Suitability and Appropriateness of Investment Advice

What are suitability requirements?

1. Client knowledge and experience
   
   Consideration must be given to the types of investments with which the client is familiar as evidenced by their trading history. In addition, the volume and frequency of the client’s transactions with the respective investments will need to be taken into account before assessing suitability.
   
   
2. Client financial situation
   
   The firm will also need to establish whether or not the client can demonstrate that they have sufficient income to ensure that any losses on investments will not cause financial distress. This will be determined by assessing the client’s assets as well as any regular financial commitments they may have.
   
   
3. Client investment objective
   
   The Wealth Management firm must ensure that the proposed investment is consistent with the client’s investment horizon. The firm will also need to be aware of the client's risk preferences, risk profile and risk tolerance.
   
   MiFID II also enforces the requirement to provide individual investors with suitability reports about the investment services available to them.

What are appropriateness requirements?

Wealth managers must assess if the financial instrument or service is “appropriate” for the client in the case of complex products defined as anything other than equities, bonds and money market funds

The firm will assess the individual client’s relevant knowledge of and experience in financial instruments, including: 

• Types of service, transaction and the regulated investments with which the client is familiar with as evidenced by their trading history in the specific product
• Nature, volume, frequency of the client’s transactions with regulated investments as evidenced by their trading history
• Level of education and profession of the client as relevant to the product traded. For instance, a career in Investment Banking could demonstrate knowledge of complex derivative products

If the service provided is an execution-only service, then the appropriateness test is deemed to be unnecessary provided that the following conditions are met: 

• The client wants to invest in non-complex financial instruments such as shares traded on regulated markets, bonds, debt instruments, investment funds or money market instruments
• The service is performed on the client’s initiative
• The client is made aware that the investment firm is not automatically obliged to perform the appropriateness test