Client Portfolio Review Template (MiFID II Periodic Report)

Client Portfolio Review: [Client name], [Period]

Periodic report and review for a client whose portfolio is managed on a discretionary basis or monitored under an ongoing advice service: valuation and holdings, transactions and income, performance against the agreed benchmark, allocation against the investment policy statement, costs and charges with their cumulative effect on return, loss alerts, goal progress, the periodic suitability review and agreed actions. Based on MiFID II (Directive 2014/65/EU) Article 25(6) and Commission Delegated Regulation (EU) 2017/565 Articles 50 (costs and charges), 54(12) and 54(13) (periodic suitability), 60 (periodic statements for portfolio management), 62 (loss alerts) and 63 (statements of client assets), with notes for US investment advisers under SEC Rule 206(4)-2. Replace every [bracketed] value and every row marked Example. Past performance does not predict future results. This is a document format, not financial, investment, tax or legal advice. Obtain the regulation or rule for the normative text.

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Contents

1. Summary for the client
2. Valuation and holdings
3. Transactions, cash flows and income
4. Performance
5. Allocation against the investment policy
6. Costs and charges
7. Risk and loss alerts
8. Corporate actions and sustainability reporting
9. Statement of client assets
10. Goal progress
11. Periodic suitability review
12. Actions and client acknowledgement
13. Jurisdiction notes
14. Glossary and references
15. Standard and licence note

1. Summary for the client

Example (joint account of Mara and Theo Lind at Kestrel Bay Capital Europe, fictional, EUR, quarter 2027-07-01 to 2027-09-30, inception 2026-10-01): opening value 226,900; contributions 4,500; investment result after costs 3,100; closing value 234,500. Return after costs 1.35% for the quarter, 2.03% year to date and 8.15% over the first twelve months. The benchmark returned 1.52%, 2.71% and 8.67% over the same periods. The portfolio returns are after all costs, while the benchmark has no costs, so roughly 0.28 percentage points a quarter of the difference comes from costs alone. Both goals remain on track (section 10). No change to the policy is proposed.

Write the summary last, after every section below has been reconciled. Lead with the facts the client most needs: what the account is worth, what it earned after all costs, how that compares with the agreed benchmark, and whether the goals are still on track. Use the same words and units as in the investment policy statement, show amounts and percentages side by side, and state any shortfall as plainly as any gain. If an action is needed from the client, say so in the summary, not only in section 12.

2. Valuation and holdings

Reconcile before you report. The holdings, cash and transactions in this report must agree with the custodian's records at the same date; investigate any difference, however small, before the report is sent, and record the outcome. Show each sleeve separately as well as the account total, because the investment policy sets targets per sleeve and a combined view can hide a sleeve that is out of range.

Prices: [source], close of YYYY-MM-DD. Where no market price was available, the fair value method was [method]. Values reconcile with the custodian statement [reference] dated YYYY-MM-DD; differences: [none / explain].

3. Transactions, cash flows and income

3.1 Transactions executed

3.2 Cash flows and income

Total dividends, interest and other payments received in the period: Example EUR 990 (Article 60(2)(f)).

4. Performance

4.1 Method

For each period the return uses the Modified Dietz approximation, which weights each external cash flow by the share of the period it was invested:

where $BV$ and $EV$ are opening and closing values, $CF_i$ the external cash flows, $D$ the number of days in the period and $d_i$ the number of days from the start of the period to cash flow $i$. Periods are chain-linked:

Returns over more than one year are annualised; returns for less than a year are not. A money-weighted return (internal rate of return of the client's cash flows) answers a different question: how the client's own money grew, including the timing of contributions.

4.2 Results

Example calculation for the quarter (92 days): contributions of 1,500 on days 14, 45 and 76 have weights 0.8478, 0.5109 and 0.1739, so the weighted cash flow is 2,298.91. The return is (234,500 minus 226,900 minus 4,500) divided by (226,900 plus 2,298.91), which is 3,100 divided by 229,198.91, or 1.35%.

Example check: year to date is 1.021 x 0.986 x 1.01353 minus 1, or 2.03%; the twelve-month figure adds Q4 2026: 1.06 x 1.021 x 0.986 x 1.01353 minus 1, or 8.15%. The account opened on 2026-10-01, so the first twelve months are not annualised.

4.3 Main drivers

Explain the result in plain words. Say which decisions helped and which hurt, separate the effect of costs from the effect of investment choices, and avoid explaining underperformance only by "market conditions". When the period is short, remind the client that one quarter says little about whether the strategy is working, and point to the longer periods in the table. Never show a return for a period shorter than a year as an annual rate.

For a full attribution analysis use the Performance Attribution Report (finance/performance-attribution-report).

5. Allocation against the investment policy

Rebalancing this period: [None needed / Describe trades and reason]. Example: none needed; contributions were directed to the most underweight classes under IPS section 8.

6. Costs and charges

6.1 Costs in this period

6.2 Annual ex-post costs and charges

Example period: 2026-10-01 to 2027-09-30 (first twelve months), average invested amount EUR 218,000.

Comparison with the ex-ante estimate in the IPS: Example 1.10% estimated, 1.12% incurred; the difference comes from fund ongoing charges of 0.18% against 0.16% assumed.

6.3 Cumulative effect of costs on return

Example check: inception value 200,000 plus contributions of 12 x 1,500 = 18,000 gives 218,000 paid in; the closing value of 234,500 leaves an investment result after costs of 16,500, and adding back the costs of 2,441 gives 18,941 before costs. These are money amounts on the average invested amount; the time-weighted return in section 4 (8.15%) differs because it removes the timing of contributions.

Description: costs reduced the return over the year by about 1.12 percentage points of the average invested amount. Costs are taken every year, so their effect grows over time: on the same assumptions, costs compound to a larger share of the final value over a long horizon. No unusual cost spikes are expected next year (Example).

7. Risk and loss alerts

Set the loss alert up as an automated daily check against the value at the start of the reporting period, with a named person who confirms that each notice was sent by the end of the business day on which the threshold was crossed, or by the end of the next business day if it was crossed on a non-business day. Keep evidence of each notice. A loss alert is a reporting duty, not an instruction to sell; the response to a large fall follows the agreed rules in the investment policy statement.

8. Corporate actions and sustainability reporting

9. Statement of client assets

Compare this report with the statement you receive from the custodian. Tell us at once if you see a difference.

10. Goal progress

Example method: the IPS formula with annual contributions (14,400 and 3,600) and expected returns after costs of 3.94% and 2.70%, applied over the remaining years. Projections are illustrative and depend on the assumptions; they are not guaranteed.

Use the same projection method and the same capital market assumptions as the investment policy statement, and change them only when the firm publishes new assumptions, saying so in this section. A goal is "on track" when the projection at the goal date is at or above the target, "at risk" when it is below the target but within an agreed tolerance, and "off track" otherwise. An off-track essential goal triggers the agreed responses in the investment policy statement: first higher contributions, then a later date, then a lower target, and a change of risk band only after a new risk profile.

11. Periodic suitability review

Example: annual meeting held on 2027-10-12. No change in income, family or health. Theo's (holder 2) employer shares fell to EUR 34,000, about 13% of the managed account and the shares combined (34,000 / 268,500); a selling plan for the next open window was discussed and remains outside the mandate. The portfolio remains suitable; no change to the IPS.

Changes since the last full suitability report: [List only what changed; refer to the last full report by ID].

Conducting the review and common errors

Before the meeting, refresh the client data that drives suitability: income and spending, assets held elsewhere, planned withdrawals, family and health changes, and any change of tax residence. In the meeting, walk through the summary, the goal progress and the costs, ask open questions about changes, and confirm the sustainability preferences. After the meeting, update the risk profile if anything changed, decide whether the portfolio and the service remain suitable, and record the reasons in this section. If a change in the portfolio or the service is recommended, document it in a new suitability report.

The errors found most often in file reviews are: returns after costs compared with a benchmark without saying that the benchmark carries no costs; time-weighted and money-weighted figures mixed in the same table; ex-post costs that leave out fund costs or transaction costs; a suitability conclusion written before the client data was refreshed; loss alerts sent late or without evidence; goal projections that quietly change assumptions; and agreed actions that are discussed but never given an owner and a due date.

12. Actions and client acknowledgement

I/we have received this review and discussed it with the adviser. I/we confirm that the information about my/our circumstances is up to date, or I/we have told the adviser about the changes listed above.

13. Jurisdiction notes

14. Glossary and references

Glossary

References

Related templates: Investment Policy Statement for an individual (finance/investment-policy-statement-individual), Client Risk Profile (finance/client-risk-profile), MiFID Suitability Report (compliance/mifid-suitability-report), Performance Attribution Report (finance/performance-attribution-report), Best Execution Policy (compliance/best-execution-policy), Net Worth Statement (personal/net-worth-statement).

Standard and licence note

Based on Directive 2014/65/EU (MiFID II) and Commission Delegated Regulation (EU) 2017/565 (Articles 50, 54, 60, 62 and 63), with US notes based on SEC Rule 206(4)-2 and SEC Release IA-5248. EU legislation is reused with acknowledgement of EUR-Lex as the source; US federal rules are public domain. FCA Handbook provisions are cited by reference only. Article and rule numbers are cited and requirements are described in original wording; the report structure, formulas as applied and all example figures are original and fictional. Check the current consolidated texts, national rules and the status of the EU Retail Investment Strategy before use. This is a document format, not financial, investment, tax or legal advice. Template licence: MIT.