The Norwegian Financial Supervisory Authority has published an inspection report on Stavanger Asset Management AS and its tied agent Noon Invest AS, concluding that the agent’s digital investment advice process did not meet suitability requirements and that customers were not given sufficient information on costs before deciding to invest. The report also highlights potentially misleading client communications about the degree of personalisation and deficiencies in documentation of investment-related communications, while taking the firm’s stated remedial measures on record. On suitability, the Authority found that the agent’s questionnaire-based mapping and subsequent account-opening form did not gather all necessary information under the Securities Trading Act and Commission Delegated Regulation (EU) 2017/565 (Articles 54 and 55), and that portfolio recommendations were presented before there was a sufficient basis to assess suitability. It also found customers were not adequately informed why the proposed model portfolio suited their needs and profile, after the agent stopped sending a welcome letter explaining the assessment, which the firm states has now been reinstated. On cost information, the Authority concluded that disclosures did not enable customers to understand total costs and their impact on returns, including because return scenarios shown alongside portfolio proposals did not also incorporate costs, and because standard terms did not clearly set out costs associated with investing through the firm as distinct from the agent. The report further found that marketing phrases such as “tailored” could mislead given advice was generated from five predefined model portfolios, and that record-keeping controls were insufficient where Microsoft Teams meetings were not recorded or minuted and WhatsApp was used without recording. Finanstilsynet asked the firm to send a copy of the report letter to its auditor.
Norwegian Finanstilsynet 2025-08-20
Norwegian Financial Supervisory Authority finds shortcomings in suitability assessments, cost disclosures and record-keeping at Stavanger Asset Management and agent Noon Invest
The Norwegian Financial Supervisory Authority's inspection report on Stavanger Asset Management AS and its agent Noon Invest AS found deficiencies in their digital investment advice process, including non-compliance with suitability requirements and inadequate cost disclosures. It highlighted misleading client communications and insufficient documentation of investment-related interactions. The Authority has requested the firm to forward the report to its auditor.