The Evidence-Based Investor

Over to you, Chris Cummings

Posted by Robin Powell on January 26, 2018

If you didn’t listen to In Business on BBC Radio 4 last night, you really should catch up with it. The programme’s called The Transparency Detectives, and it’s available for download via the In Business podcast page. Lesley Curwen and her team should be congratulated on a thorough investigation of the issues around investment fees and charges, and the continuing lack of transparency from the UK asset management industry.

During the programme, Curwen asks Chris Cummings, Chief Executive of the fund industry trade body, the Investment Association, whether he regretted the language used in its infamous “Loch Ness Monster” report from August 2016. The report claimed there was “zero evidence that funds’ returns are affected by hidden fees lurking within, suggesting that ‘hidden fund fees’ may in reality be the ‘Loch Ness Monster of investments’”. Cummings wouldn’t give a straight answer; by way of an excuse, he said the report was published before he took up his position. Although that’s true, it does remain on the IA’s website, available for everyone to read, despite the fact it is now patently clear that it is completely misleading.

Andy Agathangelou, the Chairman of the Transparency Task Force of which I’m an official Ambassador, has now written an open letter to Mr Cummings, asking him to take the report down and apologise for it.


Andy Agathangelou quote about Investment Association and Chris Cummings


Like Andrew, I found the Loch Ness Monster report offensive to everyone who’s worked so hard at drawing this issue to the public’s attention. All of us on the Task Force are volunteers. We don’t get paid for the work we do; we do it because we believe in it. For the Investment Association to suggest, effectively, that we’ve made this whole thing up when we clearly haven’t is deeply insulting.

Here is Andy’s letter in full. It demands a response. Over to you, Mr Cummings.

Dear Chris,

I trust you are well.

I have listened the BBC Radio 4 programme that was aired on 25th January about hidden fees in investments and I am connecting with you today in light of your comment on the programme, in response to a question by Lesley Curwen, that the language used by the Investment Association in its August 2016 ‘Loch Ness Monster’ press release was “regrettable.”

In that press release, referencing a research report that was widely criticized, and which I believe the Investment Association commissioned itself, the Investment Association stated: ‘The report finds zero evidence that funds’ returns are affected by hidden fees lurking within, suggesting that ‘hidden fund fees’ may in reality be the ‘Loch Ness Monster of investments’.

Despite its inaccuracy and its offensiveness the press release can still be read on your website, here.

I and many others complained at the time about the research and the offensive press release. Here’s also a link to some comments I made about the matter. If you Google Search you will find many similar comments from many others.

Furthermore, via your Director of Public Policy, Jonathan Lipkin, I asked the Investment Association to apologise to campaigners for having issued such an offensive press release. The Investment Association considered doing so but to my surprise chose not to. I wasn’t impressed with the misleading and offensive press release and I was even less impressed by your organisation’s unwillingness to act courteously and apologise for the offence caused.

As you know, some campaigners such as Gina Miller and Dr. Chris Sier have been working tirelessly and selflessly to educate your organization on the hidden fees issue for as much as ten years, using their own personal time and resources to do so, for no reward whatsoever. I believe that they and people like them deserve an apology from the Investment Association and to be honest I think Gina Miller, Dr. Chris Sier et al should also be given public recognition and thanks by the Investment Association and perhaps even Her Majesty’s Government for their dogged determination to have investors’ interests looked after properly. Pensioners in years to come will be able to enjoy a better standard of living because of the thankless work that they and many others have been doing.

In light of the admission you made in yesterday’s programme and in light of the fact that MiFID II has now completely disproven the assertion that there is no evidence of hidden fees (please see this analysis from the lang cat, on page 12) I believe that now is the right time for the Investment Association to take action and admit that it has been completely wrong about hidden fees for a long, long time.


Andy Agathangelou quote about building trust after Chris Cummings offensive report



I therefore hereby respectfully and courteously ask that you, as Chief Executive of the Investment Association take the following action:

  1. Please take down the misleading and offensive August 2016 press release from your website
  2. Please issue a communication piece clearly stating that the Investment Association’s position that there have not been any hidden fees for all these years has in fact now been proven to have been entirely wrong
  3. Please issue a public apology about your “Loch Ness Monster” press release to Gina Miller, Dr. Chris Sier and all others that have been campaigning for greater transparency on costs and charges
  4. Please give public recognition and thanks for the service to the nation that Gina Miller, Dr. Chris Sier and others have selflessly provided over the years. I can provide you with a long list of names, over 100 people in fact. In my opinion they have been doing the Investment Association’s job of reforming the Asset Management Industry and helping ensure investors get better value for money for you
  5. Please ensure that none of your members treat pro-transparency campaigners disrespectfully and discourteously; and most definitely please ensure that none of your members’ employees ever resort to the kind of bullying and emotional blackmailing mentioned by Gina Miller in yesterday’s programme
  6. Please introduce enforceable codes of conduct for all your members that insist on the highest standard of professional conduct; including properly looking after the interests of the investor
  7. There is a close correlation between transparency, truthfulness and trustworthiness. The sad truth is that The Asset Management industry is not trusted and I believe that the lack of trust in your industry is a significant factor in the UK having the lowest savings ratio it has had since 1963. We all need to work together to rebuild trust and confidence in the pensions and investments market; not doing so will be leaving a systemic risk unchecked. Nobody wants millions of people unable to afford a financially secure retirement; and the worst case scenario of that risk is extremely severe – the inter-generational tensions it may create are potentially destabilizing at a societal and at an economic level. Please do all you possibly can to exert your leadership on your membership such that all your members operate as transparently as possible; because only through transparency do we have any hope of rebuilding trust.

I am happy to discuss these requests with yourself and the Financial Conduct Authority with a view to concluding the whole matter expediently; and I am happy to be joined by all other pro-transparency campaigners that may wish to attend.

I believe that a cultural transfusion within the sector is now needed and that’s going to take a great deal of envisioned leadership from all interested parties. I am happy to do all I can to support any authentic efforts you and others make in reforming the sector.

If you, personally; the Investment Association as a whole and all your members are authentically aligned with wanting the best possible outcomes for the UK’s investors and pension savers we are on the same side. If that’s the case let’s all work together, collaboratively and collegiately with a renewed sense of purpose about what the asset management industry should be about – serving the needs of its clients to the best of its ability.

I look forward to hearing from you soon.

Kind regards,


Andy Agathangelou

Founding Chair, the Transparency Task Force


ROBIN POWELL is the founder and editor of The Evidence-Based Investor. A freelance journalist, he runs Regis Media, a specialist content marketing consultancy for financial advice firms around the world. You can follow him on Twitter and on LinkedIn.

The Evidence-Based Investor is produced by Regis Media, a boutique provider of content and social media management to financial advice firms around the world. For more information, visit our website and YouTube channel, or email Sam Willet or Christina Waider.


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Robin Powell

Robin is a journalist and campaigner for positive change in global investing. He runs Regis Media, a niche provider of content marketing for financial advice firms with an evidence-based investment philosophy. He also works as a consultant to other disruptive firms in the investing sector. Regis Media.

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