Broadridge Financial Solutions, Inc. (BR) Earnings Call Transcript & Summary

Hello, and welcome to Broadridge's webinar on Consumer Duty. We thank you all for joining us today. My name is Devin McCune. I run Broadridge's Regulatory and Compliance business and oversee our consumer duties and assessment of value product offerings. With me today I have a very special guest, Holly Mackay, Founder and CEO of Boring Money. As was recently announced, Boring Money and Broadridge will be partnering together to help asset managers solve some of their challenges they face with consumer duty. And really that is our intent today is to dive into some of those challenges that we've heard and try and help you with some of those solutions. Holly, maybe you'd like to do a brief introduction of yourself and Boring Money for those in the audience who are not aware of who you are?

Sure. And good morning to viewers in North America. Good afternoon to those of us in Europe. And for those of you who don't know Boring Money, I founded it back in 2015. Boring Money is an information business. So on the one hand, on the B2C side of things, we help consumers to make better choices with their money. We do this with comparison tables and content primarily, on the B2B side, we have a Research Business, which supports the industry both with qualitative and quantitative research to better understand their end investor, the voice of the customer.

Excellent. Thank you, Holly. Before we dive into a lot of what we want to focus on today, which are solutions around Consumer Duty, we do want to spend a little bit of time on what Consumer Duty is? Our assumption is most people, if you're joining us have some degree of background. So we're not going to spend a significant amount of time on Consumer Duty itself. However, and sorry, we're having some problems with slides here, but we'll get it taken care of. Consumer Duty essentially has 4 key outcomes that everybody along with the distribution chain needs to focus on. Today, we're really going to focus on the Asset Managers and their responsibilities looking at those 4 key outcomes, which is products and services, price and value, consumer understanding and consumer support. And I think where we'll spend a bit more of our time today is really on number 3 and 4 of those, which is consumer understanding and consumer support. There is a reasonable amount of data around products and services and the price value piece out in the market today. But what seems to have been missing all along is information on what the end investor actually feels what the end investor is actually thinking, and this is where the Boring Money content becomes very valuable and where we at Broadridge feel combining that with some of the price and value and product services information can really help improve the Consumer Duty review for asset managers. And of equal, if not more importance, is create better outcomes for the end investor, which, as we all know, is what the FCA is really looking for is that those better outcomes for the investors. So we'll really focus a lot of our time, I think, on consumer understanding and consumer support. As we dive into this, the first piece we'd like to do is ask some of the audience what -- which of the below questions or areas are most difficult to you. Holly and I as well as many of our colleagues are out constantly talking to asset managers, and we hear some continuous themes about this. But we would absolutely like to get some feedback from each of you on which areas are the most difficult and challenging for you as you think about it in light of Consumer Duty. So understanding your retail investor as an intermediated manufacturer struggling with limited resource and people to deliver boards and manage reporting related to Consumer Duty, sourcing data from distributors directly. One that I hear quite frequently is understanding vulnerable customers, and the final question or final potential answer is working out what to do with all your data, translating data into action. And this is another one that I seem to hear 7 or 8 times a day in meetings with clients what we see. So I see we are starting to get some responses into this. So we'll keep the poll open for just another 30 seconds or so, and then we'll start to try and interpret and discern what our audience is thinking, Holly.

I'm not going to preempt it, Devin, and have a guess. I'll behave myself and wait to see and not leave the witness.

Okay. And, we'll give you just another couple of seconds. Please finish up your voting if you're online, it looks like we're getting pretty reasonable response rates. And we're going to click over here. And so the biggest challenge that we're seeing is sourcing data from distributors. But Holly, what are your thoughts on the answers that we're getting here from the audience?

I'm not entirely surprised that, that is what people are saying is giving them angst at the moment. We hear a lot about the DFT. We hear a lot about the challenges the Asset Managers face in getting that data from the distributor. So I'm not entirely surprised by that, Devin. I am, however, I wonder a challenge, I think, for the industry is by jumping to something that is a problem with the distributors. I wonder instead if there could be more sort of analysis internally of what can we do because we know that DFT is going to take some years as a reality to start working well and start delivering. For me, Devin it's a question of what can we do proactively today that helps us to better understand our retail investor because that is what the data is for. It's not data for data [ seekers ]. So for me, I would have hoped perhaps to see more on the understanding of the retail investor. Because I went back to the policy statement from the FCA yesterday, sort of dug out PS-22/9 again, Devin, and was looking through there. And the third paragraph on the very first page, point 1.3: Firms need to understand their customers' needs, so they get good outcomes. And I think a massive challenge that the asset management industry faces is if you imagine them talking to their retail investor, most of them feel like they're talking to someone with a paper bag over their head. They don't have a picture of the end investor. They can't answer the Board's questions about what does that end investor actually look like. And so for me, that has to be the starting point because otherwise, it becomes very difficult to know and to understand, I think, where to pinpoint change where to lead improvements if you don't have that view of the end investor. So no, I'm not surprised that data is highlighted there the problems with the distributors. But I think there are things that the asset managers that will cover in part in this webinar, Devin, could be doing now to help solve that problem without waiting for the distributors.

Very much agreed. And one of the most common themes I've heard is from those manufacturers, which are the vast majority in reality, they are intermediated, they -- they are challenged by where their responsibility ends and where the intermediaries ends or begins and ends? And how do they get meaningful date, one of the questions I've started asking folks is, how much do you know about your end investor and whether the vast majority of their assets come in from an advise channel or from a guidance channel, execution-only channel. The common answer I get is just about zero. And to your point, if you know just about zero about that end investor, it's very hard to make sure that the outcomes you're creating are suitable and beneficial for them. And that really seems to be the most common theme. And I agree with you that understanding that is a key component, and maybe the biggest challenge the people are facing is hearing what that end investor really thinks thus far. It has been a challenge getting that type of information back. And then equally, what do I do with that once I have that information, obviously, is a question. I know you and I have talked about many times and hopefully is an area that we can help support people in. Vulnerable investors was an interesting one as I looked at those results, it was a bit lower than I thought based on conversations I've had, and equally, the importance that the FCA has put on vulnerable investors during some of their conversations or letters, what are your thoughts on the low focus on vulnerable investors, Holly?

I think this has been something that has been a problem for the asset managers in terms of how do they go about solving this? How do they go about fixing it? But I think one thing I do hear, Devin, from Asset Managers is perhaps an oversimplification of what vulnerable investor is. I think there's a tendency to think a vulnerable investor is possibly someone who's very old or a vulnerable investor might be some that can't read clearly or has special problems. And so a lot of the groups I've talked to have spent time, for example, looking at fund sizes or tackling something quite specific, but the problem is larger and in data we sourced in January just this year, so very recent data. If we look at the FCA's criteria of vulnerable investors, 27% of fund investors display one of those characteristics. So these are our clients. This is something that is very relevant. And just to pick out one sort of smaller example there. 8% of Asset Management customers are experiencing some sort of financial vulnerability today. So I think there's a tendency as well to think that fund investors are more affluent and that don't face those problems. So I think this is something where I hear the [ mood ] music coming out of the FCA is increasingly sort of hot. I think it's an area they're going to come back to, and I think it is an area that is underestimated by Asset Managers or indeed, there's a slight sense of helplessness and not quite knowing what it is they can do to help those particular investors.

Excellent. Thank you. A couple of housekeeping notes that I forgot at the beginning, I apologize. First of all, there is an opportunity to ask questions using the online tool we're using. We will try to answer as many of those at the end. If we're not unable to answer all the questions during the actual presentation today, we will provide some sort of synopsis and response back post the session. So just for anybody interested in that. We do want to move on now a little bit and talk about what Boring Money and Broadridge are doing together to help solve some of these problems, to set the stage for that, we're each going to spend a little bit of time with some of the methodology on the Data that we have, and then we'll start to show how it works. From the Broadridge perspective, we're really looking at asset managers and specific funds from that price and value perspective, at least initially. And we have created an analysis that we call the PERC score. Performance, Expense, Risk, and Consistency. So it looks at those 4 attributes of the Fund, allowing us to evaluate the price and value that a particular product is giving and then we can aggregate that up to look at the fund -- or the complex overall, and we gave it what we call the PERC score. And what that does is it's a client driven model that as a Fund Company has hypothetically, high relative returns, low relative expenses, low relative risk and high consistency. That would be theoretically the best fund out there. And so we've ranked all funds and asset managers using this PERC score. And combining that then with the information from Boring Money we can start to say where there is a perception gap. So where do investors say an Asset Manager is performing very well, but the quantitative data says they're probably not performing well or vice versa. So we'll look into that. But essentially, what we're looking at is 5-year return typically expenses versus a comparison group, risk over that same 5-year period and consistency of returns. So think of that as volatility to create that overall PERC score. Holly, maybe I'll turn it over to you very quickly to explain the methodology and how you're collecting your data from the end investor, and then we'll dive into the actual prototype.

So we go directly to end investors, Devin. So we go every year to over 6,000 fund investors and we capture data from them. And we also ask some questions pertaining to value, price, performance, quality of service, other metrics, about 30 leading retail brands today. So essentially, we're collecting data on a bottom-up basis. Asset Managers going to distribute us, they're collecting it on a sort of top-down basis. But we're going directly to end investors and capturing their thoughts on asset management brands from them. We also have a proprietary panel that's currently sitting around 4,200 fund investors. So we are able to do and follow up with qualitative work should we want to with particular Asset Managers to dive into things in a bit more detail. What we might do then, Devin, is just give people some oversight. So this is data that we are finding out on behalf of our clients today, so that they don't have to rely on the distributors, they go direct to the customer and find out some things about them. We collect data, for example, on age. You can see here, we've modeled something for a fund group. We've just called Fund Group A here. We can look at the segmentation of these customers, we can see, for example, Fund Group A, they have a higher proportion of retired investors than the average 27% of their investors, whether advised or non-advised are over 65. We can look at household income, we also capture assets as well. So we can see a picture of whether as with Fund Company A, for example, they have more customers who are relatively well. We capture Gender, and we also capture Advise data. So already, Devin, just with this one slide, we are able to say Fund Company A you have a slightly older customer base than the average. You have a wealthier customer base. They're much more likely to be men than the average, 78% of all your customers are men and then compared to an average of 64%. And they're quite likely to be DIY investors. So over 60% of them are going direct. That immediately, Devin, starts to tell me that this is a more savvy customer base. It's a more affluent customer base. And when it comes to value scores, we, therefore, know they're a harder customer base to please, they're going to be more critical. Looking to the next slide. We have added to this data specifically Devin for consumer duty, and we want to find out more about time frames, loss and risk. We're asking customers about the fund holding periods. So we can see for Fund Company A that about 40% of their customers report having holding periods of 5 years or less. We can also see that the self-reported risk profile for those investors, 40% of Fund Company As customers are saying that they are in a higher risk profile. Again, that is higher than average. It starts to complement the picture we saw on the previous slide, Devin, of an older, more savvy, confident male, more affluent investor with a higher risk profile. We're getting a picture here. And then we're looking at to go along with some of the vulnerable data we're capturing later. We're looking at capacity for loss. So we ask people how much of a material impact it would have on their financial situation if this fund work to lose money. And we can see here about 1 in 5 investors would. So what we're starting to do by going directly to the investors rather than waiting and relying on the distributors is we're removing that paper bag, Devin, I talked about earlier. And we're starting to be able to get Board's, to be able to give companies a clear sense of who their customers are, but also because of consumer duty to help them understand time frames, sort of objectives and, therefore, start to be able to evidence what good outcomes might look like.

Yes. As I started to look at this data, there's a few things that I find very interesting. The first is the advice versus the non-advice data. That starts to really provide evidence to an asset manager, a fund company where there may be challenges or how much of their materials are being used. So if it's a guidance only channel, very highly likely that the fact sheets that are appearing on that are -- or fact sheets, the ones that you created. So again, while you're intermediated and you may not know that end investor, they're relying on your information that are relying on your expertise. And this is why, for one reason, I find this so very important. The other piece that I find very interesting is how long investors are anticipating holding funds and what their risk profile is? And I think if you start to couple this when we get data from the DFT back, some of those questions around what the churn rate is. So how quickly shares were sold in less than 1 year or 1 to 3 years. This can confirm whether that is a problem or whether that fits in with what the investors' expectation and time frame is. And so one of the challenges I think we as an industry have is, one, you can't get any of the 4 criteria in a silo, you likely need to look at them as a collective; and number two, you need to have data from various angles to fully interpret it. And so this is where the content that you have is very valuable and will become even more valuable as we start to get information back from the DFT and we get more and more meaningful data back from the DFT. It will really allow fund companies to understand and analyze where the true challenges are versus where there may be some [ smoking mirrors ] with some of those challenges. Next, we want to move on and look at how investors may [ foresee ] value or where these perception gaps may exist? I recognize looking at this chart at the beginning is a little bit confusing. We call this a spaghetti chart. It's an uncooked spaghetti chart because it just shows 1 time period. But on the left-hand side, we see how investors have rated specific fund companies that Boring Money tracks from an investor perspective. And so if you look at the top of the chart, we see a large global passive brand manager, has the highest rankings from the Boring Money audience, ranking very well. We see U.K. wealth manager won in the second spot and so on. And so this is all from an investor perception standpoint. And this is from my view, and Consumer Duty highly, highly important that we look at. On the right-hand side, what we see is those same Asset Managers and their rankings based off Broadridge's PERC score, that quantitative rating. And this is where things become a little bit more interesting. The top spot is still held by the same asset manager, the large global passive brand. So they're probably sitting in a pretty good spot. They can certainly spend some time reviewing and making sure they're executing well, but there's not as much confusion there. However, when you look at U.K. Wealth Manager won and ranks second according to investor perceptions, when you look at it from the quantitative perspective using that PERC score, they're down about -- they're down in the 21st or 22nd spot in our league tables. So there is a gap there in what investors feel is good quality of service and good service overall, good value versus what quantitative rankings are. Conversely, if you look towards the bottom of the league table on the left-hand side, North American Asset Manager won, they are ranking towards the bottom in the 25th spot. However, when you look at it from the quantitative perspective, they ranked quite well in the Broadridge ratings. And so what this starts to indicate to us is that there is a perception gap with those 2 asset managers and obviously, there's some others on here, where there's a perception gap and that really, the intent of this is to really allow folks on the fund company side to say what may be driving that? So this is really just the first slice of the data that we have, but yes, we probably do have a perception gap. We need to understand what is driving that is really where we want to get to with the analysis that we are providing to fund companies. Holly, any thoughts on this before we dive into maybe some of the specific content areas?

I think for me, Devin, this is -- this, for me, is the executive summary. With 5 of us, sort of, sitting on the Board. I think there are sort of 4 counts of asset managers. There are those who fall into the top half from both the investor perception and your product data, that is a comfortable place to be. There is some who fall in the bottom camp, both when it comes to what their customers say about them and what your product data tells us. That's an uncomfortable place to be where there are structural issues that need to be addressed, and then there are those who all sort of -- that might be doing very well, as you said, with the end customer, but less with your data. And for me, this is sort of answering. This is starting to get the heart of when people are saying to us, yes, okay, this data is great. But what are we actually going to do with that? This points to the core issues. One example, I'll just touch on is we have tracked the last 5 years of brand, which is perennially popular with end investors. The end investors report overall good value, but they are very unhappy about the fees and charges. When we look at your data for the funds of that particular Asset Manager, they are proportionately more expensive compared to peers. So we can start to quite quickly identify the pain point. At the same time, we're saying, well, actually, for the Asset Manager overall, the customers are still ranking them as delivering good value, even though they are expensive. And I think that's an important part of the conversation. So for me, this is I almost see your "spaghetti chart" Devin as we call it as the executive summary, which one of those sort of bands am I in? Okay? what do I need to do about?

Absolutely. And let's dive into that. So, on this slide, we have an example of performance and quality of service or quality of service using performance as a proxy there. On the left-hand side, we showed the Broadridge rankings. And you can see this particular Asset Manager versus a peer group of 8 other asset managers, ranks right in the middle. But when you look at the data versus all the Asset Managers that are tracked by Boring Money, they're right at that border region of second to third quintile, so right about the 40th percentile. So pretty reasonable performance overall, and this is an aggregated value across all of their funds. We can dive into fund level here in a couple of minutes. What you also see is that they have slightly higher risk than both their peers and the industry average ranking in the fourth quintile. And for consistency versus their peer group, they're a little less consistent, but they actually sit right at the median of the overall industry average. So that from a quantitative perspective tells us a lot about this Asset Manager, and this is the same fund company A, that we looked at earlier. Again, their investors highlighted that they would take on more risk. So there is some unwinding myth here. Those investors say they're willing to accept more risk and we are seeing greater risk here. What becomes interesting is when you start to look at the information from Boring Money, again, we start to see that this fund company ranking towards the middle of the league table in terms of overall investor perception on performance, with a significant number, a relatively large number, about 23% of respondents rating the performance in a negative. And so this starts to tell us that there may be challenges with some of the performance pieces even though on a quantitative measure, they're not ranking too poorly. So there is some work that needs to be done to make from my perspective, at least, to make sure investors really understand what they're buying in terms of the performance, what the performance is going to look like. Holly, from your perspective, what jumps out at this chart with you?

What I see when I look at this slide is broadly speaking. If you look at the overall position of Fund company A, which is plus 4% net, if you look at their overall sort of investor sentiment for performance that broadly tells me they're tracking alongside what your data tells us we would expect to see. So it tells me that their customers have a pretty good sense of how they are, in fact, delivering value when it comes to performance. So for me, as a sort of no red flags that I take from that. One comment I will add, Devin, is we've touched very briefly here on quality of service. As we're talking to groups who are reviewing the assessment of value, quality of service is one metric has been very difficult for asset managers to report back on. I think groups have tended to report back on hygiene factors such as having 24/7 online access or a call center or however many thousand global staff they have. We also capture from end investors a quality of service metric. And when we talk to end investors about value, and of course, as part of Consumer Duty, sort of fair value very much under the spotlight. When we look at the overall weighting for end investors of value, what are the component parts. Quality of service is the fourth most important component part and from the perception of an end investor makes up 18% of total value delivered by a fund for interest charges is 23% of the total performance, 22% of the total. So quality of service is interesting because it's a really key metric for end investors. It's one which the industry struggled, I think, to report on, but it's one where we do capture that metric from the end investors.

I think that is one of the biggest challenges we have is -- and each investor is going to have their own definition of value, which creates even more complexity was really answering that. Let's move on to the cost of funds. And so here, again, very similar data, and we have, in this case, at least broken it out by asset class. But overall, we see that fund company A costs versus peers versus the industry are relatively well in line. So costs are below median across the Board for all asset classes typically ranking second versus the peer group, and again in the second quintile versus everybody else out there. What we do find very interesting or what I found very interesting is when we look on the right-hand side of the chart and using the responses from actual investors, we see that this Asset Manager actually ranks [ tied ] for the bottom. So investors feel that it's charging too much, and it has a large percentage of negative votes. So 36% of respondents say that it's charging, it's costs are high. And so there is definitely a perception gap here between what the quantitative data says and what the qualitative data says. And if I were sat on this Fund Company's Board or in management there, I would really want to focus on what the investors are experiencing? What the investors' thoughts are related to my costs, try and better explain that through some of our materials. Holly, again, what are your thoughts on cost side of the equation with the particular asset?

Yes. What this slide tells me immediately is that the customers of company A are being unduly arched about the fees and charges. 36% of its customers are scoring it and 6 or less out of 10 when it comes to the cost. What I would do, Devin sort of one step further, perhaps is this tells me it is not a problem with communicating the absolute fees. It is a problem with not communicating the relative cost. So I'll give you an example. Instead of telling people the fund, let's be generous, it's an active fund that cost 60 basis points, instead of going, we cost 60 basis points. It's probably more a question of communicating saying for every GBP 1,000 you have invested, we charge you an ongoing fee of GBP 6 a year. That's [ GBP 1.50 ] less than the average active manager, for example. Do you see what I mean is it's what's missing here is the education for that particular customer of this particular company that the fees are and as your data shows indeed competitive, but that is not understood. So it's a marketing issue. This tells me rather than a product issue, if that makes sense?

Agreed very much. So next, we want to move on to at least an area of interest to me and I'll sit back and let Holly explain the data here, but vulnerable investors. Again, this is an area where we know the FCA is focused a lot of time and attention. I know from conversations, I've had with Asset Managers, they have a lot of questions about vulnerable investors. And this is where I find some of the data from Boring Money, especially interesting because they have dug in and identified various types of vulnerable investors. So Holly, maybe you can spend a couple of minutes here?

Yes. For me, as I said at the beginning, perhaps a surprising thing for me when we start to look into this is the high -- the relatively high proportion of fund investors who report some sort of vulnerability as I said at the beginning, currently, as -- at January this year, 27% of asset management customers have some sort of a vulnerable characteristic. I know from working with some of our asset management clients that people have struggled with proportionality. Where do we start? How far do we go on this? How can we possibly help people with all these types of vulnerability, and as I said, and I didn't mean it [ sound flippant ] earlier, I meant it genuinely, I think people typically have focused on from sizes, or is the website sort of readable and have sort of struggled beyond that to go -- how do we help people? Where do we need focus? For me, when you look at the main causes of vulnerability for asset management customers, it is around mental health, particularly anxiety and it is around financial vulnerability. What that points to me, Devin, perhaps more than targeting and how can we support people with physical disabilities where there's lower amounts of people reporting that they need extra support. It actually goes to communication around objectives, risk and time frames because that is where the misalignment or a poor understanding of that will exacerbate that financial vulnerability or the anxiety that we sort of see reported there through mental health. So that's an example of how by actually understanding where we can help our customers to get a picture of this for their particular investors or their particular sort of reported vulnerabilities are, and then start to target. This goes again to what point where they can help? And particularly, as I've said, for financial vulnerability. It's all about helping people to make sure that their time frames, desired outcomes are aligned with the particular product that they're buying. The good news as well, Devin, is that by focusing on that, you're also addressing one of the main problems that all retail investors have when it comes to Asset Managers. So I think a lot of thinking and work needs to be done, not just confirm it [ rises ], but also on making sure that those time frames, the objectives and risk are really better articulated than they are in many instances today.

As I looked at this for the first time a couple of weeks ago, the 2 that were most intriguing to me, because I will admit, I think I took the perspective that you highlighted a lot of asset managers did, was looking at physical and mental disabilities, but the financial vulnerability and low confidence in choosing an investment product are really ones that we as an industry can do a lot to support Asset Managers on and coupling that quantitative with this qualitative data can be very powerful with that. So if we have an asset manager that wants to be a higher risk, higher return company, that's fine. That's wonderful. But they should then in those marketing materials in what they're doing, make that very clear for those who are financially vulnerable, it should be very easy to understand that, that is a challenge. One of the other pieces that you just highlighted is a lot of what we look at is retrospective. And one of the interesting pieces, Holly, that you and your team at Boring Money have is you actually asked some questions about where people think they're going to go. And I think this can be equally as powerful for the asset manager to really understand where we are going from an investor standpoint. Again, we all can sit in the industry and say, well, we think equities are going to have a great year or we think bonds are going to do wonderful this year. But it's really interesting to see what you have on this chart, which is where investors thinking they're going to invest in this. This shows it both historically and gives us some idea of where we think we're going to go in the future. Maybe a couple of seconds on this as well.

What I wanted to highlight this slide is clearly investor understanding and decision-making is a key part of what the regulator is trying to achieve or improve with consumer duty. I highlight this here. If you've got the bar in dark blue, that was when we were asking this question at the end of 2020. The light green bar is at the end of last year. And this is saying to people, which are the following sectors are you considering increasing holdings in the next 6 months? The basic trend we see, I want to highlight here is it has fallen dramatically across the board. Now that tells me across all the asset classes, people have a lack of conviction. That tells me people are confused. And that sort of [indiscernible] what we're seeing at the moment, the world is a particularly battling place, I think, at the moment, Devin, and investors are feeling that. And that tells me that, that need for communication for health sort of guidance for content is stronger than it's been for the sort of previous 4 years. This chart to me shows most clear [indiscernible] and more interestingly than what we might see about any one asset. Is that lack of conviction, is that lack of uncertainty? And that to me tells me, it's a time where communication with good content, where comes are more in demand and more interesting than they have been before.

I want to take a deep dive here into a particular asset manager and couple of their funds. And Holly, we should probably try and be relatively quick on this so we can get to some of the questions that are absolutely pouring in. But this takes what we've been talking about on a macro level or an asset Manager Level and starts to look at it on a fund-specific level. And for this, we've really just focused on the value for investors have given on the bottom versus the fund's actual returns for the preceding 1-year period onto rolling quarterly basis. What really jumps out to me on this is -- in some cases, there's a correlation, great returns the previous quarter, the next quarter or the value ratings go up. In other cases, there's not. Which is interesting. It shows that the time series of information is probably important, understanding the full market dynamics, but I also think it's important for asset managers as we start to build this out to look at it on an asset class or a geographic perspective because that really can be driving some of the investor understanding -- the customer understanding on this. Do they not understand the market very well, and so their perception of value is challenged by this. This is where the time series and looking at this for a broader spectrum of funds can be very interesting and beneficial. Holly, your thoughts on this? Holly?

What I would say as well, Devin, this is where it goes back to understanding who is my end customer. What we see when we're looking at this is that the more confident the customer base of an asset manager, the more quick -- closer aligned their reactions, so and so overperformance are, but the less confident that customer base, the less sophisticated customer base it tends to take sort of between 6 and 9 months of that awareness to go through. So as you say, definitely something we want to track and explore those correlations to different Asset Managers. And our proprietary panel of over 4,000 investors can really help us if we want to supplement this with some qualitative interviews at individual fund level to really get into the sort of what is driving investor perceptions around this particular fund.

Okay. Holly and I are both fans of, the so what? So what does all this mean? How can we make this actionable? And I think one of the biggest pieces for asset managers in this case is by understanding who the end investor is, whether they're advised or execution only, what their risk tolerances are, I think you really can start to then gain perspective on how you should position your products, what type of marketing and educational pieces you should get out of it? I know Holly and her team ask about what type of education pieces, people like the best, whether it be podcasts, written materials, et cetera. There's a wealth of information that can really help you build this out to support that customer understanding. So that's one of the biggest pieces that I think helps the asset manager against this. A second one that's very interesting to me is that benchmarking the investor perception versus, what I'll say, your own perception of yourself using that quantitative data. As I've dug into the data, there are a lot where there is misalignment and understanding that and beginning to try and narrow that gap, I think, is very important. For folks on the asset management side to help ensure that customers are getting the positive outcomes that the FCA is looking for Holly. Your thoughts on any of the ways that we can help take all this data and make it actionable and not just data that sits on someone's computer?

I think from me, the sort of interesting part, as you've said, is what happens when you compare what your end customers say, and just to pick up one of the questions when we're looking at end customers, it is both advised and DIY investors. It is a representative sample of your customers. It's looking a bit the differences between what they say and then what your data tell us that, to me, is crucial bit of the picture for asset managers who seem to be, this is a baffling task and dealing with consumer duty has taken a huge amount of resource. I think asset managers and looking at this enormous field going, where do we dip, where do we focus? Where do we start? And so that's sort of looking at both what your customer is saying about you and what they think about value, but what your data tells us from a product perspective is key and is super interesting. Just quickly a question but a few questions are coming around sort of vulnerable customers. When we're asking people, we don't, people tend to not self-identify as vulnerable. We ask them where they feel they would benefit from extra support from an asset manager in relation to, and we give them a list of criteria, but happy to pick up more detailed questions on that later.

Yes. One of other...

Sorry, Devin [indiscernible] to answering your question?

That's absolutely okay. That's where we were going, and we are at time, but I want to get one other question in really quickly. And it looks like a lot of people have voted for it, which is why I'm going to hit this one. What criteria should firms use to assess and prioritize potential foreseeable harm? And also which criteria they should use to assess whether good outcomes have been achieved. I don't think you can come up with a simple yes? no? And I think this is where admittedly, the FCA has put a hard task in front of Asset Managers. But some of the data, I think, that becomes a very telling allows you to understand that. So again, some of the information Holly showed at the beginning on the demographics, what types of accounts money is in. So is it being used for pension? Or is it an ISA and then what the investors time frame is. And looking at that collectively once you're on or a set of your funds allows you to make some reasonable assumptions about investor -- what the investors are expecting and then you can make some reasonable assumptions about what a good outcome is? So if you see using that data to from Holly's team that most investors are in SIPs investing in your product, you can make the assumption based off the age piece that they're going to be holding that in your -- those accounts for a longer period of time. And so their outcomes would be different than someone who expects to use that money in the relatively shorter time period. And so you're going to -- there is an interpretation of this data that's important, but I don't think with any of this, there is a simple yes, no good outcome, bad outcome, vulnerable investor, nonvulnerable investor, there is interpretation that you have to go on. And this is why, again, I think you need the quantitative data, the information from the end investor as we start getting DFT data back in analyzing that versus other components so that you're really triangulating the measurements to put together a best practice in place. Holly, any last thoughts on that question before we conclude?

No. I think we're coming up to time. I think for me, it's not about 4 legs, good 2 legs bad. I think it is about prioritization, right? There's so much that we could all do to improve, but I think for me, this is an evidence-based way to be super clear on what the sort of 5 tasks that you're going to focus on as a Board or what the kind of outcomes that the marketing team are taking? Where are you focusing and why? And that's where I think this can help give you an achievable plan without trying to boil the ocean.

Excellent. Holly, first of all, thank you for joining us today. It's been very insightful for me. As always, Hopefully, our audience has enjoyed it. To everyone in the audience, thank you very much for taking the time and listening. Again, we will get responses back to the numerous questions that have come in throughout this. Also, there will be a short survey that's available to take at the end of this presentation. So please take a couple of minutes to fill that out. And to everybody behind the scenes who has made this success. Thank you very much for helping Holly and I look like we know what we're doing from the technical side behind the scenes. Have a good day, everyone.