The 1OAK Multi-Asset Funds offer investors diversified exposure to equities, bonds, and liquid alternatives. 1OAK are the asset manager and have sole and complete responsibility for the management of the funds. 1OAK calculate the asset allocation from model portfolios provided by Blackrock.
1OAK pays a small number of investment consultants (IC) a fee to consult with 1OAK and assist in ensuring that regulated advisory and portfolio management firms understand the 1OAK proposition and the target markets/clients.
1OAK are completely independent from the investment consultants, and 1OAK always make the final decision concerning all target markets, clients and distribution channels under the FCA’s product governance (PROD) requirements.
The investment consultants are not regulated investment advisers and will not deal with any retail investors themselves, but they will consult and speak with professional intermediaries (intermediaries hereafter) such as regulated advisory and portfolio management firms and act as an “introducer” to 1OAK. The fee paid to the investment consultants will be calculated by reference to the AUM from specific intermediaries.
Why do 1OAK use Investment Consultants
1OAK use IC's for five purposes:
- Help 1OAK define the target market
- Ensure that the funds meet the needs of the identified target markets
- Consult on the distribution strategy
- Ensure that the intermediaries receive and understand the information provided by 1OAK
- Conduct post-sales checks to check that the funds have been distributed appropriately
IC's provide a vital two-way link between 1OAK and the intermediaries that distribute the 1OAK funds.
How does 1OAK select the IC's
1OAK select IC's based on various factors including their detailed knowledge of various intermediaries. The IC's understand the intermediaries advice process, how intermediaries assess their clients' attitude to risk (and capacity for loss), the other retail investment products and services they use, the platforms they use, and the intermediaries client base including their client segments.
It is considered that, by using the IC’s, 1OAK is able to meet the PROD requirements as a product manufacturer, 1OAK can better ensure that:
- 1OAK has defined the target clients appropriately and in a way that is consistent with the categorisation used by intermediaries
- The 1OAK funds meet the needs of the identified target markets/clients
- The 1OAK funds are provided to clients by appropriate distribution channels
- The funds are available via the appropriate platforms and wraps
- 1OAK provide intermediaries with the information that they require in the format that they need
- The funds have appropriate features and deliver appropriate client outcomes
- 1OAK are able to monitor the distribution of the funds by the intermediaries.
What services do the IC's provide to 1OAK?
IC's offer 1OAK information and consultation including:
- The way that intermediaries categorise clients and determine the clients' attitude to risk and capacity for loss.
- The systems intermediaries use to determine client’s attitude to risk and support their advice process
- The risk/return profile and mix of equities and bonds that intermediaries think is suitable and appropriate for different client types.
- The information about the funds that intermediaries and clients need.
- The best way to provide information to advisers and their clients.
- The types of investment style that intermediaries think is best for their clients.
- The best distribution strategy to use.
- The independent risk ratings used by intermediaries.
- The platforms used by the intermediaries.
- The independent ratings/reviews 1OAK should seek
1OAK use IC's to make sure that intermediaries understand the 1OAK funds, including:
- Have the intermediaries received the 1OAK marketing material?
- Have intermediaries received invitations to 1OAK presentations?
- Do intermediaries understand the 1OAK proposition and the target market/clients?
- Assisting in arranging meetings and presentations with intermediaries
1OAK use IC’s to perform post sales checks to ensure that the funds have been distributed to the identified target market. IC’s will report any sales to clients who are not the target market.
Do the IC's have any influence over the way that the fund is managed?
No, IC's do not influence the way that 1OAK manage the fund and they act purely in a consultation/introductory capacity between 1OAK and various professional intermediary firms. 1OAK are the manager of the fund and have complete fiduciary
responsibility for investment management. The IC's role is to provide information that 1OAK can use about the intermediary and ensure that the intermediaries receive and understand the material that 1OAK provide.
How are IC's paid
1OAK pay IC's a fee that is calculated using the AUM from specific intermediaries.
What is the inducement or Conflict of interest?
There might be a potential conflict of interest if the IC was the firm that advises clients or if the IC can exert pressure on the intermediary to use the 1OAK funds when other funds are more suitable and appropriate for an end retail investor.
1OAK does not use IC’s who also provide regulated advice to retail investors.
1OAK would not permit, under any circumstances, any inducement payment to any underlying intermediary in order to invest in 1OAK funds. All underlying regulated intermediaries that 1OAK will distribute through will also be adopting strict conflict of interest and inducement policies, under FCA requirements.
How is any potential inducement or Conflict of interest mitigated?
1OAK can employ the services of a consultant to provide information that assists 1OAK in developing and managing the 1OAK funds. 1OAK can engage consultants to assist in the distribution of the funds via professional intermediaries.
1OAK recognises the potential Conflict of interest and has put various measures in place to ensure no these are mitigated
- The IC is always a separate entity to the firm that advises clients
- The IC does not have any input into the management of the funds
- The IC is restricted to providing consultation and information to 1OAK and the intermediary
- The IC must not incentivise the advisory firm in any way or place the advisory firm under any pressure to use the 1OAK funds
- Advisers must be able to choose the investments that they offer to end retail clients without any conflict or inducement affecting their suitability obligations
- Advisers are free to offer a whole of market advice service or have a fettered central investment proposition
- Where advisers select a central investment proposition, they must be free to choose the investments without any inducement or influence from the IC
- An independent advisory firm must have procedures in place to consider funds from various providers and must be able to select funds on merit
- 1OAK, does not permit, under any circumstances, any inducement payment to underlying professional intermediaries.