Solutions / Independent advisors

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.

Pilot
90 days, free
Seats
3 to 5
Data
EU only
Writes back
Nothing

What this book looks like from here.

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.

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.

03

Growth makes it worse.

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

76%
of advisers want AI-enabled systems to take on routine work.
Capgemini World Wealth Report 2026 (1.317 relationship managers, 24 markets)

What it looks like on the day.

Three pieces of the product, at the sizes they render at. Synthetic data throughout: every name and figure below is invented.

Signal feed2 today
Vandenberg, S.89%

Risk language changed between the last two reviews.

Microsoft 365 · 2 messages and 1 meeting · 28 days
Re-run the risk profile at the next review
Routed to J. de Vries
Hoffmann, L.81%

An annual review is overdue and not rebooked.

Microsoft 365 · 2 messages · 16 days
Signals surface what changed across the book: the second pair of eyes an independent firm does not otherwise have.
Health Score
74down 6 in 30 days
Two questions about drawdown left unanswered since May.
A Health Score you can open, so it is something to act on rather than another dashboard number.
Evidence

Suitability evidence written at point of advice

MiFID II · rule fired
09.07.2026 16:52 · deterministic
The file finishes when the conversation does, and the rule that produced it is named on the record.

Two engines, and a rules core that never guesses.

The three things you just saw, and where each of them comes from.

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. Tabular models are on the roadmap and are drawn that way.

What is connected, and what is not.

Microsoft 365 and Salesforce are live today. The two drawn dashed are on the roadmap and are not shipped. We would rather tell you that than let you assume otherwise. Nothing is written back into any of them: Luscent reads, and your systems of record stay exactly as they are.

Where this sits against the rules.

Fig. 2Relationship Intelligence for Independent Advisors | LuscentThe same communications feed two paths. A language model produces a Signal, which carries a numeric confidence and decides nothing. A deterministic rules engine, fed by MiFID II Article 25, GDPR Articles 28 and 32 and EU AI Act Article 50, produces a compliance record, which carries no confidence because a rule has none, and names the rule that fired. A named person decides on both paths.CommunicationsMail, calendar, meetingsYou already have themLanguage modelProbabilisticSignalCarries a confidence: 91Decides nothing.Puts it in front ofa person.Rules engineDeterministicCompliance recordCarries no confidenceA rule has noneto carry. The rulethat fired is named.MiFID II Art. 25 · GDPR Art. 28 and 32 · EU AI Act Art. 50
One body of communications, two paths out of it. The Signal carries a number because a model produced it. The record carries none, because a rule has none to carry, and it names the rule that fired.
MiFID II
Article 25
Suitability evidence generated as advice happens rather than written up after.
DeterministicTimestamped suitability record written at the point of advice
GDPR
Articles 28 and 32
Processed and stored in the EU. Paris primary, Warsaw disaster recovery.
DeterministicProcessing record with lawful basis, retention and location
UK Consumer Duty
Not shipped
On the roadmap, not shipped. We would rather say so.
DeterministicNothing yet

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.

Who asks what.

Fig. 3Relationship Intelligence for Independent Advisors | LuscentPrincipal, Operations, Data protection, Compliance officer, Adviser. Each holds a different concern and the deal advances only when the last of them is satisfied.PrincipalCost at our sizeOperationsWhat we runData protectionWhere data goesCompliance officerThe inspection fileAdviserBeing wrongTHE DEAL ADVANCES WHEN THE LAST OF THESE IS SATISFIED, NOT THE FIRSTEach answered below
The seats that have to be satisfied, and the concern each one carries. Every question below is the first thing that seat asks.
Principal#leadership
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.
Operations#operations
What do we have to run?
Nothing. Luscent is hosted, reads from the systems you already use, and writes back into none of them.
Data protection#technology
Where does client data go?
The European Union only. Paris primary, Warsaw for recovery, and no non-EU model API in the path of client data.
Compliance officer#compliance
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.
Adviser#adviser
Will it get things wrong?
Yes, and section 07 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.

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.

Fig. 4Relationship Intelligence for Independent Advisors | LuscentLuscent reads mail, calendar, meetings and CRM records. Telephone calls, conversations in person, personal channels and anything on a system it is not connected to are outside what it can see. Deterministic outcomes are exact and carry no confidence; probabilistic Signals carry a number; anything outside the boundary carries nothing because it is not there.WHAT IT READSMailCalendarMeetingsCRM recordsINVISIBLE TO ITTelephone callsCorridor conversationsPersonal channelsAnything not connectedDeterministic outcomes are exact and carry no confidence. Probabilistic Signals carry a number.Anything in the right-hand box carries nothing at all, because it never reached the system.
The edge of what the system knows. A relationship conducted outside the left-hand box does not appear in it at all, and no confidence number is attached to something that never arrived.
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.
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.
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.
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.
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.

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, before you have to ask for them.

Fig. 5Relationship Intelligence for Independent Advisors | LuscentLuscent writes nothing into your systems, takes no decision and produces no client-facing output. Those three facts hold today. Whether a deployment is a critical or important function remains your firm's classification to make, and your outsourcing officer owns it.01Does it write into yoursystems?No02Does it take a decision?No03Does it produceclient-facing output?NoYour firmclassifies.We publish the facts.Your officer owns it.All three answers hold today and are checkable in the table below and in the Trust Center.
The three questions an outsourcing review opens with, and the answers that hold today. The fourth box is not an answer on purpose: the classification is the firm's, and a vendor drawing it as settled would be overreaching.
Written back into your systems
Nothing
Fact
Decisions taken by the system
None. A named person decides.
Fact
Output shown to your clients
None. Luscent is used by your staff.
Fact
Client data location
European Union only. Paris primary, Warsaw recovery.
Fact
Sub-processors with access to client data
One. The full list is published.
Fact
Training on client data
None.
Fact
Security certification held
None. Controls aligned to ISO/IEC 27001:2022; certification planned 2027.
Fact
Audit and inspection rights
Your firm, its statutory auditor and its competent authority.
Position
Transition assistance on exit
Twelve months.
Position
Material sub-contracting
Prior written approval.
Position
Register of Information data sheet
Provided 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. The clause set behind the second group is Article 30 of Regulation (EU) 2022/2554.

Read the full Trust Center

Whether this is a fit.

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 built 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

The pilot is ninety days, free, with three to five relationship managers, starting on synthetic data. Success metrics are agreed before day one, so at the end there is something to judge rather than an impression.