A day in the life of: David Roberts

Much of my thoughts and effort during the latter part of 2011 and now 2012 has been devoted to the promotion and marketing of Harbour - Amatica's solution for investor risk profiling and suitability assessment, to the UK wealth management sector. Since August last year, I've met with over thirty firms from Edinburgh to London, Leeds to Bristol and Jersey, covering a diverse range of wealth and investment management including private banks, stockbrokers, discretionary fund managers, wealth managers and advisers and regulatory consultants.

The universal feedback that I'm receiving is that Harbour's features and facilities address a number of concerns that the FSA has expressed in its various announcements during 2011. It seems that Harbour's approach to risk profiling and suitability is ahead of the game and hopefully our roadmap of new Harbour functionality will keep us that way.

But when the chance to attend an FSA seminar aimed at wealth managers, FSA compliance managers and consultants presents itself, I grab the opportunity; especially as it's in Manchester, the equivalent of a commute for me. The FSA has expressed serious concerns over the present techniques for risk profiling and suitability assessment including so-called risk profiling 'tools'. They engaged in a fair amount of 'sabre rattling' last year culminating in the circulation of their 'Dear CEO' letter to the heads of wealth management firms - equivalent to an invite to confess one's sins before you get caught out and summarily fined! The seminar will afford me an ideal opportunity to understand the FSA's concerns for fully as well as gauge the reaction and concerns of senior people within wealth management firms.

I'm ushered up to the suite being used for the seminar and I'm surprised not to see serried rows of chairs. We are to be seated around circular tables. Rather than being subjected to six hours of lecturing, the day's format will include workshops. Virtually all the attendees are FSA regulated compliance professionals and come from firms large and small. Their knowledge of the FSA's Codes of Business probably far outweighs my own - but I'm sure I won't embarrass myself!

Although I don't know the FSA's presenters, it's immediately obvious that I'm familiar with their specialism and activities. They were involved directly in the sample wealth management firm review that produced the assertion that “14 out of 16 firms were judged to pose a high or medium-high risk…….based on the number of client files which had a high risk of unsuitability or where the suitability could not be determined” and drafted June 2011's “Dear CEO” letter. They are obviously hands-on specialists and highly knowledgeable.

The FSA opens with a presentation on the lead-up to the sample reviews and the concerns over risk profiling and suitability. It appears that the largest problem for wealth management firms is their inability to demonstrate that the firm has a process and adequate record keeping. Interesting as the concern appears to play to one of Harbour's key features - a risk profile and suitability report forms part of the proposal dynamically generated and retained by Harbour.

The workshops are based on two case studies; one a suitability assessment, the other an MI report submitted to the board by a compliance manager. They are based on true examples found by the FSA. Everyone agrees that the case studies expose a large number of legitimate concerns and recommendations.

Lunch provides a useful opportunity to catch up with some of the attendees that I've met previously and soon we're back to the seminar and the second workshop, where a question and answer session gives us all a chance to query the FSA on risk and suitability issues.

Soon it's 4pm and the seminar finishes. A quick phone call confirms a meeting with a Manchester firm providing unregulated collective investment schemes (UCIS), very specialised and only for knowledgeable investors. Meeting over, then it's a brief walk to the railway station and the trip home.

A useful day? Absolutely. It's proven to me that Harbour addresses the shortcomings in risk profiling and suitability that the FSA is keen to resolve. We've the right product for the right market and the timing is bang on too. Now it's just a case on getting out there to meet with firms, demonstrate Harbour's unique facilities and win new customers!