Advice stays with the adviser who signs it, whatever an AI agent drafts. An advice team's approver authority matrix sets who approves each agent-prepared action for clients, from suitability reports and rebalancing trades to client messages and fee changes, with each action's depth, the approver's limit, the second approver and the certificate required.
Why does an advice team need a separate matrix?
Advice is personal and regulated. A recommendation must fit the client's circumstances, objectives and attitude to risk, and the adviser who gives it answers for it. An agent can draft a suitability report at depth 2 from the fact-find, prepare rebalancing trades to bring a portfolio back to its model, and draft review letters. It must never issue advice in its own right.
The matrix separates three kinds of action. Drafts the adviser signs: suitability reports, review letters. Trades: rebalancing within an agreed model is routine work, but placing trades moves client money and should be held for an approver. Exceptions: anything outside the model, a fee waiver, or a client showing signs of vulnerability goes to a senior adviser and often a second approver.
How do you fill it in?
- Action: name it in the team's own words.
- Agent depth: 1 reads, 2 drafts, 3 executes routine work within bounds, 4 moves money.
- Approver: the role that decides when the agent holds the action.
- Limit: a value, a drift band, or a type of client.
- Second approver: when two people must agree.
- Certificate: the credential the approver must hold, if the firm ties approval rights to certification.
- Never: what the agent must not do, and what no approver may wave through.
The template
| Action | Agent depth | Approver | Limit | Second approver when | Certificate | Never |
|---|---|---|---|---|---|---|
| Draft suitability report | ||||||
| Send annual review letter | ||||||
| Prepare rebalancing trades within model | ||||||
| Place trades outside model | ||||||
| Change client risk profile | ||||||
| Waive or reduce fees | ||||||
| Respond to a complaint | ||||||
| Act for a client showing vulnerability |
A worked example
A hypothetical wealth manager with twelve advisers, three senior advisers and a head of advice. Values are illustrative.
| Action | Agent depth | Approver | Limit | Second approver when | Certificate | Never |
|---|---|---|---|---|---|---|
| Suitability report | 2 | Client's adviser | All clients | Recommendation outside model | Operator | Send unsigned |
| Annual review letter | 2 | Client's adviser | All clients | None | Foundations | Include new advice |
| Rebalance within model | 4, held | Client's adviser | Trades up to 100,000 | Above 100,000, senior adviser | Operator | Trade on a stale fact-find |
| Trade outside model | 2 | Senior adviser | 250,000 | Always, head of advice | Operator | Agent selects the investment |
| Change risk profile | 2 | Client's adviser | All | Always, senior adviser | Operator | Change without a new fact-find |
| Fee waiver | 2 | Senior adviser | 1,000 a year | Above 1,000, head of advice | Operator | Waive to retain a complaining client without review |
| Complaint response | 2 | Senior adviser | All | Always, compliance | Operator | Admit fault in an agent draft |
| Vulnerable client action | 1 | Senior adviser | All | Always, head of advice | Operator | Any automated action |
The vulnerability row sits at depth 1 deliberately. Once an adviser flags a client as vulnerable, the agent may read the file but not draft actions for that client; every step goes through a senior adviser and the head of advice.
Rebalancing within the model is held at depth 4 even though it is routine, because a trade cannot be undone at the same price. The adviser checks that the fact-find is current before approving. If it is over a year old, the trade waits.
Fraud-related actions that cross into advice, such as a client instructing a large withdrawal under pressure, should follow the approver authority matrix for the fraud team. Service requests that do not involve advice can follow the approver authority matrix for the support team. The detailed limits for this team belong in the approver rule for the advice team.
Where the Academy fits
Pryme Intelligence Academy's Operator track trains advisers to review agent drafts against the client file, with tests set in wealth management for advisers. The certificate is valid for 12 months and is listed on a public register by name, credential and expiry, which helps a firm show who was authorised to approve on a given date.
Questions people ask
Can the agent ever give advice directly to a client?
No. It drafts; the adviser decides and signs. If a client asks the agent for a recommendation directly, it should refuse and route the request to their adviser.
Should advisers approve their own clients' trades?
For routine rebalancing within limits, yes. Above the limit or outside the model, a second person adds a check that the adviser's closeness to the client cannot. The skills each role needs are set out in AI agent skills by role.
What if the agent's certificate lapses?
Rebalancing drafts stop arriving at their usual depth and become fully manual or held work until it is recertified. Advisers should know the lapse dates before quarter-end reviews.