Suitability Review | Broker Compliance Specialist
How well do you know your clients?
I am often asked to review the suitability letters that you provide to your clients. In this regard, I sometimes receive one document. It is a stand-alone suitability letter. No Fact Find.
Reviewing a suitability letter in isolation without the accompanying Fact Find is, at best, of very limited value. The two documents are inextricably interlinked.
I attach as much value, if not more, to the information and documentation that you collect from your clients prior to the suitability stage. You are required to know your client. You are required to know your client very well.
How has the law evolved?
The law in relation to knowing your client (KYC) and suitability has evolved quite recently.
The EU (Insurance Distribution) Regulations 2018 has changed key KYC and suitability requirements. This is particularly true if you provide Insurance-based Investment products to your clients.
Where you provide protection and general insurance policies to your clients, the suitability requirements outlined in the Central Bank’s Consumer Protection Code (CPC) will apply.
It is important to note that if you provide MiFID Article 3 Services you must now also comply with the suitability provisions of the CPC.
How can we help?
As you can see, this is quite a technical area that requires a clear understanding of the regulations applying to the different products that you provide to your clients.
Let us take the stress out the process by reviewing and correctly applying the relevant KYC and suitability requirements to the products and services that you provide to your clients.
Why is this important?
First and foremost, your clients expect you to have their best interests in mind when providing a financial product or service to them. This will simply not be possible if you do not know your client as the advice and recommendation provided to them will not be suitable.
KYC and suitability remains a key priority for our own national regulator, the Central Bank, and at a European level, the European Insurance and Occupational Pensions Authority. Regulated firms will be expected to comply with the ever evolving requirements.