualifiedInvestment Fund which can be authorisedquickly and for which investment andborrowing constraints do not apply. In generalI think greater convergence will be good for themarket in terms of relative comfort forinvestors but I also think it will restrict returns.Long/short funds and event-driveninvestments and convertible arbitrage can all fitinto a UCITS structure. But there will still bethose strategies and asset classes that do not fitinto a UCITS structure and require a lot ofleverage. So that is a challenge for theregulators and the market – to accommodateboth ends of the alternative funds spectrum.”As for Northern Trust’s clients, Schoen says,
“We are advising them to keep their eyesand ears open, to stay close to theircustodians/administrators and industryassociations and to not make any sweepingchanges until it is clear what the Directivewill entail.”
Critics argue that one ofthe major failings of theAIFM Directive is that it
does not recognise theexistence and
responsibility ofthe board of directors
for alternativeinvestment funds
RETAIL DISTRIBUTION REVIEW
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The Retail Distribution Review –providing investor transparency on chargesThe RDR is a regulatory initiative limited to the UK marketand designed to add further protection for retail investors.
Despite being focused on the UK, theRDR will nevertheless affect any fund that isdistributed in the UK to retail investors socompliance will stretch beyond the UKborders in many cases. Furthermore, the EUhas commenced a study – the PackagedRetail Investment Products – the findingsfrom which may lead them to introducesimilar legislation in other Europeanmarkets. Investment managers should
therefore keenly watch any developmentson the RDR even if it does not directlyimpact them today.The main goal of the RDR is to help
ensure that UK retail investors are givengood and proper advice at all times and tomitigate the effect of uninformed orunscrupulous independent financial advisers(IFAs). The RDR will demand moretransparency around what consumers are
Investment managersshould keenly watch anydevelopments on the
RDR even if it does notdirectly impact them
9
paying for – the servicing or the expertise –and look to answer queries such as why someIFAs receive regular commissions withoutproviding regular advice.
From the investment managers’perspective, the main issue is how retailinvestors will now pay for their services andthe likely change from regular commissionsto a flat fee. The need for more transparencyaround fees may also impact the distributionchain. Potential investors will have to pay anup-front fee for their advisory services butthis may not be possible or desirable formany retail investors, particularly if theycannot be convinced that they are going toreceive better service and a good return,even if the process does become moretransparent. This may see distributorstargeting high net worth individuals, possiblyat the expense of the more modest investors.The rules are due to come into force in 2012but greater clarification is still required. On26 March 2010 the FSA issued a furtherconsultation paper 10/6 which the industryis gradually digesting. The paper reveals thatthe FSA has gone ahead with its proposalsrequiring firms to describe their adviceservices as either “independent” or“restricted” to improve clarity for consumerson advisory services. In particular the FSAhas extended the range of products to whichits rules apply so that firms providingindependent advice will be expected toconduct a detailed and fair analysis of thebroader range of retail investment products.In addition, they have also looked at thepotential for remuneration bias so that underthe new rules, adviser firms will no longer beable to receive commissions set by productproviders in return for recommending theirproducts. Instead they will have to operatetheir own charging tariffs. In the event thatthey wish to do so, providers will be able tofacilitate the collection of adviser chargesthrough the product on a matched basis. TheFSA has also made some changes to its rulesand guidance on the inducements, to reflectthe introduction of adviser charging and toensure that it cannot be circumvented byfirms being paid through “soft commissions”.
Despite these developments, there is stillmuch uncertainty as to how the RDR willwork in practice, says Hamilton. “In terms ofopportunities much will depend on theoutcome of the ongoing consultation withthe industry and feedback statement from theFSA which is due in the 3rd quarter 2010.”
Looking forward to 2012The next 18 months promise to be highlychallenging and preparation will be vital forinvestment managers worldwide.
“At Northern Trust many of our clientsviewed 2009 as the year of survival whereas2010 and beyond is very much aboutopportunity,” says Leech. “We believe that ourglobal operating platform allied with our multi-jurisdictional expertise means we are wellpositioned to help our clients navigate thesechanges and to help them capitalise on theincreased ease of distribution, increased
investor protection and greater transparencyacross Europe.”
There is still a lack of clarity around some ofthe uncompleted regulatory drafts, making itdifficult for investment managers tounderstand how their business will be impactedand put a strategic plan in place. What will becritical to their success is working with apartner that can help them achieve this – andmore importantly working with a partner thathas the expertise and solutions to enable themto capitalise on the significant growthopportunities in store.
‘At Northern Trustmany of our
clients viewed2009 as the year
of survivalwhereas 2010 and
beyond is verymuch aboutopportunity’
10-11 RDRts:Layout 1 7/5/10 15:59 Page 9
For more informationPenelope Biggs, head of asset servicing business development, EMEA
[email protected] +44 (0)20 7982 2200
Karen Hamilton, head of fund administration product [email protected] +44 (0)20 7982 2234
northerntrust.com
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