Are there additional responsibilities that come with operating a platform?
The decision to operate a platform carries with it certain legal, operational and reporting obligations that it’s important you’re aware of.
By working with Seccl, you can outsource some of the traditionally more challenging aspects of operating a platform, like custody and client money.
Nevertheless, end clients will now be paying you, and not a third-party, for platform services – and as such you should be prepared for certain additional responsibilities. These include…
- Legal responsibilities: you will need to produce new platform terms and conditions, as well as new policies (such as privacy, data protection and conflicts of interest policies), which your clients will need to sign up to.
- Operational responsibilities: as platform operator, you would act as the first port of call for all queries and calls from users of your platform (such as advisers, paraplanners, operations staff or administrators) and be responsible for providing day-to-day system support (for example password resets or simple ‘how-to’ explanations). We will, of course, handle more sophisticated queries, system fixes or functionality updates
- Reporting responsibilities: we’ll provide all regulatory reporting and alerts required of us in our role as custodian (and ISA manager, if applicable) – including CASS returns, transaction reporting, suspicious activity, regulatory breaches, all MiFID reporting, and pre- and post-sales illustrations. But you will then be responsible for fulfilling any onward regulatory reporting that’s required of you. For example, if you are a DFM, we will alert you of a 10% drop; at which point it will be your responsibility to communicate this to advisers as appropriate. As an FCA authorised firm or appointed representative, you’ll have to provide your own Gabriel returns to the FCA.
- Governance responsibilities: you will need to put in place a proper governance structure and ensure sufficient oversight of the services you outsource to us – as well as the new ones that you’re now providing to clients in your role as platform operator.
Who does what?
Knowing where our responsibilities end and yours begin can get a little tricky. We’ve given a summary in this snapshot below. For more information on operating a platform, take a look at our introductory guide to operating a platform.
More like this