Annual Review 2019-20 TISA Annual Review 2019-20 Overview

The Investing and Saving Alliance (TISA) is a unique, rapidly growing membership organisation for UK financial services.

We do this by focusing the power • TISA is recognised for the expert of our broad industry membership technical support provided to Contents base around the key issues to deliver members on a range of operational practical solutions and devise innovative, and regulatory issues targeted 1. 2019-20 Highlights evidence-based strategic proposals for at improving infrastructure and 2. From the Chairman government, policy makers and regulators processes, establishing standards of 4. Chief Executive’s Review that address major consumer issues. good practice and the interpretation and implementation of new rules and 6. Engagement: Year in Review TISA membership is representative of regulations covering MiFID II, CASS, 8. TISA Policy Development all sectors of the financial services ESG/RSI, operational resilience, industry. We have 225 member firms Cyber Risk, SM&CR and a range of 10. Strategic Policy Progress involved in the supply and distribution other areas. 10. Cash and Investment Savings of savings, investment products and associated services, including the UK’s • Digital transformation initiatives 11. Children’s Financial Education major investment managers, retail banks, that are driving ground-breaking 12. Consumer Engagement online platforms, insurance companies, innovation and the development of pension providers, distributors, building industry infrastructure for greater 14. Digital Innovation societies, wealth managers, third party operational effectiveness and revenue 16. Retirement administrators, FinTech businesses, promoting opportunity for firms. 18. Technical Policy Progress financial consultants, financial advisers, TISA has become a major industry industry infrastructure providers delivery organisation for consumer 21. TISA Members and . focused, digital industry infrastructure 23. Introducing TISAtech and TURN initiatives – TISAtech (a digital As consumers, the financial services marketplace that brings together industry and the economy react to and financial institutions and FinTechs for recover from the effects of the pandemic, greater collaboration and innovation) the importance of the three key pillars of and TURN (TISA Universal Reporting work that TISA prioritises has never been Network – a digital platform providing more apparent: a secure data exchange for financial services using blockchain technology) • Strategic policy initiatives that – alongside projects Digital ID and influence policymakers regarding the Open Savings & Investment. This financial wellbeing of UK consumers reflects TISA’s commitment to & thereby enhancing the environment open standards and independent within which the industry operates governance. in the key areas of consumer guidance, retirement planning, later lifetime lending, vulnerable customers, financial education, savings and investments. 1 TISA Annual Review 2019-20

2019/20 highlights

• Due to our game-changing digital work, TISA was • Participated in PRA/FCA Climate Risk Financial invited to sit on the Financial Action Task Force’s Forum, ran a hackathon on ESG customer reporting advisory group on Digital Identity. TISA is working in January and began work on developing the closely with government departments to align the industry guide for ESG. TISA Digital ID scheme with Gov.UK Verify scheme and sits on the FCA’s Open Finance Advisory Group, • TISA is championing extending financial guidance which is at the core of shaping this key policy. that firms can offer customers and has been facilitating ongoing dialogue between member • Our digital ID project moved into the testing phase, firms and the FCA, exploring how to deliver better which includes developing and testing a “Proof of consumer outcomes and setting out the case for Concept” with consumers, developing an acquisition change. Guidance is now a top theme in the RDR/ plan for consumers and developing a hub and testing FAMR review. with firms participating in the project. • Launched the Peer to Peer (P2P) industry • Phase 1 of the Open Savings & Investment (OSI) appropriateness guide. project has now completed, with outcomes including a detailed legal and governance framework, legal and • Our Child Trust Fund (CTF) Rollover working technical definitions of how authorisation will work, group worked with HMRC/HMT on the CTF the technical architecture needed to support the rollover process, contributing to the final APIs and a prioritised set of APIs to be developed. published regulations.

• Development of TISAtech – a digital marketplace • From the outset of the pandemic – TISA that will bring together financial institutions and successfully engaged with the FCA, DWP and FinTechs for greater collaboration and innovation. HMT on the need to adjust regulation, develop new consumer centric policy and make temporary • MiFID II industry best practice guides were product changes that allow our members to continue developed and industry standards established to support consumers’ financial wellbeing during for regulatory reporting. This work is being taken the crisis. forward by members to establish an industry solution – TISA Universal Reporting Network • Planning for the post-pandemic market – TISA has (TURN) – a digital platform providing a secure initiated a range of new policy initiatives that will data exchange for financial services using support our members and consumers in the “new blockchain technology. normal” market, including operational resilience, implementation of digital signatures and changes • TISA’s evidence-based report – “Getting Retirement to government position of tax relief. Right” – concluded that contribution levels of 12% are needed for Auto Enrolment to provide suitable • Expansion of our training programme to include replacement income for the median income wider range of regulatory and practical workshops household and we have engaged with DWP on and a successful move to online delivery amidst this basis. the pandemic.

• Launch of the Vulnerability Radar – a free online • 1,152 technical enquiries from our members self-assessment tool for firms to test their full range answered and 91 technical bulletins issued. of vulnerable customer processes against good industry practice. The tool was shared with the FCA prior to launch and over 100 member firms have undertaken self-assessments. 2 TISA Annual Review 2019-20

Tony Stenning, Chairman From the Chairman

Throughout the lockdown we have This has undoubtedly successfully modified our delivery to ensure that we aligned our services to support members and their customers. been a year of four We proactively engaged with regulators and government to seek easement quarters – our first and changes in regulation to allow our members to adapt their business models to continue to secure services for their three quarters being customers that helped protect their financial wellbeing. Our policy work and a story of continued our industry digital projects moved to full remote working and we maintained our growth and normal productivity and progress. As we emerge from the lockdown it operation, whilst in the has become clear that our major digital projects are in high demand as both consumers and our members adapt to fourth quarter TISA the “new normal”, which will undoubtedly witness consumers and members had to significantly alike further embrace higher levels of digital engagement, operations and propositions. This demand for higher adapt our member levels of digital services has seen our work in this area being further advanced services, policy and this will be a key theme as we develop our project work post-lockdown. development and projects to a fully remote model as the Overall, we remain financially strong, with COVID-19 lockdown significant support from our members, took effect. as we adapt to the post‑lockdown operating model. 3 TISA Annual Review 2019-20

We have seen one change to our Board, with Gregg McClymont leaving in early 2020. New appointments are being advanced to increase the Board’s expertise in line with TISA’s expanding range of work.

Overall, we remain financially strong, with significant support from our members, as we adapt to the post-lockdown operating model.

I’d like to thank all of our members for your continued and growing support. As we emerge from the lockdown it has become clear that our major digital projects are in high demand.

Tony Stenning Chairman 4 TISA Annual Review 2019-20

David Dalton-Brown, Chief Executive Officer Chief Executive’s Review

In summary it has While we had to adapt been a challenging but highly productive year to the pandemic where our members have embraced our environment, this approach and allowed us to further accelerate provided us with an our development in securing UK consumers’ opportunity to use our financial wellbeing. strong relationships with regulators and government to promote policy that supported our members in continuing to provide support for their clients and allowing consumers to protect their financial wellbeing as we enter a period of significant uncertainty. 5 TISA Annual Review 2019-20

The importance of our key policy and ESG/RSI – this new area sees us TISA Universal Reporting Network digital project work has been recognised working with our membership on the key (TURN) – building on our industry- by our members and the industry as our standards required to assess and report leading open standards work, this new membership base and support for our on ESG/RSI investments – post-crisis this service will provide the automation of digital projects continues to grow. During is an area of significant growth. the generation/reporting of the MiFID the lockdown and subsequent period as European Reporting Template (EMT). we enter the “new normal”, our members Operational Resilience – this area of our TURN will be further developed to support have stressed the importance of ensuring work is now expanding to understand ESG/RSI reporting and other areas of the that we accelerate work that supports the and build on the lessons learned during industry reporting that would benefit from post COVID-19 operating environment. the lockdown. digital automation, offering additional support to lower our members’ operating Key areas include advancing our: Open Savings & Investment – this costs as we emerge from lockdown. project is now being accelerated with Guidance Policy work – to ensure the wider industry support and new support TISAtech – this new industry service 40 million UK consumers who do not from leading FinTechs who provide the will allow our members to use the open have access to advice are able to receive key infrastructure, APIs etc. which will standards developed by TISA to work with the support they need in managing form the key implementation platforms over 3,000 FinTechs in the development their finances. for Open Finance. Acceleration of this of digital solutions. key project will allow our members to Pension Policy work – to ensure all embrace further levels of digitisation In summary it has been a challenging elements of society are able to save for of their propositions and operations as but highly productive year where our their future. they adapt their business models to the members have embraced our approach “new normal”. and allowed us to further accelerate our Vulnerable Consumers – our work in development in securing UK consumers’ establishing an industry tool for sharing Digital ID – this key element of our digital financial wellbeing. best practice for consumers has received roadmap has also been accelerated very wide industry support, further as the use of Digital IDs to support the advancing key policy work in this area. digitisation of our members’ operations will become more important as the post‑lockdown operating model becomes an industry reality.

Our members have stressed the importance of ensuring that we accelerate work that supports the post COVID-19 operating environment. 6 TISA Annual Review 2019-20

Ruth Moore, Executive Director Engagement: Year in Review

TISA membership This year provided TISA In 2019-20 TISA membership increased from 205 to 225 members, with a new member joining every month (13 brand with the opportunity new members from across different sectors) – plus new engagement with to demonstrate high additional sub-brands of our multi-entity Platinum members. value to our members, In recognition of the challenge that COVID-19 has posed to many of further develop our our members, we have fixed TISA membership subscriptions from July 2020 to June 2021 at the previous profile in the market year’s rates and are instead meeting the resource requirements of TISA’s and to innovate and comprehensive programme of work by attracting new members and extending the services we offer (including our extend the support and programme of Events and Training and services that we offer. our new digital services). Member Survey Results This year we introduced our first independently conducted Annual Member Survey. Members awarded TISA an above average Net Promoter Score (as benchmarked against the financial services industry) and we gained valuable insights into members’ collective views and wishes, which will be carried through our planning and delivery for the coming year. You told us that the aspects of TISA membership that you most value are: • TISA’s relationships with government and regulatory bodies and our ability to influence government policy and interpretation of new regulations • Participation in technical policy In 2019-20 TISA membership discussions and working groups to set industry standards of good increased from 205 to 225 members, practice on key issues • Engagement with fellow members with a new member joining every from across the whole of UK financial services and as a result, exposure to month (13 brand new members from a broad range of cross-sector issues, opportunities to enhance your firms’ across different sectors)… profiles and making connections with peers/other TISA members 7 TISA Annual Review 2019-20

We were delighted that members rated We will continue to run TISA Events on TISA very highly on meeting member a mainly virtual basis for the rest of …we gained valuable needs, communicating well and offering 2020 and hope to be able to welcome insights into members’ excellent value for money but took careful attendees in person for events at collective views and note that the area in which you would which this is more conducive (such like to see us do more is in knowing our as our House of Commons lunches, wishes, which will be member firms more deeply. To address networking events and some of our other carried through our this over the coming year and beyond, conferences and forums) as soon as planning and delivery we will be offering more “Exec-to-Exec” possible in 2021. for the coming year. meetings and seeking to increase the number of contacts and touchpoints with Communications & PR member firms at all levels. Throughout the height of the pandemic crisis and to ease the transition to the Events and Training “new normal”, TISA provided additional The Annual Conference in December support to members with our weekly was, as usual, the highlight of our events COVID-19 update emails and webpage, programme, with 346 attendees (an housing all related resources. Running increase of 9%) coming together to gain from March to July, these weekly insight from a senior panel of speakers, COVID-19 update communications including Baroness Altman CBE, Martin provided timely and focused updates on Gilbert, Patrick Thomson & Sir Steve the changing environment, TISA’s work Webb on themes ranging from political to influence policymakers in relation to priorities, digitalisation, the future the crisis and technical and guidance economic landscape and of course, on operational issues. We received very how best to meet the future needs positive feedback from members as to of consumers. the usefulness of these communications.

We pivoted quickly in April to reformat We carried out a refresh of the TISA to online/virtual delivery of our Events website, including enhancements to the and Training in response to the navigation to access information and COVID-19 lockdown. resources, and restructured the Policy & Technical pages to consolidate all our While the in-person Events we had groups, resources and relevant links for scheduled from March onwards each policy area together. The website obviously couldn’t take place in the also features new pages to access TISA’s planned format, we were nevertheless technical support and new Delivery pleased to welcome over two thousand Entities for the new digital initiatives. participants to TISA events in 2019-20 – Phase two of this work will see updates an increase of 37%. to the homepage and members’ area of the website over the autumn/winter. Having almost doubled the number of participants benefitting from TISA We also updated our logo (to the branding Training last year, in 2019-20 we you see on these materials) as this will maintained this despite the pandemic allow us flexibility to extend the brand by introducing workshops on new using a family of “sub-brand” logos to topics into our Training portfolio so as identify the new digital initiatives that we to further meet members’ personal and announced recently, which are launching team development needs, delivering 62 over the coming months. workshops to hundreds of participants. Indeed, we delivered 22 online training In March 2020 we appointed Cicero/AMO workshops between March and June as our new media agency and are working alone, having moved our training with them to raise TISA’s profile more provision online. widely through the media. 8 TISA Annual Review 2019-20

TISA Policy Development

All three of our pillars of policy development (Strategic, Technical and Digital Policy) have continued to develop over the last year and have been adapted to support our members and their customers during the pandemic and associated lockdown.

TISA policy development

Strategic Technical Digital policy policy policy 9 TISA Annual Review 2019-20

The pandemic has emphasised the importance of all our policy work and our A key factor in our aim to improve all consumers’ financial development over the wellbeing both during the lockdown and last year has been the as the UK emerges into the “new normal” business and consumer environment that growth in support for is starting to develop. our digital policy and associated industry Member support has seen successful projects. This support development of our proactive strategic policy work in the key areas of consumer has allowed TISA to guidance, retirement planning, vulnerable widen its digital work The pandemic has customers, financial education, savings and the resources and investments – which complements we allocate. key elements of our technical policy emphasised the work covering MiFID II, CASS, ESG/RSI, operational resilience and a wide range importance of all of other areas. our policy work and A key factor in our development over the last year has been the growth our aim to improve in support for our digital policy and associated industry projects. This support all consumers’ has allowed TISA to widen its digital work and the resources we allocate. financial wellbeing Many members have emphasised the importance of our digital work as they both during the move to the post-lockdown business environment which will see increased use lockdown and as of digital propositions and operations. the UK emerges TISA is rapidly being recognised as the leading digital membership body for into the “new UK financial services that is focused on delivery of key industry services and normal”… utilities to the benefit of members and their customers. This direction is one that we will continue to lead over the coming years.

The following pages provide a comprehensive summary across all aspects of our policy work. We hope all members find this demonstrates our continued support for you and your customers, in addition to providing you with help in assessing how you will engage with us in the coming year. 10 TISA Annual Review 2019-20

Strategic Policy Progress

Nigel Banfield, Technical Policy Manager (Cash and investment Savings) Cash and Investment Savings

The Cash & Investment Savings Policy period. This in effect removes any impact TISA has been working Council has focused on developing the on the savings placed into the Lifetime diligently behind the paper “Maintaining ISA simplicity”. This ISA and only claws back the benefit of scenes with a working pushes for a single annual ISA limit the bonus. This change came about with no restriction on the number of following discussions between TISA and group of providers, accounts that can be opened in support HMRC on what could be done to support HMRC and FCA to of this. We see it enabling wider choice consumers during this difficult time. We establish workable for the investor, not limiting their choice will continue to liaise with HMRC, seeking regulations and guidance. of providers or savings opportunities, for this to become a permanent change. increasing the potential market (as investors are not limited if they have The first children to benefit from Child placed some money in a tax year) Trust Funds reach 18 years of age in and reducing the amount of checking September 2020 and will therefore gain HMRC needs to carry out. The proposal control of these funds. TISA has been is now with HMT and we await further working diligently behind the scenes with opportunities to discuss further. a working group of providers, HMRC and FCA to establish workable regulations One of the other areas TISA has been and guidance. Successful training has vocal on is the withdrawal charge on been provided and liaison with the Lifetime ISAs. As part of an initiative to devolved governments over vulnerable provide some consumer relief during children sees the industry well prepared the lockdown caused by COVID-19, for the first maturities. However, with HMRC announced the reduction of the many accounts disconnected with the withdrawal charge to 20% for a limited investor, work continues to ensure we reach all 6 million recipients over the next 9 years.

The Cash & I Investment Savings Policy Council has focused on developing S A the paper “Maintaining ISA simplicity”. 11 TISA Annual Review 2019-20

Carol Knight, Chief Operations Officer Children’s Financial Education

The Children’s Financial Education we focus resources so that we can Council has been on hold this year, as avoid duplication and are better able we are keen to support the work which to fill gaps in provision. Therefore, the the Money and Pensions Service (MaPS) council participants felt that it was are developing through the Financial appropriate to wait for the outputs and Education Challenge group within the recommendations from MaPS so that we overarching Financial Wellbeing Strategy. can then select the areas we choose to Carol Knight sits on that Challenge work with and develop activity in line with Group, so we have a voice in the eventual the national programme. recommendations. It is important that

This year KickStart Money reached a tremendous milestone.

Through our delivery partners, MyBnk, we teacher training CPD programme, which delivered life changing financial education combined with our new digital resources, to over 18,500 primary school children will enable the programme to reach into (exceeding our original target) across 150 new areas of the UK; many of which have schools, delivering nearly 3,000 hours of been historically underserved by financial specialist-led learning. education provision.

But the last year has not just been The year ahead promises to be incredibly about reach and expansion. We have exciting as we launch our new three-year undertaken independent evaluation every strategy to help us achieve our vision of year, and we can consistently evidence ensuring that “every primary school aged that our sessions work. Months after child in the UK has access to effective taking part 70% of pupils were “working early years financial education”. towards a saving goal”, while teachers …we launch our new report that 87% of their pupils now three-year strategy to understood that their financial decisions help us achieve our had consequences. vision of ensuring that This year has also been a year of “every primary school significant development for the KickStart aged child in the UK programme. COVID-19 has accelerated has access to effective the development of digital provision, which is now capable of replacing early years financial physical delivery should schools struggle education”. to re-open in the autumn. Additionally, we saw the development of a new 12 TISA Annual Review 2019-20

Stephen Gay, Policy Team Manager Consumer Engagement

At the heart of TISA’s

TISA’s mission mission is the idea that our society can only function Financial resilience well if the public is able to achieve a level of financial resilience – and that our industry has a key role in enabling the prospect of prosperity and peace of mind to ordinary families struggling with the adversities of everyday life. 13 TISA Annual Review 2019-20

Our Consumer Engagement Policy FCA, which remains ongoing. The working Savings Culture Council is dedicated to advancing that group successfully collaborated with the The work to restore a savings culture proposition, focused on delivering FCA on its industry guidance on what firms in our society, particularly amongst the improved financial outcomes for the can communicate to worried consumers younger generation, took an exciting step public, and passionate about our (regarding their pensions and investments) forward this year with a pilot competition responsibility to look after those in amidst the COVID-19 market volatility. The for university students to design solutions society who do not have the privilege of group also raised with the FCA the many to engage their peer group in establishing health, wealth, and stability in their lives. issues firms face when crossing into the a savings habit. Twelve teams from five boundary of regulated financial advice and universities took part with a panel of The events globally that began in how the existing rules represent a road- judges reviewing video presentations February 2020 in particular have served block for firms to provide much needed and reports based on their creative ideas to highlight the importance of our work. financial guidance to consumers who and research. COVID-19 has no respect for regulation cannot afford regulated financial advice. or reputation. It strikes the great and the The winning team from Kings Business good as well as those at the margins of Elsewhere, we incorporated guidance School will receive work experience at society, and it can cause even the largest recommendations within the TISA sponsoring financial firms and will have of financial services institutions to falter. paper on required increases to AE the opportunity to pitch their idea to However, its impact is not felt equally – it contribution levels. Marketing Directors in a webinar. The pushes those without financial resources competition has been well received by deeper into insecurity, destroys incomes, For the rest of 2020, the working group universities, students, and firms and we depletes savings, dashes plans for the will continue engagement with the FCA are encouraged to develop it further in the future. Those who have established a firm as well as other stakeholders and will be year ahead. financial platform in life are insulated to commissioning some primary research a much greater degree; they are able to (from a leading University) to validate In summary, we are proud of what has face the future with a confidence that we what financial guidance people require. been achieved to date, and that it has would wish for all in our society. been delivered with the enthusiasm and Vulnerable Customers hard work of our member firms. This is a Against this background it is pleasing that Our work on Vulnerable Customers has platform to build upon, and we can do so the work of the Consumer Engagement taken major steps forward in recent with confidence. Policy Council has advanced in the last months. The working group continues to year and we have solid achievements to be very well attended and in May we held show in all three of our strategic themes. an online forum with the FCA, attended by more than a dozen firms, each speaking Against this background Financial Guidance on the challenges of working with [the COVID-19 Pandemic] TISA continued to promote the need vulnerable people in this time of COVID. it is pleasing that the in the UK for better quality financial We were also able to discuss lessons that guidance services to be provided to had been learned and the solutions that work of the Consumer consumers and the regulatory framework have emerged. Engagement Policy to support the provision of such services. Council has advanced in In February we held a conference on the last year and we have In October 2019, TISA hosted a Financial vulnerability which was attended by Guidance Roundtable attended by almost 200 people and a testimony to solid achievements to the FCA, HMT, DWP and MaPS. This the growing importance of the subject show in all three of our focused on explaining the key issues within the financial services community. strategic themes. around guidance in the UK, as well as On the same day we launched our the introduction of various case studies Vulnerability Radar self-assessment of potential guidance initiatives and was tool, a joint endeavour between TISA successful in raising awareness of the and Altus and the product of more than issues around guidance (particularly with a year of development by our working HMT and the DWP) as well as identifying group. This tool is a unique and free the FCA’s position. offering to the industry and a hundred firms are already using it, assessing their Following the roundtable, more focused practice across a wide range of metrics engagement has taken place with the to establish benchmarks and priorities for FCA, HMT, DWP and MaPS. Significant improvement in the service they provide engagement has taken place with the to vulnerable people. 14 TISA Annual Review 2019-20

Harry Weber-Brown, Digital Innovation Director Digital Innovation

Digital Identity Project The last year has seen Over the course of 2019-20, the Digital ID project team has delivered the Alpha Phase and moved into the User Testing significant progress in Phase. This phase is focusing on defining and optimising the user experience, our digital transformation through the development of user journeys for different transactions, using the Digital initiatives, driving ground- ID and then testing these with consumers. TISA has been awarded a significant breaking innovation and the government grant to support and accelerate the User Testing Phase of development of industry the Digital ID. To define the technical approach, the infrastructure for greater team has undertaken a Request for Information with leading technology providers, which seven firms responded operational effectiveness to; this will be followed by a Request for Proposal and the development of a hub, and revenue promoting which will be tested. This will inform how the scheme will be best developed and delivered in a “live” environment. opportunity for firms. The team has been working closely with the Gov.UK Verify Team to align the standards between the schemes, and in developing the Trust Framework. The project team provided input into the Joint Money Laundering Steering Group in defining the guidance for Digital Identity, following the transposition of Open Savings the 5th Anti‑Money Laundering Directive and Investment in legislation. (OSI) Project The business case, developed in the previous phase, is being validated with TISA members through a series of roundtables and events.

Digital Identity Project

MiFID II Project 15 TISA Annual Review 2019-20

Open Savings and Investment MiFID II Project (OSI) Project At the beginning of July 2019, the TISA …we made a concerted The Open Savings & Investment (OSI) MiFID II Project had received responses effort in engaging the project was initiated in January 2019, to its RFI. The project team was preparing with the vision to create a common set to issue RFPs to build an industry FinTech community and of open standards for supporting APIs solution to enable prompt and accurate are really pleased to have (Application Programming Interfaces) production and consumption of EMTs onboarded eight market capable of interfacing with legacy (European MiFID Template) between leading FinTechs, who systems and infrastructure. This will asset managers and distributors. It would enable the entire industry to release have to be a European solution – covering are established in their their data in a secure, standardised form the UK, EU and Swiss markets. It would be field and have injected so that it can be shared more easily not for profit, run for the industry. an enormous amount of between authorised organisations online energy into the delivery and deliver a range of digitally enabled A year later, the project is being benefits to the consumer. Following the transformed into TURN – TISA Universal of Phase 2. successful delivery of Phase 1, Phase 2 Reporting Network. The member firms was initiated in November 2019 and all of the project have appointed Atos participants continued their support, as the technology partner to deliver a ensuring continuity of thought and blockchain solution. momentum in delivery. Delivery of the EMT solution is due in Furthermore, we made a concerted effort the autumn of 2020. in engaging the FinTech community and are really pleased to have onboarded The founding members of TURN, eight market leading FinTechs, who including asset managers, European are established in their field and have distribution businesses and information injected an enormous amount of and technology firms, have agreed a energy into the delivery of Phase 2. Not vision for utilising a European MiFID perturbed by COVID-19, the Steering and other regulatory data highway, Committee remain resolute in terms to meet requirements for PRIIPs, of delivering a Showcase Pilot in two corporate actions, fund standing data, stages: Stage 1 (September 2020) ESG/RSI reporting and target market being a clickable prototype that will sales feedback. demonstrate Aggregation, Customer Consent Processes, alongside an Open The founding members have become Banking view; Stage 2 (November 2020) the first Board of TURN, ensuring that will be the fully working API set to drive TURN is run by and for the industry. the aggregation of the data. TURN, having successfully launched EMT v3, is now in the adoption phase, enabling firms, whether asset managers, investment platforms, other distribution businesses and information firms, to meet their regulatory obligations in an efficient, timely and straightforward way. The next step is to agree the subsequent phase for development, building on the delivery of EMT v3. 16 TISA Annual Review 2019-20

Renny Biggins, Head of Retirement Retirement

We launched our retirement paper Our inaugural “Getting Retirement Right” at the conference. This extensive piece of evidence-based research focuses on Annual Retirement the challenges that households face in achieving a target level of income in Conference was retirement through the accrual of pension savings via the Automatic Enrolment (AE) framework. It concludes with five successfully held proposals which we believe will help households achieve higher standards in February 2020 of living through retirement. The paper includes the input and support of 13 member firms, representing some of with keynote the major names in the retirement market. The paper was well received by speeches from the industry and featured in both trade and national media. Parliamentary Under- Secretary of State for Pensions and Financial Inclusion, Guy Opperman and the Executive Director for Regulatory Policy at The Pensions We launched our Regulator, David Fairs. retirement paper “Getting Retirement Right” at the conference. 17 TISA Annual Review 2019-20

The FCA published their Policy Statement Our June policy council guest was on Investment Pathways in July 2019, Baroness Ros Altmann, who shared We will also start to which sets out the requirements that her expert insights on a range of understand the impact firms need to adhere to when developing topical issues. their drawdown consumer propositions. that COVID-19 will have This is a large and challenging piece of The Retirement Technical Committee on retirement outcomes, work for firms to undertake, which is why continues to deal with a range of in particular the impact in addition to the online forum, two well topics which impact firms’ operational this has on Automatic attended working group discussions were processes which included input into the held, designed to help firms discuss and Investment Pathway work. Enrolment and deferred agree requirements and identify common pension pots. challenges and areas where additional 2020-21 looks set to continue to be an detail was required. Subsequent liaison incredibly busy time in the retirement with the FCA has helped resolve many of landscape. We have the DWP charge cap the areas of uncertainty and firms are well review, a consultation relating to IGCs and on the way to finalising their propositions, how value for money is assessed, a Call which now need to be in place by the for Input on the Pensions Dashboard and revised date of 1st February 2021. at the time of writing The Pensions Bill 19-21 has just cleared through the House Our March Retirement Policy Council was of Lords. attended by DWP Deputy Director David Bateman, where the immediate impact We will also start to understand the of COVID-19 on DWP policy and industry impact that COVID-19 will have on were discussed. A document was retirement outcomes, in particular the constructed which included a detailed list impact this has on Automatic Enrolment of factors to consider, should a decision and deferred pension pots. be taken to pause the requirement to make Automatic Enrolment contributions We will be looking to build on the success for a finite period, and sent to DWP. It was of our initial strategic policy research pleasing to see that not only the decision and proposals by developing the next to pause the requirement was not taken complimentary set. but also that contributions could be claimed for those employees furloughed through the Job Retention Scheme.

Ongoing discussions with DWP remained in place for the following weeks, where we provided details of our member firms’ experiences and impacts of dealing with the COVID-19 pandemic and regular meetings are now in the diary for the forthcoming year. 18 TISA Annual Review 2019-20

Jeffrey Mushens, Technical Policy Director and Graham Bateman, Regulation Executive Technical Policy Progress

Client Assets Responsible & Sustainable Financial Crime Investment (RSI) Cyber Risk P2P & Debt Based Securities & Certification Senior Managers Managers Senior

Operational Regime (SM&CR) Resilience MiFID II Taxation

Client Assets Cyber Risk Contemporary best practice publications TISA has engaged in several satisfactory Launched in 2019, the Cyber Risk include Powers of Attorney due diligence, face to face meetings with the FCA Technical Committee amasses industry the 5th anti-money laundering directive and ironed out the “Trade v Settlement expertise for TISA and collectively and registration of personal trusts date” debate, physical assets and considers the operational, regulatory on transfer agent systems. TISA also reconciliations, and FCA Breaches and and technical issues relating to cyber continues to be an active member of the Audit Reports covering the COVID-19 risks as they develop, and as new risk Joint Money Laundering Steering Group period including late submissions. management techniques and tools (JMLSG). On behalf of, and approved by, become available. With members HMT, the JMLSG produces the definitive Further engagement with the FRC has from influential firms including the guidance for the financial services elicited a new CASS stakeholder forum big four consultancies and specialist industry on managing financial crime risk. to work towards a greater consistency of cybersecurity providers, quarterly application and interpretation of the CASS meetings are held with key deliverables P2P & Debt Based Securities rules and CASS Assurance Standard for in producing industry best practice The P2P Working Group meet quarterly firms and accountants. guides and member bulletins on the TISA with a policy group and operational website informing of recent malicious council being considered to promote Major contributions from the group cyber threats and criminal techniques. P2P in becoming mainstream. The P2P towards the CASS Best Practice TISA has sent out several Technical sector has experienced challenges with document will be launched in the autumn Bulletins to inform firms of how to protect the PS19/14: Loan-based (“peer-to-peer”) of 2020 covering Reconciliations, ISEM, themselves and their customers from and investment-based crowdfunding Resolution Packs, the FRC CASS Audit criminal exploitation during COVID-19, platforms and subsequent FCA temporary Assurance Standard, Governance & and TISA has carried out a succinct cyber intervention order. Following open and Oversight and Mandates etc. The Client risk survey to help collectively focus our effective dialogue with the FCA, TISA Assets Committee has also continued efforts on particular areas, and enhance can help support industry changes in the practice of submitting anonymised current cyber risk guidance. developing cultural changes and produce questions from members, which are best practice guides that address debated and responded to, affording Financial Crime concerns for firms keen to strengthen members a consistent approach. This active group meets quarterly and their governance arrangements, systems addresses the challenges faced by firms and controls platforms, and have Furthermore, TISA conducted informative in administering measures to counter information in place to support the CASS training to firms throughout the money laundering, terrorist financing, outcomes they advertise. Quarterly IFISA year, responded to the Dormant Assets financial and trade sanctions, bribery, statistics are being produced consistent Expansion Consultation and produced corruption, fraud, market abuse, tax with HMRC’s figures, showing number of technical bulletins to help firms during evasion and other relevant anti‑financial IFISA managers, subscriptions by value, COVID-19. crime legislation. The group is well customers and average values. The group positioned in delivering good systems continue to build on relationships with and controls, and outcomes, for all FCA, HMRC and HMT with key issues and firms, consumers and the FCA as develop the P2P membership. well as financial crime organisations. 19 TISA Annual Review 2019-20

MiFID II Operational Resilience Despite the fact that MiFID II was Operational Resilience is not just Disaster TISA has also been implemented at the beginning of 2018, Recovery – the coronavirus crisis has participating on the TISA has had two groups working to made this clear. Having alternative update previously published good premises for staff doesn’t work if they development of a practice guides (on Product Governance can’t travel to the premises, or work European Standard for and Costs & Charges) ahead of the together even if they could travel. Product Governance MiFID Virtual Conference in September Alternative computer sites aren’t the Feedback reporting 2020. We’ve also held two popular solution if systems going down aren’t briefings on Costs & Charges and your problem. Firms need to be: (EFT) through FinDatEx. Product Governance. • Resilient for customers – What happens when firms upgrade systems The main areas of challenge that firms and these go down, so firms can’t have faced have been: access their accounts, and can’t make • Cumulative effect of costs on their payroll meaning that individuals return, particularly in the second and can’t make their mortgage payment, subsequent years or pay their rent and other bills. • Transaction costs and the capture of • Resilient for the business itself – implicit costs what happens when a major partner • Property funds – like an outsource – goes down if • Liquidity your firm’s bank can’t make payroll for • Value statements your firm? How does your firm meet • Product lifecycle their commitments? • Governance • Resilient for stakeholders – Businesses have an impact on the These are all areas that the updated market in which they do business. guide documents address. What steps does your firm have to mitigate the impact on your market TISA has also been participating on the participants, your banks, your development of a European Standard for outsource partners? Product Governance Feedback reporting (EFT) through FinDatEx. This is a whole of business issue, as it is clear that resiliency is critical to: The TISA MiFID II Project is evolving • Continuing to do business with, and into TISA Universal Reporting Network support, customers (TURN), a live solution to the production • The resilience of the market as of EMT and its sharing and consumption a whole by distribution businesses across • The continuance of the business, Europe, is a tangible outcome from the where investors capital, often through work on MiFID II, which we expect to customers retirement savings plans, incorporate feedback and other regulatory like pensions and ISAs, is at risk and compliance challenges in 2021 and beyond. At the two conferences TISA held – in December, when the FCA launched its public consultation, and in March when the Bank of England spoke – the …the importance of importance of operational resilience operational resilience as an issue for firms was clear, and following an Open Meeting TISA then as an issue for firms launched the Operational Resilience was clear, and following Working Group with firms to help an Open Meeting TISA respond to the FCA/Bank consultations, then launched the implement recommendations and develop an industry good practice, Operational Resilience building on the work already started in Working Group… the banking sector. 20 TISA Annual Review 2019-20

Responsible & Sustainable Agreement on this will then be kit, reasonable steps guide, “10 helpful Investment (RSI) underpinned by the development of an tips for manager readiness”. Using our TISA’s work in this area has focused on industry agreed data standard, similar to unique collaboration with the FCA, we 6 themes, namely; that achieved using the EMT (European were able to deliver a helpful Q&A guide to • Regulatory timelines MiFID Template). Work on this has help firms navigate through the COVID-19 • Definitions/Glossary started with FinDatEx, of which TISA period. This was well received given the • MiFID II suitability is an active member, on developing a new deadline for solo-regulated firms to • Good practice guide(s) European standard to capture ESG/RSI have undertaken the first assessment of • Communicating with customers, and data. As with the development of the EMT, the fitness and propriety of their Certified • Data standards which enabled firms to have the data Persons delay to 31st March 2021. A needed for ex ante and ex post Costs & SM&CR post-implementation forum is These themes were showcased in the Charges reporting, meaningful customer planned for 2021 which will share and successful conference in September disclosure needs to have agreed debate best practices including regulatory 2019. The first three have finished and the data standards. examples of conduct rule scenarios. work is incorporated in the Good Practice Guide Working Group, which will deliver a The group is also working with the Impact Taxation first draft in September. Investing Institute and feeding into the With a full year now underway, the group development of UKL standards through discusses, debates and replies to tax The group is intending to set out the British Standards Institute. We expect related matters that affect consumers standards for how the application of 2021 to be a critical year for developing and firms. With a wealth of tax knowledge ESG/RSI to investments, not just funds, and implementing this work, so firms within the group, the quarterly meetings but discretionary portfolios, etc., can be interested in helping deliver these should engage with a wide and active agenda objectively described so customers can contact us to join. currently covering tax topics such as meaningfully choose between investment SIPP guidance, digital working tax, VAT options. This work is being driven by Senior Managers & Certification (Partial Exemption), HMRC responses, the Communicating with Customers Regime (SM&CR) crypto currencies. We have been able to Working Group. The group has presented This has been an incredibly proactive provide guidance on the VAT Treatment visualisations and updated these year for the SM&CR Working Group. of Financial Advisory Services, and following a hackathon in January with With the build up to SM&CR live date of feedback to HMRC on DAC6, and a wide range of firms and engaged with 9th December 2019, the SM&CR “1 month contribute significantly to TISA budget the FCA in how these could work. This to implementation” event was truly representation. Liaising with HMT, HMRC is a priority for this year. The group is remarkable with a wide audience of HR Finance Liaison Group (FLG), and the also engaged in the debate around fund and compliance professionals listening CBI Industry Taxation working group, we classification (so-called Article 8 and to expert industry practitioners including can lobby and communicate tax topics Article 9 funds), where the TISA approach senior lawyers. The group has continued efficiently and effectively. is to encourage a wide range of funds to produce best practice guides for to be eligible for description as ESG/ members, available on the TISA website, RSI, rather than a binary, which would with informative and helpful resources restrict the range of funds and reduce covering living will/handover checklist, discrimination between funds that make “Don’t let SM&CR die in BAU” guide, the cut. conduct rule training, trade body comms

21 TISA Annual Review 2019-20

TISA Members As at 30 June 2020

A J Bell Securities Limited Collegia Partners Limited Halifax Share Dealing Ltd Accenture Columbia Threadneedle Investments Hampshire Trust Bank Actuare Limited Computershare Investor Services Plc Hansuke Consulting Aegon UK Plc Corterum Hargreaves Lansdown Al Rayan Bank Plc Coutts & Co Hodge Bank Allfunds Bank SAU Coventry Building Society Hogan Lovells International LLP Arbuthnot Latham & Co Limited Credit Suisse (UK) Ltd HSBC Group Artemis Investment Management Criterion Tec Limited IG Markets Ltd Ascentric/IFDL Cynergy Bank Intelligent Money Atlas Computer Systems Limited Danske Bank (Northern Bank Limited) Trading Atos DB UK Bank Ltd Invesco Perpetual Aviva Plc Defaqto InvestCloud Baillie Gifford Ltd Dentons LLP Investec Asset Management Ltd Barclays Wealth Duff & Phelps Investec Bank Barratt & Cooke Ltd Dunstan Thomas Holdings Ltd Investec Click & Invest Beyond Encryption EFG Harris Allday Investec Wealth & Investment Limited BlackRock Investment Management Embark Platform James Hay (UK) Ltd Equiniti Janus Henderson Blankstone Sington Ltd ERGO Consulting JHC LLP BMO Global Asset Management Ernst & Young JM Finn & Co BNY Mellon EValue Ltd JP Morgan Asset Management Bravura Solutions (UK) Ltd FE fundinfo (UK) Ltd Jupiter Unit Trust Managers Ltd Brewin Dolphin Ltd Fidelity International Killik & Co Brooks Macdonald Asset Fineco Bank KPMG Management Ltd FNZ UK Limited Legal & General Plc Brown Shipley & Co Ltd Folk2Folk Lending Works Limited Calastone Ltd Forester Life LexisNexis Risk Solutions Canada Life Ltd Limited LGT Vestra LLP Castle Trust Capital Management Friends Life Link Asset Services Cavendish Asset Management Ltd Fund Ourselves Cazenove Capital Management Fundscape LV= Charles Stanley & Co Ltd Fundsmith LLP M&G Ltd Close Brothers Asset Management Fusion Wealth Limited Maitland Administration Services Ltd Clydesdale Bank Plc GBST Wealth Management Ltd Man Fund Management UK Limited CMS Cameron McKenna Nabarro Olswang LLP Goji Holdings Limited Margetts Fund Management Ltd Colchester Global Investors Limited Halifax Investment Services Ltd Marks & Spencer Financial Services 22 TISA Annual Review 2019-20

Mazars LLP RateSetter Taylor Wessing McInroy Wood Rathbone Bros Plc Tesco Bank Model Office Raymond James I.S. Limited The Share Centre Ltd MoretoSIPPs RBC Investor & Treasury Services The SimplyBiz Group Ltd Morningstar UK Ltd Redmayne Bentley LLP Thesis Asset Management Multrees Investor Services Rowan Dartington & Co Ltd Third Platform Services Limited NatWest Bank Plc Royal Tilney Asset Management Nationwide Building Society Saltus Private Wealth Tilney Bestinvest NedBank Private Wealth Limited Sanlam Financial Services UK Limited Triodos Bank NV Northern Trust Santander AM UK Ltd Triplea Advisory Group Norton Rose Fulbright LLP Santander ISA Managers Tutman LLP Nucleus Financial Group Ltd Santander UK plc Virgin Money Nutmeg Saving and Investment Ltd Schroders Plc Walbrook Partners Old Mutual Global Wealth Scottish Friendly Asset Managers Ltd Walker Crips Investment Management Limited OneFamily Scottish Widows Investment Partnership Wealth at Work Limited One Savings Bank Seccl Technology Limited Wealthify Open Money Limited Secure Trust Bank plc Wealthtime Limited Openfunds EV SEI Investments (Europe) Ltd Orbis Investment Advisory Ltd Sesame Bankhall Group Whitefoord LLP Origo Services Ltd Seven Investment Management Willis Owen Limited Parallel 51 Limited Shawbrook Bank Willis Towers Watson Parmenion Capital Partners LLP Silverfinch Winterflood Securities Limited Pershing SIX Financial Information Worksmart Limited Pinsent Masons LLP Smarterly Yorkshire Bank Platforum Smith & Williamson Investment Services Ltd Zopa Limited Post Office Sopra Steria Praemium (UK) Ltd SS&C Progeny Asset Management Ltd St. James’s Place Wealth Management Progressive Building Society Standard Life Aberdeen Prudential Group State Street Punter Southall Wealth Succession Advisory Services Quilter Cheviot SWIFT Quilter Financial Planning T. Rowe Price Quilter plc Target Servicing Ltd Radius Europe 23 TISA Annual Review 2019-20

Introducing TISAtech and TURN

Launching in July 2020, TISAtech is the new digital marketplace Currently the financial market’s dissemination and aggregation created to bring together financial institutions and FinTechs of Regulatory Data and Fund Data presents numerous issues for greater collaboration and innovation. TISAtech will enable across the industry, whether it be Manufacturer, Data Vendor financial institutions to more quickly and easily identify and and Data Consumer – timeliness and accuracy are constant connect with potential FinTech partners via a searchable issues which we will resolve by building an industry data utility, database of categorised FinTechs. which is created and run by the industry.

For those financial institutions seeking to deepen engagement TISA Universal Reporting Network (TURN) will establish a with the tech ecosystem, TISAtech will provide access to blockchain (distributed ledger) digitally neutral platform that more than 3,500 FinTechs covering all industry segments aggregates and distributes all fund and regulatory data to the and technologies. The enhanced scouting, discovery and Data Providers, Consumers and Vendors. identification process will allow business leaders to more effectively scope-out and profile the suitability of FinTechs Built by Atos, with service launch in September 2020, this new on a single platform. platform will allow asset managers and distributors – including financial advisers – to capture, share and transmit MiFID II In delivering the service, TISAtech will be partnering with data across Europe to all relevant stakeholders, through a The Disruption House, the specialist benchmarking and data standardised EMT (European MiFID II Template). All relevant analytics business for financial institutions and innovative parties will have access to the EMTs on a real time basis and financial technology firms. Benchmarked scorecard this will be of a high and consistent quality. assessments will help financial institutions better understand and compare a FinTech’s ability to partner with them and For more information, head to www.tisaturn.com grow. The platform will also operate as a “clearing house” for industry problem statements that would benefit from agile tech innovation and development. Structured Tech Sprints and Sandboxing concepts will support the prototyping and validation of new technologies.

For more information, head to www.tisa.uk.com/tisatech/ TISA, Dakota House, 25 Falcon Court, Preston Farm Business Park, Stockton-On-Tees TS18 3TX

Technical queries: 01642 666999 Administration: 01642 666982 [email protected] www.tisa.uk.com

View our: EVENTS | TRAINING | NEWS

Designed by