Due diligence reporting tool
We know that platform due diligence is no easy task. It's been recognised by the FCA that there's an inconsistency of approach across providers and adviser firms in the approach and depth of relevant information to show the suitability of platforms.
To help you complete due diligence on Nucleus, we've developed an interactive tool which lets you select the areas most relevant to your business and generate our responses. You can download your tailored report as evidence of your due diligence research.
Using the reporting tool is simple…
- Find the questions you'd like answers to in the sections below.
- Click the add button next to each of the questions you’d like added to your report.
- Once you’ve added all the questions you need, simply fill in your details for your report to be created.
A platform’s business model, financial position and culture are important considerations when carrying out due diligence.
Taking a closer look at a 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.
Who owns Nucleus Wrap and how stable is the ownership structure?
The Nucleus Wrap platform is owned by Nucleus Financial Platforms. Nucleus Financial Platforms was formed in August 2021 by the bringing together of the James Hay Partnership with Nucleus Financial plc.
Nucleus Financial Platforms’ main shareholder is global investment firm HPS Investment Partners. HPS has $101 billion of assets under management. Find out more about HPS here: https://www.hpspartners.com/en/home/
UK-based independent private equity manager Epiris, which manages a £821m fund, is our minority shareholder. Find out more about Epiris here: https://www.epiris.co.uk/
For more about the ownership and credentials of our group, please refer to our 'Choosing the right platform' guide here: https://nucleusfinancial.com/choosing-right-platform
You’ll see that over time, we intend to operate one strategic platform for all Nucleus clients. FNZ is our strategic partner for this endeavour. We’ll start with James Hay Online in 2024, and then consider moving the Nucleus Wrap business across no earlier than 2025. Our plans are subject to change, not least owing to the acquisition of Curtis Banks expected to complete in 2023.
Rest assured we’ll only begin this transition when we’re confident that the new platform is operationally robust and ready. Above all else, our intention is to make the migration experience safe for you and your clients.
What was the profit/loss of Nucleus Financial Services Limited (Nucleus Wrap) over the past three years?
2020: £3.2m
2021: £4.1m
2022: As a result of the transition of the Nucleus Financial plc and James Hay Partnership into the Nucleus Financial Platforms Group, profit reporting has changed. Nucleus Financial Services Limited (Nucleus Wrap) is profitable in its own right, but is now incorporated into the Nucleus Financial Platforms Limited account. The latest annual report and accounts for the Group is available here: https://nucleusfinancial.com/annual-report
When did you reach profitability on Nucleus Wrap and has this position been sustained?
We have delivered a profit for Nucleus Wrap every year since 2012.
If the Nucleus Wrap platform is loss-making, what is the anticipated level of assets and date for breaking into profit?
N/A – we’re a profitable platform.
What are the key risks to this plan to make profit?
Once in profit, how long will it take to repay all previous costs and losses the platform has sustained?
N/A - 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.
Is the Nucleus Financial Platforms Group profitable?
Can you guarantee in writing the board is 100% behind the platform and has never discussed withdrawing from the UK market?
We’re a profitable wrap business which is part of the Nucleus Financial Platforms Group, and our Board is 100% committed to continue growing our business in the UK.
What are the capital adequacy requirements, regulatory capital structure and capital surpluses of the Nucleus Financial Platforms Group?
For details of our capital adequacy position, please see our 2022 Pillar 3 disclosure at the bottom of the following page: https://nucleusfinancial.com/
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 the wider group.
To what extent does your business modelling make allowance for any future downward pressure on pricing?
In July 2022 we introduced a price cut for all new and existing clients for portfolios of up to £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.
In December 2023 we made a further price cut for all new and existing portfolios of holdings between £200,000 and £500,000.
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 Mike Regan 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?
On 5 August 2021, the FCA gave its approval to the acquisition of the Nucleus Financial plc by James Hay Holdings Limited and as of 22 September 2021 the Nucleus shares are no longer traded on AIM. We do not expect any changes in ownership or capital structure within the next five years.
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 on ‘Our company’ board members and executive team web page: https://nucleusfinancial.com/our-people
Does the firm have any material exposure to current unresolved litigation or regulatory action?
To our knowledge and as at 12 May 2023, the signing date of the Annual Report and Financial Statements, Nucleus has no material exposure to unresolved litigation or regulatory action.
How much is invested on Nucleus Wrap?
What percentage of your book is non-advised clients i.e. orphan clients or D2C?
We have 0% as direct clients, and less than 2% are orphan clients.
Do you retain any income received from fund managers?
No, all fund manager rebates are returned to the client.
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?
Do you retain any interest from client cash held on the platform?
Yes, our active management of customer cash means we can credit our customers with a competitive rate of interest. We retain some of what’s earned so we can keep our charges low, as well as invest in our technology, propositions and provide higher service levels. Our aim is to deliver excellent financial outcomes for our customers, and ultimately help make their retirement more rewarding. Our tiered rates of interest are as follows:
Earned interest rate % of earned rate paid
0.00% - 1.00% inclusive 0%
>1.00% - 1.50% inclusive 50%
>1.50% - 5.00% 75%
>5.00% 90%
Details on our sharing policy are displayed online at https://nucleusfinancial.com/wrap/advisers/our-platform/costs-and-charges, along with the actual rates applied to customer accounts, and the level of cash interest rates retained is shown as a charge on client illustrations.
Several alternatives are available to clients, so they can obtain investment style returns on their spare cash, in some instances by locking into longer-term cash products. These include Bondsmith (from March 2024) offering a range of term deposits at several banks, money market funds, lower risk rate model portfolios and gilts and bonds through a stockbroker.
Will clients be better or worse off?
How much revenue is generated from in-house fund solutions?
What percentage of the platform’s assets are held in in-house funds?
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.
We’ve also run the Nucleus Advisory Board for over 16 years. For many years the Advisory Board has played a crucial role in helping the Nucleus executive team make key strategic and propositional decisions. It’s also a valuable forum for airing and debating the many issues affecting advice firms today, from regulatory and technological, to general practice management.
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.
How many advisers and customers does Nucleus Wrap serve?
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.
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:
- Illuminate live training events
- 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’s your environmental or green policy?
As a responsible corporate citizen, we have a responsibility to help address climate change and minimise our environmental impact in a sustainable manner. Sustainability is at the heart of our strategy
and vision of ‘making retirement more rewarding in a commercial, ethical, and sustainable way’.
For more information, please refer to our sustainability policy and our climate-related disclosure document, available on our website here: https://nucleusfinancial.com/responsible-business
Do you have any plans to enhance your sustainability?
Sustainability is a quickly evolving area and we’re on a journey to progress our environmental and
societal impact. We’ve set a number of sustainability linked ambitions and will be flexible in our
approach to adopt best practice so that their delivery is not an end point for our sustainability at Nucleus.
We have developed and implemented a B-Corp inspired Sustainability Framework. We use the
framework to measure, track, and target our impact. We’ve formed the Nucleus Sustainability Steering
and Working Groups, with three executive level sponsors, to implement the framework with the purpose
of delivering our business strategy across our six sustainability pillars:
• Governance
• Environment
• Our People
• Community
• Customers
• Sustainable Investing
They also combine and support already established sustainability linked groups, such as our Diversity & Inclusion and our charity committee.
The working group are responsible for setting and working toward long-term sustainability ambitions, which include net zero emissions ambitions, reducing the gender pay gap, employee volunteering
targets, and making enhancements to build on the platform’s ESG capabilities.
The working group regularly reports to our Executives and Board on our progress in achieving our longer-term sustainability ambitions as well as monitoring key sustainability metrics.
What CSR activities do you take part in?
We aim to have a positive impact on the environmental and social sustainability of the communities in which our people live and work. We do this through a combination of giving, volunteering and creating opportunities for our people to have a lasting impact on our communities.
The Nucleus Charity Committee identifies, promotes and co-ordinates charitable activities across the business. It matches funding on charity donations raised by our people and provides sponsorship to charitable and sustainable events in our local communities. We also recently launched a charitable foundation, entirely funded by the business and governed by a committee of independent and staff trustees. It exists to share some of the benefits of scale for the good of our stakeholders and the communities in which we operate.
More details are available here: https://nucleusfinancial.com/media/press/nucleus-launches-charitable-foundation
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?
Our key focus is to work with like-minded, progressive firms who share our ambitions and values. We therefore seek relationships based on long-term mutual commitment and respect. Our business development teams cover geographical areas across the UK. Firstly, they would get to know your goals and requirements, who would need access to our platform and the degree of support and training needed during the on-boarding process. Once this has been established, we should be able to have your agency set up within 3-5 working days. Simply visit our Contact us page to find the business development team in your area: https://nucleusfinancial.com/wrap/advisers/contact-us
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 their 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 of doing so. We value and absolutely respect the adviser / client relationship.
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. We always encourage orphans to seek the services of an adviser.
Do you have a formal risk management framework in place?
Can you facilitate my adviser charges?
What flexibility do you offer in terms of how my charges can work?
Do you provide for tiered adviser charges?
Can I exclude certain assets from adviser charging (e.g. cash)?
Do you apply any limits to what I can charge clients?
Can I vary my adviser charge for each new client contribution?
Do you offer access to a wide range of wrappers on your platform?
Are there any restrictions on how wrappers can be combined?
What types of ISA do you offer?
Who can hold a SIPP on your platform?
We offer a SIPP which is open to UK residents of all ages.
Do you offer access to third-party wrappers?
Yes, we have developed links and relationships with a number of third-party providers to allow them to invest in the Nucleus General account (GIA) via their SIPPs, SSAS’s and bond products. This allows clients to benefit from the investment range and functionality of Nucleus, while using a specialist product wrapper.
The third-party providers available are as follows. We don’t recommend or endorse any particular product provider available through our platform.
@SIPP
AXA IOM
Canada Life
Dentons
Hornbuckle
Ioma
IPM
James Hay
Liberty
Royal Skandia
Countrywide Assured
Curtis Banks
Westerby
*Please note that Countrywide Assured does not allow re-investment into the Nucleus General account.
Do you offer a fully supported range of trusts?
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 both phased and one-off flexi-access drawdown and capped drawdown options but we don't offer UFPLS. Both types of drawdown offer a range of income options for clients. We don't provide annuities.
Are all wrappers fully embedded on the platform or are they external third-party wrappers not available 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 accept in-specie instructions both in and out?
Do you subscribe to any e-transfer gateways?
Do you provide Bed and ISA functionality?
Can I apply a common model portfolio across all wrappers?
Can I rebalance investments proportionately and easily online across all wrappers?
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.
Does 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.
Our development plans include increased digitisation of our online new business process.
Do clients pay any additional charges to any of the wrapper providers that are deducted from money in the wrapper?
The Nucleus offshore bond is subject to an account opening charge of £100 and an additional charge of 0.15%.
The Nucleus onshore bond account is subject to an additional annual charge of 0.10%
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 to 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 from advisers – because it’s designed by the people who use it.
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?
Do you offer ‘superclean’ or discounted share classes?
Do you check whether clients could be in lower cost share classes?
For in-specie transfers in, we’ll communicate with the transferring scheme or platform before initiating any transfer to determine which investments can be transferred in without needing to be sold. We’ll identify the unit class with the lowest Ongoing Charges Figure (OCF) that is jointly available from both providers and, if necessary, request the transferring scheme converts the current unit class to a different unit class to enable the transfer. Once the in-specie transfer has been completed, you’ll be able to request that we convert your client’s units to a different share class, if desired.
Conversely, if you instruct us to transfer your client’s investments in-specie to another provider, we’ll collaborate with that provider to ensure their investments are transferred in the most effective way.
If you wish to view alternative share classes and compare charges, you can do so through the platform.
What investments are not available?
We’ll review and consider adding assets to the platform on request. We don’t provide access to:
• UCIS
• Derivatives
• Non GBP
• Complex/Sophisticated Investor funds
• Unquoted shares
• CDIs
• Shares not listed on the LSE
What stockbroker do you use?
What model investment portfolio functionality is available?
Can I request new assets to be added to the platform? If yes, what is the turnaround time for assets being added?
Can I set up and manage model portfolios?
What model investment portfolio functionality is 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 bulk rebalance and switch functionality can run thousands of transactions in minutes. 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?
Can model portfolios be rebalanced automatically at pre-determined intervals including quarterly, half yearly and yearly?
Do you offer tolerance-based rebalancing?
Can I hold investment trusts, ETFs or equities in my models?
Do you provide any investment analysis tools?
Can model investment portfolios be managed on a bulk basis across a group of clients?
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 any in-house investment options at this time.
What due diligence do you carry out on assets you make available on your platform?
Can my clients hold commercial property within their SIPP?
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.
We also support share class conversions as part of a re-registration to support simpler transfer of assets where there are differing classes available on each platform. We can request ceding platforms to convert to a share class that we can accept.
Can you describe any restrictions or process differences relating to re-registrations of assets to and from different share classes you have?
Do these differences carry any tax (for example capital gains tax - CGT) issues for my clients?
Can I use (insert chosen DFM) through your platform?
There’s a selection of over 70 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. For the most up-to-date DFMs, please take a look at our website: https://nucleusfinancial.com/wrap/advisers/our-platform/investment
How do I start using a DFM on your panel?
Are there any additional charges for using a DFM?
Can the selected DFM operate discretionary investment portfolios directly on the platform or does client money need to be sent to their custodianship?
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 the platform, and we retain custody.
If client money isn't within the DFM’s custodianship, how is the performance of the DFM funds reported?
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 adviser will be granted access to allocate clients to their selected DFMs model portfolios and set up DFM fee arrangements.
- Client authorities need to be completed and sent to us to allow the smooth set up of the DFM service.
The relationship with the client is retained at all times by the adviser.
Do you levy any platform charges for using a DFM over and above the DFM charge?
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.
In addition, we also review the DFMs target audience, business strategy and type of assets which will make up the model portfolios.
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?
Can my clients access the platform? If so, is this full or limited access?
No, but you can grant your clients access to Nucleus Go (https://www.nucleusfinancial.com/platform/nucleus-go-support), our fully mobile responsive client portal. It allows clients to view their portfolio, valuation charts, transaction history and important correspondence at any time. We have introduced a number of features, such as an 'Adviser login' functionality that lets advisers log in to Go and see exactly what their clients see.
Clients can also download our Nucleus Go iOS app which launched in May 2022. For more information go to our website: https://nucleusfinancial.com/wrap/clients/our-platform/nucleus-go
Can my clients trade on the platform (without the need for any adviser input)?
Can I restrict client trading on the platform?
Can the client view be dual branded with my firm’s logo?
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.
Do you produce client-facing materials in accessible formats?
What is your core platform charge?
The platform charging structure is designed to be transparent and simple for clients to understand. Please note that we apply the platform charge on invested cash, not on cash balances held in a client's account.
Charges are applied in tiers depending on the level of client assets. The tiers are:
Client holding Charge on tier:
Up to £200,000 0.33%
£200k to £500k 0.30%
£500k to £999,999 0.175%
£1m upwards 0.05%
The 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 £200k will be 0.33%, then 0.30% between £200k to £500k, and finally 0.175% on the remainder.
Any rebate associated with larger portfolios (to reflect the tiered basis) will be calculated monthly and credited to your Accounts on a pro-rata basis.
What additional or transactional charges apply?
Our transparent and simple charging structure means:
- No initial charges
- No minimum platform or wrapper charge
- No fund switching charges – we believe clients should be able to move assets freely without financial penalty
- No exit charges – we make no charges for re-registering off the platform and are committed to the free movement of assets
- No model portfolio charges from us
- No SIPP or pension establishment charges
- No charge for going into drawdown
We do have a family discount for husband and wife, civil partnerships and cohabitees.
The Nucleus offshore bond is subject to an account opening charge of £100 and an additional charge of 0.15%.
The Nucleus onshore bond account is subject to an additional annual 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.
UK structured products under £10,000 order value will be charged £5.00 per order.
UK structured products above £10,000 order value will be charged 0.05% per order (subject to a maximum charge of £150).
If more than one client of Nucleus Wrap is buying or selling or selling the same Listed Securities at the same time in the same wrapper type, the minimum Stockbroker Charge will be proportionately split between such clients.
Depending on the asset, there may be an initial and/or annual charge determined by the asset manager.
You can find out about our charges on our website: https://nucleusfinancial.com/wrap/advisers/our-platform/accounts-and-charges
How competitive are your charges for ISA and SIPP portfolios?
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 | 0.33% | £82.50 |
| £50,000 | 0.33% | £165.00 |
| £75,000 | 0.33% | £247.50 |
| £100,000 | 0.33% | £330.00 |
| £150,000 | 0.33% | £495.00 |
| £200,000 | 0.33% | £660.00 |
| £250,000 | 0.33% | £825.00 |
| £500,000 | 0.33% | £1,650.00 |
| £1m | 0.25% | £2,525.00 |
| £2m | 0.15% | £3,025.00 |
We don't 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 shown.
What is the total number of different charge types you may apply to clients using your platform?
There are only four possible charges for using the platform:
- A platform charge ranging from 0.05% to 0.33% depending on wrappers used and assets held.
- Stockbroker 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 levied by our stockbroker Winterflood.
- Bond charges – the Nucleus offshore bond is subject to an account opening charge of £100 and an additional charge of 0.15%; the Nucleus onshore bond account is subject to an additional annual charge of 0.10%
We don't charge for switching, trading funds, rebalancing, transferring in or out, using model portfolios or moving into drawdown.
Can you please supply copies of all relevant literature containing descriptions of all platform charges you have?
You can find information about our charges on our website: https://nucleusfinancial.com/wrap/advisers/our-platform/accounts-and-charges
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?
We 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 we can give you our assurances that we don’t intend to start.
We believe our simple structure, which contains only four potential charge types to clients depending on what wrappers and assets they use, genuinely allows you to compliantly predict to your clients the cost of using Nucleus regardless of how their financial needs might change in the future.
What criteria are required for you to offer non-standard pricing?
How are clients’ interests protected?
Protecting your clients' interests is always our priority. While the provision of the Financial Services Compensation Scheme (FSCS) applies if the worst should happen, you and your clients can take comfort from the fact that:
- Our business is well capitalised and financially strong.
- We’ve structured our products to ensure your clients’ assets are unlikely to be affected in the event that our business should ever fail.
- We take systems and data security very seriously.
- We have a robust governance framework that ensures all the risks associated with our business are identified and controlled.
More specifically, the investor protection regime is complex and differs for different tax wrappers and asset types, especially where cash and commercial property are involved. The key features and terms and conditions documents for each wrapper have full details.
What client protection is available under the FSCS?
What level of professional indemnity insurance (PII) do you carry?
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.
Who regulates Nucleus?
How do you prevent conflicts of interest?
We expect our business to be conducted with integrity and we won’t offer, give, solicit or accept any inducement likely to conflict with any duties owed to you and your clients.
Controls we have in place around this include:
- A pay and reward structure that isn’t directly linked to product sales.
- A compliance team that approves reward schemes, ensuring that customer outcomes have been fully considered.
- A company Anti Bribery Policy and a Gifts, Hospitality and Inducements Policy that includes sections on financial integrity, confidentiality and inducements.
- An audit team that reviews adherence to this procedure.
What is your best execution policy?
What is your approach to Environmental, Social and Governance (ESG)?
What are your modern slavery commitments?
Nucleus has a zero-tolerance policy towards modern slavery and has implemented appropriate controls to mitigate the risks of slavery and human trafficking occurring in our business or in our supply chain. Our Modern Slavery Statement is set out here: https://nucleusfinancial.com/responsible-business
What's your approach to Consumer Duty?
How are you tackling your Consumer Duty responsibilities?
Much of our Duty activity is at a Group rather than platform level. However, we have a major programme of activity to ensure we embed the spirit and letter of the Duty across our business, for the benefit of your clients. This is split into five workstreams:
• Price and value
• Product and services
• Consumer understanding
• Consumer support
• Governance and culture
Consumer Duty is a standing agenda item for all leadership groups and our Board.
In terms of Consumer Duty requirements, do you apply any limits to what I can charge clients?
Will you publish a Value For Money Assessment for Nucleus Wrap?
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 your 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.
We are an FCA solo-regulated firm. To date we have not been subject to a full supervisory visit. We keep open channels of communication with the FCA and promptly responds to any requests for information.
Please describe any disciplinary proceedings made against you.
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 investment wrappers, to help advisers achieve the optimal tax treatment for their clients. Our range of portfolio management tools allow 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 (only if the client is currently invested in 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. We have automated phased drawdown which provides 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?
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 offer managed investment strategies.
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?
In compliance with MiFID II, we provide an annual statement of costs and charges to all clients, 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?
Are the annual costs and charges provided in both monetary and percentage terms?
Can the costs and charges information be produced by the adviser on an ad hoc basis?
We're looking to build this functionality into our Narrate reporting tool. In the meantime, the cost and charges statement is produced annually and is available in the client's correspondence.
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.
You can find a copy of our target market statement here: https://nucleusfinancial.com/advisers/consumer-duty-hub
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 are client statements 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 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 allow 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 (only available for clients with an existing capped drawdown account). 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.
Our automated phased drawdown functionality allows efficient online management of the frequency, amount and payment date of income from any active phased drawdown.
Regarding target market, 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?
The Nucleus Wrap proposition has been principally designed to satisfy the needs of retail customers as defined by the FCA under the definition of 'retail clients' and consists of a narrow product set, predominantly tax wrappers, centred around retail investment funds and managed portfolio services. Underlying customers are always introduced to Nucleus Wrap on the recommendation of an FCA authorised financial adviser and are expected to have the following attributes:
- Retail customer (although it may be suitable for professional clients as defined by the FCA).
- UK resident, although overseas clients may be permitted in exceptional circumstances.
- Require assistance in one or more of the following areas; pre-retirement asset accumulation, income generation, post-retirement asset decumulation, capital preservation or inter-generational wealth planning.
- Typically have at least £50,000 of funds available for investment in the years prior to and during retirement that would require the services of a financial adviser.
- A basic level of financial capability that would enable the customer to understand, and provide informed consent to, the advice being provided.
- Ability to bear losses to capital without creating significant financial hardship.
- Age range of 18 to 80 years (except for JISA and child pension applications).
- The requirement for multiple product wrappers or multiple asset holding.
- A medium to long-term investment time horizon (5 years or more) that would allow the use of assets where capital may be at risk.
Our products aren’t suitable for investors who are looking for guaranteed investment returns or income, to invest in non-standard investments (e.g. unquoted shares) or who are only looking to invest for the short term. Our target market doesn’t include non-advised customers. In accordance with our orphan customer policy, we limit some services and encourage orphan customers to appoint a new adviser - recognising that this may lead to the appointment of an adviser who uses another platform that the customer could transfer to.
We take vulnerability seriously and our mission is to provide smart, simple and flexible support to customers who need it most. We understand that we may have to tailor the services we offer to vulnerable customers depending on their circumstances in accordance with our vulnerable customer policy.
Our aims are to:
- Understand, identify and record the needs of vulnerable customers within appropriate timescales.
- Safeguard vulnerable customers, and data relating to their vulnerability, to prevent creating or exacerbating harm.
- Ensure our staff are well trained, supported and seen as experts in supporting a wide range of vulnerabilities.
Are there any clients who you think are not suitable for Nucleus Wrap?
Can your platform describe the client monitoring it undertakes to ensure clients are aligned with the identified target market?
An annual product 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.
How can your platform evidence any in-house investment products offered via the platform are designed with a target market in mind?
We don’t offer ready-made in house investment solutions.
Do you have special policies for vulnerable clients?
Yes, spotting signs of vulnerability and dealing with clients appropriately is a key area of focus for us. Each operations team has a vulnerable client champion who is specially trained with additional knowledge and skills to help, but all operational staff receive vulnerability training.
We have a vulnerable customer policy, framework and standalone systems to record potential vulnerability safely and in line with FCA and GDPR rules. Our support solutions include a single point of contact to large print, alternative literature formats, signature stamps and the ability to take instructions via the best channel for our customers.
Vulnerability is also considered at all levels of the business from product reviews to communications and customer service in line with new Consumer Duty rules.
We have a Vulnerable Customer Working Group who help make fast decisions and tailor support for customers when their circumstances may call for bespoke assistance.
Our vulnerable customer outcomes:
- Understand, identify and record the needs of vulnerable customers within appropriate timescales through well trained and empowered people with easy access to appropriate resources.
- Safeguard vulnerable customers, and their data to prevent creating or exacerbating potential harm with effective governance, monitoring and product design to evidence good outcomes.
- Provide good outcomes for customers experiencing vulnerability through flexible processes, and clear communications.
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.
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 up to eight 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.
If your platform offers ready-made in-house portfolios, how aligned are the model portfolio names with the volatility ratings?
We don’t offer ready-made in house portfolios.
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 and other charges. 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.
How does cash work on the platform?
Cash in client accounts is pooled and may be held with one or more banking providers. Each client's individual holding within the pooled accounts is recorded by us, but not by the bank(s), and this individual holding for each product your client holds is referred to as the wrapper cash account.
All payments in, dividends, sale proceeds and the collection of your firm’s and our charges are managed through these accounts.
Is the wrapper cash account suitable for high balances or for use as an investment in its own right?
What interest rate does your wrapper cash account pay?
Are cash holdings in the wrapper cash account subject to the platform charge?
Do you offer access to third-party deposit accounts?
Does your platform charge clients to hold cash?
Does your platform retain any interest earned on client money? If so, how much?
Yes, our active management of customer cash means we can credit our customers with a competitive rate of interest. We retain some of what’s earned so we can keep our charges low, as well as invest in our technology, propositions and provide higher service levels. Our aim is to deliver excellent financial outcomes for our customers, and ultimately help make their retirement more rewarding. Our tiered rates are shown below.
Earned interest rate % of earned rate paid
0.00% - 1.00% inclusive 0%
>1.00% - 1.50% inclusive 50%
>1.50% - 5.00% inclusive 75%
>5.00% 90%
Details on our sharing policy are displayed online at https://nucleusfinancial.com/wrap/advisers/our-platform/costs-and-charges, along with the actual rates applied to customer accounts, and the level of cash interest rates retained is shown as a charge on client illustrations.
Several alternatives are available to clients, so they can obtain investment style returns on their spare cash, in some instances by locking into longer-term cash products. These include Bondsmith (from March 2024) offering a range of term deposits at several banks, money market funds, lower risk rate model portfolios and gilts and bonds through a stockbroker.
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 practice processes from their peers and industry subject matter experts.
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.
What does the Nucleus Wrap system look like? Is it easy to use?
Step-by-step guides and hints and tips are available from the platform library under the ‘User guides’ section.
Is the platform accessible 24/7?
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, Q1 2023) our rating is as follows:
- Industry average: 3.82 (out of 5)
- Nucleus average: 4.09 (out of 5)
Please describe any unplanned platform downtime over the past three years?
Who owns the underlying technology of your platform?
Nucleus Wrap is powered by core platform software from Bravura Solutions.
We develop our own in-house web services which control the adviser and client user experience and draw on the underlying administration, dealing and registry capabilities of Bravura.
Sonata, the Bravura platform we use, has particular strengths in:
- personalisation, real-time data access and 24/7 customer access
- streamlined processes and straight-through processing
- speed to market, configurability and scalability.
Bravura Solutions is listed on the Australian Stock Exchange and has over 30 years of experience. Its architecture enables the orderly administration of over £3trn of assets. Find out more about Bravura.
While Bravura’s software controls many of the core elements of workflow, order processing, registry and more, Nucleus’s own web services control many other elements, including:
- a wide range of integrations
- comprehensive reporting suites
- highly flexible adviser remuneration
- paperless application processes
- a full suite of tax wrappers
- and many more.
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 and 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). 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?
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. We have carried out initial due diligence on Bravura and refresh this on an annual basis.
Have you decided to change who provides the underlying technology of your platform?
We’ve taken the strategic decision to partner with FNZ over the medium to long-term. The move will bring a host of benefits and increase the scalability of our platform technology. In the meantime, we’ll continue to use Bravura’s next generation technology which has served our advisers and clients well since 2014.
If so, who have you changed from and to?
We will in time move to FNZ, which is market leading and incorporates the latest platform technology.
FNZ has a 15-year history in the UK of successful strategic partnerships with wealth management platforms, that have helped those platforms to continuously evolve the quality and personalisation of their services, while reducing costs to clients.
Their combination of highly configurable core platform services with state-of-the-art APIs (or interfaces) will enable us to differentiate without constraint.
With over 3,500 technology and investment employees across 16 countries, FNZ combines breadth and depth of expertise, global scale and continuous innovation that is highly regarded in the industry.
Please describe the rationale for this change including the benefits for clients and advisers?
We chose FNZ as we consider their technology and outsource capability to be as good as anything available in the market. The structure of the partnership will enable us to become a sustainably profitable and competitive business capable of investing in product, price and service.
FNZ is a complementary partner for us due to them being:
- A strong strategic fit – their consumer-focused mission is to help people achieve their financial goals, through partnerships with firms like us, and therefore enabling us to lower costs, improve digitisation and personalisation of the service we provide to adviser firms and their clients.
- Having a proven track record – they have a proven, highly scalable global solution and significant migration expertise, having implemented platforms for 150 financial institutions, including at least 40 substantial platform migrations.
- Strong support for financial advisers – a shared desire to enable financial advisers to be the best they can be, through the provision of market leading solutions, tools and customer service.
Advisers and clients will not only continue to benefit from our expertise, but also from the considerable investment FNZ has made over many years in the development of its market-leading technology, people and best-practices administration.
What disruption do you expect as a result of this re-platforming exercise?
There will be no immediate impact for our advisers and clients. In the short to medium-term we will continue to use Bravura’s next generation technology.
In the medium to long-term, we’re confident that there will be minimal disruption when we re-platform. FNZ has a track record of over 40 successful platform migrations, and has industrialised the process of platform transformation, to minimise risk and disruption for clients.
Do you plan on re-platforming or carrying out a significant upgrade over the next two years?
There will be no migration of our platform technology in the next two years. In the meantime, we’ll continue to utilise next generation technology which allows us to leverage the global expertise and the resources of Bravura via non-disruptive routine upgrades. We’ll always communicate upgrades to our users, as we have demonstrated over the years.
What are your best guess timescales for completion?
Once we’ve launched the new platform, we’ll transfer over the assets from James Hay Online. After that, we’ll bring across the assets from Nucleus Wrap. The first transfer of assets will only happen when we have certainty that it will be safe and smooth. The second will be after this, and likely not before 2025.
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 have extensive API connectivity across financial planning apps and CRM’s systems. This comprises all major providers including - intelliflo, Iress XPlan, Time4Advice, Sprint, Plannr, Adviser Cloud, Dynamic Planner, Twenty7Tec Finplan, Timeline, MoneyInfo, Prestwood Truth and Portfolio Matrix. We also support a number of bespoke integrations for firms inhouse CRM’s and DFM’s, and have a flexible two-way API that can integrated against to provide data services as required. We are constantly seeking to add to this list and welcome any conversations with any back office or third-party 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?
Yes, following the successful expansion of our scanned documents capability, we now accept electronic signatures for new business and client instructions. Users can choose from a range of e-signature software providers. More information can be found in our e-signatures guide: https://nucleusnutshell.bethebrand.com/mb/K4brp
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 1,500 people in 16 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. The team is made up of:
- six product managers
- 18 business analysts
- 21 developers
- 8 testers
- 6 programme managers/change analysts
What is it forecast to be in three years’ time?
We expect this area could increase by another 20 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 delivered a series of platform enhancements in 2022, including:
- Improved client experience, including paper reduction and robust security through Nucleus Go enhancements.
- Increased flexibility through enhancements like Flexible ISA and drawdown pot splitting.
- Scaling our capacity through new cloud-based infrastructure solutions.
- Delivery of regulatory change.
Our current roadmap includes:
- Updates to our integrations service.
- Phased drawdown enhancements.
- Narrate enhancements.
- Ensuring ongoing regulatory compliance.
What disruption do you expect because of any planned development?
Nucleus uses a blend of in-house development and core platform development with Bravura to minimise disruption to users.
This is separated to focus on where the user has touchpoints with the platform (i.e. digital apps) and core operational activity. In line with our core transformation project, and the timing of the move to FNZ, this is aligned to minimise this disruption seen by users so that those digital touchpoints will be interchangeable.
How often do you update your platform with new developments, functionality or bug fixes?
Each year we have a regular series of propositional software releases on our roadmap, which implement new product features or functionality. In addition, 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 on board 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, advisory board and the user feedback we obtain from advisers.
The platform development group meets twice a year and is made up of 15 Nucleus users – advisers, directors, business owners and operations managers. We also run regular platform user sessions giving users the opportunity to comment on developments to help improve user experience and we 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, making sure they support the advice market and drive value for all stakeholders, including end clients.
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.
How paperless are new business applications? Are there any elements of new business submissions that require paper?
How can I certify my client's age?
Do you provide online illustrations?
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?
Please describe the electronic re-registration process and average turnaround times
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 have a strict follow-up process to accelerate the transaction and users can check the progress via the 'in transit asset report' 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.
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 - a report which provides a list of your clients' details such as mailing addresses, emails and date of birth
- Client logins - a report which provides the last login date and status for your clients who can access Nucleus Go
- 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 - provides a list of in-transit assets processed on the platform, including their status amount and ceding information, by date
- Isa / Jisa contributions - a report of Isa allowances that haven’t been used for the current tax year
- 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 - provides the aggregated total value and number of units of individual assets across all of the advisers' clients
- Trades outstanding - a report on business currently in process
- Withdrawals and contributions - a report showing withdrawals and contributions to and from the platform
- Holdings: for external systems - provides a list of assets (including the cash balance) held on the platform for your clients' accounts formatted for import into 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 400 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. The tool also compares performance alongside over 120 benchmarks. 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've had limited demand for 'on-platform' tools 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 our tools:
- Illustrations - create an illustration of projected investment returns for any of the accounts within a portfolio
- Bulk model portfolio reassign and rebalance tool
- Bulk asset switch - switch all clients between investment assets
- Bulk cash switch - switch all clients from cash to an investment asset
- 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 portfolios
Contact your Nucleus business development representative for more information.
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?
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 very quickly.
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 trade online?
Can I bulk trade or bulk switch online?
How can I find a trade has settled?
Can I switch online, or do I have to instruct a separate sell and then buy?
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?
Can clients access the platform via an app?
Our mobile responsive client portal, Nucleus Go is available as a web application. It lets clients view their portfolios, transactions and correspondence at any time using their mobile device’s browser. Clients can also download and use our Nucleus Go iOS app which launched in May 2022.
Is client access 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, Q1 2023) our rating is:
- Industry average: 3.82 (out of 5)
- Nucleus average: 4.09 (out of 5)
Can I instruct withdrawals online?
Are there any charges for withdrawals?
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 administration reached £18.4bn (as at March 2023) and our administration and servicing levels have been maintained during the pandemic. We publish a service charter, including agreed service levels, to support your due diligence, and we actively encourage contact with our existing firm partners to understand their experience of our service levels.
Please list what adviser ratings you have achieved for service in past five years.
Over the past five years, we have achieved the following:
Winner - Defaqto Gold Service award 2023
Winner - Financial Adviser 5 star service awards 2019, 2020, 2021
Winner - Schroders Platform of the Year 2018
Winner – CoreData best medium-sized platform 2018, 2019, 2020
Winner – FT Adviser 5 star online service awards 2019
Have your adviser ratings improved or declined in this period?
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. We ask our users to rate us twice a year on various things and then gather a Net Promoter Score (NPS). We make sure to listen to our users and take action on these responses, communicating our actions via our "You Said, We Did" mechanism.
Surveys are great at taking a sentiment measure at a moment in time and for measuring progress, but the best insight we get is from speaking directly with firms. We run a quarterly Advisory Board comprised of representatives from Nucleus user firms that plays a pivotal role in helping our team understand what’s important to advisers, shaping the platform’s strategic direction and the development of the proposition. We also run User Sessions with operational contacts at firms to share what we have done with the feedback they gave last time and gather feedback on how things are going. Many parts of our business attend these so that we can make sure as many people as possible understand what is important to you.
Improvements resulting from this feedback include:
- Setting up a dedicated live support team who are now answering 93% of messages in under two minutes.
- Improving our answer rates across adviser call lines, and we’re now consistently answering 97% of calls, with an average waiting time of 13 seconds.
- Taking on feedback on support on Consumer Duty and coordinating a series of webinars with an expert, to help advisers meet the requirements. We’ve also launched an online hub with key information and resources.
Over the last year, our combined group has invested £4.5m in improving service and £12.6m in technology and transformation so we can better support advisers. These improvements are possible because of our scale. They’re initial steps on an exciting journey which has the needs of you and your clients at the heart of our planning.
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.
In terms of organisations which 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.
- 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 +28 (August 2022) demonstrating a clear level of advocacy from many of our users. Firms who use us as their primary platform gave us an NPS of +48.
How many people work in your servicing team?
Where are your servicing people based?
Do your servicing people work from home?
Will I be allocated dedicated field support?
Yes, each firm that actively engages with us will be allocated a small, dedicated team. They will be your personal contacts for any support or queries.
Your principal contact will proactively engage with you and support 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, they’ll support your business through project planning, training provision, and any technical queries, as required.
You’ll be given a direct line to each person on the team. This personalised service means that we’ll know each other well, making it even easier 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 to us, and view how these are progressing. Jira will also save you time, as you won’t need 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 us will be allocated a small, dedicated team.
You’ll be assigned a main contact for day-to-day platform support, case management and queries. They are based at our HQ and work in teams, so if your specific contact is unavailable, another member of the team will be on hand to help.
You’ll be given direct lines to all your contacts. 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 to us, 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 straightforward questions.
Our opening times are 8:30am-5:30pm Monday to Friday for live support and calls.
For firms that do not actively engage or sporadically use the platform, you'll still be able to access support through a centralised team who can provide ad hoc guidance on administration and processing as required.
You can find extensive online help for any service questions through our user guides in the platform library, and we also have a range of 'How-to' videos available via the platform support tab.
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 motivation and retention 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 and users) to ensure everyone is incentivised to help us build a durable business.
What contact methods are available to advisers? For example telephone, email and live online support?
Telephone: 0131 226 9535 – open Monday to Friday 8.30am to 5.30pm
Live chat: Available Monday to Friday 8.30-5.30pm
Email: Client.relations@nucleusfinancial.com
Secure Jira messaging: This can be used 24/7 and messages 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, thereby reducing the potential of fraud, which is always a risk inherent in email communications.
What specifically phone-based support do you offer?
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 clients contact you directly?
Will you accept trade instructions direct from my client?
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 onboarding 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, providing easy-to-access training, with a clear audit trail of completion and analysis of where any additional learning might be required.
Is your administration insourced or outsourced?
As part of our growth strategy and to give us more direct control in our operations, we acquired our back-office service provider, Genpact WM UK Ltd in December 2020. 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?
What's your approach to customer satisfaction?
Our aim is to make sure you and your clients are satisfied with our service. We aim to get things right first time, but where something does go wrong our policy is to fix it as soon as humanly possible.
We aim to deal fairly and promptly with any customer or adviser who is dissatisfied with our service. Complaints are all independently reviewed and seen as an opportunity to build better relationships and improve the way we work. As a regulated business we comply fully with the FCA’s complaint handling rules. You can find out more on our 'How to make a complaint' section on our website: https://nucleusfinancial.com/complaints
How many customer complaints have there been in the past 12 months?
For the 12 months to 31 December 2022, we received 249 client complaints. This is 2.4 client complaints per 1,000 accounts.
How many were referred to the Financial Ombudsman Service?
In total, seven complaints were referred to the Financial Ombudsman Service.
What percentage 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. You can find accurate up-to-the-minute technical information quickly and simply from our suite of tools including factsheets, case studies and videos.
You can find extensive online help for any service questions through our user guides in the platform library, and we also have a range of 'How-to' videos available via the platform support tab.
To complement our range of trusts, you'll be supported by our invaluable source of technical resources covering expert insight and the latest on pensions, tax and trust legislation. For access to technical webinars, blogs, tech talks and our latest illuminate articles, take a look at the Technical Hub for more information: https://nucleusfinancial.com/technical-hub
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. To complement our range of trusts, you'll be supported by our invaluable source of technical resources covering expert insight and the latest on pensions, tax and trust legislation. For access to technical webinars, blogs, tech talks and our latest illuminate articles, take a look at the Technical Hub for more information: https://nucleusfinancial.com/technical-hub
Do you provide technical support on all areas of your business?
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 our Narrate 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: https://nucleusfinancial.com/wrap/advisers/our-platform/tools-and-features/narrate-cg
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 Narrate CG 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: https://nucleusfinancial.com/wrap/advisers/our-platform/tools-and-features/narrate-cg
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: https://nucleusfinancial.com/wrap/advisers/our-platform/tools-and-features/narrate-cg
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 (https://illuminate.nucleusfinancial.com/) updated with new content every day, curated by us and authored by key industry experts, and an online technical studio (https://illuminate.nucleusfinancial.com/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 and client needs. 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 (https://www.nucleusfinancial.com/platform/narrate) Narrate CG (https://nucleusfinancial.com/wrap/advisers/our-platform/tools-and-features/narrate-cg) and our client portal, Nucleus Go (https://nucleusfinancial.com/wrap/advisers/our-platform/tools-and-features/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 (https://illuminate.nucleusfinancial.com/) 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 information. Illuminate highlights the latest thinking from expert commentators and encourages the sharing of content from advisers to advisers.
Illuminate learn (https://illuminate.nucleusfinancial.com/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.
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 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 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 maintain an incident response plan for any disruption to business continuity, at team and organisational levels. This framework uses a risk-based approach to manage any incident. 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 are overarching incident and crisis management plans. The platform runs across multiple availability zones within the hosting environment's UK Region, with a maximum recovery time objective (RTO) of four hours and recovery point objective (RPO) of 30 minutes.
Should an issue affect all availability zones within the UK, the platform can be restored within another region within 24 hours.
Monitoring is in place to ensure systems are working as expected across these zones. The process of switching operations is formally tested on an annual basis.
Each department’s business continuity action plan lists key roles and deputies to ensure that the right activities are prioritised. There are predefined processes for invoking the plan, and technical staff have documented steps to activate the disaster recovery systems.
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.
Nucleus and Bravura both have options for remote working in place that also mitigate disruption. These can be scaled up to support large numbers of people working remotely if needed, and people are also able to access other nearby offices. Workplace recovery plans include provisions 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. We will not accept instructions by email and our advisers use a secure messaging service to pass instructions to us. 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?
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?
At Nucleus, data plays a vital enabling role to allow us to achieve our objectives and deliver both outcomes for our advisers and clients, and corporate outcomes.
We are establishing an organisation wide focus on data governance and knowledge management, with a culture of collaboration, innovation and accountability that will allow us to deliver and maintain world class service and performance at a competitive cost. We are doing this through our network of Data Owners and Stewards with oversight and governance from our Data Governance Group, where we focus on strategic priorities on how we manage the data we hold.
Our Data Assets are fully catalogued in an Information Asset Register with risks and action plans associated and monitored. As we unlock our full data potential, we ensure greater alignment of the interests of advisers and clients within an agile, customer-focused, and risk-aware culture which is committed to transparency, ethical data use and the removal of complexity. 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: dataprotection@nucleusfinancial.com.
We’re a data controller for our products and tax wrappers and have appointed a Data Protection Officer who is a senior member of our team. We collect and hold data required to identify customers and manage their accounts with us. Our reason for holding client and adviser data is for contractual purposes, to satisfy regulatory requirements, and to provide our service.
Any data transfer outside of the UK will be documented in our privacy notice. 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.
If Nucleus were to fail, what would happen to client money and assets?
Should Nucleus 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 accurate books and records.
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 a 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' (https://nucleusnutshell.bethebrand.com/mb/j0VTS) – which explains protection in more detail.
What processes does 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 ad hoc 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. Most 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 has been verified as genuine.
