Relevant Practitioners refer to PWM industry practitioners engaged by PWM institutions who are in customer-facing roles making personalized or customized solicitations or recommendations to customers in provision of securities dealing and advisory service and/or portfolio management service.
Customer-facing functions refers to those roles such as Relationship Manager or Investment Advisor who have direct access to clients and provide customized solicitations or recommendations directly to clients in the provision of securities dealing and advisory services and/or portfolio management services.
For work experience at a non-PWMA member institution to be considered as PWM client-facing function for the purpose of ECF, substantiation has to be provided to demonstrate that the institution (or a unit of the institution) is or was dedicated to serve private banking customers during the period of experience.
PWM institutions can make reference to the “Definition of Relevant Practitioners” for examples of functional titles, and key roles and required competence in determining whether a customer-facing staff is a Relevant Practitioner for the purposes of ECF.
If the staff performs substantially all of the roles described in the “Definition of Relevant Practitioners”, he or she may classified as a Relevant Practitioner.
An individual with a functional title such as Relationship Manager and Investment Advisor is likely to be classified as a Relevant Practitioner if that individual in practice performs substantially all of the prescribed roles listed in the “Definition of Relevant Practitioners”. An individual that holds other functional titles such as Dealer or Product Specialist would not typically be classified as a Relevant Practitioner if that individual does not perform substantially all of the prescribed roles including the provision of investment ideas or recommendations to customers directly.
An individual who is a PWM Assistant, including but not limited to those with a functional title such as Assistant to Relationship Manager, is not considered a Relevant Practitioner for the purpose of ECF and therefore out of scope for grandfathering or CPWP certification.