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Financial advisory
RES5Financial Advisory Services✓A digital adviser that was licensed for fund management under the CMG-G02 track-record/AUM concession now wants to (i) build its model portfolios out of CIS that it manufactures itself and (ii) insert a human 'portfolio consultant' step into its advisory flow. Under CMG-G02, this is:
CMG-G02 para 24 states that a digital adviser relying on the track-record/AUM concession should not manufacture the underlying CIS used to build its model portfolios, and that its client-facing tool should be fully automated to avoid undue influence on the advisory and portfolio-construction process or the client's decision. Both the self-manufacture and the human-consultant step conflict with these conditions.
The concession comes with strings: no self-manufactured CIS and a fully automated tool — the firm cannot cure it by dropping EIP portfolios or by only doing one of the two.
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