Dr. John Spence
Saracen Fund Managers Limited
Hi John, tell us about your background and your role at Saracen Fund Managers?
I am a retired General Medical Practitioner, having worked for 30 years in the East End of Glasgow. I became a director, with responsibility for compliance, of Saracen Fund Managers Limited at its inception in 1998. I carried out this function alongside my role as a GP Principal. As the compliance role “flourished” I retired from medicine in 2009. I was the ACD until 3 years ago when that role was outsourced. I am now the part-time compliance director with responsibility for all elements of compliance and risk within the company.
MiFID II has been a headache for all investment firms throughout 2018, with smaller-sized managers facing their own unique challenges. How has this impacted Saracen & your role in the past few months?
I was contracted to nominally one day a week from March 2017, but MiFID II meant that I was working 3 days a week for six months before 3rd January and indeed since. With all legislation the challenges are sorting out the wheat from the chaff, find the paragraph that applies to Saracen in a 1068 page document, are you sure this applies, have I missed anything, who can help and the what is the cost of implementation in terms of money and time resource?
When it comes to compliance, smaller firms typically opt for outsourcing to give them some relief on resources. However, this can create it’s own challenges. What are your thoughts on with outsourcing compliance activities as a solution?
We have outsourced the ACD function to an ACD provider with good results. Previously I had the headache of monitoring the administrator and liaising with the depository, but for me the costs of that change have been worthwhile in terms of time and comfort in their expertise. The rump of compliance that I deal with including monitoring, I have heard mixed reports on providers effectiveness and costs. Tech is for the bigger players and minimums are too high.
What more do you think regulators and the industry can do to cater for all-sized firms when it comes to easing compliance burdens?
Having just tried to read PS18/14 on Senior Managers Regime I can see the regulator tying its self in knots attempting to cover all bases for all firms in the same legislative document. Whilst I see that the industry is complex and the variety of firm structures almost infinite, there must be a way of “bottom slicing” new legislation to match more specific firm categories. Is the voice of small firms within the industry being heard? We cannot afford to join the IA as their minimum fees are too high!
In regards to the regulatory landscape, what do you see will be keeping you busy moving towards 2019?
I am hoping my garden and golf swing will soon be keeping me busy, but what happens with Brexit or no Brexit. Will the UK regulator decide to ditch much of the recent ESMA material? What will keep me busy is watching for what comes next and does it apply to us, if it does what do I do about it.