Project Overview
A UK FCA-authorised boutique asset manager with £850M AUM managing 280 private client portfolios needed to rep...
Technology Stack
Compliance & Standards
The Challenge
A UK FCA-authorised boutique asset manager with £850M AUM managing 280 private client portfolios needed to replace their manual Excel-based portfolio management with a digital wealth management platform. FCA COBS 9A (suitability assessment for retail clients), FCA Consumer Duty, MiFID II/UK MiFIR transaction reporting, personalised client reporting, and HMRC tax reporting were mandatory requirements. Budget: £120,000.
Our Approach
COBS 9A
suitability assessment must consider client's knowledge and experience, financial situation, and investment objectives.
Digital suitability questionnaire
28 questions covering all COBS 9A dimensions.
Risk profiling
5-band risk profile (Cautious/Conservative/Balanced/Growth/Adventurous).
Annual review trigger
automated suitability review reminder 11 months after last assessment.
Material change
any significant change to client circumstances triggers immediate re-suitability.
Portfolio position tracking
custody data API (BNY Mellon API), live pricing (Bloomberg API), and transaction history.
Asset allocation
actual vs target allocation (per suitability band model portfolio).
Rebalancing
- automatic rebalancing proposal when allocation drifts >
- 5% from target.
- FCA COBS 2.1: best execution — rebalancing proposals include execution rationale.
FCA UK MiFIR
all trades in financial instruments must be reported to an Approved Reporting Mechanism (ARM) within working day T+1.
Trade reporting
- OMS to ARM (DTCC) via FIX protocol.
- ISIN and LEI enrichment (Bloomberg API, GLEIF).
- Pre-submission validation: validate against FCA validation rules before ARM submission.
Rejection management
automated resubmission with correction on rejection.
Client portal
portfolio performance (absolute and benchmark-relative), asset allocation chart, transaction history, and CGT (Capital Gains Tax) position.
Quarterly report
automated PDF generation (portfolio summary, performance attribution, market commentary section for manager input).
COBS 16A
periodic reporting obligations satisfied.
UK GDPR
client financial data isolated per client — no cross-client data access.
The Results
Platform live at 18 weeks, £112,000 — under budget.
Suitability review completion: 98% of client reviews completed within annual deadline (manual: 84%).
MiFIR rejection rate: 6.2% → 0.4% (pre-submission validation).
Client portal adoption: 76% of clients accessing portal monthly.
Quarterly report generation: 3 days manual → 4 hours automated.
FCA COBS 9A audit: suitability documentation commended as best practice.
“FCA audit commended our suitability documentation as best practice. 0.4% MiFIR rejection rate versus 6.2% previously — the pre-submission validation caught everything DTCC would have rejected. The quarterly report automation saved 3 days of work per quarter for our operations team." — COO, UK Boutique Asset Manager (name withheld)”
Project Details
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