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 Duty and Assessment of Value product offerings. With me today I have a very special guest, Holly Mackay, co-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 the challenges they face with Consumer Duty. 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. Good morning to viewers in North America. Good afternoon to those of us in Europe. For those of you who don't know Boring Money, I founded it back in 2015. Boring Money is an information business. 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 this, have some degree of a 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 four key outcomes that everybody along the distribution chain needs to focus on. Today we're really going to focus on the asset managers and their responsibilities looking at those four key outcomes, which are products and services, price and value, consumer understanding, and consumer support. I think where we'll spend a bit more of our time today is really on numbers 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 and 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. 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 those better outcomes for the investor. 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, 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 seven or eight times a day in meetings with clients what we see. So I see we are starting to get some responses in for 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 and not lead the witness. Okay. We'll give it just another couple seconds, please, finish up your voting if you're online. Looks like we're getting pretty reasonable response rates. 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 that asset managers face in getting that data from the distributors. 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 while we start delivering. For me, Devin, it's a question of, "Well, 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's sake. 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 PS22/9 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. 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. No, I'm not surprised that data is highlighted there, the problems with the distributors. I think there are things that asset managers that we'll cover in part in this webinar, Devin, could be doing now to help solve that problem without waiting for the distributors. Very much agreed. One of the most common themes I've heard is from those manufacturers, which are the vast majority in reality, that are intermediated. They are challenged by where their responsibility ends and where the intermediary's begins and ends. And how do they get meaningful data? 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 advised channel or from a guidance channel, an 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. Maybe the biggest challenge 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, it's 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 off 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 kind of 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 a 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 someone that can't read clearly or has visual problems. And so a lot of the groups I've talked to have spent time, for example, looking at font 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 they 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 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 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. And 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. We have created an analysis that we call the PERC Score, performance, expense, risk, and consistency. It looks at those four attributes of a fund allowing us to evaluate the price and value that a particular product is giving. Then we can aggregate that up to look at the fund or the complex overall. We give it what we call the PERC Score. What that does is it's a quant-driven model that says 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. We've ranked all funds and asset managers using this PERC Score. Combining that then with the information from Boring Money, we can start to say where there is a perception gap. Where do investors say an asset manager is performing very well? The quantitative data says they're probably not performing well or vice versa. We'll look into that. Essentially, what we're looking at is five-year return, typically, expenses versus a comparison group, risk over that same five-year period, and consistency of return. 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. 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 effectively, we're collecting data on a bottom-up basis. Asset managers going to distributors are 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. It's currently sitting around 4,200 fund investors. So we are able to go and follow up with qualitative work should we want to with particular asset managers to dive into things in a bit more detail. What I 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 and wealth. So we can see a picture of whether, as with Fund Company A, for example, they have more customers who are relatively well off. We capture gender. We also capture advised status. So already, Devin, just with this one slide, we're able to say to 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 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. We can see for Fund Company A that about 40% of their customers report having holding periods of five years or less. We can also see that the self-reported risk profile for those investors, 40% of Fund Company A's 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. 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. We ask people how much of a material impact it would have on their financial situation if this fund were to lose money. We can see here about one in five investors would. So what we're starting to do by going directly to these 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 give boards, 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 advised versus the non-advised status. That starts to really provide evidence to an asset manager of 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 your 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. They're 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. 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 1-3 years, this can confirm whether that is a problem or whether that fits in with what the investor's expectation and time frame is. So one of the challenges I think we as an industry have is, one, you can't look at any of the four 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. 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 smoke and mirrors with some of those challenges. Next, we want to move on and look at how investors may perceive 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 one 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 UK Wealth Manager One in the second spot and so on. So this is all from an investor perception standpoint. And this is, from my view, in 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 UK Wealth Manager One that ranks second according to investor perceptions, when you look at it from the quantitative perspective using that PERC Score, they're down about 21 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 One, they are ranking towards the bottom in the 25th spot. However, when you look at it from the quantitative perspective, they rank quite well in the Broadridge ratings. And so what this starts to indicate to us is that there is a perception gap with those two asset managers. Obviously, there's some others on here where there's a perception gap. The intent of this is to really allow folks on the fund company side to say what may be driving that. This is really just the first slice of the data that we have. 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 for me is the executive summary. If I were sort of sitting on a board, I think there are sort of four camps 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 are 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 will sort of might be doing very well, as you said, with the end customer but less well with your data. And for me, this is sort of answering. This is starting to get to the heart of when people are saying to us, "Yeah, okay, there's data. Great. But what are we actually going to do with it?" This points to the core issues. One example I'll just touch on is we have tracked for the last five years a brand which is perennially popular with end investors. Its 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 as saying, "Well, actually, for that asset manager overall, their 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? Ergo, what do I need to do about it? 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 show 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. 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 alignment 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 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 sort of +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, there's 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 their assessment of value, quality of service is one metric that's 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. Yeah. I think that is one of the biggest challenges we have is any investor is going to have their own definition of value, which creates even more complexity with really answering that. Let's move on to the cost of funds. So here, again, very similar data. We have, in this case, at least broken it out by asset class. But overall, we see that Fund Company A's cost versus peers and across 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 charting 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 its 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 the cost side of the equation with this particular asset manager? Yeah. What this slide tells me immediately is that the customers of Fund Company A are being unduly harsh about the fees and charges. 36% of its customers are scoring it 6 or less out of 10 when it comes to the costs. 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 costs. So I'll give you an example. Instead of telling people that the fund, let's be generous, say it's an active fund that costs 60 basis points, instead of saying, "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? What's missing here is the education for that particular customer of this particular company that the fees are, 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 has 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. Yeah. For me, as I said at the beginning, perhaps the surprising thing for me when we started to look into this is the relatively high proportion of fund investors who report some sort of vulnerability, as I said at the beginning. Currently, 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 font sizes or is the website sort of readable. And I've sort of struggled beyond that to go, "How do we help people? Where do we need to focus?" For me, when I look at the main causes of vulnerability for asset management customers, it is around mental health, particularly anxiety. It is around financial vulnerability. What that points to, to me, Devin, perhaps more than targeting, "How can we support people with physical disabilities?" where there's lower numbers 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 them, we can help our customers to get a picture of this for their particular investors, what their particular sort of reported vulnerabilities are, and then start to target this. This goes again to the so 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, their 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 kind of main problems that all retail investors have when it comes to asset managers. I think a lot of thinking and work needs to be done not just on font sizes but also on making sure that those time frames, the objectives, and risk are really better articulated than they are in many instances today. Yeah. As I looked at this for the first time a couple of weeks ago, the two that were most intriguing to me because I will admit, I think I took the perspective that you highlight a lot of asset managers did. I 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 data 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. One of the interesting pieces, Holly, that you and your team at Boring Money have is you actually ask some questions about where people think they're going to go. 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 are thinking they're going to invest. 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's trying to achieve or improve with Consumer Duty. I highlight this here. If you look at 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 of the following sectors are you considering increasing holdings in in the next six 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 stacks up with what we're seeing at the moment. The world is a particularly baffling place, I think, at the moment, Devin. And investors are feeling that. And that tells me that that need for communication, for help, for sort of guidance, for content is stronger than it's been for the sort of previous four years. This chart, to me, shows most clearly and more interestingly than what we might see about any one asset class is that lack of conviction, is that lack of certainty. And that, to me, tells me it's a time where communication, where good content, where comms are more in demand and more interesting than they have been before. Excellent. I want to take a deep dive here into a particular asset manager and a couple of their funds. 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. 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. For this, we've really just focused on the values for investors have given on the bottom versus the fund's actual returns for the preceding one-year period on a rolling quarterly basis. What really jumps out to me on this is, in some cases, there's correlation. Great returns the previous quarter. The next quarter, 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 is important. 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 a market very well? And so their perception of value is challenged by this. And 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 closer aligned their reactions to performance or overperformance are, the less confident the customer base, the less sophisticated a customer base, it tends to take sort of between 6 and 9 months for that awareness to trickle through. So, as you say, definitely something we want to track and explore those correlations for 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, etc. 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 this 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, for me, the sort of interesting part, as you've said, is what happens when you compare what your end customers say. Just to pick up on 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 at the differences between what they say and, Devin, what your data tell us. That, to me, is a crucial bit of the picture for asset managers who seem to me this is a baffling task. Dealing with Consumer Duty has taken huge amounts of resource. I think asset managers are looking at this enormous field going, "Where do we dig? 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 few questions are coming around sort of vulnerable customers. When we're asking people, 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. Yeah. One of the other questions. Sorry, Devin. I sort of dashed into answering a 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. And the question is, 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 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 the money is in. So is it being used for pension, or is it an ISA? And then what the investor's time frame is. And looking at that collectively amongst a fund or a set of your funds allows you to make some reasonable assumptions about what the investor is expecting. And then you can make some reasonable assumptions about what a good outcome is. So if you see, using that data from Holly's team, that most investors are in SIPPs, investing in your products, you can make the assumption, based off the age piece, that they're going to be holding 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 have 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, non-vulnerable 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 four legs good, two 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 five tasks that you're going to focus on as a board or what the kind of outcomes that the sort of 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 a 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.