Executive Summary
While Turnkey Asset Management Platform (TAMP) solutions were first launched in the 1980s, they have grown dramatically in the past decade... accentuating a rising trend of financial advisors outsourcing their investment management, which a recent Cerulli study found is now being done by the majority (54%) of CFP professionals. And as advisors increasingly focus on giving financial planning advice (and not just providing insurance or investment solutions), this trend seems likely to only continue further, as more and more CFP professionals adopt some combination of TAMPs and technology tools to minimize the time they spend implementing portfolio management for their clients. In other words, notwithstanding their recent growth, TAMPs and the world of outsourced investment management is about to get a whole lot bigger than it is even today!
In this week’s #OfficeHours with @MichaelKitces, my Tuesday 1PM EST broadcast via Periscope, we examine what a TAMP (turnkey asset management platform) is, why TAMPs and outsourced investment management are the future for most financial advisors, and how financial planners of the future will likely seek out and adopt TAMPs in a different manner than the popular solutions of the past!
For those who aren't familiar, TAMPs originated nearly 30 years ago, with early leaders like PMC, AssetMark, Lockwood, Brinker Capital, and SEI. The idea of the TAMP was that they would handle the process of actually managing a portfolio - making it as "turnkey" as possible - from selecting the initial stocks or mutual funds (or these days, ETFs) to then monitoring the portfolio and making investment changes (as necessary) on an ongoing basis. As a result, the TAMP structure made the investment management process much easier for advisors, allowing advisors to have consistently managed portfolios, and refocus their efforts that would have gone towards managing investments towards better servicing clients (or finding new ones).
Outsourced investment management was first popular in the broker-dealer environment, structured around a commission trail arrangement, but in the RIA community, it’s more common to use a “sub-advisor” TAMP relationship, where the client actually contracts directly with the RIA using their investment management agreement – which may acknowledge the TAMP as a sub-advisor – and then the RIA in turn contracts with the TAMP as a sub-advisor to manage their client accounts (with a Limited Power Of Attorney [LPOA] Authorization to trade in the client's account through the custodial platform). This shift towards sub-advisor TAMPs in recent years is a key distinction, as the client is first and foremost a client of the advisor, and it’s the advisor who actually decides whether to keep or fire the TAMP as their sub-advisor. Which also means that the RIA can actually claim the AUM they outsource to the TAMP as their own regulatory AUM, because the RIA is the one responsible for the primary “management” (even if that management is choosing a third-party asset manager).
Accordingly, in recent years, a new kind of TAMP adopter has emerged – the holistic financial planner. While in the past TAMPs were primarily the domain of asset-gatherers (who freed up their time to get more clients into the TAMP), for those who are paid heavily or primarily for their financial planning services (rather than being primarily an “investment advisor” for their clients) a TAMP can make a lot of sense as a means to stay involved in the investment process, but not have to be that hands-on with the portfolio (or feel compelled to hire a CFA to run the portfolios). As a result, we've seen the rise of some "simpler" TAMPs that focus on ETF or DFA-oriented mostly-passive portfolios, relying on their service and technology as a differentiator, rather than their investment results. Thus, while TAMPs have historically charged as much as 75 basis points or even a full 1% for their services, the next generation of more passively-oriented TAMPs are coming in at 50 basis points, 40 basis points, or some even at 30 basis points for larger RIAs (depending on both the size of the advisory firm, and also how much back office and other support the TAMP actually commits to provide).
Yet the addition of a new layer of TAMP costs raises another important question: who should pay for it? Or put another way, how should advisors set their fees around the TAMP? Ultimately, there’s not necessarily a “right” or “wrong” answer here, because the truth is that it depends on how the advisory firm was positioned with its clients in the first place. If the advisor's value to clients was helping them to find a good investment solution, the advisor may be able to still justify his/her fee for selection, due diligence, and monitoring, and the client would pay the TAMP fee for what the TAMP does. But if the advisor's value to clients was “managing their money”, and then the advisor outsources it, it’s a little more awkward, as arguably now that should be advisor's cost, not the client’s, because the client is already paying the advisor to do it. At the same time, it’s important to remember that according to the latest benchmarking data on advisory fees, the typical advisor is charging 1% on a portfolio up to $1M in addition to the underlying costs that average 65 to 85 basis points (with higher costs for smaller portfolios). Which means advisors who charge 1% for the first $1 million dollars, and use a TAMP that charges less than 50 basis points and has low-cost ETFs inside, will have total costs that are still below the median all-in cost for advisors today!
The bottom line, though, is just to recognize that as financial advisors increasingly focus on financial planning, and investment management literally becomes less central (though not necessarily irrelevant) to our value proposition with clients, so too does investment management become less central to what we do in our businesses (and where we spend time). Which is leading to an ongoing rise in the use of TAMPs and outsourcing investment portfolios, as the majority of CFP professionals are now outsourcing portfolio management. And the better we get at delivering financial planning value, the more that trend will likely continue!
(Michael’s Note: The video below was recorded using Periscope, and announced via Twitter. If you want to participate in the next #OfficeHours live, please download the Periscope app on your mobile device, and follow @MichaelKitces on Twitter, so you get the announcement when the broadcast is starting, at/around 1PM EST every Tuesday! You can also submit your question in advance through our Contact page!)
#OfficeHours with @MichaelKitces Video Transcript
Welcome, everyone! Welcome to Office Hours with Michael Kitces.
For today's Office Hours, I want to talk about the idea of outsourcing investment management, which a recent Cerulli study found is now increasingly popular, especially among CFP certificants. And in fact, as advisors increasingly focus more on giving financial planning advice, I think ultimately it's going to become an industry standard in the future for virtually all CFP professionals to end out using some combination of TAMPs and technology tools to either outright outsource their investment management or at least grossly minimize the time that they spend implementing portfolio management for their clients. In other words, notwithstanding their recent growth, I think TAMPs are about to get a whole lot bigger than they actually are today.
What Is A TAMP (Turnkey Asset Management Platform)? [Time - 0:58]
For those who aren't familiar, TAMP is an acronym. It stands for turnkey asset management platform. They originated almost 30 years ago with early companies like PMC (which is now part of Envestnet), AssetMark, Lockwood, Brinker Capital, and SEI. The idea of the TAMP was that they would handle the process of actually managing the portfolio, from selecting what back then would have typically been initial stocks or mutual funds, these days maybe ETFs, and then monitoring and making changes to the portfolio on an ongoing basis.
So at the time they originated, they were basically an alternative to the advisor personally taking the time to pick one individual stock at a time or identify individual mutual funds for their clients. Instead, you could outsource to a TAMP, who would then implement a more holistic investment strategy for the clients and buy whatever stocks, bonds, mutual funds etc. were needed.
So clients often felt like they got a more personalized portfolio that was really being managed for them, particularly because 20 or 30 years ago, most advisors didn't have the time to manage portfolios hands-on, they didn't have a team to manage portfolios hands-on, didn't have any technology to handle portfolios hands-on.
Typically, we would just kind of sell whatever funds were popular and doing well at the time, and then maybe when clients sat down for an annual review, we would pull some fresh Morningstar reports and do a little due diligence and say, "Okay, this one actually isn't doing very well, let's implement this new fund instead," which meant over time, every client's portfolio was kind of a different jumbled combination of stocks and bonds and funds that had been purchased over time.
The TAMP structure made this much easier for advisors so that all of your clients would have a consistent investment portfolio that the TAMP managed. And because it saved time to not need to do all that investment analysis and research, because you handed all the portfolio management duties off to a third party, your role as the advisor was to pick the TAMP manager and the strategy that your client would get invested in, and then go find more clients that wanted to invest into it.
And that process of doing manager and strategy selection and the due diligence... that was the value-add of the advisor in the process, rather than analyzing and picking each stock and bond and mutual fund. And because TAMPs could get larger with scale as they grew assets with their own standardized investment strategy and process eventually helped to bring the costs down, at least compared to what actively-managed mutual funds tended to cost at the time.
Third Party Asset Manager (TPAM) vs Sub-Advisor Arrangements [Time - 3:20]
In the early days of TAMPs, most of them were structured as what were called third-party asset managers. You still may sometimes hear the acronym T-P-A-M for short. Now, I know this is a little bit confusing. A T-P-A-M was a TAMP or a T-A-M-P, so a third-party asset manager was a subset of the TAMP category. And the key aspect with the third-party manager was that the client technically contracted directly with the TAMP for their portfolio, did the paperwork with the provider, and the advisor was essentially just assigned to be a rep on the account or may have been paid as a commission trail on the account for selling it.
So in the early days, most of those turnkey asset management platforms were actually distributed through broker-dealers and were popular as a solution for brokers who were especially good at just gathering assets into investment strategies and didn't want to take the time to do the picking of the stocks and the funds. But again, technically, the primary relationship was between the client and the third-party asset manager that was serving as a turnkey asset management platform. The broker that helped to service the client was compensated for doing so usually through the broker-dealer.
By contrast, though, in the RIA community today, it's actually more common to use a sub-advisor version of a TAMP relationship. So as a sub-advisor, the clients actually contracts directly with the RIA using their investment management agreement. So as the advisor, the client signs with me, I then acknowledge that a TAMP is my sub-advisor, and then I as the advisor in my RIA contract with the TAMP to sub-advise my client's account. In a lot of cases these days, it's done directly through the RIA's custodian. So the client technically signs a limited power of attorney (an LPOA authorization) to grant the TAMP the right to make the trades in their account on the custodial platform. Although with a few of the larger TAMPs, they actually have their own custody and clearing agreement, so the LPOA may get signed between the TAMP as the manager and the TAMP as the custodian to sort of trade in their own account.
But the key distinction is that, with a sub-advisor relationship, the client is first and foremost the client of the advisor and is the advisor who decides whether to keep or fire the TAMP as their sub-advisor, which also actually means the RIA then can legally claim the assets of the client portfolios as their own regulatory AUM because the advisor, the RIA is the one actually responsible for the primary management, even if their management process is then selecting a third-party manager for implementation.
Now, there are some other TAMPs that still operate more as third-party asset managers and may pay RIAs a solicitor fee for bringing them business rather than sub-advising, kind of akin to the old brokers trail commission arrangement, but most of the RIAs I'm seeing these days structure their TAMP arrangements as sub-advisors instead, especially with independent RIAs that provide TAMP services to other RIAs. So this is how we actually structured it for our own TAMP for other RIAs at Pinnacle, recognizing that most other RIAs, you know, we all like to control our own client relationships and control which TAMPs they do or don't do business with. So our TAMP sub-advises to other RIAs for their clients, which is how we're seeing more and more RIAs do it these days.
The Rise of Fee-For-Service Financial Planning and the Rise Of The TAMP [Time - 6:32]
Historically, TAMPs were more popular in broker-dealer platforms, either for those who were especially good at business development and asset gathering but didn't want to be doing all the investment management analysis so they outsourced it or for those who just thought that some TAMP strategies were especially compelling. They would sell it to their clients as basically a more individualized, customized, personalized, separately managed account strategy than just buying some mutual funds or stocks.
But in recent years, a new kind of TAMP adopter has emerged, the holistic financial planner. These are the advisors who are paid heavily or primarily for their financial planning services rather than being paid for their clients to just do the investment stuff. They are typically RIAs and not under a broker-dealer, because you have to be an RIA to charge an advice fee, and they might be charging an AUM fee on the portfolio but they build their value proposition, not around just picking and managing investments, but all the financial planning advice. And in some cases they literally don't even charge for assets, they just charge financial planning fees, which not coincidentally that growth in fee-for-service planners is why we recently launched our AdvicePay platform.
But from the TAMP perspective, the key point is that RIA financial planners are often advisors who do still want to be certain clients get properly invested. They want to play at least some role in the investment or manager selection and monitoring process but aren't trying to create their value by making better portfolios and don't want to be that hands-on in the portfolio and don't want to hire a CFA to internally run and manage their portfolios. So they need an outsourced investment management solution, a TAMP, and often a relatively simple TAMP. Because when your value isn't about trying to bring output to the table, you don't necessarily want or need a more complex investment management solution, just something that gets clients reasonably implemented into a diversified portfolio with low-cost funds.
And so in this context, we've seen the rise of larger, more passively-oriented TAMP platforms, you know, DFA-oriented shops like Loring Ward and BAM Alliance. We built our own XY Investment Solutions TAMP for XY Planning Network members specifically to be comprised entirely of low-cost index ETFs and DFA funds for the same reason. And these TAMPs actually are ending out being simpler and often cheaper than other TAMPs, which historically were charging as much as 75 basis points or more. Next generation of TAMPs that we see for financial planning-oriented advisors, we're seeing at 50 basis points, 40 basis points, some even 30 basis points for larger RIAs because you get breakpoints at larger sizes.
How Much Do TAMPs Cost And What Do Advisors Charge? [Time - 9:09]
And these costs for TAMPs are important because ultimately, it is an extra layer of cost for the end client, right? Because the advisor gets paid, then the TAMP gets paid, and then if they're not investing directly into stocks and bonds, the underlying funds still get paid as well, right? The mutual fund or the ETF expense ratio is a third layer of cost here. Now again, as TAMPs grow, especially in the RIA space, costs do seem to be coming down. What was 75 basis points or more in the past, I see more commonly as 30 to 50 basis points now, with maybe a little bit of variability based on how much service the TAMP provides. In the world of third-party asset managers, they often did everything and just remitted a fee to the broker.
Sub-advisor relationships, though, if the RIA retains more control, they also have more responsibility, and usually the direct primary relationship with the custodian. So some sub-advisor TAMPs for RIAs just manage the money. They set the models, they do the trading or rebalancing but that's it. It's up to the advisor to onboard clients, free up cash if the client needs a distribution, handle their own billing. Other sub-advisor TAMPs or RIAs do more of the back-office functions as well. It might be a little more expensive since they're adding an extra layer of service, or some even charge separately for the service layer and you buy up if you want those back-office options.
All of which raises what's actually one of the most common questions I hear from advisors that are looking for TAMPs, which is, how do you set your fees around the TAMP? This was actually a discussion we had recently on the XYPN Radio podcast as well. Because after all, you could just charge your client a single advisory fee and then pay the TAMP out of your fees, you could charge two separate layers of fees, right? Your fee for your role and then the TAMP fee for the TAMP's role, it might have add up to the same thing but they're billed separately, and some advisors will then reduce their fees in recognition of the work that the TAMP is doing. Others tend to keep charging their own fee and just let the TAMP charge its own fee. You know, kind of akin to a mutual fund manager charges a management fee for buying the stocks and bonds while the advisor would get paid for selecting the mutual fund, you know, or the ETF manager gets paid to actually put together the ETF and the stocks, but the advisor gets paid to select the ETF. Now, the good news is the typical cost for TAMPs these days is less than the cost of a lot of mutual fund managers, and then the advisor gets paid for the selection process.
Ultimately I have to admit, I'm not sure there's a right or wrong answer here about the best or most proper way to get paid for a TAMP, because the truth is that it really depends on how the advisor was positioned with their clients in the first place. You know, if your value for clients was helping them to find a good investment solution and you used to pick, you know, mutual funds for them, now you're picking TAMPs, it's just from picking one type of manager to another type of manager, you can still justify your fee for selection, due diligence and monitoring, you don't necessarily have to change anything.
If your value to clients was, you manage their money and then you outsource it and don't manage it, now it's a little bit more awkward. If the client expected you to be the portfolio manager, you would have either had to hire a CFA and staff or you're outsourcing to a TAMP, but arguably now that should be your cost, not your clients because the client was paying you to do it and you're delegating it down.
Now, if your value to your clients is primarily the financial planning and that's what they're paying for, arguably once again, you should be able to continue charging what you're charging for the value you're delivering and let the client pay for the TAMP. You know, maybe you'll charge some AUM fee since you're still responsible for selection, due diligence, and monitoring of the TAMP, but if most of what you get paid is for financial planning and you're still doing the financial planning, there's no reason you need to cut out your fee to pay the TAMP any more than you give advice for estate planning but you don't pay the client's lawyer, and you might give advice on tax planning but you don't pay the client's CPA. You can give advice around investment portfolios, you don't need to pay the client's TAMP fee if they're already paying you or they're separately paying you for the advice.
And at the same time, it is important to remember that according to latest industry benchmarking data on advisory fees, the typical advisor is charging 1% on a portfolio up to $1 million in addition to the underlying costs, which average about 65 to 85 basis points, depending on size of portfolio. You know, higher costs for small portfolios, slightly lower costs for larger portfolios. So frankly, if you charge 1% for up to the first $1 million and then use a TAMP that charges less than 50 basis points with a bunch of low-cost ETFs inside, you are already lower than the median cost of advisors today.
And I think that's important because I see a lot of advisors putting huge pressure on themselves to cut their 1% AUM fee when they use a TAMP, not realizing that their fee plus a low-cost TAMP is already below the average all-in fee. Now, that may change at some point as firms get more efficient and costs continue to come down, but it doesn't mean you have to reduce your fees just to be price-competitive and win the business today, at least not unless you're working with much more affluent clients who may demand lower fees. But that's why most of us already have graduated fee schedules with lower fees as the assets rise.
The key point to all of this, though, is just to recognize that as financial advisors, as we increasingly focus on financial planning and investment management kind of literally becomes less central to our value proposition with clients, it becomes less central to what we actually do in our businesses, which I think is going to continue to lead to this ongoing rise of TAMPs and outsourced investment management solutions. The recent Cerulli study actually found the majority of CFP professionals, 54%, are already outsourcing portfolio management. And I think the better we get at delivering value with financial planning, the more we will outsource the investments.
Now, it's ironic because I know some have been predicting that the value of investment management services is going to zero, that TAMPs are going to go away, but the reality is that client's money still has to be invested somewhere. That won't change. They have money, and it needs to get to the capital markets. The less the financial planner focuses on investments, the more relevant outsourced investment management solutions become as a way to implement this, albeit perhaps at a lower cost as they get bigger with more scale.
And, you know, new innovations I think will continue to mix this up as well. Things like the rise of model marketplaces, where the third-party manager gives you the model but you use the rebalancing software to implement it yourself. So if you're an RIA that wants to retain a little more control and not be solely responsible for building and managing the model but want to simplify it, that makes it a little bit easier with the model marketplace, which will put I think more pressure on TAMPs to be more about the service and the back-office assistance and not just the investment models themselves, just as we as advisors are focusing more on financial planning and not so much on the investment management and the models themselves.
In any event, though, I hope this is some food for thought around the rising trend of TAMPs, why I think financial planners are more likely to use TAMPs as part of their value proposition, and where a TAMP fits into the picture for what financial advisors do and how they charge for their services.
This is Office Hours with Michael Kitces. We're normally 1 p.m. East Coast time on Tuesdays. Obviously, we're here on Wednesday today because I had some meeting conflicts yesterday, but thanks for joining us, everyone, and have a great day.
So what do you think? Have you used a TAMP? Have you thought about outsourcing your investment management? What types of services would you like to see TAMPs provide going forward? Please share your thoughts in the comments below!
Adam says
LPL told me last week all in fee 1.3% with them.
Michael Kitces says
Sometimes there are a lot of hands in the cookie jar. :/
– Michael
Does an individual have to be licensed or registered to accept solicitor payments?
From RIA Compliance Consultants:
The Investment Advisers Act of 1940 and the associated SEC rules do not require the solicitor to register as an investment adviser as long as the solicitor’s activities are strictly limited to merely referring clients to a registered investment adviser in compliance with SEC Rule 206(4)-3.
State regulators’ rules may differ from the SEC.
https://www.ria-compliance-consultants.com/frequently_asked_questions/faq_investment_adviser_investment_advisor_solicitor_referral_arrangements/
Thanks Bill,
I do mostly financial coaching but decided to register because I feared mentioning the word ‘security’ without an RIA would result in non-compliance. Registering was probably overkill but I have 2 clients with whom I act as a solicitor for a large RIA. It appears as though the landscape may be changing for solicitors with the DOL rules but it would have been nice to avoid some of the compliance costs for registration.
John Safaric CFP®, RMA(sm) , EA
Thanks for pulling this together Michael. Very well done. I thought a TAMP would be price prohibitive, but for a client that is sitting in mutal funds (say 0.7% expenses) and paying an advisor 1% AUM today, you made a great case that a TAMP (0.5%) using ETFs (0.07% maybe??) plus the 1% advisory fee still comes out lower. Great for those RIAs making the TAMP (marketing) case to their clients.
There was a time when TAMP prices were higher. (And as some other commenters note, a few still are.)
But technology efficiencies and scale have been bringing TAMP prices down for years. And the movement towards low-cost ETFs drives down internal costs even further. It’s become a really interesting space over the past 5-10 years with new tech tools!
– Michael
Michael, here’s what has escaped me about using a TAMP (as a solo adviser). If my investment philosophy centers around the use of DFA funds, buy-and-hold-and-rebalance, what does a TAMP add that I can’t accomplish myself with a monthly TradeWarrior subscription?
As long as you don’t mind spending the time to make the models, handle the due diligence on the funds, and execute the rebalancing, nothing.
If you continue to grow, at some point you may decide there are better uses of your time. To each their own about how they allocate their time. 🙂
– Michael
Michael, my advisory firm utilizes an Investnet platform and in addition to TAMP or SMA fees thier is an additional program fee of .25% – .40% (based upon AUM). This program fee covers all platform fees, trading cost, statements, performance reporting, custodial costs, etc and a % to pay Investnet and my Advisory Firm… is this typically how ALL advisory firms work or are the “program fees” typically baked into the TAMP or SMA management fees??? For instance, my SMA mgrs charge .30%, platform fee is .30% and my advisor fee is .50% then my “all in” client expense would be 1.10%. I’m just curious if thus is how it works with all Advisory platforms??? Thanks for your response in advance…
Brian Saranovitz
Thank you. Would it make sense to obtain the CIMA designation in order to provide more value to client by selecting appropriate investment managers and TAMPs? Assuming you have the CFP desgination.
The CIMA certification is certainly the right one for doing this kind of analysis.
But most advisors find a small subset of managers/strategies they’re comfortable with, and use those regularly with all their clients.
Implementing different TAMPs or SMAs with (almost) every client will eventually bury you in operational inefficiencies and/or an insurmountable level of ongoing due diligence that you must do across all those managers. It’s not an “investment” issue. It’s a business issue at that point.
– Michael
Thank you Michael for the inisight. In terms of post-CFP education and to grow in expertise in the area of investment management is CIMA a quality designation? Together CFP general financial planning and CIMA, advanced investment management I would like to provide value for clients.
Yes, CIMA is definitely a credible and quality designation. One of the few to have ANSI accreditation. And they’ve been updating the curriculum and focus to reflect the shifting role of financial advisors.
Just be certain to review the curriculum first to understand the scope of what it does and doesn’t cover. It’s very effective for tasks like manager search and selection and portfolio due diligence, but isn’t built to help you do individual stock or bond analyses (the way the CFA is).
– Michael
Thank you Michael!! I will look at the CIMA program with Yale University. By the way, I love reading your blogs posts they are very insightful. As young planner I strive to learn as much as I can about the field to gain confidence and credibility and your site helps me a lot.
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