CSA Webinar

July 22, 2026.  Please note that this is an automated transcript of the above mentioned podcast; errors may exist. If you have any questions, please contact Castine.

Robin Hodgkins: Hello, and welcome to this episode of Castine Conversations. My name is Robin Hodgkins, and I’m the president of Castine. By way of introduction, Castine is the leader in providing a full continuum of research and commission management solutions to brokers and asset managers worldwide. In these episodes, we meet the business leaders involved in commission management and research as they are managed, reported on, or paid for by both investment managers and brokers around the world. My conversation today is with Rudolf Siebel, the managing director of the BVI German Investment Funds Association.

The German Investment Funds Association represents the interests of over 100 large German funds with almost €5 trillion in assets under management. Rudolf is responsible for several different areas, including regulatory affairs, industry standards, and market research. He is a member of the European Commission Expert Group on European Data Space, has authored several papers through that group, and has participated on panels at several CSA-focused conferences in the United Kingdom.

He has been with BVI, with a break or two, since 1991. He brings a wealth of experience and knowledge on commission management and research to this podcast. I hope you enjoy this conversation.

Rudolf, thank you very much for joining me today. I really appreciate your joining this conversation.

Rudolf Siebel: Thank you, Robin, for having me. It’s a pleasure to meet you and to have an exchange of views on research procurement from a purely continental voice versus the US.

Robin Hodgkins: Absolutely. We’ve been together at different CSA conferences, but I don’t think we’ve ever had a chance to speak on the same panel or on the same podcast before. So I’m honored to have you here today. Thank you very much. I think that also plays into the fact that you have a unique view because of your legal experience and training in Germany, and also at Georgetown. So you have a view from both sides of the Atlantic, I would guess.

Rudolf Siebel: That’s true. I was always interested in international affairs, and in participating in exchanges with universities during my German legal education. But I had the privilege of a Fulbright scholarship, which allowed me to go to Georgetown, the heart of US policymaking and government, and that obviously helped tremendously in my career. I completed a Master of Laws in 1988, when there were just fifty people in Germany who held a Master of Laws from a US institution. So it was really something special. At the time there was a shortage of lawyers versed in international law, and also of people who could speak decent English.

That was particularly important because the EU was becoming more and more relevant, especially in financial services. My career largely hinged on the ability, thanks to my US law degree, to converse fluently in English and take part in English-language negotiations.

Robin Hodgkins: Excellent. And not only do you have the legal education, but you’ve also, I think, been in finance throughout your entire career in one manner or another. I was wondering whether that’s something you picked up in Germany or at Georgetown, or something in your DNA that led you into finance, and specifically to the BVI.

Rudolf Siebel: I really started out as an Air Force brat. My father was in the German Air Force, so I wasn’t really drawn to finance initially. Going to Georgetown was meant to prepare me for a career in the diplomatic service. My thesis at Georgetown was on the use of force against terrorists and terrorist-sponsoring states, so you can imagine I was watching the news with particular interest. But a lot of the curriculum at Georgetown focused on the economy, the laws affecting the economy, and also on finance, so my interest turned more in that direction.

Since I was interested in policymaking, after finishing my German legal education in 1990, I was pleased when the BVI approached me, because it offered a unique opportunity to be close to the financial services industry, particularly the mutual fund industry, which I didn’t know anything about at the time. At the same time, it let me pursue my original interest in policymaking, because that’s what a trade association does: it gathers the views of its members, primarily on regulatory projects, and then tries to advance those projects, either proactively with its own proposals, or, as is usually the case, by influencing a proposal that’s already come from lawmakers, so that the effects on the industry are positive, or at least not negative. From that perspective, working for an association was genuinely interesting to me.

Then I took a bit of a detour, again back to my beloved USA. Very early on while working in international relations at the BVI, I had the privilege of coming into contact with international visitors. Moody’s Investors Service, the credit rating agency, was expanding its German business at the time, and they approached me with a very favorable offer. I joined Moody’s after just one year at the BVI. I stayed with Moody’s Investors Service for five years, working in both New York and their German office. I was responsible for credit ratings on money market funds, bond funds, and debt issued by closed-end funds, and, toward the end of those five years, life insurance as well, and I also helped the investment banking side with the first ratings of asset-backed securities in the German market. All of these areas obviously have a portfolio management aspect, but they’re also very much governed by laws and regulations. That’s certainly true of the mutual fund industry, but asset-backed securities also involve a great deal of fine print in their prospectuses.

Robin Hodgkins: Absolutely.

Rudolf Siebel: So I was able to help the team, which was primarily made up of economists and financial services professionals, with the legal expertise needed so that together we could hopefully secure good ratings. That experience certainly helped me when I went back to the BVI in 1998, because they were still looking for someone who could lead their international efforts and speak decent English. When the BVI also said they would make me part of the management team, I came back in 1998.

Robin Hodgkins: So your time at Moody’s was in New York. You moved to New York and then came back. Was there perhaps a bit of the travel bug from your Air Force background, or your family’s Air Force background?

Rudolf Siebel: Yes. At the very least, I got a lot of miles and points, which was a nice fringe benefit at the time.

Robin Hodgkins: I’m married to an Army brat myself, and my family also traveled all over the world for non-military reasons, so I definitely understand the experience of traveling back and forth. But was it the appeal of getting back into the regulatory side that brought you back to the BVI?

Rudolf Siebel: Yes, and also the prospect, starting in 2003, of joining the management team. We have two managing directors: the CEO, Thomas Richter, and myself, and together we’re responsible for the association. The association has a double-digit-million budget. We have about 60 employees and three locations: Frankfurt, Berlin, and Brussels. So it was quite an enterprise to manage.

Beyond our core mission of influencing regulation at the German, European, and, depending on the case, global level, which has increased considerably since the 2008 financial crisis, we’re considered a shadow bank, or NBFI, in the current terminology. So we also have to do a lot of educational work with regulators at the global level to make sure they don’t mistake mutual funds for an unregulated, shadow-bank-type industry. That’s a relatively new development. The most recent wave came in the 2010s, with the whole shift toward ESG regulation, which placed a broad layer of new requirements on the industry that also had to be addressed.

Robin Hodgkins: And I think talking about requirements for the industry brings us to the issue of commission management. Perhaps you can help us, because the situation between the UK and the EU was once unified, pre-Brexit, and then changed post-Brexit. I’d like to set the calendar back a few years and understand what things were like back in the 2017–2018 timeframe, when things shifted toward CSAs, and then move forward to what’s been happening more recently and some of its impact. But we’ll get to that later. Let’s go back in time first and understand that period.

Rudolf Siebel: As you said, in the years before 2017, before the active discussion around what in Europe is called MiFID, the Markets in Financial Instruments Directive, began, most of the industry was content with the CSA model that was prevalent at the time. My members in particular were very keen to procure US investment banking research, mainly through their London-based entities, but also through their Frankfurt-based branches or subsidiaries, under that system. I think the industry was surprised to find that an FCA-led initiative suddenly sought to unbundle the payment of transaction and research fees.

There were huge conferences and extensive discussions; institutional investors and others held a lot of conferences on the subject. There was a great deal of debate about how it could work. Then, in 2018, the FCA and the UK prevailed in the MiFID discussions in Brussels, and this unbundling regime was introduced. Our own regulators, both the finance ministry and our local supervisory agency, BaFin, were quite quiet in these discussions. It was a subject they hadn’t thought much about, and they saw it as a secondary matter. The FCA was quite persuasive at the time and strongly committed to its own approach, so continental Europeans essentially gave way, and we ended up with that new system.

I think the main concern for our members was how they could continue to procure research, especially from US investment banks. That was the most important issue. Then there was the technical discussion of how to unbundle going forward. In Europe, the law essentially provided for one approach, the well-known research payment account, which allowed firms to take client money, set a budget for a specific fund, and place it there. There were a lot of organizational requirements around that, so in practice very few members used it. Both international members, like Fidelity, and more local firms, like Deka, from the German savings and loan sector, used it in part for some of their products.

But somewhat to our surprise, the discussion essentially moved away from the legal side to the practical side. What I mean is that most firms adopted an approach of buying unbundled research going forward, especially from investment banks, through direct payment from their own accounts, the so-called profit-and-loss alternative. There was virtually no regulation around this. At the same time, as you’re likely more aware from your own research, the market for research essentially collapsed. Investment banks reduced their research coverage, and research moved away from small caps toward large caps.

We felt this strongly, because in 2017 we published a paper together with the German Listed Companies Institute, the German Financial Analysts Society, the equivalent of the CFA in the US, and the German Investor Relations Association, encouraging small and medium-sized companies in particular to commission issuer-sponsored research, because there was a real sense that they would fall off a cliff in terms of research coverage. At the same time, our members and other users pushed for lower prices, which, I imagine, also led investment banks to cut back their research. Members had to learn, more intensely, more quantitatively, and more thoroughly, to assess the quality of research, budget for it, and set up a control process to ensure that research spending complied with whichever regulation applied, whether the lighter rules for P&L or the more detailed rules for the research payment account, and then implement all of that.

What we really learned is that a process that used to be as simple as a portfolio manager casting a vote once, twice, or three times a year under a commission sharing agreement suddenly became a full-fledged organizational process, where research is evaluated in depth, budgeted, and procured under clear governance. I think that’s something that will persist going forward and will also shape how CSAs are applied in the future. The kind of informality that may have existed in 2017 and before, where the portfolio manager simply cast a vote and that was that, isn’t going to prevail again, even if we return to using CSAs.

Robin Hodgkins: And we’re certainly seeing a different approach in the UK versus the US. CSAs are very widely used in the US. In the UK, we expect they’ll be widely used again; it’s just taking a while for that shift back to happen. But what I find interesting, especially in the German market, is the differences in how that market works and the size of the firms involved. Could you talk a bit about why, even though in 2017 and 2018 nearly everyone shifted to P&L, and even though there may be a slow return to CSAs in the UK, that same shift might not happen as quickly, or as extensively, in Germany? Could you talk about the aspects of the German market that are unique to your members, who are very large, and how that might differ from your neighbors on the continent?

Rudolf Siebel: Yes. In Germany, we currently have about €5.2 trillion in assets, and of that, roughly €2.4 trillion is held in so-called institutional mutual funds, with probably an additional €500 billion or more in separately managed mandates. That concept of mandates is more prevalent here than what you’d typically see in the Americas or the UK. These institutional products largely come from retirement institutions across the board. Unlike, say, UK or Dutch pension funds, which tend to be quite large and have a trustee-driven investment approach that allows for allocations to riskier assets, including equities, private equity, and others, the German pension industry is more fragmented. There are only a handful of large players, especially once you exclude insurance companies. There are many medium-sized players in the single-digit-billion range of assets under management, so they have comparatively small management teams.

Even so, contrary to what you might expect, they don’t rely heavily on external consultants for strategic and tactical asset allocation. Instead, they tend to be guided more by insurance regulation, which favors fixed income investments over equities. So their demand on asset managers to identify specific opportunities in equities, or to expand equity allocations, isn’t as strong as it is in the UK or in Dutch pension funds. These funds also tend to focus on low management fees. In the institutional funds space, we’re really talking about single-basis-point fees, or fees near zero for fixed income, and maybe 20 to 30 basis points at most on the equity side. Even the premium that used to exist for US managers in the early 2000s has largely disappeared.

So the focus here is on low cost, which means that any discussion of even a single basis point of overall research cost is a significant issue in that context. That might explain why, similar to what I hear from the UK, there’s a reluctance to discuss with clients, mainly pension institutions in our case, an indirect increase in fees from rebundling transaction and research costs. On the surface, the two situations look similar, but I think in our case, given the specific structure of the German pension industry, that reluctance might be even greater than it would be for a UK pension fund with larger equity exposure and a clearer understanding that a certain amount of high-quality research is needed to improve returns on equity portfolios.

On the fixed income side, there’s always been less debate about research pricing and less need for individual company research. The rating agencies handle part of that work, and broader economic assessments are supported by other types of research. So the focus on rebundling has always centered on equity research.

Robin Hodgkins: It’s quite different for the German market, where the mix between fixed income and equities may differ dramatically from a UK-based fund.

Rudolf Siebel: We don’t have exact figures for institutional funds, since that space is somewhat less transparent. But on the retail fund side, equity funds clearly make up the largest share, at 53%. I’d assume institutional funds still have a strong equity allocation as well, probably even more than in France, where the focus has traditionally leaned more heavily toward fixed income and derivatives than it has for us.

On the retail side specifically, one could more easily explain a move back toward CSAs, because retail investors are numerous and firms don’t need to have individual conversations with each one. But even there, given strong competition and greater fee awareness among both investors and regulators, appetite for shifting back to CSAs in the retail space has been dampened.

One point worth mentioning: ten years ago, ETFs were an exceptional type of investment. Now, out of about €2,000 billion in retail funds, ETFs account for over €600 billion, so roughly a third, and the vast majority of that is in passive, index-tracking ETFs. So cost is becoming an increasingly important consideration for retail investors, which further dampens the outlook for managers proactively pursuing research through rebundling. Instead, they might build up their own internal research capabilities, which some have already done in part. I think one of the main factors that would change the situation dramatically is if US investment banks started asking for rebundled fees.

Our members have consistently told us that our main mission is to ensure that, between 2018 and 2025, while rebundling was in effect, they could still procure US research. We had direct discussions with the SEC on at least two occasions to find out whether the SEC, particularly under the Biden administration, would be interested in extending the territorial reach of the Securities Exchange Act by requiring London- or Frankfurt-based branches of US banks to also apply the same bundling regime used in the US. The SEC never issued a written no-action letter on that, but there was enough confidence in the market that this wouldn’t happen. And once that legal risk was essentially removed, once the EU allowed rebundling, our members now feel quite secure and would be ready to return to CSAs, especially in that context.

But as I mentioned briefly earlier, it’s likely to be a somewhat different type of CSA going forward, because members are now much more skilled at evaluating the quality of research, budgeting for it, and maintaining internal governance over how research is procured.

Robin Hodgkins: You don’t think there will be a real problem obtaining high-quality research when your member firms want it, even with a smaller, more tightly reviewed budget? You think there will still be a way for them to access the research they need?

Rudolf Siebel: The association operates at a high level, so to speak, while our members are on the ground making these decisions themselves. We haven’t received requests from members to change anything because they lack access to the research they want. That’s simply how things appear to us. Of course, they should be making these comparisons, especially against US managers, since our association’s membership is about 60% foreign, including all the major US firms active in the European and specifically the German market. And looking at Morningstar figures, we can’t identify a clear performance gap between the two overall. There may be differences in individual asset classes, but that could go either way, for example in European equities. So members aren’t telling us that this is a specific concern for them, though of course I can’t track every detail or agreement individual members may have with US investment banks to ensure they have enough research at their disposal.

Robin Hodgkins: And from the standpoint of looking at other member countries within the European Commission, what are your thoughts on their interest and the pace at which they might return to unbundling? You mentioned that Dutch funds differ in structure and approach from German funds. What are your thoughts on some of the other large markets out there, whether they’ll return to CSAs, and whether that might happen long-term or perhaps never?

Rudolf Siebel: As James Bond taught us, never say never again, so definitely not never. One scenario I’d point to is if investment banks start requesting rebundling themselves, taking on the responsibility for having initiated it. That could move the market quite quickly, because, as I’ve mentioned, procuring US investment bank research was one of the most important goals our members gave us for the regulatory debate.

We have a longstanding dialogue on these issues, especially with the French and Italian markets. The Italians have pointed out that there’s significant interest among their membership in retaining the profit-and-loss option, because in law they’ve tried to establish more clearly that payments made from profit and loss, meaning a firm’s own capital as an asset manager, are not client money and therefore shouldn’t be subject to the same transparency, organizational, and quality standards as money taken from clients. That was an important point for the Italians, though lawmakers didn’t ultimately implement it. I don’t think that will prevent a return to CSAs.

There was also a request for clarification that the detailed organizational and transparency requirements retained for the research payment account, which only a minority of members use and which is an inheritance from the FCA, should apply only to research payment accounts, and that commission sharing agreements should only be subject to the general standards on transparency and organizational requirements that apply to all research procurement. That hasn’t been fully clarified in the law either. I think the law is clear enough to allow the reintroduction of CSAs, but strictly speaking, one could still argue there are minor gaps in the clarity of the law regarding the use of both CSAs and profit-and-loss going forward. So, to put it another way, the law doesn’t actively encourage a move back to CSAs. It allows it, but it doesn’t encourage it.

Robin Hodgkins: Right, and I think it might be different in other regions, where there’s more active encouragement to return to CSAs, unlike the situation you’re describing from a European standpoint. From what you’re saying about the Italian market, it may be easier from a reporting standpoint for firms to continue using P&L as it’s currently structured, rather than taking on more transparency and reporting obligations. But you’ve also touched on the performance side, which is something we hear from the UK as well, where the FCA’s view, as I understand it, is that allowing the use of client commissions leads to more research being produced. Setting aside the equities-versus-fixed-income debate for a moment, more research, and higher-quality, more comprehensive research, could in theory lead to better performance. Based on how your member firms are structured, do you believe there will be an impact on performance if those firms continue to rely on P&L?

Rudolf Siebel: That’s at least what they tell us. I’d also say we broadly agree with the UK’s assessment, and that holds true across the continent, that there aren’t enough listings, and that we’re seeing a crowding-out effect, particularly for small and medium-sized companies, both in terms of research coverage and listings. But that’s not solely because of the reduction in research; there are other factors at play. For a number of years now, we’ve seen a broader shift toward private assets rather than public assets, which certainly hasn’t helped the research market either. Beyond investment bank research, which is now largely focused on large blue-chip, index-inclusion-type investments, we’re also seeing more dedicated research firms that are paid directly, so for them, P&L is simply the normal way of doing business.

So our members aren’t especially eager to be at the forefront of reintroducing CSAs. We even had one large member firm whose board, more than a year, maybe close to two years ago, made a formal decision to stick with P&L for the time being. In that case, the finance department had asked other departments whether the amount spent on P&L research payments could be reduced. That’s just one example that shows this discussion is happening and the awareness is there, but, similar to the UK, everyone seems to be waiting for someone else to make the first move.

Robin Hodgkins: Yes, I think that’s definitely the case. We’re certainly seeing that in the UK. In our conversations with people, a lot of firms are lining up. They’re evaluating different solutions and getting ready for a potential move to CSAs. Some firms are doing it quietly, but there’s a lot of discussion about who’s going to move first, who’s going to be the lead firm that ends up on the front page of the Financial Times for making that move.

Rudolf Siebel: Other areas of research have also become important. I mentioned ESG earlier. We now have dedicated ESG data vendors and rating agencies that have become quite prominent, and those are also paid for directly. So we really need to look at which types of research, especially third-party research, will still be paid for through a CSA, because I think today we’re seeing more research overall, in the broader sense, including credit rating agencies on one side and ESG rating and ranking agencies on the other, and both are typically paid for directly. So direct payment is no longer the exception, even once CSAs are reintroduced for investment bank research and other third-party research paid through commission sharing agreements. It may not represent the majority of research-related spending, especially when you factor in data feeds and quantitative information, which is becoming increasingly important for an increasingly digital industry and which is also usually paid for directly.

Robin Hodgkins: It’s interesting that you mention the idea of waiting for the first domino to fall. One thing we hear a lot these days in our conversations with firms in the UK is that, since the UK has seen some movement on the policy side, and the European Commission has made progress with Level 1 and Level 2, some firms in the UK are waiting to see which direction the European market decides to take. From what I’m hearing from you today, it seems things aren’t likely to change that dramatically in the short term for a lot of member firms in Europe.

Rudolf Siebel: I agree. It’s entirely up to the firms themselves. Regulators and supervisory agencies, both in Brussels and here in Germany, at BaFin, aren’t particularly focused on this subject, so we won’t be getting more detailed rules on how research procurement should be organized across the three approaches we’ve discussed. Firms are entirely free, within the existing regulation, to make that decision, so they’re waiting for the economic or psychological push to act.

I’d be more concerned about the UK, given the FCA’s detailed involvement going back to 2018, and the extensive debate that followed, including the Rachel Kent report, which ran to hundreds of pages just on research procurement. There was nothing comparable in the EU. In the context of the Listing Act, the necessary legal changes to allow rebundling were included, along with some explanation, and then there was a similar treatment at Level 2, the implementing regulation, and the whole thing was maybe 30 pages long in total. There wasn’t much debate about the underlying philosophy; it was more the typical legal back-and-forth over getting the wording right. So I’d agree that the EU can move much more easily, because in the UK, it may take much longer to work through all the details with the FCA before things are finalized.

So, in that sense, we could move faster. Like you, I’m looking for the first domino, the one that will start the chain reaction. From my members’ perspective, that likely depends on whether the rules around procuring US investment bank research change, either proactively initiated by the banks themselves, or in reaction to a move by the SEC, which we don’t currently see happening, especially given that the new administration is more pro-market and unlikely to push for that kind of change.

Robin Hodgkins: And every conversation we have around potential SEC changes tells us that nothing is coming down the pike anytime soon. There are a lot of other priorities they want to focus on. My understanding is that they believe the US market is working just fine, and they don’t want to change course in response to what’s coming out of Brussels or out of Canary Wharf. So I don’t think there will be changes on that front.

Rudolf Siebel: Actually, both Canary Wharf and Brussels have essentially moved back toward the US approach, in the sense that rebundling is now the starting point, though there are more details still to be worked out in the UK than in the EU. In that sense, there’s no requirement for the US to react to EU regulation. So we’ve stepped back from our earlier push for a more globally consistent approach in that regard.

That said, I understand there’s still some unbundling discussion happening in the US as well, and growing investor interest in it, but it hasn’t reached the point where a legal change is actively being discussed. That said, it’s possible that could eventually prompt one or more US investment banks to shift their model.

Robin Hodgkins: I agree. I don’t see changes coming from that direction either. But looking at it from the perspective of a global firm, how do you see this working for them? They may end up with one structure in the US, another in the UK, which we believe is leaning more toward CSAs given the pressure from CFOs to move costs off the P&L, and then a different approach on the continent. How do you think global firms will view this, since I think they were hoping for standardization, with maybe some edge cases around corporate access and market data, but generally one consistent global approach? How do you think it’ll play out for them?

Rudolf Siebel: I think your point about performance differences tied to the availability of research could well prove true over the long term. We clearly see that large US managers typically drive their investment policy decisions out of their US headquarters, where they also source their research. In a simplified model, they might have sales and sales administration functions here in Europe, but this is a simplification, since all portfolio management happens in New York. So naturally, they can largely rely on their US-centric approach.

That could genuinely be an issue for large European firms. There are a few based in Germany, and a few in France as well, less so in Spain and Italy, that essentially have to procure research based on EU regulation and could therefore find themselves at a competitive disadvantage in, say, Asian markets or elsewhere, compared to American firms that can operate differently. But as I mentioned earlier, this concern hasn’t yet reached us in any meaningful or vocal way as an association, so I’d need to think carefully about what, if anything, we could do from a regulatory standpoint to improve the situation.

Robin Hodgkins: Do you have recommendations, or thoughts, on what the next step should be for European firms that are weighing whether to stay with P&L, dip their toes into RPAs, or move fully to CSAs, what would your thoughts be on what they should consider as they map this out over the next six to twelve months?

Rudolf Siebel: As I said, since the association is operating at a high level while our members are on the ground, it’s ultimately up to them to decide. What I can say is that we’re still pushing for two clarifications in the law that haven’t yet happened: first, making clear that CSAs carry lighter requirements than RPAs, and second, clarifying that P&L payments aren’t considered an inducement, since they come entirely from a firm’s own funds rather than client money. We’ll continue pursuing that at the association level, both through BVI in Germany and alongside our counterparts in Italy, France, and across the EU.

But what firms probably need, and this may be where firms like yours come in, is a broader discussion about what the new CSA should actually look like and how it should be structured. I mentioned that our members now have ten years of experience valuing research, not just through the portfolio manager’s role, but across all departments within the firm involved in consuming, valuing, budgeting, and governing research procurement. I haven’t yet heard of a discussion between investment banks, as the primary providers of CSAs, and the buy side as users, about how the new CSA should account for that. Will it still be based solely on the portfolio manager’s role, or will there be some other mechanism for incorporating how asset managers actually perceive the value of research within a CSA?

I remember, when the industry shifted away from CSAs toward RPAs and ultimately P&L, there was a lot of discussion about how that transition could work, along with a great deal of technical and organizational debate. That’s what I think is missing a bit right now. There are a few conferences, and some firms are organizing discussions around the topic, but if that kind of dialogue got started in some form, it would make it much easier to restart the broader conversation about moving back to CSAs. Because then people could say, “Okay, here’s the new CSA, and here’s how it clearly aligns with the research procurement processes we’ve built over the past ten years on the buy side.” At that point, we could move forward with real confidence.

That could also be an opportunity, at least in terms of the general terms and conditions of such an agreement, for some degree of industry-wide standardization or debate. Of course, we’re all operating under competition law, so clear pricing arrangements and similar details would need to be excluded from that. But the general framework is something I could see being discussed productively. How will the new CSA apply to the new buy side when it comes to research procurement? That’s something that could really help kickstart the conversation.

Robin Hodgkins: And I think a lot of that will evolve over time. Transparency and disclosure are certainly paramount. Doing thorough, complex research evaluations and improving communication with research providers are all part of strengthening the research ecosystem. But as you say, it will take time. There’s a lot of ongoing discussion and debate about the best way to approach that, and the best way to report on it, among other things.

Rudolf Siebel: That process could be sped up, for example, if SIFMA or AFME, representing US and European investment banks respectively, put forward a proposal for a standardized CSA master agreement, similar to what we see with ISDA on the derivatives side, though obviously for research rather than derivative contracts. Those associations are already familiar with master agreement structures, which could help the market streamline the discussion and move forward. Right now, there’s no real need to engage with the subject: investment banks aren’t approaching us, and we aren’t approaching them. But if there were some kind of focal point for the discussion, that could genuinely help.

Robin Hodgkins: That’s really interesting. It’s fascinating to learn about the different pressure points and dynamics playing out in different parts of the world. I really appreciate you spending time with me today. I’m sure our audience will also find it fascinating to hear about the different ways this is likely to play out over time. I think this is a very interesting time to be in the research and commission management space, and I’d love to check back in with you in six to twelve months to see how things are evolving in the German market and across the EU.

Rudolf Siebel: Yes, I look forward to our next discussion, Robin. Thank you for having me, and I hope your audience finds this podcast interesting.

Robin Hodgkins: Thank you. They definitely will. Thank you so much, Rudolf. I really appreciate the time, and I look forward to our next conversation.

Rudolf Siebel: Goodbye.

Robin Hodgkins: For more information on the German Investment Funds Association, please visit bvi.de.

For more information on Castine and our continuum of research and commission management solutions, please visit castinellc.com. Thank you very much.