Unfair Gaps🇺🇸 United States

Investment Advice Business Guide

18Documented Cases
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All 18 Documented Cases

Manual, duplicative suitability documentation driving compliance overhead

$100–$300 of advisor/compliance time per advice event in many European wealth firms (estimated from KPMG MiFID II survey benchmarks) and significant additional FTEs devoted to suitability file remediation during regulatory reviews, equating to millions per year for mid‑ to large‑size firms

MiFID II requires a written suitability report for each instance of personal investment advice, explaining why a recommendation is suitable for the client based on collected data; US state regulators similarly expect detailed documentation to answer specific suitability questions. This leads to high advisor and back-office time spent preparing, editing, and storing repetitive suitability narratives when processes are not automated.

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Unsuitable advice leading to client redress, reimbursements, and lost ongoing revenue

£34.2m redress and costs for suitability/poor advice failings at UK wealth firm Charles Stanley in 2014 (pre‑MiFID II), with similar multi‑million remediation programs repeatedly cited by the FCA in later portfolio reviews; US state regulators also report suitability-based restitution orders in the tens of millions annually across advisers

When suitability and risk profiling are weak, firms recommend products inconsistent with a client’s risk tolerance or objectives, triggering regulator‑mandated remediation, compensation, and loss of future advisory fees. Suitability breaches are repeatedly highlighted in MiFID II and US state examinations as a core cause of costly client redress programs.

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SEC Examinations Failing Best Execution Documentation Requirements

$Unknown - fines and settlements from enforcement actions

Investment advisers frequently fail SEC examinations due to inadequate documentation of best execution evaluations, lack of periodic reviews of broker-dealer performance, and insufficient policies and procedures for trade execution. This leads to audit deficiencies where firms cannot demonstrate they selected execution options most beneficial to clients. Systemic issues include not considering full factors like execution capability, financial responsibility, and responsiveness, resulting in recurring compliance breaches.

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Fines and sanctions for inadequate suitability assessments and risk profiling

Suitability and mis‑selling enforcement actions frequently run into the tens of millions in fines and client redress for larger firms; even smaller advisers can face six‑ or seven‑figure penalties plus mandated remediation, as seen in repeated FCA and US state enforcement reports for unsuitable advice cases.

Regulators globally, under regimes such as MiFID II and US state securities laws, routinely sanction firms for failing to perform or document proper suitability assessments before giving investment advice. Requirements include obtaining relevant information, issuing a written suitability statement, and demonstrating that recommendations align with client risk tolerance and objectives; failure leads to fines, censures, and costly remediation.

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