The FCA recently reported that 83% of ongoing advice suitability reviews were conducted as required. On the surface, this sounds like great news – but before breathing a premature sigh of relief, it’s important to consider the broader picture.

To do just that, TCC reached out to wealth managers in a poll to gauge market opinion and the responses were mostly positive: 72% were pleasantly surprised by the regulator’s findings, 26% felt the results met expectations, and only 2% thought it fell short. However, the review data was self-reported and did not consider the qualitative content of the said reviews.

To unpack this further, TCC hosted a roundtable with professionals from across the industry. From these discussions, four critical focus areas emerged for firms navigating the ongoing advice landscape; implementing a back book review, demonstrating an evidence trail, getting regulatorily ready, and future proofing for the long term.

1. Back book review: looking back to move forward
The regulator now expects firms to assess whether all ongoing advice services promised since January 2018 have been delivered. This means reviewing old files, mining data, and testing samples – not just ticking boxes. Many firms are already sampling reviews and preparing for possible redress, all while navigating risks like tax-wrapped investments and indemnity insurance.

2. Evidence trail: show your work
Firms must clearly document that advice meetings occurred and met regulatory standards. Desk-based checks alone are not sufficient. From maintaining thorough notes to tracking client goals and risk tolerance, the emphasis is on capturing the substance of advice, not just the form. Transparency in client agreements is key to setting expectations and avoiding future disputes.

3. Regulatory readiness: be prepared
The FCA has clarified that if a client declines a review, redress is less likely – but not off the table. Firms must demonstrate reasonable efforts to engage clients, track communications, and understand disengagement patterns. Tailored client contact strategies and strong record-keeping are essential to minimise risk.

4. Future proofing: build resilience
With the Consumer Duty obligations now front and centre of compliance standards, firms need clear refund policies, fair value assessments, and processes that adapt to client vulnerabilities. Evaluating whether clients are achieving value from ongoing services is no longer optional – it’s a regulatory necessity.

What’s next?
The journey doesn’t stop there. Firms should embed robust advice practices into their business, supported by clear management information and regular evaluations. Partnering with compliance experts like TCC can help firms navigate complexity, maintain high standards, and future-proof operations.

At TCC, we provide tailored solutions – from expert reviews to interim resource and specialised RegTech – so your firm can thrive in this evolving regulatory environment.

Want to stay ahead of the curve? Get in touch with us to explore how we can support your compliance goals with confidence.