[00] Who it is for · Independent advisorsSynthetic data throughout

You are the advisor and the compliance function.

An independent firm does not have a compliance department. It has an advisor doing compliance in the evening, from memory, about a conversation from three weeks ago. Luscent writes the evidence while the advice happens.

The pilot, in four factsCheckable on this page

  • Pilot90 days, free
  • Seats3 to 5
  • DataEU only
  • MigrationNone
Your outsourcing officer opens with three questions. They are answered below.
SignalSynthetic
Critical · needs actionAdvice restricted
von HabermannHNW · 18,5 Mio. EUR

Suitability review lapsed · advice restricted

The annual suitability review lapsed on 31 August. Advisory capability is restricted until it is refreshed: if the client calls today, no advice can be given.

18,5 Mio. EUR at riskComplianceT-1186 · To do
100 % · RuleToday 06:00
Produced byA rule, not a model
Review lapsed31.08.2026
Turned intoT-1186 · To do

One signal, in the product. The review lapsed on 31 August, so advice is restricted until it is refreshed, and the product says so before the client calls.Synthetic data. Every name and figure is invented.

[01] The bookIndependent advisors

What this book looks like from here.

Three patterns that hold across firms like yours, and one number from outside that frames them.

76%

of advisers want AI-enabled systems to take on routine work.

Capgemini World Wealth Report 2026 (1.317 relationship managers, 24 markets)

Observation 01

The file is written last and remembered worst.

Documentation happens when you are tired, from memory, about the exchange you can least clearly recall.

Observation 02

There is no second pair of eyes.

A bank has a supervision layer that catches what one person misses. An independent firm has whatever that person noticed on the day.

Observation 03

Growth makes it worse.

The constraint on how many clients you can serve well is not capital. It is attention.

The figure is somebody else's number about the market, with its source. It is not a Luscent result.

[02] Who asks whatFive seats

Who asks what.

The seats that have to be satisfied, and the concern each one carries. Every question below is the first thing that seat asks, with the answer that holds today.

PrincipalCost at our size

Is this affordable at our size?

The pilot is free for ninety days with three to five seats, and the commercial model is per seat rather than per institution. Nothing here is priced for a bank.

OperationsWhat we run

What do we have to run?

Nothing. Luscent is hosted and reads from the systems you already use.

Data protectionWhere data goes

Where does client data go?

The European Union only: stored on Scaleway in Paris, with the data and AI services on Hetzner in Germany, and no non-EU model API in the path of client data.

Compliance officerThe inspection file

What does the file look like at an inspection?

A timestamped record of the advice, its basis and the client circumstances relied on, with the rule that produced it named. It is generated as the advice happens rather than reconstructed afterwards.

AdviserBeing wrong

Will it get things wrong?

Yes, and section 06 says where. Probabilistic Signals carry a numeric confidence, deterministic outcomes carry none because they need none, and false positives are triaged weekly during the pilot.

[03] The productSynthetic data throughout

What it looks like on the day.

Three pieces of the product, in the order a relationship manager meets them: a Signal, the Health Score it moves, and the evidence a rule writes. Every name and figure is invented.

Signals Today
Vandenberg, S.89 %
Retail client · Netherlands · 2.150.000 EUR

Risk language changed between the last two reviews.

Microsoft 365 · 2 messages and 1 meeting · 28 days
Task: Re-run the risk profile at the next reviewJ. de Vries
Hoffmann, L.81 %

An annual review is overdue and not rebooked.

Microsoft 365 · 2 messages · 16 days
Signal, then Task

Signal

Signals surface what changed across the book: the second pair of eyes an independent firm does not otherwise have.

Vandenberg, S. · Health Score

74down 6 in 30 days
827873

Two questions about drawdown left unanswered since May.

0 to 100 · opens onto its sources

Health Score

A Health Score you can open, so it is something to act on rather than another dashboard number.

EvidenceNo confidence · a rule
RecordSuitability evidence written at point of advice
RuleMiFID II · rule fired
Written09.07.2026 16:52 · deterministic
ClientVandenberg, S.
Decided byJ. de Vries, a named person
Deterministic · on the record

Evidence

The file finishes when the conversation does, and the rule that produced it is named on the record.

Four use casesOne trigger each, start to finish
[04] The rulesProduct regulation only

Where this sits against the rules.

Each row names its article, its method and what it puts on the record. A row that is not shipped says so, and is drawn that way.

FrameworkMethodWhat it puts on the recordWhat that means
MiFID IIArticle 25
Deterministic
Timestamped suitability record written at the point of advice
Suitability evidence generated as advice happens rather than written up after.
GDPRArticles 28 and 32
Deterministic
Processing record with lawful basis, retention and location
Processed and stored in the EU: Scaleway in Paris and Hetzner in Germany.
UK Consumer DutyNot shipped
Roadmap
Nothing yet
On the roadmap, not shipped. We would rather say so.

This describes what Luscent does, not what your firm is obliged to do. It is not legal or compliance advice. The platform generates evidence and surfaces Signals; decisions remain with the firm and its professionals at all times.

[05] FitIndependent advisors

Whether this is a fit.

Said plainly, both ways, so nobody spends ninety days finding out what one page could have told them.

Built for

  • Independent firms running Microsoft 365
  • Advisors who write up files after the client work rather than during it
  • Firms where growth is limited by attention rather than by capital

Not for

  • Firms looking to replace their CRM or their platform
  • Firms wanting the system to make or approve an advice decision
  • Sole practitioners, for whom a per-seat tool is the wrong shape
[06] The common groundThe same for every firm

The same for every firm.

Five things that do not change with the kind of firm you are. Each one opens in place.

06.1

Where Luscent sits in your operating model.

An independent advisory practice runs its Clients across front, middle and back office on systems it already owns, and Luscent replaces none of them. The numbers mark the three places relationships are most often lost. Select a tile.

Luscent todayLuscent, in buildYour systems10 today · 6 in build · select a tile
Front office
Client management
Advice
Portfolio management
Middle office
Orders
Investment control
Back office
Servicing
Reporting
Oversight and control
Systems you already run

Luscent today

Health Score for every Client, 0 to 100

Every Client carries a Health Score from 0 to 100, updated from the conversations Luscent reads. A falling score is the early sign that a relationship is cooling, before it shows in the assets.

See it on the day, section 03 →
  1. 1A relationship cools between reviews, and the first sign anyone sees is the transfer request.
  2. 2Advice is given on a call and written up later, from memory.
  3. 3Supervision reads a sample of files, weeks after the conversation.

Luscent reads only the systems it is connected to, listed under What is connected below. In build means designed and in development; no date is promised on this page.

06.2

Two engines, and a rules core that never guesses.

The three things you saw in section 03, and where each of them comes from.

01
CommunicationsInput
Language models, EU-hostedProbabilistic
Signals, Health Scoreswith a confidence
Live
02
Structured dataInput
Tabular modelsProbabilistic
Signals, Health Scoreswith a confidence
Roadmap
03
The same recordsInput
Deterministic rulesNo model in the path
Evidencewith the rule that fired
Live

A Signal carries a confidence because a model produced it. A compliance outcome carries the rule that fired and no confidence at all, because a regulatory result is not a guess.

Inference is EU-hosted, by EU providers only, with no US model API in the client-data path. Tabular models are on the roadmap and are drawn that way.

06.3

What is connected, and what is not.

2 of 4 live
Signals
Tasks
Evidence
Luscent, the intelligence layerAlongside your systems of record
Microsoft 365Mail, calendar, TeamsLive
SalesforceRecords and activityLive
Advisor platformsHoldings and valuationsRoadmap
PortfolioHoldings and returnsRoadmap
Your systems of recordUnchanged

Microsoft 365 and Salesforce are live today. The two drawn dashed are on the roadmap and not shipped. We would rather tell you that than let you assume otherwise. Luscent reads them and replaces none of them.

06.4

Where this gets it wrong.

Every firm evaluating this has been shown a confident wrong answer by something before. So the limits are on the page rather than in the room, and each one names the control that catches it.

Limit 01

Confidence is a number, not a feeling.

Every probabilistic Signal carries a numeric confidence on its face. Deterministic outcomes carry none, because they have none to state: the same input produces the same result every time.

Limit 02

It reads what it is connected to, and nothing else.

A relationship conducted by telephone, in person, or on a channel Luscent does not read is invisible to it. The systems drawing above is the whole of what it can see.

Limit 03

It surfaces, it does not decide.

No Signal approves advice and no score authorises an action. Every consequential decision is taken by a named person, and the record says who.

Limit 04

It will be wrong, and the pilot counts it.

False positives are reviewed weekly with your compliance function during the pilot, and the rate is one of the success metrics agreed before day one rather than something discovered at the end.

Limit 05

A thin month is a thin month.

The representation of a relationship accumulates from your own communications. Month six is worth considerably more than month one, and no amount of capital shortens that for anyone.

06.5

What your outsourcing officer needs.

Whether a deployment is a critical or important function is your firm's classification to make, and your outsourcing officer owns it. What we can do is put the facts that classification turns on in one place.

Your CRMStays the record

Luscent reads it and does not write to it.

Decisions taken by the systemNone

Every consequential decision is taken by a named person.

Where client data sitsEU only

Stored on Scaleway, Paris; services on Hetzner, Germany.

QuestionAnswerKind
Your CRMStays the system of recordFact
Decisions taken by the systemNone. A named person decides.Fact
Output shown to your clientsNone. Luscent is used by your staff.Fact
Client data locationEuropean Union only. Stored on Scaleway, Paris; services on Hetzner, Germany.Fact
Client data sent to a modelEU-hosted inference, EU providers only, no US model API in the client-data path.Fact
Sub-processorsNamed in the published list in the Trust Center.Fact
Training on client dataNone.Fact
Security certification heldNone. Controls aligned to ISO/IEC 27001:2022; certification planned 2027.Fact
Audit and inspection rightsYour firm, its statutory auditor and its competent authority.Position
Transition assistance on exitTwelve months.Position
Material sub-contractingPrior written approval.Position
Register of Information data sheetProvided on request, in the fields you have to file.Position

Fact means true today and checkable, here or in the Trust Center. Position means the stance Luscent takes into a negotiation; it binds nobody until it is in a signed agreement.