The compliance officer, the head of investment operations and the lead paraplanner. In a wealth manager, those three approve or oversee the agent work that carries the most risk: trades and money movements, suitability drafts, and the supervision of both. Advisers and relationship managers come next, once the people checking their agent-prepared work are certified.
Why not advisers first?
Advisers own the client relationship and the recommendation, but agents rarely act in their name first. Agents start behind them: drafting review packs and suitability reports for paraplanners, preparing rebalancing trades and withdrawals for operations, and producing file notes that compliance samples. The held actions land with those teams. Train them first and the adviser receives agent work that has already been checked by someone who knows how.
Who is in each wave?
| Wave | Role | Why | Training |
|---|---|---|---|
| 1 | Compliance officer | Supervises advice and money movements; answers to the regulator | Common grounding plus sampling verdicts and reading the record |
| 1 | Head of investment operations | Releases trades, withdrawals and transfers | Reviewer track with practice on held money movements |
| 1 | Lead paraplanner | Approves agent-drafted suitability reports | Reviewer track with practice on past client files |
| 1 | Chief executive or senior manager responsible | Owns the decision to deploy | Common grounding |
| 2 | Advisers and relationship managers | Sign final reports and client letters | Reviewer track, shorter practicum |
| 2 | Paraplanners and operations staff | Approve day-to-day held actions | Reviewer track |
| 3 | Client service and administration | Take hand-offs | Common grounding |
A training needs analysis confirms the order in your own firm.
What may the agent do, and what stays with people?
- Depth 2: draft review packs, suitability reports, file notes and client letters.
- Depth 3: chase know-your-client documents and book review meetings.
- Depth 4: place rebalancing trades and process withdrawals; held for a named person unless the agent has earned that depth for that capability and the action sits inside the firm's own limits.
- Stays with a person: every recommendation, every judgement about a client's risk or capacity for loss, and every instruction to move money that arrived by email.
An example: a rebalance that broke a client's exclusions
Take a discretionary manager running model portfolios. The agent prepares the quarterly rebalance for each client against the model and holds trades above a set size for investment operations. One client has asked, in a signed mandate letter, to exclude certain sectors. The model now includes a new holding in an excluded sector, and the agent's rebalance buys it. Because the firm's own limits hold any trade that conflicts with a recorded client restriction, the trade is held.
A trained head of operations reads the hold reason, removes the holding for that client and substitutes from the approved list. An untrained operations analyst sees a rebalance that matches the model and releases it. The client finds the holding in their next statement. Investment operations is in wave one because the agent puts these decisions in front of them, not in front of the adviser.
Which rules make wave one matter?
In the UK, the FCA Consumer Duty expects good outcomes for retail customers and the Senior Managers and Certification Regime makes individuals accountable. In the US, the SEC and FINRA supervise advisers and brokers. In each case the firm must show that the people overseeing client work are competent. This is an explanation of the rules, not legal advice; confirm how they apply to you with counsel.
How does the firm show wave one is ready?
A written test and a supervised period of real held decisions with no missed red line, signed off by someone outside the team. A firm can make approval rights at each depth depend on a current certificate. Agent certificates lapse after 90 days and a run that clears no depth drops an agent to depth 1 the same day, so operations must be able to complete a rebalance by hand.
Run a readiness assessment in a wealth manager, then roll the training out across the firm. Compare the order in a bank and a fintech. The full approach is in training teams for AI agents.
Where the Academy fits
Pryme Intelligence Academy issues certificates through VerifyDoc.ai, so the compliance officer can check any reviewer's status at source rather than in a spreadsheet. A lapsed or revoked certificate shows as such on the same page, and the public register lists each certified person's credential and expiry.
Questions people ask
Should investment managers be trained in wave one?
If agents draft trades or model changes for them, yes. Otherwise they can join wave two with the advisers.
What about introducers and platforms?
They do not approve your agent's work. Tell them what your agent does with instructions they send.
How do we cover holiday periods?
Certify at least two people for each kind of held action, especially money movements.