FCA and SEC dual-regulated robo-advisor platform with automated portfolio rebalancing, tax-loss harvesting, MiFID II risk profiling, and real-time investment dashboards — managing $500M AUM for 18,000 active investors across the UK and USA.
ClearWealth wanted to democratise wealth management for the mass-affluent segment — investors with £20K–£2M who were underserved by traditional wealth managers (minimum investment £500K) but too sophisticated for simple index fund apps. They needed a fully regulated robo-advisor with institutional-grade portfolio management, not a digital savings account with a growth button.
We built WealthPilot in 20 weeks: a dual FCA/SEC regulated platform with MiFID II-compliant risk profiling, AI-driven portfolio construction, automated rebalancing, tax-loss harvesting, and real-time dashboards. $500M AUM and 18K investors onboarded within 12 months of launch.
ClearWealth served investors in both the UK (FCA regulated) and USA (SEC registered). A single platform had to satisfy MiFID II suitability requirements, FCA COBS rules, and SEC investment adviser obligations simultaneously — with jurisdiction-aware onboarding and reporting.
Rebalancing 18,000 portfolios in real-time without triggering unnecessary capital gains events required a rebalancing engine that considered tax impact at the individual investor level — not just portfolio drift. Naive rebalancing would have eliminated the tax advantage entirely for high-net-worth investors.
MiFID II requires a documented suitability assessment before any investment recommendation. The platform needed to conduct, record, and re-assess investor suitability — not as a compliance checkbox, but as a genuine risk profiling engine that informed actual portfolio construction.
The growth portfolio needed access to 4,000+ equities and ETFs, including high-price securities like Amazon and Alphabet. Fractional share execution was required to allow any investment amount — but order aggregation across 18K investors needed to minimise market impact and slippage.
Daily tax-loss harvesting is highly valuable but legally complex — the US wash-sale rule prohibits repurchasing a substantially identical security within 30 days of selling at a loss. An automated TLH engine had to enforce this rule across 18K portfolios with cross-security substitution logic.
Investors expected real-time portfolio valuations. Fetching live prices for 4,000+ securities, calculating unrealised P&L across 18K portfolios, and rendering a personalised dashboard in under 2 seconds required an aggressive caching and pre-computation architecture.
Built a compliance module with a jurisdiction-aware rule engine that dynamically applies FCA or SEC requirements based on investor residence. MiFID II suitability assessments, FCA COBS disclosures, and SEC Form ADV delivery are all automated at the correct point in the onboarding and investment flow.
Rebalancing triggers only when portfolio drift exceeds the target threshold AND the after-tax expected gain is positive. The engine calculates the tax cost of rebalancing at the lot level for each investor before executing, automatically deferring rebalances that would destroy more value in taxes than they recover in drift.
Built a behavioural finance-informed 18-question risk profiling questionnaire that adapts follow-up questions based on prior answers. Responses are mapped to 7 MiFID II suitability categories and 5 internal risk tiers. The system re-assesses suitability annually and on significant account changes.
Alpaca API fractional share execution with order aggregation across all investor portfolios. Orders with the same security and direction are batched into a single market order, split back to investor proportions after fill. This minimises market impact and ensures uniform execution price across all investors in the batch.
A Celery-scheduled daily TLH scanner identifies positions with unrealised losses, checks a 30-day wash-sale lookback window across all positions and recent sales, then executes the harvest by selling the loss position and immediately substituting with a correlated but not substantially identical ETF — preserving market exposure.
Market data is cached in Redis with a 15-second refresh cycle using a background Celery task. Portfolio valuations are pre-computed on price update events and pushed to connected investor dashboards via WebSocket. Dashboard load time is under 600ms because data is pre-computed, not calculated on request.
Beta launched with 2,000 invited investors. $18M AUM in the first 4 weeks, dashboard performance under 600ms, and TLH generating an average £1,400 in tax savings per investor in the first tax year. FCA compliance review passed without findings.
18,000 investors onboarded through the self-service flow. $500M AUM milestone reached. Growth portfolio delivered 2.4x benchmark outperformance on a risk-adjusted basis. SEC registration approved for US investors, expanding the addressable market by 3x.
ClearWealth raised a Series B at £85M valuation with WealthPilot cited as the primary differentiator. Named "Best New Robo-Advisor Platform" at the UK FinTech Awards. Platform now managing assets for clients in 12 countries.
"WealthPilot is the infrastructure behind our entire advisory offering. The rebalancing engine, tax-loss harvesting, and FCA/SEC dual-compliance tools are production-grade and auditor-approved. Digivance built what our internal team estimated would take 2 years — in 20 weeks. We raised our Series B on the back of this platform."
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