The Research Payment Accounts Code of Conduct

The RPA Code of Conduct is the product of an extensive consultation process lead by Substantive Research, involving over 50 asset management firms along with key representatives from the pension fund, SWF, wealth management and retail investment communities.

This consultation process has proceeded over a 15-month period covering June 1st 2015 – October 1st 2016, but has been most concentrated since the April 7th 2016 publication of MiFID II Delegated Acts, and the AMF and FCA consultation papers in September 2016 concerning inducements and investment research.

The RPA Code of Conduct has the objective of providing a clear guide to best practice processes post-MiFID II.  The code is intended to cover the different approaches asset managers can use to charge end investors for their use of external research.

The RPA Code is also intended as a resource for pension funds, SWFs and retail investors as they seek to understand what they should expect from asset managers who charge them for the external research they use.

This is a first draft, with which we hope to stimulate debate and feedback on how to make this the best possible resource for investors, asset managers and research providers alike. A 2017 version will be produced prior to MiFID II taking effect in January 2018.

RPA Code of Conduct

Substantive Research would like to thank the following individuals for their time and perspectives on best practice in research procurement. They encompass a wide range of firms, business models and eventual approaches to new market structures, but one thing they all have in common is a commitment to rigour in their research procurement processes. They are in no way responsible for the content or direction of the RPA Code of Conduct, but their input was much appreciated.

Robert Alster – Head of Research, Close Brothers AM
Travis Barker – Business Manager, HSBC GAM
Chantal Brennan – Research Director, Davy Asset Management
Chris Brown – CIO, IPS Capital
Morgan Davies – Counterparty Relationship Manager, Newton Investment Management
Richard Dunbar – Head of Economic and Thematic Research, Aberdeen Asset Management
Mark Gallardo – Broker Relationship Manager, Aviva Investors
Ian Jones – Head of Market Conduct, Fidelity Worldwide Investment
Sheena Kelman – Lead MiFID II Project, Martin Currie
Andrew Moscow – Head of Investment Risk, Fixed Income, Schroders
Karen Russell – Equity Business Manager, Columbia Threadneedle
Roland Spurr – Equity Business Manager, AB Global

Substantive Research would like to thank the following people and their firms for their support and their advice in this process as Co-Founders:

Tom Conigliaro, Managing Director – IHS Markit
Patrick Gill, Executive Director – Instinet Europe Limited
Mark Sandeford, Director – WeConvene Extel
Indy Sarker, CEO – ANALEC