Yes. A recommendation is the adviser's, whoever drafted it. When an AI agent prepares a suitability report or a rebalancing proposal, the wealth adviser who presents it to the client or approves the trades owns it. What they do not own is an error in a source they could not see, or bounds set by others. The record shows the difference.
Why does advice stay with the adviser?
Advice is a personal duty to a client. It rests on knowing their goals, their circumstances and their attitude to risk, and on judging how those fit the market. Regulators expect a named person to stand behind it. In the UK, for example, the FCA's Consumer Duty expects good outcomes for retail customers, and the Senior Managers and Certification Regime makes individual accountability explicit.
An agent fits underneath that duty. It gathers the client's holdings, compares them with their target allocation, drafts a rebalancing proposal and a suitability report, and prepares the trades. Placing trades moves money, which is depth 4 work, and stays held.
What may the agent do, and what stays with the adviser?
| The agent | The wealth adviser |
|---|---|
| Pulls holdings and transactions | Confirms the client's current circumstances |
| Compares holdings with the target allocation | Decides whether the target still fits |
| Drafts a rebalancing proposal and report | Approves, edits or rejects it |
| Prepares trades, held for release | Releases them after client agreement |
| Refuses products outside the client's risk profile | Owns any exception, with reasons |
What does the record show about who decided?
Every figure in a proposal carries its provenance. Holdings from the custodian are signed. The client's risk profile from the last review is declared, and it carries a date. An email from the client mentioning a change in their life is declared too, and recent.
When the adviser approves a proposal, the record shows the risk profile it used, its age, any recent client messages the agent flagged, and the adviser's decision. A recommendation built on a three-year-old profile, flagged as stale and approved anyway, is the adviser's recommendation.
An example: the profile that was out of date
Take a wealth manager with a few hundred clients. The agent drafts a rebalancing proposal for a client, moving them further into equities to match the target for a "growth" profile. The profile was set three years ago. Last month, the client emailed to say they were retiring early. The agent flags both the age of the profile and the email, and holds the proposal.
The adviser approves and sends it for signature. The client signs and suffers a fall in value just before drawing income. The record shows the stale profile, the flagged email and the approval. The adviser is accountable for the recommendation. The firm is accountable for whether a stale profile could reach the approval screen without forcing a review.
Which controls fit a wealth team?
- Stale risk profiles block proposals until the adviser confirms them with the client.
- Recent client messages are surfaced next to any proposal.
- Advisers practise on real files through a two-week practicum for wealth advisers, recorded in a practicum log template for wealth advisers.
- Review at each renewal. Agent certificates lapse after 90 days; see how to prepare wealth advisers for 90-day recertification.
Advisers in other fields share the duty of care; compare HR advisers and AI agent mistakes and caseworkers and AI agent mistakes. The wider topic is in AI literacy and certification for people who work with agents.
This is an explanation of the rules, not legal advice; confirm how they apply to you with counsel.
Questions people ask
Can the agent send a proposal to the client directly?
Most firms keep it held, because sending a proposal is part of giving advice. A proposal the adviser has not seen should not reach a client.
Is the adviser accountable for a custodian's wrong valuation?
Not for the valuation itself. If the agent flagged a mismatch and the adviser ignored it, the adviser shares the outcome.
Does the agent's record count as a file note?
It can support one. The adviser should still record their own reasoning, which the record then keeps beside the agent's draft.