OK Frank, thanks for the reply.
Devils advocate #2
My firm have certain preferred products that we use. We like them for their competitiveness in the fee area whilst maintaining a high level of usability and ease of reporting etc.
Extending your logic does this constitute pooling? We have never been a big enough group to receive volume discounts etc but I know they are available in the industry. If a dealer group promotes certain platforms/products to their adviser base because they will then receive a volume discount and therefore make more from the product helping cover costs, can that be argued to be a UMIS in disguise?
There is much talk about these behind the scenes discounts as "ripping off the client" and that any discount should be passed on. My understanding is that if it was passed on then some other fee would need to be increased as the licencee must remain profitable to retain the licence.
Plus is it all that different from an industry fund who automatically gets access to the full pool of monies from members and can negotiate a special price with a fund manager to manage the monies? One gets a discount if they hit certain hurdles, the other walks in with an amount already over the hurdles and negotiates the discount up front.
I guess the other question is exactly what is it in the agreement that you feel triggers a pooling situation? Is it the use of the valuation software? Is it the extra LVR? Storm had so many varied client situations as explained, how many fell under the CBA Home Loan / Colonial Margin Loan combination?
I ask this because if the extra LVR is the supposed trigger I could argue that any agreement made no difference to the advice. Storm always geared clients up to 50% or there abouts unless the client specifically requested a lower LVR. The change in the Margin Call LVR did not result in Storm recommending more borrowing in their advice, it was simply sold as additional "protection" they had arranged.
If I go to our providers and negotiate a better deal in some form for our clients (extra protection, lower fees etc) does that automatically mean I have entered into a UMIS?
Devils advocate #2
My firm have certain preferred products that we use. We like them for their competitiveness in the fee area whilst maintaining a high level of usability and ease of reporting etc.
Extending your logic does this constitute pooling? We have never been a big enough group to receive volume discounts etc but I know they are available in the industry. If a dealer group promotes certain platforms/products to their adviser base because they will then receive a volume discount and therefore make more from the product helping cover costs, can that be argued to be a UMIS in disguise?
There is much talk about these behind the scenes discounts as "ripping off the client" and that any discount should be passed on. My understanding is that if it was passed on then some other fee would need to be increased as the licencee must remain profitable to retain the licence.
Plus is it all that different from an industry fund who automatically gets access to the full pool of monies from members and can negotiate a special price with a fund manager to manage the monies? One gets a discount if they hit certain hurdles, the other walks in with an amount already over the hurdles and negotiates the discount up front.
I guess the other question is exactly what is it in the agreement that you feel triggers a pooling situation? Is it the use of the valuation software? Is it the extra LVR? Storm had so many varied client situations as explained, how many fell under the CBA Home Loan / Colonial Margin Loan combination?
I ask this because if the extra LVR is the supposed trigger I could argue that any agreement made no difference to the advice. Storm always geared clients up to 50% or there abouts unless the client specifically requested a lower LVR. The change in the Margin Call LVR did not result in Storm recommending more borrowing in their advice, it was simply sold as additional "protection" they had arranged.
If I go to our providers and negotiate a better deal in some form for our clients (extra protection, lower fees etc) does that automatically mean I have entered into a UMIS?