SFC Type 4 · Advisers

Suitability measured on the whole portfolio.

You advise clients on investments. You need to show that a recommendation suits the client, and that a complex product was explained with the risk warning on file.

Today

Where the time goes

01Suitability checked one trade at a time rather than across the portfolio.
02Product approvals spread across email threads.
03Complex product warnings hard to find when someone asks for them.
04Staff dealing reviewed from a spreadsheet, after the event.
With TAC

What changes

01

Suitability is measured on the whole portfolio against the client's risk rating, read from the signed client agreement.

02

Product risk ratings come from one policy page, so the same product type is rated the same way across clients.

03

A product cannot enter a portfolio without approval, whether it arrives by upload, trade, link or manual entry.

04

A complex product needs its explanation and risk warning on file. A trade that needs approval waits until it has one.

05

Staff trades are checked against client orders in the same security, including trades in the opposite direction.

Records

What you receive

01

Exception list, each item with one owner

02

Senior Management Summary, by rule

03

Approval record: who approved, when and what changed

04

History of each test run, for an SFC inspection

Your firm

Your advisers make the recommendations. Our compliance team investigates what the tests flag and records the outcome. The decision on each exception, and the quarterly sign-off, stay with your responsible officers.