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Sparrows Papers,
April 3, 2024 - Sparrows Capital

Robin Powell, editorial consultant to Sparrows Capital
Low-cost, evidence-based investment solutions have severely disrupted the traditional DFM market and are greatly improving outcomes for clients in the accumulation phase. But, says ROBIN POWELL, it’s in decumulation that product innovation is really needed now. The good news is that better and more personalised offerings are on the way.
It’s hard to overstate the transformation of accumulation-phase investment solutions available to advisers over the last ten years. A decade ago the market was dominated by traditional DFMs.
Overwhelmingly, their model portfolios were actively managed and very expensive, which meant that most clients, whether they realised it or not, were underperforming the broad market. Today advisers have a range of low-cost, evidence-based solutions at their disposal, like Sparrows Capital’s SCore mps and, increasingly, that’s what they’re moving over to.
But although, from the adviser’s point of view, wealth accumulation is a solved problem, there’s still plenty of room for improvement in outcomes for clients in decumulation.
Changing demographics make this a pressing challenge. The latest projections suggest that all age groups over the age of 60 are expected to increase substantially in number in the UK between now and 2050. The biggest growth, it’s predicted, will be in the number of those aged 80 and older.
A recent survey of more than 200 advice professionals by Just and NextWealth showed there is concern among advisers about the approaches and tools they currently have available for managing risk in decumulation. The vast majority of those surveyed said they were only “somewhat confident” of managing a range of risks including capital erosion and longevity risk. Almost one in ten said they were “not confident at all” of being able to manage sequence of returns risk.
Interestingly, 59% of advisers surveyed said they use the same DFM for clients in accumulation and decumulation. Three quarters of advisers said they don’t change the process for managing investment portfolios for those in retirement, or review their situation more frequently, despite the additional complexities that decumulation entails.
Three traditional approaches to decumulation

Traditionally, there’ve been three main ways to provide clients with an income in decumulation. The first is to carry on investing in a combination of equities and bonds. The Just/ NextWealth survey shows that continuing to invest, either in a multi-asset or multi-manager fund or by using a discretionary MPS, is the most popular solution with UK advisers
The second approach is to use an annuity or guaranteed income solution; 27% of advisers surveyed said they were doing so.
The third approach is smoothed market exposure, or setting aside some of the returns in good years to bolster returns in less favourable years.
All three strategies have their merits, but also their drawbacks. The biggest problem with continuing to invest is the risk that falling markets will deplete clients’ capital so severely that they eventually run out of money. This is a particular danger when advisers deal with inadequate pension provision by increasing equity risk to bridge the expected shortfall.
Now that interest rates have risen, annuities can be attractive to clients with smaller retirement pots. But, crucially, they don’t produce any legacy value. The annuity is extinguished when the client dies, regardless of how early that is. If markets perform well, the client forgoes the opportunity to build a legacy for his or her dependants.
Smoothed funds may also appeal to those with smaller pots, or those with a low risk tolerance. But they often lack transparency, and they also tend to be complex and expensive as well. Smoothing involves hidden arbitrage costs as well.
More and better products are needed

The good news is that there is, at long last, a high level of innovation in the market for decumulation products. The number of tools available to advisers has also risen, largely as a result of the normalisation of interest rates over the past two years. Mark Northway, investment Director at Sparrows Capital, nevertheless believes there’s still plenty of work to do.
“There is an urgent need for savers to be able to consolidate multiple pots in a simple and cost-efficient manner,” he says, “and to access cost-effective pre-retirement and in-retirement advice and products relevant to their situation and relevant to the market environment.”
One of Northway’s main concerns is the need to address inflation risk. “The adviser community has de-emphasised real outcomes in decumulation in recent years,” he says, “largely because we have been in a zero-inflation environment. It is important to consider whether, and how, a retirement plan will address real-world inflation.
“The UK’s breakeven inflation rate is approximately 2.25% per annum. Work by Dimson, Marsh and Staunton suggests long-term real equity returns in the region of 3% per annum and marginally negative real bond returns.
“Many retirement strategies rely on expected real equity returns to provide protection against rising costs. This is a logical approach, but it can be painful and scary over the short term as equity markets initially respond to inflationary change.”
Tom Lovett from the structured investments platform FNZ Q-Hub agrees that many existing products fail to address inflation adequately. “It’s possible,” Lovett says, “to allocate clients towards investments that may outperform in periods of high inflation — for example, commodities, property or inflation-linked bonds) — but there is no guarantee this approach will work, and the investor may take a lot of risk in the process.
“The challenge with index-linked annuities is that the pricing becomes even more expensive than a traditional annuity, and the customer has to be confident that whatever reference index is used, will fairly reflect their personal spending habits throughout retirement.”
Blended solutions offer a ‘free lunch”

Lovett does, however, see an increasing role for solutions that blend features of drawdown and annuity together in an intelligent and dynamic way. “Much like the basic principles of portfolio diversification,” he says, “blending can offer a ‘free lunch’ in some circumstances from a risk- return standpoint.”
Northway agrees that blended solutions offer huge potential. “Combining a growth portfolio with guaranteed income,” he says, “provides an efficient way of reducing longevity risk and sequence of return risk simultaneously. This strategy maintains the exposure to growth assets, which produces attractive expected portfolio values and provides some degree of expected inflation protection.”
“Help is on the way”

Encouragingly, Tom Lovett reports a “marked change” in attitude towards decumulation among platforms in recent months, with a growing emphasis on improving functionality.
“FNZ recently conducted research with advisers around their approach to decumulation,” says Lovett, “and there was a strong consensus that more could be done in the area of secure income products on-platform.
“Consumer Duty places a direct responsibility on firms to help customers avoid foreseeable harm, as well as help customers realise their financial objectives. Advisers are rightly turning to the market to ask ‘what tools and products can you give me to meet these requirements?’
‘These new platform features may take a few more months to filter through to advisers, but help is on the way.”
A chance for advisers to shine

As well as improvements in on-platform functionality Mark Northway wants to see the introduction of holistic approaches to decumulation that can be implemented within a SIPP. He also wants better cashflow modelling, with an increased focus on tail risk. But he fully expects advisers to rise to the challenge.
“The point of retirement, and arguably the years immediately before retirement, is where an adviser can really shine,” he recently told UK Adviser. “Choices, costs and tax implications can be bewildering for clients, and mistakes at this point can be extremely costly. Explanation, looking at potential future scenarios and mentoring are all part of the adviser toolkit at this stage.”
Tom Lovett agrees that advisers have a vital role to play. Alongside innovative product development, he expects to see a greater emphasis on the emotional needs of investors in retirement, instead of seeing it as a purely financial problem to solve.
“It’s not just the outcome that matters, it’s the journey too,” he says. “We expect that the future approach to decumulation will not only solve the conundrum of how to provide both market exposure and income guarantees in one package, it will also need to offer ways to deliver this outcome in a smoother way for clients.”
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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.
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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;
Pillar 2 – requires firms to take a view on whether additional capital should be held against capital risks not covered by Pillar 1; and
Pillar 3 – requires firms to publish certain details of their risks, capital and risk management process.
Disclosure policy
The rules in BIPRU 11 provide that Sparrows may omit one or more of the required disclosures if it believes that the information is immaterial. Materiality is based on the criteria that the omission or misstatement of material information would be likely to change or influence the assessment or decision of a user relying on that information for the purposes of making economic decisions. Where Sparrows considers a disclosure to be immaterial, this will be stated in the relevant section.
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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.
Verification
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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