국경 간 펀드 분배의 미래

### 국경 간 자금 분배의 미래: 주요 트렌드와 혼란
* 🌍 해외 펀드 유통은 주로 룩셈부르크와 더블린에 본사를 두고 있으며 **미국 외 지역에서 글로벌 펀드 시장의 지배적인 브랜드**가 된 **UCITS 판매에 주력**하고 있습니다.
* 💰 현재 유럽(프랑스, 독일, 스페인, 이탈리아, 영국)과 아시아(대만, 한국, 일본, 싱가포르, 홍콩)를 주요 시장으로 하는 **UCITS 상품은 7조 1,000억 달러 규모**를 형성하고 있습니다.
* 📜 MiFID II 규정은 **유인 행위의 부분적 금지, 투자자 보호 강화, 투명성 요건**을 도입하여 비즈니스 모델을 검토해야 하는 제조업체와 유통업체 모두에게 영향을 미칩니다.
* 🎯 또한 판매사는 **투자자가 부담하는 비용과 수수료가 명시된 개인별 보고서**를 각 투자자에게 보내야 합니다.
* 🔒 MiFID II의 상품 거버넌스에 따라 제조업체는 각 제품의 **목표 시장을 식별**하여 유통업체가 각 투자자에 대한 적합성 테스트를 수행하도록 의무화합니다.
* 📈 타겟투증권(T2S)과 자본시장연합(CMU)과 같은 긍정적인 발전은 유럽에서 **국경 간 펀드 유통 프로세스를 간소화**하는 것을 목표로 합니다.
* 🤖 디지털 투자자 여권, 로보 어드바이저와 같은 기술 혁신이 **유통 환경을 재편**할 것으로 예상됩니다.
* 🎓 기술에 능숙하고 소셜 네트워크에 익숙한 밀레니얼 세대의 참여를 유도하고 유지하는 것은 **펀드 유통 업계에 중요한 과제**입니다.

국경 간 펀드 유통의 미래는 규제, 시장 표준, 기술 혁신, 경쟁의 영향을 받아 글로벌 유통 시장을 형성하고 있습니다.

so my topic was disruption in the future. Of course, border fun mark a fun distribution. Today, when we talk about cross-border fun distribution, we essentially talk about selling use. It's mainly domiciled in Luxembourg and Dublin across, you know, other nations, are the regions in the world. Usage has, over the past thirty years, become a very strong brand that dominates the global fund market outside of the US. And if you want to, I mean, uses can be really sold anywhere in the world, again, outside of the US. And you see, by the size of the bubble, you know, still uses is mainly sold within Europe, across Europe. The bubble is so big that you can't really see it effectively, but you can also sell it in Asia, the Middle East, South Africa, Africa, and Latin America, and really stands for investor protection, risk diversification, and efficient supervision, so thereby creating a product that is liked by distribution as it inspires confidence and trust from investors. So maybe just to give you a little idea of the size of the market, so use its products today.

represent seven point one trillion US dollars all domiciled in Europe. The largest markets in Europe would be France, size of the bubble again, France, Germany, Spain, Italy, and the UK. In Asia, it's mainly Taiwan, Korea, Japan, Singapore, and Hong Kong. Now, usage have not been the only products that have benefited from a passport. Actually, in the late AFM deregulation, alternative investment funds have also benefited from a passport, albeit across Europe, not as wide as the USIT's passport, but there is hope that the AF nd passport will live a similar life as the one that was lived by usage. I either will extend outside of Europe to be much more of a global brand. Now, at the moment, there is also in 2018 as the private placement regime in Europe should disappear. I'm saying should because there's discussions to extend that period. Other states outside of the EU might also get access to the passport. So, the countries on top here of the lists are countries that have applied for recognition within that framework, and I must say that in a recent paper of ESMA.

on the 16th of September, the US has a fair chance of getting at least the passport for a certain number of funds, namely alternative funds, only destined to professional investors. So that's good news. That would mean that US investment measures with US funds could distribute the funds through the AF and D passport in the future in Europe. Still a little way ahead, but there is a possibility now. Outside of the US, there is another region where passporting has become a fashion, and that is Asia. There are three passports currently being discussed in Asia. Already existing, implemented, the first one is the China-Hong Kong mutual recognition. So this is really sort of southbound, northbound recognition of funds, very much dependent on the host regulator accepting the other fund, and mainly used today. You can see the number, I think, yeah, there's in total only 42 funds that were accepted by both regulators to be distributed in the other market, but we still think it's a good initiative to look at for the future in order to get access to

distribution, particularly in China. The second Passport, the agency's framework with different participating countries, namely Singapore, Malaysia, and Thailand, has been the oldest passport existing. It had a very difficult start as every regime is very different, so particularly tax treatments, your local legislation, are very different. So for the moment, there are only six funds that have been accepted for distribution, but still the anisa initiative is still worth looking at. And finally, the new passport, the Asia region fund passport, still being discussed to be implemented by the end of 2017, will include Australia, Japan, New Zealand, and South Korea. Thailand and the Philippines might join, but I think what's very interesting outside of the passport in itself is that at the moment, some of the European associations who are obviously fond of promoting use it's in an FMD are advising the EU commission to consider having a sort of interconnectivity with Asian passports, i.e., to create a possibility of mutually recognizing the passport of each other, thereby extending, I would say, the reach of usit's into some of these markets, but also obviously

offering, on the other side, the possibility to those markets to potentially distribute into Europe. And so, a new model might appear in the future, which would be mutually recognized passports between regions, thereby creating a single, or at least less diversified, global distribution market. Now, moving away from the passports and evolutions of cross-border direct/supported distribution, legally, I think I want to look at change. What is driving change for the moment? And I had a very long part of the presentation on a particular regulation, which I have to shorten right now, which is method. So, we think when we look at change, we look at four axes of change that are all interconnected, and you can't really look at one without looking at the other. But one is regulation. I'm going to start with that one, followed by market standards, which are obviously evolving. And here, I've taken a slide that looks quite European, but that could really be shown in any part of the world. Technological innovation was generally associated directly with disruption. And finally, competition, in which we all live.

now if I look at regulation and start with regulation. First, the first regulation I want to look at is method to method. To is the second version of method and post method one. There was a recognition but there was still a large part of mis-selling in after method one and the regulator who particularly looked at investor protection who wanted to introduce many new rules to ensure more transparency and control on the whole distribution chain. So that's really what myth is about for fun distribution. It has lot lots of different applications but this is the part that looks at us. This one I'm gonna skip this one. So when we look at admitted. Basically, it introduces on the one hand side a partial ban of inducements, a greatly increased investor protection, a disclosure requirement, and a lot of new rules that regulate product design and governance. With these new regulations and rules, we will have a very strong impact on both manufacturers and distributors who will effectively have to review their business models and operating models and consequently and if you are anywhere

close to distribution. I think this is the topic that should give you the headache every day until at least the first of January 2018. It's certainly the case of the clients we talk to. So if I start with ban of inducements, so this becomes very complicated, but slides are available, so I think we try to squeeze the essence out of the regulation. But ban of inducements, the partial ban of inducements introduces the fact that independent advisors and discretionary portfolio managers will in the future not be able to collect any inducements anymore from the manufacturer or if they are, they have to basically give it back to the class. So this is very, very new. And so we considered today. And so therefore, the distributors today have to position themselves. They have to decide on whether they want to stand for independent advice, thereby not receiving any inducements, or whether they want to continue living as they are today. That is generally tied to many to a manufacturer or multitude of manufacturers, thereby receiving

inducements. But on the other side, method requires them to then prove that the end investor is receiving a benefit of that inducement, and that is a higher quality of service. It's not clear how that will pan out in terms of, you know, how do you sort of confirm that. But for sure, we, for the moment, we see a majority of players going the tied route, and less of them to an independent route. I have to say, though, that the independent routes we consider will create a sort of quality label for independent fund selection advice, unbiased advice that we believe in the future can have, you know, as sort of standout value for marketing. Now, as it's you EU directive, the partial ban of inducements is not necessarily final. When the partial ban will be incorporated international legislations, local legislators could decide to go to plate method two and make it a full ban of inducements. We think it's, however, very unlikely as most of the, I would say, negotiation was around keeping some possibility of receiving inducements so.

maybe one or two countries could go that route, but it would be very rare. Now, on the other side, distributors would clearly need to position themselves as either independent or dependent, but at the same time, manufacturers will therefore have to adapt their products because their products need to be sort of the right product for the right target market, and they will need to introduce what we call clean share classes. That is, share classes without a fee or inducement, as some independent advisors might buy them. Now, if it too is also on the other side, putting in strong emphasis on ensuring that investors obtain transparency in all costs and charges they're paying for. So, in the future, distributors will need to send a personalized report to each and every investor, stating the exact costs and charges borne by the investor at the side of distribution on the product itself, and all types of inducements received for those investments. For sure, this will raise the amount of information and discussion that the distributor needs to have with an investor over the life of his investment.

now, at the same time, manufacturers will need to provide the costs and charges to distributors so that they can basically give it to the end client. And that, we consider, will be done through the preps kid. So, I'm sorry for the language, but you know, it's another regulation in Europe. Now, the bad thing is that preps was due to enter into force January 1st, 2017. It was just sort of the proposal of implementation regulation technical standards was just refused by the European Parliament. So, it might be that the Commission postpones the implementation of trips also to 2018, which would fit quite nicely with method. Now, and this is the last point on method, so after that year, hopefully both an expert and horrified product governance. So, we look at product governance other than the information on cost and charges. Product governance means that a manufacturer will have to decide what product will be destined to what target market. It has to be clearly identified and chosen so that distributors can then market to that type of a class. Now, it

sounds very easy, but certainly, it creates a sort of additional onus on manufacturers to have a process in place that is outside of the regular sort of marketing selection process. Not only will they have to decide upon the target market and target product, they will have to give that information to the distributor, and the distributor has to provide what we call a suitability test for each and every investor that invests into the product, with some rules to be defined and specified so as to ensure that only those types of clients would enter that fund. The distributor will, at the end, also have to report back to the manufacturer on the fact that they've only included those types of clients. So, as you can see, there's a lot of sort of new regulation, which seems to be, I would call it rather administrative, but it is supposed to ensure that the investor is protected when getting into the fund, that is, the product is appropriate for that type of investor, and he will get all the information on costs that he bears on that investment. Now, on the more positive side, so this is

really the constraint for 2018 that will you know make sure or that will probably get the manufacturer very close to the distributor. Today it's a very sort of separate activity. In the future, manufacturers and distributors will need to work hand-in-hand to get this process working. Now under more and I think I have to be very quick now. I'd say are the more positive sides and I'm gonna be very quick here target 2 securities. Targeted securities is an initiative of basically creating a single settlement platform with a centralized DVP solution which also includes mutual funds. So in Europe today as you might know some countries like Germany in France have a sort of clearing history a little like the US with DTCC and all the funds are generally cleared local funds are generally cleared through that clearing infrastructure markets like Luxembourg and the UK for example are more register organized countries hence when you distribute a Luxembourg fund in Germany for example a distributor will need to work with the register function or you have a more

complex sort of process to get your funds into clear stream. Which is the clearing organization. In the future, you will be able to clear both local and cross-border funds through a single infrastructure, which will be T2. T2 S not going to drag into this a bit more. CMU capital market Union. So this is the very wide initiative of the European regulator to create a single capital market in Europe. We consider we're told, at least, that the regulatory overhaul is over. So at this stage, particularly the EU Commission is looking at initiatives to streamline processes, get rid of additional barriers that are existing in cross for the cross-border fund distribution. And maybe I can name just some of them so that you get an idea of what we're going to look at in the next probably month and years. Marketing and distribution rules in Europe, they're different country by country. Reverse solicitation has never been clearly defined. So we're asking the regulator to put a single definition, a rulebook in place so that's the same across Europe for.

those distributing in Europe, we know that language is an issue. Today, you have to, when you distribute in any European country, you need to provide a report in that country-specific language. Financial reports, prospectus, kids. We think that we could at least ease that requirement for professional investors whom we believe should be able to speak either English or French, whatever any language. And even after the Brexit, we'll keep English. But, you know, requirement to have just a single language, any language really in Europe. Also, you need to have a local paying agency representative, agent in every country in which you are publicly distributing your fund. This, we think, should be streamlined or even disappear. We think we should only keep it when there's a real added value of the paying agency in Europe. The notification process, once you distribute across Europe, you have to notify every country of your intention to distribute. The process is different country by country, very complex. There also, we think it would be beneficial to have a central notification process. And finally, the last one I want to mention is maybe the digital investor Passport.

all of us distributors manufacturers transfer agents banks have an even heavier and heavier compliance process more and more KYC KYD to perform. We believe it would be beneficial to have a single or a limited number of providers who could be some kind of infrastructures to keep documentation on individual investors so that all of us could get that information from that infrastructure versus, you know, collecting it ourselves. Maybe just to be very quickly on the last box to technological information so don't worry I'm not going to have a me too discussion around blockchain. I think the only one the only two or three points I want to mention are initiatives or solutions where technology or there are technology enabled. I think the first one that I wanna mention is something like the digital investor passports so that is market utilities that will perform KYC KYD activity in the future. I think I've seen in conference program that there is some discussion around this but we're a firm believer that this will happen and there's a lot of traction on this.

activity at the moment, at least in Europe, Robo advisory. I mentioned before the ban of inducements. Actually, if you remember, when the UK introduced RDR, there was actually a quite a perverse side effect of RDR, which was not really accounted for at the beginning. That is, that there was a whole segment of clients who were like advise orphans, people that would not pay for, could not pay for the advice they were requiring, and suddenly robo robo advice basically came in as the solution for those type of clients. So, the whole the emergence and the rise of Robo advisors in the UK has been facilitated by the initial ban of inducements of RDR. So, we would expect actually that something similar would happen in the rest of Europe with the partial ban of inducements. And if the partial ban becomes gold-plated, then for sure Robo advice will continue to grow across Europe. Now, this has also another side effects on, you know, the competition between active and passive managers, as Robo advisors obviously mainly use ETFs.

as underlying investments for their strategy. And finally, the Millennials. I think I didn't want to end my speech with that, talking about Millennials. Millennials are obviously the result of the rise in technology and the new generation of Millennials, you know, that are very much empowered, that are close to technology, do want to do everything socially with others and on the iPhone. I think the big, the big question that we have as an industry for the future is how are we going to get those Millennials to buy our products, first, and second, how are they going to become loyal to our brand. This, for me, is the biggest question that we have in front of us with that part of a segment. So I think I don't want to conclude it any other way because I know we're lacking time, but thank you very much for your attention. Great startup conference.

Disruption and the future of cross-border fund distribution

IMpower Incorporating FundForum

룩셈부르크와 더블린은 유럽, 아시아, 중동, 라틴아메리카를 아우르는 미국 외 지역의 해외 펀드 유통을 위한 주요 허브입니다.

유럽에 소재한 펀드의 총 가치는 7조 1,000억 달러이며, 가장 큰 시장은 프랑스, 독일, 스페인, 이탈리아, 영국, 대만, 한국, 일본, 싱가포르, 홍콩입니다.

유럽의 대체투자 펀드도 패스포트의 혜택을 받고 있으며, 향후 미국 펀드도 AF 및 D 패스포트를 통해 유통될 가능성이 있습니다.

펀드 분배를 위한 가장 오래된 패스포트 프레임워크에는 싱가포르, 말레이시아, 태국이 포함되며 현재 6개 펀드만 분배가 허용됩니다.

2017년 말까지 시행될 것으로 예상되는 새로운 아시아 지역 펀드 패스포트에는 호주, 일본, 뉴질랜드, 한국이 포함되며 태국과 필리핀이 추가될 가능성이 있습니다.

다른 지역의 패스포트를 상호 인정하여 보다 통일된 글로벌 유통 시장을 만들 수 있는 가능성에 대한 논의가 활발히 진행되고 있습니다.

금융 유통업체에 대한 유인책의 부분적 금지가 미치는 영향

인센티브의 부분적 금지로 인해 독립 어드바이저와 포트폴리오 매니저는 제조업체로부터 인센티브를 받지 않게 될 것입니다.

투자자가 인센티브를 통해 이익을 얻었음을 증명하는 방법에 대한 불확실성이 존재하기 때문에 대부분의 유통업체는 묶여 있는 경로를 선택하게 됩니다.

또한 금지 조치에 따라 제조업체는 투자자에게 깨끗한 주식 클래스를 제공하고 비용의 투명성을 보장해야 하며, 유통업체가 투자자와 논의해야 하는 정보의 양이 늘어날 것입니다.

새로운 규정이 제조업체 및 유통업체에 미치는 영향

PRIIP 시행 연기와 같은 새로운 유럽 규정으로 인해 제조업체는 추가적인 관리 부담을 안고 있습니다.

이러한 규정에 따라 제조업체는 제품의 목표 시장을 신중하게 선택하고 유통업체에 비용에 대한 자세한 정보를 제공해야 합니다.

또한 이 규정은 유통업체가 투자자를 대상으로 적합성 테스트를 실시하고 제조업체에 보고하도록 의무화하여 양사 간의 협력 관계를 더욱 긴밀하게 만들었습니다.

더 긍정적인 측면에서 Target 2 Securities는 단일 결제 플랫폼을 도입하여 유럽 내 펀드 청산 인프라에 영향을 미치고 더욱 간소화된 프로세스를 촉진할 것입니다.

유럽에서 국경 간 자금 분배 간소화

유럽 규제 당국은 단일 자본 시장을 만들고 마케팅 및 유통 규칙을 표준화하는 등 유럽 내 국경 간 펀드 유통 프로세스를 간소화하기 위한 이니셔티브를 추진 중입니다.

또한 재무 보고서 및 투자설명서에 대한 언어 요건을 완화하고 유럽 전역에 배포하기 위한 신고 절차를 간소화하는 것을 목표로 하고 있습니다.

또한 디지털 투자자 여권을 구축하고 KYC(고객 파악) 및 KYD(판매사 파악) 활동을 위해 기술을 활용하는 방안도 추진 중입니다.

로보 어드바이저의 부상에 대한 RDR의 영향

영국 RDR의 유인 금지 조치로 인해 로보 어드바이저가 등장하고 성장하면서 전통적인 금융 자문을 받을 수 없었던 고객에게 솔루션을 제공하게 되었습니다.

유럽에서 부분적으로 금지될 가능성이 있는 유인책은 유럽 전역에서 로보 어드바이저의 확장을 더욱 촉진할 것으로 예상됩니다.

로보 어드바이저의 부상은 액티브 매니저와 패시브 매니저 간의 경쟁에도 영향을 미치고 있으며, 금융 업계가 밀레니얼 세대 고객을 유치하고 유지하는 데 있어서도 도전 과제를 안겨주고 있습니다.