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Introduction by Cherry Reynard
In the decade since pension freedoms were introduced, financial markets have been kind. Bond and equity markets have risen, and most advised clients will have been happy with the performance of their drawdown portfolio. However, decumulation advice is becoming more complicated. A changing interest rate environment and higher inflation have brought a new fragility to financial markets while threatening to dent retirees’ living standards. There is a danger that the next generation of drawdown clients will have a very different experience. The new environment has also brought opportunities. Bond yields have risen, enabling fixed income to resume its traditional role in a portfolio — income generation, capital preservation and diversification. It has been a better period too for equity income strategies, which have lagged broader market indices over recent years. This gives advisers a broader palette with which to create decumulation options for their clients. For the first time in 30 years, inflation is a real risk to retirees’ living standards. Economists are predicting that inflation will be structurally higher from here as deflationary factors such as globalisation and cheap imports from China diminish. For the duration of many advisers’ careers, inflation has been little more than a theoretical risk — but now it needs to be front and centre of all decumulation advice. This can be a complex message; it is difficult to emphasise the importance of incorporating growth assets at a time when investors are nursing losses on their equity portfolios. Nevertheless, it is vitally important. Clients are more vulnerable in retirement. Often, they cannot make back whatever they lose. If inflation takes a chunk out of their retirement savings, they must live with the deterioration in their spending power and lifestyle. Mistakes — such as exiting the market at the wrong point, a lack of diversification or, simply, the wrong assets at the wrong time — can be particularly costly. At a time of greater economic and financial markets instability, the importance of advice in building robust decumulation portfolios has never been greater. In this supplement, we aim to help you shape your decumulation strategy for the future.
Interview: Richard Parkin
The BNY Mellon FutureLegacy 5 Fund
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Decumulation strategies in a time of uncertainty
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Decumulation advice: Why it is under scrutiny
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The decumulation strategy of the future
Interview
Investing for retirement income is different from an accumulation strategy, says BNY Mellon's Richard Parkin
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‘Inflation now needs to be front and centre of all decumulation advice’
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The goal of most decumulation advice — individual circumstances aside — is likely to include a high and sustainable income, while preserving capital as necessary for inheritance purposes and/or care costs. However, a changing environment is forcing advisers to be flexible in the way that outcome is achieved, and it may expose decumulation strategies that are not fit for purpose. In the first few years after the introduction of pension freedoms, it was relatively straightforward to build a successful decumulation strategy. Financial markets were buoyant and annuity rates were so low it made for easier decision making. BNY Mellon Investment Management head of retirement Richard Parkin says: “When pension freedoms were introduced there was a lot of discussion about risk, but then markets kept going up and that was forgotten. The first wave of retirees under the new rules did pretty well. Interest rates were on the floor and annuities didn’t look attractive, so people didn’t buy them.” Those entering drawdown in more recent times are having a very different experience. Markets have dropped significantly across both bonds and equities, and the 40-year deflation cycle has come to a sudden end. Tillit chartered wealth manager Gabriella Macari says the market remains very uncertain. “Yields have risen but the rate environment has shifted significantly,” she observes. “Rates remain relatively low compared to historical averages – we can’t just compare them to those of the last decade – and it’s unlikely we’ll see them return to pre-financial crisis levels for a sustained period. “This puts bond income under scrutiny. How long will the current yields be sustained?” Macari continues: “Dividend income distributed to investors comes from company profits. As such, if we go through a recession or a period of economic weakness, many companies may need to reduce or even withhold their dividend payments.”
As advisers strive to adapt to widespread change — from retirement patterns and annuity rates to inflation and regulation — decumulation strategies will receive greater attention from the FCA
‘All investment strategies should reflect the fact retirees are not a homogeneous group’
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For much of the past 30 years, inflation has been little more than a theoretical risk for advisers and their clients. However, a lot of economists now forecast structurally higher inflation, with many of the forces that have kept it low (notably globalisation) set to reverse. Advised clients may be wealthier but nevertheless will face higher bills and a declining standard of living. Although inflation has always been a factor in decumulation planning, it has become a more urgent and important variable.
Higher inflation
The role of annuities may also be transformed as rates rise. A few years ago, with rates at rock bottom, annuities seemed a poor solution for retirement needs. As such, advisers tended to use them mostly to cover essential spending in retirement. Today’s annuity rates have more appeal.The newly retired may already have sufficient guaranteed income, through either the state pension or a DB scheme. For them, there may be genuine advantages in deferring an annuity purchase. There is also the problem that all annuities are underwritten now. Retirees who choose to annuitise early, when they are in good health, may come to regret their choice if health problems set in that would have qualified them for a higher, impaired life annuity. Parkin says temporary annuities have become more popular as a means of dealing with this issue. But advisers also need to remain flexible because the next generation of retirees are unlikely to have the same abundance of guaranteed income as that of their predecessors. DB schemes are working their way out of the pensions system and the retirement age is rising.
By Cherry Reynard
On top of all the investment considerations around decumulation portfolios, advisers need to factor in changing retirement patterns. A recent survey from Rest Less found there were 446,601 people above the age of 70 still in work last year; a rise of 61% in the past decade. There is an increasing recognition of the social and financial benefits of continuing to work beyond retirement age. AJ Bell head of investment analysis Laith Khalaf says all investment strategies should reflect the fact retirees are not a homogeneous group. “Some are investors in the lucky position of treating their drawdown pot as a bit of extra retirement money, or a way to potentially save inheritance tax, because of large final salary pensions or income from other investments. “But, since the decline of defined benefit [DB] schemes, increasing numbers of people are relying on their drawdown plan to provide them with their main retirement income; a trend that was hugely accelerated by the pension freedoms. “Within this group, there will again be a range of risk tolerances and engagement, with some wanting to simply set up an income portfolio that pays out continually, while others are willing to take a more hands-on approach by investing in growth strategies and taking gains to supplement income, as and when they see fit.”
New retirement patterns
Higher annuity rates
Regulation and Consumer Duty
Regulation too will shape advisers’ decumulation strategies. Retirement advice is being seen as a bellwether for the effectiveness of firms’ implementation of the Consumer Duty. The new regulation requires advice to be outcome based and to avoid foreseeable harm. Although advisers have formalised their decumulation strategies in the past decade, more work may be needed. Parkin says the Financial Conduct Authority is likely to become increasingly unhappy where the same investment strategies and funds are used for both accumulation and decumulation, given the difference in investment objectives. Although he believes retirement advice in the UK is generally good, there will be areas advisers need to look at. With a previously benign market environment, retirement solutions have mostly been subject to less scrutiny – clients have been happy and outcomes have been good – but, in today’s tougher environment, this may change. There are signs this message is being absorbed by advisers. In a recent survey by Copia Capital Management, around half of participants said the FCA’s thematic review of retirement income advice should recommend a different investment approach for clients in decumulation compared to those in accumulation, with only 5% saying there was no need for a different approach. Advisers recognise the challenges of building a decumulation strategy during these times of widespread change. They are working to adapt to the new environment.
‘Yields have risen but the rate environment has shifted significantly’
“The decumulation problem is defined as the challenge involved in efficiently turning wealth into income, which stands in direct contrast with the accumulation problem, which is about efficiently turning income into wealth.” EDHEC Business School neatly defines the essential challenge of decumulation — but within that simple definition lies significant complexity. A range of factors is driving advisers to rethink their decumulation strategy. Top of mind is likely to be the new focus on decumulation from the Financial Conduct Authority as part of the Consumer Duty rules. However, changing financial markets, shifting retirement needs and the increasing availability of products are also proving important . In this new environment, where decumulation strategies are likely to be under increasing scrutiny and the investment parameters have changed, what does best practice look like and is it simple to achieve?
Decumulation solutions must adjust to both the prevailing investment climate and a client’s changing circumstances during retirement. Advisers must not rely on a one-size-fits-all strategy — neither the environment nor the regulator will allow it
‘There needs to be far more emphasis on not losing money as a result of retirement’
Downside risk
Any decumulation strategy needs to recognise that most people become a lot less financially resilient once in retirement. BNY Mellon Investment Management head of retirement Richard Parkin says: “While they are preparing for retirement, they can decide to work longer or to take consultancy work to mitigate any shortfall in their income. However, once they are in retirement this becomes difficult. “There needs to be far more emphasis on not losing money as a result of retirement. The pain of losing 5% is much greater than the joy of gaining 5%, which creates a different dynamic. It requires far greater emphasis on managing downside risk.” That is not to say advisers can simply hide within ‘safe’ assets. Inflation is an increasingly pressing risk to retirees’ standard of living. Although it has become easier to generate a high income as bond yields have risen, the inclusion of growth assets is vital for inflation protection. Advisers also need to manage sequencing risk — the risk created by the particular sequence in which portfolio returns are generated and when withdrawals are made. This has been especially evident in recent years. Those who went into drawdown in early 2022 were exposed to an average 16% drop in a balanced 60/40 portfolio. Although there has been a recovery in 2023, investors who withdrew significant sums will have experienced permanent losses. Many advisers are gravitating to a solution that blends some guaranteed income — to cover essential spending — with a long-term growth strategy. Argentis head of client and proposition Natalie Kempster says the firm’s approach is to use secure income sources for essential spending while keeping the remaining fund in growth assets to provide flexibility for discretionary spending. Its advisers work closely with clients to understand their expenditure requirements and to build a robust cashflow model. Kempster adds: “Reducing the requirement for a target return also takes some pressure off the asset allocation decisions. This is especially important in challenging markets, such as the ones we have seen over the past couple of years. “Fixed withdrawals are then set up from the pension fund and any other assets, which allows the client to budget effectively. The income is reviewed annually, and we regularly refer back to the cashflow model to prove sustainability and to enable clients to achieve their objectives.” Cashflow models are now commonplace, used by more than 80% of advisers. They enable the adviser to incorporate potential investment volatility and calculate capacity for loss. They can also be an important source of reassurance during difficult market conditions. Tillit chartered wealth manager Gabriella Macari agrees that the more modern approach is to focus on total return, rather than on income return or capital return in isolation. “If you have £500,000 in your portfolio and you need an annual drawdown of, say, £25,000, you need your total portfolio return for the year — net of fund fees, platform costs and advice charges — to be at least 5% to ensure this income is sustainable,” she says. “This 5% can be achieved across capital returns and income. If you want to preserve the real value of your portfolio [the £500,000], you’ll need a net return equivalent to your income need plus inflation.”
This blended approach is likely to become more popular than decumulation strategies that focus exclusively on natural income or capital growth. There needs to be a recognition that decumulation solutions must adapt to the prevailing investment environment, and that advice appropriate in one scenario may not be suitable as the environment changes. Equally, just as decumulation solutions need to adapt to the market environment, so they must accommodate a client’s changing circumstances too. Decumulation solutions need to be appropriate throughout retirement. While it is tempting to believe that every client just requires a steady income without much impairment to their capital, the range of needs in retirement is diverse. Some retirees have vast ambitions while others would rather, simply, ‘retire’. Equally, a retirees’ needs in their 60s may be fundamentally different from those in their 70s, and certainly from those in their 80s, when care costs are a greater consideration. A decumulation strategy must be sufficiently flexible. Such flexibility may be easier to achieve with an active approach rather than with a passive one. Parkin says: “It has been easy for passive managers to make money over the past decade. More recently, however, there has been more dispersion in markets and more room for active managers to maximise returns. “In retirement, people need to achieve a certain level of return with reasonable certainty. This is where active management can really make a difference.” Undoubtedly, relying on market beta to do the heavy lifting for clients is unlikely to be a successful strategy at a time when economic growth is low and markets are volatile. There is no single, ‘correct’ model for decumulation. A range of methods can be used to achieve specific goals. Advisers must not rely on a one-size-fits-all strategy — neither the environment nor the regulator will allow it. Just as advisers have built adaptable accumulation strategies to reflect a range of client needs over time, they will need to ensure their decumulation strategies are every bit as robust.
Flexibility
Q&A: Ed Harrold
Investing for retirement income is different from an accumulation strategy
Fixed income investment director, Capital Group
This is where experts such as Richard Parkin come in. He joined BNY Mellon Investment Management in early 2023 in the newly created role of head of retirement. Parkin will focus on growing the group’s position in the retirement market, and on developing its intermediary and retirement propositions. He brings a wealth of experience. He has spent five years as head of his own consultancy business, Richard Parkin Consulting, where he helped pension schemes, providers, policymakers and regulators to understand and respond to the shifts in the retirement landscape. Prior to that, he held various roles at Fidelity over 15 years. He has also worked with The Investment Association as chair of its Retirement Funds Working Group, as well as at the Association of British Insurers and with the Financial Services Compensation Scheme. Hence he has a solid understanding of all sides of retirement advice.
Wide expertise
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Uncertainty in the retirement market has increased in recent years, says Richard Parkin.This makes it even more important to examine the way decumulation strategies are built and delivered
The advent of pension freedoms changed the landscape for investment managers. Previously their role had been largely about the accumulation of wealth, before handing over to a life company to provide an annuity. But the growing popularity of drawdown has created demand for a different type of product — one adapted to the needs of decumulation. Investment managers increasingly recognise the importance of their role in this still immature market. It is a market that is becoming more complex, however. In the early years after compulsory annuitisation was withdrawn, it was possible to rely on similar strategies to those that had been used for accumulation. Although initially there were concerns over risk, markets kept rising and decumulation portfolios needed only to be reasonably well diversified and run to give retirees a good result. Equally, with interest rates on the floor, annuities offered little competition. However, both the regulatory and market environments have shifted. As part of the new Consumer Duty rules, the Financial Conduct Authority has made it clear it expects advisers to have a separation between accumulation and decumulation strategies. Investment managers recognise they are providing the right options for changing client needs while helping advisers to build robust decumulation solutions.
Role of advice
Parkin says the importance of retirement advice is increasing all the time. “With the demise of defined benefits [DB] plans, consumers are becoming more and more reliant on retirement savings,” he says. “Getting the investment decision right can have a profound effect on the quality of retirement they are able to enjoy.” There is also greater peril involved. The accumulation phase is, by its nature, flexible; people can work longer, save more, reorganise their assets. Those in retirement can’t remake any money they lose if the decumulation strategy is wrong. Parkin says this leaves them more vulnerable to difficult market conditions. Retirement advice is also very important to advisers, making up around 60% of their assets under advice. Parkin adds: “Most of all, retirement advice is really complex because it is full of uncertainty.” He believes uncertainty has increased in recent years, making it even more important to examine the way decumulation strategies are built and delivered. The market environment has shifted. Parkin points out those who went into drawdown in more recent years are having a very different experience from those who retired in the early days of pension freedoms. “Markets have dropped, across both bonds and equities, and there has been an abrupt end to a 40-year deflation cycle,” he says.
‘With the demise of DB plans, consumers are becoming more and more reliant on retirement savings’
Inflation protection
This has required a more nuanced and sophisticated approach to decumulation. It also calls for a greater awareness of inflation protection. Parkin says retirees are now demanding more from their retirement savings. “Everyone is feeling the cost-of-living crisis, even if they are wealthy,” he adds. “The recent shift in environment has made guaranteed income more attractive, including sticking money on deposit. Advisers are increasingly seeing clients who would rather take the 5%-plus return on a cash Isa over the volatility of a stock portfolio, even if it comes with inflationary risks.” Advisers have a crucial role in stressing the importance of inflation protection, with inflation likely to be structurally higher from here. Parkin says, above all, any decumulation strategy needs to recognise that investing for retirement income is different from an accumulation strategy. “The question is not, ‘How do I maximise my return?’ but more, ‘What are my objectives? What is the proper balance between risk and reward?’”
‘The question is not about how to maximise one’s return. It’s more about what one’s objectives are’
Investment changes
For Parkin, this environment should encourage advisers to place a greater emphasis on tactical asset allocation, including products with embedded flexibility that can move assets around. He adds: “Flexibility and responsiveness are very important. Portfolios need to be able to adapt to changing conditions.” Several factors emerge from that, the first being the importance of active management. Until recently, investors could choose the simplest, lowest-cost option and cling to the coat tails of market beta. Dynamic asset allocation had gone out of fashion because most assets had risen for a decade. However, during the recent crisis a static portfolio would simply have tracked the market lower, with no power to move into protective assets or dampen the falls. This is also unlikely to be a resilient strategy in future. The low-volatility environment was artificial and is now over. It will be important to allocate dynamically through the cycle, paying attention to the fortunes of individual securities. This flexibility, says Parkin, underpins BNY Mellon Investment Management’s multi-asset range, where managers do not simply assume the future will look like the past, or asset classes will have the same characteristics throughout the cycle. Equally, active management has the ability to deliver a more targeted return — through specific income, for example, or protection strategies. This might bring more certainty to a decumulation portfolio than is possible through passive strategies.
Consumer Duty
The complexity of retirement advice is also being increased by the regulatory landscape. Parkin says it is becoming clearer how the FCA will apply the Consumer Duty to this sector. He says the regulator has been explicit that its current Thematic Review of Retirement Income Advice will be an important indicator of how well advisers are implementing the new rules. The review findings are due at the end of this year and, in the meantime, firms should consider how their retirement advice proposition could be viewed by regulators, says Parkin. The new market environment may expose strategies that are no longer fit for purpose. He adds: “It’s vital this change of environment is recognised by the FCA and it understands how firms are adapting their advice approaches to accommodate this. In the context of the Consumer Duty, retirement advice is — on the whole — pretty good. However, there will be some things advisers need to look at. They have been operating in a benign environment and everyone has been happy, but this has shifted over the past 18 months.” He is hopeful advisers will arrive, finally, at a model that offers a measure of guaranteed income and downside protection, along with some upside potential from stockmarkets. This, he says, was the model initially envisaged by the regulator and is likely to be the most robust model for the long term.
Role of guaranteed income
A final consideration is the role of annuities, which — until recently — has looked unappealing. However, the interest rate environment has improved their appeal and annuity purchases have risen. Nevertheless, Parkin suggests many of the current crop of retirees already have sufficient guaranteed income, whether through the state pension or via a DB scheme. There is also the problem that all annuities are now underwritten. Parkin adds: “They may be taken out at age 60 or 65 at a relatively low rate when the buyer is in good health. But the buyer may develop health conditions in their early 70s and then have no option to change.” He says temporary annuities have become more popular as a way of managing this issue. However, it is possible this situation will change over time as retirees with DB schemes become rarer. Investment managers will need to keep developing solutions that are competitive with annuities in all market conditions. Within this shifting environment, BNY Mellon Investment Management is looking at four main ways to support advisers. The first is getting out and about, talking to them and helping them to find the best ways to structure their clients’ retirement investments. The second is to help advisers with consumer support and understanding, in light of Consumer Duty rules; the group also wants to help improve the consumer experience, though strong reporting and information sharing. The third is to create content and events that foster good practice and help advisers to understand what their peers are doing. The final area is product development, but also positioning existing products appropriately. Parkin will sit at the heart of all these means of support, helping advisers to build robust retirement strategies for the future. He believes the role of advisers is as important as ever, and they need the right tools to do the best job for clients.
BNY Mellon FutureLegacy 5 Fund
6 members (3 independent)
Income has returned to fixed income
Over 100 years of combined investment experience
46 meetings held
3 strategic asset allocation changes
For professional clients only, not suitable for retail investors. The views expressed are the contributor’s own and do not constitute investment advice.
Why the global high income opportunities strategy?
FOR PROFESSIONAL clients ONLY
Newton is a global investment management firm, founded in 1978 and owned by BNY Mellon. Our purpose is to improve people’s lives through active, thematic and engaged investment which strives to deliver attractive outcomes to our clients and helps foster a healthy and vibrant world for all.
Past results are not a guarantee of future results.
All information and opinions in this document are as at 31 December 2022 and attributed to Capital Group, unless otherwise stated. In US$ terms. High yield, EM hard currency sovereign, EM local currency sovereign and EM corporates as represented by the Bloomberg US High Yield 2% Issuer Cap Index, JPMorgan EMBI Global Index, JPMorgan GBI-EM Global Diversified Index and JPMorgan CEMBI Broad Diversified Index respectively. Yields are yield-to-worst. EM: emerging market. Source: Bloomberg
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60%
We have been managing fixed income assets for 49 years. Our distinctive investment approach, with analysts empowered to invest alongside portfolio managers, is driven by rigorous company research and a long-term perspective. Reflecting investor confidence in our fixed income capabilities, Capital Group's fixed income assets under management have grown more than 110% from 2015 to 2021.
Investing for our futures, creating a powerful legacy
Inception date: 07/02/2023
target equity allocation 60%
The investment company
AUM: £86.9Bn
Investment & stewardship policy universe median:
Fixed income SSA universe median:
50%
Fixed income corporate universe median:
62%
5/5
&
94%
4/5
88%
78%
Listed equity active fundamental incorporation universe median:
71%
Listed equity active fundamental voting universe median:
54%
The philosophy
The BNY Mellon FutureLegacy Fund is one of a range of five risk-targeted Multi-Asset portfolios that through the expertise at Newton Investment Management aim to help clients achieve their long-term goals investing for and during their retirement.
Why choose this strategy?
The BNY Mellon FutureLegacy 5 Fund is a multi-asset fund risk managed to Dynamic Planner volatility band 5, enabling advisers to recommend a solution which aims to meet the needs, risk appetite and expectations of their client, identified as part of their advice process:
Actively managed by a dedicated team at Newton to manage volatility and take advantage of timely investment opportunities, drawing on the best ideas and expertise across the firm
Global & Sustainable, the fund looks to invest globally for a fully diversified approach regardless of geography or sector, drawing on Newton’s established sustainable framework to select investments which support a lower carbon transition and a fairer society
Directly invested – providing investment flexibility to seek out opportunities to invest as well as transparency in costs and environmental, social and governance (ESG) risk reporting
the best of Newton’s Sustainable Asset Management skills
Equity
100%
Key investment risks
Objective/Performance Risk: There is no guarantee that the Fund will achieve its objectives.
Currency Risk: This Fund invests in international markets which means it is exposed to changes in currency rates which could affect the value of the Fund.
Emerging Markets Risk: Emerging Markets have additional risks due to less-developed market practices.
Sustainable Funds Risk: The Fund follows a sustainable investment approach, which may cause it to perform differently than funds that have a similar objective but which do not integrate sustainable investment criteria when selecting securities. The Fund will not engage in stock lending activities and, therefore, may forego any additional returns that may be produced through such activities.
To achieve capital growth and potential for income over the long term (5 years or more) while being managed to a pre-defined level of risk. The Fund will aim to maintain a risk profile classification of 5 from a scale of 1 (lowest) to 10 (highest) which is assessed against the risk ratings scale provided by an external third-party risk rating agency.
OBJECTIVE
This Fund is actively managed without benchmark-related constraints. The Fund uses a composite index, comprising 5% SONIA GBP, 35% BAML Global Broad Index GBP Hedged and 60% MSCI ACWI GBP NR as a point of reference (comparator) against which the ACD invites Shareholders to compare the Fund’s performance. The ACD considers the composite index to be an appropriate comparator because it includes a broad representation of the asset classes, sectors and geographical areas in which the Fund predominantly invests.
BENCHMARK
The BNY Mellon FutureLegacy 5 Fund is actively managed typically by using forward-looking expectations of volatility. In doing so, the Investment Manager uses its own internal risk model, whilst also considering external independent risk profiling methodologies. Based on a risk profile scale of 1 (lowest) to 10 (highest), this fund targets a risk profile of 5 but this is not guaranteed. This risk profile is not the same as the risk and reward category shown in the fund’s Key Investor Information Document(s). The risk profile of the fund is currently assessed against the risk ratings scale provided by Dynamic Planner, but is subject to change at the ACD’s discretion. Source: Newton, 28 February 2023. Pie charts illustrate the breakdown of equities and bonds by region/market. Source for Ratings: BNY Mellon as at 30 June 2023. Ratings are for illustrative purposes only and should not be relied upon when making an investment decision. Dynamic Planner Risk Ratings should not be used for making an investment decision and it does not constitute a recommendation or advice in the selection of a specific investment or class of investments. Dynamic Planner’s risk-profiling process is driven by rigorous analysis of the underlying asset mix of a fund, as well as considering factors such as the flexibility of the investment mandate, monthly trend analysis of the underlying asset constituents and observed performance. Once this analysis is complete, the data is calibrated to the underlying asset forecast assumptions of the Dynamic Planner model. The expected risk of the fund is then determined using a scale from 1 (lowest) to 10 (highest) which can then be aligned to client risk profiles. 1. 2.
Source: Newton as at 30 June 2023.
Source: 2021 Principles for Responsible Investment report. The rating was given by UN PRI to Newton Investment Management Limited on 18 August 2022 relating to the period of 1 January to 31 December 2020.
The value of investments can fall. Investors may not get back the amount invested. Income from investment can vary and is not guaranteed.
IMPORTANT INFORMATION
For Professional Clients only. This is a financial promotion. Please refer to the prospectus and the KIID before making any investment decisions. Go to www.bnymellonim.com. For a full list of risks applicable to this fund, please refer to the Prospectus or other offering documents.
BNY Mellon is the corporate brand of The Bank of New York Mellon Corporation and its subsidiaries. The Fund is a sub-fund of BNY Mellon Investment Funds, an open-ended investment company with variable capital (ICVC) with limited liability between sub-funds. Incorporated in England and Wales: registered number IC27. The Authorised Corporate Director (ACD) is BNY Mellon Fund Managers Limited (BNY MFM), incorporated in England and Wales: No. 1998251. Registered address: BNY Mellon Centre, 160 Queen Victoria Street, London EC4V 4LA. Authorised and regulated by the Financial Conduct Authority. Assets under management (AUM) relates to the combined assets managed by the Newton Investment Management group. From 1 September 2021, Newton group of companies includes Newton Investment Management Limited (NIM) and Newton Investment Management North America LLC (NIMNA).
Issued in the UK by BNY Mellon Investment Management EMEA Limited, BNY Mellon Centre, 160 Queen Victoria Street, London EC4V 4LA. Registered in England No. 1118580. Authorised and regulated by the Financial Conduct Authority. Document ID: 1548979. EXP: 31 December 2023. T11876 09/23.
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