Our client was a London-based, global investment management subsidiary of an international banking group with assets under management of over £40bn, with London and regional service locations. The Firm provides a wide range of investment management services with a large volume of retail clients.
Cordium was engaged as the external provider for compliance monitoring across the client’s whole retail and wholesale investment management business. The requirement arose while the organisation re-constructed its own internal compliance team. Our work followed a risk based framework, implemented by the client, but Cordium developed new compliance monitoring work programmes, documented procedures and then provided external reporting as part of this engagement.
Additionally our work covered consultancy advice and expertise in assessing quality of advice and investment management services provided to retail investors, sales and marketing practices, complaints handling, conduct of business rules and the application of Treating Customers Fairly requirements. Specific areas of conduct of business obligations reviewed included client categorisation, client disclosure, client agreements, suitability, appropriateness, complaints, dealing, client communications, client money and assets, and mandate compliance including COLL investment and borrowing compliance.
Cordium has extensive experience of conduct compliance in the investment management sector which extends to experience of firms managing assets for all types of investor. We have helped establish retail investment management firms and provide our clients with compliance infrastructures that meet the requirements of investment management service provisions.