Who Owns Investment Product Marketing?

From product availability to investor reach: how the growth of ETFs and online distribution is prompting the asset management industry to rethink demand generation, cost allocation, and product governance responsibilities.

Between “Available to Buy” and “Reaching Investors”

On August 28, 2026, the JAMP Group announced an expansion of marketing support for asset managers through a collaboration between JAMP Financial Solutions Co., Ltd. and Green Monster Inc., a company with expertise in digital communication in financial services and experiential investment-learning apps for retail investors. The initiative supports investor communication and web marketing after investment trusts, ETFs, and other investment products have been launched or listed. This certainly expands the range of support available to asset managers. But behind it lies a more fundamental question: whose job is it to market an investment product?

ETFs provide a useful way to think about this question. Once an ETF is listed on an exchange, investors can generally buy and sell it through a securities account much as they would a stock. That distribution structure differs significantly from the traditional model for publicly offered mutual funds in Japan, where a distributor adds the fund to its product lineup and sales representatives explain or recommend it to customers.

Yet making a product available to buy is not the same as making investors aware that it exists or helping them understand what it is for. Market makers can support tradability, but awareness and understanding do not arise automatically. This is particularly important for active, thematic, and strategy-based ETFs. Investors may need to understand not only what the ETF invests in, but also what role it can play in a portfolio and under what market conditions. The Tokyo Stock Exchange’s ETF market-making scheme is fundamentally designed to improve the trading environment and liquidity through continuous quoting. Product awareness is a different function.

Demand Generation Was Embedded in Distribution

Under the traditional model for publicly offered investment trusts in Japan, the asset manager created the product, a distributor adopted it, sales representatives explained it to customers, and the distributor continued to support customers after purchase. Product awareness, customer proposals, and product explanations were therefore largely embedded within the distribution process. Sales commissions and the distributor’s share of the fund’s ongoing management fee formed part of the economic structure supporting those distribution and customer-service activities.

With ETFs, that integration is much weaker. An exchange and securities firms may provide the places and accounts through which an ETF can be bought, but no one automatically assumes responsibility for making investors aware of each individual product or helping them understand it. What ETFs unbundle is not necessarily the distributor itself, but many of the functions that were previously embedded in the distributor’s sales process: helping investors discover a product, understand it, and ultimately include it among the choices they consider.

When I use the term “demand generation” here, I do not mean individual solicitation. I mean the functions that increase awareness, understanding, and comparability so that investors can decide for themselves whether a product belongs in their consideration set.

And this change is not limited to ETFs. As investors increasingly search for and compare publicly offered investment trusts themselves, models that depend primarily on active solicitation by sales representatives may become relatively less dominant. Online securities firms also play a role in information distribution and demand generation through product pages, special features, rankings, and other content. But as the number of available products increases, the distance between being “on the shelf” and actually entering an investor’s consideration set becomes wider.

Who Pays for Demand Generation?

It is easy to say that asset managers should strengthen their own marketing. But content production, websites, video, social media, advertising, and media relations all require people and money. If the sales incentives of traditional distributors become weaker while the underlying demand-generation function remains necessary, who should bear its cost?

The issue is particularly acute for ETFs because fee competition tends to be intense. Raising a fund’s trust fee to recover marketing costs could undermine the product’s competitiveness. On the other hand, if the asset manager absorbs all of those costs as fixed expenses, the burden can be substantial until the product reaches sufficient scale. Large firms with established brands and distribution networks and emerging, specialist, or overseas asset managers do not have the same capacity to bear those costs.

This is therefore not simply a question of advertising. It is a business-model question about where to relocate both the demand-generation functions that used to sit inside distribution and the costs associated with them. If the objective is to create a market in which a diverse range of investment strategies can participate, there may be value in structures that allow asset managers to access the functions they need without building large sales and marketing organizations of their own.

Marketing, of course, cannot substitute for the investment merits or competitiveness of the product itself. These functions only make sense when there is a sound product proposition to communicate in the first place.

Separating Marketing Execution from Business Ownership

There is another distinction that matters here. The question of who executes the marketing function is not the same as the question of who bears primary responsibility for growing the product business.

As a provider of white-label infrastructure to multiple asset managers, the JAMP Group does not take primary responsibility for demand generation for individual client products or fund their promotional activities from a common platform P&L. Doing so would raise questions about how much the platform should invest in promoting one client’s product versus another, as well as how those costs should be allocated fairly among users. This is not to suggest that there is only one correct model for a white-label business. Rather, it reflects the allocation of functions we have chosen in order to maintain our neutrality as a platform provider.

At the same time, once JAMP Fund Management Co., Ltd. serves as the investment trust management company for a product, its responsibility does not end when the product is launched. It continues to have responsibilities relating to ongoing information about investment performance and risks, product governance, disclosure, and the accuracy of product information. Those responsibilities are distinct from setting asset-growth targets, making marketing investments, and taking primary business responsibility for growing the product.

In our white-label model, we generally view the asset manager using the service—the party leading the product strategy, target-investor definition, and business plan, and holding the primary economic interest in the growth of that product business—as the product’s business owner. At least under our model, it is therefore natural for the marketing and growth investment required for an individual product should, in principle, sit within that business owner’s P&L.

JAMP Fund Management cannot outsource or otherwise shed the regulated responsibilities it bears as the investment trust management company. Business ownership and regulated product responsibility need to be distinguished rather than blurred together.

Execution Can Be Outsourced; Learning Cannot

The collaboration with Green Monster is one attempt to put this division of roles into practice. The asset manager leads product strategy and business growth. Within the JAMP Group, JAMP Fund Management provides the fund structuring and operating platform through its white-label services, while JAMP Financial Solutions supports the coordination of investor communication and marketing activities, drawing on Green Monster’s execution expertise.

But even when execution is outsourced, the learning generated through contact with investors should not be outsourced with it. What investors understand, what fails to resonate, what questions repeatedly arise, and which types of investors see a need for the product are all information that should flow back into product strategy and business decisions.

The Next Competitive Frontier

As investors increasingly search, compare, and choose investment products for themselves, where the functions of product discovery and investor understanding sit within the value chain will continue to evolve.

The next phase of competition in asset management may therefore be shaped not only by investment performance and fees, but also by how effectively firms combine the right functions with a sustainable economic model, clear allocation of responsibilities, and feedback loops that bring investor learning back into product strategy.

Author: Keiichi Ohara, President & CEO, JAMP Corporation
About This Article
This article is an adapted English edition of JAMP Perspective No. 348, originally written in Japanese by Keiichi Ohara and distributed on september 2. It has been edited and supplemented where necessary to make the discussion and its Japan-specific context clearer to readers outside Japan. It is therefore not a direct translation of the original Japanese newsletter.

This article is provided for informational purposes only and does not constitute investment advice or a recommendation regarding any financial product.