Monday, 16 January 2017

Suitability of Investments: Why it's so complicated but doesn't need to be

There is much on-going controversy in the financial advice industry amongst regulators, so-called and real advisors and their firms and consumer advocates about the current suitability standard for recommending investments versus a possible best interests standard.

There are three main issues:
1) suitability definitions (e.g. IIROC Rules or Ontario Securities Commission requirements) for investment industry salespeople are meant to stop abusive practices. Most often this involves putting clients into highly risky, high cost securities. This issue accounts for 99% of the whole suitability vs best interests debate.
2) suitability for someone like me, a reasonably informed self-directed investor (who thereby has no ethical conflicts), equates to the best interest standard. The only thing that's suitable for me is what's best for me. ... But it still leaves a very wide possible variation of investments. I could probably ask three highly experienced, completely ethical true financial advisers to tell me what investments to make and I could probably get three very different answers. This reality shows up in the definitions - beyond the words about Know Your Client and Know Your Product, the regulatory definition of suitability is still either circular where the word suitable itself is repeated, or it says something vague like "must apply sound professional judgement". That's because there is no single correct best answer even when you take into account risk tolerance and risk capacity, short and long term objectives, complete financial circumstances, including taxes and so on. The world, and life, is too uncertain to be sure you have what will turn out to be the best answer. I can say that things get even more complicated in retirement when additional factors become as or more important than the investment portfolio, such as future inflation, unknown longevity, other products like annuities, unknown health, mental decline, account choice for holdings and withdrawals (TFSA, RRSP, RLIF, regular), CPP and OAS changes by the government. If you don't believe me, peruse the writings of Wade Pfau whose research seems not to (yet?) have uncovered, after probing many suggested approaches, a right answer on how to organize the investment side alone. For example, see this discussion of three ways to incorporate bonds in a retirement portfolio about which he notes "Scholars and practitioners have numerous disagreements about the best way to incorporate bonds into a real-world retirement income plan."
3) suitability can and should also apply at the portfolio level, not just individual securities, funds or ETFs. Asset allocation is a powerful risk mitigation tool that works at the portfolio level. Thus, robo services that propose and actually implement collections of ETFs with rebalancing rules should not have to apply a suitability judgment against individual ETFs - a more volatile emerging markets ETF as a minor portfolio component with USA equity and a bond fund can reduce overall volatility and that would make it ok even for a conservative investor. On its own, it would probably not be ok however.

When all is said and done, I believe, for example, that a low fee balanced equity - fixed income fund (such as Larry Macdonald's One Minute Portfolio or our similar Reluctant Investor's Lifelong Portfolio) is suitable for everyone and anyone, of whatever age or financial circumstances. Why? simply because it is not unsuitable. The anti-definition is best >> What is suitable? = Anything that is clearly not unsuitable. 

Eliminating the Unsuitable by avoiding dangers
In practical terms, a default automatic suitability pass could consist of individual securities, mutual funds, ETFs or portfolios with all of:
  • no leverage 
  • no use of derivatives
  • low fees, for example under 0.75% MER
  • diversification, such as individual mutual funds or ETFs with holdings of 50 or more individual securities
  • avoid over-concentration by holding less than 10% of total portfolio value in individual securities, which also must be listed in the TSX Composite index, or S&P 500
  • fixed income (individual) with ratings of investment grade or funds with no less than 70% investment grade holdings
  • portfolios (such as robo advisors provide) of equity combined with fixed income where each of the two is limited to 30% to 70% of the total value
  • minimum liquidity characteristics, an exact number for which I cannot suggest but would be based on trading volumes in a public market
It's quite possible that other securities could pass the suitability test - indeed one of my favourite and highly suitable funds is BMO's Low Volatility Canadian Equity ETF with only 46 holdings. Such alternatives would need to have more justification as to why they are suitable e.g. low volatility is very beneficial for a retired investor to reduce sequence of returns risk (a large market drop early in retirement combined with portfolio withdrawal causing an irretrievable reduction in the portfolio) while retaining the equity exposure.
Such a restrictive approach to suitability as the above makes investing simpler and allows the focus to shift to the other elements of financial management for individuals, which is where it should be.

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