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.
Where the time goes
What changes
Suitability is measured on the whole portfolio against the client's risk rating, read from the signed client agreement.
Product risk ratings come from one policy page, so the same product type is rated the same way across clients.
A product cannot enter a portfolio without approval, whether it arrives by upload, trade, link or manual entry.
A complex product needs its explanation and risk warning on file. A trade that needs approval waits until it has one.
Staff trades are checked against client orders in the same security, including trades in the opposite direction.
What you receive
Exception list, each item with one owner
Senior Management Summary, by rule
Approval record: who approved, when and what changed
History of each test run, for an SFC inspection
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.