Choosing a platform that can support you in delivering a tailored investment solution for your clients is vital. A comprehensive suite of tax wrappers and wide range of investment options is important to offer the right amount of flexibility, to help you manage your clients' portfolios without compromise. While pricing is important, adviser firms should look for 'value' when it comes to a platform.

    Do you offer access to a range of wrappers on your platform?

    On platform we offer access to a Sipp, Isa, Junior Isa, general investment account (GIA), onshore bond and offshore bond.

    Do you offer a fully supported range of trusts?

    Yes, we offer a range of trusts specifically designed for platforms that have been approved by external counsel and supported by Technical Connection, who provide free access to their online Techlink service for platform users - https://nucleusfinancial.com/support/techlink/ .

    Do you offer a range of wrappers designed to provide income to meet the needs of my clients including flexi-access drawdown, capped drawdown, uncrystallised funds pension lump sum (UFPLS) and annuities?

    We offer flexi-access drawdown and capped drawdown options but we don't offer UFPLS. Flexi-access drawdown offers a range of income options for clients.

    Are all wrappers fully embedded on the platform or are they external third-party wrappers not available on the platform?

    All investment wrappers are fully embedded on the platform.

    Can I carry out inter-account transfers?

    Yes, this is available between GIAs and Isas for an individual investor and also between investors. For pensions, an inter-account transfer can be used when tax free cash is to be moved to another account, held by the same investor. The inter-account transfer feature can move assets from one account to another in-specie, and cash holdings can also be moved from one account to another. A transaction history is recorded on both accounts.

    Do you provide Bed and Isa functionality?

    Yes, Bed and Isa functionality is available. This gives the user the option to sell assets from a client’s GIA and buy into their Isa in one transaction. Our trade-on-trade capability allows two Bed and Isas to be keyed at the same time.

    Can I apply a common model portfolio across all wrappers?

    Yes, each client wrapper account can be aligned to a common model portfolio when the account is first created, and on an ongoing basis.

    Can I rebalance investments proportionately and easily online across all wrappers?

    Yes, proportionate rebalancing can be scheduled to run on a date and period specified by the user or can be performed ad-hoc by selecting the 'Rebalance today' option. This can be applied across specific accounts or all client accounts.

    Can I run multiple investment portfolios within one wrapper? Is it possible to obtain a report both on an individual and consolidated basis for model investment portfolios?

    Only one model investment portfolio can be held within each account. However, you can create multiple accounts within a wrapper, apportion the money appropriately and apply a different model investment portfolio to each account. Client reporting can be done either at the individual account level or aggregated at client level via our Narrate client reporting tool.

    Is the new business process for each wrapper on your platform and not on an external or third-party website (regardless if there’s a portal to an external location or not)?

    The new business process is fully embedded on the platform. Features include the ability to apply for more than one wrapper within the same application and instruct re-registrations as part of the new business process.

    Do clients pay any additional charges to any of the wrapper providers that are deducted from money in the wrapper?

    The only additional wrapper charge is for the Nucleus offshore bond account which is subject to an initial charge of £100.

    If I asked you to add a product or service you don’t currently offer, would you investigate and discuss my request?

    Yes, we discuss all requests received. If the development of new products and features is an area you’re interested in, we’ll invite you to join our platform development group. Our proposition has been designed from day one based on adviser requirements. This makes our approach for researching and prioritising developments somewhat unique. Although we monitor what our competitors do, our main driver is user demand, led by those who use the platform. We believe this is a key reason for our proposition receiving high ratings by advisers; because it’s designed by the people who use it.

    What plans do you have to widen your product range beyond investment products?

    We have plans to expand the platform infrastructure beyond traditional investment products. Using the same core philosophy of wrapping investment products but widening the use of technology to provide a deeper range of services needed by advisers and their clients.

    Does your platform offer access to cash products, Oeics, unit trusts, offshore funds, structured products, listed securities including ETFs and investment trusts, VCTs, gilts and corporate bonds?

    Yes, we offer over 5,000 investment funds on the platform including Oeics and unit trusts along with a wide range of investment trusts, ETFs, VCTs, bonds, structured products, equities, offshore funds (denominated in sterling) and interest paying cash products.

    Do you provide full fund open architecture? Would I be able to construct and manage the investment portfolios and specific assets I have supplied without compromise on fund choice or asset type?

    We do have full fund open architecture and if we don't currently offer any assets within your chosen portfolios we're happy to consider adding them, subject to UK regulation and our own internal policies. Our service standard to add an exchange-listed asset is five business days. The asset range is restricted to GBP priced and traded assets only, and in the case of exchange-listed assets must be tradable on the London Stock Exchange Main or AIM markets.

    Can I request for new assets to be added to the platform? If yes, what is the turnaround time for assets being added?

    Yes, we can add a new asset to the platform, subject to UK regulation and our own internal policies. Our service standard to add an exchange-listed asset is five business days. The asset range is restricted to GBP priced and traded assets only, and in the case of exchange-listed must be tradable on the London Stock Exchange Main or AIM markets.

    Can I set up and manage model portfolios?

    Yes, model investment portfolios can be created and managed on the platform.

    Describe the model investment portfolio functionality available

    We provide access to a model investment portfolio self-service tool to allow advisers, and DFMs when required, create and maintain model portfolios. There’s no restriction to access or how often portfolios can be rebalanced. Users have a range of access options to manage portfolios, either across an entire book of business, segments of clients, or individual clients. Our investment analysis tool also allows deeper analysis of funds and model portfolios.

    Can the model investment portfolios be applied across all client wrapper accounts?

    Yes, assuming the chosen assets are allowed in all wrappers, the model investment portfolio can be applied across all client accounts.

    Can model portfolios be rebalanced automatically at pre-determined intervals including quarterly, half yearly and yearly?

    Yes, automatic rebalancing can be set up to occur monthly, quarterly, half yearly or annually.

    Can model investment portfolios be managed on a bulk basis across a group of clients?

    Yes, either you or your chosen DFM can reallocate or rebalance all of your model portfolios across all, or a selection of your clients with just a few clicks.

    Do you offer an in-house range of packaged solutions (central investment propositions (CIPs), centralised retirement propositions (CRPs), multi-asset funds, multi manager funds etc)?

    No, we don't offer an in-house range of packaged solutions at this time.

    What due diligence do you carry out on assets you make available on your platform?

    We carry out operational due diligence to make sure the asset can be serviced and meet its trading, settlement, corporate action obligations, and comply with our asset manager agreement. We also validate the asset is permissible for specific product wrappers, such as Isa eligibility, and we have an asset acceptance policy in place.

    What is the average turnaround time for a re-registration on and off your platform?

    Where both parties have adopted electronic re-registration via Origo Options and offer the same share classes, the re-registration request will be made within one business day. Where it’s on a manual basis the request will be made in two working days. The full transfer process will vary depending on the details provided on the documentation but we follow a strict follow up process to accelerate the transaction and users can check the progress via the ‘in transit asset report’ available on our platform. Our experience shows the Origo process can happen in two to three weeks (subject to accurate details) while the manual process may take four to six weeks for completion.
     
    We have championed the Origo Options electronic re-registration and offered the facility since it was available in mid-2013.

    Can I re-register assets to and from every type of share class through your platform?

    Yes, we operate re-registrations to and from all available share classes. Where a specific share class is not listed on the platform this can be requested to enable re-registration and if the asset manager permits access we will add the share class for re-registration. We will register any share class off the platform where it can be received by the acquiring party.

    Can you describe any restrictions or process differences relating to re-registrations of assets to and from different share classes you have?

    There are no differences in our processes across share classes. On occasion, an asset manager will not permit access to certain share classes which will prevent any re-registration, and in these cases the asset will need to be sold or switched to an acceptable share class at the ceding scheme or product before transferring.

    Do these differences carry any tax (for example capital gains tax - CGT) issues for my clients?

    Any switch or conversion between share classes could carry CGT implications, you should refer to the transferring scheme or provider to check.

    Can I use (insert chosen DFM) through your platform?

    There’s a selection of around 50 DFMs available on the platform. If there’s a DFM you work with who isn’t currently on the platform we’ll enter into discussions to add them, subject to agreement between both parties.

    If yes, can the selected DFM operate discretionary investment portfolios directly on the platform or does client money need to be sent to their custodianship?

    DFMs are provided with access to our platform to allow them to manage their discretionary portfolios directly on the platform. We retain custody of the client assets and cash.

    If client money is sent to the DFM’s custodianship, how is client reporting and valuation done through the platform?

    This doesn’t apply. DFMs are provided with access to the Nucleus platform to allow them to manage their discretionary portfolios on platform.

    If client money isn't within the DFM’s custodianship, how is the performance of the DFM funds reported?

    The performance can be reported by using Narrate, our award-winning client reporting tool, or our investment analysis tool.

    What arrangements need to be put in place for the adviser to use the DFM service through the platform and how does this respect the relationship I have with my client?

    These are the steps for adding a DFM:

    • Adviser DFM request received by Nucleus.
    • Detailed discussions between Nucleus and the adviser to agree the specific requirements.
    • Bipartite agreement is completed between Nucleus and the selected DFM.
    • Nucleus initiates the onboarding and training process to allow the DFM to manage their portfolios on our platform.
    • Access to the platform is provided to the selected DFM to manage their portfolios.
    • The requesting adviser has oversight of client money and assets.

    Do you levy any platform charges for using a DFM over and above the DFM charge?

    There’s no additional platform charge over and above the charge agreed between you and your chosen DFM.

    What due diligence do you carry out on the DFMs you make available on the platform?

    We make sure all DFMs have the relevant permissions to manage money and assets on a discretionary basis.

    Can your platform take on the reporting requirements for DFMs following implementation of the Mifid II rules, particularly the 10% drop report?

    For any advice firms with discretionary permissions, we can put in place a transmission agreement taking on the transaction reporting obligation. Client reporting is the responsibility of the adviser. Advisers and DFMs can download a report from the platform which provides details of any drop in value of a client's discretionary portfolio held on our platform within the current reporting period. Should your client's portfolio drop by more than 10% your client must be notified the same day.

    How are the investment charges presented and in what format?

    Investment management charges are presented in a Mifid II compliant way. The ongoing, incidental and transactional costs are combined to provide the total cost of ownership. This is displayed as a percentage.

    Are there any exit penalties charged by your platform or the DFM?

    No, we don’t charge any exit penalties, however some DFMs may do so. You should check this with the DFM.

    Can my clients access the platform? If so, is this full or limited access?

    You can grant your clients access to Nucleus Go, our fully mobile responsive client portal. It allows clients to view their portfolio, transaction history and important correspondence at any time.

    Can my clients trade on the platform (without the need for any adviser input)?

    No, only advisers can trade on our platform.

    Can I restrict client trading on the platform?

    Clients are unable to trade on the platform.

    Can the client view be dual branded with my firm’s logo?

    Yes, this is offered on our client portal, Nucleus Go, at no extra charge.

    What support do you offer my clients e.g. telephone support?

    We always recommend clients speak to you first, but client telephone support is available as is our client portal, Nucleus Go which is supported by Live chat.

    Do you offer a direct to consumer (D2C) proposition?

    We always support the valuable adviser and client relationship and don’t have a D2C proposition. We only accept new clients who have a relationship with an authorised and regulated advisory firm.

    What is your core platform charge?

    The platform charging structure is designed to be transparent and simple for clients to understand. Charges are applied in tiers depending on the level of client assets. The tiers are:

    Client holding Charge on tier:
    Up to £499,999.99 0.35%
    £500k to £999,999.99 0.175%
    £1m upwards 0.05%

    The 0.35% charge is accrued daily and debited from cash each month. Any rebates associated with larger portfolios are credited monthly. Please note the charge applies on a tiered basis, for example, if a client has a portfolio of £0.8m the charge on the first £500k will be 0.35% and 0.175% on the remainder.

    What additional or transactional charges apply?

    Our transparent and simple charging structure means we don’t have:

    • Initial charges
    • A minimum platform or wrapper charge
    • Fund switching charges – we believe clients should be able to move assets freely without financial penalty
    • Exit charges - we make no charges for re-registering off the platform and are committed to the free movement of assets
    • Model portfolio charges
    • Sipp or pension establishment charges
    • A charge for going into drawdown


    We do have a family discount for husband and wife, civil partnerships and cohabitees.

    The Nucleus offshore bond account is subject to an initial wrap charge of £100 and an additional annual wrap charge of 0.15%.

    The Nucleus onshore bond account is subject to an additional annual wrap charge of 0.10%.

    Market traded instruments including equities and ETFs are subject to a transaction charge of 0.035% of the value being traded, subject to a minimum of £3.50 per trade. These charges are made by our stockbroker, Winterflood.

    Depending on the asset, there may be an initial and/or annual charge determined by the asset manager.

    For more information, please see https://nucleusfinancial.com/platform/#nlink-charging-structure

    How competitive are your charges for Isa and Sipp portfolios of (insert preferred values)?

    Here’s the range of charges, based on a 60% / 40% split in Sipp / Isa, with 30 fund trades per year

    Portfolio size Blended percentage charge (%) Approximate £ charge
    £25,000 0.35% £87.50
    £50,000 0.35% £175.00
    £75,000 0.35% £262.50
    £100,000 0.35% £350.00
    £150,000 0.35% £525.00
    £200,000 0.35% £700.00
    £250,000 0.35% £875.00
    £500,000 0.35% £1,750.00
    £1m 0.26% £2,625.00
    £2m 0.16% £3,125.00

    We do not charge for switching, trading funds, rebalancing, transferring in or out, using model portfolios or moving into drawdown.

    When considering core charges plus additional or transactional charges, how does this change your competitive position on price outlined in the above question taking into account typical portfolios of 25 funds rebalanced quarterly?

    As we don’t have additional or transactional charges for fund rebalancing, this has no impact on the above charges.

    What is the total number of different charge types you may apply to clients using your platform?

    There are only three possible charges for using the platform:

    • A platform charge ranging from 0.05% - 0.35% depending on wrappers used and assets held. The Nucleus Offshore Bond account is subject to another charge of 0.15%. The Nucleus Onshore Bond account is subject to an additional annual wrap charge of 0.10%
    • A £100 initial charge if opening an offshore bond account
    • Charges for using market traded instruments of 0.035% of the trade or £3.50 minimum, although they are aggregated across all clients appropriately on each trade. These charges are made by our stockbroker, Winterflood

    Can you please supply copies of all relevant literature containing descriptions of all platform charges you have?

    Can you please provide written confirmation that, regardless of what actions my clients take on their portfolio, there are no additional charges you could levy to those you have included in the calculations and information you have provided above?

    “I can confirm the charges we have told you about are the only ones we have. It’s always been our core philosophy to encourage transparent and predictable client charging. For this reason, our charging structure has been deliberately designed so it doesn’t contain lots of extra event-driven charges. We don’t charge clients to switch funds, move money on to the platform or indeed to withdraw their money and I can give you my assurance we don’t intend to start.
    I believe our simple structure, which contains only three potential charge types to clients depending on what wrappers and assets they use, genuinely allows you to compliantly predict the cost of using Nucleus to your clients regardless of how their financial needs might change in the future.”
    David Ferguson, CEO, Nucleus

    What criteria are required for you to offer non-standard pricing?

    We have no set criteria for this, however this is something we may explore in the future.

    The platform’s business model, financial position and culture are important considerations when carrying out due diligence. 

    Taking a closer look at the platform's balance sheet helps form a picture of their commitment to the market in the longer term, and their future aspirations for investment in the platform and growth of the business.

    As a platform will be intrinsic to your strategic proposition, it should integrate seamlessly into your business which is where culture is an equally important consideration alongside profitability and financial strength.

    What is the profit/loss of specifically your platform business (and not a parent company) over the past three years?

    We are a platform business, and therefore reference our group results. We achieved profitability in 2012 and have delivered a profit every year since. Our full-year profit after tax over the past three years is:

    2017: £4.1m
    2018: £4.8m
    2019: £6.0m

    When did you reach profitability and has this position been sustained?

    We have delivered a profit every year since 2012.

    Can you supply the past three years’ accounts of your platform business including the allocation of central or shared costs?

    Our last three years accounts can be viewed at https://nucleusfinancial.com/investors/

    If the platform is loss-making, what is the anticipated level of assets and date for breaking into profit?

    This doesn’t apply as we’re already a profitable company.

    What are the key risks to this plan to make profit?

    This doesn't apply as we're already a profitable company.

    Once in profit, how long will it take to repay all previous costs and losses the platform has sustained?

    This doesn’t apply as we created a new platform operating model which allowed us to become profitable and remain competitive on a fraction of the capital base of our competitors. We’re an AIM quoted, debt-free and profitable company.

    Can you guarantee in writing the board is 100% behind the platform and have never discussed withdrawing from the UK market?

    We’re a profitable, standalone wrap business and our board is 100% committed to continue growing our business in the UK.

    Does the platform pre-fund any investments such as regular contributions, switches, pension tax relief and withdrawals?

    Yes, we pre-fund pension tax relief as standard. For switches, rebalances and Bed and Isa we operate on a ‘switch on confirm’ basis.

    What are the capital adequacy requirements, regulatory capital structure and capital surpluses of Nucleus?

    Please see our Pillar 3 statement for details on our capital adequacy position.

    https://nucleusfinancial.com/investors/

    Is your platform subject to a cross-subsidy from your wider group of businesses?

    No, we're a standalone, profitable business and don’t rely on cross-subsidy from a parent company.

    To what extent does your business modelling make allowance for any future downward pressure on pricing?

    We’ve modelled various scenarios within our business plan and have a clear strategy for adapting to changing market conditions and the continuing development of the wrap market. In July 2017 we introduced a price cut for all new and existing clients for portfolios greater than £500,000. The cut was made from a profitable position and it’s our strategy to ensure we continue to be one of the most cost-effective platforms in the UK, for all portfolio sizes and types.

    Can I speak directly with your finance director / chief financial officer?

    Yes, it’s our philosophy to ensure all member firms have access to our senior management team. Our CFO is Stuart Geard who would be happy to answer any questions you have about our business model.

    Do you expect any changes in ownership or capital structure (for example IPO or sale) within the next five years? If so, what details can you share?

    In 2018, Nucleus was admitted to the AIM market of the London Stock Exchange. This was done to introduce a more mature, simplified capital structure, to unwind residual obligations from the start-up shareholders agreement, and to offer shareholder liquidity.

    Can you provide a breakdown of your board of directors and executive team, as well as key committee structures?

    Yes, these can all be found online at https://nucleusfinancial.com/investors/

    Does the firm have any material exposure to current unresolved litigation or regulatory action?

    To our knowledge and as at 30 September 2020, Nucleus has no material exposure to unresolved litigation or regulatory action.

    What was the percentage split of your revenue (based on the past three year’s accounts of your platform business) between fixed and event-driven charges?

    It was 100% from fixed charges.

    What is your average basis point client charge and how is it divided between fixed and event-driven charges?

    Taking all charges into consideration it approximates to 0.298% and is 100% derived from fixed charges. This is based on data from our 2019 full-year report and accounts.

    Do you model the impact of stock market fluctuations on assets and consequently revenue inflows on profitability and sustainability? If yes, can you share these findings?

    Yes, the group's capital requirements are reviewed on a quarterly basis and are also subject to periodic stress testing to evidence that its regulatory capital requirements can continue to be met in a range of stressed scenarios (including macro-economic shocks, company-specific shocks and a combination of simultaneous internal and external shocks). Our platform fees are subject to asset levels, which are a function of net flows of assets under administration (AUA) to or from the platform and market movements. We benefit from a base AUA at the beginning of each financial year which is usually complemented by net positive inflows, providing the board with comfort and future revenues.

    What percentage of your book is non-advised clients i.e. orphan clients or D2C?

    We have 0% as direct clients, and a very small number of orphan clients.

    Do you retain any income received from fund managers?

    No, all fund manager rebates are returned to the client.

    What level of income was this in each of the past three years?

    This doesn't apply.

    Do you sell advertising space on your platform or marketing / sponsorship opportunities to third parties including access to your adviser and client database?

    No, there’s no advertising of third parties on our platform, website or marketing material.

    What level of income has been achieved from this over each of the last three years?

    This doesn’t apply as we don’t sell advertising on our platform or website.

    Do you retain any interest from client cash held on the platform?

    No, all interest is returned to the client.

    How much revenue is generated from interest not paid to client cash accounts?

    No revenue is generated as all interest is returned to the client.

    What percentage of overall revenue does this constitute?

    The revenue is 0% as all interest is returned to the client.

    How much revenue is generated from in-house fund solutions?

    Nil, we don’t offer our own funds.

    What percentage of the platform’s assets are held in in-house funds?

    It is 0%, as we don’t offer our own funds.

    What percentage of overall revenue does this constitute?

    It is 0% of revenue as we don’t offer our own funds.

    Is there an expectation platform users will adopt your own investment solutions?

    This doesn’t apply as currently we don’t offer our own investment solutions.

    Will the CEO provide a 100-word description of your corporate culture to help us with this exercise?

    Our purpose has been the same since day one, to transform financial services for the better. We've built a truly customer-centric business model, putting advisers and clients at the heart of everything we do. This builds a framework around which all of our decisions are made, and provides a compass for our direction of growth. Our transparent, customer-centric culture mitigates the potential impact of future regulatory changes as our customers’ needs come first in all decisions. Our culture is defined by four values; authentic, accountable, energetic and inspiring, and it's by these values that we hold ourselves to the highest standards.

    David Ferguson, Founder and CEO

    Is your CEO and senior leadership team available for a telephone call or face-to-face meeting at relatively short notice (within reason)?

    Yes, it’s our philosophy to make sure all member firms have access to our senior management team.

    Can you evidence everything you do is in line with my values as an adviser?

    Nucleus is an adviser-led business meaning everything we do is guided by our users. The platform has been designed with a high level of adviser input to offer a robust wrap which enables users to define and administer a diverse range of propositions to different client segments. This approach means our functionality is aligned with what quality advice firms require to ensure their chosen platform continues to keep pace with their own evolving client requirements. Our developments are designed in conjunction with, and the approval of, our adviser platform development group.

    Our ethos is to help improve the administration efficiency of our users to enable them to focus their time and energy on providing additional ‘value added’ services to their clients.

    Given how intrinsic your platform would be to my business model, please explain what channels I have to influence the direction of your platform?

    As a user of our platform, we’d invite you to join our adviser community and to share resource and information with other like-minded advisers supported by our events team and various industry experts. We hold a range of ‘community’ events each year to allow users to share feedback and best practice, helping to shape our platform proposition and the service and support we provide to users. These include:

    Adviser strategy groups:

    • Quarterly advisory board
    • Quarterly practice management group
    • Quarterly platform development group

    In addition to regular meetings of the groups mentioned above, our annual programme includes:

    • Bi-annual user sessions
    • Bi-annual Illuminate live training events
    • An annual conference
    • Illuminate masterclasses

    Our diary of events is driven by advisers and is based on what they tell us adds most value to their business and for their clients. These events act as an opportunity for advisers to make contact, share practices, learn from industry experts and each other.

    What is the process for gaining an agency to use the platform? What do you consider in a potential firm and why do you have these processes?

    Since day one, we’ve applied targeted acceptance criteria when recruiting new users, with a view to attracting advisers that might generate meaningful inflows but are also ethically and operationally aligned to us. We target mid-market, directly-authorised, dynamic and growing advice firms with between two and 50 advisers, at least £25 million in ‘wrappable’ assets and a high-quality client base. This approach has resulted in many mutually beneficial partnerships being formed, letting us develop our platform to meet the needs of solid, scalable advice firms, who have a commitment to transparency and a desire to use technology to streamline their operations.

    Do your terms and conditions respect the relationship I have with my client?

    Yes, our terms and conditions are written to fully acknowledge and respect the valuable relationship advisers have with clients. For example:

    You and your adviser section
    We will deal with you if you have a relationship with an Adviser Firm, and as such you should be aware if you choose to  change your Adviser to someone working for a firm that does not have access to the Nucleus wrap, or you decide not to use an adviser, we will not be able to offer you full access to the Accounts and Services.

    Opening an account section
    If you wish to have access to your Account online, this can be done as part of the Application or once your Nucleus wrap has been opened, by contacting your Adviser.

    In what circumstances would you market directly to my clients or reserve the right to market directly to my clients?

    We have no clauses in our terms and conditions allowing us to market directly to clients and have no intention to do so. We value and absolutely respect the adviser / client relationship.

    What percentage of your direct clients used to be under an adviser on your platform?

    We have a small number of orphaned clients (as at 31 October 2019 this was 1.9% of our total client population).

    What routes do you provide for clients to move direct to you?

    We’ll only accept new clients who have a relationship with an authorised and regulated advice firm.

    What is your policy on orphan clients?

    Our terms and conditions state “Where you do not have an Adviser you will be deemed a ‘non-advised’ client which means Nucleus will not be able to offer you full access to the Accounts and Services.” We regularly communicate with our orphan clients to remind them of the restrictions applying.

    Prior to FCA PS13/1, the onus of evidencing platform regulatory compliance was on the platform itself. The onus is now on the adviser firm to make sure their platform complies with the relevant FCA policies and Cobs rules. Advisers are faced with an ever-changing regulatory landscape, with Mifid II, GDPR, Prod rules and the senior managers' regime to name but a few changes in the past few years.

    This makes it more important than ever to carry out regular due diligence on platforms to avoid falling short of regulatory requirements, particularly if you work with a single platform for the majority of your client business. Advisory firms should not use a platform unless satisifed it complies with relevant FCA policies and Cobs rules.

    Do you clearly disclose the total platform charge in a durable format including all platform, wrapper and event driven charges that may take place?

    Yes, we fully disclose our explicit charges and relevant wrapper charges pre-sale on the terms and conditions, key features and pre-sale illustration. Post-sale the charges can be found on quarterly statements, the annual statement of costs and charges and online at any time.

    Can you show you present investment products without bias, including how they are displayed and selected on your platform or sit within your overall promotional approach including website and literature?

    The selection of investment products on the platform is entirely free choice and sorted alphabetically, numerically, by asset class or rating. We don’t promote any assets, allow fund managers to advertise on our platform, or have any form of commercial involvement with fund managers. We’re entirely agnostic in terms of the assets advisers and their clients use.

    Do you cross-subsidise platform charges with fund charges (if you are also the asset manager)?

    This doesn’t apply as we don’t manage our own funds.

    What assurance can you provide that you haven’t offered better distribution to any asset managers in return for preferential fund pricing through your platform?

    We can give you absolute assurance we’ve never followed a strategy of offering distribution for lower prices, and there’s no favouritism towards certain assets or asset managers. We provide a list of assets, with prices, via our platform.

    Do you accept payments from fund managers for promoting their products?

    There’s no promotion of assets on our website, platform or marketing material, all of which can be viewed here - https://nucleusfinancial.com/.

    Do you incentivise your sales staff differently in relation to assets depending on who the provider is?

    No, our sales team incentivisation and rewards programme is entirely agnostic of asset type.

    Please confirm when your last supervisory visit was by the FCA/ PRA and confirm any key issues arising.

    To date we have only been subject to regular supervisory visits, and we keep very open channels of communication with the FCA.

    Please describe any disciplinary proceedings made against you.

    We’ve had no proceedings against us since we launched in December 2006. You can validate this independently via the FCA register - https://register.fca.org.uk/.

    Is your platform a suitable vehicle for my clients who are in different life stages, for example those in accumulation and decumulation?

    Yes, since launch advisers have been using our platform to help manage clients in accumulation and decumulation life stages. For clients in the accumulation stage we provide access to a range of assets to suit client needs in relation to risk, asset and fund allocation. Also, we offer a range of savings and investments wrappers, to help advisers achieve the optimal tax treatment for their clients. Our range of portfolio management tools allows users to effectively manage accumulation portfolios.

    We provide easy access to suitable assets for clients in the decumulation life stage. Our pension tax wrapper is split into accumulation and decumulation accounts, the latter includes flexi-access, phased and capped drawdown. We make no additional charges for either capped or flexible drawdown. We also provide a pension income report for each client to help advisers establish how much income is currently being paid or is available for an individual client.

    Portfolio decumulation is a key area of focus and development for platforms and in 2019 we delivered automated phased drawdown. This provided the functionality to allow efficient online management of the frequency, amount and payment date of income from any active phased drawdown.

    Do you provide customers in a decumulation stage with easy access to their money across their on-platform wrappers?

    Yes, it’s easy to take money off our platform. Our philosophy is to make taking an income easy and our wrappers allow straight-through-processing income set-up at the new business stage, or easily at any time subject to the wrapper type e.g. pensions and bonds have specific withdrawal tax-related rules.

    Are there any circumstances where it’s easier to contribute than to withdraw money from the platform?

    Where regulations allow we always make the ability to withdraw money from a platform account as straightforward as making contributions.

    Do you make any charges for withdrawals?

    No, we don’t and have never made any charges for withdrawals.

    Does your charging structure disproportionately favour any particular size of portfolio?

    No, we’re one of the most cost-effective platforms in the UK across all portfolio sizes and the structure is tiered to ensure this is the case. We carry out regular market reviews of pricing trends to maintain our cost-effective position.

    Are the planning tools you offer designed more specifically for some life stages than others?

    No, we don’t offer planning tools and feedback from our users shows a preference to use independent tools before placing business on the platform. We monitor the demand for advice planning tools and are open to adding them to the platform.

    If you offer managed investment strategies, do they cover different life stages as well as attitudes to risk?

    We don’t currently offer managed investment strategies but this is an area we’re currently exploring in terms of expanding our proposition.

    How can I identify and manage my different client segments on your platform catering for their different needs?

    You can use our platform to execute and manage different client risk profiles segments into appropriate model portfolios and this can also be easily designated to a DFM. Additionally, you can implement and manage different segments of charging structures and our rich range of modifiable reporting supports this.

    What upfront, ongoing and summarised costs and charges information are you providing to help my clients?

    We provide an annual statement of costs and charges to all clients and an online adviser tool will be available in 2020 to allow ad-hoc reporting, showing the breakdown and total cost of investment for each client. Charges will be displayed in percentage and monetary terms and the report can be shared directly with clients.

    Do you produce an annual costs and charges statement in line with Mifid II regulations?

    Yes, the first statements were produced in April 2019 and will be issued every February from 2020 onwards.

    Are the annual costs and charges provided in both monetary and percentage terms?

    Yes, the costs are disclosed in percentage and monetary terms.

    Can the costs and charges information be produced by the adviser on an ad hoc basis?

    Yes, advisers will be able to run these at any time via costs and charges reporting tool, which will be available in 2020.

    What information do you provide regarding a fund’s target market?

    Fund target markets are provided by the asset manager and are included in the fund factsheets. Our platform library also shows Mifid II target market information for assets.

    How do you identify a product’s target market?

    We’ve a clear picture of the target market clients we expect advisers to place on the Nucleus platform and into each of the available wrappers. We monitor this position via an annual product review to establish if clients investing in products are outside the target market.

    How does your platform help advisers with their discretionary transaction reporting requirements?

    For any advice firms with discretionary permissions, we offer a service to put in place a transmission agreement taking on the transaction reporting obligation.

    How frequently will client statements be produced?

    Client statements are produced on a quarterly basis. The reporting periods are:

    • 6 April – 5 July
    • 6 July – 5 October
    • 6 October – 5 January
    • 6 January – 5 April

    How are falls of more than 10% communicated to advisers, DFMs and clients?

    Advisers and DFMs can download a report from the platform which provides details of any drop in value of a client's discretionary portfolio held on the Nucleus platform within the current reporting period. Should a client's portfolio drop by more than 10% the client must be notified the same day.

    How does your platform help me ensure the products and service is suitable for my target market? How does your platform meet the requirements for each of my client segments?

    Since launch advisers have been using our platform to help clients in accumulation and decumulation life stages. We’re a retail platform and have a strategy of only adding assets we’re satisfied meet our strategy for our target audience.
    For clients in the accumulation stage we provide access to a range of assets to suit client needs in relation to risk and asset allocation. Also, we offer a range of wrappers, so advisers can achieve the most advantageous tax treatment for their clients. Our range of portfolio management tools allows users to effectively manage accumulation portfolios.
    We provide access to assets for clients who are in the decumulation life stage. Our pension wrapper is split into accumulation and decumulation accounts, the latter including flexi-access, phased and capped drawdown. We also provide a pension income report for each client to help advisers establish how much income is being paid or is available for each client.

    Portfolio decumulation is a key area of focus and development for platforms and in 2019 we delivered automated phased drawdown. This provided the functionality to allow efficient online management of the frequency, amount and payment date of income from any active phased drawdown.

    Is your platform clear about which type of clients would be considered most suitable, in terms of wealth, functionality requirements and the range and type of wrapper and investments offered?

    We’ve clear target market definitions for our platform and each of the available wrappers. This is based on a combination of wealth, life stage, financial sophistication and propensity to use financial advice. We monitor this position via an annual product and client review to ensure there’s no drift in the suitability of clients being added to our platform.

    Can your platform describe the client monitoring it undertakes to ensure clients are aligned with the identified target market?

    An annual product and client review is undertaken to ensure there’s no drift in the suitability of clients being added to the platform.

    If there are a significant number of clients outside this target market, what action does your platform take?

    Internal investigations into any advice firm with a significant book of ‘non-target’ clients are undertaken, and (if required) the results will be raised directly with the firm. Conduct requirements mean we have a responsibility to monitor activity and recognise taking a ‘that’s not our responsibility’ attitude isn’t satisfactory in the eyes of the regulator, or for end clients.

    Have you made any changes to your platform proposition in response to the Prod rules?

    No, we haven’t had to make any changes to our proposition. However, we have increased our monitoring and data mining of the types of clients being added to the platform, and the wrappers used to ensure alignment with our identified target market. We’ve strengthened our product approval process to support the adviser suitability process. Our annual product and client review process has been improved and we've also embedded a customer-centric culture, with product governance recognised as a management competence.

    Have you removed any products from your platform in response to the Prod rules?

    No, we aren’t burdened by a significant volume of legacy products, therefore there has been no need for us to remove any products from our platform. We focus on mainstream retail investment instruments as these are deemed suitable for our target audience. Processes are in place to ensure complex instruments aren’t made available to inappropriate client segments.

    How can your platform evidence any in-house investment products offered via the platform are designed with a target market in mind?

    This doesn’t apply as we don’t offer any in-house investment products at this time.

    What timescales are involved when switching onto your platform?

    Where both parties have adopted electronic re-registration via Origo Options and offer the same share classes, the switch or re-registration request will be made within one business day. Where it’s on a manual basis the request will be made in two working days. The full switch process will vary depending on the details provided on the documentation but we follow a strict follow up process to accelerate the transaction and users can check the progress via the ‘in transit asset report’, available on our platform. Our experience shows the Origo process can happen in two to three weeks (subject to accurate details) while the manual process may take four to six weeks for completion.
     
    We have championed the Origo Options electronic re-registration and offered the facility since it was available in mid-2013. We expect average times for completion of re-registration to reduce.

    Does your platform charge any exit fees when trying to switch away from the platform?

    We don’t charge any exit fees. We remain committed to the free movement of assets both onto and off the platform.

    If your platform offers ready-made in-house portfolios, how aligned are the model portfolio names with the volatility ratings?

    We don’t currently offer ready-made in-house portfolios but this is an extension to our proposition we’re considering.

    How often does your platform check any model portfolio names are aligned with the volatility rating?

    We don’t offer ready-made in-house portfolios.

    Does your platform require a minimum cash balance to be held?

    A minimum cash balance of 2% should be held to cover adviser fees. Alerts can be set up to warn if the client’s cash balance falls below this level. The adviser can contact the client to discuss whether they wish to deposit cash (where the regulations permit) or sell other assets in the account. Automatic sell down options are available.

    Does your platform charge clients to hold cash?

    Yes.

    Does your platform retain any interest earned on client money? If so, how much?

    No, all interest earned is returned to the client.

    How does your platform ensure the services offered to advisers benefit their clients?

    We believe all on and off-platform services offered to advisers directly benefit clients, for example providing platform features to enable efficient, accurate processes for users, rather than relying on manual, time-consuming and often inaccurate actions. Our off-platform services such as our user sessions and Illuminate events are key training and networking events for our users. These allow advisers to better service client needs through a better understanding of best practise processes from their peers and industry subject matter experts.

    With rapid advances in technology and a greater prevalence of cyber crime, it's never been more important to conduct regular reviews of your platform's ability to safeguard your client's assets and data.

    A combination of robust technological solutions, watertight security policies and staff training and compliance with regulation are vital to make sure your selected platform offers the protection your clients need. 

    How do you ensure that client data is protected and your systems are secure?

    The protection of client data and systems is our highest priority, that's why we've set high standards for the hosting of our platform. It's hosted in ISO 27001 and 22301 certified data centres and has been designed with security and resilience as a core principle. There are multiple layers of network and application level security controls, and the hosting provider maintains 24x7 monitoring of security and network operations in order to promptly address any issues.

    As part of our internal security framework, we have a dedicated team who are accountable for detecting any security breaches at Nucleus, including email and website monitoring and taking immediate action. We're confident our security provides the best protection for our users and clients.

    How robust is your Information Security Management System (ISMS)?

    The information security standards framework we have in place with our outsourced administration provider, Genpact, means we must comply with best practice and the international standard that lays out the specifications for implementing ISMS, ISO 27001 certification.

    The datacentre selected to host our platform has been awarded information security standard ISO 27001 certification, as has our outsourced administration provider, Genpact, and our hosting partner Bravura.

    What controls and risk-assessments do you place on third parties?

    Information security is our highest priority and we expect our partners to have the same high standards.

    We interrogate this through our robust risk-based vendor management framework, and security-focused due diligence is performed on all new vendors. Regular on-going due diligence continues on selected and existing vendors, throughout the lifecycle of the commercial agreement. All due diligence is completed on a risk-based approach based on assessments for each vendor.

    How are your network and servers protected against external threats and attacks?

    Our core platform technology, the ‘Sonata’ application is provided by our strategic technology partner, Bravura, and is developed using secure development principles, aligned to the OWASP (open web application security project) standards. This means there is regular application level ethical hacking conducted internally by Bravura throughout development.

    In production, the platform is subject to two penetration tests per year, conducted by third parties, as both "white box" and "black box" tests.

    Our dedicated security team is accountable for tracking all the monitoring and detection systems deployed throughout our internal network.

    How do you respond to a cybersecurity incident?

    We operate an incident response plan for disruption to business continuity, at team and organisational levels. This framework uses a risk-based assessment framework to manage any incidents. We carry out testing on an annual basis and any incidents are fully reviewed, with actions being implemented and incorporated into our incident response plan.

    What data recovery, business continuity and disaster recovery plans do you have?

    Our business continuity plan is aligned to ISO 22301. Each department has a business continuity action plan and there’s an overarching incident management plan. The platform is covered by a separate business continuity plan from our back-office supplier Genpact, also aligned to ISO 22301. There’s a real-time connection between the primary and cold standby sites, with a maximum recovery time objective (RTO) of four hours and recovery point objective (RPO) of 30 minutes.

    The platform has a cold standby site with data replicated to it in real time. Should an issue appear in the primary site, the standby site can be activated quickly. Each department’s business continuity action plan lists key roles and deputies. There are multiple, defined people in our back-office supplier, Genpact and in Nucleus who can invoke the plan, and technical staff in different locations are able to follow pre-defined steps to activate the disaster recovery site.

    If the platform experiences a significant disruption, we’ll communicate with you via a mixture of email and messages through other systems, and other relevant channels.
    We have a formal process to maintain business continuity which allows us to switch operations from the production data centre to our disaster recovery data centre, within four hours of an incident.
    The systems are maintained in a warm standby state, with monitoring in place to ensure they are working as expected. The process of switching operations is formally tested on an annual basis.

    Nucleus, Genpact and Bravura all have options for remote working in place that also mitigate disruption. These can be scaled up to support large numbers of staff working remotely if needed, and are supplemented by workplace recovery facilities where a physical location is needed (e.g. for mail delivery).

    Are staff privileges and data access rights controlled?

    Yes, we have a role-based access control framework embedded in our business. This provides staff with the correct level of access to carry out their role and mitigate excessive access to sensitive data.

    All access for planned leavers is revoked at 4pm on the day they leave. Unexpected leavers have their access revoked within 24 hours.

    What security measures are in place in relation to staff working from home (or remotely) and using removable media?

    Remote working is only permitted using company issued devices and secured over a Virtual Private Network with multifactor authentication.

    How do you make sure staff are not a security risk?

    Staff are subject to background checks on joining the company, before they are granted access to company systems. These background checks include:

    • Government prescribed identity must be provided
    • Address validation
    • Right to work validation
    • Criminal background
    • Employment history
    • Education and certification validation
    • Financial checks

    All staff must complete a range of mandatory computer-based training courses on security and awareness. These courses are refreshed regularly throughout employment with an 80% pass benchmark. Data protection training is given to new staff as part of our induction process.

    How do you manage the risks associated with fraudulent email instructions?

    As well as our data and system security, we have implemented processes to help prevent fraud, particularly through email. Many fraud attempts are the result of advisers taking client instructions via email (such as change of bank details and subsequent withdrawal requests).

    It’s important that advisers have processes in place to ensure such requests are genuine. To reduce the risk to clients, we have implemented a control by which the adviser must confirm that they have checked bank details with the customer either face-to-face or via a phone call. For payments to us, we apply a risk-based approach to determine if we would apply enhanced due diligence to verify the underlying source of wealth and source of funds if the client is investing a large sum or lives in a higher risk country.

    How do you make sure a payment instruction is genuine?

    Our payment controls process means we will only pay to named accounts associated with the designated platform account. These details will have previously been verified by the relevant adviser via our secure messaging.

    Changes to associated accounts are controlled and the adviser must attest to doing this face to face or by phone.

    Are you a member of Cifas, the UK’s fraud prevention agency?

    No, as we are an adviser-facing platform we don’t see membership to Cifas as being of benefit. However, we liaise with various anti-financial crime organisations to share best practice.

    Are you registered with the information commissioner’s office? If so, what is your registration number?

    Yes, Nucleus Financial Group (NFG) is registered with the Information Commissioner's Office (ICO) and holds registration number Z9643780. Nucleus Financial Services Limited (NFS) is also registered and holds registration number Z9643794.

    How does your platform conform with the seven high level principles on which GDPR is based, and how has your platform demonstrated it meets these requirements?

    The GDPR regulations came into effect in May 2018, enhancing the security and privacy of personal data. We made all necessary changes to our policies and processes to ensure we are compliant with the regulations. Full details of our privacy policy, including details of how we use client information, what information we collect and use, and your rights under this policy can be found on our website: https://nucleusfinancial.com/privacy-policy/.

    All GDPR enquiries should be directed to: data.protection@nucleusfinancial.com.

    We’re a data controller and data processor. For our products and tax wrappers we’re the data controller, for the platform service we’re the data processor. We’ll process personal data of employees of financial adviser firms as well as clients of financial adviser firms. We collect and hold data required to identify customers and manage accounts. Our reason for holding client and adviser data is for contractual purposes and to satisfy regulatory requirements, and to provide our service.

    Any data transfer outside of the UK will be documented in our privacy policy and disclosed in our privacy statement. We take appropriate steps to ensure the protection of personal data. Our data protection and information security policy suite is reviewed and approved at board level, and we mandate staff training on data protection and staff responsibilities.

    What safeguards are there in relation to my client’s assets on the platform?

    If Nucleus were to fail, client money and assets would be protected under a combination of the FCA’s CASS rules, pension rules and the arrangements operated by the bond providers. Under these rules, Nucleus Financial Services is required to maintain books and records that can be accessed by administrators/insolvency practitioners in order to establish where client monies and assets are held and which bank accounts are client money accounts, to ensure prompt return of monies and assets to individual clients.

    What processing and reconciliation systems do you have in place to protect client money?

    All client money is held by us in trust and is segregated from our own funds so any creditors of ours would have no legal right to it. Similarly, we're unable to use any of this money to meet our own obligations as a company. We deposit client cash with authorised banks, in what’s known as a pooling arrangement, where each client’s individual share of the pool is recorded in our records and reflects what we show in each client’s wrap account summary. We work within a control framework which helps ensure accurate books and records are maintained. Each business day we complete a reconciliation to ensure the total of all individual accounts held on the platform matches what we hold in the pooled cash arrangement.

    What protection is there for clients in the event of a failure of an asset provider, for an asset held in client’s accounts?

    Investments will be with the individual fund managers and their books and records will reflect legal title consistent with our records. All assets bought through the Nucleus platform are registered to a separate nominee so segregated from the financial position of Nucleus. These would remain registered to the relevant nominee in case of a Nucleus failure and therefore would be available for the insolvency practitioner or purchasing company to ensure safe return to the clients.

    If a client holds an investment with a fund manager that's failed, it may be possible to claim compensation but this will depend on the specific circumstances of the fund manager involved.

    What action has your platform taken to ensure clients wouldn’t face a deduction from their assets (e.g. to pay administrators fees) in the event of the platform failure?

    The special administration regime (2011) introduced the right of administrators to deduct fees involved in returning assets to a client from those assets, even if they are held in trust in nominee accounts. This applies in the event of a special administration although instances of special administration are rare.

    Regardless, we are required to hold sufficient funds in our own capital, in reserve, to allow the firm to be wound down while covering these administrator fees and therefore we wouldn’t expect clients to face deductions from their assets in the event of our failure.

    We have a guide – 'the investor protection guide' – which explains protection in more detail.

    What processes do your platform insist on to ensure all communication between a firm and platform is secure? Does your platform offer a secure messaging service?

    We uses Jira messaging to ensure secure communication with firms. If an adviser firm wants to raise a query with us, they can do so by raising a Jira. Each firm has their own Jira 'project' and for each firm there’s a dedicated client relationship manager (CRM) who is responsible for managing the firm's workflow.

    For firms that don't actively engage or who use the platform sporadically, you can still access support through a centralised team who can provide adhoc guidance on administration and processing as required.

    What measures do you have in place to prevent fraud attempts?

    As well as our data and system security, we have implemented processes to help prevent fraud. Many fraud attempts are the result of advisers taking client instructions via email (such as change of bank details and subsequent withdrawal requests). It is important that advisers have processes in place to ensure such requests are genuine. To reduce the risk to clients, we have implemented a control by which the adviser must confirm to us on Jira that any change of bank details request has been verified as genuine.

    When considering technology and development, looking at what exists currently isn't enough. It's important to find out the future plans for development of the platform, including how they're being prioritised or whether any major infrastructure maintenance or 're-platforming' is planned.

    At Nucleus, we have a multi-skilled team working on a mix of platform enhancements and in-house tools to help meet the changing needs of you and your clients.

    Is the platform accessible 24/7?

    Yes, the platform is available online 24/7 and accessible via all types of mobile device.

    How has the usability of your platform been independently rated?

    Based on the most recent four quarters of adviser ratings on web usability (collated by Platforum) our rating is as follows:

    • Industry average: 3.81 (out of 5)
    • Nucleus average: 4.09 (out of 5)

    The most recent report (Q1 2019) rated Nucleus fifth out of 18 platforms for general web usability.

    Please describe any platform downtime over the past three years?

    Our achieved SLA for the core platform during core business hours is 99.9% uptime, and 99% during extended hours.

    Who owns the underlying technology of your platform?

    Nucleus outsources the provision of its technology via a strategic partnership with Bravura Solutions (UK) Ltd. Bravura is one of the world’s largest providers of financial services systems, with over £1.4tr in assets entrusted to their systems. The Nucleus wrap is designed to meet the changing needs of financial advisers and their clients, through a blend of in-house and outsourced technology. We believe this model allows us to leverage the global resources and expertise of Bravura while benefiting from the input of our partner firms to ensure platform development is relevant and current for the UK adviser market.

    Is the underlying technology provider fully committed to the UK platform market, and how does your platform evidence this?

    Yes, in 2018, Bravura expanded its London presence with a move to new offices. The office relocation reflects strong business growth across the UK and the EMEA region, with rapid growth in Bravura’s flagship product, Sonata, continuing to underpin the business’s performance.

    What are the implications If your platform is built on proprietary systems as opposed to outsourcing this to a third party?

    Outsourcing to a third party means we benefit from the use of specialist software which can offer performance, cost or scalability advantages. We also benefit from shared development costs with other Bravura clients (that use the Sonata product) and proven scalability. Globally more than 20 companies use and support the development of Sonata (Bravura’s core platform technology) and during 2019, the product is expected to benefit from approximately 7,500 days of development effort per month. This strategy has allowed us to incur modest development costs in respect of certain propositional enhancements and major regulatory changes, such as Mifid II and GDPR.

    Our approach is to use outsourced technology broadly for the back-end and infrastructure areas of our platform, and in-house technology where that technology touches the customer. We believe this blend of in house and outsourced technology balances cost with agility, scalability and resilience. Our aim is to develop technology internally where we can add value, but to use outsourced technology for commodity services where scale is the overriding factor.

    If your platform is built on proprietary systems, are there any key person dependencies within the platform?

    N/A.

    What due diligence have you carried out on the technology provider?

    As part of our vendor management framework, initial due diligence is performed on all new vendors with on-going due diligence for existing vendors. All due diligence is done on a risk-based approach based on the risk assessments for each vendor. Due diligence is performed across the following areas in the form of a vendor due diligence questionnaire supported by a range of documentation provided by the vendor to support their response - company information, risk and compliance frameworks, anti-financial crime, recruitment and training, use of third-party suppliers, information security, data privacy, resilience, corporate responsibility and financial strength. The due diligence response is reviewed and signed off by a number of internal stakeholders depending on the nature of the services and risks - these include the outsourcing partner, information security officer, data privacy officer, head of risk, head of compliance and the business owner for the service Bravura, our selected technology provider performed strongly through the due diligence process.

    Have you decided to change who provides the underlying technology of your platform?

    No, Nucleus re-platformed in July 2014 but again, as a result of due diligence remained with Bravura technology, as it supported our strategic objectives and provided access to a next generation wealth management system.

    If so, who have you changed from and to?

    The re-platforming was an upgrade from Bravura’s legacy system (Talisman) to the next generation wealth management administration system (Sonata). We believe that the re-platforming from Bravura’s Talisman product to Sonata in 2014 sets us apart from competitors who are yet to fully implement re-platforming programmes and who may become overly reliant on outsourced technology providers, which can generate extensive costs and become disruptive to adviser users and customers.

    Please describe the rationale for this change including the benefits for clients and advisers?

    This was carried out to make the Nucleus platform more scalable and developments easier to implement.

    What disruption do you expect as a result of this re-platforming exercise?

    No further disruption.

    Do you plan on re-platforming or carrying out a significant upgrade over the next two years?

    No, we’re already on a next generation technology system which allows us to leverage the global expertise and resources of Bravura via non-disruptive routine upgrades, which we always communicate to our users.

    If so, please describe the rationale for this change including the benefits for clients and advisers?

    No re-platforming or significant upgrade is planned.

    How much do you expect to spend on this upgrade?

    No re-platforming or significant upgrade is planned.

    How will this technology upgrade impact profitability over the next three years?

    There is no impact to profitability as no re-platforming or significant upgrade is planned.

    What are your best guess timescales for completion?

    No re-platforming or significant upgrade is planned.

    What is your communications strategy for ensuring minimal disruption to advisers and clients during this period?

    No re-platforming or significant upgrade is planned.

    Are all clients maintained on one platform system or do you run multiple legacy systems alongside the core platform?

    Yes, our platform is a single system, described as ‘a platform in a box’. There are no legacy systems that integrate with or sit alongside the platform.

    Do you support API links to back-office software and other third parties?

    We currently support API integration with Adviser Cloud, Client Assyst, Bluecoat, Distribution Technology, Intelliflo, IRESS, Adviser office and Xplan, MoneyInfo, Prestwood, Sprint, Time4Advice and True Potential. We also have a link in place with Prestwood’s Truth cash flow modelling tool and Timeline the retirement planning tool. We’re comfortable having discussions with any back-office or third-party tool provider.

    Can your platform cope with a substantial increase in client numbers and transactions? To what level of increase from its current position until the system can no longer cope?

    Yes, linear scalability is a key feature of the Sonata system. This creates the ability to deal with many millions of clients before capacity is reached, meaning we could easily cope with a substantial increase in client numbers and transactions.

    Do you currently accept digital client signatures, or have any plans to accept these in the future?

    We don’t currently offer this but following the introduction of Nucleus Go, our new client portal we are looking closely at online client permissions being available.

    What is the headcount of your development team?

    The Nucleus wrap is designed to meet the changing needs of financial advisers and their clients, through a blend of in-house and outsourced technology. Our core platform technology (Sonata) is developed by Bravura who employ over 950 people in 12 offices across the world. A large proportion of these people are involved in development (including business analysts, developers, testers and project managers). At any one time, the number of people working on tasks for Nucleus varies, depending on the work instructed.
    Our approach is to use the outsourced technology broadly for the back-end and infrastructure areas of our platform, and in-house technology where that technology touches the customer. We believe that this blend of in house and outsourced technology balances cost with agility, scalability and resilience. In house, we have multi-skilled team working on a mix of platform enhancements and in house tools. There are:

    • three product managers
    • nine business analysts
    • 11 developers
    • eight testers
    • two programme managers
    • one change analyst

    What is it forecast to be in three years’ time?

    We expect this area could increase by another 10 people, but this could change depending our growth, the changing needs of customers and the resulting pipeline of work.

    Can you provide me with a list of upcoming developments?

    We have delivered a series of platform enhancements in 2019, including our new client portal, improved pension income options and streamlined trading. Our road map for 2020 is focused on:

    • Enhanced efficiencies and servicing for advisers
    • Improving client experience, including paper reduction and robust security
    • Scaling our capacity
    • Delivering regulatory change

    What disruption do you expect because of any planned development?

    None, as our model of blending external technology with our own internal expertise minimises the impact to our users.

    How often do you update your platform with new developments, functionality or bug fixes?

    We run a monthly rolling programme of maintenance enhancements and bug fixes, plus internal releases to enhance our platform tabs, in house tools and MI.

    How do you take onboard user feedback for developments including user experience (UX) and user interface (UI) changes?

    Our developments are designed in conjunction with, and the approval of, our platform development group. We also run regular platform user sessions giving users the opportunity to comment on developments to help improve user experience and prioritise our development programme accordingly.

    How do you ensure you don’t waste shareholder money on unnecessary developments or ‘bells and whistles’?

    Our developments are designed in conjunction with, and the approval of, our adviser platform development group.

    What is your test process and how do you ensure sufficient testing has been undertaken for every new development?

    Our test approach is an integral part of our development process. All changes are managed through a product management workflow where the product and the associated tests are generated. Each change is aligned with one-to-many tests, executed to verify and validate the change meets its goal. This ensures a linkage between the original requirement, the work undertaken for the change, and the test output.

    Do you provide an online new business process and top up that caters for all wrappers?

    Yes, we have a six-stage online new business process allowing users to smoothly and efficiently make online applications.

    All wrappers are fully on-platform and more than one wrapper can be included in a single application. Re-registrations can also be instructed within the new business process and incomplete applications can be saved and revisited at a later time. At the end of the process, a client declaration is auto-populated.

    Is this new business application process integrated; for example, can I apply for an Isa and pension in the same application?

    Yes, all wrappers are fully on-platform and more than one wrapper can be included in a single application.

    Do you offer electronic re-registration on and off the platform?

    Yes, we’ve championed electronic re-registration and have offered this since mid-2013.

    If so, please describe the process and average turnaround times?

    Where both parties have adopted electronic re-registration and offer the same share classes, the process can take as little as a few days. Where electronic re-registration hasn’t been adopted by both parties or where there is no existing relationship with the fund manager in place, the average time remains three to four weeks.
    We’ve championed electronic re-registration and offered the facility since it was available in mid-2013.

    Please detail the client reporting and management information available.

    As well as having an adviser firm MI tab on the platform, we also have a wide range of reports you can download, including:

    • Accounts – account information for your clients
    • Client assets - a report of your clients and their assets held on the platform
    • Client cash balance - cash balance including details of regular withdrawals and cash required to ensure regular withdrawals are paid and retain the required 2% cash balance
    • Client details
    • Client logins
    • Correspondence - a report of the correspondence provided to your clients
    • Discretionary fund manager - a report of accounts for which a discretionary manager is active
    • Fees - a report of fees paid to you for each client, by date
    • All assets
    • In-transit assets
    • Isa contributions - a report of Isa allowances that haven’t been used for the current tax year
    • Mifid II 10% drop – a list of client accounts with a drop in value of 10% or more in the reporting period
    • Model portfolios and accounts - a report of the accounts using model portfolios
    • Model portfolio asset allocation - a report of the asset allocations within existing model portfolios
    • Model portfolio valuations - a report providing a current valuation for each asset within the model portfolio
    • New business - a report on the new business added to the platform
    • Pension contributions - provides the total pension contributions made by clients within their current pension input period
    • Pension income - provides details on the amount of income that can be taken by your clients
    • Summary assets - a report of the assets held
    • Trades outstanding - a report on business currently in process
    • Withdrawals and contributions - a report showing withdrawals and contributions to and from the platform
    • First Adviser extract: holdings
    • First Adviser extract: cash
    • Holdings - for external systems

    Our award-winning client reporting tool - Narrate - is a detailed transactional based performance analysis tool. It allows clients and advisers to analyse over 340 different transaction types, create interactive reports across single or multiple accounts and carry out both time weighted and money weighted performance analysis while overlaying transactional information to highlight specific events. Narrate is continually being improved based on user feedback.

    Please describe the range of advice tools you offer and how these can improve my business and benefit my clients?

    To date we have seen little demand from our audience who prefer to use independent advice tools. Our approach has always been to focus on offering the core functionality at a low cost rather than introducing tools that may not be used.

    Please describe the range of portfolio management tools you offer and how these can improve my business and benefit my clients?

    Our range of portfolio management tools are designed to assist advisers to compliantly and efficiently execute and manage client’s financial plans across the whole book of business.

    Here’s a summary of other available tools:

    • Illustrations - create an illustration of projected investment returns for any of the accounts within a portfolio
    • Bulk asset switch - switch all clients between investment assets
    • Bulk cash switch - switch all clients from cash to an investment asset
    • Bulk model portfolio re-assign and rebalance - re-assign and/or rebalance multiple clients who are using a particular model portfolio
    • Alerts - configure and maintain alerts for platform events
    • Events history- view a history of transactional-based events
    • Model portfolio self-service - create, edit and analyse model portfolios.
    • Bulk summary report - create a bulk summary report across multiple clients and accounts.
    • Manage favourite assets - create, edit, delete and convert favourite assets.
    • Investment analysis – analyse funds and model portfolio

    Can the client facing reports be adviser branded?

    Yes, outputs from our client reporting tool, Narrate can be branded using a firm’s corporate identity.

    Can these provide both time weighted and money weighted returns?

    Yes, Narrate allows users to carry out both time weighted and money weighted performance analysis while overlaying transactional information to highlight specific events.

    Can these be presented with performance graphs showing cumulative, discrete and annualised returns?

    Yes.

    How long does it take to generate a client report?

    Client reports can be generated in a matter of minutes using the Narrate client reporting tool. Templates can also be created which save time in producing reports and can provide an updated position with a couple of clicks of your mouse.

    Do you offer a capital gains tool on your platform?

    Yes, Narrate CG (capital gains) can help with your client’s capital gains calculations. The CG tool will calculate and display both realised (historical) and unrealised (potential) capital gains/losses on the GIA for the current and previous tax years. The tool allows you to download the information to a pdf or csv file giving a detailed breakdown including acquisition details, disposal details and net gain or loss at both individual asset and portfolio level. The report can run on multiple client accounts at the same time.

    The tool allows the price of specific transactions to be overridden by the adviser and stored against an asset. This has the impact of increasing or decreasing that asset’s acquisition cost. The original price is still stored against the transaction so it’s easy to revert where required.

    Also, the estimate view within the Narrate CG tool allows you to view the potential gain or loss that may result in the event of a disposal you propose. Again, these reports can be downloaded as pdf or csv files.

    Do you have a tool that can analyse the performance and make up of individual investments and model portfolios before a client invests?

    Yes, our Investment analysis tool can demonstrate how up to five funds or model portfolios have performed historically when recommending investment options to your clients. The tool generates several report components includes holdings, performance, stock overlap, an asset allocation, geographic and sector breakdown.

    How quickly and easily can I investigate transactions on a client’s account. Are all accessible online?

    Yes, a full online transaction history report for your clients can be easily accessed. This can be generated by a few clicks on each client’s account.

    Can I produce reports directly on the platform that show client information at a bulk level?

    Yes, by using the client details report on the platform, you can download a full list of your clients very quickly and easily.

    Can I set the platform to tell me when key events are happening such as the completion of a transfer / fees and income have been paid / trades have settled etc?

    Yes, a list of platform alerts is available which covers many events, including auto sell down, the payment of advice fees, the creation and settlement of a trade or transfer and the payment of a withdrawal.

    Can clients access the platform via an app?

    Yes, our new mobile responsive client portal, Nucleus Go is available. It lets clients view their portfolio, transactions and correspondence at any time.

    Is client access mobile responsive?

    Yes, Nucleus Go is mobile responsive.

    What adviser ratings can you evidence on system usability?

    Based on the most recent four quarters of adviser ratings on web usability (collated by Platforum) our rating is:

    • Industry average: 3.81 (out of 5)
    • Nucleus average: 4.09 (out of 5)
    The most recent report (Q1 2019) rated Nucleus fifth out of 18 platforms for general web usability.
    Service and support doesn't end at the day-to-day help you and your clients should expect as standard, it should also include a more holistic approach to practice development and technical assistance, to help you create better client outcomes and grow your business.

    How would you describe and evidence your service reputation?

    The success of our business depends on our ability to efficiently and cost-effectively administer client assets. Assets under management reached £15.3bn (as at June 2019) and our administration and servicing levels have continued to improve. We continue to receive top adviser-rated awards, see below. We publish a service charter, including agreed service levels and, to support your due diligence, and actively encourage contact with our existing firms to understand their experience of our service levels.  

    Our awards
    Winner - Schroders Platform of the Year 2016-2018
    Winner – CoreData best medium-sized platform 2012-2019
    Winner – FT Adviser 5 star online service awards 2016 and 2019
    Winner – Platform of the year - UK Platform Awards 2011 (and a pretty respectable second place in 2012, 2013 and 2015)

    Please list what adviser ratings you have achieved for service in past three years.

    Adviser rating and awards are available on our website.

    https://nucleusfinancial.com/about-us/#nlink-trophy-cabinet

    Have your adviser ratings improved or declined in this period?

    Our rating has improved over the three years until Q2 2019. These results were based on adviser reviews received in the quarterly Platforum user leader board between Q2 2016 and Q2 2019.

    What's your approach to maintaining or improving adviser ratings?

    Our objective is to maintain a continuous improvement programme to help us deliver great service and support for users. To support this we seek regular customer feedback and insight, including participation in the Investors in Customers survey, interactive workshops at our bi-annual user sessions and input from our platform development groups.

    Improvements resulting from this feedback include enhancements to our telephone system and call handling to make sure it’s easier for you to contact us when you need to. Also, we’ve grown our client relations team through recruitment of experienced candidates and implemented a formal training plan to improve our service .

    Additionally we’ve created a customer insight team who are using data to help analyse and understand where common issues occur. Using this analysis we’ll be looking at ways to prevent the same things happening again and how we can improve the customer journey. Finally, we’re making improvements to how we handle and communicate issues when things go wrong.

    Please detail which ratings companies or publications you have sponsored or paid money to and over which periods.

    We don’t sponsor any ratings companies or pay fees to use their logos.

    In terms of organisations who provide ratings for platforms, our subscription approach has been:

    • We’ll pay required charges to be represented on best advice systems so our users can compare our proposition and support compliant client recommendations; and
    • We purchase some market research publications in order to benchmark our performance.

    Our strategy has always been to rely on user ratings rather than any form of sponsored or purchased ratings. We firmly believe peer ratings are a much truer measure of performance than those produced by ‘industry experts’.

    Does your platform have a net promoter score (NPS)? If so what is it?

    Yes, our most recent NPS across all Nucleus users was +11 (August 2019) demonstrating a clear level of advocacy from many of our users.

    Will I be allocated dedicated field support?

    Yes, each firm actively engaging with us will have a dedicated account manager who is based regionally along with a dedicated client relationship manager (CRM) based at Nucleus HQ. The account manager and CRM work closely together and will be your main contacts for any support or queries.

    Your account manager pro-actively engages with you and supports our relationship through regular contact and face-to-face meetings. They’ll make sure you’re aware of all the resources available to you as a user of our platform. Harnessing their in-depth knowledge of regulatory, compliance and industry issues, your account manager will support your business through project planning, training provision, and any technical queries, as required.

    You’ll be given a direct line to both your CRM and your account manager. This personalised service means that we really get to know you, making it easy for you to do business with us.
    We believe in transparency because knowing how things are going helps you manage your clients and gives you peace of mind that your cases are progressing. You’ll use our secure messaging system, Jira, that allows you to send instructions and queries, and view how these are progressing. This will save you time having to call us to find out what’s going on.

    Will I be allocated a dedicated member of your client services team for day-to-day queries?

    Yes, each firm that actively engages with Nucleus will have a dedicated client relationship manager (CRM) based at Nucleus HQ. The account manager and CRM work closely together and will be your main contacts for any support or queries.
     
    Your CRM will be your key contact for day-to-day platform support and case management. Like the account managers, the CRMs work in small teams who are aligned to your region. If your CRM is ever unavailable, one of the team will be on hand to help.

    You’ll  be given a direct line to both your CRM and your account manager. This personalised service means that we really get to know you, making it easy for you to do business with us.

    We believe in transparency because knowing how things are going helps you manage your clients and gives you peace of mind that your cases are progressing.  You'll use our secure messaging system, Jira, that allows you to send instructions and queries, and view how these are progressing. This will save you time having to call us to find out what’s going on.

    In addition, for any “how to?” questions, we offer a live support (Live chat) service on the platform and this has become increasingly popular for our users. Anecdotal feedback shows Live chat provides a quick and efficient way to obtain answers to straight forward questions.
    Our opening times are Monday to Friday, 8:30-5:30pm for live support and calls.

    For firms that do not actively engage or use the platform sporadically, you'll still be able to access support through a centralised team who can provide ad hoc guidance on administration and processing as required.

    How are sales staff incentivised and what procedures do you have in place to mitigate conflicts of interest in attracting assets to the platform and delivering the right customer service outcomes?

    All incentive schemes are designed to ensure they are consistent with supporting advisers to deliver good client outcomes as well as enabling retention and motivation across our sales team. The FCA have made clear the culture of a firm is important in ensuring good customer outcomes and our incentive scheme ensures risks to customers are adequately counterbalanced and controlled to remain compliant with regulatory best practice. The scheme also seeks to maintain alignment with the long-term interests of all stakeholders (including customers, users and shareholders) to ensure everyone is incentivised to help us build a durable business.

    Do you make online ‘live support’ or other online support services available as an alternative to telephone or email contact?

    Yes, our live support (Live chat) is available Monday to Friday 8.30am to 5.30pm and can be accessed via our platform. It provides a quick and efficient way to get responses to straight forward questions.

    Can you describe any structured training and onboarding support you would provide?

    From day one, you'll have a dedicated account manager to support all elements of the implementation and the on-going day-to-day relationship management, plus a client relationship manager, who'll manage any post-sale/client specific enquiries).

    In addition to providing basic platform training, our Ignite program is a structured approach to make sure all areas of your business and client proposition that may be impacted by using the platform are managed from outset. This is delivered via a project timeframe and will integrate the platform with your business by minimising disruption to your day-to-day client activities.

    Our Ignite service provides online accreditation modules, which provides easy-to-access training, with a clear audit trail of completion and analysis of where any additional learning might be required.

    What contact methods are available to advisers? For example telephone, email and live online support?

    Telephone – Monday to Friday 8.30am to 5.30pm

    Live chat – Monday to Friday 8.30am to 5.30pm

    Email – Monday to Friday 8.30am to 5.30pm

    Secure messaging via Jira is available. This can be used 24/7 and will be dealt with during our normal opening hours.

    Does your platform offer a more secure online alternative to email?

    Yes, our users must use our secure Jira messaging system, which provides a clear audit trail of all correspondence and keeps any sensitive data secure.

    Is your administration insourced or outsourced?

    Our back-office administration is outsourced to Genpact but full responsibility for the servicing of customers sits with our own client relations team, based at our Edinburgh HQ.

    If it's outsourced, do I deal with you directly or with the outsourced party?

    You’ll always deal directly with your dedicated Nucleus client relationship manager.

    How many customer complaints have there been in the past 12 months?

    For the 12 months to 30 June 2019, we received 251 client complaints.

    How many were referred to the Financial Ombudsman Service?

    We're please to say only four complaints were referred to the Financial Ombudsman Service.

    What percentage were upheld?

    Of all complaints received, 69% were upheld.

    Do you offer a range of technical support material, including how to videos, platform accreditation modules, case studies and presentations?

    Yes, our Illuminate technical studio is available online. This takes rafts of technical legislation and regulation on pensions, investment bonds, Isas and trusts, and translates them into simple bite-size pieces which are easy to understand. Advisers are able to find accurate up-to-the-minute technical information quickly and simply from our suite of tools including factsheets, case studies and videos. We also have 12 online platform accreditation modules which allow new users to complete detailed training on all aspects of the platform, and understand where more training may be required.

    You can also access Techlink which is provided by Technical Connection.

    Do you offer a comprehensive range of trust documents designed in conjunction with the tax wrappers on the platform?

    We offer a range of specifically platform-designed trusts approved by Counsel and supported by Technical Connection, who provide free access to their online Techlink service for platform users.

    Do you provide technical support on all areas of your business?

    In addition to the trust deeds we also provide access to adviser guides, user guides, client guides, a trust selector tool and a fund selector tool. We also provide technical support as well as free access to Technical Connection’s Techlink platform (https://nucleusfinancial.com/support/techlink). We have a product technical team who are available for any questions concerning Nucleus’ product offering. Additionally our account management team has extensive technical knowledge and can field a range of questions.

    Do you have a capital gains calculator that can export both realised and unrealised gains and also exclude certain assets that have been acquired before a re-registration?

    Yes, we provide a capital gains calculator that can show unrealised gains and also realised gains for the current and previous tax years. The outputs can be downloaded to a PDF or CSV file giving a detailed breakdown including acquisition details, disposal details and net gain or loss at both individual asset and portfolio level.

    Can the capital gains tool raise the acquisition cost of an asset to ensure clients don’t pay capital gains tax (CGT) on an asset they have already paid income tax on?

    Yes, the tool allows the price of specific transactions to be overridden by the adviser and stored against an asset. This has the impact of increasing or decreasing that asset’s acquisition cost. The original price is still stored against the transaction so it’s easy to revert where required.

    Can the capital gains tool produce estimated gains or losses for any proposed disposal amount?

    Yes, the estimate view within the Narrate CG tool allows you to view the potential gain or loss that may result in the event of a disposal you propose. These reports can be downloaded into pdf or csv files.

    Does your platform facilitate the sharing of best practice among key advisers in your local area?

    A key benefit of adopting our platform is joining an adviser community, which provides the opportunity to share resource and information with other like-minded advisers. As a member of this community, you’ll have access to a range of CPD accredited events, a knowledge centre updated with new content every day (https://illuminate.nucleusfinancial.com/), curated by us and authored by key industry experts, and an online technical studio. All of these initiatives together are known as illuminate, and are designed to help you grow your business, share best practice and provide better client outcomes. Our regular Illuminate live events are shaped by advisers to help develop best practice, and add value to their businesses.

    Our community also comes together for our platform development groups and user sessions, which are designed to gather and prioritise our platform developments and user experience. This makes sure we focus on developments driven by, and designed for those using it, with clients at the centre of everything we do.

    Does your platform offer adviser representation at board level?

    Yes, our advisory board provides the Nucleus board with adviser input into the ongoing strategic development of the platform, the group and the wider market. The advisory board representatives reflect the interests of the Nucleus audience and our board will receive regular reports on the matters of interest to the advisory board.

    Does your platform have a group run by advisers that has a direct link into the future planning process for the platform?

    Yes, our platform development group. Our proposition has been designed from day-one based on adviser requirements. This makes our approach for researching and prioritising developments somewhat unusual. Although we monitor what our competitors do, our main driver is user demand driven by advisers who use the platform, and the needs of their clients. We believe this is a key reason for our proposition receiving high ratings by advisers; because it’s designed by the people who use it, for the benefit of their clients.

    Does your platform facilitate feedback sessions from day-to-day users of the platform including paraplanners, office managers and administrators?

    Yes, via our six monthly platform user group sessions. User feedback gathered at our user sessions is prioritised and put into development. We bring back our ideas, to test the user experience to assess how easy or pleasing something is to use. Our user sessions have improved the UX of many of the tools available on the platform, such as Narrate, Narrate CG and our client portal, Nucleus Go.

    Does your platform provide training sessions purely for the development of advisers and adviser firms and not overt sales opportunities from fund managers or providers?

    Yes, Our Illuminate live sessions (https://illuminate.nucleusfinancial.com/attend) are local events aimed specifically at sharing knowledge across the Nucleus community in areas vital to successful business progression, and based on the needs of clients. Illuminate live consists of in-depth workshops led by independent experts in areas such as networking and influencing, tax and technical matters, business coaching and digital marketing. The event gives you four hours of CPD points.

    Does your platform provide online training support, thought leadership support and a forum for small businesses to come together to debate latest issues and share best practice?

    Yes, our online illuminate hub is a resource designed to help advisers build and share knowledge in areas vital to the successful development of your business, including compliance and regulation, practice development, marketing and technical knowledge. Illuminate highlights the latest thinking from expert commentators and encourages the sharing of content from advisers to advisers.

    Illuminate learn forms part of this hub and is an online portal designed to support advisers and your teams whether you're studying for diploma or looking for a way to take your business to the next level. All courses are regularly updated and competitively priced.

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