Frequently Asked Questions

Yes, Wealthify is authorised and regulated by the Financial Conduct Authority (FCA).

The FCA regulates the financial services industry in the UK. It has three operational objectives in support of this strategic goal: to protect consumers, to protect and enhance the integrity of the UK financial system, and to promote healthy competition between financial services providers in the interests of consumers.

Up to the first £85,000 of your money invested with Wealthify can be protected by the FSCS in the event of the insolvency of your custodian Winterflood Securities, or Wealthify.

Aviva and Wealthify are independently covered by the FSCS scheme, so a customer holding investments with both companies may be covered by the FSCS on each of their investment balances up to £85,000.

However, it’s important to understand that the FSCS doesn't cover you in the event that your investments do not perform as expected and you get back less than you originally invested.

When you sign up for a Wealthify Plan, we will use the bank details you give us and online sources such as the electoral roll and credit reference agency databases to check both your identity and address. We need to obtain this information in order to comply with UK anti-money laundering regulations.

Occasionally, we may not be able to verify your identity electronically, in which case we will get in contact with you to request additional forms of identification.

The type of identification we ask for will depend on what details we need to confirm. We will ask you to send one or more items from LIST A if we need proof of address identification, and one or more forms of ID from LIST B if we need proof of identity. Both lists are below.

Please note:

  • Please only send us certified copies of your photo ID – don’t send original copies, as we cannot accept responsibility if they are lost.
  • We accept original or certified copies of statements and letters, but unfortunately we can’t guarantee to return these, so don’t send originals if you need them back.

A certified copy is a photocopy or scan of your original ID, signed by a responsible third party to certify that it is a true copy – there’s a list of suitable certifiers below.

 

Proof of Address

N.B. Your proof of address MUST CLEARLY show your full address to be accepted. PO Boxes WILL NOT be accepted.

We will accept:

  • Utility bill issued within the past three months
  • Local authority council tax bill for the current council tax year
  • Bank, Building Society or Credit Union statement or passbook
  • Original mortgage statement from a recognised lender issued for the last full year
  • Solicitor’s letter confirming recent house purchase or land registry confirmation of address
  • Council or housing association rent card or tenancy agreement for the current year
  • Benefit book or original notification letter from Benefits Agency (not acceptable as proof of name)
  • Inland Revenue self-assessment or tax demand
  • NHS Medical card
  • Letter from a Care Home

 

Proof of identity

DO NOT send originals of the documents in this list as we CANNOT guarantee to return them and we DO NOT accept responsibility for loss of original documents sent to us.

Please send certified copies only – i.e. a photocopy or scan of your original ID, signed by a responsible third party to certify that it is a true copy. A list of suitable certifiers can be found below.

We will accept

  • EEA member state identity card (this can also be used as evidence of address if included)
  • Current UK or EEA photocard driving licence
  • Full old-style (paper) driving licence
  • Photographic registration cards for self-employed individuals in the construction industry -CIS4
  • Benefit book or original notification letter from Benefits Agency
  • Firearms or shotgun certificate
  • Residence permit issued by the Home Office to EEA nationals on sight of own country passport
  • National identity card bearing a photograph of the applicant

 

Approved certifiers

The person who certifies the copy of your original identification must hold a position of responsibility, such as those described in the list below.

The person certifying your documents must also:

  • Print their name, sign and date the copy document and state in writing ‘I certify this to be a true copy of the original document, which I have seen’
  • Confirm their position (in line with acceptable certifiers list below) and provide a contact telephone number or email address where they can be contacted
  • Where a document has a photograph, the certifier must confirm in writing ‘I certify that this is a true likeness of (your name)’

If available, they should stamp the copy with an official company stamp.

Where do I send my documents?

You can send your ID in the post to Wealthify, Tec Marina, Terra Nova Way, Penarth, CF64 1SA.

It’s up to you. You should not send any original ID to us, as we cannot take any responsibility for it being returned safely to you, this makes it less necessary to use registered post, however you can if you wish.

No, we don’t run a formal credit check. We use the credit reference agencies to verify your details and this leaves a footprint on your profile, but it doesn’t affect your credit rating in the same way as a credit check.

Our Terms and Conditions are available to download and read. You will be asked to read and accept them when you sign up, and you can find a link to them from the footer of our website. 

You can find all of Winterflood Securities Limited policies by clicking on the links below:

Privacy Policy

Conflicts of Interest Policy

Complaints Policy

Best Execution Policy

New legislation called MIFID II is coming into effect on 3 January 2018. As a result, we require you to advise us of your nationality. If you are a non-UK national or have multiple nationality you will need to provide your National Client Identifier (NCI).

Its full name is Market in Financial Instruments Directive II.  Its key aims are to offer better investor protection and increase transparency.
It does this in several ways, and we’ve included the highlights below.

Costs & charges
Traditionally some investment companies haven’t included all the costs that relate to the service provided. For instance, not including fund charges or the transaction costs related to buying and selling investments. These must now be included to make it clear exactly what you’re paying for. 

Research has previously found that some customers struggle to understand charges when displayed as percentages. MiFID II requires investment companies to show this in both percentages and monetary amounts making it easier to see what the service costs you.

Knowledge & competence of employees
MiFID II introduced new rules around the knowledge and competence of employees, ensuring that the employees you speak to have an excellent understanding of the products and services we offer. Clearly, this has always been a top priority for us! 

Suitability
The new regulation has strengthened the rules around ensuring that companies offer their customers suitable investment portfolios. We do this when you go through our questionnaire when you first sign up to Wealthify.

Transaction Monitoring
We are now required to report the trades we place to the regulator, the Financial Conduct Authority (FCA). This allows the FCA to keep tabs on all the trades placed by investments companies throughout the UK to protect the financial system and you from any potential market abuse, sometimes called insider trading.

If you do not provide your nationality details, we will not be able to buy and sell exchange-traded funds (ETFs) on your behalf, and this could impact on the performance of your Wealthify Investment Plan.

The new rules require us to share your name, date of birth, nationality and National Client Identifier (NCI) with the Financial Conduct Authority (FCA) for every ETF trade we place on your behalf.

We issue a yearly tax statement to customers who hold investments within a general investment account (GIA) or in other words a 'non-ISA' account.

If you hold a GIA you will receive a consolidated tax certificate (CTC) which includes details of any dividends and income for the period.

As dividend, income or capital gains are not reportable on ISAs, you will not receive a report if you hold an ISA plan.

Each time we buy and sell investments on your behalf, it results in a capital gain or loss. Your account will contain all transaction information which can then be used to calculate this figure, since we may still trade on your behalf during periodic rebalancing of customers’ plans. If you need to declare capital gains on your self-assessment tax return, you’ll need to combine this figure with any other capital gains or losses made from other investments you hold. If you're subject to UK tax in the usual way you have a capital gains total allowance of £12,000 in the financial year 2019/20 and will only need to report total gains in excess of this.

Receiving a CTC does not mean that you have to complete a tax return — we are required to send this information to customers who held any investments outside an ISA for any time during the period.

If you’re unsure if you have to complete a tax return, visit www.gov.uk/self-assessment-tax-returns/who-must-send-a-tax-return or call the HMRC helpline on 0300 200 3300.

Learn more about Capital Gains Tax: www.gov.uk/topic/personal-tax/capital-gains-tax

 

The tax treatment of your investment will depend on your individual circumstances and may change in the future.

 

Our Pillar 3 Statement

Wealthify Limited 2019 Pillar 3 and Remuneration Code Disclosure
FCA Reference Number: 662530 

1. Background

The European Union’s Capital Requirements Directive (“CRD”) came into effect on 1 January 2007 and introduced a set of regulatory capital adequacy standards and associated supervisory framework across the European Union.  Within the United Kingdom, this is governed by the Financial Conduct Authority (“FCA”) in its regulations through the General Prudential Sourcebook (“GENPRU”) and the Prudential Sourcebook for Banks, Building Societies and Investment firms (“BIPRU”).

The CRD framework consists of a three “Pillar” approach:

  • Pillar 1 establishes minimum capital requirements, defines eligible capital instruments, and prescribes rules for calculating risk weighted assets;
  • Pillar 2 requires banks and investment firms to have an Internal Capital Adequacy Assessment Process (“ICAAP”) and requires that regulatory supervisors evaluate each firm’s overall risk profile as well as its risk management and internal control processes; and
  • Pillar 3 encourages market discipline through a prescribed set of disclosure requirements which allow market participants to assess the risk and capital profiles of banks and investment firms.

The requirements for Pillar 3 disclosures are detailed in the FCA Handbook of Rules and Guidance under BIPRU 11.

 

2. Disclosure

The rules in BIPRU 11 provide that a firm may omit one or more of the required disclosures if it believes that the information is immaterial. Materiality is based on the criteria that the omission or misstatement of material information would be likely to change or influence the assessment or decision of a user relying on that information for the purposes of making economic decisions.

The firm is also permitted to omit one or more of the required disclosures where it’s believed that the information is regarded as proprietary or confidential. Proprietary information is that which, if it were shared, would undermine the firm’s competitive position. Information is considered to be confidential where there are obligations binding the firm to confidentiality with its clients and counterparties.

If Wealthify have omitted information for any of the above reasons, a statement explaining this will be provided in the relevant section.

The Pillar 3 disclosure will be reviewed on an annual basis as a minimum. The disclosures will be published as soon as is practical following the finalisation of the ICAAP and the publication of our annual reports. The information contained in this disclosure has not been audited by our external auditors and does not constitute any form of financial statement.

All figures contained in this disclosure are based on our Board approved ICAAP report of 30th November 2019.

 

3. Firm Profile

Wealthify Limited (“Wealthify”) is a wholly owned subsidiary of Wealthify Group Limited. Wealthify provides discretionary investment management services and is authorised and regulated by the FCA and is categorised as a limited license firm for capital adequacy purposes.

Aviva Group Holdings Limited have a majority share holding of Wealthify Group Limited.

 

4. Risk Management

Wealthify is governed by its directors who determine its business strategy and risk appetite. They are also responsible for establishing and maintaining the governance arrangements along with designing and implementing a risk management framework that recognises the risks that our business faces.

The directors also determine how the business risks may be mitigated and continually assess the arrangements to manage those risks.  The Board of directors meet on a regular basis and discuss current projections for profitability, cash flow, regulatory capital management, and business planning and risk management.

They manage Wealthify’s risks though a framework of policy and procedures having regard to relevant laws, standards, principles and rules (including principles and rules of the FCA) with the aim to operate a defined and transparent risk management framework. These policies and procedures are updated as required.

Areas of risk to which Wealthify are exposed include credit risk, market risk, operational risk and liquidity risk.

  • Credit Risk
    Wealthify does not extend credit to its clients.  Revenue is gained from annual management fees received from clients based on a percentage of assets under management. These charges are made directly to the clients’ portfolios therefore the credit risk relating to this income is negligible.
  • Market Risk
    We are indirectly subject to market risk as a significant element of income is dependent upon the value of client assets under management. This risk is mitigated by the asset allocation strategy adopted, which ensures that clients have highly diversified portfolios with limited exposure to any one asset class. Accordingly, exposure to market risk is considered minimal.
  • Operational Risk
    Operational risk is defined as the potential risk of financial loss or impairment to reputation resulting from inadequate or failed internal processes and systems, from the actions of people or from external events.

    Major sources of operational risk include IT security, internal and external fraud, outsourcing of operations, implementation of strategic change and regulatory non-compliance.}

    Wealthify operates a robust risk management process which is regularly reviewed and updated by the Board. Compliance have oversight and are responsible for the periodic reviews and recommending any changes to the Board.

    All senior management will bear responsibility for internal controls and the management of business risk as part of their accountability to the Board. Individuals are responsible for identifying the risks surrounding their work, implementing controls over those risks and reporting areas of concern to their line manager.

    Wealthify analyses its operational risk within the context of its risk management framework. This brings together an analysis of all possible risks that can have an effect on its business and considers the interconnectivity of those risks. We have identified a number of operational risks, which have been mitigated with systems and controls. The residual risks are perceived as low.
  • Liquidity Risk
    Wealthify maintains sufficient surplus cash to meet its working capital requirements and other immediate requirements that can reasonably be foreseen. This is supported by a robust budgeting and forecasting process which has the full involvement of the Board. The risk that the business will be unable to meet its financial obligations as they fall due is not considered material for the purposes of this disclosure. 

 

5. Capital Resources

5.1 Pillar 1
In accordance with the FCA handbook GENPRU 2.1.45R, which provides the calculation of variable capital requirement for a BIPRU firm, our capital requirement has been determined as being our fixed overhead requirement and not the sum of our credit risk capital requirement and our market risk capital requirement.

The Pillar 1 capital requirement for Weathify is £455,000.


5.2 Pillar 2

The capital required under Pillar 2 is the sum of the capital required under Pillar 1 plus any additional capital required to be maintained against risks not adequately covered by Pillar 1 capital. 

Wealthify’s overall approach to assessing the adequacy of its internal capital is set out in its ICAAP.  The ICAAP involves consideration of a range of risks we face and determines the level of capital needed to cover such risks. 

The level of capital required to cover identified risks is a function of their impact and probability and risk mitigation controls in place.  Wealthify’s Pillar 2 capital requirement, which is our own assessment of the minimum amount of capital that we believe is adequate against the risks identified, has been assessed as lower than our Pillar 1 requirement. There is a considerable surplus of reserves above the capital resource requirement deemed necessary to cover the risks identified.

Stress and scenario tests performed during the ICAAP support management’s view that adequate capital is held by the firm under Pillar 2.  


5.3 Regulatory Capital

Wealthify’s capital resources for regulatory purposes is:

Capital Item

 

Total Tier 1 capital

£455,000

Total Tier 2 capital

£0

Deductions from Tier 1 and Tier 2 capital

£0

Total capital resources, net of deductions

£455,000

 

6. Remuneration Code Disclosure

The objective of the FCA’s Remuneration Codes is to ensure that all regulated firms have risk-focussed remuneration policies which are consistent with and promote effective risk management and do not expose the firms to excessive risk.

  • Remuneration Committee
    Wealthify has a Remuneration Committee comprising of company directors who have the responsibility of setting the Remuneration Policy.

    Decisions over remuneration considers relevant legal and regulatory requirements, including the FCA’s rules and guidance concerning conflicts of interest and senior manager systems and controls under the SYSC handbook, as well as the UK Corporate Governance Code.

 

  • Pay and Performance
    Competitive salaries form the basis of our remuneration package. In addition, there is an element of variable pay for all staff which is based on firm wide and individual performance and comparison against the market rate. Whilst most of the variable reward components are awarded to employees across the business, the structure, balance and amounts may differ.

    When assessing individual performance, we use a robust performance review process, which includes qualitative criteria and compliance with the company policies and procedures.

 

  • Aggregate Quantitative Information on Remuneration
    We are subject to data protection legislation when disclosing remuneration information. Such legislation prohibits disclosing information that will result in individual information being easily identifiable. Remuneration disclosures will therefore be made on a limited basis in terms of any publicly or Company-wide circulation. However, all necessary information will be made available to a regulatory authority on request.