Pilot Financial Systems Limited

System Specification (Schedule to Terms & Conditions)

Last Updated: January 2026

1. Purpose and Scope

This System Specification forms part of the Terms and Conditions of Pilot Financial Systems Limited ("Pilot") and describes, at a high level, the functionality, technical architecture, security controls, and intended use of the Pilot platform (the "System").

This specification is primarily customer-facing and is also intended to support transparency with regulators and other stakeholders. It is descriptive in nature and does not constitute a binding commitment that any specific feature, workflow, or output will be available at all times or in any particular form.

The System is designed to support regulated financial advisers and advisory firms in the delivery of financial planning and investment advice to personal, trust, and corporate clients. The System is an adviser-support tool only and does not provide regulated advice to end clients.

Functionality described in this specification may evolve, be enhanced, restricted, or withdrawn over time in accordance with the Terms and Conditions.

2. Supported Client Types

The System supports the following client structures:

Personal Clients (individuals and joint clients)
Trust Clients (including, but not limited to, bare trusts, discretionary trusts, loan trusts, and other common UK trust structures)
Corporate Clients (including owner-managed businesses, companies, partnerships, and LLPs)

Client records may be linked to reflect real-world relationships (e.g. individual trustees, company directors, beneficiaries).

3. Core Functional Modules

Unless expressly stated otherwise, all modules are provided as adviser-support tools only. Outputs generated by the System require professional judgement, validation, and approval by the authorised adviser prior to use, disclosure, or reliance.

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3.1 Client Portal

Secure, web-based portal for client access.
Enables clients to view selected documents, reports, and information shared by the adviser.
Supports secure two-way messaging between adviser and client.
Access is controlled by adviser-defined permissions.

3.2 Factfind

Structured digital factfind covering personal, financial, tax, investment, and protection information.
Supports different factfind pathways depending on client type (personal, trust, corporate).
Client version of the factfind via the Client Portal.

3.3 Cashflow Modelling

Cashflow modelling tools to project income, expenditure, assets, liabilities, and investment growth over time.
Supports multiple scenarios and assumptions.
Outputs designed to support adviser analysis and suitability reporting.
Cashflow outputs are illustrative and reliant on adviser-defined assumptions.

3.4 Suitability Report Generation

Automated generation of suitability reports based on data held within the System.
Template aligned to common UK regulatory expectations.
Ability to include adviser commentary, product comparisons, risk explanations, and disclosures.
Reports are generated for adviser review and approval prior to issue.

3.5 Portfolio Research and Risk Profiling

Risk profiling tools to assess client attitudes to risk and capacity for loss.
Portfolio analysis and comparison functionality.
Mapping of client risk profiles to portfolio or investment solutions.
Risk profiling outputs are advisory-support tools and do not constitute advice in isolation.

3.6 Product Research

Structured product research and comparison tools.
Supports analysis across pensions, investments, bonds, and other financial products.
Records rationale for product selection and rejection.
Designed to evidence suitability and research processes.

3.7 Income Reconciliation

Ability to upload or enter bank account receipts and provider statements.
Supports matching bank accounts receipts against provider payments.
Individual payments from providers can be matched against client policies.
Designed to support firms in categorising and reporting their income.
Reports are exportable.

3.8 Management Reporting

Adviser and firm-level reporting dashboards.
Metrics may include client segmentation, servicing activity, workflow status, and financial planning outputs.
Reports are configurable and exportable.

3.9 Document Storage (AWS)

Secure document storage using Amazon Web Services (AWS) infrastructure.
Supports storage of client documents, reports, correspondence, and attachments.
Documents are encrypted at rest and in transit.
Access controls applied at firm, adviser, and client level.
Pilot does not guarantee the long-term retention of any specific document beyond contractual retention periods.

3.10 Task Management

Task and workflow management tools for adviser teams.
Supports assignment, prioritisation, and tracking of tasks.
Links tasks to clients, cases, or review cycles.

3.11 Audit Trail of Data Changes

Comprehensive audit logging of key data changes.
Records include user, timestamp, and nature of change.
Audit logs are retained to support compliance, governance, and internal oversight.

3.12 Secure Messaging System

Encrypted internal messaging between advisers and clients.
Messaging retained as part of the client record.
Designed to reduce reliance on unsecured email communication.
Messaging is not intended to replace formal client disclosures or regulatory communications where alternative delivery methods are required.

4. Security and Access Controls

Role-based access controls for firms, advisers, and support users.
Multi-factor authentication (where enabled).
Encryption of data in transit (TLS) and at rest.
Logical segregation of firm data within the System.
Pilot does not warrant that unauthorised access can never occur and shall not be liable for breaches arising outside its reasonable control.

5. Data Hosting and Resilience

Hosted on AWS infrastructure located within approved jurisdictions.
Regular system backups and disaster recovery procedures.
High availability architecture designed to minimise downtime.
Pilot does not guarantee uninterrupted availability of the System.

6. Regulatory Positioning

The System is an adviser enablement platform and does not provide regulated financial advice.
Pilot does not act as an authorised person under the Financial Services and Markets Act 2000 in relation to advice provided using the System.
Responsibility for advice suitability, regulatory compliance, disclosures, record-keeping, and client outcomes remains solely with the authorised firm and adviser.
Outputs generated by the System must be reviewed, validated, and approved by an authorised individual before being relied upon.

7. Limitations

The System relies on the accuracy, completeness, and timeliness of data input by users or imported from third-party sources.
Projections, cashflow modelling, risk profiling, and portfolio analysis outputs are illustrative only and are not guarantees of future performance or outcomes.
Pilot does not warrant that use of the System will ensure regulatory compliance or suitability in any specific case.
The System does not replace professional judgement, internal controls, or compliance oversight within an advisory firm.

8. Artificial Intelligence and Automated Data Extraction

The System may use artificial intelligence (AI) and machine-learning techniques to extract, classify, and structure data from documents uploaded to the System (including, but not limited to, statements, policy documents, and reports).
AI-assisted extraction is intended to support efficiency and reduce manual data entry and does not guarantee accuracy or completeness.
Users remain responsible for reviewing, validating, and correcting all data extracted by AI before reliance or onward use.
Pilot does not warrant that AI-generated outputs will be complete, error-free or suitable for use without human oversight.

9. Changes to the Specification

Pilot may update this System Specification from time to time to reflect enhancements, regulatory developments, security requirements, or operational changes, in accordance with the Terms and Conditions.

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