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

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.

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

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. 

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.

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

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,

------------------------------
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. 

------------------------------
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.

------------------------------
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

------------------------------
William Goodhart
Chief Executive
------------------------------

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,

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. 

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.

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

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?

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,

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. 

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.

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

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?

------------------------------
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,

------------------------------
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. 

------------------------------
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.

------------------------------
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

------------------------------
William Goodhart
Chief Executive
------------------------------

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

------------------------------
James Doyle
Director, Green Finance, Investment Management
------------------------------

Original Message:
Sent: 17-01-2024 16:36
From: David Manuel
Subject: SDR implementation

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?

------------------------------
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,

------------------------------
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. 

------------------------------
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.

------------------------------
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

------------------------------
William Goodhart
Chief Executive
------------------------------

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 

https://www.theia.org/campaigns/sustainability-and-responsible-investment/sustainability-disclosure-requirements

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.

https://www.theia.org/sites/default/files/2024-05/Cross-trade%20WG%20Guidance%20on%20SDR%20CFD%20-%20May%202024.pdf

Sent from Outlook for iOS

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

------------------------------
James Doyle
Director, Green Finance, Investment Management

Original Message:
Sent: 17-01-2024 16:36
From: David Manuel
Subject: SDR implementation

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?

------------------------------
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,

------------------------------
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. 

------------------------------
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.

------------------------------
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

------------------------------
William Goodhart
Chief Executive
------------------------------

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?

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,

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. 

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.

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

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,

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. 

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.

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

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. 

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.

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

Hi William,

Where to start...

The first part of the regulation currently comes into play in May, the Anti Greenwashing Rule. Whilst we await the consultation to close, with a response to then be written, we are starting to think about how we will meet the Rule.

From compliance checklists, to creating evidence documents...there is not currently a right or wrong way to meet this.

I guess another burning question is...what funds will be assigned what labels. A Morningstar paper stated that roughly 8% of all UK domiciled funds will be assigned a label (roughly 300 funds). Will we have the same situation where funds will re-assign labels like the SFDR Article 8 and 9.

We then have those funds that require the 'non-label' designation, and then all the reporting to do.

There is a lot to work on, however I guess the first step is working out what the Anti-Greenwashing Rule entails and what we need to do to meet the regulation!

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. 

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.

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

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

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

Good morning everyone.

Very excited to see you tomorrow, 1 - 1:45 pm UK time, online for our SDR Implementation round table. @William Goodhart will be hosting and we have invited speakers from KPMG.

You can still book your free place today using this link.

For those who have booked, the zoom link will be sent to you by my colleagues tomorrow morning.

Thank you and see you there.

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

Good morning everyone.

Very excited to see you tomorrow, 1 - 1:45 pm UK time, online for our SDR Implementation round table. @William Goodhart will be hosting and we have invited speakers from KPMG.

You can still book your free place today using this link.

For those who have booked, the zoom link will be sent to you by my colleagues tomorrow morning.

Thank you and see you there.

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

Hey Aya, Just wanted to check if the zoom links have been sent out? I registered for the event last week but haven't received any link yet. Is there anyway you could send me the link privately? Thanks!

Good morning everyone.

Very excited to see you tomorrow, 1 - 1:45 pm UK time, online for our SDR Implementation round table. @William Goodhart will be hosting and we have invited speakers from KPMG.

You can still book your free place today using this link.

For those who have booked, the zoom link will be sent to you by my colleagues tomorrow morning.

Thank you and see you there.

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

Hi everyone. I wanted to share what we see in the press today about how UK managers are racing to apply SDR Lables. Here's a snap shot:

Financial Times:  In brief, asset managers are actively preparing for SDR implementation by:

• reviewing their communications
• adjusting products to meet criteria
• collaborating with advisers

Luke Murray from Bovill says that managers that use sustainablity language but do not offer sustainability products are now applying rigour to how they communicate to clients through materials on their website for example. Asset managers, according to Luke, are going through the qualifying criteria for labels to ensure their funds meet the requirements. This has taken the form of a mapping exercise to go throught he areas of the criteria, to see where the gaps are in meeting the label.

Stuart Burnside, head of product governance and ESG product at M&G Investments mentions 13 ESG-associated UK funds offered to retail investors by M&G where the SDR and labels regime would be applicable. Out of those 13 funds, 10 are esesntially parallesl to SFDR article 9 funds. They are already quite "dark green". 

Shroder's spokeperson says that they have developed infrastructure and technology to monitor engagement activity, which they believe will help ensure meeting the SDR requirements.

more information here 

Hey Aya, Just wanted to check if the zoom links have been sent out? I registered for the event last week but haven't received any link yet. Is there anyway you could send me the link privately? Thanks!

Good morning everyone.

Very excited to see you tomorrow, 1 - 1:45 pm UK time, online for our SDR Implementation round table. @William Goodhart will be hosting and we have invited speakers from KPMG.

You can still book your free place today using this link.

For those who have booked, the zoom link will be sent to you by my colleagues tomorrow morning.

Thank you and see you there.

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

Good morning community.

There is a lot of regulation and updates these days. Many agree that with the UK Sustainable Disclosure Requirements (SDR) and investment labels, the FCA has taken on board much of the feedback from the industry. Many feel optimistic that SDR may not be as big of a minefield as the EU's Sustainable Finance Disclosure Regulation (SFDR).

Here's the brief overview of UK SDR from Novata with a nice summary 

FCA's own summary and timelines are here

What do you think - do you feel optimistic? What are your main challenges that you are foreseeing? Can other members help?

Hi everyone. I wanted to share what we see in the press today about how UK managers are racing to apply SDR Lables. Here's a snap shot:

Financial Times:  In brief, asset managers are actively preparing for SDR implementation by:

• reviewing their communications
• adjusting products to meet criteria
• collaborating with advisers

Luke Murray from Bovill says that managers that use sustainablity language but do not offer sustainability products are now applying rigour to how they communicate to clients through materials on their website for example. Asset managers, according to Luke, are going through the qualifying criteria for labels to ensure their funds meet the requirements. This has taken the form of a mapping exercise to go throught he areas of the criteria, to see where the gaps are in meeting the label.

Stuart Burnside, head of product governance and ESG product at M&G Investments mentions 13 ESG-associated UK funds offered to retail investors by M&G where the SDR and labels regime would be applicable. Out of those 13 funds, 10 are esesntially parallesl to SFDR article 9 funds. They are already quite "dark green". 

Shroder's spokeperson says that they have developed infrastructure and technology to monitor engagement activity, which they believe will help ensure meeting the SDR requirements.

more information here 

Hey Aya, Just wanted to check if the zoom links have been sent out? I registered for the event last week but haven't received any link yet. Is there anyway you could send me the link privately? Thanks!

Good morning everyone.

Very excited to see you tomorrow, 1 - 1:45 pm UK time, online for our SDR Implementation round table. @William Goodhart will be hosting and we have invited speakers from KPMG.

You can still book your free place today using this link.

For those who have booked, the zoom link will be sent to you by my colleagues tomorrow morning.

Thank you and see you there.

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

Thanks Aya - i feel optimistic in that the FCA has actively engaged and listened to feedback from firms in its consultation process and will continue to - as noted in recent Sustainability Advisors group announced a few weeks ago, supported by PIMFA as Secretariat.

Immediate challenges are around covering off the requirements to address the new Anti-greenwashing rule from 31 May  - there's a lot of practical considerations and the scope is broad, applying to all communications where sustainability claims or terms are used in conjunction with promotion of FCA regulated investment products and services.  The FCA's draft guidance and consultation on anti-greenwashing outlines some examples of what they see are principles to be applied (now closed end Jan) so will be interesting to see what further examples of good/poor practice and clarifications when the FCA issues its finalised guidance - there are a number of areas that need further clarification and use of sustainability related terms/further examples e.g. when discussing at entity level, use of images, positive examples of language that is acceptable and not misleading etc e.g. see PIMFA's response as an example of one of the many industry bodies that have responded.  

Good morning community.

There is a lot of regulation and updates these days. Many agree that with the UK Sustainable Disclosure Requirements (SDR) and investment labels, the FCA has taken on board much of the feedback from the industry. Many feel optimistic that SDR may not be as big of a minefield as the EU's Sustainable Finance Disclosure Regulation (SFDR).

Here's the brief overview of UK SDR from Novata with a nice summary 

FCA's own summary and timelines are here

What do you think - do you feel optimistic? What are your main challenges that you are foreseeing? Can other members help?

Hi everyone. I wanted to share what we see in the press today about how UK managers are racing to apply SDR Lables. Here's a snap shot:

Financial Times:  In brief, asset managers are actively preparing for SDR implementation by:

• reviewing their communications
• adjusting products to meet criteria
• collaborating with advisers

Luke Murray from Bovill says that managers that use sustainablity language but do not offer sustainability products are now applying rigour to how they communicate to clients through materials on their website for example. Asset managers, according to Luke, are going through the qualifying criteria for labels to ensure their funds meet the requirements. This has taken the form of a mapping exercise to go throught he areas of the criteria, to see where the gaps are in meeting the label.

Stuart Burnside, head of product governance and ESG product at M&G Investments mentions 13 ESG-associated UK funds offered to retail investors by M&G where the SDR and labels regime would be applicable. Out of those 13 funds, 10 are esesntially parallesl to SFDR article 9 funds. They are already quite "dark green". 

Shroder's spokeperson says that they have developed infrastructure and technology to monitor engagement activity, which they believe will help ensure meeting the SDR requirements.

more information here 

Hey Aya, Just wanted to check if the zoom links have been sent out? I registered for the event last week but haven't received any link yet. Is there anyway you could send me the link privately? Thanks!

Good morning everyone.

Very excited to see you tomorrow, 1 - 1:45 pm UK time, online for our SDR Implementation round table. @William Goodhart will be hosting and we have invited speakers from KPMG.

You can still book your free place today using this link.

For those who have booked, the zoom link will be sent to you by my colleagues tomorrow morning.

Thank you and see you there.

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

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

------------------------------
William Goodhart
Chief Executive
------------------------------

All

for those who have been tracking SDR implementation - the FCA's consultation CP 24/8 on extension of SDR to Portfolio Management services closed last week. 

I know a number of members who have been actively involved in various trade body industry responses (see IA, PIMFA, UKSIF below) and roundtables with the FCA as well as putting together our own respective firm's responses.   General industry consensus is overall support for the extension to Model Portfolio Management services and centralised investment propositions but a delay requested for implementation by 12 months from publication final rules.  Less support given for the extension and application  to bespoke portfolio/customised portfolio management services for discretionary wealth managers (at least should be out of scope for now.) Lessons can also to be learned from the implementation of labels/non-labelled requirements for UK authorised funds first. 

Here's a summary of PIMFA's response to the consultation highlighting the significant practical and technical implementation challenges, but also suggestions for consideration in the final rules to make the regulation fit portfolio services (as opposed to direct read across from funds as products): 
PIMFA calls for a year delay to SDR portfolio management rules (investmentweek.co.uk)

PIMFA has responded to the FCA Consultation Paper 24/8: Extending SDR to Portfolio Management. While we are supportive of the intended purpose and spirit of the proposals contained in the consultation, we consider that they fail to sufficiently take account of the unique requirements of the market for portfolio management and of retail investors and consider the following to be critical for our sector and the success of the policy more broadly:

• Delay the implementation of the SDR rules for portfolio management by 12 months after the publication of final rules.
• Allow for the implementation of the SDR rules for funds before extending the regime to portfolio management.
• Reconsider including bespoke portfolios in the SDR regime as they are not products but services.
• Consider lowering the 70% threshold for labels to avoid any unintended consequence of portfolio managers building less diversified portfolios to meet the proposed threshold.
• Provide more clarity around the inclusion of overseas funds as they are currently out of scope of the SDR regime and the role of portfolio managers when including them in portfolios.
• Include in the final rules a carve out that addresses the retail client requirement for non-labelled responsible investments which seem to lack a 'home' under the current proposals.

Read the full response here.

See also   UKSIF response: CP24/8 Extending the Sustainability Disclosure Requirements regime to portfolio management – UKSIF

Plus the Investment Associations final response: Final - IA response - FCA CP on extending SDR to PMS.pdf (theia.org)

------------------------------
James Doyle
Director, Green Finance, Investment Management

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

------------------------------
William Goodhart
Chief Executive
------------------------------

Hi Community,

What does this mean for the industry? Keen to hear your thoughts!

FCA: Extending the SDR regime to Portfolio Management

The Financial Conduct Authority (FCA) has published Consultation Paper CP24/8, proposing to extend the Sustainability Disclosure Requirements (SDR) and investment labels regime to portfolio management services. This initiative aims to enhance transparency and consistency in sustainability-related disclosures across various investment products and services.​

Key Proposals:

• Application of SDR and Labels: The FCA proposes that portfolio managers offering model portfolios, bespoke discretionary mandates, or other portfolio services to retail clients should adhere to the same SDR and labelling requirements as those applicable to investment funds.​

• Sustainability Labels: Firms would need to classify their portfolios under specific sustainability labels, such as 'Sustainable Focus', 'Sustainable Improvers', or 'Sustainable Impact', based on the portfolios' objectives and underlying assets.​

• Disclosure Requirements: Portfolio managers would be required to provide clear and comparable disclosures regarding the sustainability characteristics of their portfolios, including information on objectives, investment strategies, and performance metrics.​

• Anti-Greenwashing Measures: The proposals include measures to prevent misleading sustainability claims, ensuring that marketing materials and communications accurately reflect the sustainability attributes of the portfolios.​

Implementation Timeline:

The FCA is seeking feedback on these proposals, with the consultation period open until 14 June 2024. Subject to the consultation outcomes, the FCA plans to finalise the rules and guidance later in the year, with implementation expected in 2025.​

For more detailed information and to participate in the consultation, please refer to the full consultation paper: CP24/8: Extending the SDR regime to Portfolio Management.

All

for those who have been tracking SDR implementation - the FCA's consultation CP 24/8 on extension of SDR to Portfolio Management services closed last week. 

I know a number of members who have been actively involved in various trade body industry responses (see IA, PIMFA, UKSIF below) and roundtables with the FCA as well as putting together our own respective firm's responses.   General industry consensus is overall support for the extension to Model Portfolio Management services and centralised investment propositions but a delay requested for implementation by 12 months from publication final rules.  Less support given for the extension and application  to bespoke portfolio/customised portfolio management services for discretionary wealth managers (at least should be out of scope for now.) Lessons can also to be learned from the implementation of labels/non-labelled requirements for UK authorised funds first. 

Here's a summary of PIMFA's response to the consultation highlighting the significant practical and technical implementation challenges, but also suggestions for consideration in the final rules to make the regulation fit portfolio services (as opposed to direct read across from funds as products): 
PIMFA calls for a year delay to SDR portfolio management rules (investmentweek.co.uk)

PIMFA has responded to the FCA Consultation Paper 24/8: Extending SDR to Portfolio Management. While we are supportive of the intended purpose and spirit of the proposals contained in the consultation, we consider that they fail to sufficiently take account of the unique requirements of the market for portfolio management and of retail investors and consider the following to be critical for our sector and the success of the policy more broadly:

• Delay the implementation of the SDR rules for portfolio management by 12 months after the publication of final rules.
• Allow for the implementation of the SDR rules for funds before extending the regime to portfolio management.
• Reconsider including bespoke portfolios in the SDR regime as they are not products but services.
• Consider lowering the 70% threshold for labels to avoid any unintended consequence of portfolio managers building less diversified portfolios to meet the proposed threshold.
• Provide more clarity around the inclusion of overseas funds as they are currently out of scope of the SDR regime and the role of portfolio managers when including them in portfolios.
• Include in the final rules a carve out that addresses the retail client requirement for non-labelled responsible investments which seem to lack a 'home' under the current proposals.

Read the full response here.

See also   UKSIF response: CP24/8 Extending the Sustainability Disclosure Requirements regime to portfolio management – UKSIF

Plus the Investment Associations final response: Final - IA response - FCA CP on extending SDR to PMS.pdf (theia.org)

------------------------------
James Doyle
Director, Green Finance, Investment Management

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

------------------------------
William Goodhart
Chief Executive
------------------------------

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