CISI Platforms (IOC) cheat sheet

A platform is an intermediary that aggregates products from multiple providers and holds client assets in a nominee or custody arrangement, delivering consolidated valuation and reporting.

Core platform revenue lines: platform/administration charge (usually basis points of assets), dealing/transaction charges, fund manager rebates or clean share class discounts, cash margin, and ancillary service fees.

Adviser platform versus direct-to-consumer (D2C) platform: adviser platforms assume an authorised intermediary selects and monitors investments; D2C platforms contract with the retail client directly and must apply retail suitability and appropriateness rules themselves.

Business model distinction: bundled (all-inclusive percentage fee) versus unbundled/clean pricing (explicit platform fee with no fund manager commission), the latter driven by RDR-style rules banning provider payments to advisers.

Key demand drivers: adviser outsourcing of administration, consolidation of legacy books, demand for tax-wrapper aggregation (ISA, SIPP, GIA, JISA), and digital client expectations.

Key cost drivers: technology and change spend, custody and settlement fees, regulatory capital, financial crime controls, contact-centre service, and client indemnity/compensation levy exposure.

Scale economics: platform costs are largely fixed, so profitability improves with assets under administration; small books may be loss-making and trigger minimum fees or exit charges.

Competitive threats: vertical integration by product providers, low-cost D2C entrants, adviser in-house custody, and consolidation via platform acquisitions or book migrations.

Regulatory environment shapes the market: capital adequacy, client money rules, inducements bans, and consumer duty obligations determine which operating models remain viable.

Legal structure options: the platform may be the authorised firm itself, or an appointed representative/distributor of a product provider; the underlying assets sit with a custodian, trustee or nominee, not the platform.

Nominee versus designated custody: nominee accounts allow bulk settlement and efficiency but pool client assets; designated accounts give named legal title but increase administration cost.

Typical technology stack: front-end adviser/client portal, order management and dealing engine, product/asset master, tax-wrapper engine, cash ledger, custody/settlement interface, reporting engine, and data warehouse.

Straight-through processing (STP) requires clean reference data, standard identifiers (ISIN, SEDOL), and reconciled position and cash records between platform, custodian and fund managers.

Re-registration versus transfer: in-specie re-registration moves holdings without sale (no CGT disposal, potential exit/transfer fees); sale-and-repurchase realises gains and takes the client out of the market.

Model portfolios and rebalancing engines: platform must support bulk rebalancing, tolerance bands, and cash-raising logic that respects settlement and tax-wrapper constraints.

Resilience obligations: business continuity, disaster recovery, outsourcing oversight (including cloud and material third parties), and tested recovery objectives for critical services.

Data architecture must support a single client view across wrappers, joint holdings, trusts and third-party assets, with audit trails for every transaction and price applied.

Change control: migrations and re-platforming carry client detriment risk; require parallel runs, reconciliation, and clear client communication before cut-over.

The platform is typically an authorised firm with permission to hold client money and/or client assets, deal as agent, and arrange or advise on investments; permissions must match actual activity.

Client asset rules (CASS-style): client money must be segregated, reconciled daily/internal and externally, and held in trust; a statutory trust protects client money on insolvency.

Client money vs client assets: money awaiting investment or withdrawal is client money; invested securities are safe custody assets - the two regimes have different reconciliation and record-keeping duties.

Inducements/commission rules: platform charges must be explicit and disclosed; provider payments to advisers are restricted, and any non-monetary benefit must be minor and enhance service quality.

Capital adequacy: firms must hold regulatory capital covering fixed overheads and/or expenditure-based requirements; prudential category determines the calculation.

Supervision approach: threshold conditions, periodic reporting, skilled-person checks, appointed representatives regime, and thematic reviews of platform charges and transfers.

Complaints handling and redress: defined complaint timescales, root-cause analysis, and reporting to the regulator; systemic platform errors can trigger redress programmes.

Vulnerable customers and consumer duty-style outcomes: products and services must deliver fair value, with evidence of price and charges assessment.

Outsourcing and operational resilience rules require board accountability, documented service levels, exit plans, and notification of material outsourcing.

Client categorisation: retail, professional (per se or elective) and eligible counterparty; most platform clients are retail and attract the highest protections.

Know-your-client data: identity, tax residency, investment objective, risk tolerance, capacity for loss, time horizon, income/liabilities, and existing holdings.

Suitability assessment applies where advice is given; appropriateness (knowledge and experience) applies to execution-only and non-advised services.

Advice versus guidance: a personal recommendation to buy, sell or hold a specific investment is advice; generic information, tools and filters are guidance and must be clearly labelled.

Execution-only platforms must warn where a product is not appropriate, offer a right to proceed after the warning, and avoid straying into implicit recommendations.

Vulnerability assessment at onboarding: record health, capability, life events and resilience factors; adjust communications and, where relevant, restrict channels.

Financial crime onboarding: identity verification, sanctions and PEP screening, source of funds/wealth, and enhanced due diligence for higher-risk clients.

Ongoing review duties: suitability must be kept under review where advice is ongoing; platform should support annual reviews and trigger events (retirement, bereavement).

Record-keeping: retain suitability reports, appropriateness tests and client agreements for the required period and make them retrievable for supervision.

Main wrappers: ISA (and JISA), SIPP, personal pension, GIA, onshore/offshore bonds, and offshore/onshore investment accounts; each has distinct tax treatment and contribution limits.

ISA rules: annual subscription limit applies per individual per tax year, can be split across cash/stocks-and-shares/innovative finance, and transfers between providers preserve tax wrappers.

SIPP features: tax relief at marginal rate (subject to limits), pension commencement lump sum, income drawdown, and annual/lifetime allowance constraints (rules change - verify current).

GIA: no tax shelter; dividends, interest and capital gains taxed on the client, with reporting obligations and the need for tax-lot tracking and CGT calculations.

Offshore bonds: gross roll-up with chargeable event taxation on gains, top-slicing relief, and 5% annual withdrawal allowance (verify current rules).

Collectives, ETFs, investment trusts, structured products and cash: platform must hold accurate product data, KIDs/KIIDs, costs and risk labels.

Costs and charges disclosure: ongoing charge figure (OCF), transaction costs, platform fee, adviser charge and any incidental costs must be aggregated and shown.

Restrictions: some products are not permitted in certain wrappers (e.g., unregulated collective investment schemes generally excluded from ISAs), so eligibility checks are required at order entry.

Transfers and Bed & ISA / Bed & SIPP: selling and repurchasing to move assets into a wrapper crystallises gains; platform tools must flag the tax consequence.

Order types: market, limit, stop and forward-dated; platform must capture client instruction, price tolerance, and validity period before routing.

Trade lifecycle: order capture, pre-trade checks (cash, eligibility, restrictions), execution, confirmation, settlement, and reconciliation to custody.

Settlement cycles: equities typically T+2, funds priced forward (e.g., 12:00 cut-off, same-day or next-day pricing), and cash settlement on the value date.

Contract note content: price, quantity, charges, commission, settlement date, and the capacity in which the firm acted.

Corporate actions: dividends, rights issues, scrip, stock splits, mergers and takeover elections require timely client notification and instruction deadlines.

Asset administration: position keeping, cost-base and tax-lot records, income collection and tax vouchers, proxy voting, and unclaimed asset handling.

Failed or late settlement: buy-in procedures, compensation for late settlement, and client communication; reconciliation breaks must be investigated and cleared.

Re-registration and transfers in specie: track asset movement between custodians without sale, with defined timescales and client status updates.

Best execution: platform must take reasonable steps to obtain best result for clients, considering price, cost, speed and likelihood of execution; execution-only firms still owe this duty.

Client cash handling: cash must be held in a client money account with an approved bank, segregated from firm money, and reconciled; interest treatment must be disclosed.

Cash sweep and interest: platform may retain a margin on client cash; rules require disclosure of whether interest is paid to clients and on what basis.

Fee types: platform/administration fee (bps of assets), dealing charge per trade, fund switch charge, transfer/exit fee, SIPP annual fee, and ancillary charges (paper statements, express dealing).

Fee calculation methods: ad valorem (percentage of holding), tiered/banded rates, flat monetary fee, and minimum/maximum caps; state the basis and frequency (monthly/quarterly in arrears).

VAT: platform administration and dealing fees are generally VAT-able; fund manager charges and some pension services may be exempt - verify treatment per service.

Collection mechanics: fees may be deducted from cash, from the wrapper, or collected from an external account; tax-wrapper rules affect whether fee payment counts as a contribution or withdrawal.

Adviser charges: facilitated via platform, deducted with client consent, disclosed in cash terms, and cancellable by the client.

Disclosure requirements: total cost of ownership, illustrative charges, and the effect of charges on returns; client must receive clear pre-sale cost information.

Exit and transfer fees must be fair, disclosed, and consistent with consumer duty-style fair value assessments; excessive charges attract supervisory scrutiny.

Valuation basis: holdings valued at latest available price (bid/mid/close), with the pricing source and timestamp disclosed; illiquid assets may need independent valuation.

Reporting frequency: periodic statements (at least annually, often quarterly), transaction confirmations, tax-year summaries, and on-demand portal access.

Statement content: opening/closing values, transactions, charges, income, realised/unrealised gains, cash movements, and a clear cost breakdown.

Tax reporting: consolidated tax certificates, CGT reports, interest and dividend summaries, and pension contribution statements for self-assessment.

Performance reporting: time-weighted vs money-weighted returns, benchmark comparison, and disclosure of the methodology and whether fees are included.

Data quality: reference data (ISIN, price, corporate action) must be validated; stale or missing prices require fallback rules and disclosure.

Client-facing portals: role-based access, adviser view vs client view, audit logging, and secure authentication to protect personal data.

Regulatory reporting: firm-level returns, complaints data, and client money/client asset reports must reconcile to the same source data used for client statements.

Data protection: lawful basis for processing, retention limits, subject access requests, and breach notification obligations.

Risk framework: three lines of defence (business, risk/compliance, internal audit) with board-approved risk appetite and defined tolerances.

Key platform risks: operational error, cyber, outsourcing failure, market/valuation error, client money loss, conduct risk, and concentration on a single custodian or technology provider.

Controls: segregation of duties, maker-checker on payments and static data changes, four-eyes on fee and price overrides, and reconciliation controls.

Financial crime: customer due diligence, sanctions screening, PEP checks, transaction monitoring, and suspicious activity reporting to the financial intelligence unit.

Fraud controls: call-back verification for bank detail changes, device and behavioural monitoring, and protection against authorised push payment fraud.

Market abuse: surveillance for insider dealing and manipulation where the firm executes or arranges; suspicious transaction and order reports.

Cyber and data: access management, encryption, penetration testing, incident response, and third-party risk assessment of cloud providers.

Business continuity: defined recovery time/point objectives, tested failover, and client communication plans for outages.

Breach and error handling: root-cause analysis, client remediation, regulatory notification where required, and lessons-learned tracking.

Core conduct principles: act with integrity, due skill and care; manage conflicts of interest; treat customers fairly; communicate clearly and not misleadingly.

Treating Customers Fairly outcomes: fair treatment embedded in culture, clear pre-sale information, suitable advice, products meeting needs, no unreasonable post-sale barriers, and clear complaints handling.

Conflicts of interest: identify, disclose or manage; platform must not favour its own products or a connected provider without disclosure and fair treatment.

Vulnerability: identify and support clients with health, capability, life-event or resilience issues; adjust processes and record actions.

Consumer duty-style outcomes: products and services, price and value, consumer understanding, and consumer support - with evidence of fair value assessments.

Complaints: acknowledge promptly, resolve within defined timescales, offer redress where loss is caused, and use root-cause analysis to fix systemic issues.

Incentives and remuneration: staff incentives must not drive mis-selling; sales targets should be balanced with quality and fairness measures.

Transparency: charges, risks and product features communicated in plain language; no misleading past-performance or guarantee claims.

Ethical decision tests: would the client understand and expect this? Could we defend it to the regulator? Is the client able to make an informed choice?