Advisory agreement redaction is the removal of personal data from a client contract. FCA COBS 8A requires a firm doing MiFID business to set out its agreement with a client in writing before it provides the service, with COBS 8 covering the rest. The fee section answers to COBS 6.1A adviser charging, which since the Retail Distribution Review took effect on 31 December 2012 has barred a firm giving personal recommendations on retail investments from taking commission. For a consumer, Consumer Rights Act 2015 s.62 tests the fairness of the terms and s.68 requires them to be transparent. anonym.plus marks each party detail on your device, so the terms stay clear while the names go.
When this applies
A discretionary management agreement names the parties, the mandate, the fee scale and the debit account. An external counsel review, a template audit or a fee benchmarking exercise needs the drafting, not the client. You trim the identity parts before it is filed or shared; the executed original stays on the client file.
How anonym.plus handles it
- Open the contract in anonym.plus on your device.
- Local OCR reads the scanned signature and schedule pages.
- The tool flags party names, addresses and account numbers.
- Keep the fee schedule, mandate description and operative clauses.
- Swap or black out the marked items.
- Save the clean copy locally.
What you need to provide
- The contract (PDF, DOCX, or scan).
- An operator (Replace keeps the terms readable).
- Optional alias map so a party is consistent across linked papers.
PII & financial identifiers detected
| Category | anonym.plus entity type | Example |
|---|---|---|
| Names | PERSON | Mr Quinn → [PARTY] |
| Financial | UK_BANK_NUMBER | fee debit acct → [ACCOUNT] |
| Identifiers | UK_NINO | tax NINO → [NINO] |
| Money | MONEY | fee 1.00% of funds → [FEE] |
| Location | LOCATION | party address → [ADDRESS] |
| Contact | PHONE_NUMBER | +44 161 496 0210 → [PHONE] |
Compliance achieved
- FCA COBS 8A requires a written client agreement before MiFID services are provided, with COBS 8 covering other business; the executed agreement is the record, so redaction applies to a copy.
- The fee schedule answers to COBS 6.1A adviser charging, which since the Retail Distribution Review took effect on 31 December 2012 has barred commission on personal recommendations for retail investment products.
- For a consumer, Consumer Rights Act 2015 s.62 tests a term for fairness and s.68 requires it to be transparent — plain, intelligible and legible; redaction must not make the operative wording unreadable.
- A discretionary mandate is managing investments under RAO 2001 art. 37, so the agreement evidences a regulated permission and is kept whole in the firm's own file.
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Limitations & cautions
A bespoke fee scale or a tailored mandate can identify one client even with every name gone, and side letters compound that. The tool flags named items, not unique commercial terms, and it does not assess fairness under the Consumer Rights Act 2015. Review tailored clauses before you share.
Frequently asked questions
Can I keep the fee schedule?
Yes. Allow-list the fee terms and operative clauses. Only personal identifiers are marked, which matters because COBS 6.1A adviser charging is judged on the fee wording itself, not on who signed it.
Does the redacted copy replace the client agreement?
No. COBS 8A requires the written agreement to be in place before MiFID services start, and the executed version is the record. A redacted copy is a working document for review or benchmarking.
Will the contract still read after the swap?
Yes. The Replace operator drops a steady label for each party, so the clauses still flow — which also helps with the transparency requirement in Consumer Rights Act 2015 s.68.