Insights for modern advisory firms

Review evidence

Traceable

Review scheduling, completion, follow-up and closure should sit in one evidence trail.

Delivery proof

Not diary-led

A booked review is not the same as a completed and evidenced advice event.

Remediation control

Time-bound

Missed reviews should trigger escalation, ownership and closure evidence rather than apology notes.

Support ownership

Explicit

Support failures often begin where ownership is implied rather than assigned.

Vulnerability signal

Dynamic

Vulnerability should be reviewed as a changing condition, not a one-off checkbox.

Response evidence

Traceable

The regulator will care whether support was meaningful, timely and connected to the client state.

Outcome MI

Board-ready

The board should see client-impact signals, not just process activity counts.

Remediation visibility

Closed-loop

Escalations matter only when the board can see whether they were resolved.

Evidence chain

Traceable

From indicator to committee action to client-level resolution.

Defect timing

Too late

A defect found after advice has been given is a control failure, not a success.

Guardrail logic

Point-of-entry

Input gaps, CFL conflicts and unsupported recommendations should trigger before completion.

Review burden

Reduced

Compliance should review by exception, not reconstruct preventable reasoning after the fact.

Income anxiety

Immediate

In decumulation, market falls are interpreted against spending security, not just fund value.

Support timing

Critical

Delayed contact gives clients time to self-interpret risk and make irreversible decisions.

Decision framing

Scenario-led

Vulnerable clients need structured options, not generic reassurance during stress.

Recurring revenue

Defensible

Buyers increasingly test whether service income is actually supported by delivered work and evidence.

Operating proof

Data-room ready

Review delivery, suitability evidence and remediation discipline now shape diligence quality.

Control quality

Visible

A buyer wants to see how the firm finds, owns and resolves operational issues before they become liabilities.

Files reviewed

100

Across 24 firms, covering drawdown, annuity and mixed scenarios.

Register accuracy

46%

Only 46% of advice registers were fully accurate.

Missed reviews

6,108

Customers who paid for ongoing reviews but didn't receive one.

Register gaps

54%

Of firms had incomplete or inaccurate advice registers.

QA failure

Widespread

Firms' own QA failed to catch issues the FCA found.

MI requirement

Mandatory

Consumer Duty requires demonstrable outcome monitoring.

Accumulation bias

All 24

No firm had decumulation-specific risk profiling language.

CFL incomplete

9 of 67

Files with incomplete capacity for loss assessment.

K&E missing

6 of 67

Files where knowledge and experience was not established.

Files incomplete

33%

Had missing documents or significant information gaps.

MIG rate

22%

Of files had material information gaps preventing assessment.

Inconsistent data

Multiple

Fact-finds between revisions contradicted each other.

CFM usage

765

Firms using cashflow modelling tools out of 977 surveyed.

CFL tools

596

Firms using capacity for loss tools.

Stress gaps

Common

Longevity and inflation stress testing inconsistent.

Tool reliance

95%

Of firms use third-party tools or services.

Due diligence

50%

Of firms completed research on their tool providers.

Risk tools

842

Firms using third-party risk profiling tools.

Delivery proof

Traceable

Every promised service can be mapped to a completed action and client outcome.

Value coverage

89%

Typical coverage target for completed annual service commitments.

Refund risk floor

Low

Structured remediation controls reduce unresolved fee-value exceptions.

Retention window

10 days

Most effective intervention period after material downside events.

Scenario briefings

Structured

Consistent scenario language improves client understanding under stress.

Attrition delta

-18%

Illustrative reduction when intervention cadence is actively managed.

Simulation depth

Path-based

Each run projects annual wealth path, drawdown, and terminal state.

Decision outputs

10 metrics

Success, shortfall, confidence bands, drawdown, volatility and depletion signals.

Validation pack

80 tests

Deterministic, stochastic, stress and API consistency checks.

Yearly logic

5-step

Consistent sequence from contributions to surplus reinvestment.

Shortfall policy

3-stage

Cash first, investments second, pension third.

Adviser signal

Sustainability

Income-expense ratio and shortfall years drive action.

Scenario breadth

Multi-domain

Market, inflation, rates, longevity, currency, personal events.

Resilience outputs

5 signals

Survival, shortfall, worst case, resilience score, mitigation priority.

Action framing

Priority tiers

Immediate, short-term, and long-term mitigation guidance.

Validation design

4 domains

Monte Carlo, cashflow, stress transforms, and API consistency.

Release control

Gate-based

Defects block release until regression coverage is in place.

Evidence quality

Traceable

Assumption, result, defect, and fix chain is auditable.

Duty outcomes

4 outcomes

Products & services, price & value, understanding, support.

Monitoring layers

3 layers

Governance, MI, remediation workflow.

Portfolio letters

Sector-led

Consumer investments, asset management and more.

COBS coverage

COBS 9/9A

Suitability plus pensions and retirement guidance.

Evidence inputs

6 inputs

Objectives, horizon, ATR, CFL, affordability, vulnerability.

Review trail

Traceable

Clear link from inputs to recommendation.

Range view

3 bands

Downside, central, upside outcomes.

Stress tests

2 tests

High inflation and early drawdown.

Decision levers

3 levers

Age, withdrawals, contributions.

Thematic review

TR24/1

FCA thematic review of suitability practices across firms.

Assessment sections

13

Sections required for comprehensive suitability coverage.

Evidence standard

100%

Firms reviewed must evidence compliance across all areas.

Inadequate records

62%

Firms with inadequate CFL records in FCA samples.

Emergency fund

3-6

Months of expenditure as minimum emergency fund.

CFL dimensions

4

Key dimensions to assess for capacity for loss.

Duty outcomes

4

Consumer Duty outcomes to evidence in suitability.

Implementation

PS22/9

The implementation standard for Consumer Duty.

Evidence standard

100%

Suitability reports must evidence all four outcomes.