Investment Operations Certificate

Introduction: focus

roles, participants, markets and the purpose of financial services

Introduction: control

Map the relevant actor, transaction or exposure through the Introduction process, then identify the control owner, evidence and escalation point.

Introduction: common error

Avoid treating every institution or market as performing the same role.

Economic Environment: focus

economic indicators, policy and their effects on markets and investors

Economic Environment: control

Map the relevant actor, transaction or exposure through the Economic Environment process, then identify the control owner, evidence and escalation point.

Economic Environment: common error

Avoid reversing the effects of interest-rate, inflation or exchange-rate changes.

Equities: focus

share types, ownership rights, issuance, trading and equity valuation signals

Equities: control

Map the relevant actor, transaction or exposure through the Equities process, then identify the control owner, evidence and escalation point.

Equities: common error

Avoid confusing shareholder ownership rights with creditor claims.

Bonds: focus

bond cash flows, price-yield relationships, credit quality and market conventions

Bonds: control

Map the relevant actor, transaction or exposure through the Bonds process, then identify the control owner, evidence and escalation point.

Bonds: common error

Avoid assuming a fixed coupon means a fixed market value.

Other Markets and Investments: focus

money markets, foreign exchange, property, commodities and alternative exposure

Other Markets and Investments: control

Map the relevant actor, transaction or exposure through the Other Markets and Investments process, then identify the control owner, evidence and escalation point.

Other Markets and Investments: common error

Avoid mixing the liquidity, ownership and risk features of different asset classes.

Derivatives: focus

forward, futures, option and swap purposes, payoffs and core risks

Derivatives: control

Map the relevant actor, transaction or exposure through the Derivatives process, then identify the control owner, evidence and escalation point.

Derivatives: common error

Avoid ignoring leverage or the different obligations of buyers and sellers.

Investment Funds: focus

collective structures, pricing, dealing, charges and investor outcomes

Investment Funds: control

Map the relevant actor, transaction or exposure through the Investment Funds process, then identify the control owner, evidence and escalation point.

Investment Funds: common error

Avoid confusing open-ended fund dealing with exchange-traded share dealing.

Financial Services Regulation: focus

UK regulatory bodies, authorisation, conduct and customer protection

Financial Services Regulation: control

Map the relevant actor, transaction or exposure through the Financial Services Regulation process, then identify the control owner, evidence and escalation point.

Financial Services Regulation: common error

Avoid inferring permission or competence from qualification alone.

Taxation, Investment Wrappers and Trusts: focus

the purpose and broad treatment of UK taxes, wrappers and trusts

Taxation, Investment Wrappers and Trusts: control

Map the relevant actor, transaction or exposure through the Taxation, Investment Wrappers and Trusts process, then identify the control owner, evidence and escalation point.

Taxation, Investment Wrappers and Trusts: common error

Avoid using a tax rule without fixing the applicable date and taxpayer.

Other Financial Products: focus

insurance, pensions, mortgages and other common financial products

Other Financial Products: control

Map the relevant actor, transaction or exposure through the Other Financial Products process, then identify the control owner, evidence and escalation point.

Other Financial Products: common error

Avoid treating protection, credit and investment products as interchangeable.

Financial Advice: focus

fact finding, risk, suitability, disclosure and ongoing client service

Financial Advice: control

Map the relevant actor, transaction or exposure through the Financial Advice process, then identify the control owner, evidence and escalation point.

Financial Advice: common error

Avoid recommending a product before establishing objectives and capacity for loss.

The Regulatory Environment: focus

UK legislation, regulators, authorisation, accountability and regulatory objectives

The Regulatory Environment: control

Map the relevant actor, transaction or exposure through the The Regulatory Environment process, then identify the control owner, evidence and escalation point.

The Regulatory Environment: common error

Avoid confusing the FCA, PRA, Bank of England and government responsibilities.

Conduct of Business and Client Assets: focus

client classification, communications, service standards, suitability and CASS safeguards

Conduct of Business and Client Assets: control

Map the relevant actor, transaction or exposure through the Conduct of Business and Client Assets process, then identify the control owner, evidence and escalation point.

Conduct of Business and Client Assets: common error

Avoid applying the wrong conduct test or losing track of legal ownership and segregation.

Enhancing Market Integrity: focus

market abuse, financial crime, controls, reporting and ethical market behaviour

Enhancing Market Integrity: control

Map the relevant actor, transaction or exposure through the Enhancing Market Integrity process, then identify the control owner, evidence and escalation point.

Enhancing Market Integrity: common error

Avoid focusing only on criminal offences and ignoring regulatory or firm-control duties.

Complaints and Redress: focus

complaint handling, FOS, FSCS, limitation and customer remedies

Complaints and Redress: control

Map the relevant actor, transaction or exposure through the Complaints and Redress process, then identify the control owner, evidence and escalation point.

Complaints and Redress: common error

Avoid confusing eligibility, jurisdiction, compensation and complaint time limits.

Life Cycle of an Event: focus

announcement, capture, entitlement, election, payment and reconciliation stages

Life Cycle of an Event: control

Map the relevant actor, transaction or exposure through the Life Cycle of an Event process, then identify the control owner, evidence and escalation point.

Life Cycle of an Event: common error

Avoid skipping a deadline, status or reconciliation point in the event life cycle.

Mandatory Events: focus

automatic corporate actions and the processing of cash and securities entitlements

Mandatory Events: control

Map the relevant actor, transaction or exposure through the Mandatory Events process, then identify the control owner, evidence and escalation point.

Mandatory Events: common error

Avoid seeking an investor election where the event terms are mandatory.

Voluntary Events: focus

options, elections, deadlines, default choices and instruction management

Voluntary Events: control

Map the relevant actor, transaction or exposure through the Voluntary Events process, then identify the control owner, evidence and escalation point.

Voluntary Events: common error

Avoid assuming a late or absent instruction can always be corrected.

Corporate Governance: focus

voting, meetings, communications and the responsibilities attached to ownership

Corporate Governance: control

Map the relevant actor, transaction or exposure through the Corporate Governance process, then identify the control owner, evidence and escalation point.

Corporate Governance: common error

Avoid confusing beneficial-owner instructions with registered-holder mechanics.

Tax: focus

withholding, relief, reclaims, documentation and event-related tax processing

Tax: control

Map the relevant actor, transaction or exposure through the Tax process, then identify the control owner, evidence and escalation point.

Tax: common error

Avoid applying one investor's tax status or treaty outcome to every account.

Participants: focus

issuer, agent, CSD, custodian, broker and investor responsibilities

Participants: control

Map the relevant actor, transaction or exposure through the Participants process, then identify the control owner, evidence and escalation point.

Participants: common error

Avoid assigning an instruction or record-keeping duty to the wrong participant.

Legal and Compliance: focus

event terms, sanctions, disclosures, record keeping and regulatory obligations

Legal and Compliance: control

Map the relevant actor, transaction or exposure through the Legal and Compliance process, then identify the control owner, evidence and escalation point.

Legal and Compliance: common error

Avoid processing an event without checking legal, sanctions or disclosure constraints.

Risk and Controls: focus

operational risk, segregation, reconciliations, authorisation and exception management

Risk and Controls: control

Map the relevant actor, transaction or exposure through the Risk and Controls process, then identify the control owner, evidence and escalation point.

Risk and Controls: common error

Avoid relying on automation without ownership, evidence or escalation controls.

Fundamentals of Client Money and Assets: focus

the CASS purpose, scope, ownership, segregation and protection objectives

Fundamentals of Client Money and Assets: control

Map the relevant actor, transaction or exposure through the Fundamentals of Client Money and Assets process, then identify the control owner, evidence and escalation point.

Fundamentals of Client Money and Assets: common error

Avoid assuming all money received by a firm is client money.

Client Money Fundamentals (CASS 7): focus

client-bank accounts, trust status, receipts, payments and permitted placements

Client Money Fundamentals (CASS 7): control

Map the relevant actor, transaction or exposure through the Client Money Fundamentals (CASS 7) process, then identify the control owner, evidence and escalation point.

Client Money Fundamentals (CASS 7): common error

Avoid mixing firm money and client money outside a permitted or controlled exception.

Controls over Client Money (CASS 7): focus

records, reconciliations, calculations, acknowledgements and shortfall correction

Controls over Client Money (CASS 7): control

Map the relevant actor, transaction or exposure through the Controls over Client Money (CASS 7) process, then identify the control owner, evidence and escalation point.

Controls over Client Money (CASS 7): common error

Avoid treating a reconciliation difference as a bookkeeping issue with no prompt action.

Safe Custody Fundamentals (CASS 6): focus

custody registration, records, third parties, liens and asset protection

Safe Custody Fundamentals (CASS 6): control

Map the relevant actor, transaction or exposure through the Safe Custody Fundamentals (CASS 6) process, then identify the control owner, evidence and escalation point.

Safe Custody Fundamentals (CASS 6): common error

Avoid confusing physical or registered custody with beneficial ownership.

Governance and Oversight: focus

senior accountability, CASS oversight, audit, reporting and control assurance

Governance and Oversight: control

Map the relevant actor, transaction or exposure through the Governance and Oversight process, then identify the control owner, evidence and escalation point.

Governance and Oversight: common error

Avoid delegating a task and assuming responsibility has also transferred.

When Problems Arise: focus

shortfalls, primary pooling events, distribution and firm-failure responses

When Problems Arise: control

Map the relevant actor, transaction or exposure through the When Problems Arise process, then identify the control owner, evidence and escalation point.

When Problems Arise: common error

Avoid using normal-course processing after a pooling or insolvency trigger.

The Client: focus

client categorisation, agreements, disclosures, consent and client communications

The Client: control

Map the relevant actor, transaction or exposure through the The Client process, then identify the control owner, evidence and escalation point.

The Client: common error

Avoid using consent or disclosure that does not meet the relevant CASS condition.

Collective Investment Schemes: focus

open-ended, closed-ended and other collective structures and their features

Collective Investment Schemes: control

Map the relevant actor, transaction or exposure through the Collective Investment Schemes process, then identify the control owner, evidence and escalation point.

Collective Investment Schemes: common error

Avoid assuming every pooled product has the same legal form or dealing mechanism.

The Regulatory Framework: focus

UK fund rules, permissions, documents, oversight and investor protection

The Regulatory Framework: control

Map the relevant actor, transaction or exposure through the The Regulatory Framework process, then identify the control owner, evidence and escalation point.

The Regulatory Framework: common error

Avoid using a rule for the wrong fund type or jurisdiction.

Key Roles and Responsibilities: focus

operator, depositary, trustee, administrator, manager and auditor duties

Key Roles and Responsibilities: control

Map the relevant actor, transaction or exposure through the Key Roles and Responsibilities process, then identify the control owner, evidence and escalation point.

Key Roles and Responsibilities: common error

Avoid allocating pricing, custody or oversight responsibility to the wrong party.

Diversification and Investment Limits: focus

spread, concentration, borrowing, derivatives and eligibility limits

Diversification and Investment Limits: control

Map the relevant actor, transaction or exposure through the Diversification and Investment Limits process, then identify the control owner, evidence and escalation point.

Diversification and Investment Limits: common error

Avoid testing one limit in isolation and ignoring linked exposure rules.

Valuations and Pricing: focus

NAV, valuation points, pricing bases, dilution and error correction

Valuations and Pricing: control

Map the relevant actor, transaction or exposure through the Valuations and Pricing process, then identify the control owner, evidence and escalation point.

Valuations and Pricing: common error

Avoid mixing valuation, dealing and settlement times or signs.

Unit Dealing and the Register: focus

subscriptions, redemptions, settlement, registration and transfer processes

Unit Dealing and the Register: control

Map the relevant actor, transaction or exposure through the Unit Dealing and the Register process, then identify the control owner, evidence and escalation point.

Unit Dealing and the Register: common error

Avoid treating an order as ownership before the register and settlement are complete.

Launching a New CIS: focus

authorisation, documents, service providers, classes and operational readiness

Launching a New CIS: control

Map the relevant actor, transaction or exposure through the Launching a New CIS process, then identify the control owner, evidence and escalation point.

Launching a New CIS: common error

Avoid launching before approvals, documents and operating controls align.

Unit/Shareholder Rights: focus

meetings, voting, information, changes and investor remedies

Unit/Shareholder Rights: control

Map the relevant actor, transaction or exposure through the Unit/Shareholder Rights process, then identify the control owner, evidence and escalation point.

Unit/Shareholder Rights: common error

Avoid confusing fund-operator powers with investor approval rights.

Income: focus

income recognition, allocation, equalisation, distribution and accumulation

Income: control

Map the relevant actor, transaction or exposure through the Income process, then identify the control owner, evidence and escalation point.

Income: common error

Avoid confusing capital movements with distributable income.

Taxation: focus

fund and investor tax concepts, reporting and withholding

Taxation: control

Map the relevant actor, transaction or exposure through the Taxation process, then identify the control owner, evidence and escalation point.

Taxation: common error

Avoid assuming the fund's tax treatment determines every investor's outcome.

The Background and Nature of Financial Crime: focus

drivers, impacts, typologies, law, regulators and international standards

The Background and Nature of Financial Crime: control

Map the relevant actor, transaction or exposure through the The Background and Nature of Financial Crime process, then identify the control owner, evidence and escalation point.

The Background and Nature of Financial Crime: common error

Avoid treating financial crime as only money laundering.

Money Laundering: focus

placement, layering, integration, predicate offences and AML obligations

Money Laundering: control

Map the relevant actor, transaction or exposure through the Money Laundering process, then identify the control owner, evidence and escalation point.

Money Laundering: common error

Avoid assuming a transaction must complete before suspicion can arise.

Terrorist Financing: focus

fund raising, movement, use, indicators and counter-terrorist-financing controls

Terrorist Financing: control

Map the relevant actor, transaction or exposure through the Terrorist Financing process, then identify the control owner, evidence and escalation point.

Terrorist Financing: common error

Avoid assuming terrorist funds must originate from crime.

Bribery and Corruption: focus

offences, facilitation risks, gifts, hospitality, third parties and controls

Bribery and Corruption: control

Map the relevant actor, transaction or exposure through the Bribery and Corruption process, then identify the control owner, evidence and escalation point.

Bribery and Corruption: common error

Avoid relying on local custom instead of testing intent, value and influence.

Fraud and Market Abuse: focus

fraud schemes, insider dealing, manipulation, detection and response

Fraud and Market Abuse: control

Map the relevant actor, transaction or exposure through the Fraud and Market Abuse process, then identify the control owner, evidence and escalation point.

Fraud and Market Abuse: common error

Avoid collapsing distinct fraud and market-abuse tests into one offence.

Tax Evasion: focus

evasion, avoidance distinctions, facilitation offences and reporting risk

Tax Evasion: control

Map the relevant actor, transaction or exposure through the Tax Evasion process, then identify the control owner, evidence and escalation point.

Tax Evasion: common error

Avoid treating aggressive avoidance and criminal evasion as identical.

Economic Sanctions: focus

targets, restrictions, ownership, screening, licensing and breach response

Economic Sanctions: control

Map the relevant actor, transaction or exposure through the Economic Sanctions process, then identify the control owner, evidence and escalation point.

Economic Sanctions: common error

Avoid screening names only and ignoring ownership, control or transaction context.

Financial Crime Risk Management: focus

governance, risk assessment, CDD, monitoring, reporting, training and assurance

Financial Crime Risk Management: control

Map the relevant actor, transaction or exposure through the Financial Crime Risk Management process, then identify the control owner, evidence and escalation point.

Financial Crime Risk Management: common error

Avoid using a checklist without a documented, risk-based rationale and escalation path.

Introduction to Derivatives: focus

forwards, futures, options, swaps, payoffs, terminology and commercial uses

Introduction to Derivatives: control

Map the relevant actor, transaction or exposure through the Introduction to Derivatives process, then identify the control owner, evidence and escalation point.

Introduction to Derivatives: common error

Avoid confusing rights with obligations or hedge direction.

Underlying Markets: focus

equity, rate, bond, currency, commodity and credit underlyings

Underlying Markets: control

Map the relevant actor, transaction or exposure through the Underlying Markets process, then identify the control owner, evidence and escalation point.

Underlying Markets: common error

Avoid pricing a contract without identifying the correct underlying quotation.

Market Structure: focus

venues, participants, order flow, documentation and market infrastructure

Market Structure: control

Map the relevant actor, transaction or exposure through the Market Structure process, then identify the control owner, evidence and escalation point.

Market Structure: common error

Avoid assuming exchange-traded and OTC contracts use identical processes.

Principles of Pricing and Valuation: focus

no-arbitrage relationships, carry, discounting, volatility and valuation inputs

Principles of Pricing and Valuation: control

Map the relevant actor, transaction or exposure through the Principles of Pricing and Valuation process, then identify the control owner, evidence and escalation point.

Principles of Pricing and Valuation: common error

Avoid using inconsistent units, signs, dates or compounding.

OTC Derivatives: focus

bilateral terms, confirmations, master agreements, collateral and lifecycle events

OTC Derivatives: control

Map the relevant actor, transaction or exposure through the OTC Derivatives process, then identify the control owner, evidence and escalation point.

OTC Derivatives: common error

Avoid treating a master agreement as eliminating counterparty risk.

Principles of Clearing and Margin: focus

CCP clearing, initial and variation margin, default waterfalls and collateral

Principles of Clearing and Margin: control

Map the relevant actor, transaction or exposure through the Principles of Clearing and Margin process, then identify the control owner, evidence and escalation point.

Principles of Clearing and Margin: common error

Avoid confusing margin with the economic value or premium of a position.

Delivery and Settlement: focus

cash and physical settlement, expiry, exercise, assignment and fails

Delivery and Settlement: control

Map the relevant actor, transaction or exposure through the Delivery and Settlement process, then identify the control owner, evidence and escalation point.

Delivery and Settlement: common error

Avoid ignoring notices, cut-offs or deliverable specifications.

Trading, Hedging and Investment Strategies: focus

directional, spread, income, hedging and portfolio strategies

Trading, Hedging and Investment Strategies: control

Map the relevant actor, transaction or exposure through the Trading, Hedging and Investment Strategies process, then identify the control owner, evidence and escalation point.

Trading, Hedging and Investment Strategies: common error

Avoid selecting a strategy without checking payoff, basis risk and downside.

Regulatory Requirements: focus

conduct, reporting, clearing, margin and market-integrity obligations

Regulatory Requirements: control

Map the relevant actor, transaction or exposure through the Regulatory Requirements process, then identify the control owner, evidence and escalation point.

Regulatory Requirements: common error

Avoid applying one venue's or counterparty's regulatory treatment universally.

The International Regulatory Environment: focus

regulatory approaches, standard setters, markets, conduct and cross-border obligations

The International Regulatory Environment: control

Map the relevant actor, transaction or exposure through the The International Regulatory Environment process, then identify the control owner, evidence and escalation point.

The International Regulatory Environment: common error

Avoid assuming a global standard has identical legal force in every jurisdiction.

The Compliance Function: focus

independence, mandate, advice, monitoring, reporting, culture and assurance

The Compliance Function: control

Map the relevant actor, transaction or exposure through the The Compliance Function process, then identify the control owner, evidence and escalation point.

The Compliance Function: common error

Avoid making compliance the sole owner of first-line business risk.

Managing the Risk of Financial Crime: focus

AML, sanctions, bribery, fraud, risk assessment, due diligence and reporting

Managing the Risk of Financial Crime: control

Map the relevant actor, transaction or exposure through the Managing the Risk of Financial Crime process, then identify the control owner, evidence and escalation point.

Managing the Risk of Financial Crime: common error

Avoid using customer screening as a substitute for ongoing risk management.

Ethics, Integrity and Fairness: focus

ethical reasoning, conflicts, conduct, culture and fair customer outcomes

Ethics, Integrity and Fairness: control

Map the relevant actor, transaction or exposure through the Ethics, Integrity and Fairness process, then identify the control owner, evidence and escalation point.

Ethics, Integrity and Fairness: common error

Avoid equating technical legality with an ethical and fair outcome.

Governance, Risk Management and Compliance: focus

boards, control functions, risk appetite, policies, information and oversight

Governance, Risk Management and Compliance: control

Map the relevant actor, transaction or exposure through the Governance, Risk Management and Compliance process, then identify the control owner, evidence and escalation point.

Governance, Risk Management and Compliance: common error

Avoid confusing governance approval with effective implementation and evidence.

Main Industry Participants: focus

issuers, investors, intermediaries, venues, clearing systems, CSDs and custodians

Main Industry Participants: control

Map the relevant actor, transaction or exposure through the Main Industry Participants process, then identify the control owner, evidence and escalation point.

Main Industry Participants: common error

Avoid assigning execution, clearing, settlement and custody to the same actor.

Settlement Characteristics: focus

trade dates, matching, clearing, settlement cycles, delivery and settlement risk

Settlement Characteristics: control

Map the relevant actor, transaction or exposure through the Settlement Characteristics process, then identify the control owner, evidence and escalation point.

Settlement Characteristics: common error

Avoid confusing contractual trade status with final settlement.

Other Investor Services: focus

custody, safekeeping, corporate actions, income, proxy voting and reporting

Other Investor Services: control

Map the relevant actor, transaction or exposure through the Other Investor Services process, then identify the control owner, evidence and escalation point.

Other Investor Services: common error

Avoid treating custody as passive storage without asset-servicing obligations.

Aspects of Taxation: focus

transaction, income, withholding, relief and documentation concepts across markets

Aspects of Taxation: control

Map the relevant actor, transaction or exposure through the Aspects of Taxation process, then identify the control owner, evidence and escalation point.

Aspects of Taxation: common error

Avoid assuming the issuer market alone determines tax treatment.

Risk: focus

principal, counterparty, settlement, liquidity, operational and custody risk controls

Risk: control

Map the relevant actor, transaction or exposure through the Risk process, then identify the control owner, evidence and escalation point.

Risk: common error

Avoid naming a risk without identifying its exposure window and control.

Risk Basics: focus

risk, exposure, likelihood, impact, appetite, tolerance and control concepts

Risk Basics: control

Map the relevant actor, transaction or exposure through the Risk Basics process, then identify the control owner, evidence and escalation point.

Risk Basics: common error

Avoid confusing inherent risk, residual risk and actual loss.

Other Major Risks: focus

credit, market, liquidity, strategic, reputational and systemic risk interactions

Other Major Risks: control

Map the relevant actor, transaction or exposure through the Other Major Risks process, then identify the control owner, evidence and escalation point.

Other Major Risks: common error

Avoid classifying an event by consequence while ignoring its root risk.

The Nature of Operational Risk: focus

people, process, systems and external-event risk, frameworks and measurement

The Nature of Operational Risk: control

Map the relevant actor, transaction or exposure through the The Nature of Operational Risk process, then identify the control owner, evidence and escalation point.

The Nature of Operational Risk: common error

Avoid treating operational risk as only technology failure.

The Causes and Impacts of Operational Risk: focus

root causes, event types, direct and indirect impacts and lessons learned

The Causes and Impacts of Operational Risk: control

Map the relevant actor, transaction or exposure through the The Causes and Impacts of Operational Risk process, then identify the control owner, evidence and escalation point.

The Causes and Impacts of Operational Risk: common error

Avoid recording the visible loss without analysing the underlying cause.

Operational Risks Arising in the Trade Cycle: focus

front-to-back processing, confirmations, settlement, custody and reconciliation risks

Operational Risks Arising in the Trade Cycle: control

Map the relevant actor, transaction or exposure through the Operational Risks Arising in the Trade Cycle process, then identify the control owner, evidence and escalation point.

Operational Risks Arising in the Trade Cycle: common error

Avoid looking at one processing step without its upstream and downstream dependencies.

The Support and Control Functions: focus

operations, finance, risk, compliance, audit, technology and governance responsibilities

The Support and Control Functions: control

Map the relevant actor, transaction or exposure through the The Support and Control Functions process, then identify the control owner, evidence and escalation point.

The Support and Control Functions: common error

Avoid assuming a control function owns the business process it oversees.

Operational Risk in the Regulatory Environment: focus

regulatory expectations, resilience, outsourcing, reporting and accountability

Operational Risk in the Regulatory Environment: control

Map the relevant actor, transaction or exposure through the Operational Risk in the Regulatory Environment process, then identify the control owner, evidence and escalation point.

Operational Risk in the Regulatory Environment: common error

Avoid treating regulatory compliance as proof of operational resilience.

Platform Assets: focus

funds, securities, cash and other assets commonly held through platforms

Platform Assets: control

Map the relevant actor, transaction or exposure through the Platform Assets process, then identify the control owner, evidence and escalation point.

Platform Assets: common error

Avoid assuming every platform supports or administers every asset type.

Platform Wrappers: focus

ISA, pension, bond, general account and wrapper ownership and tax purposes

Platform Wrappers: control

Map the relevant actor, transaction or exposure through the Platform Wrappers process, then identify the control owner, evidence and escalation point.

Platform Wrappers: common error

Avoid confusing the wrapper's rules with the underlying asset's features.

The Market and the Platform Service Provider: focus

platform models, advisers, discretionary managers, custodians and outsourcing chains

The Market and the Platform Service Provider: control

Map the relevant actor, transaction or exposure through the The Market and the Platform Service Provider process, then identify the control owner, evidence and escalation point.

The Market and the Platform Service Provider: common error

Avoid failing to identify which party owns each customer and operational duty.

Transactions and Ownership: focus

orders, aggregation, execution, settlement, nominee ownership and records

Transactions and Ownership: control

Map the relevant actor, transaction or exposure through the Transactions and Ownership process, then identify the control owner, evidence and escalation point.

Transactions and Ownership: common error

Avoid confusing beneficial ownership with legal registration or transaction status.

Asset Servicing: focus

income, corporate actions, voting, cash, reconciliations and customer communications

Asset Servicing: control

Map the relevant actor, transaction or exposure through the Asset Servicing process, then identify the control owner, evidence and escalation point.

Asset Servicing: common error

Avoid processing an event without tracing entitlements through pooled records.

Regulatory Framework: focus

permissions, conduct, CASS, product governance, resilience and oversight

Regulatory Framework: control

Map the relevant actor, transaction or exposure through the Regulatory Framework process, then identify the control owner, evidence and escalation point.

Regulatory Framework: common error

Avoid assuming outsourced platform activity removes the regulated firm's responsibility.

Taxation: focus

platform, wrapper and investor tax reporting and operational treatment

Taxation: control

Map the relevant actor, transaction or exposure through the Taxation process, then identify the control owner, evidence and escalation point.

Taxation: common error

Avoid using a tax outcome without fixing wrapper, investor and transaction facts.

Principles of Risk Management: focus

risk frameworks, appetite, identification, assessment, response and monitoring

Principles of Risk Management: control

Map the relevant actor, transaction or exposure through the Principles of Risk Management process, then identify the control owner, evidence and escalation point.

Principles of Risk Management: common error

Avoid treating a risk metric or limit as the whole risk-management process.

International Risk Regulation: focus

global standard setters, capital, liquidity, resolution and supervisory approaches

International Risk Regulation: control

Map the relevant actor, transaction or exposure through the International Risk Regulation process, then identify the control owner, evidence and escalation point.

International Risk Regulation: common error

Avoid assuming international standards apply unchanged as domestic rules.

Operational Risk: focus

operational event types, measurement, controls, resilience and scenario analysis

Operational Risk: control

Map the relevant actor, transaction or exposure through the Operational Risk process, then identify the control owner, evidence and escalation point.

Operational Risk: common error

Avoid measuring recorded losses only and ignoring near misses or tail scenarios.

Credit Risk: focus

default exposure, probability, recovery, counterparty risk, limits and mitigation

Credit Risk: control

Map the relevant actor, transaction or exposure through the Credit Risk process, then identify the control owner, evidence and escalation point.

Credit Risk: common error

Avoid confusing exposure, expected loss and maximum possible loss.

Market Risk: focus

price, rate, currency and volatility risk, sensitivities, VaR and stress testing

Market Risk: control

Map the relevant actor, transaction or exposure through the Market Risk process, then identify the control owner, evidence and escalation point.

Market Risk: common error

Avoid using one market-risk measure without its assumptions and limitations.

Investment Risk: focus

portfolio risk, diversification, performance, benchmarks and client outcomes

Investment Risk: control

Map the relevant actor, transaction or exposure through the Investment Risk process, then identify the control owner, evidence and escalation point.

Investment Risk: common error

Avoid assuming diversification removes systemic or liquidity risk.

Liquidity Risk: focus

funding and market liquidity, cash flows, buffers, stress and contingency plans

Liquidity Risk: control

Map the relevant actor, transaction or exposure through the Liquidity Risk process, then identify the control owner, evidence and escalation point.

Liquidity Risk: common error

Avoid treating accounting solvency as proof that obligations can be met on time.

Model Risk: focus

model design, data, validation, use, limitations and governance

Model Risk: control

Map the relevant actor, transaction or exposure through the Model Risk process, then identify the control owner, evidence and escalation point.

Model Risk: common error

Avoid accepting precise model output without challenging assumptions and data.

Risk Oversight and Corporate Governance: focus

board accountability, three lines, committees, information and challenge

Risk Oversight and Corporate Governance: control

Map the relevant actor, transaction or exposure through the Risk Oversight and Corporate Governance process, then identify the control owner, evidence and escalation point.

Risk Oversight and Corporate Governance: common error

Avoid confusing formal committee structure with effective oversight.

Enterprise Risk Management (ERM): focus

integrated risk taxonomy, aggregation, strategy, culture and reporting

Enterprise Risk Management (ERM): control

Map the relevant actor, transaction or exposure through the Enterprise Risk Management (ERM) process, then identify the control owner, evidence and escalation point.

Enterprise Risk Management (ERM): common error

Avoid managing risk silos without dependencies or aggregate exposure.

Technology in Investment Management: focus

technology architecture, data, automation and the investment-management operating model

Technology in Investment Management: control

Map the relevant actor, transaction or exposure through the Technology in Investment Management process, then identify the control owner, evidence and escalation point.

Technology in Investment Management: common error

Avoid treating technology as isolated from people, process, data and controls.

The Regulatory Framework: focus

technology governance, resilience, data, outsourcing and regulatory accountability

The Regulatory Framework: control

Map the relevant actor, transaction or exposure through the The Regulatory Framework process, then identify the control owner, evidence and escalation point.

The Regulatory Framework: common error

Avoid assuming a vendor owns the regulated firm's compliance outcome.

Technology and the Functional Flow of Financial Instruments: focus

front-to-back systems, reference data, interfaces and transaction states

Technology and the Functional Flow of Financial Instruments: control

Map the relevant actor, transaction or exposure through the Technology and the Functional Flow of Financial Instruments process, then identify the control owner, evidence and escalation point.

Technology and the Functional Flow of Financial Instruments: common error

Avoid losing the authoritative record as data moves between systems.

The Role of Technology in Trade Capture: focus

orders, execution, booking, validation, enrichment and exception handling

The Role of Technology in Trade Capture: control

Map the relevant actor, transaction or exposure through the The Role of Technology in Trade Capture process, then identify the control owner, evidence and escalation point.

The Role of Technology in Trade Capture: common error

Avoid automating bad or incomplete trade data into downstream systems.

The Role of Technology in the Pre-Settlement Phase: focus

confirmation, matching, clearing, netting, instructions and readiness

The Role of Technology in the Pre-Settlement Phase: control

Map the relevant actor, transaction or exposure through the The Role of Technology in the Pre-Settlement Phase process, then identify the control owner, evidence and escalation point.

The Role of Technology in the Pre-Settlement Phase: common error

Avoid treating an executed trade as ready for settlement.

The Role of Technology in the Settlement and Post-Settlement Phases: focus

settlement messages, status, reconciliation, custody and asset servicing

The Role of Technology in the Settlement and Post-Settlement Phases: control

Map the relevant actor, transaction or exposure through the The Role of Technology in the Settlement and Post-Settlement Phases process, then identify the control owner, evidence and escalation point.

The Role of Technology in the Settlement and Post-Settlement Phases: common error

Avoid closing an exception before cash, securities and records agree.

The Impact of Technology on Financial Control: focus

ledgers, valuations, reconciliations, reporting, access and audit evidence

The Impact of Technology on Financial Control: control

Map the relevant actor, transaction or exposure through the The Impact of Technology on Financial Control process, then identify the control owner, evidence and escalation point.

The Impact of Technology on Financial Control: common error

Avoid assuming system-generated financial output is self-validating.

Technology Management: focus

service levels, security, incidents, continuity, capacity and third-party oversight

Technology Management: control

Map the relevant actor, transaction or exposure through the Technology Management process, then identify the control owner, evidence and escalation point.

Technology Management: common error

Avoid monitoring availability alone and ignoring security, integrity or recoverability.

Managing Business Change: focus

requirements, governance, testing, migration, release and benefits realisation

Managing Business Change: control

Map the relevant actor, transaction or exposure through the Managing Business Change process, then identify the control owner, evidence and escalation point.

Managing Business Change: common error

Avoid moving to production without reconciled data, acceptance evidence or rollback.

Technology Services Procurement: focus

requirements, due diligence, contracts, service levels, exit and concentration risk

Technology Services Procurement: control

Map the relevant actor, transaction or exposure through the Technology Services Procurement process, then identify the control owner, evidence and escalation point.

Technology Services Procurement: common error

Avoid selecting a provider on price without control, resilience and exit analysis.

The Transfer Agency (TA) Framework: focus

fund structures, participants, TA services, records, outsourcing and operating models

The Transfer Agency (TA) Framework: control

Map the relevant actor, transaction or exposure through the The Transfer Agency (TA) Framework process, then identify the control owner, evidence and escalation point.

The Transfer Agency (TA) Framework: common error

Avoid confusing the legal fund role with a delegated transfer-agency task.

The Regulatory Framework: focus

authorisation, conduct, investor protection, data and outsourcing obligations

The Regulatory Framework: control

Map the relevant actor, transaction or exposure through the The Regulatory Framework process, then identify the control owner, evidence and escalation point.

The Regulatory Framework: common error

Avoid assuming service-provider delegation removes operator oversight.

Products: focus

fund and share-class features, dealing terms, wrappers and investor outcomes

Products: control

Map the relevant actor, transaction or exposure through the Products process, then identify the control owner, evidence and escalation point.

Products: common error

Avoid applying one product's dealing or ownership terms to another.

Managing the Risk of Financial Crime: focus

CDD, sanctions, fraud, monitoring, reporting and investor-risk controls

Managing the Risk of Financial Crime: control

Map the relevant actor, transaction or exposure through the Managing the Risk of Financial Crime process, then identify the control owner, evidence and escalation point.

Managing the Risk of Financial Crime: common error

Avoid treating initial identity verification as complete financial-crime control.

Managing TA Operations: focus

dealing, registration, settlement, pricing, distributions, records, reconciliations and controls

Managing TA Operations: control

Map the relevant actor, transaction or exposure through the Managing TA Operations process, then identify the control owner, evidence and escalation point.

Managing TA Operations: common error

Avoid correcting one record without reconciling every affected book and account.

Distribution, Front and Ongoing Charges: focus

distribution arrangements, fee calculation, disclosure and operational processing

Distribution, Front and Ongoing Charges: control

Map the relevant actor, transaction or exposure through the Distribution, Front and Ongoing Charges process, then identify the control owner, evidence and escalation point.

Distribution, Front and Ongoing Charges: common error

Avoid confusing investor charges, distributor payments and fund expenses.

Customer and Investor Relations: focus

communications, complaints, data, vulnerable customers and service standards

Customer and Investor Relations: control

Map the relevant actor, transaction or exposure through the Customer and Investor Relations process, then identify the control owner, evidence and escalation point.

Customer and Investor Relations: common error

Avoid prioritising process completion over a clear and fair investor outcome.

Compliance and Oversight: focus

monitoring, service levels, breaches, audit, reporting and governance challenge

Compliance and Oversight: control

Map the relevant actor, transaction or exposure through the Compliance and Oversight process, then identify the control owner, evidence and escalation point.

Compliance and Oversight: common error

Avoid relying on provider attestations without evidence, trend analysis or escalation.