Advice is personal and regulated, so the approver rule is tight. The agent prepares; a qualified adviser decides. Advisers approve client letters and meeting packs they will put their own name to. Anything that changes a client's investments needs the adviser plus a second approver. No approval right survives the lapse of the adviser's certificate.
What does the approver rule cover in an advice team, and who owns it?
In a wealth or financial advice team, the agent helps with the work around advice: gathering client information, summarising meetings, preparing suitability reports, drafting letters and preparing instructions for the platform or custodian. The advice itself, the recommendation to a client, stays with an adviser who holds the right permissions. The approver rule says who may release each piece of agent work, and with what checks.
The head of advice owns the rule. Compliance signs it off and samples against it. The agent owner configures the holds. Our guide to AI agent skills by role lists what an adviser needs to know about agents before approving their work.
What are the steps?
- Head of advice: lists the agent's actions by depth. Depth 1: reads the client file, holdings and fact-find. Depth 2: drafts meeting packs, suitability reports and client letters. Depth 3: books review meetings and sends routine reminders. Depth 4: submits a switch, withdrawal or new investment instruction.
- Head of advice: decides depth 2 approvals. The adviser who owns the client approves drafts that go out in their name. Paraplanners may correct drafts but not send them.
- Head of advice: decides depth 4 approvals. The client's adviser approves the instruction; a second approver checks that it matches the signed recommendation and the client's authority.
- Head of advice: ties rights to certificates. Advisers must hold their regulatory qualifications; the firm can add a current operator-level agent certificate for anyone approving agent work.
- Compliance: signs off and sets a sampling rate for suitability reports.
- Agent owner: configures and files the rule.
| Step | The agent does | Depth | Stays with a person |
|---|---|---|---|
| Read client file | Gathers holdings and fact-find | 1 | Nothing |
| Draft suitability report | Drafts from the meeting notes | 2 | Client's adviser approves and signs |
| Book reviews | Sends meeting invites | 3 | Nothing beyond house rules |
| Submit instruction | Prepares and holds | 4 | Adviser plus second approver |
| Recommend | Nothing | none | Adviser alone |
What must never pass through an agent approval?
The recommendation. An agent can lay out the client's position and the options the firm offers, but choosing among them for a client is advice, and it belongs to an adviser with the permissions to give it. The agent's brief should refuse any request to recommend a product to a named client, and those refusals should be visible in the record.
Instructions to move a client's money need a match against three things before release: the signed recommendation, the client's own instruction, and any authority the firm holds. The second approver checks the match, not the merits. This is what a second approver is for: an independent check on a specific thing.
A client's email asking to sell everything is a declared instruction. It may be real; it may be from someone who has taken over their email. The rule should require confirmation through a known channel before the agent's held instruction is released.
Which controls make the rule work, and what evidence do they leave?
Only the client's adviser approves letters in their name. Evidence: the approver on each sent letter matches the adviser of record.
Two people for instructions. Evidence: two named approvers on each released instruction in the verdict record.
Refusals to recommend are logged. Evidence: refused verdicts naming the scope bound.
Rights lapse with certificates. Evidence: approver certificate status on the date of each approval.
Source shown at approval. The adviser sees whether holdings are sealed from the platform or declared by the client. Evidence: provenance stamps on the draft.
What should you measure?
- Suitability drafts corrected by advisers, grouped by cause.
- Instructions released with one approver. The target is none.
- Refusals to recommend, which show whether clients or staff are asking the agent for advice.
- Time from meeting to suitability report sent, which agents should shorten without loosening checks.
The approver authority matrix for the advice team and the competency matrix for the advice team give the full grid of roles and skills.
Where does it usually go wrong?
Paraplanners become approvers by default. They do the work, so they press send. The rule must state that only the adviser of record releases client-facing advice documents.
The second approver checks the wrong thing. They re-argue the recommendation instead of checking the instruction against it. Make the second approver's job explicit.
Annual reviews are approved in bulk. The agent prepares fifty review packs before a busy month and the adviser releases them in an afternoon. Each pack still goes to one client about their money. If an adviser cannot read a pack properly, it should wait, and the response-time target for reviews should allow for that. The agent's job is to make each pack quicker to read, not to make reading optional.
A single adviser covers a colleague's clients. Cover is fine, but the covering adviser must be named on the client file before they approve.
The rule copies the support team's. Compare the approver rule for the support team: support approvals are about goodwill within limits, which is a different problem from regulated advice.
Questions people ask
Can the agent send a suitability report if the adviser has approved the template?
No. Approving a template is not approving a report. Each suitability report is specific to a client and goes out after the adviser has read and approved that report.
Does the second approver need to be an adviser?
Not necessarily. They need to be competent to check an instruction against a recommendation and an authority. Many firms use a senior administrator or a compliance-trained colleague for this.
What about wealth advisers who work alone?
A sole adviser can approve their own client documents, but should arrange an outside second approver for instructions above a set amount, or keep those instructions as manual work.