FSA Fines Manager for Systemic Suitability Failings

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On November 14, the UK Financial Services Authority (FSA) announced that it had fined Savoy Investment Management Limited (Savoy) £412,000 (approximately $653,000) for failing to take reasonable care to ensure the suitability of the investment portfolios of its wealth management clients. Savoy was found to be in breach of Principle 3 (management and control), Principle 9 (customers: relationships of trust) and rules COBS 9.2.1 to 9.2.3 on suitability requirements.

The FSA stated that Savoy had limited front office controls over the provision of investment advice and portfolio management services and it failed to take reasonable care to ensure the suitability of its advice and portfolio management services. This included failures to collect and record “know your client” information and compliance monitoring failures. The FSA had reviewed Savoy as part of its thematic review of the wealth management sector, which found there was an unacceptable risk of clients of wealth management firms experiencing unfavorable outcomes. Twenty-three of the sample of 52 Savoy files reviewed by the FSA were found not to contain sufficient information to determine suitability.

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