Project Overview
A UK network of 84 Independent Financial Advisers (IFAs) with £2.4B client AUM needed a unified digital wealth...
Technology Stack
Compliance & Standards
The Challenge
A UK network of 84 Independent Financial Advisers (IFAs) with £2.4B client AUM needed a unified digital wealth management platform — replacing spreadsheet-based client onboarding, paper suitability reports, and manual portfolio monitoring. FCA COBS 9 (suitability for investment advice), FCA PROD 3 (product governance), MiFID II suitability records, FCA Consumer Duty PS22/9, CASS 7 (client money), UK GDPR, and MiFID II investment advice records were mandatory. Budget: £130,000.
Our Approach
FCA COBS 9 Suitability Assessment Engine
FCA COBS 9.2: investment advice must be suitable for the client.
Digital suitability
- 1Risk profiling questionnaire (14 questions — ATR, capacity for loss, investment horizon),
- 2ESG preferences (Sustainable Finance Disclosure Regulation — SFDR integration),
- 3knowledge and experience assessment (sophistication),
- 4financial situation (income, assets, liabilities — open banking integration via TrueLayer for asset verification).
Suitability matrix
risk profile + investment horizon + capacity for loss → suitable investment universe.
Automated suitability check
proposed portfolio allocation checked against suitability matrix before adviser can recommend.
MiFID II Suitability Report Automation
MiFID II requires a written suitability report explaining why the recommendation is suitable for the client.
Automated suitability report
client profile (risk score, financial situation, objectives) + recommended portfolio (allocation, expected return, risk metrics) → auto-generated suitability report (Word/PDF) with mandatory MiFID II disclosures.
Adviser review
adviser reviews auto-generated report, adds narrative commentary, and approves.
FCA record
suitability report stored immutably — accessible to FCA on request for 7 years (SYSC 9 records retention).
Consumer Duty outcomes monitoring
investment performance vs client objectives, charges vs value assessment (PROD 3 fair value), and client understanding of investment risks (annual communications).
Portfolio monitoring
real-time portfolio valuation (LSE and NYSE price feeds), benchmark comparison (IA sector benchmark), rebalancing alerts (when portfolio drifts beyond tolerance from target allocation), and annual review reminder workflow (COBS 9 obligation to conduct periodic reviews).
Consumer Duty dashboard
adviser and network management can see outcome metrics across all clients.
CASS 7
client money held in segregated client money accounts.
Custody
shares and funds held in custody by a third-party custodian (Pershing or Fidelity FundsNetwork — ClickMasters integrates via Custodian API).
Portfolio transactions
buy/sell instructions sent via custodian API, settlement confirmation received, portfolio updated.
CASS reconciliation
daily reconciliation of client money account vs sum of client committed funds.
Custody reconciliation
weekly reconciliation of platform portfolio data vs custodian holdings statement.
The Results
FCA COBS 9 suitability confirmed by FCA compliance review.
Platform live at 22 weeks, £120,000 — under budget.
Suitability report generation: 3.2 hours → 18 minutes. 84 IFAs onboarded in 6 weeks.
Consumer Duty outcomes dashboard: first annual Consumer Duty report produced automatically.
MiFID II suitability record retention: 100% automated.
Adviser NPS: 82 (legacy paper process: 28).
Client digital portal adoption: 72% of clients using portal within 3 months.
“Suitability report from 3.2 hours to 18 minutes. 82 NPS for advisers versus 28 on paper. Consumer Duty annual report produced automatically for the first time — previously 2 weeks of manual work. MiFID II 100% automated retention. Client portal 72% adoption in 3 months. The FCA compliance review confirmed suitability — that is the validation that matters most for our regulatory obligations." — CEO, UK IFA Network (name withheld)”
Project Details
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