Bastion Row

Independent consultancy for St. James’s Place Partners

Clarity under
scrutiny.

Independent risk, suitability and client-outcome support for St. James’s Place Partners and Advisers — ensuring your advice stands up to Risk, Supervision, FCA and FOS scrutiny, while delivering consistently good client outcomes in line with Consumer Duty.

Expert compliance oversight — and the peace of mind that comes with it.

Led by Cosmin Zamfir·Risk, Suitability & Client Outcome Specialist

01Why Bastion Row

The reassurance that your standards never slip.

Most Partners aren’t looking to become compliance experts — they’re looking for the confidence that their practice is, and stays, compliant. That confidence is what I provide.

Think of Bastion Row as peace of mind and ongoing assurance. I act as an independent gatekeeper, checking your files and processes periodically against FCA rules and SJP guidance, so standards never quietly slip between formal reviews, and issues are caught and put right long before they become findings.

And as guidance evolves, you don’t inherit another problem — you receive a clear, ready-made plan of action. Compliance comes off the principal’s desk, so you can focus on your clients and your growth, not the sleepless nights before a Practice Compliance Review (PCR).

This is not a tick-box exercise. It is a real-world, outcome-focused view of your risk exposure.
— Cosmin Zamfir
i.

A constant gatekeeper

Files and processes reviewed periodically against FCA rules and SJP guidance, so nothing slips between reviews.

ii.

Guidance, translated

As rules and guidance evolve, you get a clear, practical plan of action — not another task added to your list.

iii.

The burden, lifted

Compliance off your desk and off your mind, with the assurance your practice will hold up to scrutiny.

02The Specialist

The view from both sides of the table.

Your compliance is only as reassuring as the person behind it. I am a former St. James’s Place Supervisor and Risk Manager, with more than fifteen years in conduct and business risk, regulatory supervision, consultancy and complaint handling — across SJP, KPMG, Barclays, Lloyds Banking Group and the Financial Ombudsman Service. I know exactly what a review looks for, and what gets flagged, because assessing adviser competence and client outcomes has been my day job for years.

i.

Supervisor's eye

I supervised adviser competence and client outcomes at SJP — I know what “good” looks like from the inside.

ii.

Former FOS adjudicator

Files assessed as a complaint would actually be judged — from years inside the Ombudsman service.

iii.

Big Four remediation

KPMG QA and remediation case reviews: root causes and durable fixes, not cosmetic corrections.

iv.

Outcome-testing background

Years of TCF and Consumer Duty outcome testing at Lloyds — measuring whether clients are genuinely well served.

v.

Commercially grounded

Accountancy trained, and fluent in the numbers behind your advice and your practice.

vi.

Change that sticks

A distinction-level qualified coach, so improvements embed and hold — rather than simply being filed.

Track record across
St. James's Place·KPMG·Barclays·Lloyds Banking Group·Financial Ombudsman Service
Qualifications
BA Accounting & ManagementDipFACeMAPPRINCE2Level 5 Coaching Professional (Distinction)EMCC Recognised Coach
03How It Works

A simple, two-step partnership.

Step 01

The initial assessment

We start with an independent Practice Health Check — a structured review of file quality, the client journey, MI, documentation and risk exposure, delivered as a clear RAG rating with a prioritised action plan.

You get an honest, evidence-based picture of exactly where your practice stands today — and what, if anything, needs attention first.

Step 02

The assurance partnership

We then put a fixed-term agreement in place — typically twelve months — under which I act as your ongoing gatekeeper. Everything is set out in detail, so you know precisely what reassurance you are getting:

  • Periodic file checks against FCA rules and current SJP guidance
  • Independent outcome testing aligned to Consumer Duty
  • Emerging risk trends, translated into targeted, preventative action
  • Focused preparation ahead of any PCR visit
  • Periodic check-ins to review progress and answer your questions

When practices bring me in

Preparing for a PCR visitConcerns over file quality or documentationRapid business growthPrevious risk findingsNeed for independent reassurance

Scope & Fees

Every practice is different. Engagements are scoped and priced individually, prior to the initial assessment — so you only ever pay for the reassurance your practice actually needs.

For an indicative scope and fee, get in touch for a confidential, no-obligation conversation.

Contact us for details
04The Toolkit

The support you can draw on.

The assurance partnership is the flagship — but each service below is also available on its own, as a focused one-off engagement.

01

Assess & Diagnose

Know where you stand

Practice Health Check

Structured, independent end-to-end review of file quality, client journey, MI, documentation and risk exposure — delivered as a clear RAG rating with a prioritised, actionable improvement plan.

Full Practice Deep Dive

A comprehensive review of your operating model: front-to-back process alignment, scalability, governance, financial crime, GDPR, complaints handling and vulnerable-client processes.

02

Strengthen & Improve

Fix the root cause

Remediation & Issue Resolution

Root-cause analysis, file remediation and sustainable, long-term solutions for identified risks.

Adviser Coaching & Development

Hands-on, qualified-coach support to strengthen client-facing skills, improve suitability and enhance overall advice quality.

Consumer Duty & Outcome Testing

Independent, evidence-based assessment that advice delivers fair, consistent client outcomes.

03

Monitor & Prepare

Stay inspection-ready

Ongoing File Review Programme

Regular, risk-based sampling and thematic reviews, supported by trend analysis to identify emerging issues early and keep file quality consistent.

Pre-Supervision / Pre-PCR Support

Targeted preparation ahead of reviews — gap analysis, file enhancements and alignment to expected standards — for confidence and fewer challenges.

05Your Outcomes

What you’re left with.

Every engagement is built to leave the practice measurably stronger — and to keep it that way. In practical terms, that means:

01

Clarity on your risks

You know exactly where the exposure sits, and what to address first.

02

No surprises at inspection

No surprises during a PCR visit — you walk in knowing what they'll find.

03

Fewer recurring findings

Issues fixed at the root, so they don't return — and supervisory intervention reduces over time.

04

Consistently good client outcomes

Fair, consistent client outcomes, evidenced and in line with Consumer Duty.

05

Peace of mind

A resilient, inspection-ready practice — and the reassurance that standards will hold between reviews.

The bottom line

Current, checked, and off your desk — the reassurance that your standards will hold.

06Start the Conversation

Let’s talk before
your next review.

Whether you’re preparing for a PCR visit, addressing a risk finding, or you simply want independent reassurance — the first conversation is confidential, and always directly with me.

Telephone
0787 244 5827
Principal
Cosmin ZamfirRisk, Suitability & Client Outcome Specialist

Your enquiry is treated as private & confidential and goes directly to Cosmin.