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Assessment of Value Take 2 : Lessons Learned?

With the majority of firms having now issued their first Value Statements and with Regulator commentary expected in the not too distant future, at Devlin Mambo we look across the market at what has been issued to date and take a view on what good looks like (or at least what it shouldn’t look like).  Each firm has their own identity, tone and client base therefore it’s positive that we’re not seeing prescriptive uniformity in the way that the value statements are drafted, however there is certainly some room for improvement…  


Under Assessment of Value firms are now obligated to demonstrate value delivered to their underlying investors, however many reports are tied up in technical language that won’t speak to the average retail investor.  Speak to your investors in language they understand using comparators that are relevant and meaningful to them.  A good example is the use of cash at bank as a performance benchmark, a universal comparator which all retail consumers can relate to.



Many of the reports issued to date are unclear in crucial areas such as Performance or Comparable Market Rates and get bogged down in heavy text.  The use of visuals, diagrams, and tables are rare and many firms have missed a trick here in terms of providing accessible reports.  We believe a balance between visuals and succinct, effective wording will enhance your clients understanding.


Be Efficient

Some of the reporting has been laborious to say the least with the same text being used again and again as each fund in a given range is reported on using almost exactly the same text as the others.   Linking to our thoughts on visuals, a table can convey the same message whilst removing the need for repetition, increasing the impact and effectiveness of your reports.


What’s important to your investors?

If your fund is aimed at a particular client, sector or niche in the market then make sure your AoV reporting speaks to this.  There will more than likely be a key reason why they have selected your fund to invest in, so make sure that they understand the value you are offering in this context.  A very topical example is ESG – there is nothing to prevent a firm explaining why a fund is delivering value in relation to ESG goals despite this not featuring in the FCA’s 7 pillar framework.  This reporting should be more than a box ticking exercise, expand on the framework provided by the regulator, speak to what’s important to your firm and more importantly your investors.


The Sweeping Statement

Many of the reports that we saw are only too happy to make sweeping statements testifying that their “Board is happy” or that the “Board concluded that this represents good value” without any qualification or back up provided.   Through various regulations implemented since 2008 the regulator has again and again referred to the need for accountability and transparency to the underlying investor.  If you want to assure your investors that they are getting a good deal, provide the evidence to back this up or at the very least explain how you arrived at your conclusions. 

We look forward to reviewing the second round of reporting…

At Devlin Mambo we review and document key value statements which are then compared to our ‘best practice example value statement’. If you would like to discuss Assessment of Value further, please contact Graeme Devlin ( or your Devlin Mambo relationship contact.

About the author

Graeme Devlin

Graeme is a co-founder of Devlin Mambo and leads our Product & Distribution and Compliance & Governance practices.

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