G. Appropriateness and suitability
Appropriateness test for transaction-based investment advice
In the case of transaction-based investment advice, the financial institution provides investment advice for individual transactions without taking into account the entire client portfolio.
In this case, the financial institution must ascertain the client's knowledge and experience before recommending financial instruments. In addition, before recommending financial instruments, it must be determined whether they are appropriate for the client.
In particular, the company must ensure that it is aware of the client's knowledge and experience in relation to each relevant investment category used in the financial service.
Suitability test for portfolio-based investment advice and asset management
When providing portfolio-based investment advice, the financial institution provides investment advice that considers the client portfolio. When providing asset management services, the financial institution must also consider the entirety of the client portfolio it manages. In contrast to investment advice, it also makes the investment decision itself.
In both these cases, the financial institution must determine the financial circumstances and investment objectives as well as the knowledge and experience of the clients. In this context, the knowledge and experience relate to the financial service and not to the individual transactions.
The information gathered by the financial institution about the knowledge and experience of the clients must take account of the investment strategy, and the granularity of the survey must be adapted to the complexity and risk profile of the investment and the investment strategy. In particular, the financial institution must be certain about the knowledge and experience of the clients in relation to each relevant investment category used in the financial service.