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Page 1: RPC, Quarry Bay, Hong Kong; October 10th, 2019 · The 219 Edelman Trust Barometer. Mobile: +44 (0)7501 460308 andy.agathangelou@transparencytaskforce.org ... • The financial services

RPC, Quarry Bay, Hong Kong; October 10th, 2019

Page 2: RPC, Quarry Bay, Hong Kong; October 10th, 2019 · The 219 Edelman Trust Barometer. Mobile: +44 (0)7501 460308 andy.agathangelou@transparencytaskforce.org ... • The financial services

Welcome to

Jonathan CromptonPartnerRPC

on

“How can we accelerate the rebuilding of trustworthiness and confidence in

Financial Services?”

Page 3: RPC, Quarry Bay, Hong Kong; October 10th, 2019 · The 219 Edelman Trust Barometer. Mobile: +44 (0)7501 460308 andy.agathangelou@transparencytaskforce.org ... • The financial services

Welcome to

Andy AgathangelouFounderTransparency Task Force

on

“How can we accelerate the rebuilding of trustworthiness and confidence in

Financial Services?”

Mobile: +44 (0)7501 460308 [email protected]

Page 4: RPC, Quarry Bay, Hong Kong; October 10th, 2019 · The 219 Edelman Trust Barometer. Mobile: +44 (0)7501 460308 andy.agathangelou@transparencytaskforce.org ... • The financial services

[email protected]

Let’s please show our appreciation to today’s host and sponsor:

Mobile: +44 (0)7501 460308

But before we go any further…

Fundraising ideas to Tina Kenyon please!

[email protected]

Page 5: RPC, Quarry Bay, Hong Kong; October 10th, 2019 · The 219 Edelman Trust Barometer. Mobile: +44 (0)7501 460308 andy.agathangelou@transparencytaskforce.org ... • The financial services

[email protected]: +44 (0)7501 460308

Very brief introductions please

Please very briefly, in just a few seconds, deal with:

• Who you are; and what you and your organisation do

• Why the question “How can we accelerate the rebuilding of trustworthiness and confidence in financial services?” matters to you

Just before your introductions, a short video

Some of the speakers at our 16th May 2019 symposium in London

https://youtu.be/Ky0Qg9IpjCA

Page 6: RPC, Quarry Bay, Hong Kong; October 10th, 2019 · The 219 Edelman Trust Barometer. Mobile: +44 (0)7501 460308 andy.agathangelou@transparencytaskforce.org ... • The financial services

[email protected]: +44 (0)7501 460308

About

• We are the collaborative, campaigning community, dedicated to driving up the levels of transparency in financial services, right around the world

• We believe that higher levels of transparency are a pre-requisite for fairer, safer, more stable and more efficient markets that will deliver better value for money and better outcomes

• Furthermore, because of the correlation between transparency, truthfulness and trustworthiness, we expect our work will help to repair the reputational damage the sector has been suffering for decades

Page 7: RPC, Quarry Bay, Hong Kong; October 10th, 2019 · The 219 Edelman Trust Barometer. Mobile: +44 (0)7501 460308 andy.agathangelou@transparencytaskforce.org ... • The financial services

[email protected]: +44 (0)7501 460308

About mission• We are an informal but increasingly influential forum of ethically-

minded people that care about the financial services sector and the people it serves

• We are collaborative, collegiate and consensus-building; focusing on solutions not blame

• We believe the financial ecosystem is profoundly important to the wellbeing of society, the global economy and political stability; but there’s a great deal wrong with it that needs reforming

➢ Our mission: “To protect consumers’ financial interests by reforming the financial services sector through harnessing the transformational power of transparency”

Page 8: RPC, Quarry Bay, Hong Kong; October 10th, 2019 · The 219 Edelman Trust Barometer. Mobile: +44 (0)7501 460308 andy.agathangelou@transparencytaskforce.org ... • The financial services

• Hidden and excessive costs

• Hidden and excessive risks

• Opportunistic opacity

• Opportunistic obfuscation

• Short-termism

• Insufficient client-centricity

• Scams and scandals

• Regulatory capture

• Irresponsible reward systems

• Malpractice, malfeasance, misconduct, miss-selling

[email protected]: +44 (0)7501 460308

What is

• A ‘profit before principles’ mindset

• A ‘money before morals’ mindset

• Conflicts and misalignment of interest

• Excessive lending and gearing

• Disingenuous communications

• Financial instability

• Weak governance

• A lack of market integrity

• A lack of values-based leadership

working to reform?

Page 9: RPC, Quarry Bay, Hong Kong; October 10th, 2019 · The 219 Edelman Trust Barometer. Mobile: +44 (0)7501 460308 andy.agathangelou@transparencytaskforce.org ... • The financial services

The 219 Edelman Trust Barometer

Page 10: RPC, Quarry Bay, Hong Kong; October 10th, 2019 · The 219 Edelman Trust Barometer. Mobile: +44 (0)7501 460308 andy.agathangelou@transparencytaskforce.org ... • The financial services

[email protected]: +44 (0)7501 460308

My message on 6th May 2015 at Senate House, London University

• The financial services sector has to be trusted to function successfully• If we take trust out of financial services we have nothing left • The trust deficit is therefore a serious and systemic issue• The gradual but continuous “drip, drip, drip” of reputational damage caused

by misconduct means we may be sleep-walking into perceiving low levels of trust as “business as usual”

• If we allow the trust deficit to be “business as usual” we run the risk of tolerating what we should not tolerate

• If we tolerate what we shouldn’t we will start to expect it• If we tolerate and expect it, we are unwittingly condoning it; perpetuating

the problem• The problem will not go away on its own; we should do something• Solving the trust deficit is such a huge task that it may seem possible• But it definitely can be solved; we just need to do what needs to be done

➢ What would need to be done?

Page 11: RPC, Quarry Bay, Hong Kong; October 10th, 2019 · The 219 Edelman Trust Barometer. Mobile: +44 (0)7501 460308 andy.agathangelou@transparencytaskforce.org ... • The financial services

[email protected]: +44 (0)7501 460308

What would it take to fix the trust deficit?

• Essentially, we would need to do 4 things. • We would need to:

1. Fully embrace “the art of the possible”2. Create a very strong sense of purpose about the change that is needed3. Bring together the right people4. Develop a plan; that we execute to the best of our collective ability

Page 12: RPC, Quarry Bay, Hong Kong; October 10th, 2019 · The 219 Edelman Trust Barometer. Mobile: +44 (0)7501 460308 andy.agathangelou@transparencytaskforce.org ... • The financial services

[email protected]: +44 (0)7501 460308

“Plan Beats No Plan”Mark Carney, 30th June 2016 at the Court Room, The Bank of England

• In the absence of any other plan; our plan is better than nothing• The more people we share the plan with:

- The better the plan will get- The better we will get at executing the plan

Page 13: RPC, Quarry Bay, Hong Kong; October 10th, 2019 · The 219 Edelman Trust Barometer. Mobile: +44 (0)7501 460308 andy.agathangelou@transparencytaskforce.org ... • The financial services

[email protected]: +44 (0)7501 460308

Late last year, the plan started taking shape

• We would first need to show there is a problem that needs fixing• We produced a White Paper* to provide evidence that there is a problem • The White Paper is

- a meta-study of research about the Trust Deficit; its causes and consequence- a call to action

• The call to action is for all key stakeholders to work together to develop and execute the plan

• How can we bring people together?• We decided to use a question to initiate and

facilitate a global conversation about the Trust Deficit and what can be done about it

* Download it here: https://www.transparencytaskforce.org/rebuilding-trust-confidence-in-financial-services/

Page 14: RPC, Quarry Bay, Hong Kong; October 10th, 2019 · The 219 Edelman Trust Barometer. Mobile: +44 (0)7501 460308 andy.agathangelou@transparencytaskforce.org ... • The financial services

[email protected]

“How can we accelerate the rebuilding of trustworthiness and confidence in financial services?”

Mobile: +44 (0)7501 460308

• The question is very deliberately future-orientated; we must learn from the past but not live in it – this is not about apportioning blame

• The question is very deliberately solution-orientated; we avoid the temptation to just pose the question – we want answers

• The question is very deliberately palatable to all stakeholders such as politicians, policymakers, politicians, academics, regulators, thought-leaders, subject-matter experts, progressive market participants, trade bodies and professional associations and so on

• The question is a gateway question through which dialogue can move into the many underlying causes of the trust deficit

Page 15: RPC, Quarry Bay, Hong Kong; October 10th, 2019 · The 219 Edelman Trust Barometer. Mobile: +44 (0)7501 460308 andy.agathangelou@transparencytaskforce.org ... • The financial services

The approach to solving the trust deficit needs to comprehensive

Mobile: +44 (0)7501 460308

• Dealing with just the individual “heads” of the problem won’t work• If we just “chopped off” individual heads they will just “grow back”• We need a whole-system solution to fix a whole-system problem• The solution needs to be systemic and systematic

[email protected]

Page 16: RPC, Quarry Bay, Hong Kong; October 10th, 2019 · The 219 Edelman Trust Barometer. Mobile: +44 (0)7501 460308 andy.agathangelou@transparencytaskforce.org ... • The financial services

We are “crowd-sourcing” our plan

[email protected]: +44 (0)7501 460308

• We are meeting a wide range of stakeholders around the world

• Group meeting such as today’s event

Page 17: RPC, Quarry Bay, Hong Kong; October 10th, 2019 · The 219 Edelman Trust Barometer. Mobile: +44 (0)7501 460308 andy.agathangelou@transparencytaskforce.org ... • The financial services

Progressively-minded people want to help improve and execute the plan; they are authentically aligned with the mission

Boston 12th March 2019

New York 14th March 2019

[email protected]: +44 (0)7501 460308

London 16th May20109

Dublin 29th May 2019

Amsterdam 6th June 2019

Zurich 18th March 2019

Brussels 20th June 2019

Page 18: RPC, Quarry Bay, Hong Kong; October 10th, 2019 · The 219 Edelman Trust Barometer. Mobile: +44 (0)7501 460308 andy.agathangelou@transparencytaskforce.org ... • The financial services

Progressively-minded people want to help improve and execute the plan; they are authentically aligned with the mission

[email protected]: +44 (0)7501 460308

Washington DC September 10 2019

Boston September 12 2019

New York September 11 2019

Page 19: RPC, Quarry Bay, Hong Kong; October 10th, 2019 · The 219 Edelman Trust Barometer. Mobile: +44 (0)7501 460308 andy.agathangelou@transparencytaskforce.org ... • The financial services

[email protected]

The Programme of events for 2019

Mobile: +44 (0)7501 460308

✓ Boston on 12th March, kindly hosted by Mercer✓ New York on 14th March, kindly hosted by Davies Ward Phillips Vineberg✓ London on 16th May, kindly hosted by Newgate Communications✓ Dublin on 29th May, kindly hosted by Azon Recruitment Group✓ Amsterdam on 6th June, kindly hosted by AON✓ Zurich on 18th June, kindly hosted by Charles Russell Speechlys✓ Brussels on 20th June, kindly hosted by CFA Institute✓ Washington DC on 10th September kindly hosted by King & Spalding✓ New York on 9th September, kindly hosted by Grant & Eisenhofer✓ Boston on 12th September, kindly hosted by First Republic Bank• Hong Kong on 10th October, kindly hosted by RPC• Sydney on 15th October, kindly hosted by Dimensional Fund Advisors• Melbourne on 17th October, kindly hosted by Mercer• Singapore on 22nd October, host wanted• London on 5th November, kindly hosted by Duff & Phelps• Dublin on 7th November, host wanted• Amsterdam 19th November, host wanted• Paris on 20th November, host wanted• Brussels on on 21st November, host wanted• Luxembourg City on 22nd November, host wanted• Frankfurt on 10th December, kindly hosted by European Banking Federation• Zurich on on 11th December, host wanted• Geneva on 12th December, host wanted

Page 20: RPC, Quarry Bay, Hong Kong; October 10th, 2019 · The 219 Edelman Trust Barometer. Mobile: +44 (0)7501 460308 andy.agathangelou@transparencytaskforce.org ... • The financial services

We are “crowd-sourcing” our plan

[email protected]: +44 (0)7501 460308

• We are meeting a wide range of stakeholders around the world

• Group meeting such as today’s event

• Plus some profoundly positive and impactful individual meetings….

Page 21: RPC, Quarry Bay, Hong Kong; October 10th, 2019 · The 219 Edelman Trust Barometer. Mobile: +44 (0)7501 460308 andy.agathangelou@transparencytaskforce.org ... • The financial services

[email protected]

15th March 2019; meeting with Georg Kell

Mobile: +44 (0)7501 460308

• A very memorable meeting; coffee and bagels in New York• Founder of the United Nations Global Compact and a key driver behind

the UN Global Compact’s Sustainable Development Goals• I explained the overall aims and objectives of the TTF; and our idea to

bring ethically-minded people together to help tackle the trust deficit• His response was wonderfully supportive• The conversation inspired the creation of the

Finance Development Goals• Each FDG to be developed by subject-matter experts

experts from around the world

➢ What is your level of interest in relation to each of the 12 Finance Development Goals?

Page 22: RPC, Quarry Bay, Hong Kong; October 10th, 2019 · The 219 Edelman Trust Barometer. Mobile: +44 (0)7501 460308 andy.agathangelou@transparencytaskforce.org ... • The financial services

[email protected]: +44 (0)7501 460308

VIRTUOUS LEADERSHIP“The supreme quality for leadership is unquestionably integrity. Without it, no real success is possible, no matter whether it is on a section gang, a football field, in an army, or in an office."- Dwight D. Eisenhower

This FDG covers topics such as:

•Virtues-based and values-based leadership•Why we must deal with the "leader's dilemma" problem, to unlock the potential for major transformational change•Moral Quotient•The insights of Adam Smith's work on moral sentiments•The insights of Alexandre Havard on virtuous leadership

Page 23: RPC, Quarry Bay, Hong Kong; October 10th, 2019 · The 219 Edelman Trust Barometer. Mobile: +44 (0)7501 460308 andy.agathangelou@transparencytaskforce.org ... • The financial services

[email protected]: +44 (0)7501 460308

CREATE A CLIENT-CENTRIC CULTURE“Ethics is knowing the difference between what you have a right to do and what is right to do.”- Potter StewartThis FDG covers topics such as:•Ethics, Values, Professionalism, Fairness•“Principle before profit” and “Morals before money”•The need for a cultural transfusion•The use of Moral Quotient•Diversity and Gender•Mandating for higher standards of conduct•The effective use of oaths, codes of conduct, standards boards and pledges•Trade Bodies and Professional Associations to realise their potential role as cultural architects•Individual, Organisational and Market Integrity•Encourage diversity of ownership structures such as Mutuals, Coops and FairShare•Why it is so important that individuals think for themselves and don’t "follow the herd" despite the potential career risk consequences of doing so•Having metrics to measure, monitor and manage trust

Page 24: RPC, Quarry Bay, Hong Kong; October 10th, 2019 · The 219 Edelman Trust Barometer. Mobile: +44 (0)7501 460308 andy.agathangelou@transparencytaskforce.org ... • The financial services

[email protected]: +44 (0)7501 460308

HARNESS THE TRANSFORMATIONAL POWER OF TRANSPARENCY“Sunlight is the best of disinfectants; electric light the most efficient policeman”- Justice Louis Brandeis

This FDG covers topics such as:

•The need for transparency on costs & charges•The need for transparency on any risks the client may be exposed to•The need for transparency on performance metrics•The need for transparency on the agenda and motivations of actors•The development of a Global Transparency Index•Why is transparency in and of itself necessary but not sufficient?•What are the limitations and potential pitfalls of having too much of "the wrong type of transparency” and “unconstrained standardisation”?•Decision-making being underpinned by relevent and reliable data•Benchmarks and indices being free of bias and distortion•Credit Rating Agencies being fit for purpose

Page 25: RPC, Quarry Bay, Hong Kong; October 10th, 2019 · The 219 Edelman Trust Barometer. Mobile: +44 (0)7501 460308 andy.agathangelou@transparencytaskforce.org ... • The financial services

[email protected]: +44 (0)7501 460308

HARNESS THE TRANSFORMATIONAL POWER OF TECHNOLOGY“Computers are useless. They can only give you answers.”- Pablo Picasso

This FDG covers topics such as:

•How “technology is a friend of transparency” and why it should be fully utilised•Harnessing the inherent advantages and efficiencies provided by technology •The enormous potential for Fintech, Blockchain, Smart Contracts, AI, greater Interoperability and evolutions thereof to radically improve the integrity of the system•The scope for technology to reduce operating friction and the sector's higher-than necessary costs, thereby protecting consumers from excessive friction costs that worsen outcomes e.g. they corrode investment returns•Making good use of technology to provide person-specific data; for example, through data dashboards dealing with pensions and investments contextualised with individual-specific planning goals•The potential risks of over-reliance on technology and inadvertently absorbing systemic risks into the ecosystem; particularly through inadequate cyber security

Page 26: RPC, Quarry Bay, Hong Kong; October 10th, 2019 · The 219 Edelman Trust Barometer. Mobile: +44 (0)7501 460308 andy.agathangelou@transparencytaskforce.org ... • The financial services

[email protected]: +44 (0)7501 460308

GOVERN WELL“Good governance is the art of putting wise thought into prudent action in a way that advances the well-being of those governed.”- Diane Kalen-Sukra

This FDG covers topics such as:

•Compliance•Regulatory reform•Firm and consistent enforcement of the rules; with adverse publicity for rule-breakers, thereby creating an effective deterrent•The vital role of effective accounting, auditing, financial reporting and credit rating•Custodianship•Stewardship of capital; such that the world's capital markets can operate as a force for good•Encouraging greater inclusion and diversity•Developing an “International Regulatory Master Plan”

Page 27: RPC, Quarry Bay, Hong Kong; October 10th, 2019 · The 219 Edelman Trust Barometer. Mobile: +44 (0)7501 460308 andy.agathangelou@transparencytaskforce.org ... • The financial services

[email protected]: +44 (0)7501 460308

DESIGN PRODUCTS THAT DELIVER“Good design is like a refrigerator—when it works, no one notices, but when it doesn’t, it sure stinks.”- Irene Au

This FDG covers topics such as:

•Products to be engineered to a high standard•Products to be fit for purpose•Products to be free of fundamental flaws•Product Accreditation•Transparency Accreditation•Providing value for money

Page 28: RPC, Quarry Bay, Hong Kong; October 10th, 2019 · The 219 Edelman Trust Barometer. Mobile: +44 (0)7501 460308 andy.agathangelou@transparencytaskforce.org ... • The financial services

[email protected]: +44 (0)7501 460308

COMMUNICATE AUTHENTICALLY“The single biggest problem in communication is the illusion that it has taken place.”- George Bernard Shaw

This FDG covers topics such as:

•Presenting data and information clearly and intelligibly•Encouraging greater consumer engagement wherever possible•Seek to minimise the amplification of adverse publicity through active PR and Reputation Management•Asymmetries of information to be minimised•Use of Simple Benefit Statements•Asymmetries of information to be minimised•Use of Simple Benefit Statements•Communicating with integrity, credibility and authenticity

Page 29: RPC, Quarry Bay, Hong Kong; October 10th, 2019 · The 219 Edelman Trust Barometer. Mobile: +44 (0)7501 460308 andy.agathangelou@transparencytaskforce.org ... • The financial services

[email protected]: +44 (0)7501 460308

ACT WITH PURPOSEFULNESS"When you are inspired by some great purpose, some extraordinary projects, all your thoughts break their bonds; your mind transcends limitations; your consciousness expands in every direction; and you find yourself in a great new and wonderful world. Dormant forces, faculties and talents become alive and you discover yourself to be a greater person by far than you ever dreamed yourself to be."- Patanjali

This FDG covers topics such as:

•Impact Investing•Sustainability•Climate Change•ESG•Socially Responsible Investing•Social Finance•Social Stock Exchanges

Page 30: RPC, Quarry Bay, Hong Kong; October 10th, 2019 · The 219 Edelman Trust Barometer. Mobile: +44 (0)7501 460308 andy.agathangelou@transparencytaskforce.org ... • The financial services

[email protected]: +44 (0)7501 460308

INCENTIVISE RESPONSIBLY“Show me the incentives and I’ll show you the outcome"- Charlie Munger, Berkshire Hathaway

This FDG covers topics such as:

•Responsible Reward•Fully account for human nature and “what’s in it for me?” mindsets•Manage out conflicts of interest where possible; fully disclose where not•Alignment of Interests; dealing with the “Principal-Agent Problem."•Use fee and payment structures that align interests wherever possible•Alignment of goals, returns and risks•Adopt Fiduciary Duty, Duty of Care and Best Interests thinking

Page 31: RPC, Quarry Bay, Hong Kong; October 10th, 2019 · The 219 Edelman Trust Barometer. Mobile: +44 (0)7501 460308 andy.agathangelou@transparencytaskforce.org ... • The financial services

[email protected]: +44 (0)7501 460308

STABILISE THE ECOSYSTEM“Remember when nurses, carers, teachers and students crashed the stock market, wiped out banks, took billions in bonuses and paid no tax? No, me neither.”- Fuad Alakbarov

This FDG covers topics such as:

•Minimising the risk of systemic market failures that lead to severe shocks to the system

Page 32: RPC, Quarry Bay, Hong Kong; October 10th, 2019 · The 219 Edelman Trust Barometer. Mobile: +44 (0)7501 460308 andy.agathangelou@transparencytaskforce.org ... • The financial services

[email protected]: +44 (0)7501 460308

PROTECT CONSUMERS FROM HARM“To not do what you can to protect someone, that's cowardly.”- Jodi Lynn Anderson

This FDG covers topics such as:

•Minimise the risk of fraud and scams•Properly support and care for those that have been scammed•Be alert to policy failures that risk harming consumers - pension freedoms•Financial Consumers' Bill of Rights•Use litigation to provide redress and proactively drive changes in market practice•Encourage and facilitate worry-free whistleblowing•Safeguard data integrity; develop resilient and robust Cyber Security•Get the administration right - strive for operational and administrative excellence•Proactively seek to repair damage when it is done; problems will inevitably arise; and mistakes will inevitably happen•The vital role that can be played by more and better financial education to boost financial literacy for consumers, mitigate the risks associated with asymmetries of information and help prevent miss-selling to the vulnerable

Page 33: RPC, Quarry Bay, Hong Kong; October 10th, 2019 · The 219 Edelman Trust Barometer. Mobile: +44 (0)7501 460308 andy.agathangelou@transparencytaskforce.org ... • The financial services

[email protected]: +44 (0)7501 460308

MANAGE RISK“Not taking risks one doesn't understand is often the best form of risk management"- Raghuram G. Rajan

This FDG covers topics such as:

•The need for transparency on any risks the client may be exposed to•The need for transparency on performance metrics•The need for transparency on the agenda and motivations of actors

Page 34: RPC, Quarry Bay, Hong Kong; October 10th, 2019 · The 219 Edelman Trust Barometer. Mobile: +44 (0)7501 460308 andy.agathangelou@transparencytaskforce.org ... • The financial services

[email protected]

Comments?

Mobile: +44 (0)7501 460308

Questions?

Ideas?

3 minute comfort break; Followed by “the book that is much more than just a book”

Page 35: RPC, Quarry Bay, Hong Kong; October 10th, 2019 · The 219 Edelman Trust Barometer. Mobile: +44 (0)7501 460308 andy.agathangelou@transparencytaskforce.org ... • The financial services

[email protected]: +44 (0)7501 460308

Title: “Rebuilding Trust and Confidence in Finance”…why we need to; and how we

• A new edition each year

• Edition #1; May 2020 (coinciding with a major meeting in London)

“The book that is much more than just a book”

Page 36: RPC, Quarry Bay, Hong Kong; October 10th, 2019 · The 219 Edelman Trust Barometer. Mobile: +44 (0)7501 460308 andy.agathangelou@transparencytaskforce.org ... • The financial services

[email protected]: +44 (0)7501 460308

Chapter 1: Executive summary

Page 37: RPC, Quarry Bay, Hong Kong; October 10th, 2019 · The 219 Edelman Trust Barometer. Mobile: +44 (0)7501 460308 andy.agathangelou@transparencytaskforce.org ... • The financial services

[email protected]: +44 (0)7501 460308

Chapter 2: strategy for driving change

• Which is all about bringing together the thinking of two very important groups:

- #1, those with a sense of passion & purpose about what needs to change, such as our Ambassadors and the members of our Special Interest Groups- #2, those with the power & position to make change happen; such as

the politicians, policymakers, regulators, leaders of key trade bodies and professional associations, leaders of key commercial organisations etc.

We already do this in many ways including through our Special Events; here are three good examples of our Special Events:

Page 38: RPC, Quarry Bay, Hong Kong; October 10th, 2019 · The 219 Edelman Trust Barometer. Mobile: +44 (0)7501 460308 andy.agathangelou@transparencytaskforce.org ... • The financial services

‘The First Transparency Strategy Summit in the World’

‘The primary purpose of the first Transparency Strategy Summit in the world is to begin to build consensus on the best way to protect the interests of the UK’s pensions-saving public through full disclosure on all the costs and charges they are paying but not being told about’.

• 12th September 2016 at the Houses of Parliament

Page 39: RPC, Quarry Bay, Hong Kong; October 10th, 2019 · The 219 Edelman Trust Barometer. Mobile: +44 (0)7501 460308 andy.agathangelou@transparencytaskforce.org ... • The financial services

……which may have led to the opening of the Work & Pensions Select Committee’s Enquiry on Pensions Costs Transparency

5th Sept 2018 at the Commons:

x 110 (99 in the UK+ 11 overseas)13th Jan 2017

Page 40: RPC, Quarry Bay, Hong Kong; October 10th, 2019 · The 219 Edelman Trust Barometer. Mobile: +44 (0)7501 460308 andy.agathangelou@transparencytaskforce.org ... • The financial services

‘Launch of the TTF Banking Team’s White Paper on Current Accounts’

• 26th June 2017 at the Houses of Parliament

‘Sensible recommendations about the lack of transparency around charges for Free-If-In-Credit personal current accounts’

Page 41: RPC, Quarry Bay, Hong Kong; October 10th, 2019 · The 219 Edelman Trust Barometer. Mobile: +44 (0)7501 460308 andy.agathangelou@transparencytaskforce.org ... • The financial services

“Ideas to help reduce the chance of another Global Financial Crisis”

• 7th February 2018 at the Houses of Parliament

‘A special meeting at which we presented our White Paper on the topic and initiated the launch of a new All Party Parliamentary Group on Financial Stability’; the inaugural meeting is on 23rd May

Page 42: RPC, Quarry Bay, Hong Kong; October 10th, 2019 · The 219 Edelman Trust Barometer. Mobile: +44 (0)7501 460308 andy.agathangelou@transparencytaskforce.org ... • The financial services

[email protected]: +44 (0)7501 460308

Chapter 3: The 1,000 VIPs

• We will refer to the 1,000 most influential people in the world’s financial ecosystem; they will be listed in the Appendix

• These individuals are the “power and position” group for whom the book has been especially written; they will be told that

• The book is a clarion call for engagement to that group; we will be reaching out to each one

• The process of outreach is happening already and it is working

• The more engagement we get the easier it will become to get more engagement

• There will be a “tipping point dynamic”

Page 43: RPC, Quarry Bay, Hong Kong; October 10th, 2019 · The 219 Edelman Trust Barometer. Mobile: +44 (0)7501 460308 andy.agathangelou@transparencytaskforce.org ... • The financial services

[email protected]: +44 (0)7501 460308

Chapter 4 - The Problem Statement

The Problem Statement will give an Evidence-Based account of:

- What the Trust Deficit is- Why it is like “a festering sore on the face of financial services” that

desperately needs treating- Its causes and consequences

Virtually 80% of Chapter 5 has already been written; we will be repurposing the White Paper written with Newgate Communications

Page 44: RPC, Quarry Bay, Hong Kong; October 10th, 2019 · The 219 Edelman Trust Barometer. Mobile: +44 (0)7501 460308 andy.agathangelou@transparencytaskforce.org ... • The financial services

[email protected]: +44 (0)7501 460308

Chapter 5 - The Vision Statement

The Vision Statement is where we

- “Dare to dream” of having a transparent, truthful and trustworthy financial services sector

- Articulate a deliberately utopian view that will help us envision what it will mean for society if trust and confidence in financial services was restored

- Showing the contrast/compare between the Problem Statement and the Vision Statement will give the book a natural sense of direction

Page 45: RPC, Quarry Bay, Hong Kong; October 10th, 2019 · The 219 Edelman Trust Barometer. Mobile: +44 (0)7501 460308 andy.agathangelou@transparencytaskforce.org ... • The financial services

[email protected]: +44 (0)7501 460308

Chapters 6 to 17; each dedicated to a Finance Development Goal

- Each of these FDG Chapters will be a collection of of thought-leadership essays written by relevent subject-matter experts mostly drawn from the TTF Ambassadors Their essays will be a response to a FDG-specific question:“How can we accelerate the rebuilding of trustworthiness and confidence in financial services through……better leadership?”…cultural reform?”…harnessing the power of transparency?”…harnessing the transformational power of technology?”…better governance?”…better product design?”…communicating authentically?”…greater purposefulness?”…intelligent incentives?”…stabilising the financial ecosystem?”…better consumer protection?”…better management of risk?”

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Subject Matter Experts so far

First Name Surname Job Title Organisation FDG

Carol Nolan Drake President and CEO Carlow ConsultingGovernance

Chris Tobe Founder Stable Value ConsultantsTransparency

Darby Hobbs Founder Conscious CapitalismPurposefulness

Ian McDonald Founder Integral Business CentreLeadership

Jeff Mamorsky Co-Chairman Greenberg Traurig

Jon Lukomnik Founder Sterling Capital

Larry Bates Founder The Wealth GameTransparency

Laurence Wormald Investment Manager Random PerformanceRisk

Marcin ZabaInvestor Relations Manager SyndicateRoom

Communications

Mark Turner Managing Director Duff & PhelpsGovernance

Matthew Priestley

Head of Investment Management Oversight FundRock Partners

Meredith Gibson Principal Meredith Gibson AdvisoryCommunications

Nicholas Morris Adjunct ProfessorUniversity of New South Wales

Governance

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Subject Matter Experts so far, continued

First Name Surname Job Title Organisation FDG

Paul MoxeyProfessor of Corporate Governance

London South Bank University

Governance

Paul Bates Founder Bates Barristers

Consumer Protection

Peter Schmid Managing Partner Iamdix

Piotr Konwick Senior LecturerUniversity of Hertfordshire

Rob Lake Founder Authentic InvestorPurposefulness

Robert Van Beek Founder About Life & Finance

Ruth Steinholtz Managing Partner AreteWork Culture

Simon Grover Lead Writer QuietroomCommunication

Sue LewisIndependent Board Member

Financial Services Consumer Consultant

Consumer Protection

Sue Jaffer

Sunil Chadda Managing Director Cairn ConsultingTransparency

Tamar Joulia-Paris Managing Director TJ Capital

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Subject Matter Experts so far, continued

First Name Surname Job Title Organisation FDG

Andrew Mills Director Insight Financial Research

Darby Hobbs Founder Conscious CapitalismPurposefulness

Graham Boyd CEO & Founder EvolutesixPurposefulness

Justin O'Brien Director The Trust Project

Susan Cuff Director Cuff AssociatesCulture

Robert Dellner Managing Director I3 Partners

Risk Management

Dan Brocklebank Director, UK Orbis InvestmentsIncentives

Sheri Markose Professor of Economics Essex UniversityFinancial Stability

Prabhu Guptara Executive Director Relational Analytics

John Hewson ProfessorCrawford School of Public Policy

Governance

William Jannace Senior Counsel Ross PLLC

Rohanna Wise Founder & CEO Wise Trading Technologies

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Subject Matter Experts so far, continuedFirst Name Surname Job Title Organisation FDG

Thom Young President FARcapitalIncentives

Michael Erlanger Co-Founder GoKnownTechnology

Shann Turnbull PrincipalInternational Institute of Governance

Governance

Paolo Sironi Industry AcademyWatson Financial Services, IBM

Transparency

Guy Spier CEO Aquamarine CapitalIncentives

Willi Brammertz Managing Director AriadneTransparency

Allan MendelowitzActus Research Foundation

Transparency

Markus Krebsz Member

United Nations’ Group of Experts on Risk Management in Regulatory Systems

Risk Management

Cliff Southcombe Managing DirectorSocial Enterprise International

Purposefulness

Rory Ridley-Duff Co-Founder Fairshares AssociationPurposefulness

Liz MurphySteering Group Member UK Values Alliance

Culture

Kara Tan Bhala President & FounderSeven Pillars Institute for Global Ethics & Finance

Culture

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Subject Matter Experts so far, continued

First Name Surname Job Title Organisation FDG

David M. Rowe PresidentDavid M. Rowe Risk Advisory

Risk Management

Stefan Pagacik Co-Founder AI 4 Impact

Consumer Protection

Roger Miles Head of FacultyHead of Conduct and Academy

Pascal Hogenboom Associate Director Strategia WorldwideLeadership

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[email protected]: +44 (0)7501 460308

Chapters 6 to 17; continued

- Each of these FDG chapters will also have a set of Formal Recommendations written collaboratively by members of The Scientific Committee; addressed to the 1,000 VIPs

- The Scientific Committee will be made up of highly credible academics and renowned experts from around the world

- They will be a “Dream Team,” too credible to be ignored; and they will also be mostly sourced from the fast-growing community of Transparency Task Force Ambassadors…

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Scientific Committee so far

First Name Surname Job Title Organisation FDG

Professor Anna TilbaAssociate Professor in Strategy & Governance

Durham University Business School

Financial Stability

Professor Andreas HoepnerProfessor of Risk Management & Data Science University College Dublin

Risk Management

Dr. Krzysztzof Grabowski Lecturer in Corporate Governance Kozminski UniversityGovernance

Professor John Wilson Pro-Vice Chancellor Newcastle University

Laurence Wormald Investment Manager Random Performance

Martin Rich Co-Founder & Executive Director Future Fit Foundation

Dr. Nicholas Morris Adjunct ProfessorUniversity of New South Wales

Professor Paul Moxey Professor of Corporate GovernanceLondon South Bank University

Professor David Webber Professor of Law Boston University

Dr. Shann Turnbull PrincipalInternational Institute of Governance

Governance

Dr. Piotr Konwicki Senior Lecturer University of Hertfordshire

Professor Tamar Joulia-Paris Managing Director TJ Capital

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Scientific Committee continuedFirst Name Surname Job Title Organisation FDG

Professor Sheri Markose Professor of Economics Essex Univursity

Financial Stability

Dr. Ashby Monk Executive and Research DirectorStanford Global Projects Center

Transparency

ProfesssorMichael Mainelli Executive Chairman Z/Yen Group

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[email protected]: +44 (0)7501 460308

Chapter 18: Conclusion

• New input wanted from existing subject-matter experts

• New subject matter experts invited to input

• The 1,000 VIPs invited to respond to the Formal Recommendations they have been given; the readers become the writers over time

• Invitation for suggestions for new additions to the 1,000 VIPs

• We will refresh the 1,000 VIPs each year; selecting out those that have not engaged and replacing them with those that do

• There will only ever be 1,000 people in the 1,000 VIPs

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[email protected]: +44 (0)7501 460308

Chapter 19: Thanks and recognition

• All contributions duly recognised and fully attributed• The book will be seen to be a team effort because that’s exactly what

the whole initiative is• We will be fully recognising all support given whether that be by way of

written content, operational support, project management support, technical input, sponsorship, guidance and so on

• We will be showing names, logos, websites and so on

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[email protected]

The book will be highly impactful

Mobile: +44 (0)7501 460308

• The people involved with the book will be a dream-team of experts• The book will be too credible and too compelling to be ignored• It will articulate good, Evidence-Based ideas; and it will explain precisely

who needs to do what to turn those ideas into reality• Each year there will be an updated edition with a refreshed set of

recommendations• We will be able to shine a bright light on who has done what in response to

the actions recommended by the Scientific Committee• If they wish, the 1,000 named individuals will be able to report on actions

taken and progress made since the previous edition• Over time, we hope and expect more and more of the 1,000 to become

increasingly involved in this initiative• The book will work like having a sat-nav for finance reform, always asking:

- Where are we?- Where do we want to get to? - How are we going to get there?

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Mobile: +44 (0)7501 460308 [email protected]

Mark GochnourHead of Global Client ServicesDimensional Fund Advisors

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Redefining Investment Advice

Mark R. Gochnour, CFA

Head of Global Client Services and Vice President, Dimensional Fund Advisors LP

10 October 2019

FOR ATTENDEES OF THE TRANSPARENCY TASK FORCE SYMPOSIUM HELD IN HONG KONG ONLYThis document is deemed to be issued by Dimensional Hong Kong Limited (CE No. BJE760), which is licensed by the Securities and Futures Commission to conduct Type 1 (dealing in securities) regulated activities only and does not provide asset management services.

For use by licensed financial advisors and institutional investors who are “professional investors” (as defined in the Securities and Futures Ordinance [Chapter 571 of the Laws of Hong Kong] and its subsidiary legislation) only in Hong Kong. This document is provided solely for internal training and educational purposes and is not for the purpose of inducing, or attempting to induce, such financial advisors and institutional investors to make an investment nor for the purpose of providing investment advice. Not for use with the public.

Unauthorized copying, reproducing, duplicating, or transmitting of this material are prohibited. This document and the distribution of this document are not intended to constitute and do not constitute an offer or an invitation to offer to the Hong Kongpublic to acquire, dispose of, subscribe for or underwrite any securities, structured products or related financial products or instruments nor investment advice thereto. Any opinions and views expressed herein are subject to change. Neither DimensionalHong Kong Limited nor its affiliates shall be responsible or held responsible for any content prepared by financial advisors or institutional investors. Financial advisors in Hong Kong shall not actively market the services of Dimensional Hong Kong Limited or its affiliates to the Hong Kong public.

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“The Investment Experience People Deserve”

SALES-CENTRIC MODEL CLIENT-CENTRIC MODEL

ProductProviders

Salespeople

Customers

Clients

Advisors

Dimensional

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Putting Clients First

Dimensional

Discover

Design

Deliver

Discipline

ADVISORS

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Growth of Global Financial Advisor Assets

In US dollars. "Global" refers to the Dimensional separate but affiliated entities generally, rather than to one particular entity. These entities are Dimensional Fund Advisors LP, Dimensional Fund Advisors Ltd., DFA Australia Limited, Dimensional Fund Advisors Canada ULC, Dimensional Fund Advisors Ltd., Dimensional Japan Ltd., and Dimensional Hong Kong Limited. Dimensional Hong Kong Limited is licensed by the Securities and Futures Commission to conduct Type 1 (dealing in securities) regulated activities only and does not provide asset management services. Dimensional Japan Ltd. does not manage any financial advisor assets.

As of 31 March 2019

$0

$50

$100

$150

$200

$250

$300

$350

$400

$450

96 97 98 99 00 01 02 03 04 05 06 07 08 09 10 11 12 13 14 15 16 17 18 19

Asia ex JapanUS Australia Canada Europe

$402BAUM

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Putting Clients First

DIMENSIONALSolutions for AdvisorsADVISORSClient Expertise

AdvisorBusinessSuccess

AnOutstanding

InvestorExperience

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Appendix

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Financial Advisor Assets

“Dimensional” refers to the Dimensional separate but affiliated entities generally, rather than to one particular entity. These entities are Dimensional Fund Advisors LP, Dimensional Fund Advisors Ltd., DFA Australia Limited, Dimensional Fund Advisors Canada ULC, Dimensional Fund Advisors Pte. Ltd., Dimensional Japan Ltd., and Dimensional Hong Kong Limited. Dimensional Hong Kong Limited is licensed by the Securities and Futures Commission to conduct Type 1 (dealing in securities) regulated activities only and does not provide asset management services. All assets in US dollars. Numbers may not total 100% due to rounding.

Financial

Advisor

Services

• The composition of financial advisor assets reflects a

globally diversified approach to investing.

• Dimensional offers a full range of equity and fixed

income strategies, as well as specialized solutions,

including REIT, commodity, tax-management, social, and

sustainability strategies.

Dimensional

at a Glance

(as of 31 March 2019)

• Founded in 1981

• $576B in global AUM

• More than 1,400 employees globally

• 13 offices around the worldVancouver

Santa Monica Austin

London

Amsterdam

Berlin

Singapore

Sydney

Tokyo

Toronto

Melbourne

Investment Personnel

Client Service

Charlotte

Hong Kong

US Equity39.8%

Developed ex US Equity18.8%

Emerging Markets Equity8.4%

Global Equity5.9%

Fixed Income20.1%

Other6.8%

$402 billion as of 31 March 2019

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Putting Clients First

Client Messaging

Business Strategy

DIMENSIONAL

Investment Solutions

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Recommending Your Advisor

1. PwC, Sink or swim: Why wealth management can’t afford to miss the digital wave.2. J.D. Power Studies, U.S. full Service Investor Satisfaction Study.3. CFA Institute, From Trust to Loyalty: A Global Survey of What Investors Want.4. Results from Dimensional 2017 Investor Feedback Survey.

J.D. Power 2016 USFull Service Investor Satisfaction Study2

CFA Institute2016 Trust to

Loyalty Survey3

39% 48% 98%51%

Advisors workingwith Dimensional4

2016 PWC Strategy Report1

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The money I have entrusted with you represents years of hard work and sacrifice. Your actions will impact this family for generations. It not only will be long-term business for you but the opportunity for my children, and their children’s education and well-being, are in your control.

Please don't let us down.

”Source: 2016 Dimensional Investor Feedback Survey.

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Don't let my account value fall below $850,000.00.

Contact me for further information.

“”

Source: 2016 Dimensional Investor Feedback Survey.

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The Dimensional Experience

“The focus on the client experience has always been, and will continue to be, why we do what we do.”

DAVE BUTLERDirector, Co-Chief Executive Officer and

Head of Global Financial Advisor Services

AN

OUTSTANDING

INVESTOR

EXPERIENCE

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Source: Michael Ramirez, cartoon, Investor's Business Daily, April 7, 2008, www.investors.com/editorial/cartoon.asp.

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How Dimensional’s Approach Is Different

There is no guarantee strategies will be successful.

Conventional Management

Attempts to identify mispricing in

securities

Relies on forecasting to select “undervalued” securities or time markets

Generates higher expenses,

trading costs, and risks

Indexing

Allows commercial index to

determine strategy

Attempts to match index

performance, restricting which

securities to hold and when to

trade

Prioritizes low tracking error over

higher expected returns

Dimensional

Gains insights about markets and

returns from academic research

Structures portfolios along the

dimensions of expected returns

Adds value by integrating

research, portfolio management,

and trading

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[email protected]

We restart at 11:30

Mobile: +44 (0)7501 460308

Refreshments & Networking

Fundraising ideas to Tina Kenyon please!

[email protected]

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Mobile: +44 (0)7501 460308 [email protected]

Jonathan Crompton,PartnerRPC; Member of the Advisory BoardJustice Without Borders

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Fraud Recoveries and the Protests

The Transparency Task Force, Hong Kong Meeting

Jonathan Crompton

Partner, RPC

10 October 2019

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Agenda

Fraud Recoveries

• Business Email Compromise – The $26 Billion Scam

• Hong Kong and BEC

• Issues with Fraud Recoveries in Hong Kong

The Protests

• Effect on Fraud Recoveries

Towards Greater Trust

76 10 October 2019Fraud Recoveries and the Protests

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77 10 October 2019Fraud Recoveries and the Protests

“Business Email Compromise The $26 Billion Scam”

“The BEC/EAC scam continues to grow and evolve, targeting small, medium, and

large business and personal transactions. Between May 2018 and July 2019, there

was a 100 percent increase in identified global exposed losses…

The scam has been reported in all 50 states and 177 countries. Fraudulent

transfers have been sent to at least 140 countries...”

Source FBI PSA Alert No. I-091019-PSA, 10 September 2019 (https://www.ic3.gov/media/2019/190910.aspx)

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78 10 October 2019Fraud Recoveries and the Protests

“Business Email Compromise The $26 Billion Scam”

*Source FBI PSA Alert No. I-091019-PSA, 10 September 2019 (https://www.ic3.gov/media/2019/190910.aspx)

June 2016 to July 2019 (reported)

Domestic and international incidents: 166,349*

Domestic and international exposed [US] dollar loss: $26,201,775,589*

Average exposed USD loss per incident $157,510.87

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FBI PSA Alert No. I-091019-PSA, 10 September 2019

Hong Kong and BEC:

“Based on the financial data, banks located in

China and Hong Kong remain the primary

destinations of fraudulent funds.”

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Recent Frauds Involving HK Bank Accounts

• UK citizen investing in Thai property development (<US$100,000)

• Leading global animal genetics company headquartered in the US (approx.

US$100,000)

• Singapore-based corporate gift company (approx. US$150,000)

• Singapore-based building materials company (approx. $200,000)

• Australian office of a port logistics company (approx. US$250,000)

• And… UK-resident victim of US$50-100 million asset manager Ponzi scheme

(approx. US$28 million)

80 10 October 2019Fraud Recoveries and the Protests

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Suspicious Transaction Reporting – OSCO

• If know / suspect any property represents proceeds of an indictable offence

– Must disclose to JFIU or HKPF as soon as reasonable practicable – s.25(A) OSCO

– Failure to report → up to HK$50,000 and 3 months’ imprisonment

• Tipping off – an offence to broadcast or publish any information which reveals

that a report has been made to JFIU or the identity of anyone who has made a

report

81 10 October 2019Fraud Recoveries and the Protests

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Suspicious Transaction Monitoring –AMLCTFO

• Duty to continuously monitor business relationship (AMLCTFO Sch. 2, para 5),

incl.:

• “conducting appropriate scrutiny of transactions carried out for the

customer to ensure that they are consistent with the financial

institution’s… knowledge of the customer and the customer’s

business and risk profile, and the with financial institution’s…

knowledge of the source of the customer’s funds”

• “identifying transactions that are complex, unusually large in amount or

of an unusual pattern, and have no apparent economic lawful

purpose”

• Financial institutions incorp’d in HK must ensure that its branches and

subsidiaries have procedures to ensure compliance with similar CDD and

record keeping requirements

• Obligation to report suspicious transactions

• Knowing contravention → up to HK$1 million + 2 years

82 10 October 2019Fraud Recoveries and the Protests

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Fraud Recovery in Hong Kong

• Account holder

– Often a new company (easy to set up)

– Overseas shareholders

• PRC nationals?

• Offshore corporations?

• Victims

– Overseas companies

– Individuals

– SMEs

– MNCs

– Especially Retail, but all industries

83 10 October 2019Fraud Recoveries and the Protests

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Fraud Recovery in Hong Kong (ii)

84 10 October 2019Fraud Recoveries and the Protests

• Financial Institutions

– HK a trusted international business hub → international fund flows normal

– Transaction monitoring unreliable (from victim’s perspective) and not SAFE → lots of

protective reports

– Relationship / rapport is key

• Police

– Efficient use of customer resources

– Broad investigative powers

– Inconsistent

• Courts

– Effective, but slow

– Inconsistent approaches

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Fraud Recoveries in HK… in normal practice

85 10 October 2019Fraud Recoveries and the Protests

Contact the bank

If USD / US involvement:

Report online to FBI

Online report to HK Police

Move quickly

File a civil claim

Civil injunction

application (expensive)

Report in person to HK Police

Report to local law

enforcement

Write to FBI

LegAt

Email and phone HK Police

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The Protests

86 10 October 2019Fraud Recoveries and the Protests

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Effect of the Protests on Fraud Recoveries

E.g.s:

• Online report – Slow allocation to investigating officer

• Inability to contact investigating officer

• HKPF distracted & frustrated

• Access to physical reporting rooms

• Transport difficulties (to and from reporting rooms / Court)

• Business interruption, including banks (e.g. 5 August ‘general strike)

BUT still possible relatively efficiently, with persistence and patience

87 10 October 2019Fraud Recoveries and the Protests

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Fraud Recoveries in HK… during the protests

88 10 October 2019Fraud Recoveries and the Protests

Contact the bank

If USD / US involvement:

Report online to FBI

Online report to HK Police (ineffective / no

allocation to investigating officer)

Move quickly

File a civil claim

Civil injunction

application (expensive)

Report in person to HK Police (longer and more

expensive)

Report to local law

enforcement

Write to FBI

LegAt

Email and phone HK Police (CTSB)

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Rebuilding Trust and Confidence in Financial

Services

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Towards Greater Trust

90 10 October 2019Fraud Recoveries and the Protests

Law Enforcement

• Responsive

• Concerned

• Fast

• Pro-active → contacting victim regularly

• Informative → providing information on funds in account

• Quick and flexible use of consent letters where evidence of fraud

Courts

• Fast

• Efficient

• Consistent

Financial Institutions

• Stringent account opening

• Effective transaction monitoring

– Considered

– Consistent

– ‘SAFE’

• Pro-active → Appropriate freezing of accounts

• Contactable

• Sympathetic and helpful to victims

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Fraud Recoveries and the Protests

Q&A

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Fraud Recoveries and the Protests

The Transparency Task Force, Hong Kong Meeting

Jonathan Crompton

Partner, RPC

10 October 2019

[email protected]

Tel: +852 2216 7173

Mob: +852 6822 5016

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[email protected]: +44 (0)7501 460308

Suggestions for “The 1,000 VIPs”

• Politicians?• Policymakers?• Regulators?• Trade Bodies?• Professional Associations• Bankers• International organisations• Other…

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Mobile: +44 (0)7501 460308 [email protected]

Raphael DouadyHolder of the Robert Frey Endowed Chair for Quantitative Finance at Stony Brook, New York; Fellow of the Centre d’Economie de la Sorbonne, Paris; Academic Director of the Laboratory of Excellence on Financial Regulation;Ambassador of the Transparency Task Force

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Raphael Douady

Are more conservative capital adequacy rules always safer?

Transparency Task Force, RPC, Quarry Bay, Hong Kong October 10th 2019

University Paris 1 – CNRSRiskdata

9606/06/2013

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97

0

500

1000

1500

2000

2500

3000

1980's Savings & Loans Crisis vs. 2008 Credit CrunchCommercial Banks and Savings Intitutions

# Failed Banks & Institutions

Deposits $Bn

06/06/2013

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• Basel I (1988, enforced in 1992)– Cooke Ratio

• Basel II (2004, enforced in 2008)– 3 “pillars” (capital, governance, discipline)

– Cooke ratio + VaR + Operational risk

• Basel III (expected 2013, TBE 2018)– Risk-Weighted Capital (Tier1, 2, 3)

vs. Risk-Weighted Assets

– Stressed VaR = VaR + Stress Tests

– Credit Counterparty Risk (CCR)

– Credit Value Adjustment (CVA)

9806/06/2013

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• Aim of Basel III

– Face “Black Swans”➢Stressed VaR

– Avoid Contagion➢Credit Counterparty Risk

– Align Capital with Expected losses➢Risk Weighted Assets

➢CVA

➢Is more capital safer?

9906/06/2013

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• Haldane “The dog and the Frisbee”• Proven irrelevant and dangerous over-simplicity

– Gaussian distributions missing “fat tails” (Mandelbrot)– Frozen correlations, linear factor modeling– Markowitz optimization

• Good simplicity: goal– Don’t lose more than X– Stay alive if Y happens– Don’t destroy the source of revenues

• Bad simplicity: means– Most of the time, relation is mostly linear– Distribution is mostly bell-shaped Gaussian

• Solutions to goal simplicity in a complex environment are never simple• Mathematics are rich: they can model almost everything, provided good

questions are asked!

10006/06/2013

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• A flaw of VaR-based Capital Adequacy

Market falls Volatility surges VaR increases

Massive sales to meet CA Market falls…

• A flaw of Marked-to-Market

Distrust Demand vanishes Price falls Distrust…

• Tragedy of the Commons in the Risk

• VaR + M2M produce an embedded instability

• J.C. Trichet (Paris, 1994)

– “Beware of herd behavior with VaR”

10106/06/2013

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• Stressed VaR

– Stress Tests not procyclical, but SVaR = VaR + STests

– Higher capital requirement More pressure Overreaction to Market drops

– If simply added to VaR, stress tests increase procyclicality

• CCR + CVA

– Same logic as VaR with each Counterparty

CTP Credit CVA CTP out of business Default

– Even worse with CTP credit hedging with CDS

CTP Credit Buy CDS CDS CVA …

10206/06/2013

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• VaR = Market Scenario x Sensitivity

• When markets fall:

Scenario Sensitivity Sale

• Regulator computes Scenarios

– Must anticipate crises

– Provides means to deflate a bubble before it bursts, by preemptively widening scenarios

• Institutions compute Sensitivities

– Must account for complex instruments and nonlinearities

– Back-test possible to check sensitivity computation

10306/06/2013

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104

Source: Accenture “Basel III and Its Consequences”

06/06/2013

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• Risk-weighted Assets + Quantitative Easing

Capital arbitrage Lend to AA/AAA rather than High Yield

Capital is absorbed by less profitable business

Growth More QE More money to AAA

Leverage of AAA Systemic crisis

• RWA rule imposes the ratio between credit spreads of investment grade and high yield bonds

– Biased markets

– Instability: capital flies away precisely when needed!

10506/06/2013

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• Weights in RWA apply only beyond a threshold

– Base Cooke Ratio = 8% Lend 12.5 x Capital

– Below 6 x Capital Unweighted Assets

– Beyond 6 x Capital Weights apply

• Impose Leverage limit

• Avoid procyclical definition of Capital

– RWC amplify procyclicality

• Adapt weights to economic conditions in order to maintain financing of the “growth tank”

10606/06/2013

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• Macroeconomic consequences of RWA

– Downgrade from Tier 1 to Tier 2 is worse than by Rating Agencies

– Required Capital x 2, then x 4 Credit Spreads x 2, x 4

– On the one hand, Central Banks help endangered states

– On the other hand, Regulators remove capital from same states

• Weak states are driven to default by the “deadly debt spiral”

• Stronger states borrow at almost 0 rates

Minsky’s “Financial Instability Hypothesis”

10706/06/2013

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• Sovereign Debt ≠ Corporate Debt

– Decision process, social constraints…

• Avoid shock following change of tier

– Time to rebalance portfolio (months, year…)

– Smooth change of multipliers in RWA

• In Europe, mutualize sovereign debt

– European Treasury borrows on markets, lends to states at prescribed credit spread No more “spiral”

– E-bonds always Tier 1

10806/06/2013

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• If banks cannot lend, other institutions, less regulated will do it, e.g. Hedge Funds– Less reliable source of liquidities

– Unregulated lender must apply strict management rules for its own survival (no “implicit” government guaranty)

– Wild environment for business

• Too tough regulations drive credit market to even less regulated environment

• Like “too much taxes kill taxes”, we may say

“too much regulation kills regulation”

10906/06/2013

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• Keep banking sector competitive

• Give clear targets, avoid contradictory incentives

– Governments ask for more business financing

– Regulators ask for more capital constraints

• Regulatory instability + lack of Interbank confidence

Banks even more cautious than requested

• Regulations must be simple, clear and stable

11006/06/2013

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• Full Transparency perceived as panacea for ultimate risk control. Dangerous illusion!– Mass of data impossible to process

– Regulator underequipped

– Complex instruments will be left aside

• Financial institutions unaccountability– Once positions are fully reported, regulators can no longer blame

managers for irresponsibility in case of a systemic event

– Unanalyzed fully reported positions are more dangerous than unreported positions

• Full transparency doesn’t allow monitoring contagion risk– Counterparty exposure is complex, numerous

– The impact of a given market event is almost impossible to model

11106/06/2013

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• Full Risk Transparency• Risk reporting ≠ Position reporting

– Risk reporting is about scenarios– List of Stress Tests– Identification of major Risk factors– Alternative extreme sensitivities

• Counterparty risk reporting also by scenarios analysis• Scenario and Risk Factor info

– Much less complex than full position transparency– Clear, simple and unified format– Can be used to monitor contagion and systemic risk– Identify rising bubbles

11206/06/2013

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• Immense literature on Risk Measures• Full process to compute risk

Market data x Position data x Counterparty data Statistics, Risk factors, Sensitivities Loss distribution Risk Measure (VaR, ESF…)

• Risk measure computation is the last and the less sensitive step• Most important steps

– Risk factor identification– Scenarios on risk factors (incl. crises)– Impact on portfolio and counterparties

• Details provide a fake safety feeling, makes bad events look like unpredictable “black swans”, whereas they were very visible

• Rely on the wrong math, e.g. Maximum Likelihood Estimator, when the question is about scenarios and market dynamics, liquidity dry-up, ability to act and the consequences of a erroneous estimate (Taleb’s fragitility)

• A good risk measure is not one that is wrong 1% of the time by an uncontrolled amount. It is one that is never wrong by, say, a factor more than 2.

11306/06/2013

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• Refrain from focusing on Risk Measures• Focus on Risk Factors and Scenarios

– Account for the asymmetric impact of estimation errors (Taleb’s heuristics)

• A risk report stating only risk measures is useless for management will be ignored– Doesn’t say where the risk come from– Doesn’t say which actions can improve the situation

• An actionable risk report contains– Sources of risk– Scenarios that may impact the institution with detailed analysis: full

consequences of the scenario, incl. cascade effects– Possible actions (deleveraging, hedge, etc.)

• Include economic forecasts into Risk reports– Don’t simply rely on statistics and time series analysis

11406/06/2013

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• Margining is the true risk measure– If too low bankruptcy risk– If too high not competitive out of business

• High competition between exchanges and brokers– More and more complex and nonlinear derivatives

• Deal-wise Margining (e.g. SPAN) looks conservative but, to remain competitive, must apply lousy parameters

• Cross-product Margining exposed to Correlation risk• Nonlinear derivatives Full repricing methodology

– Compatible with speed and high frequency?

• Squeeze in case of missed margin call– Unwind position at a loss?– Wait and face liquidity trap?

• Many failures and systemic events start with a margin call…

11506/06/2013

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• EMIR– Eventually all standard instruments centrally cleared

– SEF growing mike mushrooms

• CCP the ultimate protection?– The ultimate SIFI…

– If deemed “riskless”, will accumulate risk and leverage, up to being truly risky

• CDS margining and clearing– Protection seller = lender Same issues as Cooke ratio

– Safety pool: what happens in case of major systemic event?

11606/06/2013

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• Increase market volatility– Is it verified?– Which volatility?

• Destabilizes markets– “Glitch” on May 6, 2010: DJIA -10% in a few minutes

• Pros– Execution costs divided by 5 vs. Market Makers– Oct 1987 Black Monday wasn’t due to High Frequency

• Is High Frequency THE problem?– Can we improve orders execution, market efficiency, without

destabilizing markets?– Where is the “enemy”?

• Fast execution?• Fast information?

11706/06/2013

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• Re-regulating finance is a necessity

• Over-reaction of industry excess has opposite effects of those sought– Regulation must respect regulated entities

• Detailed knowledge only at operators, not at regulators– Lack of trust is worse than over-confidence

– Regulators must keep overall control, leave details to operators

• Simplicity of goal– Ask for true, verifiable Risk reporting: Risk factors, extreme sensitivities

– Restore true accountability and responsible attitude

• Collect risk information that can be used to watch systemic risk: Regulator’s responsibility!

11806/06/2013

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Mobile: +44 (0)7501 460308 [email protected]

Jeff NieCo-ChairAbsolute Return Investment Management Association, China; Chief Risk OfficerKeywise Capital Management

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Transparency & Mutual understandings

Jeff Nie

2019.10.10

Hong Kong, China

120

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Bank of England poll one key word on financial sector: corruption, manipulation, self-serving, destructive, greedy

2008 Financial Tsunami

CDO rating

Madoff scandal

Question: Are we better of now?

Dangerous Situations

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Madoff Scandal

Madoff Fund approached my teams at different firms three times, and was rejected each time. The last time was in July 2008, a few months before Madoff scandal was discovered. I applied my veto power as CRO to deny any investment to the fund.

The Fairfield Sentry Fund, a Madoff feeder fund, required a $100,000 minimum investment, and was billed as a way to tap Madoff's trading expertise using "algorithmic technology" while Fairfield with due diligence conducted "systematic investment compliance". It had more than $7 billion invested with Madoff, and became one of his largest victims. It was Fairfield's signature fund, one of several feeder funds through which money from wealthy foreign investors could capitalize on Madoff’s supposed investment acumen. Its marketing prospectus promised low volatility and steady returns, and boasted 11 percent annual return over the prior 15 years, with only 13 losing months, a record that grew increasingly desirable over recent years of volatility.

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Negative Interest Rate bondsAs of Aug 31, 2019, total size of negative IR bonds was $16.2 trillions, across 13 countries, and still growing

Negative IR will drive world economics into recession, central banks will lose control of guiding the economics

Everybody is worried about NIR, but Mr. Trump is big fan of NIR UST

Fed will expand the balance sheet again shortly

UST reached $22 trillions and is still expanding —— Ponzi scheme!

Geopolitical games

Risky Situations

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At the wave of China Inclusion, ➢ Chinese companies and regulators need to understand better the

international transparency rules to meet the expectations of the overseas investors

➢ Overseas investors need to understand better the transparency requirements to avoid violating the local laws & rules

Mutual understandings

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On Sept. 27, Bloomberg reported that the White House was considering limits on US portfolio flows into China which includes delisting US-listed Chinese companies

It caused market collapsed right after the news came out

Some “experts” came to justify the means by claiming that some Chinese companies had flaws in their financial statements.

As a matter of fact, all those US-listed Chinese ADRs have US GAAP financial reports. They should NOT be selected out for particular “flaw scheme”.

IF the US-listed Chinese ADRs were forced to be delisted, then ALL investors including large US pension funds would experience large losses

Mutual understandings

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NBA & Hong Kong

"Is that what standing for the people of Hong Kong means?" he asked, referring to the NBA's continued struggles to contain the fallout from Houston Rockets general manager Daryl Morey's now-deleted tweet on Friday supporting the demonstrations in Hong Kong.

"Right now, we're talking about a destructive anarchy," the former Morgan Stanley Asia chairman said in a "Squawk Box" interview.

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Thank you very much for your time!

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Mobile: +44 (0)7501 460308 [email protected]

Discussion:

“What are the consequence of low levels of trust and confidence in financial services; for- Regulators?- Policymakers?- Market participants? (commercial entities) - Society as a whole?”

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[email protected]

• The TTF shines a light on problems; to help solve them

• The TTF also shines a light on transparency champions; to encourage others

• We do this by awarding a Transparency Trophy at each of our symposia

• The winner gets to keep it

• The star-shape is significant - people can navigate using the stars so the star shape has been chosen to symbolise the idea that the winners are helping to navigate the sector to a better place

Mobile: +44 (0)7501 460308

About

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[email protected]

• February 2016: Tomas Wijffels, Pensioen Federatie

• April 2016: Rachel Haworth, ShareAction

• June 2016: Jackie Beard, Morningstar

• September 2016: Gina & Alan Miller, the True & Fair Campaign

• October 2016: Robin Powell, Evidence-Based Investor

• November 2016: Daniel Godfrey, The People’s Trust

• December 2016: Ralph Frank, Cardano Risk Management

• February 2017: Con Keating, Brighton Rock Group

• May 2017: David Pitt-Watson, London Business School

• July 2017: Mike Barrett, The Lang Cat

• September 13th 2017: Steve Conley, Founder, Values Based Adviser

• September 28th 2017: George Kinder, Founder, The Kinder Institute

• November 15th 2017: Angela Brooks, Founder, Pension Life

Mobile: +44 (0)7501 460308

Previous winners of

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[email protected]

• November 23rd 2017: Dr. Chris Sier, Independent Chair, FCA’s IDWG

• November 30th 2017: Dan Brocklebank, Head of UK, Orbis Investments

• March 8th 2018; Henry Tapper, Pension PlayPen, First Actuarial & AgeWage

• March 14th 2018; Bob Compton, Director, ARC Benefits Ltd

• May 24th 2018: Susan Flood, Vice Chair, Ark Campaign Group

• May 24th 2018: Nicholas Morris, Adjunct Professor, Faculty of Law, UNSW

• July 11th 2018: John Howard, Director, Consumer Insights

• July 26th 2018: JB Beckett, UK Lead, Association of Professional Fund Investors

• September 20th 2018: Heather Buchanan, Dir. of Pol. APPG/Fairer Business Bk’g

• 6th November 2018: Lesley Curwen, Reporter, BBC Freelance

• 14th November 2018: Dr. Kara Tan Bhala, President and Founder, Seven Pillars Institute for Global Finance and Ethics

Mobile: +44 (0)7501 460308

Previous winners of continued

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[email protected]

• 17th December 2018: Julia Dreblow, Founder, SRI Services & The Fund EcoMarket

• 16th January 2019: Norma Cohen, Former Financial Times Correspondent

• 12th March 2019: Darby Hobbs, CEO/Founder SOCIAL3, Co-Founder & Chairperson Conscious Capitalism Boston Chapter; and Professor Boston University

• 14th March 2019: Connie and Michael Erlanger, Co-Founders of GoKnown.

• 20th March 2019: Mark Falcon, Director, Zephyre

• 16th May 2019: Dr. Anna Tilba, Associate Professor in Strategy and Governance, Durham University Business School

• 29th May 2019: Paddy Delaney, Founder, Informed Decisions

• 6th June 2019: Paolo Sironi, Watson Financial Services, IBM

• 18th June 2019: Guy Spier, Chief Executive, Aquamarine Fund

• 20th June 2019: Josiana Kamerling, Head of Regulatory Outreach, EMEA, CFA Institute

Mobile: +44 (0)7501 460308

Previous winners of continued

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[email protected]

• 10th September 2019: Chris Tobe, Founder, Stable Value Consultants

• 11th September 2019: Jon Lukomnik, Managing Partner, Sinclair Capital

• 12th September 2019: Robert McNulty, Dir of Prog’s, Hoffman Ctr for Business Ethics

• 10th October 2019: Rick Adkinson, Chief Executive, Private Capital, Hong Kong

Mobile: +44 (0)7501 460308

Previous winners of continued

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[email protected]: +44 (0)7501 460308

Lunch & networking break We restart at 13:50 please, ready for the “team photo”

Fundraising ideas to Tina Kenyon please!

[email protected]

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[email protected]: +44 (0)7501 460308

Our second short video…

Some of the speakers at our 16th May 2019 symposium in London

https://youtu.be/Is7N5DqjfXM

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[email protected]

4 main ways we will build momentum:

Mobile: +44 (0)7501 460308

#1 I will run 1 annual symposium a year in each City x 20 each one bigger and better than the one before

#2 We are going to be creating a Global Network of TTF Chapters- 8 Chapter Leaders, operating as 4 pairs- Each pair responsible for 1 meeting a year; 4 quarterly meetings a year- Meetings at breakfast, lunch or early evening- Marketing by TTF UK (+local help)- Purpose: TTF’s Strategy for Driving Change “Passion/Purpose +

Power/Position”- Must always remain “true to mission” - robust governance framework - “Like a franchise but without a profit motive; the motive is the cause; a

cause which is both noble and necessary”

#3 Quarterly Zoom Calls for EMEA, APAC, Americas + 18 Special Interest Gps

#4 New Edition of “The book that is much more than a book” each May

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Mobile: +44 (0)7501 460308 [email protected]

The Power Panel"How can we accelerate the rebuilding of trustworthiness and confidence in financial services?“

- Janet Li, Asia Wealth Business Leader, Mercer; Chairman of the Executive Committee, a member of the Members Communications Sub-Committee and a member of the Business Strategy Sub-Committee of the Hong Kong Retirement Schemes Association.

- David Piesse, Chairman of the International Insurance Society Ambassadors; Global Insurance Evangelist and advisory board of Guardtime; Advisory Board of Ultimate Risk Solutions; former Global Insurance Lead for SUN Microsystems, Asia Pacific Chairman for Unirisx, United Nations Risk Management Consultant.

- Mary Leung, Head, Advocacy, CFA Institute, Asia Pacific; The Asia-Pacific Research Exchange (ARX) and formerly with Coutts & Co and UBS AG

….leading to the Open Debate

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What does this all mean to you?

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• You have the option, if you wish, to be included in the project

• I believe that the best form of teamwork is where everybody gets to play to their strengths; so the best way for you to be involved is for you to do what is best and easiest for you

• What are your strengths and how can we help you to use them for the cause?

• The cause is both noble and necessary; please help if you can

• I will be in touch to schedule a debrief ‘phone call with each of you ☺

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Our work is done, for today!

Thank you for your attendance, input and ongoing support!

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Andy AgathangelouFounding ChairTransparency Task Force

Fundraising ideas to Tina Kenyon please!

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[email protected]: +44 (0)7501 460308

Many thanks again to today’s host, sponsors and everybody else for taking part so fully!