CISI Platforms (IOC) study materials
CISI Platforms (IOC) study resources

CISI Platforms (IOC): Client onboarding, suitability and advice boundaries

CISI Platforms (IOC) · Work through your exam, one topic at a time.

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Client onboarding, suitability and advice boundaries

What this domain tests

Where advice ends and execution-only begins, what a suitability process must contain, and the onboarding controls - KYC, vulnerability, adviser due diligence - that a platform must operate.

Advice, guidance and execution-only

  • Regulated advice is a personal recommendation. Guidance is generic information with no recommendation. Execution-only involves no advice, and firms must not drift into implying suitability.
  • Appropriateness or eligibility tests apply to complex products; non-advised sales of packaged products require information about knowledge and experience.
  • Platforms must ensure the adviser is authorised and holds the right permissions, and must not facilitate unregulated introducers who are effectively advising.

Suitability

  • COBS 9 requires a suitability report for advised sales covering demands and needs, risk profile, capacity for loss, costs and why the recommendation is suitable.
  • Risk tolerance, attitude to risk and capacity for loss are three different things. Capacity for loss is the financial ability to absorb a fall.
  • DB pension transfers are high-risk: triage, abridged advice, specialist referral, contingent charging banned since 2020, and the transfer must be in the client's best interests.

Onboarding controls

  • MLR 2017: identity, address, source of funds and wealth, PEP and sanctions screening, ongoing monitoring.
  • Vulnerability under FG21/1: identify drivers of vulnerability and adapt the process and communications.
  • Insistent clients: document the client's instruction, but consent does not cure unsuitable advice.

Worked example

A client wants to move a £400,000 SIPP to the platform execution-only after dealing with an unregulated introducer. The platform should decline unless an authorised adviser is involved, and should consider a suspicious activity report if the arrangement looks like unauthorised advice or a scam. Reason: the platform's permissions do not extend to advising, and facilitating unregulated pension advice breaches COBS and FCA expectations on transfers.

Traps that cost marks

  • Treating a risk questionnaire score as the suitability decision - it is one input among several.
  • Confusing capacity for loss with attitude to risk.
  • Assuming a signed insistent-client letter removes the firm's obligations.
  • Forgetting that KYC is ongoing, not a one-off onboarding step.