Before we look at how ex-ante and ex-post charges disclosure is dealt with in Genovo, let's just clarify the difference between the two. In simple layman's terms:

  • Ex-ante charges disclosure involves looking forward. It provides a reasonable estimate of costs before they are incurred. 
  • Ex-post charges disclosure is retrospective. It confirms the actual costs that were incurred over a given timeframe.


Ex-ante charges disclosure in Genovo


In Genovo, ex-ante charges disclosure is dealt with in the Plan Charges steps of the review sections for existing plans, and the Plan Charges steps of the recommendation sections for newly recommended plans. This is the case for all Report Types.


In the review sections, you may, depending on the recommendation being made in respect to the existing plan, be prompted to complete two Plan Charges steps - Current Plan Charges and Revised Plan Charges. These both relate to ex-ante (forward looking) charges disclosure. They are designed to allow you to provide the client with a clear "before" and "after" view of the future charges of an existing plan in instances where a recommendation (e.g. a change of investment strategy or a top-up) is being made that results in a change to the plan's percentage or monetary charge.




If you are only prompted to complete the Current Plan Charges step, this will serve as the ex-ante charges disclosure. However, if the Revised Plan Charges step is also triggered and completed (leaving it blank means it won't appear in the report), then this will serve as the ex-ante charges disclosure.


You'll find more information about how plan charges are dealt with in the recommendation sections here.


Ex-post charges disclosure in Genovo


Due to the regulatory requirement to only deal with ex-post charges disclosure as part of a periodic review, you will only find the option to deal with ex-post charges in the following Report Types in Genovo:

  • Review Report - Recommendations
  • Review Report – No Change


Within the Ex-post Charges Disclosure step of the Important Information section, you will be prompted to confirm the approach you wish to take to ex-post charges disclosure in that particular report. 



There are a number of options available to you:

  • Do not include ex-post charges disclosure - No snippet will be triggered in the Important Information section and hence no reference to ex-post cost and charges will be included in the report.

  • Signpost to separate charges statement - The 'Ex-post Signpost to Charges Statement' snippet will be triggered in the Important Information section. This contains a sentence referring the reader to a separate standalone charges statement. IOHO signposting to a separate document created by a third party will always prove to be the quickest and easiest way to address the requirements of MIFID II charges disclosure.

  • Include a summary of platform's charges statement - The 'Ex-post Platform Charges' snippet will be triggered in the Important Information section. This contains a template table where you can summarise all the ex-post costs and charges of any investments the client holds on platform. You customise the content / format of this table to reflect the exact output of your preferred platforms ex-post cost and charges statement via the Report Content Manager.

  • Include a breakdown of charges for each plan (just investments) - The 'Ex-post Plan Charges (investments only)' snippet will be triggered in the Important Information section. This contains an auto-generated table where you can insert the ex-post costs and charges of all the plans included within the Review of Your Existing Investments section of the report.

  • Include a breakdown of charges for each plan (investments and pensions) - The 'Ex-post Plan Charges (all plans)' snippet will be triggered in the Important Information section. This contains an auto-generated table where you can insert the ex-post costs and charges of all the plans included within the investment, pension and retirement income plan review sections of the report.


MIFID II regulation


When it comes to periodic reviews and MIFID II charges disclosure, including "ex-ante" as well as "ex post" (actual) charges will clearly provide the client with a much fuller understanding of the impact charges have on their plan(s), and should therefore be considered the "gold standard" in periodic charges disclosure. However, it is worth bearing in mind that under the strict letter of the MIFID II regulation, only ex-post charges is specifically required and there is no specific requirement to provide ex‑ante charges in a periodic review report.


If you want to further reduce the time it takes you to write 'no change' review reports whilst still meeting the requirements of MIFID II charges disclosure, it is possible to configure your Genovo account so the Current Plan Charges step does not show in the review sections for this report type for you (and your users).


Consolidated plan charges


In terms of the report output, it is also possible to consolidate all charges disclosure (ex-ante and ex-post) in one dedicated section. You'll find more information about how to do this in this article.