Risks Are Piling Up for Firms' Cash Sweep Programs: Report

Analysis August 20, 2024 at 02:25 PM
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What You Need To Know

  • Moving clients to high-yielding accounts results in lower revenues, putting new pressure on profitability.
  • Less diversified firms operating at higher leverage have been most reliant on elevated cash sweeps.
  • The treatment of client cash can affect recruiting trends, according to one M&A consultant.
A piggy bank in a vise

Wealth management firms are under growing pressure from regulators, litigators and their own advisors regarding the treatment of client cash held in sweep accounts.

In the past few months, major wirehouse firms including Morgan Stanley and Wells Fargo have been sued by clients who say that the firms used customers' cash balances to enrich themselves at clients' expense.

At the same time, regulatory filings suggest that the Securities and Exchange Commission is looking into the interest rates that brokerages pay customers on uninvested cash swept into bank accounts.

Against this backdrop, a detailed new report from Moody's warns that rising attention on cash sweep programs is "credit negative" for wealth managers because it could lower their spread-based revenue earned on clients' uninvested cash balances — while increasing legal and regulatory compliance costs.

Cash sweep revenue is particularly profitable for wealth managers because it typically does not accrue financial advisor compensation. Highly leveraged wealth managers face the greatest competitive risk from an increase in rates paid to clients and a corresponding decline in revenue, according to Moody's.

"Wealth managers regularly review and compare their rates paid to clients with what competitors are offering, and any moves by larger firms to shift to more favorable client rates will likely drive similar shifts across the industry, posing particular risk for highly leveraged firms," the report warns.

Regulatory risk is "less prominent" overall, although the scope may be widening.

"Wealth managers have operated cash sweep programs across several interest rate cycles without significant adverse regulatory actions," the report notes. "Regulators have generally limited their focus to ensuring proper disclosures to clients about options for their uninvested cash and the potential conflicts of interest posed by these arrangements."

However, the uptick in litigation and regulatory activities may bring fiduciary and best interest standards into the spotlight.

No new regulation has yet been proposed, and wealth managers with appropriate disclosures have a case to defend their current cash sweep practices. Nonetheless, Moody's warns, firms may very well end up yielding to competitive forces and offering higher rates, as well as incurring increased regulatory compliance costs.

How Cash Sweep Programs Work

A cash sweep program is a method used by wealth management firms to manage clients' cash balances, the report explains. Cash balances in these programs are typically transactional or transitory and do not represent cash as an investment or asset allocation decision.

The typical program automatically sweeps investors' idle cash out of their accounts on a daily basis, according to Moody's, depositing the balances in accounts at partner banks.

"Upon account opening, clients are shown this default option, but in some cases, depending on the product and the firm, clients have the opportunity to elect another vehicle for their transactional cash," the report explains.

These alternatives generally include taxable or tax-exempt money market funds or other non-bank options. As interest rates have increased, so has the relative attractiveness of such options relative to the default low-yield bank accounts.

Under this framework, the type of cash sweep option elected by the client dictates the economics received by the wealth management firm. The typical default option is the FDIC-insured bank sweep, according to Moody's, offering the client a lower yield than money market funds — but with FDIC insurance.

In turn, wealth management firms typically earn the most spread-based revenue from this option. Should clients move en masse to higher-yielding options, the thinking goes, firms could be robbed of potentially significant amounts of heretofore dependable revenue.

What It Means for Wealth Managers

As Moody's report details, less diversified firms operating at higher leverage with more aggressive financial and strategic policies have been most reliant on elevated cash sweep revenue and profit in the current interest rate environment to service their debt.

"Therefore, those firms would be most adversely impacted by industry-wide changes to cash sweep programs that lower spread-based revenue," the report notes.

With the increased attention paid to cash sweep programs, Moody's expects the strongest and most diversified firms to have a growing incentive to shift the rates paid to clients on such programs to make them more competitive. This would force the less diversified and more leveraged firms into weaker competitive positions.

This trend would be reminiscent of the race to zero commissions at online brokers that was seen between 2017 and 2019, according to the report.

The Advisor Recruiting Angle

Jason Diamond, a recruiter and M&A consultant at Diamond Consultants, said the cash sweep question has increasingly been a topic of conversation in the wealth management industry — both in terms of the potential effect on firms overall and on advisors contemplating moving shop.

"This is especially important for some independent firms after the reduction of custody costs," Diamond said. "Firms could make custody free because they were being compensated via cash sweeps. Now, there's clear regulatory scrutiny being applied to these practices."

Diamond said this dynamic could jumble some of the math that has driven record levels of advisor recruiting and M&A activity in recent years.

"Consider a big firm that has been very successful at bringing in new advisor teams," Diamond said. "If they are suddenly not able to make money on cash to the same degree, could that put their deals and their profitability under strain? Will they be able to recruit as aggressively going forward?"

Diamond said he's confident that the broader drive for scale will maintain a health pace of recruiting and M&A.

"My sense is that firms will figure out a way to squeeze value and revenue out of advisors, and they'll just do it in a more transparent way," Diamond said. "Maybe it means they'll get somewhat less aggressive with payouts, or they'll charge some sort of technology or custody fees. … I think they'll figure it out, but this does have the potential to be a disruptive trend."

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