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  • Client Profiling

    • DA-1.3.5

      Licensees providing digital financial advice to clients must record the client profile accurately and comprehensively if they are critical and to the extent needed for the algorithms underlying the client facing tool. The licensees must at a minimum:

      (a) obtain information to understand the clients overall financial situation, including sources of regular income, financial returns objective, time horizon, liquidity, legal issues, taxes and any unique constraints;
      (b) obtain information to make assessment of both the customers' risk tolerance, capacity and willingness;
      (c) have a process in place for resolving contradictory or inconsistent responses or advice in a client profiling tool or questionnaire, if any;
      (d) have a process for assessing whether investing (as opposed to saving or paying off debt) is appropriate for the client individual;
      (e) establish a process for contacting customers to update changes to their profile, at least annually; and
      (f) establish appropriate governance and supervisory mechanisms for the client profiling tool.
      Added: April 2019

    • DA-1.3.6

      Due to the nature of digital financial advice tools, much information referred to in the Paragraph DA-1.3.5 will be obtained using questionnaires, which should be comprehensive and fuzzy logic enabled.

      Added: April 2019

    • DA-1.3.7

      Licensees must obtain a declaration from the client to ensure that he understands the scope and nature of digital financial advice and the associated risks and limitations.

      Added: April 2019

    • DA-1.3.8

      Licensees must disclose in writing any actual or potential conflicts of interest arising from any connection or association with product provider, including any material information or facts that may compromise its objectivity or independence.

      Added: April 2019

    • DA-1.3.9

      Licensees must disclose in writing the full particulates of any arrangement, including basis for commissions, charges or fees, involving related parties including parent, associates, fellow subsidiaries and other connected parties.

      Added: April 2019

    • DA-1.3.10

      Any disclosure of information that requires acceptance by the client should be tracked for an acknowledgement or response from the client confirming receipt thereof.

      Added: April 2019