What happened?
As featured in Always Finance News, TCC Group’s Strategic Regulatory Director, Jason Wintie, explored what the FCA’s latest feedback on ongoing advice means for advice firms.
The regulator’s softer tone should not be mistaken for lesser expectations. It made clear that firms still have obligations under the Consumer Duty and the Dispute Resolution: Complaints Sourcebook (DISP) to identify and put right any harm caused to clients.
Why does it matter?
That responsibility is not limited to responding to complaints; it extends to identifying foreseeable harm wherever it may have occurred, including in advice delivered as far back as 2018.
Who is affected?
The analysis is directed at financial advice and wealth management firms, and pensions and retirement income providers, that deliver or have historically delivered ongoing advice services.
Key risks
- Mistaking the FCA’s softer tone for reduced obligations
- Failing to identify foreseeable harm beyond client complaints
- Overlooking advice delivered as far back as 2018
Actions to take
- Review historic ongoing advice delivery, not only cases that have generated complaints.
- Assess obligations under the Consumer Duty and DISP to identify and put right foreseeable harm.
- Extend the review period back to 2018 where advice of this type was delivered.
Recommendations
Firms should treat the FCA’s feedback as confirmation that historic advice review remains a live obligation, not a closed chapter.
Supporting sources
Frequently asked questions
Does the FCA's softer tone mean lower expectations for firms?
No. The FCA made clear that firms still have obligations under the Consumer Duty and DISP to identify and put right harm caused to clients.
How far back can this obligation extend?
The obligation can extend to advice delivered as far back as 2018.
Is this obligation limited to responding to complaints?
No. Firms must identify and remedy foreseeable harm wherever it may have occurred, not only in response to complaints.
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- Pensions & Retirement IncomeTCC helps pension providers, retirement specialists, advisers, platforms and consolidators strengthen retirement income governance, evidence customer outcomes and manage regulatory risk. Our specialists support firms with retirement income reviews, ongoing servicing assessments, Consumer Duty programmes, DB transfer reviews, vulnerability frameworks, remediation projects and compliance monitoring across the customer lifecycle.
- Wealth Management & Financial AdviceTCC helps wealth managers, financial advisers, networks, platforms and consolidators strengthen compliance, evidence customer outcomes and manage regulatory risk. Every engagement is designed to deliver practical improvements, stronger governance and regulator-ready evidence. For more than 25 years, we have helped FCA-regulated firms navigate regulatory change, supervisory reviews and business growth.