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Client Risk Profile Template (MiFID II Suitability, Reg BI)

Fact-find and risk profiling: classification, finances, goals, knowledge, risk tolerance vs capacity for loss, sustainability preferences, model mapping

Finance, Investment & AccountingFullMiFID II Art. 25(2); Delegated Reg (EU) 2017/565 Art. 54-55; SEC Reg BIclientriskprofilemath

How to use: Use it when onboarding or re-profiling an advisory or discretionary client before any recommendation. Fill the financial situation, goals and capacity for loss first, then the questionnaire and sustainability preferences. The main pitfall is letting a high questionnaire score override a low capacity for loss.

Preview

Client Risk Profile: [Client or household name]

Fact-find and risk profiling record for an individual, joint or represented client of an investment adviser, wealth manager or portfolio manager. It captures the information that a suitability assessment needs: client classification, financial situation, investment objectives and time horizon, knowledge and experience, risk tolerance and capacity for loss, sustainability preferences, liquidity needs and vulnerability indicators, and it ends with a resulting risk profile mapped to a model portfolio. Based on MiFID II (Directive 2014/65/EU) Article 25(2), Commission Delegated Regulation (EU) 2017/565 Articles 54 and 55 as amended by Delegated Regulation (EU) 2021/1253 (sustainability preferences, applying from 2022-08-02), the ESMA Guidelines on certain aspects of the MiFID II suitability requirements (ESMA35-43-3172) and, for US firms, the retail customer investment profile in SEC Regulation Best Interest (17 CFR 240.15l-1). Replace every [bracketed] value and every row marked Example. This is a document format, not financial, investment, tax or legal advice. Obtain the regulation or rule for the normative text.

Document control

FieldValue
Document ID[CRP-YYYY-NNN]
Version[1.0]
Status[Draft / Client confirmed / Approved / Superseded]
Owner[@adviser]
Approvers/reviewers[@supervisor], [@compliance-reviewer]
Last updatedYYYY-MM-DD
ClassificationConfidential: client personal data
Firm[Firm legal name, licence or registration number]
Client reference[Client or account number]
Service covered[Investment advice / Discretionary portfolio management / Brokerage with recommendations]
Methodology version[Risk profiling methodology ID and version]
Next scheduled reviewYYYY-MM-DD
Related documents[Suitability report ID], [IPS ID], [Engagement agreement ID]

Approvals

RoleNameDecisionDate
Adviser who completed the profile[Name][Completed]YYYY-MM-DD
Supervisor or four-eyes reviewer[Name][Approved / Returned]YYYY-MM-DD
Client (each account holder)[Name][Confirmed accurate]YYYY-MM-DD

Revision history

VersionDateAuthorChange
0.1YYYY-MM-DD[@adviser]First draft from the onboarding meeting
1.0YYYY-MM-DD[@adviser]Client confirmed; supervisor approved
[1.1]YYYY-MM-DD[@adviser][Annual review or change in circumstances: describe]

Contents

1. Client identification and classification

Identify every person on the account and the role each plays. A profile that covers a household must still record each holder, because knowledge, experience and attitude to risk differ between people even when the money is shared. Delegated Regulation (EU) 2017/565 Article 54(6) requires the firm to have a recorded policy for groups of persons, legal persons and represented clients: the financial situation and objectives are those of the underlying client, while knowledge and experience are those of the representative who makes the decisions.

FieldHolder 1Holder 2
Full name[Name][Name]
Date of birth and ageYYYY-MM-DD ([age])YYYY-MM-DD ([age])
Tax residence[Country][Country]
Citizenship(s)[Country][Country]
Employment status and occupation[Status, role][Status, role]
Dependants[Number, ages][Number, ages]
Identity verified (KYC file reference)[KYC-ID][KYC-ID]
Trusted contact person (where offered)[Name, relationship][Name, relationship]
ItemValueNotes
Account type[Individual / Joint / Trust / Company / Power of attorney]
Client category[Retail / Professional (per se or on request) / Eligible counterparty]MiFID II Annex II and Article 30; retail gives the highest protection
Person(s) whose financial situation and objectives are assessed[Names]Policy under Article 54(6)
Person(s) whose knowledge and experience are assessed[Names]Usually the decision maker
Decision rule for joint accounts[Lower of the two risk scores / Agreed joint answers / Other]State the firm policy reference
Communication preferences and language[Language, format, durable medium]

Example: Mara Lind (46, software engineer) and Theo Lind (44, quality manager at a listed pharmaceutical company), married, two children aged 12 and 9, tax resident in [EU Member State], joint discretionary account with Kestrel Bay Capital Europe, a fictional MiFID investment firm. Both holders are classified as retail clients. The firm policy applies the lower of the two risk tolerance scores to a joint account and assesses knowledge and experience for both holders because either may give instructions.

2. Financial situation

Record the source and amount of regular income, all assets including liquid assets, investments and real property, all liabilities and the regular financial commitments. State the currency, the valuation date and whether each figure was evidenced or declared. Amounts below are in [currency]; the Example uses EUR and a valuation date of 2026-09-30.

2.1 Income and expenditure (monthly)

LineAmountSource and evidence
Net employment income, holder 1[amount][Payslip / declared]
Net employment income, holder 2[amount][Payslip / declared]
Other income (rental, pension, benefits)[amount][Source]
Total net income[amount]
Essential expenditure (housing, food, utilities, insurance, childcare, loan repayments)[amount][Budget / bank statements]
Discretionary expenditure[amount]
Monthly surplus available to save[amount]Net income minus all expenditure

Example (EUR per month): net income 9,100; essential expenditure 5,200 (including the mortgage payment); discretionary expenditure 1,600; surplus 2,300, of which the clients commit 1,500 to the managed account and keep 800 as a buffer.

2.2 Assets and liabilities

IDItemOwnerValueLiquidityNotes
FS-A-001 (Example)Current and savings accountsJoint38,000Same dayEmergency reserve
FS-A-002 (Example)Existing investment account at another providerJoint200,0002 to 5 daysTo be transferred into the managed mandate
FS-A-003 (Example)Employer pension plansEach holder185,000Locked until retirement ageNot in scope of the mandate; considered for capacity
FS-A-004 (Example)Employer shares held by holder 2Holder 240,000Restricted trading windowsOutside the mandate; concentration noted in section 7
FS-A-005 (Example)Family homeJoint520,000IlliquidValuation basis: recent comparable sales
FS-L-001 (Example)MortgageJoint310,00021 years left, fixed rate until 2031Payment included in essential expenditure

Example net worth: assets 38,000 + 200,000 + 185,000 + 40,000 + 520,000 = 983,000; liabilities 310,000; net worth 673,000 (EUR).

2.3 Financial resilience indicators

IndicatorFormulaExample value
Emergency reserve coverLiquid savings divided by essential monthly expenditure38,000 / 5,200 = 7.3 months
Debt service ratioMonthly debt payments divided by net monthly income1,450 / 9,100 = 15.9%
Share of net worth in the proposed mandateMandate amount divided by net worth200,000 / 673,000 = 29.7%
Expected large outflows in the next 5 yearsListed amounts and datesCar replacement 25,000 in 2028 from savings

3. Investment objectives and time horizon

List each purpose the money serves. Rank the goals so that the portfolio can be split or sequenced when goals compete, and so that a review can test whether the portfolio still serves them.

IDGoalTarget amount (today's money)Target datePriorityHorizonFunding source
OBJ-001 (Example)Supplement retirement income from age 62 (holder 1) and 60 (holder 2)Pot of 590,000 nominal at year 162042Essential16 years, then drawdown160,000 sleeve plus 1,200 a month
OBJ-002 (Example)University costs for two children66,000 nominal2032Important6 years40,000 sleeve plus 300 a month
OBJ-003 (Example)Help with first home deposit for childrenNo fixed amountAfter 2040Aspirational15 years or moreSurplus from OBJ-001 if any
[OBJ-NNN][Goal][Amount]YYYY[Essential / Important / Aspirational][Years][Source]

Record also:

  • the intended holding period for the whole mandate and any date when a large part will be withdrawn;
  • whether the client needs regular income from the portfolio, and how much;
  • the expected return the client has in mind, so that unrealistic expectations are discussed now and not at the first loss;
  • whether the money is the client's main or only long-term savings.

4. Knowledge and experience

Ask factual questions, not only self-ratings. A short knowledge check with two or three questions per product family is more reliable than asking the client whether they "understand" a product. Record the evidence and the outcome per product family. The firm must not discourage the client from giving this information (Article 55(2)) and may rely on what the client says unless it knows, or should know, that it is manifestly out of date, inaccurate or incomplete (Article 55(3)).

Product familyHolder 1: experience (years, frequency, volume)Holder 1: knowledge checkHolder 2: experienceHolder 2: knowledge checkOutcome
Deposits and money market funds[Detail][Pass / Fail][Detail][Pass / Fail][Eligible / Not eligible / Eligible after explanation]
Collective investment funds and ETFs (equity, bond, multi-asset)Example: 12 years, monthly purchases, about 30 trades a yearPass 3/3Example: 5 years, savings plan onlyPass 2/3, explained tracking errorEligible
Individual listed sharesExample: 8 years, about 10 trades a yearPass 3/3Example: employer shares onlyPass 2/3Eligible
Individual bondsExample: nonePass 2/3Example: noneFail 1/3Eligible in funds only
Structured products[Detail][Result][Detail][Result]Example: Not eligible
Derivatives and leveraged productsExample: noneNot testedExample: noneNot testedNot eligible
Private markets and illiquid fundsExample: noneNot testedExample: noneNot testedNot eligible
Crypto-assets[Detail][Result][Detail][Result][Outcome]
FieldHolder 1Holder 2
Highest education level and field[Detail][Detail]
Profession or former profession relevant to finance[Detail][Detail]
Training or explanation given in this meeting[Topics][Topics]

5. Risk tolerance and capacity for loss

5.1 Risk tolerance questionnaire

Use the firm's validated questionnaire. Record each answer and its score so that a reviewer can reproduce the result. Describe the scoring bands in the methodology document and reference its version in Document control. The questions below show the themes a questionnaire usually covers; write your own wording and test it with clients for clarity, as Article 54(7)(b) and (c) expect tools and questions to be fit for purpose and understood.

IDThemeHolder 1 answerScore (1 to 5)Holder 2 answerScore (1 to 5)
RTQ-01Reaction to a 20% fall in portfolio value within a yearExample: hold and wait4Example: sell part2
RTQ-02Preference between a stable low return and a variable higher return[Answer][Score][Answer][Score]
RTQ-03Past behaviour in a real market fall[Answer][Score][Answer][Score]
RTQ-04Importance of avoiding any loss over the horizon[Answer][Score][Answer][Score]
RTQ-05Self-assessed comfort with investment risk compared with peers[Answer][Score][Answer][Score]
RTQ-06Choice among illustrated ranges of one-year outcomes[Answer][Score][Answer][Score]
RTQ-07Time needed to recover from a loss before it changes plans[Answer][Score][Answer][Score]
RTQ-08Attitude to borrowing to invest[Answer][Score][Answer][Score]
RTQ-09How often the client expects to check the portfolio[Answer][Score][Answer][Score]
RTQ-10Reaction to underperforming a reference index for two years[Answer][Score][Answer][Score]
Total (10 to 50)Example: 34Example: 29

Example scoring bands (illustrative only, set your own in the methodology):

Total scoreTolerance band
10 to 171 Defensive
18 to 252 Cautious
26 to 333 Balanced
34 to 414 Growth
42 to 505 Adventurous

Example result: holder 1 scores 34 (band 4, Growth), holder 2 scores 29 (band 3, Balanced). Under the firm policy for joint accounts the lower band applies: Balanced (3) for the joint account.

5.2 Capacity for loss

State the largest fall in the value of the mandate the client could absorb without changing an essential goal, cutting essential spending or taking on debt. Base it on the financial situation in section 2, not on the questionnaire.

QuestionExample answer
Is the emergency reserve held outside the mandate and sufficient?Yes: 7.3 months of essential spending
Are there other assets that secure essential goals?Employer pensions (185,000) secure a base retirement income
Will any part of the mandate be withdrawn within 3 years?No; education withdrawals start in 2032
Could income continue if one holder lost their job?Yes for 12 months on one income with the surplus reduced to zero
Largest absorbable fall in value of the mandate50,000 (25% of 200,000)
Capacity for loss ratingMedium

5.3 Combined risk rating

The overall profile is the lower of the willingness band and the band that the capacity for loss supports. Test each candidate band against the capacity with a stress loss for the model that the band maps to (section 9). A stress loss is an illustrative fall, set in the firm methodology from historical or hypothetical scenarios.

Candidate bandModel stress loss (Example)Loss on 200,000Within capacity of 50,000?
3 Balanced20%40,000Yes
4 Growth28%56,000No
Profile=min⁡(Tolerance band, Capacity band)\text{Profile} = \min\left(\text{Tolerance band},\ \text{Capacity band}\right)

Example combined rating: Balanced (3) for the retirement sleeve. The education sleeve has a 6-year horizon with an important goal, so the adviser applies Cautious (2) to that sleeve (see section 9).

6. Sustainability preferences

Explain the three elements in plain language before asking. Record a minimum proportion or a choice for each element, and whether the client is willing to adapt the preferences if no product meets them. Article 54(10), as amended by Delegated Regulation (EU) 2021/1253, and ESMA35-43-3172 expect the firm not to present a product as meeting the preferences when it does not, and to keep a record of the explanation and of any decision by the client to adapt them.

ElementDefinition in plain languageClient choiceMinimum proportion or detail
(a) Taxonomy alignmentShare invested in activities that qualify as environmentally sustainable under Regulation (EU) 2020/852Example: no minimum[%]
(b) Sustainable investmentsShare invested in sustainable investments as defined in Regulation (EU) 2019/2088 (SFDR) Article 2(17)Example: yesExample: at least 20% of the portfolio
(c) Principal adverse impacts (PAI)The product considers specified negative effects on sustainability factorsExample: yesExample: greenhouse gas emissions; exposure to controversial weapons
Exclusions requested outside the three elementsEthical or religious exclusions the client wants[Detail][Detail]
Willing to adapt preferences if no match[Yes / No]Record the decision and reasons if it happens

7. Liquidity needs and constraints

IDConstraintDetailEffect on the mandate
CON-001 (Example)Planned withdrawalsEducation: about 11,000 a year from 2032 to 2037Hold the education sleeve in a separate, more cautious allocation
CON-002 (Example)Concentration40,000 in employer shares held outside the mandate (about 17% of the 240,000 invested outside pensions: 200,000 mandate plus 40,000 shares)Underweight the employer's sector in the mandate; review a selling plan in the trading windows
CON-003 (Example)TaxCapital gains realised on transfer of the existing accountTransfer in kind where possible; [tax adviser] to confirm
CON-004 (Example)Legal and regulatoryHolder 2 is on the employer's insider listEmployer shares excluded from the mandate; outside holdings sold only in open trading windows
CON-005Unique circumstances[Expected inheritance, business sale, divorce, emigration][Effect]

8. Vulnerability and support needs

A client in a vulnerable situation may be less able to protect their own interests. Record indicators and the support the firm will give; do not record diagnoses unless they are needed and consented to. The UK FCA guidance FG21/1 on the fair treatment of vulnerable customers names four drivers (health, life events, resilience and capability); other jurisdictions use similar concepts under their conduct rules.

DriverIndicator observedAdjustment agreedConsent recorded
Health[None observed / Detail][Large print, extra time, trusted contact][Yes / No / Not applicable]
Life eventsExample: none observed
ResilienceExample: none observed (reserve 7.3 months)
CapabilityExample: holder 2 asked for written summaries before meetingsSend summary two days before each reviewYes

9. Resulting profile and model portfolio mapping

Profile bandExample modelGrowth assetsDefensive assetsIllustrative stress lossEligible products
1 DefensiveModel D0 to 20%80 to 100%7%Deposits, money market and short bond funds
2 CautiousModel C20 to 40%60 to 80%12%Plus diversified bond and multi-asset funds
3 BalancedModel B40 to 60%40 to 60%20%Plus equity funds and ETFs, listed shares
4 GrowthModel G60 to 80%20 to 40%28%As Balanced, higher equity
5 AdventurousModel A80 to 100%0 to 20%35%As Growth, may add specialist funds if knowledge allows

The bands are contiguous, so every portfolio maps to one band; a portfolio exactly on a boundary takes the lower band. The model ranges and stress losses above are examples. Use the firm's approved models and their current documentation.

SleeveAmountProfileModelRationale
Retirement (OBJ-001) (Example)160,0003 BalancedModel BLower of tolerance bands; Growth fails the capacity test; 16-year horizon
Education (OBJ-002) (Example)40,0002 CautiousModel C6-year horizon, important goal, withdrawals from 2032
Total mandate200,000

Sustainability filter: both sleeves use model variants with at least 20% sustainable investments and PAI consideration on greenhouse gas emissions and controversial weapons (Example). Product eligibility: funds, ETFs and listed shares only; no structured products, derivatives or illiquid funds (section 4).

The selected models and products are recorded in the suitability report and the investment policy statement, which explain why the recommendation is suitable. This profile does not make that recommendation itself.

10. Inconsistencies and how they were resolved

IDInconsistencyHow it was foundResolutionDate
INC-001 (Example)Holder 1 chose "hold and wait" after a 20% fall but sold most equity funds in a 2022 market fallTransaction history reviewDiscussed; client explained a house purchase at that time; answer kept, note addedYYYY-MM-DD
INC-002 (Example)Growth band preferred by holder 1 versus capacity for loss of 25%Section 5.3 testBalanced applied; client informed in writingYYYY-MM-DD
INC-003 (Example)Expected return of "about 8% a year" versus Balanced model assumptionsObjectives discussionExpectation reset with scenario ranges; recorded in IPSYYYY-MM-DD
[INC-NNN][Detail][Source][Resolution]YYYY-MM-DD

11. Review, confirmation and record keeping

Firms that provide a periodic suitability assessment review the suitability of their recommendations at least annually, and more often where the client's risk profile or the instruments call for it (Delegated Regulation 2017/565 Article 54(13)). Firms with an ongoing relationship need procedures to keep client information adequate and up to date (Article 54(7)). Set the review cycle accordingly.

ItemValue
Scheduled review frequency[Annual / Semi-annual]
Event triggers for an earlier reviewChange of job or income; birth, death, marriage or divorce; inheritance; withdrawal above [amount]; change of tax residence; new health issue; client request
Information refresh method[Meeting / Secure form / Video call]
Records retainedThis profile, questionnaire answers, evidence, knowledge checks, inconsistency log, client confirmations
Retention period[Years, per local record-keeping rules]

Supervisor checks and common errors

The four-eyes reviewer should be able to rebuild the result from the record alone. Check first that every figure used later (net worth, surplus, reserve months, capacity for loss) is computed from the section 2 tables and that the dates agree. Then check that the questionnaire totals add up, that the band follows from the published scoring table, that the joint-account rule was applied as the firm policy states, and that the capacity test in section 5.3 used the stress loss of the model actually proposed. Finally, read the inconsistency log: an empty log on a profile with two holders whose answers differ is itself a warning sign.

The errors found most often in file reviews are: income recorded but regular commitments left out, so the surplus is overstated; assets held outside the firm ignored, so a concentration such as employer shares is missed; a capacity for loss written as a word ("medium") with no amount behind it; knowledge assessed only by self-rating; sustainability preferences recorded as "interested in ESG" with no minimum proportions; vulnerability noted in a meeting but not turned into an agreed adjustment; and a profile that is never refreshed although the client changed job, moved country or received an inheritance. Return a profile with any of these errors to the adviser before a recommendation is made, and record the return in the approvals table.

Client confirmation

I/we confirm that the information in this profile is accurate and complete to the best of my/our knowledge. I/we understand that the firm relies on it to assess suitability, that incomplete or inaccurate information may lead to unsuitable recommendations, and that I/we should tell the firm promptly about any material change.

HolderSignature or electronic confirmationDate
[Name][Signature]YYYY-MM-DD
[Name][Signature]YYYY-MM-DD

Adviser declaration

I have explained the purpose of this assessment to the client, which is to enable the firm to act in the client's best interest, and I have checked the answers for consistency.

AdviserSignatureDate
[Name][Signature]YYYY-MM-DD

12. Jurisdiction notes

Status as of 2026-10. Check local law and the current consolidated texts.

JurisdictionLegal basis (names and numbers)Local items to add
EUMiFID II Article 25(2); Delegated Regulation (EU) 2017/565 Articles 2(7), 54, 55 (as amended by 2021/1253); ESMA35-43-3172Sustainability preferences; professional client opt-up procedure; national language and record rules. The Retail Investment Strategy amendments were not yet in force at 2026-10
United States, broker-dealersRegulation Best Interest, 17 CFR 240.15l-1 (care obligation and the retail customer investment profile in paragraph (b)(2)); FINRA Rules 2090 and 2111 (by number); FINRA Rule 4512 trusted contact (by number)Age, other investments, tax status and the other profile items the rule lists; Form CRS delivery
United States, investment advisersAdvisers Act fiduciary duty as interpreted in SEC Release IA-5248 (2019-06-05)Reasonable inquiry into financial situation, experience and objectives; update as circumstances change
United KingdomFCA COBS 9A (suitability), PRIN 2A Consumer Duty, FG21/1 vulnerable customers (by reference)Consumer Duty outcomes; targeted support regime from 2026-04-06 is separate from advice
[Other][Law or rule][Items]

13. Glossary and references

Glossary

TermMeaning in this template
Capacity for lossThe fall in value a client can absorb without harming essential goals or standard of living
Risk toleranceThe client's willingness to accept fluctuations and losses in pursuit of return
Risk profileThe resulting band used to select a model portfolio; the lower of tolerance and capacity
Retail clientA client that is neither a professional client nor an eligible counterparty under MiFID II; highest protection
Sustainability preferencesThe client's choices on taxonomy alignment, sustainable investments and principal adverse impacts, as defined in Delegated Regulation 2017/565 Article 2(7)
Principal adverse impacts (PAI)Significant negative effects of investment decisions on environmental, social and governance factors
Stress lossAn illustrative fall in value of a model portfolio under a defined adverse scenario
Durable mediumA format that lets the client store and reproduce information unchanged, such as a PDF

References

SourceVersion or dateUse in this template
Directive 2014/65/EU (MiFID II)OJ L 173, 12.6.2014; check the consolidated textArticle 24 best interest, Article 25(2) suitability
Commission Delegated Regulation (EU) 2017/565OJ L 87, 31.3.2017; consolidated textArticles 54 and 55 information and process
Commission Delegated Regulation (EU) 2021/1253Adopted 2021-04-21, applies from 2022-08-02Sustainability preferences, Article 2(7), amended Article 54
ESMA Guidelines on certain aspects of the MiFID II suitability requirementsESMA35-43-3172, applied from 2023-10-03Supervisory expectations (cited, not reproduced)
SEC Regulation Best Interest17 CFR 240.15l-1, 84 FR 33318 (2019-07-12)US broker-dealer customer profile
SEC Commission Interpretation Regarding Standard of Conduct for Investment AdvisersRelease IA-5248, 2019-06-05US adviser duty of care
FINRA Rules 2090, 2111, 4512Cited by number onlyUS broker-dealer know-your-customer and suitability
FCA COBS 9A, PRIN 2A, FG21/1Cited by reference onlyUK suitability, Consumer Duty, vulnerability

Related templates: MiFID Suitability Report (compliance/mifid-suitability-report), Investment Policy Statement for an individual (finance/investment-policy-statement-individual), Client Portfolio Review (finance/client-portfolio-review), Financial Plan (personal/financial-plan), Net Worth Statement (personal/net-worth-statement), Conflicts of Interest Register (compliance/conflicts-of-interest-register).

Standard and licence note

Based on Directive 2014/65/EU (MiFID II), Commission Delegated Regulation (EU) 2017/565 as amended by Delegated Regulation (EU) 2021/1253, and SEC Regulation Best Interest (17 CFR 240.15l-1), with reference to the ESMA suitability guidelines ESMA35-43-3172. EU legislation is reused with acknowledgement of EUR-Lex as the source; US federal rules are public domain. ESMA does not endorse this template. FINRA rules and FCA Handbook provisions are cited by number only and no text from them is used. Article and rule numbers are cited and requirements are described in original wording; the text, questionnaire themes, scoring bands, models and examples are original and fictional. Check the current consolidated texts and any amendments, including the pending EU Retail Investment Strategy, before use. This is a document format, not financial, investment, tax or legal advice. Template licence: MIT.

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