Growth Segment: Minority Broker Dealers
The MFDVs only have access to limited research and therefore require better access to more research. Pension funds are interacting with each other more and more thereby generating MFDV overlaps between funds and increasing the spotlight on the MFDV goals . Commission Sharing Agreements (CSA) and ‘step-out’ policies are slowly being disbanded in this space.
As such, sell-side partners are becoming a necessary requirement of MFDVs. An investment manager can no longer simply ‘cut-a-cheque’ to avoid utilizing MFDVs. This has been confirmed with CalPERS/CalSTRS (who state that multi-firm arrangements such as ‘step-outs’ are generally considered to be non value-added, uncompetitive business models. As such, firms that are not directly involved in the execution will not be included in the investment process).
New York under NY SEC Amendment 12A-1 (this states that directed brokerage is banned. The SEC added a new paragraph [h] to rule 12A-1 to prohibit funds from compensating a broker dealer for any promotion or sale of fund shares by directing brokerage transactions to that broker. These amendments also prohibit ‘stepout’ and similar arrangements designed to compensate selling brokers for selling fund shares). Representatives of the Chicago chapter of the NASP confirmed on 8 December 2010 that CSAs and ‘step-out’ arrangements are now outlawed in Illinois for MFDVs.
Finally, MFDV operational efficiencies are of high importance in the face of cross-asset business, and cross-border international equity flow. This covers back office, settlement, custody and clearing, and is intrinsic to the operational efficiencies of an MFDV with respect to taking advantage of the SEC rule 15a-6 for cross-border trade execution and settlement. MFDVs need to be able to reduce costs whilst ensuring a workable regulatory solution.
If MFDVs wish to expand in competitive marketplaces, they may require sell-side participation to ensure international DMA, lower operational and management costs, potentially pure agency trading, assurances of no crossing or internalization of trades, the minimization of counterparty risk (i.e. agency trades have less chance of failure); a provision for a single point of entry for all markets; anonymity for institutional investors (i.e. trading and settlement process protects clients’ identities), and a standard of matching every trade within 24-hours makes T+1.
It is important to note that the MFDV’s operations solutions are very important, as they provide the foundation for the MFDV to sell-side relationship. For the MFDV it ensures that SEC rule 15a-6, which sanctioned brokers to transact international securities on an agency basis adhered to the rules; for the ability for the sell-side to perform the MFDV’s business is proven; ensures minimized MFDV regulatory capital requirements; minimizes sell-side risk capital requirements, and for both sides assuring STP throughout the trade’s life-cycle where execution and settlement costs are minimized (i.e. $5-$15 per ticket, instead of $90-$127 per ticket) ensuring a better ‘bang-for-buck’ on both side of the transaction.
An example of the latter was identified in a statement by the North Carolina Department of State Treasurer (NCDST) who through an Ennis Krupp and Associates independent review of the North Carolina MFDV HUB programme found that at least one of their MFDVs had not only the highest traded volumes as compared to the investment managers, but also the lowest commission rates, which made an attractive average market impact cost to NCDST. This led to an increase and a positive usage of MFDVs in their HUB programme.
The latter could not have been done without both the trading and operational efficiencies in place and a global institutional broker with a large execution and custody footprint, who had strengths in the very emerging markets the pension funds wanted to invest in. Looking at the MFDV space in 2011 The potential of the MFDV space can be summed up by a quote from Ted Krum CFP, VP, Portfolio Management, and Northern Trust Global Advisors. In his article ‘Insights on … Emerging Managers Hold Their Edge vs Elephants’, he states: “We hear over and over again that institutional clients hire the largest firms because they view them as safer than emerging managers. In reality, this decision is just another over-crowded trade that may expose clients to excess volatility and nasty surprises, without adequate compensation in terms of full life-cycle performance.
Investors who limit their large cap exposure to just the large and mega-managers (AUM > $33bn) are missing out on 78% of the manager opportunities and 61% of the products on the market .” While there has been much ‘handwringing’ in the financial press concerning the funding and liability issues facing pension funds, the likelihood that these entities will disappear any time soon seems remote.
Many have strong local political support, and possible avenues of increased funding through various reform strategies. And even if their structure were to be altered from the defined benefit to the defined contribution format, it is quite likely that the mandates will survive that modification. What opportunities will you seek?