Agenda item

MiFID II Compliance and Declaration

The Investment and Accounting Team Lead will present an update requesting completion by members of their self-certification of MiFID II.

Minutes:

Chris Moore, Investment and Accounting Team Lead, presented an update requesting completion by members of their self-certification of MiFID II. The update included but was not limited to that MiFID II related to the professional investor status held by the Fund, with it noted that the Fund decided to opt for the status during the Committee meeting that took place on 13 September 2017. It was outlined that the committee completes this annual self-certification process as part of its assessment of maintaining professional client status.

 

It was outlined that previously the assessment had been made by asking each voting member of the committee to sign a self-certification form. This year it was proposed that the Fund made a collective assessment of its competence, or if preferred members can complete the individual signed declarations.

 

The Committee discussed the update with it suggested that within the Committee there was the ability to collectively ask the right questions and make informed decisions using advice given by the professional advisors supporting the Committee. A further point was raised in regard to the Government consultation paper that though the Fund had professional advisors available, it was questioned whether Committee members had sufficient knowledge to make challenges to those advisors and that the Committee and Pension Board would have to be at the same level.

 

A point was raised about the recent churn rate of the Committee with Membership often changing and that in the past there had been greater consistency, possibly suggesting that the knowledge base of the Committee had declined.

 

It was suggested that a recorded vote be taken should the Committee agree to collectively confirm their competence as apologies had been received from the voting Employer Body representatives on the Committee. Therefore, enabling the Committee to have an audit trail of the Membership who would need to complete declaration at a later date.

 

Lizzie Watkin, Treasurer of the Wiltshire Pension Fund stressed the importance of being evidence based with decisions and that there would be a need to identify risks and gaps in knowledge to ensure that training provided was targeted. This would therefore enable the Committee to fulfil its responsibilities in a robust manner with confidence.

 

A further point was raised regarding the local election in May and how this could potentially cause a further churn to the Committee Membership and that training would be important as well as ensuring that if a new Membership was to be assembled that they had a chance to get to know each other.

 

At the conclusion of debate, it was,

 

Resolved:

 

The Committee agreed:

 

For the Committee to confirm that collectively they have the requisite skills, experience and support to remain a professional investor.

 

For individual Committee Members to be aware and conscious of particular training that they might require and take responsibility to raise this with the Chairman or officers in order to receive training.

 

A recorded vote took place with all Members present voting unanimously on the resolution: Cllr Gavin Grant, Cllr Richard Britton, Cllr Kevin Small, Cllr Stuart Wheeler, Cllr Vijay Manro, Cllr Gordon King and Cllr Robert Yuill.

Supporting documents: