Important Update on Transfers- Comms 18/10/21

Dear Client

In 2019 the FCA published its Investment Platforms Market Study.  As you may recall, one of their key concerns was the complexity and timescales associated with moving platforms.  While the STAR initiative has encouraged platforms to make their own improvements, progress has been slow. 

We have a relatively small number of transfers out of Hubwise, but we are planning to review this process to see how we can improve.  We are also very mindful of these challenges as we work with you to transfer money in. This process, which involves multiple parties, can be frustratingly slow, particularly where electronic transfers are not supported by the ceding scheme.  

We realise that not everyone involved will have an in-depth knowledge of the process, so the aim of the attached diagram is to help illustrate the key stages and multiple parties involved.  Please share this with your colleagues, as appropriate.  We also want to update you on several improvements we have underway and to highlight some of the things you can do to help ensure delays are kept to a minimum. 

What are we doing to help? 

We have built a largely automated and paperless approach. For GIA's and ISAs, once the Transfer Authority Form with either an electronic or wet signature is uploaded onto the Hubwise portal, the system sends an electronic notification to the ceding platform within two days, using the Altus Transfer Gateway (ATG).  We do this in writing, within the same 48-hour window, for manual transfers.  

For pensions, Hartley follows a similar approach, with the Origo system used for electronic cash transfer notifications where no additional paperwork is required. In-specie pension transfers are instructed manually.  We have just delivered an enhancement to enable the signed Transfer Authority Form to be uploaded onto the Hubwise portal, to avoid the need for you to send by separate email.  Hartley also aims to send transfer requests within two days of receipt of the transfer information and forms.  

Once a transfer is instructed and confirmed by the ceding party, it is out of our hands and there is little we can do to influence the time it takes the transfer to complete, but we do try.  As set out in our note last summer, we do everything we can to ensure the transfer arrives in a timely manner.  It is in our interests to get these assets onto the platform, as until they arrive, we don’t earn any revenue!  We, therefore, chase the ceding platform regularly, using a combination of electronic notification with a list of outstanding transfers, personal email and phone calls, which can on occasion elicit a response from the ceding party asking we stop chasing.  If the transfer is in-specie, as soon as the first asset is received and we know the request has made its way to the fund manager, we also include them in the chasing process.  Pension transfers are also chased proactively by Hartley every ten working days.  

Since COVID, we have concluded that chasing has little impact on how quickly a transfer completes.  However, we do chase regularly throughout the process and the latest position can be found in the Transfer MI reports on the portal.  You will find these at transfer level and at stock level for assets moving in-specie.  We deliver an updated report on a Monday and a Thursday and, having heard your feedback, we have just implemented some improvements, including; 

• Showing if the transfer is currently sitting with the ceding platform, fund manager, IFA or Hubwise

• Highlighting when we will start chasing and how (i.e. through the automated or manual process)

• Including delay information or rejection reasons notified through ATG

• Adding who we last chased, when and in what format (along with a count of how many times)

• Improving the note, so that those added manually appear alongside automated system notes 

• Addressing some statuses that were not moving on automatically in the way we expected

And we are currently working on including Hartley updates, either directly from Origo or manually.

We do realise that the frequency we chase, or the method we use, may not always fit your preference and we fully understand your desire for as much information as possible. However, ad hoc requests for updates on transfers have proven to deliver minimal (if any) quicker resolution and tend to have the opposite effect when engaging with the ceding parties.  We kindly ask that you limit ad hoc chasers, we will of course continue to support you with exceptional cases, or where a change in approach is needed.  Additionally, if funds have left a ceding platform and have not yet been received, do get in touch with us by raising a Freshdesk ticket and escalating it to freshdesk.manager@hubwise.co.uk. 

In addition to the improvements already delivered, we have a number of others underway.  This includes undertaking a full audit of third-party contact details, ensuring these are as up to date as possible for the automated chasing process. You may have noticed the introduction of a new field on the portal when setting up a new ceding party, for a suitable email address.  Our preference is that wherever possible this should be a generic mailbox address, rather than a named individual and this does need to be for the ceding platform.  We also have a new more regular process, to review this data going forward. 

We continue to focus on improving our commentary.  Unfortunately, we are hampered by the lack of meaningful updates we get from the ceding platform/fund manager. Where funds are migrating for your existing clients, we are always grateful for any support you can give.  This can be especially impactful where the delay is at either the Fund Manager or Transfer Agent.  We frequently find you will have better access to a support function that can give an improved experience than we do as the acquiring platform. 

We are also in the process of automating the notification of transfer rejections, to get these to you quicker than the current approach via Freshdesk.  In the meantime, we have added details to the Transfer MI.  

What can you do to help? 

There are some things you can also do to help increase the pace of transfers.  The first is to consider carefully whether to transfer in cash at the outset.  Transferring in cash is undoubtedly quicker, but does involve time out of the market, so we appreciate you will need to consider if the risk of missing potential gains is outweighed by the benefit of a smoother transfer process. 

Please do check meticulously that the Transfer Authority Form is complete, signed (with a wet or electronic signature), correct and uploaded to the Investor Document area of the portal.  If the details we have don't match those of the ceding platform, the work involved in clarifying will slow things down. We cannot be held responsible for delays or associated financial detriment if an incorrect or incomplete form has been provided or uploaded incorrectly. 

Once you have issued a transfer instruction, it would also help greatly if you did not deal on the investor's account, even if you do have to wait sometime for the transfer to complete.  It will undoubtedly complicate the overall process and potentially cause delays if you do.

As mentioned above, in our experience ad-hoc chasers do not close out transfers any quicker.  We understand the frustration that can be caused and your need for progress updates however we have an established process, which we want to ensure is focused on those cases that really need intervention.  We are constantly reviewing our process to make sure it adequately caters for exceptions and identifies those cases where the process is not working as it should, as quickly as possible.  

Where there are several funds with a particular fund manager or ceding party, which we think need intervention, we may ask you to work proactively with us to help unblock these.  This partnership approach has served us well with recent delays experienced with certain platforms. 

Finally, please do get in touch urgently if you think funds have gone astray, or if the underlying investor is particularly concerned. As noted earlier, you can do this via freshdesk.manager@hubwise.co.uk.

We hope you have found this update useful.  We will write again with further progress as soon as we can.

Should you have any questions then please contact the Customer Services Team via your Freshdesk Account.

Kind regards