The gaps, found before the supervisor finds them
A two-week, fixed-price Readiness Review that identifies the distance between your stated investment policy and your actual client portfolios, so your compliance team reaches the next supervisory cycle with every gap already documented.
The Readiness Review
A pre-supervisory review of client documentation, suitability records, IPS coverage and disclosure posture against FinSA Articles 4 to 14 and the expectations of your supervisory organisation, whether PolyReg, SAAM or AOOS.
The output is the remediation report your compliance team uses to close gaps before the cycle starts. It is not a replacement for the statutory audit or for the internal compliance function: it is the hygiene check that surfaces what the supervisor would find, and your team continues to own the file.
Every portfolio is scored on five pillars
| # | Pillar | What it checks | FinSA |
|---|---|---|---|
| 1 | Client classification and profile | Documented classification, risk profile, horizon, financial capacity, objectives, knowledge and experience, and evidence of annual review. | Art. 4, 6 |
| 2 | Investment Policy Statement | Existence per client, alignment with the risk profile, documented constraints, and the date of last review. | Art. 11 |
| 3 | Suitability per transaction | Every advisory or discretionary trade linked to an IPS clause, with sign-off and an immutable audit trail. | Art. 12–14 |
| 4 | Allocation drift and monitoring | Current allocation against IPS bands, cross-custodian consolidation, documented rebalancing decisions, quarterly review evidence. | Art. 11 |
| 5 | Cost and inducement disclosure | Annual aggregated cost statement, TER aggregation with look-through, inducement disclosure where applicable. | Art. 8, 9 |
Confidentiality. The engine runs on your machine and your data stays where it is. No cloud transit and no copy retained. An NDA and a data processing agreement are signed before kickoff.
Beyond the review
What can follow
Nothing below is a condition of the review, and the review does not commit you to any of it. Each is scoped and priced separately.
Documentation and compliance
- Compliance and documentation foundation. A FinSA-aligned documentation system maintained on an ongoing basis: a client profile and an IPS for every client, a suitability record for every trade for your sign-off, and a monthly one-page compliance summary per client that exports for the supervisory file.
- Workflow diagnostic. A structured two-week assessment of current operating workflows, mapping the three to five most costly, with an ordered automation roadmap and a data privacy and auditability assessment. Taken before any recurring commitment, and credited in full against later work.
Reporting
- Consolidated portfolio report. One monthly view per end-client across every custodian: performance against benchmark, allocation against the IPS on a traffic light, fund and ETF look-through, risk metrics, and the resulting action items.
- Risk and performance report. A per-report deliverable in your own colours and logo, produced from return series you supply: cumulative and annual returns against benchmark, hit rate and streaks, return distribution, drawdown detail, VaR, Sharpe, tracking error and alpha. Delivered as an editable presentation.
Investment work
- Tactical portfolio construction and AMC design. Three risk profiles in your reference currency, every weight argued and every figure dated and sourced: strategic allocation with full instrument selection including ISIN, TER and all-in cost; diversifier sleeves argued chosen against rejected; a protection overlay sized to implied volatility; crisis replays for 2008, 2020 and 2022 against a naive blend; and a ten-year monthly backtest. Delivered as a branded document with a live workbook carrying explicit formulas.
- Treasury and ex-ante risk. For conservative, fixed-income and reserve-style books: value at risk on three methods, expected shortfall, tracking error, duration, convexity, DV01 and key-rate duration, historical replays and reverse stress testing, and fixed-income attribution split into income, curve, spread, currency and selection.
- House view. A monthly macro overlay with the regime signal and its allocation implication by profile type.
Client communication
- Tailored investment communications. Your own investment decisions turned into client-ready notes, in your firm's voice and under its name, at your cadence. Variants by client profile, rationale notes when an allocation changes, and a rapid note within hours of a major move. Every chart and figure sourced. English, French, German and Mandarin. You approve every issue before it goes out.
Greater China
- Client introduction and implementation support. Qualified private-client introductions from a Greater-China network, with optional implementation of the agreed strategy and follow-up communication in the client's language. Your firm retains the mandate, the custody and the relationship; onboarding, KYC and all regulated activity remain yours. An introducer agreement is signed before any introduction.
Live
Three tools, live
Portfolio look-through, performance and risk against a benchmark, and the regime and momentum work behind the house view — the same engines used in the engagements above. The look-through is open to anyone; the other two are client tools and ask you to sign in.
Common questions
| Question | Answer |
|---|---|
| We are covered already. | Statutory auditors come once a year, after the fact. This works the six months before, alongside your compliance team. It replaces neither. |
| How does it run? | Two weeks, on client portfolios of your choosing, all processing on your hardware. Your compliance team holds the report before the audit cycle starts. |
| What is the engine? | Purpose-built: consolidation, look-through, drift detection and tamper-proof signing. Your compliance officer interprets the findings, and every one is reviewed by a practitioner before it reaches the report. |
| And confidentiality? | Engine on your machine, data stays where it is. NDA and data processing agreement before kickoff. No cloud transit, no copy retained. |
Beginning
The usual first step is a demonstration of the methodology rather than a document. Thirty to forty-five minutes, no commitment, and it establishes whether the review would find anything worth the fee before either side commits to it.
Nothing on this page is investment advice or a recommendation to buy or sell any security. Backtested results are historical simulations and are not a representation of future returns. New Way Capital Advisory replaces neither a statutory auditor nor an internal compliance function, and is not a law firm.