A thematic review: Room for development in reporting the costs of investment services and products to clients

In 2022, the Financial Supervisory Authority (FIN-FSA) conducted a thematic review on the reporting of the costs of investment services and products to clients. The thematic review was part of a Common Supervisory Action (CSA) coordinated by the European Securities and Markets Authority (ESMA).

Clients must receive information, at least on an annual basis, on the realised overall costs of their investment services and products as well as their impact on the return (so-called ex-post cost disclosure). Furthermore, clients must be given a more detailed breakdown at request.

The objective of the thematic review was to assess whether credit institutions providing investment services and investment firms (hereinafter firms) comply with the disclosure obligations in reporting to their clients:

• the costs and charges and
• fees (inducements) received by the firm from other parties, such as fund sales commissions.

Eight firms participated in the thematic review by responding to a written survey and submitting a sample of their clients’ cost reports to the FIN-FSA for scrutiny.

In the FIN-FSA's view, the presentation of the reports was mainly consistent with regulatory requirements, although there was variation among the companies in the way of presentation.

Room for development in cost reporting was found particularly in the following areas:

• FIN-FSA recommends that firms report the annual costs sooner, within three months of the end of the reporting period.
• If a firm reports the costs of investment services on an aggregated basis and the costs of products on an aggregated basis, clients should be informed of the possibility to request a more detailed breakdown.
• Most of the firms could improve the description of fluctuation in the level of costs and the effect of costs on return.
• Some of the firms should define additional services involving inducements in more detail
• All the firms lacked either adequate internal guidelines on cost reporting and/or inducements. Even if a firm had guidelines concerning cost reporting, it did not necessarily indicate all costs that are reported.
   

The FIN-FSA’s findings will require all eight firms to take actions, which will be monitored by the FIN-FSA. The FIN-FSA also requires that other parties providing investment services consider the findings and opinions pointed out by the FIN-FSA in the supervision letter and take requisite actions.

The FIN-FSA will report on the findings and conclusions to ESMA as part of its supervisory action on cost reporting. ESMA may provide more detailed guidelines on the subject to firms or national supervisors.

For further information, please contact:

• Merja Junnonen, Legal Counsel, tel. +358 9 183 5554 or merja.junnonen(at)fiva.fi
• Esa Pitkänen, Senior Policy Advisor, tel. +358 9 183 5248 or esa.pitkanen(at)fiva.fi
• Riitta Seppä, Senior Policy Advisor, tel. +358 9 183 5027 or riitta.seppa(at)fiva.fi

Appendix

*Supervision letter: Thematic review on the reporting of the costs of investment services and products to clients

^{*The appendix has been changed on 15th February 2023}