The Financial Conduct Authority (FCA) has published its findings of a review of suitability of retail investment portfolios provided by wealth management and private banking firms. Whilst some progress has been made in demonstrating the suitability of clients’ portfolios, significant concerns remain around the management and use of client information. The regulator has referred a number of firms to Enforcement or issued S166 Skilled Person requirements.
The thematic review found that:
Firms providing discretionary and advisory portfolio management services to retail clients must review the FCA's report.
Firms should ensure they are able to demonstrate how the portfolios they manage are suitable and consider whether any of the issues identified apply to them. Firms will be required to take any necessary action promptly.
To discuss the implications of the report for your firm, whether you need to consider a review of your systems and controls or would like support in responding to a S166 please contact Noline Matemera on +44 (0)333 006 0734 or Emily Benson on +44 (0)333 006 1471.
This publication is intended for general guidance and represents our understanding of the relevant law and practice as at December 2015. Specific advice should be sought for specific cases. For more information see our terms & conditions on www.TLTsolicitors.com
On 12 October 2018, the FCA published a Guidance Consultation (GC 18/4) on the Senior Managers and Certification Regime on statements of responsibilities (SoRs) and responsibilities maps (which apply to enhanced firms).