Independent Review

An instruction should not leave the firm on the word of the person who raised it. A review decision records the decision (Approve, Reject or Return), the reason, the reviewer, the time and the version number it applies to. The reviewer is a different team member from the instruction’s owner.

If the instruction changes after submission, the decision on the earlier version no longer applies. The new version waits for its own review. An approval authorizes the instruction only when its counterparty is eligible, so a reviewer’s approval of an ineligible counterparty does not reach the provider.

• Approve. The instruction becomes Authorized and can be submitted to the provider.
• Return. The instruction goes back to the advisor with a reason, for a revised version.
• Reject. The instruction stops, with the reason kept for the client file.

Name the reviewers and their deputies, and confirm that no reviewer approves an instruction they own. Agree what reviewers check: mandate, amount, counterparty eligibility, documents and any limits your policy sets. Decide how quickly reviews must be turned around for time-sensitive instructions such as redemptions before a dealing cut-off.

An advisor submits an instruction to pay $85,000 from a client’s account to a property lawyer for a house purchase. The Compliance Reviewer opens Instructions in Review and finds the attached letter names a different law firm from the counterparty selected. She returns the instruction with that reason.

The advisor confirms the correct firm with the client by phone, updates the counterparty and attaches the call note. The new version comes back for review. The reviewer approves it, and the decision records the version number, reason and time. The earlier return stays in the decision log as part of the client file.

• Instructions in Review — Instructions waiting for a decision, with owner, counterparty, amount and version.
• My Review Decisions — Decisions the signed-in reviewer has recorded.
• Review Decision Log — Every decision with reason, reviewer and version.

• Instruction to confirmation: See where review sits before submission.
• Order to fill: See how trading orders are authorized against the client mandate.

Rehearse access with an advisor account before go-live.