Are Regulators Forcing You to Become an RIA?

Are Regulators Forcing You to Become an RIA?

Written by: Jason Plucinak

For many advisors, the slow-motion action on the Department of Labor/fiduciary rule has led them to take a serious look at their business models. With regulators moving the industry inexorably toward strict rules on commission-based business, advisors are considering whether turning their practice into a Registered Investment Advisor (RIA) now will keep them ahead of the industry and allow them to retain valuable clients.

The commissioned broker working for a wirehouse has been in decline for more than a decade. Aite Group estimates wirehouses have declined from almost 42 percent of all assets in 2007 to 36 percent this year. Cerulli Associates projects that independent RIAs will rise to 28 percent of the market in 2020.

RIAs do not make commissions on securities’ sales but rather charge a fee for their advice and services.

As important, RIAs are already fiduciaries to their clients and are not regulated by the Financial Industry Regulatory Authority (FINRA) but are by the Securities and Exchange Commission (SEC). And, there’s a level of independence an RIA can experience that is an attraction on its own.

But, it’s no simple decision. The move to become an RIA offers its own options: whether to be a pure RIA, charging clients a flat-fee or a percentage of assets, or to be an RIA hydrid, registered as both an RIA and with a broker-dealer.

Importantly, you have to consider what your clients want and need. The more sophisticated they are, the more likely they are to look closely at how you are compensated (and the more access they have to competitors that include RIAs and robo-services that are growing marketshare on their own).

So, if it’s on your mind, here’s a place to start. What follows are three reasons NOT to change your business model to RIA-only and three reasons TO change to RIA-only:

The case for switching to RIA-only:


1. It’s the future


Some say the handwriting is on the wall: commissioned “salespeople” have no place in managing Americans’ retirement dollars and regulators will never stop until every financial advisor in any capacity is acting as a fiduciary in all scenarios.  If this happens sooner than later, why fight it?

2. Stress Relief/Quality of Life


If you are able to successfully transition your business and clients to a fee-based only relationship, you now have much less pressure to “sell” your clients anything.  You are now getting paid to successfully manage their assets – if you make them money, you make more money. Interests aligned.  Win-win for you and your clients.

3. To save yourself and your practice from the coming legal war


Most commissioned brokers feel that FINRA will “get them” at some point – it’s only a matter of time.  Even though you run a clean practice and do what’s best for your clients, the impending fiduciary standard rules will crack open doors that plaintiff attorneys and regulators want to bust open.  Go now while you still can.

Related: What's an Investor to Do When History Doesn't Repeat Itself?

The case against switching to RIA-only:


1. Business continuity


Transitioning a practice takes a lot of time & effort, requiring you to explain the differences in your compensation to every one of your clients and having them sign off on the change. Are you ready for what could be difficult conversations with your clients about past practices?

2. A cut in pay


Commissioned brokers generally make lump-sum compensation upon every sale to every client. Changing to the RIA model means you will only make a fixed rate fee on the amount of assets you are managing for each client and you’ll generally only collect that small fee once per quarter -  at the most. Transitioning to RIA from a financial aspect generally will take two-to-three years of building your Assets Under Management (AUM) until your total fees equal or exceed what your prior take-home income was.

3. Because no one tells you what to do


If you are already acting in the best interest of your clients at all times, why would anything a regulator tries to enact make you change your business?

No matter your frustration with what seems to be continually increasing regulations, keep your focus on doing what’s best for your clients.

Jason Plucinak has over 14 years of experience as a financial professional in the life insurance, securities, and alternative investment industries. Currently Senior Vice President of Business Development at GWG Holdings, his background includes wholesaling, sales management, and Broker Dealer due diligence. Mr. Plucinak holds his Series 7 and 63 license with Emerson Equity LLC, a FINRA registered broker dealer. Mr. Plucinak earned a Bachelor of Science degree in finance from St. Cloud State University in Minnesota.
GWG Holdings, Inc.
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ETFs: The Importance of “Looking Under the Hood"

ETFs: The Importance of “Looking Under the Hood"

Written by: Doug Sandler, CFA, Global Strategist at Riverfront Investment Group

The growth of the ETF industry has been a boon to investors, providing access to new asset classes and time-tested investment strategies at a competitive cost.  However, the industry’s rapid growth has also brought its own set of challenges with one of the biggest being how to ‘make sense of it all’. 

With thousands of ETFs in existence and new offerings becoming available every day (see chart below), it has become increasingly important to thoroughly research an ETF before buying it.  Most ETFs are not as alike as their naming conventions or category classification might imply. Only by ‘looking under the hood’ can an investor truly assess the unique features and risks that ultimately impact the performance of an ETF in varying economic environments. 

Many of the investment professionals at Riverfront have been building ETF portfolios for nearly 15 years and we are fortunate to have a number of proprietary and third-party tools that enable us to easily identify and quantify the risks in every ETF we invest in.  However, since these tools can be expensive and difficult to develop, we often see investors relying on simple points of comparison like expense ratios or size/trading volume when choosing between several ETFs. 

This lack of in-depth analysis means that investors can be unknowingly comparing ‘apples’ to ‘oranges’ and making a purchase decision based upon which is cheapest or which is most popular.  In this article, we share a framework to help compare ETFs and properly assess their key features and risks. 

We believe that the three most important characteristics to consider when comparing ETFs are: 1. Universe Definition, 2. Selection Criteria and 3. Weighting Methodology.


1. Universe Definition:  


Every ETF is built from a defined universe of stocks.  A universe can be defined broadly, like all companies in the Wilshire 5000, or narrowly, like all biotechnology companies in the S&P 500.  What a universe includes or excludes can have meaningful performance implications, and thus should be an important consideration when comparing ETFs.  Below are a few examples of universe differences that are often overlooked by investors.

A. Europe Example:  What one index provider defines as European companies may differ from the definition used by another provider.  One important distinction is whether they are including companies that are members of the European Union (EU), or members of the European Monetary Union (EMU).  The EU is comprised of 28 countries that have agreed to principals governing interactions including trade and immigration.  The EMU, on the other hand, is made up of only the 11 countries that utilize the Euro as their common currency.  A number of countries like Germany and France are members of both the EU and EMU; however there are a number of countries like the UK, Switzerland, and Norway that are members of the EU and not the EMU.  The countries in the EU but not in the EMU represent nearly 50% of the EU index and their exclusion can be expected to impact an ETF’s performance.  This difference may become increasingly relevant as the UK faces its own unique challenges navigating its exit from the EU (Brexit).

B. Emerging Market example: The two largest emerging market (EM) ETFs have one key difference, the inclusion of South Korea.  South Korea is the 2nd largest country weighting in the emerging market index as defined by MSCI, currently representing roughly 15% of the index.  The FTSE emerging market index, which is the index behind the largest EM ETF in the marketplace, does not consider S. Korea as an emerging market country and thus does not include it in its index.  The dissimilar treatment of S. Korea can have material performance implications on the two ETFs, as it has so far in 2017, with S. Korea significantly outperforming other emerging market countries.  Investors worried about escalating tensions with North Korea, or believe that these fears are overblown, need to consider these differences when choosing their EM ETF.

C. Technology Example: Some indexes define technology more broadly than others.  A key area of differentiation is with regard to how they define Internet Retail.  Some index providers classify these companies within the technology sector, while others view them as members of the consumer discretionary sector.  Similar varied treatment can be found with regard to the media and the electric vehicle industries.  With Internet retail, media and electric vehicles comprising a significant portion of some technology indexes, the performance implications can be profound.  Those that believe companies in these industries represent the future of technology should consider an ETF that is built on a more inclusive index.   

2. Selection Criteria: 


The next characteristic to consider, in our view, is the ETF’s selection methodology. ETFs with a selection methodology based on criteria (i.e., ‘factors’) other than ‘market capitalization’ are often referred to as ‘Smart-Beta’.  A factor is a characteristic like ‘share-price volatility’ or ‘dividend yield’ that is used to screen or rank securities within a defined universe.   With over 2,000 listed ETFs, there is likely an ETF to satisfy the needs of even the most discerning ‘stock-picker’.  An ETF’s selection criteria can be simple, utilizing just a few static factors, or sophisticated like those that employ dozens of variable factors. 

A. Number of Criteria (Factors): Every selection methodology has the potential to introduce biases into an ETF that may not be entirely transparent or intentional.  For example, an ETF that selects its constituents using a factor like ‘value’ will also likely impart significant sector overweights and underweights into the fund.  Many “value”-based indexes, for example, are currently overweight financials and underweight technology and healthcare. Investors who are bullish on technology and bearish on financials should steer clear of value ETFs with these structural biases. A general rule of thumb is that ETFs that employ a small number of factors (four or less) tend to have more biases than those that have more complex factor selection methodologies.  While there is nothing inherently wrong with a bias if it’s what an investor intended, it is important that those biases are known ahead of time and not a ‘surprise’ later.  We like to say: ‘Every ETF has a bias, never make a purchase decision before you find it.”

B. Factor Definition: Selection methodologies can also vary in the way they define a factor.  For example, the ‘value’ factor can be defined differently by different index compilers.  One might use a company’s price/book ratio while another uses price/earnings or price/sales.  To complicate things further, one provider may only include the constituents with the most extreme ‘value’ rankings and another might include a broader group of companies with attractive ‘value’ rankings.  This can lead to significant cap, sector and industry weighting differences between two similar sounding ‘value’ ETFs.  For example, as of 11/30/17, the two largest value ETFs as determined by ETFdb vary in their small and mid-cap exposure by ten percentage points.  Just like you should not judge a book by its cover, it can be dangerous to judge an ETF by its name alone.

C. Static or Variable (Active): Active ETFs differ from traditional ETFs in an important way.  Active ETFs do not follow an index and as a result have the flexibility to adjust their selection criteria, as opposed to traditional ETFs that follow indexes whose selection methodology is set at the time of the index’s inception.  There are pros and cons to each methodology.  One advantage of active ETFs is that they have the ability to evolve and adapt to a changing investment climate.  Some might view this advantage as a disadvantage, since the ETF’s biases will be dynamic and less predictable. For example, an active US equity ETF that falls under a mid-cap classification one day, may become more large-cap focused three months later.    

Related: Ready to Dive Into ETFs? Read This Q&A Before Taking the Leap

3. Construction/Weighting Methodology:


The third important differentiating characteristic, in our view, is the ETF’s weighting methodology.  The weighting methodology not only has the potential to introduce additional biases, but can also dilute or amplify the selection methodology.

A. Capitalization Weighting vs Non-Capitalization Weighting: 

  • Size Bias: ETFs that utilize a market capitalization weighting scheme will tend to contain a size bias that favors large-caps, while a non-cap weighted methodology will tend to have greater exposure to mid and small-caps.  This can be particularly important at various market stages.  For example, it is not unusual for small and mid-caps to outperform in the early stage of a bull market due to their greater leverage to improving business conditions, while large-caps often outperform in a bear market when investors demand stronger balance sheets.
  • Concentration Bias: Market-cap weighting methodologies can also introduce concentration risk to a portfolio, where a handful of securities comprise a significant portion of the ETF.  A popular South Korean index, for example, is cap-weighted and dominated by a single company that comprises more than 23% of the index. Concentration issues can undermine an objective to diversify risk, particularly in higher risk areas like biotechnology or emerging markets.   Ultimately, an unintended concentration bias can turn the ‘right’ idea into the ‘wrong’ outcome if not monitored closely. 
     

B. Factor-Weighted:  Factor-weighting methodologies assign the greatest weights to the stocks that have the highest factor scores.  For example, the largest constituents in a factor-weighted momentum ETF will be the stocks displaying the strongest momentum.  A factor-weighted ETF can be expected to perform differently than one that simply identifies the 100 strongest momentum stocks and weights them equally. Factor-weighting methodologies have the potential to amplify returns positively or negatively.

Bottom Line

One could argue that buying an ETF is similar to buying an automobile.  A car buyer rarely makes their purchase decision based solely on price.  Instead they consider the vehicle’s design, drivetrain and safety features to determine if it meets their unique needs.  In most cases, the decision to purchase an ETF should also not be made solely on the fund’s expense ratio, since there are likely other distinguishing features that will be more impactful to the fund’s performance.  By understanding the construction and drivers of performance in an exchange-traded product, investors can minimize the potential for surprises down the road.
 

Important Disclosure Information:

The comments above refer to generally to financial markets and not RiverFront portfolios or any related performance.

Past results are no guarantee of future results and no representation is made that a client will or is likely to achieve positive returns, avoid losses, or experience returns similar to those shown or experienced in the past.

Information or data shown or used in this material was received from sources believed to be reliable, but accuracy is not guaranteed.

Exchange-traded funds (ETFs) are sold by prospectus. Please consider the investment objectives, risk, charges and expenses carefully before investing. The prospectus and summary prospectus, which contains this and other information, can be obtained by calling your financial advisor. Read it carefully before you invest. As a portfolio manager and a fiduciary for our clients, RiverFront will consider the investment objectives, risks, charges and expenses of a fund carefully before investing our clients’ assets. 

ETFs are subject to substantially the same risks as those associated with the direct ownership of the underlying securities owned by the ETF.  Additionally, the value of the investment will fluctuate in response to the performance of the underlying index or securities. ETFs typically charge and/or incur fees in addition to those fees charged by RiverFront. Therefore, investments in ETFs will result in the layering of expenses.

Actively managed funds are subject to management risk.  In managing a fund’s investment portfolio, the sub-advisor will apply investment techniques and risk analysis that may not have the desired result.

Diversification does not ensure a profit or protect against a loss.

Technology and Internet-related stocks, especially of smaller, less-seasoned companies, tend to be more volatile than the overall market.

Small-, mid- and micro-cap companies may be hindered as a result of limited resources or less diverse products or services and have therefore historically been more volatile than the stocks of larger, more established companies.

Investments in international and emerging markets securities include exposure to risks such as currency fluctuations, foreign taxes and regulations, and the potential for illiquid markets and political instability.

Beta measures volatility relative to a benchmark. A result greater than 1.0 implies that a security is more volatile than the benchmark; a result less than 1.0 suggests that the security is less volatile than the benchmark. Betas may change over time.

RiverFront Investment Group, LLC, is an investment adviser registered with the Securities Exchange Commission under the Investment Advisers Act of 1940. The company manages a variety of portfolios utilizing stocks, bonds, and exchange-traded funds (ETFs). RiverFront also serves as sub-advisor to a series of mutual funds and ETFs. Opinions expressed are current as of the date shown and are subject to change. They are not intended as investment recommendations.

RiverFront is owned primarily by its employees through RiverFront Investment Holding Group, LLC, the holding company for RiverFront. Baird Financial Corporation (BFC) is a minority owner of RiverFront Investment Holding Group, LLC and therefore an indirect owner of RiverFront. BFC is the parent company of Robert W. Baird & Co. Incorporated (“Baird”), a registered broker/dealer and investment adviser.

These materials include general information and have not been tailored for any specific recipient or recipients.  Accordingly, these materials are not intended to cause RiverFront Investment Group, LLC or an affiliate to become a fiduciary within the meaning of Section 3(21)(A)(ii) of the Employee Retirement Income Security Act of 1974, as amended or Section 4975(e)(3)(B) of the Internal Revenue Code of 1986, as amended.

Index Definitions (You cannot invest directly in an index):

The Wilshire 5000 Total Market Index, or more simply the Wilshire 5000, is a market-capitalization-weighted index of the market value of all stocks actively traded in the United States.

The MSCI Emerging Markets Index captures large and mid cap representation across 24 Emerging Markets (EM) countries*. With 838 constituents, the index covers approximately 85% of the free float-adjusted market capitalization in each country.

The FTSE Emerging Index is a free-float, market-capitalization weighted index representing the performance of around 850 large and mid cap companies in 22 emerging markets. The index is derived from the FTSE Global Equity Index Series.

The MSCI Europe Index represents the performance of large and mid-cap equities across 15 developed countries in Europe. The Index has a number of sub-Indexes which cover various sub-regions  market segments/sizes, sectors and covers approximately 85% of the free float-adjusted market capitalization in each country.

The S&P 500® is widely regarded as the best single gauge of large-cap U.S. equities. There is over USD 7.8 trillion benchmarked to the index, with index assets comprising approximately USD 2.2 trillion of this total. The index includes 500 leading companies and captures approximately 80% coverage of available market capitalization.

Copyright ©2017 RiverFront Investment Group. All rights reserved. 2017.298

This document is a general communication being provided for informational purposes only. It is educational in nature and not designed to be a recommendation for any specific investment product, strategy, plan feature or other purpose. Any examples used are generic, hypothetical and for illustration purposes only. Prior to making any investment or financial decisions, an investor should seek individualized advice from personal financial, legal, tax and other professional advisors that take into account all of the particular facts and circumstances of an investor’s own situation.

J.P. Morgan Asset Management is the marketing name for the asset management business of JPMorgan Chase & Co. and its affiliates worldwide.

J.P. Morgan Asset Management and JPMDS are not affiliated with RiverFront Investment Group.
J.P. Morgan Asset Management
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See how ETFs differ from other investment vehicles, learn how to evaluate them, and discover how ETFs can be used effectively to achieve a diversity of investment strategies. ... Click for full bio