At EISA , we are well aware that it can often be difficult to compare the fees of different EIS managers. We are very keen to promote transparency and clarity in our industry, and so we have been looking at how we can best achieve this.
The approach that we are now taking is to equip advisers so that they can ask the right questions of the fund managers, so that they are fully informed and so can make fair comparisons.
To this end we have produced some guidelines or Principles for managers, as to what they should be disclosing. In turn they can also be used by advisers to ask questions of the managers. The principles can be found here
It is important to note that these are guiding principles that we view as best practice rather than a mandatory set of rules. EIS and SEIS managers are of course, free to set their own fee structures as they see fit in line with their commercial and business model and it is not EISA’s role to preach to members about their fee or any other arrangements. The idea behind the principles we have come up with is that they are financial planner led. This means the principles are purely and simply based on extensive feedback we have sought from financial planners about what they would like to see from EIS and SEIS managers when reviewing and comparing fees.
As examples, we believe that it should be clear if VAT is payable and on what; and what fees are charged to the investor and which to the investee companies.( this impacts on both the tax relief that can be claimed, and the amount available for the investee company to use).We would also suggest that all fees over the first 5 years ( excluding performance fees) are disclosed, so that it is in line with fee disclosure of other investment products.
As well as the Principles we have also produced an example sheet on how fees might be disclosed. ( Please note that these are example figures only). These can be found here
This is stage 1 in a wider body of work we are conducting on fees and how they can be compared. As a result we would welcome feedback on how you are using the guidelines, and any improvements you would like to see.
Please send any feedback to Martin Fox, chair of EISA’s Research, Education and Marketing Committee, at firstname.lastname@example.org.