Keeping suitability on track for a large investment manager
The first phase of this project involved Bovill conducting an independent review of suitability across a large wealth management business. The review recommended that the firm undertake a series of actions to bring their client take-on and suitability processes up to date and compliant with current and near future FCA expectations.
We’ve been meeting with the board-level project sponsor and compliance officer on a regular basis throughout the year. Before each meeting we are given various documents for review. We then use our sessions to discuss current topics and give our sense for whether we believe the firm is on track with its suitability project. Together with the client, we look at whether the various workstreams and corresponding outputs are likely to produce an end result that will enable the firm to demonstrate current and ongoing compliance with its suitability obligations.
Bovill have not been project managing on behalf of the firm, nor have we been directly involved in the day-to-day activities of the workstreams. We have been used as a sounding board – and on an occasional basis – specifically where crucial decisions are being made within the project. Our advice and recommendations have been fed back into the appropriate project workstream for consideration and, more often than not, implementation.
After each meeting, we summarise our advice by way of a letter to the firm which succinctly gives our views in the context of the discussions that took place.
This firm has been able to drive their suitability project from within, crucially ensuring that ownership remains with the business. There will be no long term dependency on Bovill once the project outputs have been implemented.
The client also has an audit trail of what they have discussed with us. This means it can show evidence of decisions made in discussion with a respected third party adviser who has worked with similar firms on similar projects.