140: Frontier Advisors' Charles Wu and Elie Saikaly – Launching an ICIO Business

In episode 140 of the [i3] Podcast, Conversations with Institutional Investors, we speak with Charles Wu, Director of Investment, and Elie Saikaly, Head of Liability-driven and Government Investors at Frontier Advisors about the recently launched Independent CIO service, not to be confused with outsourced CIO services. We delve into the background of establishing the new service, the backing by State Super, the potential market size and why this services is needed now. Enjoy the show! __________ Follow the Investment Innovation Institute [i3] on Linkedin Subscribe to our Newsletter Explore our library of insights from leading institutional investors at [i3] Insights  __________ Frontier Advisors: ICIO Podcast – Overview [00:15] Introduction – Wouter Klijn frames the episode around Independent CIO (ICIO) services vs. outsourced CIO (OCIO), with guests Charles Wu (Director of Investment, Frontier Advisors, formerly State Super) and Elie Saikaly (Head of Liability-driven and Government Investors, Frontier Advisors). [02:00–06:37] Origins of the deal – Charles explains that State Super's investment team joined Frontier in a "win-win-win" arrangement: State Super de-risks by handing over portfolio management while retaining continuity; Frontier gains institutional-grade implementation capability and people. He details why State Super's situation is complex – a 100+ year-old scheme in decumulation, with average actuarial cash outflows around 7 per cent annually, creating major liquidity forecasting demands. [06:45–10:34] Frontier's motivation and custody issues – Elie discusses Frontier's 31-year history adapting to client needs, and why smaller asset owners struggle with key-person risk, operational risk, and custody access (partly due to the closure of NAB Custody Services), creating an opening for Frontier's expanded service. [10:34–13:35] Defining ICIO vs OCIO – Charlie distinguishes ICIO by its independence and non-conflicted, tailored approach (no predefined product suite), contrasted with more standardized outsourced models. Governance benefits like stock lending and balance sheet management are passed to clients. [13:35–16:43] Service integration and structure – Elie describes the combined offering (strategy through implementation) and lessons learned from merging Charlie's tactical asset allocation process with Frontier's advisory teams. They discuss the managed discretionary account structure and the governance partnership with Ironbark, including an investment management committee. [17:19–20:09] Target market – Referencing KPMG research showing a fragmented market (no player over ~10 per cent share), Elie outlines target clients: insurers, universities, charities, endowments, small-to-medium super funds, and family offices – emphasizing deeper transparency on reporting and costs as a differentiator. [20:09–22:45] Japan expansion – Charlie discusses a recent trip to Japan, Frontier's local office (established ~4 years ago) and partnership with Mitsubishi UFJ Asset Management and interest in partnership models rather than full portfolio outsourcing. Expansion plans remain APAC-focused rather than global. [22:45–24:35] Current status – State Super is confirmed as the first client, with regulatory steps nearly complete and significant inbound interest from prospects citing key-person risk, operational risk, and performance/custody concerns. [24:35–27:26] Scope of services – Charlie explains services extend beyond portfolio construction to strategic guidance (e.g., specialist help building hedge fund or real estate platforms), tailored case-by-case to each client's governance maturity. [27:26–28:11] AI capabilities – Charlie confirms new clients can request an AI roadmap/governance framework, drawing on State Super's earlier AI work. [28:11–29:23] Sydney office – Charlie discusses the new Sydney office (with room to grow) supporting Sydney-based clients, plus light banter about Melbourne/Sydney rivalry. [29:23–31:17] Next steps – Elie outlines finalizing regulatory approval, change management efforts (a December immersion day, training sessions, governance/risk work groups) ahead of official launch. [31:17–33:25] Insurance sector potential – Elie notes insurers are a strong candidate client base, particularly those without the resources or desire to fully in-source investment management risk. [33:25–35:00] Addressing suboptimal portfolios – Charlie acknowledges it's a widespread issue that off-the-shelf products don't suit varying risk appetites, and notes Frontier is investing in internal technology to balance scalability with tailored service. Full Transcript of Episode 140: Wouter Klijn  00:15 Welcome to the [i3] Podcast. Today, we're going to talk about Independent CIO services as opposed to the outsourced CIO services, and we'll go into this distinction later. But I'm here today with Charlie Wu, who is the Director of Investment for Frontier Advisors. So Charlie leads the former State Super investment team that joined Frontier Advisors at the end of last year, and established the ICIO office. We also have Elie Saikaly, who is Head of Liability-driven and Government Investors at Frontier Advisors. Charlie, Elie, welcome to the show.  Charles Wu  01:57 Happy to be here.  Elie Saikaly  01:58 Great to be here.  Wouter Klijn  02:00 Excellent. So, Charlie, maybe we start with you. From what I understand, the conversation about this started a few years ago, and and we're partly tied to sort of you know projections about the future of State Super. State Super is in runoff. Obviously, over time, this this will pose some issues. Can you walk us a little bit through why State Super was interested in this partnership?  Charles Wu  02:24 Yeah, sure. Well, maybe let me put that in a bit of the context. I think if you look at State Super, it is not unusual. State Super actually has a really long history of coming up with innovative structure. So all the way back in the 1980s 1990s we're talking about Stay Super being one of the in in house investors. The funds manager like DB Reeve and Axiom is all coming out from State Super. So this is, I guess, the most recent iterations of the the innovation that has been in STC's portfolios for a very long time. And just to again set that context correct, so the way to look at this is State Super effectively has exchanged the investment team and I to Frontier or an equity stake. Subsequently, hire Frontier to manage Stay Super's DC portfolio, and this is really a rare win-win-win situation. And what I mean by that is, in many ways, State Super wins by de-risking the portfolio management activity by appointing Frontier, and you get that continuity of services. Frontier wins because this acquisition brings on board an institutional grade implementation and operational capability, and the people for the people that's involved is actually really the core component that the discussion that we're talking about. We win because we get we now get to expose either in my term horizontally, like the breadth, such as like me being exposed to different client segments, or vertically going all the way from the formulation of investment strategy down to the implementation, and those are all group potential. So the outcome of this is, like you said, ICIO offers that provides a non-conflicted service offering. There's a strong synergy between the two different investment teams, which we're in the part of bringing them together and the growth potential for everybody.  Wouter Klijn  04:25 So, at the announcement of this transaction, I spoke with John Livanas, the CEO of State Super, and he told me a little bit about the importance of sort of retaining access to adequate resources from an investment perspective, and he partly related this back to the fact that State Super is in runoff, but it has quite a complex sort of structure in place that you know you can't just have like one or two guys looking after it and take care of it until it's completely run off. Why is that? What what's sort of the complication there?  Charles Wu  04:59 Yeah. So for most people that don't know, State Super, State Super is one of the oldest schemes in New South Wales state government. I think the inception. I still use the word "we" every now and then. Like you know, the inception for State Super is back in the early 1900s and so it's more than 100 years old. The scheme was closed in the later end of the 1990s, and so what that created is a very aged member demographics. It has a very complex scheme dynamic. We're talking about various conditions, including reverse due spouse and so on and so forth. But the key thing from an investment perspective is it created a portfolio that is the in decumulation mode, and I'm not just talking about you know one or 2 per cent that you that that's in line with the the state the spending policy of an endowment. We're talking about on average, it's a 7 per cent actuarial projected cash outflow every year, and depends on where you draw that line because, like I said, we have age member demographics, so depends on where you draw that line. That instantaneous liquidity shock can be quite high, and so it's not a simple. By no, I mean it's not a simple investment, but in this particular case, because it is unique, we have to pay a lot more attention in terms of ensuring that the liquidity there, like we we do forecasts not just the member in our flow, so to speak. We're also talking about how do we ensure that we have enough liquidity to pay the member benefit payments. We have sufficient liquidity to meet the investment drawdown, so on and so forth. And all of those isn't as straightforward.  Wouter Klijn  06:37 Yeah, yeah, for sure. So Elie, State Super obviously had some incentive to look at this deal. What's in it for Frontier?  Elie Saikaly  06:45 Yeah, great question, Wouter. So, Frontier and State Super have known each other for a very long time. There's a lot of comfort between the two organisations, so that's important to to bear in mind here. Also, as our clients have evolved, our services have evolved with them, and in Frontier's 30-one year history, we'd like to think we've adapted to the changing needs of that client base. And as you'll also know, our clients range from large, complex super funds all the way through to much smaller asset owners such as charities and foundations. And over the course of that journey, Frontier has wanted to be alongside those asset owners who are looking for services outside of just advice, and in an environment where it is becoming more challenging to invest portfolios, and the burden of investing those portfolios from a compliance and regulatory point of view is ever increasing. Frontier understands better than most that those those demands on those organisations is is becoming a challenge for them, and that if Frontier can step in and provide additional services over and above advice, then we remain a very relevant partner for those organisations, and I'll give you some examples which are relevant to us today, and also based on market feedback, we we understand that key person risk is a challenge for a number of smaller asset owners that are struggling with retaining an investment team. That is particularly relevant outside of the large capital cities like Melbourne and Sydney.  Wouter Klijn  08:25 Yeah,  Elie Saikaly  08:26 the operational risk burden is also one that is challenging for organisations, and that sits alongside the custody challenge, where smaller asset owners are struggling to retain custody, and we observe these trends in the industry. And Frontier wants to be a consultant that sits alongside our clients and helps them solve those challenges. Yeah. So all in all, there's a there's a range of events that have taken place in the industry in Australia, where Frontier feels like it can provide a solution, and bringing the best of what we do today in the advice space, and what Charlie and his team does today in the portfolio management implementation space, gives us an interesting proposition for the industry.  Wouter Klijn  09:20 So you briefly mentioned there custody as well, and from what I understand is that it was important to get support from a large custodian to sort of get this deal offline. Why is that so important? Do they just not want to deal with the smaller clients anymore?  Elie Saikaly  09:36 The challenge that that we observe, Wouter, is that smaller asset owners, and particularly outside the superannuation space, don't offer those larger global custodians scale, and also are going to struggle offering those services at a reasonable price, given the sizes of those portfolios, and. This is not just an Australian phenomenon; it's one that's also happening globally, but one that really was seeded by the closure of NCS (NAB Custody Services) a number of years ago, and that had a cascading effect on the rest of the industry. And as some of the global firms are looking for much larger minimum sizes, it does leave a gap in the market for asset owners who want to retain an advisor on an independent basis, but also are struggling with the back end of their investment programs.  Wouter Klijn  10:34 We got a little bit ahead of ourselves, but you know, I opened up this podcast with the comment that independent CIO is not the same as outsourced CIO services. Can you tell me a little bit about you know the difference and why it's important to make that distinction? Yeah, maybe Charlie, maybe you can give that a go. Do we need another acronym in the industry?  Charles Wu  10:55 We're always short of acronyms, right?  Wouter Klijn  10:56 Exactly.  Charles Wu  10:57 Yeah, like this. This topic is actually really interesting because before this, I'm probably quite oblivious in terms of the different operating model that they are to provide such a service, and we've just done a trip, really leveraging our connections to assess the different operating model across different outsourced CIO service provider. So let me touch on that, and then we'll come back to the ICIL, and it's not just a play on words. There are there really many different models that we're talking about, and they really range from your standardise everything for all the way to the other end of the spectrum that would be spoke everything. And this shouldn't be a surprise, but you really should look at all these operating model from the lens of organisational strength, the governance strength, the investment sophistication, and so on and so forth. And so this is how we look at that operating model and pick what is right for Frontier. Now to bring it back to what Frontier has decided to offer to our clients is the whole independence, and that's the I in the ICIL. We're not just talking about our source. We're not talking about you giving us the whole lots of the portfolio. We're talking about independent, unconflicted. We don't we we don't have a predefined product to put you into our product suite. We provide tailor-made solution flexibility and that tail to clients, and that's quite important. And Elie, by all means, jump in as you see fit. And this is important because as we see the increasing, I guess, requirements from regulatories and not regulatory, but client preferences such as responsible investment need. We see all those things are just if you provide a predefined product structure, it's just not going to be enough. And in addition to that, we're also talking about governance, governance and organisational strength. So we also bring on board the strength of so for example managing the balance sheet, stake lending. We do believe that those benefits are the one that we should pass on to the clients and not retain within us. And so that again is where the term independent independence come in.  Elie Saikaly  13:12 Yeah, yeah, that's right. And in addition to that, it's clear from the clients that we talk to and other asset owners in the industry that the the independence angle is critical for them, and in some cases, they feel they don't have a choice in the in the offering that's out there in the market today. And Frontier is determined to remain the leading independent advisor.  Wouter Klijn  13:35 So, can you tell me a little bit, Elie, about where they sit within the existing services? Because I remember I spoke to Andrew Paulson a while ago and he said we used to have like 60 odd deals that we were looking at and we couldn't really implement it because that was not really part of our service offering and now with this ICIO office we should be able to do that.  Elie Saikaly  13:57 Yeah, absolutely. The reality here is that the team that comes across to Frontier is complementary to what we do today, and so that allows us to provide the full set of services within an investment program that asset owners may require, and that starts with policy and investment strategy advice all the way through to portfolio construction, it might be DAA or TAA manager selection, and then operational efficiency and excellence to really drive better outcomes for those portfolios. So even the coming together of two teams has taught us a lot.  Wouter Klijn  14:40 Can you give an example of one of those lessons?  Elie Saikaly  14:43 Yeah, absolutely. So, for example, Charlie's team runs a process around asset allocation that might be more tactical than what some of our clients might be used to, and that informs us. The consulting teams of the opportunities that potentially lie in front of us in terms of providing advice from a strategic perspective, a dynamic perspective, and also a more tactical perspective. So there's a lot of work that's commenced and also continues to determine how best we can bring all these capabilities together, and most importantly, what are the needs of asset owners going forward? What would they expect from an organisation like Frontier, and what adds true value at the end of the day? And that's that's really important to us, and that's a process we're still going through as we speak,  Wouter Klijn  15:41 yeah, and I think as part of the setup, you have explored sort of the model of the managed discretionary account structure. I believe there's a partnership with Ironbark as a management around that. Why have you chosen that structure?  Elie Saikaly  15:54 Well, that structure, Wouter, gives us the flexibility to tailor portfolios for clients. It gives us the framework and infrastructure to implement the advice that we provide those clients, and working with a partner like Ironbart gives us great breadth. It gives us again complementary skill sets, but in essence oversees the delivery of the service and aims to ensure that what clients receive from us and the outcomes clients expect is exactly what they they have signed up for. And I embark so far have been a great partner, and they've supported our our ICIO capability so far. And we look forward to how that partnership grows in the future,  Charles Wu  16:43 And to this last point on the partners Ironbark being the partner, just to be very clear, like you know, take a more tangible example, like on the governance structures, we set up this investment management committee which oversees the portfolio activities, and Ironbark representative will be sitting on that committee to give that additional governance support, and they also holding us account very accountable to the investment due diligence and operational due diligence as we do something. And all of those should be taken as a strengthening of the governance requirement in order to provide this this service offering.  Wouter Klijn  17:19 Yeah. So let's talk a little bit about the potential market. I understand that Frontier has done some work with KPGM on on what potential the market is for independent CIO services. I think one of the learnings from that exercise was it's a very fragmented market. There's no single player with more than sort of 10 per cent of of that market, can you describe a little bit in who you see as the key sort of client for for this service? Is it family offices? Is it private wealth? Charities? Who are you targeting?  Elie Saikaly  17:56 As it stands today, the the market is fragmented. You are correct. There is also wide scope for opportunity, not just in Australia, but also in New Zealand, in the Pacific, and as we expand our reach into the region and utilise our presence in Japan, we would expect that those conversations will also take place outside of the domestic market, but in essence, the the clients who have shown the most interest in this service are those that are looking for an organisation like Frontier to manage their investment programme, and they could be insurers, they could be universities, charities, endowments, they could be small to medium super funds, all the way through to private wealth and family offices. The types of asset owners you would expect that would use a consultant's capability. However, the reality here is that given that those asset owners still need to retain responsibility for investment policy and strategy, that those asset owners that we would look to service and would be comfortable with a partner like Frontier taking care of manager selection, portfolio construction, rebalancing portfolios, helping them around activities such as proxy voting, building mandates to account for RI exclusions, for example, and that's the focus for us: is what are the activities and needs of those asset owners, regardless of who they are, and whether Frontier can provide the support that those asset owners expect. And one of the key points of difference for us here is that we are offering a much deeper level of transparency than the industry is used to, and that's very much around reporting. It's very much around costs, and it's very much around what's in the portfolio driving returns, driving risk to those assets. Have a reasonable amount, if if not a sufficient amount of comfort around the activities in those investment programmes.  Wouter Klijn  20:09 Charlie, I just mentioned Japan. I think you've been reasonably on a trip to Japan. Did you go there for the for these services, or did you go for investment research?  Charles Wu  20:20 Well, well, how did you know that?   Wouter Klijn  20:22 I'm well informed.  Charles Wu  20:25 I was definitely there to to see some prospects, and I guess Japan is one of those. If you speak to any funds management business person, they'll tell you that Japan is a market that will take easily four or five years to crack, and I think we so Frontier established established a Japan office about four years ago, and and we're definitely working closely with our strategic partner, Mitsubishi UFJ Asset Management. We're growing the revenue there steady and stable, and we're seeing a bit of the crack. And so this trip in many ways is to bring the ICIO capability to to the prospect to see if they're interested, and and and ICIO is one of those very interesting, I guess, service in the sense that we're not talking about just coming in to do the whole lots of the portfolio. Like after dealing with some of the prospects in Japan, we also find that sometimes they just want us to come in and manage a sleeve of the portfolio, and that's easily something that the team can do. So yeah, no, we're seeing opportunity there.  Wouter Klijn  21:33 So a sleeve of the portfolio is that sort of like the Texas Teachers' model, like the partnership model.  Charles Wu  21:38 It is a partnership model, and normally, as you can probably imagine, that in Japan, a lot some of the clients I can't say a lot of clients, some of the clients, some of the prospect, they like our research in the real asset segment, for example. And so the natural question there is, well, I can manage my own bonds and equities portfolios, but you have a lot more experience in real asset,  Wouter Klijn  22:01 so Japan is a natural second sort of market. Is it the intention to make this sort of a global service? Are you looking at other countries?  Charles Wu  22:11 At this stage? No, primarily is still in Japan, Japan and domestic domestically in Australia. Now I can say in due course that's probably more an APAC initiative rather than a global initiative. At the end of the day, there's a very very well developed US markets and very well developed European markets already. Yeah, this initiative was announced last year. I think there were some regulatory hoops to jump through before you sort of could open for business, how's it going? Do you have any clients?  Elie Saikaly  22:45 Absolutely, our first client is State Super New South Wales, and and so the focus the focus at the moment is completing the project and making sure we jump those hurdles, and that's imminent. And then it is about ensuring that those existing clients and prospective clients understand the offering. So we have had significant amount of inbound interest in this service, particularly around solving the challenges that I mentioned around key person risk, operational risk, performance reporting, custody. They are the the real drivers of concern for asset owners interested in a service like this, and we cannot underestimate the challenges around performance in today's market, particularly given the outcomes of active management, in particular asset classes, the desire for asset owners to look into private markets as well and access opportunities offshore. So there's some significant drivers ensuring that asset owners are revisiting their current arrangements, and that Frontier has benefited from those inbound queries. And we we would expect to be in a very good position to bring on additional clients in the imminent future, and that's going to have cascading effects on not only State Super but our whole business in terms of building scale, making sure that our clients benefit from that scale, but but also giving our staff different career paths, making our work more interesting, and also connecting us much closer to the end portfolio or the end client. And I think there's real value in that type of work. And we look forward to the next steps of of this service.  Wouter Klijn  24:35 And will the services focus predominantly on sort of the portfolio construction piece, asset allocation piece, or are you also looking at more strategic type of questions like, should an organisation do TPA, or maybe these organisations are too small for it, but it's a lively debate. Charlie, do you have any views on that?  Charles Wu  24:56 Yeah, yeah. I was thinking where TPA is going. Come up in this conversation. No, no. We can talk about TPA in a in a slightly separate context. But in this particular case, I think it has a lot more to do with what we can offer. And if you look at this in from a business perspective, we're talking about a slightly smaller asset owners and in a challenging environment, not just regulatory, but also the market dynamic that is going. So naturally, you cannot you can see that, for example, if an organisation that wants to establish hedge fund platforms, hedge fund portfolios, or real estate portfolio, the specialist services that need in order to build out that portfolio is quite meaningful, and not everybody has the the budget to develop their internal team, let alone talking about data modelling, so on and so forth. And so those are things where we stepped in in terms of helping them to develop their services. And for some, that is of different path maturity of the organisational maturity, we also we can also be there to help them to guide them through the setting of the policy. If if they want to grow the internal team, then we're there to help them to grow that internal team. They all those are all on the table for people to consider. And I think as as we kind of heading into a more complex environment, every organisation. every smaller SEO owner has the right to to get that type of services, and that's why we're here to to develop. In terms of more just portfolio construction, now I do think we we offer a lot more than just portfolio construction because at the end of the day, and from my perspective, while there is an end-to-end investment process, and we can range from let's call that the SAA down to put the dollars on on the on the road, so to speak, every organisational has a different organisational strength, has a very different governance setup, and some are better and well positioned to play all parts of them. Some are less so. So it's not as straightforward to say, "Yep, let's just go do a TPA or go do a SAI or let's focus on manager selections. It all it's it's all quite independent case by case, in my opinion, and that's something that we can bring as a holistic assessment of that process, and then we focus on the where we can have value.  Wouter Klijn  27:26 So, Charlie, we we've spoken in the past a little bit about artificial intelligence, and you've done quite a bit with that at State Super. Are you bringing some of those learnings now to new clients coming on board? Can they ask for a AI roadmap for their organisation.  Charles Wu  27:43 Ah, they definitely can. They can ask AI roadmap. They can ask AI governance. But what are they like? We started this conversation eight years ago, and back then no one was doing AI or machine learning. Nowadays, if you don't do, if you don't use AI, you're falling behind. So I think the world is in a slightly different place, as you you will know that we're always open to compare nodes and helping people. We're definitely bringing our capability to frontier and assist the clients.  Wouter Klijn  28:11 Yeah, yeah, Charlie, you didn't have to go all the way to Melbourne to to make this work. There's now a Sydney office. What are the plans for that office? And I don't know if you can answer this as well. I understand there's a few spare seats as well, so you can have some growth there in the office.  Charles Wu  28:27 Yeah, yeah. Well, let's start with the senior office. We definitely have few spare seats, and we will grow the the senior office, senior presence. Sydney is really important for for us for Frontier in many ways, we do have many clients that is Sydney based, and so instead of flying everybody from Melbourne to Sydney, which we still do, but now that they have a permanent location, where say Ela, when he comes to Sydney, there's an open arm, a nice cup of tea, you know, being made ready for him to to step in, and he has an office to work on, so all that is good. Now that being said, we still like to maintain like a you know let's let's call that friendly rivalry between our Sydney and Melbourne office.  Elie Saikaly  29:10 I mean, the reality is, Charlie, that that AFL is the permanent football code, so there's probably no argument there. And I'll let you have the benefit of better weather as well, being in Sydney.  Charles Wu  29:21 No comment on that one.  Wouter Klijn  29:23 Fair enough. So, what's what's ahead in the next couple of months? What's on your agenda? Do you need to, you know, are you developing more portfolios that you prepare for future clients, or what's going on?  Elie Saikaly  29:36 We are essentially finalising the regulatory process, and we are not far away from official launch, which which we're really excited about. In the meantime, we are ensuring that we continue with our change management programme, making sure our whole team, our whole business, is on the journey with us and understands how this service fits in with. What Frontier has historically provided to clients, and we've held a number of company-wide initiatives and activities to make that happen. So in December we held an immersion day where everyone joined us in the Melbourne office, and there was a lot of rivalry between Melbourne and Sydney. But at the end of the day, we all came together, and and it was it was a very it was a very energising event for the whole organisation, and we've conducted a number of training sessions across the business around education, and and under and and getting together a real understanding of what this service means and how we deliver that service into the future, as well as a number of work groups which have sought to make some important strategic decisions around our governance framework, as Charlie mentioned earlier, our risk framework, ensuring that our service remains independent. We offer the transparency that asset owners are looking for as well. So there's there's a lot to be done, and and we've made a lot of progress so far. But we are really looking forward to to the official launch of this service for client two and beyond.  Wouter Klijn  31:17 Yeah. Now, Elie, you've built up quite a practice amongst the insurance companies for for Frontier and your title. Are they also potential clients for this service? Is that suitable for an insurance environment?  Elie Saikaly  31:34 Absolutely, it is. There are a number of insurers who have internal teams with fantastic capability and have a long history of adding value for shareholders and policyholders. I'd imagine those insurers will continue to do that internally, and run their own investment programmes. But there is a significant number of insurers who are looking for support around managing an investment programme, and really that comes down to the fact that an insurance company, just like a university and just like other asset owners, have a core business to run. And typically, managing the investment portfolio is not part of their core business. It could be a secondary or tertiary activity, and they may not want to in-source some of the risks that we spoke about earlier. It could be operational risk, could be key personal risk, and so Frontier is in a good position to provide those services. And it's experience working with the boards of insurance companies and its stakeholders that gives it an understanding of the the solutions that they are looking for and the problems that we have identified or the challenges that we have identified that are all part of this service and and essentially a part of our value proposition.  Wouter Klijn  32:59 I think when I was speaking to Andrew last year. He sort of indicated that he's seen some smaller clients, not frontier clients, but people out in the market with portfolios that use off-the-shelf products, where he thought, well, these portfolios are not as well run as they could be. Is that sort of a widespread problem, or how do you think about that? Because that's a potential client base, I suppose.  Charles Wu  33:25 Yeah, sure. It is a widespread problem, and when we're looking at the portfolio, and this comes back to well, again, how do we how do we ensure that we do the right thing by the clients and by providing that flexibility? So again, you can probably get the sense from the way I talk. I come back to a lot about the organisational risk appetites. Like they all have different things. This this is this is not standardised. While this may not be their day job, but I'm pretty sure that they have different type of risk appetite for different company, be insurance or charities. They have they in different parts of their potentially their journey as as they establish their different sophistication, different level of commitments. Then all of those triggers one way or the other about how you can manage that portfolio for more, I guess, sophisticated, higher risk appetite clients, the ability to withhold drawdown is would be a lot larger than you know someone that just started this journey, and so by just applying the same type of portfolio to every single client in that, it just doesn't make a lot of sense to me. Now I'm I'm not going to shy away from saying that. Yes, we do need to address the the problem between scalability and efficiencies, and I'm very aware of that. And that's why we're spending a lot of time to develop internal technology to enable how we can approach this problem in a more, I guess, disciplined and consistent manner.  Wouter Klijn  35:00 Fair enough. All right, excellent. Well, thank you very much for that. Thanks, Charlie, and thanks, Elie, for this conversation and for making the time.  Charles Wu  35:08 Thank you. Appreciate that.  Elie Saikaly  35:09 My pleasure.