SS&C Hubwise – TYE reminder, AML update and Transfer guidance

Dear client

SS&C Hubwise – TYE reminder, AML update and Transfer guidance  

As we draw near to the end of the Tax Year, please see below a few reminders and updates to ensure business is processed as efficiently as possible.

1. Tax Year End key information 

• Please see a link to the tax year end cut off times Received from the nominated bank details Tax Year End 2024/2025 - Key Information : Knowledgebase Hubwise
•  For an ISA application to be successful for new investors in the 2024/25 Tax Year we must have: 
  • Cleared funds by 18:00 on 4th April
  • Received from the nominated bank details 
  • Have a corresponding expectation in place 
  • The Investor must have passed the onboarding AML checks. 
• What happens if something is missing: 
  • Monies received on or before 4th April without a valid application in place, will not be eligible for the 2024/25 Tax Year and monies will be returned within 10 business days.
  • Monies received on or before 4th April where AML checks are referred/documents are outstanding will not be eligible for the 2024/25 Tax Year and monies will be returned within 10 business days. 
  • Monies received on or before 4th April but not sent from the nominated bank details will not be eligible for the 2024/25 Tax Year and monies will be returned within 10 business days. 
• 3rd party 
  • If SS&C Hubwise receive a payment from an account which has not been registered as the Nominated Bank Account, the money will not be applied to the Account.  The exception is if the payment is from an Employer (SIPP only) or other verified third party who has an agreed arrangement. Instead, SS&C Hubwise will hold the money as Client Money pending fulfilment of our responsibility to verify source of funds. 
  • In this instance SS&C Hubwise will attempt to check the account as belonging to the client via an external verification service. Where this initial verification fails, SS&C Hubwise will attempt to check by requesting a certified copy of a bank statement.  
  • Once verification has been obtained, through either of these means, the payment will automatically be applied to the Product and invested per your investment strategy or Model Portfolio.  
  • Where SS&C Hubwise is unable, within a ten day period, to verify the bank account from which the money was received, the money will be returned directly to the source account. 
  • Payment rules re: Nominated Bank Accounts & Trust or Professional 3rd / Third Party Bank Accounts : Knowledgebase Hubwise 
• For any time critical tax year end escalations, we recommend that you contact us using the Customer Services phone number - 0203 975 7428 or 0845 783 5500 (Mon-Fri 9am-5pm) 

2.    AML update/ guidance 

Following the move to a non-reliance model, SS&C Hubwise would like to thank you for your cooperation and feedback.  This feedback has helped to refine our processes while continuing to reduce the risk of financial crime.  Please find information and guidance on our AML process and uplift project below.

• Uploading AML referral evidence 
  • When requested, please ensure that AML referral evidence is submitted via the Investor AML screen (not the generic document uploader).  This will ensure the evidence is quickly channelled to the correct team for assessment.
• KYC Data Capture 
  • Please be as accurate as possible when selecting the new personal details fields on opening a new account: 
    • Occupation 
    • Industry 
    • Annual Income (range)  
    • Reason for Investment   
    • The options selected here feed into the assessment of risk (along with other factors).  
• Reminder - Combined AML and Bank Verification Referral report
  • Under “Company Reports”, please use the “HUB_Bank_AML_Referals” report for a consolidated view of all referrals (filter by column C for the referral type) 

3.    AML project – Uplift of historic reliance model investors 

Through 2025 we will be undertaking a project to verify all existing investors (set up under our previous AML “reliance” model).  More details of this project and timeline will follow in a future communication after tax year end. However, there are actions you can start to take now to help reduce the administrative burden:  

• Review/cleanse client name, address, NINO, and DOB data.  Where clients fail the Identity Verification stage of this project, we will be required to reach out for documentation to evidence identity.  A reminder on the acceptable ID&V evidence can be found here (Question 10) - AML_Release_FAQ_v2.0 (12).pdf      
• Review your current fact find documents to ensure consistency with the SS&C Hubwise KYC fields on occupation/ industry and income range.  A reminder of the current lists of Occupation/ Industry/ Salary Band can be found in the Appendix of this document -  AML_Release_FAQ_FollowUp_v.Final (17).pdf 
• (Note that we are looking to enhance the current list of occupations and industries.  A separate communication will be sent when this is due for release). 

4.    Transfers process update/ guidance

• For cases input as “Full Cash transfers”, where client holds a suspended asset, we will send our acceptance for the suspended asset in Specie by default, rather than raising a ticket.  This will speed up the transfer process as suspended funds cannot be encashed. 
• When raising Freshdesk tickets you must include the full 11 digit alphanumerical account number in the subject line. This will ensure the ticket is picked up and assigned to correct account transfer (not abbreviated) 
• Only submit one ceding plan reference per transfer to avoid duplication or rejections from ceding schemes.  
• Do not submit a single transfer request to be split into multiple sub accounts/ multiple expectations, as these are most likely to get rejected by the ceding party.  If you need the incoming transfer to be split into multiple sub accounts once received by SS&C Hubwise, please submit a separate FD ticket specifying the investment instruction for each sub account. 

Kind regards,

Anil Dala

Deputy Managing Director