It’s been on the agenda for ages, and yet suitability remains the FCA’s over-riding concern in the Wealth Management sector. We’re now over eight years on from the 2011 ‘Dear CEO’ letter, but it’s clear from recent supervisory activity that the regulator believes an unacceptably high proportion of client files are still failing to evidence suitability.
In this session, we’ll give you an insight into the most common suitability-related problems we come across, and some ideas about how you can evidence high quality advice and portfolio management in your firm. In particular, we’ll look at how to evidence:
- Suitability of the selected investment service (e.g. bespoke discretionary)
- Suitability of the selected investment strategy/mandate
- That the client’s portfolio is being managed in line with the selected strategy
- That the client’s portfolio remains suitable for their needs over time
As a former practitioner and regulator, Richard Scrivener – consultant at Bovill – spends much of his time helping wealth management firms with – among other things – matters relating to suitability, appropriateness, governance and systems and controls. He is often asked to provide an independent view of whether the information firms gather from clients, and the content of their individual client files, stand up to scrutiny.