FYI - another IA/ joint industry working group guidance document for SDR Consumer Facing disclosures published yesterday in conjunction with Eversheds Sutherland - see IA SDR landing page / link to guidance
Regards
J
Following the FCA's statement in PS23/16 that it 'encourage(s) development of an industry-led template and industry collaboration on best practice' in relation to the SDR consumer-facing disclosure (CFD) requirements, the IA established a cross-trade working group to produce guidance and associated frameworks that firms can use when implementing the FCA's CFD rules.
This guidance - produced jointly by the IA, Eversheds Sutherland, UKSIF, AIC, the UK Depositary Association, PIMFA, TISA, and the ABI - has been developed to encourage more consistent disclosure between firms, improved comparability between products and better consumer understanding.
Original Message:
Sent: 5/10/2024 8:17:00 AM
From: James Doyle
Subject: RE: SDR implementation
All fyi - excellent joint guidance issued by Eversheds Sutherland and the Investment Association yesterday on Q&A SDR Implementation Guidance v1.0 - will be updated in future for additional clarification, insights, For now, a great source of practical guidance and clarification around some of the thorny practical implementation challenges most of us are busy trying to address ...
https://www.linkedin.com/posts/es-financial-services_ia-eversheds-sutherland-sdr-implementation-activity-7194366979732869122-MdvI?utm_source=share&utm_medium=member_desktop
enjoy
James
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James Doyle
Director, Green Finance, Investment Management
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Original Message:
Sent: 17-01-2024 16:36
From: David Manuel
Subject: SDR implementation
There should be a best practice checklist. The difficulty is picking the height of the bar for defining sustainable then making the disclosure transparent and understandable as a product communication. This should all tie back to the investment process and how "sustainability" is assessed. If the process can be explained clearly and authenticity it matters. There seems a lot of flexibility in practice so I hope FCA might give more guidance or case studies then look to do some spot checks with marked homework perhaps redacted a bit to demonstrate what they expect before using fines to enforce standards.
How acceptable is it to subcontract the scoring to a third party? either entirely or on a quality assurance basis.
David
Original Message:
Sent: 1/16/2024 5:09:00 AM
From: William Goodhart
Subject: RE: SDR implementation
Thanks James. That is a really good resource, with good signposting to the different measures that firms in different market sectors should take. I guess what I'm wondering about is where they say things like 'firms should prepare...', 'firms should decide...', what's the best way to do that? What should be on a preparation checklist? What should be in a decision-making framework? It would be great to either direct our members to info on that or perhaps to come up with some ideas following a virtual roundtable. Is that something that the community would find useful?
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William Goodhart
Chief Executive
Original Message:
Sent: 16-01-2024 09:07
From: James Peel
Subject: SDR implementation
Hello Will,
I would highlight this excellent summary from ESG Accord:
https://www.linkedin.com/posts/elly-dowding_esg-accord-ps2316-review-activity-7141384989266382849-29M6/
More than happy to help out here by providing some thoughts from a DFM's perspective too.
Best,
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James Peel
Portfolio Manager
Original Message:
Sent: 15-01-2024 09:39
From: William Goodhart
Subject: SDR implementation
Thanks Francesca. I think there probably are a large number of implementation challenges. I think it would be helpful first to get our heads around what's on that list and then to see if we can provide some proposed good practices on a number of the challenges that might be more common to our members.
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William Goodhart
Chief Executive
Original Message:
Sent: 12-01-2024 11:07
From: Francesca Wheble
Subject: SDR implementation
Hi William,
I think this would be a great idea.
I know working in an Asset Management Firm myself we are currently tackling both what Labels to assign our funds, and overcoming the first hurdle of the anti-greenwashing rule coming into play in May.
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Francesca Wheble
Responsible Investment Analyst
Original Message:
Sent: 11-01-2024 10:38
From: William Goodhart
Subject: SDR implementation
Sorry to bother the group, but I was just wondering if anyone has seen work/research looking at the implications of implementing the new SDR rules? Might it be helpful for us to draw a group together for an online discussion about some of the technicalities of that? Perhaps we could try to draw up a checklist for members (or even better to circulate someone else's if it's thought to be good/comprehensive). Thanks, Will
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William Goodhart
Chief Executive
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