Getting suitability right is a constant challenge for most wealth management and financial planning firms. It can be a struggle to obtain and maintain quality, up-to-date client information, make sure portfolios are properly aligned to the client’s mandate or that risk profiling processes and discussions are adequate.
There are numerous pitfalls when it comes to suitability. Issues include using professional judgement to assess capacity for loss, rather than relying on clients’ self-assessment, or focusing client file reviews on whether suitable outcomes are achieved, rather than on whether the process has been followed. It is also essential to embed a suitability culture throughout the front-office and encourage front office management to take ownership of suitability.
We’re experts in suitability
We’ve been helping clients with suitability for many years, helping them to keep pace with the developing landscape and stay out of trouble with the FCA. The team’s experience is drawn from in-house compliance roles with wealth managers and financial advice networks, consultancy roles at the big four and working on wealth management projects at the regulator.
Suitability health checks
Because we work with a wide variety of firms in this area, we know what good looks like, what the FCA would expect to see and how your performance would be judged in that context.
Back book reviews
We can undertake file review exercises of any size – from ten files to 500 – with formal reporting. We are on the FCA’s section 166 panel for carrying out conduct of business reviews and have tried and tested methodologies to deliver consistent, outcomes-focussed results.
Suitability control framework
We will take a deep dive into your oversight and monitoring arrangements, assessing how suitability fits within your three lines of defence model.
Training of IMs/QA/file checking teams
We’re happy to train all levels of staff from the Board down or help your file checking teams to focus on evidencing suitable outcomes, rather than clouding the picture by mixing up suitability with ‘process-checking’. We can offer bespoke solutions targeted at focus points of your choosing; or help to shift the culture of the front-office to a more suitability-centric approach.
Preparing for an FCA visit
If you’ve got an impending FCA visit, we can help you plan for it; carrying out mock interviews and role plays to ensure you demonstrate best practice throughout the organisation.
Sitting with your client-facing staff, we can walk-through the end-to-end client take-on process to understand how they put your policies and procedures into practice, how they gather the right client information and get a feel for the types of conversations they’re having with prospects and clients.
Small focused file reviews
We can take a small sample of client files and review them with a particular focus such as capacity for loss, client vulnerability or portfolio content.
This isn’t an exhaustive list – whatever your suitability issue, we can help. And that includes offering one of the team to you on a secondment basis.