What happened?
The FCA has been requesting information from firms on their ability to report the number of ongoing advice reviews conducted and missed since 2017, an area many firms have struggled to evidence within the required timeframe. Firms that maintain a business register or client management system tracking review subscriptions, meeting frequency, scheduled and actual review dates, and follow-up reviews, are better placed to respond to these requests.
In its Retirement Income thematic review, the FCA has also set out examples of data firms should hold, including clients’ attitude to risk, capacity for loss and total assets, including their primary residence, to help identify inheritance tax exposure ahead of the IHT changes due in 2027.
Why does it matter?
Firms with well-structured client data are not only able to respond to FCA information requests more easily, they can also use review meetings to identify clients with protection or inheritance tax needs, supporting better outcomes and a stronger business.
For retirement income clients, understanding who is in the decumulation phase, who has had a cash flow analysis in the past year, and who is at risk of running out of funds allows firms to prioritise engagement before regulatory deadlines land.
Who is affected?
Financial advice and wealth management firms managing ongoing advice services, and those advising clients on retirement income and decumulation, are most directly affected.
Key risks
- Inability to evidence the number of ongoing advice reviews conducted and missed when the FCA requests this information.
- Client management systems that do not capture review frequency, scheduled dates, actual dates and follow-up reviews.
- Missing data on clients’ attitude to risk, capacity for loss and total assets, limiting firms’ ability to identify inheritance tax exposure ahead of the 2027 changes.
Actions to take
- Review your business register or client management system against the FCA’s ongoing advice review reporting requirements.
- Capture review subscription status, meeting frequency, scheduled dates, actual dates and follow-up review dates for every client.
- Record attitude to risk, capacity for loss and total assets, including primary residence, for retirement income clients.
- Use the data gathered to prioritise client engagement ahead of the IHT changes taking effect in 2027.
- Seek external support to review and refresh your business register if this represents a significant undertaking.
Wider implications
Enhancing customer data is not solely a response to a specific FCA request; it strengthens the underlying evidence base a firm needs to demonstrate ongoing compliance and to identify commercial opportunities within its existing client bank.
Recommendations
Firms should treat their business register as a strategic asset rather than an administrative record, and prioritise the data fields the FCA has specifically referenced in its ongoing advice review requests and Retirement Income thematic review.
Supporting sources
Frequently asked questions
Why is the FCA interested in ongoing advice review data?
The FCA has been requesting information on the number of ongoing advice reviews conducted and missed since 2017, and firms need to be able to report this data quickly and accurately.
What retirement income data does the FCA expect firms to hold?
The FCA’s Retirement Income thematic review references data such as clients’ attitude to risk, capacity for loss and total assets, including their primary residence.
Why does inheritance tax matter for customer data now?
From 2027, inheritance tax changes will affect more clients, so firms need accessible data on total assets to identify and prioritise those with potential IHT exposure.
Where should firms start if their data is lacking?
Reviewing and refreshing the business register or client management system is a practical first step, and external support can help firms do this efficiently.
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