Scaling
Controls that keep pace with the business.
As assets, strategies and headcount grow, the controls the FCA, prime brokers and allocators expect grow with them. We build them properly now, so they don’t have to be retrofitted later.
- Signs you’re here
- More strategies, venues or asset classes; a first institutional allocator; a fund or SMA launch on the way
- Typical work
- Surveillance, algo controls, reporting, prudential and role separation
- How we engage
- Project, retainer, or fractional CCO while the firm grows
What we build
Market abuse surveillance
Trade and communications surveillance calibrated to your strategies, with alert handling and escalation that stands up to review.
Algorithmic trading controls
RTS 6 self-assessment, kill functionality, conformance testing and change management for systematic and algorithmic firms.
Regulatory reporting
Transaction, position and short-selling reporting where you are in scope, with testing and reconciliation behind it.
Fund launches and CPMI
Fund structuring, variations of permission and the controls needed to run SMAs alongside your funds.
Prudential and ICARA
MiFIDPRU own funds, liquidity, ICARA and wind-down planning that match how the firm actually operates.
Role separation
Separating CCO and COO responsibilities before an allocator or the FCA asks why they’re combined.
How it works
Step 1
Baseline
We map what exists against your activities, venues and regulatory perimeter.
Step 2
Prioritise
A short, ranked plan: what regulators and allocators will test first.
Step 3
Build
Controls, monitoring and reporting built and documented, with owners named.
Step 4
Run
We operate them with your team, or hand them over ready to run.
Questions firms ask
What is RTS 6 and does it apply to us?
RTS 6 sets the organisational requirements for investment firms engaged in algorithmic trading. It applies where a computer algorithm determines order parameters — timing, price, quantity or routing — with limited or no human intervention. Where it applies it requires an annual self-assessment, kill functionality, conformance testing and controlled change management. Whether your execution set-up is in scope is fact-dependent.
When should the CCO and COO roles be separated?
There is no fixed threshold, but as assets and headcount grow, combining the roles becomes a conflict. Institutional allocators increasingly flag it at operational due diligence, and it can stall a capital raise. We help plan the separation and the hire.
What changes when we add SMAs to a fund business?
Running mandates for third-party clients alongside your own funds usually means adding MiFID permissions to become a CPMI firm, with new conduct, reporting and prudential obligations. We scope the variation of permission and build the controls before the first mandate goes live.
Start with a 30-minute call.
Tell James where the firm is and what it needs next. No pitch deck, no obligation.