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Industry Guide

Section 250 Compliance for Wealth Managers

Wealth managers typically have a large, distributed adviser workforce — many of whom hold CF30 (Customer) functions but are not Senior Management Function holders. Section 250's s.250(3) test captures individuals who play a significant role in managing or organising a substantial part of the organisation's activities. Senior relationship managers, private banking heads, and discretionary portfolio leads often meet this definition, creating a meaningful gap between your SM&CR register and your true Section 250 exposure.

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TL;DR

Wealth Managers face Section 250 obligations under the Crime and Policing Act 2026. Wealth managers typically have a large, distributed adviser workforce — many of whom hold CF30 (Customer) functions but are not Senior Management Function holders. Section 250's s.250(3) test captures individuals who play a significant role in managing or organising a substantial part of the organisation's activities. Senior relationship managers, private banking heads, and discretionary portfolio leads often meet this definition, creating a meaningful gap between your SM&CR register and your true Section 250 exposure. Typical Section 250 gap: Uncovered advisers and managers in a mid-size wealth firm. Key roles in scope: Senior relationship managers, Discretionary portfolio managers, Private banking heads. Deadline: June 29, 2026. CoverProof automates the SM&CR gap analysis, declarations, and PDF/A-3B board evidence pack generation for wealth management firms.

20–60

Uncovered advisers and managers in a mid-size wealth firm

The typical Section 250 gap for a wealth management firm — roles with significant financial authority that may sit outside SM&CR approval and need governance declarations now the law is in force.

The adviser population problem in wealth management

Senior relationship managers below SMF level

A senior private banker who manages £500m of client assets, sets team strategy, and approves discretionary trades has real significance to the firm — but may not hold an SMF. Section 250 captures them.

Discretionary portfolio managers

Managers with full discretionary authority over client portfolios sit in Section 250's core scope. The discretionary element is key — you are not just executing instructions, you are making financial decisions.

Branch network complexity

Multi-branch wealth managers face complexity in identifying every individual who meets the Section 250 threshold across their entire network. A systematic import and analysis is the only reliable approach at scale.

Roles typically in scope for wealth management firms

  • ⚑Senior relationship managers
  • ⚑Discretionary portfolio managers
  • ⚑Private banking heads
  • ⚑Branch managers with financial authority
  • ⚑Senior investment advisers

Common questions from wealth management compliance teams

Our advisers are all CF30-registered. Does that mean they are covered?

Not necessarily. CF30 is an FCA controlled function for customer-facing advisers. Section 250 has a different scope — it focuses on significant influence over the firm's activities, not just customer advice. A CF30 holder who also manages a team or has authority over firm-level risk may fall within Section 250.

How do we handle leavers who were senior before they left?

Section 250 obligations apply from commencement on June 29, 2026. You need declarations from people who are in covered roles from that date onward. Leavers who departed before that date are not within scope for post-commencement conduct, but you should document the analysis.

Identify every attribution-risk adviser now.

CoverProof maps your entire adviser population against Section 250 criteria — not just your SMF holders. You see exactly which roles are in scope, why, and what declaration is needed. First analysis is free.

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