Anewoperatingmodelforwealth compliance.
Every area a wealth firm answers for, running on one engine with one audit trail. Start where it matters most to you, and extend across the rest at your own pace.
Complete file review
Pension drawdown · WM-4471
Attitude to risk recorded and consistent
Fact find · p4
Capacity for loss evidenced separately
Suitability report · p9
Fund exhaustion stress tested
Cash flow · not found
Aggregated costs disclosed in £ and %
Illustration · p2
Independently certified, and built for regulated firms
The FCA has been reading advice files,
Its recent work lands on one point: the file has to evidence the advice, and often it does not. Completeness fails before quality does. And the standard itself is about to move.
The FCA has been reading advice files,
Its recent work lands on one point: the file has to evidence the advice, and often it does not. Completeness fails before quality does. And the standard itself is about to move.
Every area of the file, and the rule it answers to.
Each card below is one area of an advice file. The tag on it is the part of the rulebook that area is read against.
Onboarding and financial crime
MLR 2017 · SYSC · COBSIdentity, anti-money laundering and sanctions, source of funds and wealth, client agreement, conflicts.
Know your client
COBSObjectives, attitude to risk, capacity for loss, horizon, knowledge, vulnerability, wider planning.
Cash flow and retirement
COBSForecast and assumptions, stress testing, sustainability of income, tax free cash, future needs.
Consumer Duty
PRIN 2A · PRODCross-cutting rules, target market, fair value, ongoing charge justification, clarity, access.
Research and mandate
COBSDue diligence, mandate completed and consistent, risk match, platform and wrapper cost.
Illustrations and disclosure
COBS · PRIIPsIllustration and key information document on file, consistent with the recommendation, costs in pounds and per cent.
Suitability report
COBSMatches the client profile and the mandate, disadvantages set out, switch comparison, charges.
Ongoing service
COBS · PRIN 2APeriodic suitability assessment delivered, and the service matches what the client pays for.
Drawdown and UFPLS
COBSThe risk warnings a drawdown report has to carry, each one confirmed present.
Insistent client
FCA guidanceWhether the client went against advice, what they were told, acknowledgement, separation, record.
Your checklist, not ours
This is our standard wealth set and it is where we start. We configure against your own file review checklist and advice guidelines, removing questions as readily as we add them. An area that does not apply to a case is marked not applicable, not passed quietly.
The same file, read at the depth the moment calls for.
One configuration, read at three moments. Before the advice goes out, a completeness check finds the gap while the adviser can still fix it, which is the cheapest moment there is. After it goes out, the full review grades every area and cites every answer, across the whole book rather than a sample. On the ongoing service file, the annual review evidences what the adviser charge pays for.
Before the advice goes out
Completeness check
Is everything on the file that has to be there, while it can still be fixed.
After the advice goes out
Complete file review
Every area graded, every answer cited, remediation on anything that fails.
On the ongoing service file
Annual review
Does the recommendation still hold, and can the service be evidenced.
Nobody tags the case by hand.
The system reads the documents, works out what kind of case it is, and asks only the questions that apply.
Case types classified automatically
Ways the work reaches us
A grade you can challenge,because the evidence is attached to it.
Every answer comes from an agent that reads the whole file, not a keyword search. You get the grade, the reasoning written out, the document and page behind it, and remediation you can hand straight to the adviser.
- Red, amber, green or not applicable
- Cited to document and page
- Remediation on anything that fails
- An area summary a head of compliance reads in a minute
- Per adviser: a repeated weakness is a training need, not three errors
- Per firm: which area is weakest, and whether it is moving
Complete file review
Case WM-4471 · Pension drawdown
Graded against your standard
Know your client
GreenIs capacity for loss assessed separately from attitude to risk?
Yes. Assessed against essential expenditure and other assets, distinct from the recorded risk profile.
Read from
Fact find v3, p.11 · Suitability report, p.4
Drawdown and UFPLS disclosure
RedDoes the report disclose that the capital value of the fund may be eroded?
No such disclosure located in the report or the illustration.
Remediation
Add the erosion disclosure and reissue before the drawdown is set up.
Start where it costs you most. Add the rest when you want it.
Nine oversight areas, one engine, one audit trail. Almost every wealth firm starts with the advice file, because that is where the cost sits today.
Where wealth firms start
Advice file review
Suitability, disclosure, Consumer Duty, cash flow, vulnerability and the record. This is everything the rest of this page is about.
Add the rest when you want them
Adviser onboarding
Status, permissions, identity, adverse history, and competence read from their first files rather than asserted.
Ongoing supervision
Risk signals per adviser and per firm, drawn from every check that has already run.
Training and competence
Which adviser is weak on what, evidenced by the files that show it.
Financial promotions
What advisers publish, read on a cycle you set and graded against your own breach taxonomy.
Complaints
The file re-examined, root cause named, and whether the same cause appears elsewhere in the book.
Financial crime
Identity, screening, control, source of funds and source of wealth, read on the file rather than beside it.
Conduct and outcomes
Vulnerability, fair value, understanding and outcomes, aggregated for the board.
Firm onboarding
For networks and acquirers: independent sources, from the FCA Register through Companies House.
One engine, one record
Because these run on the same engine, a weakness found in an adviser’s files is the same fact that shapes their supervision, their training plan and how closely their promotions are read.
A finding does not stop on the file it was found in.
Run these areas separately and one weakness becomes three pieces of work: a file finding, a supervision note, a training action, each raised by a different person from a different system. Run them on one engine and it is one fact, arriving everywhere it matters, already evidenced.
Running today, not on a roadmap.
This is the wealth file review as a firm can have it configured and reading files now.
The review itself
- ✓Wealth advice file review across investment advice, pension accumulation and pension drawdown
- ✓Review areas configured to your checklist and your advice guidelines rather than ours
- ✓Completeness check before the advice leaves the building
- ✓Complete file review after the advice goes out, graded and cited in full
- ✓Annual review of the ongoing service file, against your review checklist
- ✓Automatic case type classification from the documents, so nothing is tagged by hand
What it gives the firm
- ✓Every file rather than a sample, because the cost of checking one more file is close to nothing
- ✓Cited evidence and remediation on every finding, so a grade can be tested rather than trusted
- ✓Findings rolled up per adviser, turning a repeated weakness into a training need
- ✓Findings rolled up per firm, showing which areas are weakest and whether they are moving
- ✓A dated record of what was read, and which version of your standard it was read against
- ✓Protection and mortgage files on the same engine, into the same adviser and firm record
Bring us files you have already reviewed. Compare what comes back.
The only honest test of a file review is whether it agrees with your own compliance team on cases they have already judged, including the ones that failed.
- 1
We configure to your standard
You send your file review checklist and your advice guidelines. We map them onto the question set, add what is missing and remove what does not apply.
- 2
You pick files where you already know the answer
Real cases your compliance team has already reviewed, including the ones that failed. A benchmark is only worth running against cases with a known answer.
- 3
We run them and sit down with the findings
Question by question, against your own conclusions. Where we disagree we look at why, and often it is a configuration point, so we change it.
- 4
Then it runs on the live book
At the depth you choose, with findings rolling up per adviser and per firm.
What we need from you
- Your file review checklist and your advice guidelines
- A handful of complete cases, good and bad
- One person in compliance who can settle a judgement call
You keep control of all of it.
Your configuration, your evidence and your record sit with you, in a form your risk function, your board and your regulator can read without us in the room.
Your configuration
Human-readable, versioned, exportable, and changed by your team without waiting on a release from us. Your compliance officers tune each question until the answers match your own standard, and if it ever ends, the configuration leaves with you along with the full record of every file read against it.
Your evidence
Every finding cites its document and page. Every override is retained with the name and the time. The whole trail exports for internal audit, a thematic review, or a regulator asking how.
Continuity
UK and EEA hosting on Microsoft Azure, role-based access, and your data never trains a foundation model. Escrow governance, configuration vaulting and annual recovery verification.
Accuracy held in place
A reserved set of cases with known answers runs on a schedule against every model provider we use, catching drift before it reaches your results. Every configuration change is replayed across a graded corpus before it ships.
Certified AI governance
Curvestone is certified to ISO/IEC 42001:2023 (Cert No. 19087, ISOQAR), the international standard for AI management systems. The controls above are audited against it by a third party, and the certificate is on the Trust Centre.
Regulatory posture
Built for FCA-regulated firms. Reproducible for a Section 166 or a thematic review, with an evidence trail that reconstructs how any judgement was reached long afterwards.
Your standard, your evidence, your record.
Answers for wealth firms evaluating Curvestone.
See it read a fileyou already know the answer to.
Send us cases your compliance team has already reviewed. We will run them against your own standard and go through the findings with you, question by question.