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Sparrows Papers,
November 16, 2023 - Sparrows Capital
By Robin Powell, editorial consultant to Sparrows Capital

“The four most dangerous words in investing,” the famous investor Sir John Templeton once said, “are ‘this time it’s different’.”
Again and again, investors who have assumed that things were different at any one point in time, and changed their strategy accordingly, have paid the price.
The obvious example is active investing. There’ve been constant assertions over the years that active was about to make a comeback; but investors who heeded the advice of Charley Ellis, Burton Malkiel and others in the 1970s, invested in equity index funds, and stuck with it, have outperformed the vast majority of active investors. Those who tilted their portfolios towards the risk premia identified by the likes of Fama and French — principally size, value, quality, profitability, momentum and low-volatility — have done even better over the long term.
Like Sparrows Capital, I’m a staunch advocate of disciplined, low-cost, systematic investing. But, to play devil’s advocate for a moment, what if the situation we find ourselves in today really is different? What if systematic factor investing is no longer optimal in the investing environment we face today? And if that is the case, should investors now be looking, as many are suggesting, to alternative asset classes such as hedge funds?
We’re in a new era
In answer to the first question, there are two respects in which we genuinely are in a new era. Firstly, investment returns in the future are likely to be lower than they have been in the past. This is down to the gradual re-rating of equities over the last century and reflects, at least in part, reduced investment risk.
As Dimson, Marsh and Staunton, authors of the classic book, Triumph of the Optimists, explained in the 2013 edition of the Credit Suisse Global Investment Returns Yearbook, investing is essentially less risky than it was, say, in 1900. Over the last century, “new industries emerged, diversified closed and open-ended funds appeared, liquidity and risk management improved, and institutions and wealthy individuals invested globally. As equity risk became more diversifiable, the required risk premium is likely to have fallen.”
Although the financial markets have been treading water for the last two years, recent decades have seen ever-increasing valuations and realised returns, with falling yields.
This trend has been accentuated since 2008 through the policies of central banks, particularly very low interest rates and Quantitative Easing. This resulted in a long-drawn-out “everything rally”, in which the value of most financial assets rose. So, in a sense, lower yields and higher asset prices have brought forward future returns and that couldn’t continue indefinitely. Consequently, we are probably entering payback time for the windfall gains that we’ve enjoyed for so long.
The second respect in which the present really does differ from the past is that we are now in a higher-inflation world. Inflation ran at historically low levels for many years. That changed dramatically at the start of 2022, not least as a result of the war in Ukraine. Since then, inflation has risen across the globe, with the UK one of the worst hit of all developed nations.
So we face, if you like, a double whammy. Just when we need to earn higher returns simply to beat inflation, expected market returns are about as low as they have ever been in living memory.
It’s no wonder, then, that we are seeing repeated claims from the asset management industry that the current climate calls for new approaches — particularly unconstrained, high-conviction active strategies like those used by hedge funds.
The arguments for hedge funds
What are the arguments being made for investing in hedge funds now?
A common view is that hedge funds provide a degree of protection against inflation. According to Société Générale, “hedge funds are dynamically arbitraging inflation. Surging inflation… helps hedge funds remain resilient (and) usually outperform traditional assets, thanks to uneven strategies’ sensitivity to inflation. They then tend to perform even better when inflation normalises.”
A second argument in favour of hedge funds is that the world has arguably entered a prolonged period of elevated macro-economic volatility. According to a recent note from Goldman Sachs, this increased volatility should lead to better investing opportunities for hedge funds. “Historically,” the authors claim, “when equity and fixed income volatility has increased, hedge fund alpha generation has also improved.”
Goldman Sachs suggests several reasons why this might be. For example, it says, when short-term cash instruments offer materially higher interest rates, it creates a “total return tailwind” for hedge funds, which typically have large cash holdings.
It also says that the new macro-economic environment benefits the trend-following and directional macro strategies that many hedge funds favour. “We expect the environment to remain attractive for tactical trading funds in the medium term,” the authors state, “particularly for global macro managers.”
A third argument for hedge funds is that they act as a diversifier. According to SocGen, “The menu of diversifying assets is limited (but) hedge funds look particularly appealing. (They) show little sensitivity to traditional assets… With an adequate rotation of strategies along the economic cycle, hedge funds provide durable diversification.”
The counter arguments
There are no obvious arguments against investing in hedge funds in a high-inflation, low-return environment specifically, but the case against using them in general is strong.
First of all, even though some funds have moved away from the traditional two-and-twenty charging structure, hedge funds generally remain very expensive. Fees are a significant drag on investment performance and. empirically, the less you pay to invest, the higher your returns are likely to be. Yes, hedge funds offer the potential for outperformance, but to make it worth investing in them at all, the alpha they generate has to exceed the costs entailed. In the vast majority of cases, the fees they charge present too big a hurdle for hedge fund managers to overcome.
Secondly, and partly because of their higher expense ratios, hedge funds have consistently produced disappointing returns, particularly since the global financial crisis. According to Aurum, an investment consultancy specialising in alternative investments, hedge fund performance in the five-year period to the end of June 2023 stood at a cumulative abnormal return (CAR) of +4.7%. Although that put hedge funds comfortably ahead of bonds, which were down 1.3% over the same period in US dollar terms, they still lagged equities, which had a CAR of +5.6%.
A third main reason for being wary of hedge funds is the additional tail risk they entail. Yes, you could win big if a hedge fund’s bets pay off, but, by the same token, you could also suffer large losses. Hedge funds whose strategies involve the use of leverage and derivatives to trade securities are particularly vulnerable to short, sharp shocks.
The 25th anniversary of the collapse of Long-Term Capital Management has put the spotlight on that particular fund in recent weeks, but several other hedge funds have failed as well, including Amaranth Advisors, Tiger Funds and Marin Capital. There are bound to be more failures in future.
Fast pain or slow pain
As we’ve seen, there are arguments for and against using hedge funds. My own strong preference, as stated earlier, is for systematic indexing over any form of discretionary active management. But every investor is different.
As the behavioural finance expert Meir Statman has explained, there are all sorts of reasons why people invest in particular things; some, for example, may choose to invest in a hedge fund for a sense of excitement or may even see it as a status symbol. A more pressing reason why investors may be attracted to hedge funds is that, for whatever reason, they need to take more risk. The right solution is certainly not the same for everyone.
Informed investors in search of helpful perspectives on this issue may want to to read Investing Amid Low Expected Returns by Antti Ilmanen. The book’s rather sobering bottom line is that all investors today should brace themselves for pain. Generating the sort of returns we’ve grown used to is going to be very much harder in future.
Investors, suggests Ilmanen, can do one of two things in response: either they take more risk or they can carry on as they have been doing and simply accept the likelihood of lower future returns. Either route will be painful; you just have to choose between what the author calls short pain and long pain.
For some investors, the short pain option may involve some exposure to hedge funds. If you can identify in advance the right fund manager — and that’s a very big if — you may be able to hit your goals in spite of the low-return environment.
The alternative is to not to increase your risk, but to focus instead on factors within your control — particularly cost, diversification and discipline. Get those things right, and your chances of outperforming the great majority of investors are very high.
I know which option appeals more to me!
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United Kingdom Stewardship Code
The Stewardship Code (the “Code”) was developed from the Walker Review on Corporate Governance in the UK and aims to enhance the quality of engagement between investors (and investment managers) and UK listed companies.
Sparrows supports the principles enshrined in the Code. Although the Code is voluntary, the FCA requires Sparrows to include on this website a disclosure about its commitment to the Code or, where it does not so commit, its alternative strategy. The FCA and the Financial Reporting Council have acknowledged that certain aspects of the Code are not directly relevant to all investment firms.
Sparrows invests almost exclusively in rule-based ETFs and index funds in order to capture market returns across all asset classes globally. Sparrows does not directly invest in shares or bonds issued by UK listed companies and therefore has no direct interaction with the management of such companies and does not enjoy voting rights in relation to such companies. For this reason, the Code is not directly relevant to Sparrows and it is not practical for Sparrows to implement a policy of direct engagement.
Sparrows’ due diligence prior to investing in an ETF or index fund does, however, take specific account of the fund manager’s own commitment to the Code (or equivalent depending on jurisdiction) and the nature of their engagement and voting policies with regard to companies in which their funds invest.
Given both Sparrows’ and the ETF or index fund provider’s index tracking requirements, there is very limited scope for stewardship through selective allocation or de-allocation decisions. For this reason, Sparrows’ analysis focuses on stewardship through engagement and through the exercise of voting rights.
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Background
These are the Pillar 3 disclosures made by Sparrows Capital Limited (“Sparrows”) in accordance with the UK Financial Conduct Authority’s (“FCA”) Prudential Sourcebook for Banks, Building Societies and Investment Firms (“BIPRU”).
The European Union Capital Requirements Directive (“CRD”) created a regulatory capital framework consisting of three ‘pillars’ namely:
Pillar 1 – sets out the minimum capital requirements that firms are required to meet;
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Disclosure policy
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Where Sparrows has omitted information for any of the above reasons, a statement explaining this will be provided in the relevant section.
Unless stated as otherwise, all figures contained in this disclosure are based on Sparrows’ audited annual reports for the year ending 31 December 2025.
Frequency
These Pillar 3 disclosures will be reviewed on an annual basis as a minimum. The disclosures will be published as soon as is practical following the finalisation of Sparrows’ Internal Capital Adequacy and Risk Assessment (“ICARA”) and its annual accounts.
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The information contained in these disclosures has not been audited by Sparrows’ external auditors and does not constitute any form of financial statement.
Publication
Sparrows’ Pillar 3 disclosures are published on its website.
Scope and application of CRD requirements
These disclosures are made in respect of Sparrows, a BIPRU firm authorised and regulated by the FCA, providing financial advice and discretionary investment management services.
Risk management objectives and policies
Sparrows’ risk management policy reflects the FCA requirement that it must manage a number of different categories of risk. These include: liquidity; credit; interest rate; market; and operational risks.
Sparrows manages all cash and borrowing requirements to maximise potential interest income whilst ensuring it has sufficient liquid resources to meet the continued operating needs of its business. This is supported by a robust budgeting and forecasting process which has the full involvement of the senior management team.
The main credit risk for Sparrows relates to income from fees, the risk being that a client does not pay amounts due for services provided by Sparrows. In most cases, quarterly management fees are charged to clients based on a percentage of the client’s assets under management. Concentration risk is defined as the risk of loss of income through external changes having a disproportionate impact on overall income due to a reliance on revenue from certain sectoral, geographic areas and/or businesses. Credit risk concentrations include significant exposure to an individual client or group of clients and credit exposures to clients in the same economic sector or geographic region.
A significant proportion of Sparrows’ income is received from clients that are part of the same group as Sparrows’ major shareholders. This ongoing interest in the activities of Sparrows by the group mitigates the risk of the group jeopardising Sparrows’ income flow.
Sparrows is exposed to country risk as a number of clients are based in a non-European Economic Area country. As these clients are all high net worth or ultra-high net worth long-term investors with spare capital invested in globally diversified liquid financial instruments, the risk of being unable to meet unforeseen financial needs and payment of Sparrows’ fees is low.
Based on the analysis of concentration risk, the risk of non-payment of fees has been assessed as minimal.
Sparrows has no exposure to interest rate risk as it has no debt and no client cash deposits.
The main market risk for Sparrows relates to falls in value of assets under management following a market downturn, which would lead to lower management fees. To mitigate its market risk, Sparrows regularly analyses various different economic scenarios to model the impact of economic downturns on its financial position.
Operational risk is defined as the potential risk of financial loss or impairment to reputation resulting from inadequate or failed internal processes and systems, from the actions of people or from external events.
Major sources of potential operational risk include: Outsourcing of operations, IT security, internal and external fraud, implementation of strategic change and regulatory non-compliance.
Sparrows operates a robust risk management process which is regularly reviewed and updated by its Board. The Board formally reviews all significant risk issues at least annually as part of the ICARA.
All senior members of staff bear responsibility for internal controls and the management of business risk as part of their accountability to the Board. All staff are responsible for identifying the risks surrounding their work, implementing controls over those risks and reporting areas of concern to their senior member of staff.
Sparrows operates a simple business model. Accordingly, many of the specific risks identified by the FCA do not apply. For example, it has no material outsourcing arrangements and does not hold any client assets.
Capital resources
Pillar 1 requirement
In accordance with the FCA rule GENPRU 2.1.45R (calculation of variable capital requirement for a BIPRU firm), Sparrows’ capital requirement has been determined as being its fixed overhead requirement and not the sum of its credit risk capital requirement and its market risk capital requirement.
The Pillar 1 capital requirement for Sparrows was £688,000 as at 31 December 2025.
Pillar 2 requirement
Sparrows’ overall approach to assessing the adequacy of its internal capital is set out in its ICARA report. The ICARA involves separate consideration of risks to Sparrows’ capital, combined with stress testing using scenario analysis. The level of capital required to cover risks is a function of impact and probability. Sparrows assesses impact by modelling the changes in its income and expenses caused by various potential risks over a 1-year time horizon. Probability is assessed subjectively. In addition, Sparrows has reviewed the outputs of its risk reviews to quantify any risks identified. This has identified a number of key business risks, which (having reviewed the guidance in BIPRU 2.2.61-65) Sparrows has classified against the risk categories outlined in FCA rule GENPRU 1.2.30R.
Sparrows Pillar 2 capital requirement, which is its own assessment of the minimum amount of capital that it believe is adequate against the risks identified, has been assessed as greater than its Pillar 1 requirement.
There is a considerable surplus of reserves above the capital resource requirement deemed necessary to cover the risks identified.
Regulatory capital
The main features of Sparrows’ capital resources for regulatory purposes, as at 31 December 2025 are as follows:
| Capital item: | £000 |
| Tier 1 capital (called up share capital, share premium account, profit and loss account, externally verified interim net profits) | 1,157 |
| Total of Tier 2 and Tier 3 capital (broadly long and short term subordinated loans) | – |
| Deductions from Tier 1 and Tier 2 capital | – |
| Total capital resources, net of deductions | 1,157
|
Sparrows holds regulatory capital in accordance with the CRD. All such capital is classified as Tier 1 capital and is therefore of the highest quality.
Remuneration Code Disclosures
Sparrows is subject to the BIPRU Remuneration Code. This section provides further information on Sparrows’ remuneration policy.
BIPRU Remuneration Code Staff
Sparrows has identified, and maintains a record of, BIPRU Remuneration Code staff (“Code staff”), i.e. staff to whom the BIPRU Remuneration Code applies. This includes senior management and members of staff whose actions may have a material impact on Sparrows’ risk profile. All of Sparrows’ Code staff fall into the “senior management” category of Code staff (rather than the “risk taker” category) for the purposes of the BIPRU Remuneration Code.
Decision Making / Remuneration Committee
Sparrows does not have and is not required to have a Remuneration Committee. The Board is responsible for Sparrows’ remuneration policy including determining the framework and policy for remuneration and ensuring it does not encourage undue risk taking; agreeing any major changes in remuneration structures; reviewing the terms and conditions of any new incentive schemes and in particular, considering the appropriate targets for any performance related remuneration schemes; and considering and recommending the remuneration policy for senior staff taking into account the appropriate mix of salary, discretionary bonus and share based remuneration.
In determining remuneration arrangements, the Board will give due regard to best practice and any relevant legal or regulatory requirements including the BIPRU Remuneration Code.
Link between pay & performance
There is ostensibly a discretionary variable pay element to the Sparrows’ remuneration package.
Quantitative information on remuneration
The FCA rules require certain firms to disclose aggregate information on remuneration in respect of its BIPRU Remuneration Code staff broken down by business area, senior management and other Code staff, including “risk takers”.
Sparrows has only one business area – investment management & advice.
Sparrows has 4 Directors but no material “risk takers”. Director remuneration is agreed formally at Board meetings. The link between performance and pay is inevitable in a small firm, but Sparrows’ risk-averse strategy and robust risk management systems mitigate risks.
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