Project Overview
A UK discretionary investment manager (DIM) with £840M AUM and 1,400 client portfolios needed to replace their...
Technology Stack
Compliance & Standards
The Challenge
A UK discretionary investment manager (DIM) with £840M AUM and 1,400 client portfolios needed to replace their legacy portfolio management system (PMS) with a modern platform — providing real-time portfolio analytics, MiFID II / FCA COBS 9A suitability, and the Consumer Duty value assessment. FCA MiFID II (transaction reporting, best execution), FCA COBS 9A (suitability assessments), FCA Consumer Duty PS22/9, FATCA/CRS (international client tax reporting), and Custody compliance were the requirements. Budget: £200,000.
Our Approach
Portfolio Management System Architecture
Real-time portfolio analytics: market data via Refinitiv (LSEG) Data API (equities, bonds, fund prices), portfolio valuation (mark-to-market, daily), and performance attribution (time-weighted return, money-weighted return).
Asset classes
equities (UK, international), bonds, funds (OEIC, SICAV), alternatives.
Model portfolios
- discretionary models (Cautious, Balanced, Growth) applied across all client portfolios — bulk rebalancing engine (generate orders for all portfolios deviating from model by >
- threshold).
FCA COBS 9A Suitability Assessments
COBS 9A (MiFID suitability for discretionary management): annual suitability review for all clients.
Suitability factors
investment objectives, financial situation, risk tolerance, investment knowledge and experience.
Suitability assessment workflow
structured questionnaire → algorithm → suitability score → DIM signs off → client notified.
Suitability mismatch alert
if client portfolio drifts outside suitability band (e.g., growth portfolio for cautious client after market movement) → automatic DIM alert.
FCA MiFID II transaction reporting
all transactions in financial instruments must be reported to FCA within T+1 via an Approved Reporting Mechanism (ARM).
ARM
Unavista (LSEG) — API integration from PMS.
Transaction report fields
65 mandatory fields per transaction (instrument identifier, quantity, price, execution venue, client LEI).
LEI validation
Legal Entity Identifier validation via GLEIF API for all institutional clients.
Regulatory reporting dashboard
daily confirmation of T+1 reports submitted, any failures flagged.
Consumer Duty Value Assessment Automation
FCA Consumer Duty (PS22/9): investment management firms must demonstrate value for all products and services.
Annual value assessment
charges vs benchmark (costs and charges disclosure per COBS 6.1ZA), performance vs benchmark, service quality (complaint rate, response times).
Value assessment report
generated automatically from PMS data, reviewed by compliance officer, approved by Board.
Distributor reporting
if DIM distributes third-party funds, fund performance and charges data provided to fund managers for their value assessment.
The Results
Platform live at 22 weeks, £188,000 — under budget.
Portfolio valuation latency: 3 hours (batch, legacy) → 4 minutes (real-time).
MiFID II T+1 reporting: 100% compliance (legacy: 3 reporting failures in prior year — each requiring FCA notification).
Suitability review completion: 97% within regulatory deadline (target: 95%).
Consumer Duty value assessment: automated — previously 6 weeks of manual work per year.
AUM growth: platform cited by 18 new clients as reason for choosing the DIM.
“18 new clients cited the platform as a reason for choosing us. That is AUM growth directly attributable to technology. MiFID II zero reporting failures — three in the prior year, each requiring FCA notification and a bad week. Consumer Duty value assessment from 6 weeks manual to automated — the compliance team genuinely celebrated that." — CEO, UK Discretionary Investment Manager (name withheld)”
Project Details
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