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Avoiding foreseeable harm

Date: 20 August 2025

The change from a world of low interest rates, low inflation, and muted geopolitical risks to a world of higher interest rates, a cost-of-living crisis, and simmering international tensions has helped turn conventional investment approaches on their head.

Meanwhile, today’s regulatory focus, which requires advisers to be more proactive in their pursuit of good customer outcomes, has made life increasingly difficult for those advisers still offering their own in-house portfolios.

This shifting backdrop means many advisers now need to evaluate their existing investment processes. They need to recognise where the risk lies in their businesses, how to manage escalating costs, and improve their profitability, while still delivering positive outcomes for their clients.

Creating an efficient investment process

If you are still managing in-house portfolios for your clients, your first step is establishing an appropriate long-term strategic asset allocation. This requires in-depth analysis, research, and specialist investment tools. The strategic asset allocation is the bedrock for investment returns in any portfolio, so finding that optimal mix of asset classes and investment styles is key to success. 

Once an appropriate investment mix has been decided, it then comes down to screening and choosing the appropriate funds with which to populate each of the portfolios.

Manager selection

To withstand regulatory scrutiny, any investment process will need robust, repeatable practices in place to identify which funds, and which managers, are best placed help the portfolios achieve their objectives. This is where due diligence will need to be evidenced as it is the only way to ensure the right building blocks are selected.

Not being able to demonstrate an understanding of the funds in a portfolio can increase the chances of foreseeable harm for your clients. This is especially important in the context of the Consumer Duty.
Andy Miller Lead Investment Director Quilter

Portfolio construction

The next step is portfolio construction. This means assembling the right constituent parts of your portfolio and instigating a process for tactical overlays that enables you to exploit short-term market conditions or to refine the overall risk levels of the portfolios as market conditions evolve.

Monitoring and oversight

Once you have constructed your portfolios, the requirement to continuously monitor and manage them kicks in. This means identifying any changes to an underlying fund’s management team, its investment process, or its style bias. It also means dedicated performance analysis and a whole host of operational investment and due diligence considerations.

If you offer your clients in-house portfolios, it comes down to managing two significant business risks:

  1. Your clients not being in the right investment at the right time.
  2. Being unable to demonstrate an understanding of the fund mechanics underpinning a portfolio.

Not being able to demonstrate an understanding of the funds in a portfolio can increase the chances of foreseeable harm for your clients. This is especially important in the context of the Consumer Duty.

Process flow chart showing 1. Asset allocation, 2. Manager selection, 3. Portfolio construction, 4. Monitoring and oversight and 5 Portfolio rebalancing.

The Consumer Duty challenge

The challenge for every adviser is to evidence that your business is actively looking to deliver the very best outcomes for your clients. From an investment perspective, this means detailing your process at a much more granular level than before.

For example, the Consumer Duty requires advisers operating their own portfolios to detail and rationalise any funds that have been added to, or removed, in the last 12 months. It also requires full disclosure of the governance arrangements that are in place, including minutes from the meetings covering each fund going back 12 months.

For most advisers, this level of forensic investment analysis, continuous monitoring, and ongoing governance is not possible due to the financial and time costs involved.

Outsource or build your own?

All of this points to just a couple of realistic options for advisers operating their own portfolios:

  1. Invest in a highly disciplined, well-resourced, in-house investment process, with appropriate fund research, due diligence, governance, and reporting capabilities.
  2. Outsource your investment process, the regulatory risks, and the added costs it represents, to a recognised investment manager.

If you pursue the first option, ensuring that your investment process meets all Consumer Duty requirements, and that it remains aligned with an ever-evolving regulatory landscape, is not an easy task. The pace of regulatory change has become relentless.

Ultimately, avoiding foreseeable harm is not about predicting the future, it is about anticipating what could happen, and having the right procedures in place to act effectively, when things go wrong.