Relationship manager
- One answer for a household booked in two places
- A path to proceed, not only a refusal
OutcomeCross-border clients served from one view.
Use case 03 / 04 · Cross-BorderNot sure which fits? Find your firm type
Two rulebooks. One household. One defensible answer.
A household booked in Luxembourg and São Paulo answers to MiFID II and to CVM at the same time. Luscent evaluates one action under both, shows where they diverge, and when the action cannot be split, applies the stricter answer with a path to proceed.
- Trigger
- One action across two booking centres
- Checks
- MiFID II and CVM, each on its own terms
- Reconciles
- The stricter answer governs when the action cannot be split
- Decides
- The relationship manager, choosing a path
§ 01 · The story
From two desks to one answer.
- 01 · Today
Two desks, two answers.
A household booked in Luxembourg and São Paulo gets one proposal. One desk checks MiFID II, the other CVM, and neither sees the other's answer.
- 02 · The moment
One action, two rulebooks, side by side.
The same action is evaluated under both regimes with the same inputs, and the divergence is shown, not hidden in two systems.
- 03 · With Luscent
A path forward, on one record.
When the action cannot be split, the stricter answer governs and a path to proceed is offered. Both verdicts stay with the decision.
One finding, one decision at a time.
Household · two booking centres
Luxembourg · MiFID II
28.400.000 EUR
EU sleeve
Not evaluated
São Paulo · CVM
13.600.000 EUR
Brazil sleeve
Not evaluated
PROP-0113 · capital-protected note. One allocation across the household. It cannot be divided between the sleeves.
Cross-border · PROP-0113CVM Res. 30
Territorial by design. Each sleeve is judged under its own regulator, never a blend.
Evaluate under both regimes
Demo environmentSynthetic data. Klein Family Office and everyone named here are fictional.
Step 1 of 6: Two sleeves, one finding
§ 02 · Who gets what
One workflow, four people who stop chasing it.
Compliance officer
- Both verdicts side by side, each with its rule
- The reconciliation kept with the signed decision
OutcomeEvidence for two supervisors in one record.
Head of advisory
- Luxembourg and São Paulo teams working from the same record
- No household falls between two desks
OutcomeOne household, one position.
Management
- The corridor served without a parallel compliance process
- Luxembourg and Brazil books held to one standard of evidence
OutcomeGrowth in the corridor without a second process.
§ 03 · The business case
One evaluation where there used to be two.
Cross-Border works on the compliance effort of checking one household against two rulebooks. This is the part of the homepage estimate it addresses.
- 01Both regimes evaluated in one pass, same inputs
- 02The divergence shown before the proposal goes out
- 03Dual-regime evidence stored once
- PilotMeasured on your own book in the pilot, against success metrics agreed in writing before anything is connected.
Your firm
Compliance effort addressed
195.840 EUR a year
40 % of the compliance effort addressed
- Hours returned
- 2.304 h a year
- Per relationship manager
- 192 h a year
The working
12 relationship managers × 10 h a week × 48 weeks × 85 EUR an hour × 40 % of the effort addressed. The same model and assumptions as the estimate on the homepage. Modelled from time-and-motion assumptions, not measured client results.
§ 04 · Boundaries
What it always does, and what it never does.
Always
- Judges each booking sleeve under its own regulator.
- Shows both verdicts side by side, each with its rule.
- Offers a path to proceed, not only a refusal.
- Stores both verdicts, the reconciliation and the decision together.
Never
- Blends two regimes into one score.
- Chooses the path. The relationship manager does, and signs.
- Claims Swiss coverage. FinSA and FinIA are on the roadmap, not in the product.
§ 05 · The rule
Our reading of MiFID II, Article 25(2), and CVM Resolution 30/2021
“... to recommend to the client or potential client the investment services and financial instruments that are suitable for him ...”
Each booking centre answers to its own suitability rule, and an action that touches both has to satisfy both. The stricter-wins reconciliation is Luscent's design for an action that cannot be split, not a legal requirement.
Our reading, not legal advice. The rules engine applies the firm's own configuration of these rules, and the relationship manager decides.
§ 06 · Questions
Questions
Which jurisdictions does the rules engine cover?
MiFID II for the European Union, and the Brazilian CVM and ANBIMA rules, in the same deterministic engine. Swiss FinSA and FinIA are on the roadmap and not in the product today.
Why does the stricter rule win?
Because the action cannot be divided between the two sleeves. When it can be, each sleeve is judged on its own. The reconciliation is Luscent's design choice, shown on screen with both verdicts; it is not legal advice.
§ 07 · The same Loop
Three more triggers, one way of working.
Use case 01 · Suitability GateEvery trade checked before the advice leaves.
Before a relationship manager sends a rebalance, Luscent checks each trade against the mandate and the strictest jurisdiction, and names the smallest fix.
See it run Use case 02 · Comms to ComplianceAn email changes the client. The advice waits.When a client email says their circumstances changed, Luscent reads the change, holds the advice that relied on the old picture, and opens a reassessment.
See it run Use case 04 · Relationship DriftRelationships rarely end loudly. They drift.When a client relationship starts to slip, Luscent shows it in the Health Score, links the messages behind it, and puts the next conversation on the relationship manager's list.
See it runThe pilotCohort open
Find out before you move a single client record.
Ninety days, at no cost, with three to five relationship managers, starting on invented clients. Success metrics are agreed in writing before anything is connected, so at the end there is a decision rather than an impression.
The terms
- Length
- 90 days
- Cost
- Nothing
- Seats
- 3 to 5 relationship managers
- Data
- Synthetic first
- Client data
- Stays in the EU
- Writes back
- Nothing
- DAY 0Metrics agreed, in writing
- ConnectWeek 1 to 4
- WEEK 4The book, ranked
- First Signal acted onWeek 5 to 8
- WEEK 8A decision on the record
- ReviewWeek 9 to 13
- DAY 90Written review