FinTech Wealth Management Platform — UK Discretionary Investment Manager

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. MiFID II Transaction Reporting: 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.