What should firms do about disengaged clients?

TCC experts David and Garry explain how financial advice firms must handle cohorts of disengaged and uninvited clients, including historical data checks and disengagement policies.

What happened?

Following the FCA’s release of its findings into its recent ongoing advice review, TCC’s Chief Product and Commercial Officer Garry Evans catches up with our Technical Director David Boyhan – who specialises in wealth management to unpack all the detail.

In the second instalment of five-part mini-series, Garry asks David what firms should be doing about clients who are not engaging with them. Watch part two now to learn more or read the transcript below.

Watch part two:

Frequently asked questions

What is the FCA's expectation for clients who were never invited to reviews?

The FCA expects immediate, proactive redress and fee remediation for any client who was charged an ongoing advice fee but was never invited to their annual review.

How should firms handle disengaging from unresponsive clients?

Firms must implement a structured, compliant disengagement process. This includes assessing client vulnerability, executing a documented chase sequence, and formally ending the contract if engagement is not achieved.

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.

Reviewed by TCC Group Editorial Team September 15, 2026

Ready to strengthen your compliance?

Speak to our experts about your regulatory challenges.

Contact us today