The Financial Conduct Authority is consulting on how fund managers can enable direct-to-fund dealing and use tokenised registers.

Steven Haynes
9 Min Read

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Fund Managers & Tokenised Registers: The Future of Direct Dealing?

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The Financial Conduct Authority (FCA) has thrown open the doors to a potential revolution in how investment funds operate. In a recent consultation, the UK’s financial watchdog is exploring how fund managers can embrace direct-to-fund dealing and leverage the power of tokenised registers. This isn’t just a regulatory tweak; it’s a seismic shift that could redefine efficiency, accessibility, and the very nature of investment.

### What’s Cooking at the FCA? Direct-to-Fund Dealing and Tokenised Registers

At its core, the FCA’s consultation aims to streamline the investment process. Currently, investors typically buy and sell fund units through intermediaries like platforms or brokers. Direct-to-fund dealing would allow investors to transact directly with the fund manager, potentially cutting out layers and reducing costs.

Complementing this, the FCA is examining the use of tokenised registers. Imagine a digital ledger where ownership of fund units is represented by unique digital tokens. This technology, often associated with blockchain, promises enhanced security, transparency, and real-time record-keeping. Together, these concepts could usher in a new era of fund management.

### The Promise of Direct-to-Fund Dealing: Cutting Out the Middleman

The traditional fund dealing process, while functional, is often a multi-step affair. An investor decides to buy or sell, places an order with their platform or broker, who then communicates with the fund’s transfer agent, who finally updates the fund’s register. Each step adds time, potential for error, and a cost.

Direct-to-fund dealing aims to collapse this chain.

**Key benefits include:**

* **Reduced Costs:** By eliminating intermediaries, fund managers can potentially pass on savings to investors in the form of lower fees or improved fund performance.
* **Increased Efficiency:** Faster transaction settlement times can lead to quicker access to capital for investors and more predictable cash flows for fund managers.
* **Enhanced Investor Experience:** A more direct relationship could foster greater transparency and a more personalised service for investors.
* **Greater Control for Fund Managers:** Direct engagement allows fund managers to have a clearer view of their investor base and manage flows more effectively.

However, this shift isn’t without its challenges. Fund managers would need to build robust infrastructure to handle direct client onboarding, compliance checks, and customer service.

### Tokenised Registers: The Digital Backbone of the Future

Tokenisation is the process of representing an asset, such as a fund unit, as a digital token on a blockchain or distributed ledger technology (DLT). This isn’t just a futuristic concept; it’s a technology with tangible benefits for the financial industry.

**How tokenised registers can transform fund management:**

* **Immutable and Transparent Records:** DLTs create a tamper-proof and auditable trail of all transactions, significantly enhancing transparency and reducing the risk of fraud.
* **Real-Time Updates:** Ownership records can be updated instantaneously, eliminating the delays associated with traditional paper-based or batch processing systems.
* **Fractional Ownership:** Tokenisation can facilitate the division of fund units into smaller, more accessible fractions, democratising investment.
* **Automated Compliance:** Smart contracts, self-executing agreements coded onto the blockchain, can automate compliance checks and dividend distributions, reducing operational risk.
* **Improved Liquidity:** For certain types of assets, tokenisation can potentially unlock new avenues for liquidity and secondary market trading.

Imagine a scenario where an investor buys a tokenised fund unit. The token is instantly registered on the ledger, ownership is verified, and any subsequent dividend payments are automatically distributed to the token holder’s digital wallet. This is the promise of efficiency and security that tokenised registers offer.

### Navigating the Regulatory Landscape: The FCA’s Consultation

The FCA’s consultation is a crucial step in understanding the practicalities and potential risks of these innovations. It’s an invitation for industry participants to voice their opinions, concerns, and suggestions. The regulator is looking to gather insights on:

* **Operational Readiness:** What infrastructure and processes do fund managers need to implement to support direct dealing and tokenised registers?
* **Investor Protection:** How can investor rights and protections be maintained or enhanced in this new environment?
* **Cybersecurity and Data Privacy:** What measures are necessary to ensure the security of digital assets and sensitive investor data?
* **Market Integrity:** How can the integrity of the market be preserved with these new technologies?
* **Interoperability:** How will tokenised funds interact with existing financial systems and market infrastructures?

The FCA’s approach is one of cautious optimism, seeking to foster innovation while safeguarding the financial system. Their consultation paper acts as a bridge, connecting the potential of new technologies with the established principles of financial regulation.

### What Does This Mean for Fund Managers?

For fund managers, this consultation represents a significant opportunity, but also a call to action. They need to:

1. **Educate Themselves:** Understand the capabilities and limitations of DLT and tokenisation.
2. **Assess Operational Impact:** Evaluate the costs and benefits of investing in new technologies and revising existing processes.
3. **Engage with the FCA:** Actively participate in the consultation process, providing constructive feedback.
4. **Consider Strategic Partnerships:** Explore collaborations with technology providers specialising in DLT and tokenisation.
5. **Focus on Investor Value:** Determine how these innovations can translate into tangible benefits for their clients.

The ability to offer direct dealing and manage tokenised registers could become a competitive differentiator, attracting a new generation of tech-savvy investors.

### The Investor’s Perspective: A Win-Win Scenario?

From an investor’s viewpoint, the prospect of direct-to-fund dealing and tokenised registers is incredibly exciting.

**Potential advantages for investors include:**

* **Lower Fees:** As mentioned, cost savings could be passed on.
* **Faster Transactions:** Quicker access to buy or sell investments.
* **Greater Transparency:** A clearer understanding of ownership and transaction history.
* **Increased Accessibility:** Potentially lower investment minimums through fractional ownership.
* **Enhanced Security:** The inherent security features of blockchain technology.

However, investors will also need to be aware of any new responsibilities or risks associated with managing digital assets and interacting directly with fund managers. The transition will require a learning curve for all parties involved.

### The Road Ahead: Challenges and Opportunities

The FCA’s consultation is a starting pistol, not a finish line. The journey towards widespread adoption of direct-to-fund dealing and tokenised registers will involve:

* **Technological Advancements:** Continued development and standardisation of DLT solutions.
* **Regulatory Clarity:** Further guidance and rule-making from the FCA and other regulators.
* **Industry Collaboration:** A concerted effort from asset managers, custodians, technology providers, and investors.
* **Education and Adoption:** Building trust and understanding among all market participants.

The potential for a more efficient, transparent, and accessible investment ecosystem is immense. The FCA’s proactive stance is a clear signal that the UK is serious about embracing the future of finance.

### Conclusion

The Financial Conduct Authority’s consultation on direct-to-fund dealing and tokenised registers marks a pivotal moment for the investment management industry. By exploring these innovations, the FCA is paving the way for a future where fund transactions are faster, cheaper, and more transparent. While challenges remain in terms of technological implementation, regulatory adaptation, and investor education, the potential benefits for both fund managers and investors are substantial. This proactive approach signals a commitment to fostering innovation while upholding the highest standards of investor protection.

**Are you ready for the future of fund investing? Stay informed and engage with the evolving landscape of financial technology.**

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Source: [https://www.fca.org.uk/news/press-releases/fca-consults-fund-managers-enable-direct-fund-dealing-use-tokenised-registers](https://www.fca.org.uk/news/press-releases/fca-consults-fund-managers-enable-direct-fund-dealing-use-tokenised-registers)
Source: [https://www.investopedia.com/terms/t/tokenization-cryptocurrency.asp](https://www.investopedia.com/terms/t/tokenization-cryptocurrency.asp)

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