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 is being made that could result 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 an annual review, you will only find the option to deal with ex-post charges in the following Report Types in Genovo:
- Review Report 2.0
- Continued Suitability Report
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 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.
- 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.
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.