Operations & Tech

The Zero-Defect Annual Review

Under Consumer Duty and PROD rules, the annual review is the single most critical compliance event in a client's lifecycle. Here is a systematized approach to ensure reviews are executed consistently without burying staff in administration.

Pre-Meeting Administration (T-Minus 30 Days)

The adviser should not touch a file until the paraplanner or administrator has assembled the data.

Step 1: Data Gathering

Admin team pulls up-to-date valuations from platforms and providers. Issues a pre-meeting questionnaire to the client requesting updates on health, income, and objectives.

Step 2: Capacity for Loss Assessment

Paraplanner runs initial cash-flow models to see if the client's capacity for loss has fundamentally shifted due to market movements or inflation.

The Meeting Agenda

The review meeting must follow a structured agenda to ensure regulatory requirements are met and documented.

  • 1. Re-affirm Objectives: Are the goals established in the original financial plan still valid?
  • 2. Risk & Capacity Check: Explicitly confirm there are no changes to risk tolerance or financial dependents.
  • 3. Suitability Confirmation: Confirm the current investment mandate (e.g., the CIP portfolio) remains suitable.
  • 4. Cost & Charges Disclosure: Visually present the ex-post costs and charges document. This is non-negotiable under MIFID II.