Page 59 - Profile's Unit Trusts & Collective Investments - September 2025
P. 59

Costs and pricing                                                     Chapter 3

           It is sometimes argued that a kickback is not really a
         “hidden cost” and doesn’t affect the investor at all. This   All-in fees
         argument contends that the portion of the manager’s fee   The  advent  of  broker  funds  and
         being paid to the adviser or LISP was part of the disclosed   other  white  label  funds  has  seen
         fees to begin with and would have been retained by the   the  introduction  of  all-in  fees.  The
         manager had it not been paid over to the adviser or LISP.   so-called all-in fee is an annual charge levied by the
         The  investor,  therefore,  is  no  worse  off  than  had  the   management  company  which  includes  the  trailer
         kickback not been paid – the amount represented to the   commission due to a broker or LISP. All-in fees make
         investor as available for investment (after fees) has not   for  easier  administration  for  brokers  and  clients:
         changed.                                        instead  of  units  possibly  having  to  be  sold  to  pay
           While this is true, kickbacks do distort the investor’s   trailer commissions (which can create CGT events),
         perception of the amount that may have been available   the  fund  manager  collects  the  fee  and  remits  the
         for  investment  if  all  commissions  and  rebates  were   commission  to  the  broker  or  LISP.  In  comparing
         excluded  (for  example,  by  choosing  a  competing   annual charges it is important to differentiate all-in
         product). Furthermore, kickbacks potentially distort the   fee structures from regular fee structures.
         principle of negotiated fees agreed by client and adviser:
         the client may not have agreed to the disclosed fee had he or she known about the kickback.
           Even if one accepts the dubious “no loss to the investor” argument, kickbacks have two more
         insidious harmful effects. Firstly, they may predispose an adviser or LISP to push investors into funds
         offering the most attractive kickbacks rather than considering the clients’ best interests. Secondly,
         where they are not disclosed they create a hidden cost which makes it impossible for investors to
         fully understand the fees and to objectively compare the costs of competing products.
           Even where they are disclosed kickbacks are inherently less transparent than regular fees and
         significantly complicate the task of calculating and comparing costs.
           In a circular published in January 2013, the FSCA directed that all payments made to a financial
         adviser must be disclosed to the investor and the investor’s consent must be given for all payments,
         including kickbacks. The impact of fees and commission on investment performance should also
         be disclosed.
           Note that some ETFs use rebates to deal with progressive fee structures (eg, where investments
         above a certain threshold enjoy a lower annual fee). See unit classes, page 64 .
         Annual service fees
           Annual service fees are the fees charged by the manager or management company for asset
         management and related services. These fees are expressed as a percentage of the funds under
         management.
           Under  the  Unit  Trust  Control  Act,  annual  service  fees  were  regulated  (until  1998),  and  a  cap
         was placed on the maximum initial fees that could be charged by a management company. Under
         CISCA, service fees are unregulated, and managers may charge what they like provided fees are
         fully disclosed. Charges against the portfolios are also defined and must be disclosed.
           Annual fees today are anything from under 0.10% on the lowest cost passive fund available to
         over 2.5% on the most expensive active fund unit classes (excluding performance fees). Given
         the complete deregulation of fees under CISCA even higher fees could be charged by collective
         investment schemes – the only requirement is full disclosure. It is up to advisers and investors to
         make sure they are fully aware of all fees which may be charged by a fund. Hedge fund fees, inclusive
         of performance fees, could amount to an effective 7.0% of initial investment for a fund charging a
         2% annual fee and 20% of the performance above a benchmark if the fund delivers 25% growth in a
         year. Annual fees for South African money market funds average 0.30%.
           Management fees are quoted as an annual percentage, but in practice they are recovered monthly
         or even daily by the fund. A portfolio with a net asset value of R2bn, for example, and an annual
         service fee of 1% is entitled to recover R20m per annum in fees.
           Given that portfolio values change daily, however, the manager may choose to recover 1/365 per
         day, based on the daily valuation. This amounts to around R55 000 per day on a portfolio of R2bn.




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