# TCC Group > TCC Group is the collective strength of TCC, Recordsure and Momenta: > intelligent compliance consultancy, regulator-trusted AI technology and > strategic resourcing for FCA-regulated financial services firms in the UK. > Legal entity: The Consulting Consortium Ltd (Companies House 04144405). ## Detailed Content ## Pages ### Privacy Statement: TCC Associates - URL: https://tcc.group/privacy-statement-tcc-associates/ - Published: 2026-09-03 - Modified: 2026-09-03 ## Policy title and summary Privacy Statement: TCC Associates If you have any queries or requests concerning this privacy statement, your personal information or how we process it, please contact TCC and Recordsure at dpo@tcc.group. ## Key facts panel TCC Group ## Related policies - Privacy and Policies — /privacy-statement/ - Privacy: Visitors and clients — /privacy-statement-visitors-and-clients/ - Privacy: Employees — /privacy-statement-tcc-employees/ - Privacy: Legal basis — /privacy-statement-legal-basis/ - Privacy: Third parties — /privacy-third-party-list/ - Cookies — /cookies/ ## Privacy / compliance contact Data protection dataprotection@tcc.group 020 3772 7230 ## Freshness and last reviewed 2026-09-03 ## Editorial byline TCC Group Editorial Team /meet-the-team/ ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": 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"position": 3, "name": "Privacy: Employees", "url": "https://tcc.group/privacy-statement-tcc-employees/" }, { "@type": "ListItem", "position": 4, "name": "Privacy: Legal basis", "url": "https://tcc.group/privacy-statement-legal-basis/" }, { "@type": "ListItem", "position": 5, "name": "Privacy: Third parties", "url": "https://tcc.group/privacy-third-party-list/" }, { "@type": "ListItem", "position": 6, "name": "Cookies", "url": "https://tcc.group/cookies/" } ] }, { "@type": "ContactPoint", "@id": "https://tcc.group/privacy-statement-tcc-associates/#contact-point", "contactType": "Data protection", "email": "dataprotection@tcc.group", "telephone": "020 3772 7230" } ] } ``` ### Privacy Statement: Legal basis - URL: https://tcc.group/privacy-statement-legal-basis/ - Published: 2026-09-03 - Modified: 2026-09-03 ## Policy title and summary Privacy Statement: Legal basis ## Key facts panel TCC Group ## Full policy content TCC relies upon the following legal bases for processing the personal data obtained from the practices outlined in [Personal Data we Collect](/privacy-statement-visitors-and-clients/). **Legitimate interest** ‘Legitimate Interest’ means the interests of our company in conducting and managing our business to enable us to give you the best services and experience. For example, we have an interest in making sure our services are relevant for you, so we may process your personal data to contact you by telephone with discussions tailored to your interests. When we process your personal information for our legitimate interests, we make sure to consider the balance, and any potential impact, on you (both positive and negative) and your rights under the data protection regulation. Our legitimate business interests do not automatically override your interests – we will not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). Our legitimate business interests may include some or all of the following: - For evidential purposes to effectively manage and maintain records of our relationships/communications with you; - For business development related activity such as contacting you by telephone or email to arrange meetings with our experts in relation to work or knowledge sharing; - To enhance, modify, personalise or otherwise improve our services and communications for the benefit of you; - To better understand how you interact with our website and content in order to enhance your customer experience; - To determine the effectiveness of promotional campaigns to inform marketing strategy. **Legal obligation** Sometimes we will process your personal data to enable us to comply with our obligations to the FCA when carrying out a Section 166 Skilled Person’s Review. ## Related policies - Privacy and Policies — /privacy-statement/ - Privacy: Visitors and clients — /privacy-statement-visitors-and-clients/ - Privacy: Employees — /privacy-statement-tcc-employees/ - Privacy: Associates — /privacy-statement-tcc-associates/ - Privacy: Third parties — /privacy-third-party-list/ - Cookies — /cookies/ ## Privacy / compliance contact Data protection dataprotection@tcc.group 020 3772 7230 ## Freshness and last reviewed 2026-09-03 ## Editorial byline TCC Group Editorial Team /meet-the-team/ ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/privacy-statement-legal-basis/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Privacy Statement: Legal basis", "item": "https://tcc.group/privacy-statement-legal-basis/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/privacy-statement-legal-basis/#webpage", "url": "https://tcc.group/privacy-statement-legal-basis/", "name": "Privacy Statement: Legal basis", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-09-03T17:52:12+01:00", "dateModified": "2026-09-03T00:00:00+00:00", "breadcrumb": { "@id": "https://tcc.group/privacy-statement-legal-basis/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] }, "lastReviewed": "2026-09-03" }, { "@type": "Organization", "@id": "https://tcc.group/privacy-statement-legal-basis/#editorial-team", "name": "TCC Group Editorial Team", "url": "https://tcc.group/meet-the-team/" }, { "@type": "DigitalDocument", "@id": "https://tcc.group/privacy-statement-legal-basis/#policy", "name": "Privacy Statement: Legal basis", "description": "", "text": "TCC relies upon the following legal bases for processing the personal data obtained from the practices outlined in\u00a0Personal Data we Collect.\n\nLegitimate interest\n\n\u2018Legitimate Interest\u2019 means the interests of our company in conducting and managing our business to enable us to give you the best services and experience. 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We also adhere to the Privacy and Electronic Communications Regulations (PECR) to protect your privacy rights when carrying out direct marketing activities.  Your personal information will be held by TCC, registered as The Consulting Consortium Ltd.  TCC is the Controller of personal data relating to the professional individuals within its client or prospective client firms. We use this data in the process of providing our services to clients and for the purposes of relationship management, direct marketing and business development. This statement relates to personal data used for this purpose only. Please refer to our other statements if you are an associate or prospective employee.  **Personal Data We Collect**  TCC collects your personal data, including information provided in various ways. Some of this data is obtained directly from you, including:  - In emails, during telephone calls and conversations, from business cards, when registering for services, as part of providing our services, when participating in surveys and webinars, and when using TCC’s websites.  Some personal data may also be obtained indirectly, such as:  - From other organisations and public sources, for example LinkedIn. [Learn more here](/privacy-third-party-list/). - From your use of, and interaction with, our website and the devices you use to access them, using technology such as [cookies](/cookies/).  The data that we collect will depend upon our interactions with you and the privacy settings and features that you choose. You can change these preferences at any time by contacting dpo@tcc.group. The personal data we collect normally includes names, job title, company, IP addresses, cookie strings and contact details such as phone numbers and email addresses.  **How We Use Personal Data**  TCC will only process your data where we have a legal basis for doing so. TCC uses the data collected to communicate with you, carry out our services and to conduct direct marketing of our services and services related to our sister company Record Sure Limited, which offers technology systems and services that are complementary to the services provided by TCC. We will also use your data to improve or maintain the services we offer to you and our website. We will never share your data with any other third party, other than those stated in this policy, nor use your data for any other purpose, unless we firstly obtain your explicit consent to do so.  We may use your data for profiling. This means we may use the personal data we hold about you from a variety of sources to build a picture of your interests, behaviours and preferences. This profile may combine personal data such as job title, sector and company with your interactions with our website and marketing communications obtained through cookies. We may also enrich this information with other intelligence derived from social media, conversations we have with you or inferred insights from people similar to you. We use these profiles to segment you into audience types for direct marketing, enabling us to provide information and promotions likely to be relevant to you. These profiles are not solely automated; both human analysis and technology are used.  We may also use data such as your name and job title to personalise communications you receive from TCC and our website.  **Your Rights**  You have the right to access, rectify, erase, object to and restrict the processing of your personal data. You also have the right to object to profiling and enrichment activities and can opt out of receiving marketing communications at any time.  **Our Legal Basis for Processing Personal Data**  Our legal basis for processing your personal data may rely upon our Legitimate Interest or Legal Obligation.*** ***[Further information is here](/privacy-statement-legal-basis/). **Recipients of Personal Data**  TCC shares your data with the following third-party service providers. The data storage and processing systems are protected by access controls, to minimise any risk to the integrity or security of your personal data, and the data is stored in servers in the UK, EU and USA. Where the data is stored in the USA, the company (i.e. Salesforce) is certified by the EU-US Data Privacy Framework. TCC shares your data with the following third-party service providers. The data storage and processing systems are protected by access controls, to minimise any risk to the integrity or security of your personal data, and the data is stored in servers in the UK, EU and USA. Where the data is stored in the USA, the company (i.e. Salesforce) is certified by the EU-US Data Privacy Framework. - **Salesforce / Hubspot** – customer relationship management and marketing automation software that is necessary to process your data securely. - **Typeform** – survey software necessary to gather responses to questionnaires used as part of marketing activities or feedback. - **Webinar Software: Zoom/GoogleMeet** – webinar software necessary to host webinars and manage attendance. - **Zapier** – workflow automation apps necessary to transfer data from software we use, such as from Typeform to Salesforce. - **Microsoft Sharepoint** – intranet and file storage and management for TCC projects. This is necessary to store some of your data securely, particularly as part of the services we are providing. - **Replicon:** Sales Invoicing - **Lightyear:** Purchasing invoice approval - **Xero:** Accounting - **HSBC:** Banking TCC will ensure that any third-party processor has adequate data protection measures in place that align with the requirements of the GDPR by conducting periodic due diligence. TCC will not share your data with any third-party processor outside of the UK, EU or USA. TCC does not sell your personal data or other information to any third-party. TCC stores personal information on a secure database which is shared with our sister company Record Sure Ltd (Recordsure). Although data is stored centrally, communication is segmented between the separate companies. To unsubscribe from Recordsure or TCC emails or update your preferences at any time, use the unsubscribe link within the email. Where possible we will tailor the content we send subscribers to keep it relevant, for example, if you work in compliance we will share compliance specific material with you. Once TCC has received your information we are committed to ensuring we have all necessary technical and organisational controls in place to keep your information secure. In order to prevent unauthorised access or disclosure TCC has put in place suitable physical, electronic and managerial procedures to safeguard and secure the information TCC collects. **Retention Period**  TCC will only keep your personal data for as long as necessary for the purposes for which it was obtained. Personal data will be retained for the purposes of direct marketing, relationship management and business development, or where we have another legal basis for processing (such as your consent or where we have a contract to provide our services to you). TCC will review the personal data we hold on you every 12 months to check for accuracy and relevancy and to ensure that we continue to have a legal basis for processing. If the personal data is no longer necessary, or where we no longer have the legal basis for processing, we will delete or fully anonymise the data we hold on you, in line with our GDPR Policy. If your data becomes inaccurate, we will update it accordingly. The exception is information collected from surveys, feedback and questionnaires, which are held only for the duration of its usefulness i.e. the duration of a campaign. The data is then anonymised and retained for internal evidential purposes, or deleted. **Complaints**  TCC will be more than happy to help you should you have any complaints about the processing of your personal data.  Under the GDPR, you have the right to lodge a complaint with the Supervisory Authority, the Information Commissioner’s Office (ICO), who are the national authority responsible for the protection of personal data. A complaint can be made to the ICO via their website: [ico.org.uk](http://ico.org.uk/) or through their helpline: 0303 123 1113. **Changes to This Privacy Statement**  We reserve the right to change this statement. Changes will be published on our website and we recommend that you also check this statement regularly so that you are informed of any changes. ## Related policies - Privacy and Policies — /privacy-statement/ - Privacy: Employees — /privacy-statement-tcc-employees/ - Privacy: Associates — /privacy-statement-tcc-associates/ - Privacy: Legal basis — /privacy-statement-legal-basis/ - Privacy: Third parties — /privacy-third-party-list/ - Cookies — /cookies/ ## Privacy / compliance contact Data protection dataprotection@tcc.group 020 3772 7230 ## Editorial byline TCC Group Editorial Team /meet-the-team/ ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/privacy-statement-visitors-and-clients/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Privacy Statement: Visitors and Clients", "item": "https://tcc.group/privacy-statement-visitors-and-clients/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/privacy-statement-visitors-and-clients/#webpage", "url": "https://tcc.group/privacy-statement-visitors-and-clients/", "name": "Privacy Statement: Visitors and Clients", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-09-03T17:41:55+01:00", "dateModified": "2026-09-03T18:23:12+01:00", "breadcrumb": { "@id": "https://tcc.group/privacy-statement-visitors-and-clients/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "Organization", "@id": "https://tcc.group/privacy-statement-visitors-and-clients/#editorial-team", "name": "TCC Group Editorial Team", "url": "https://tcc.group/meet-the-team/" }, { "@type": "DigitalDocument", "@id": "https://tcc.group/privacy-statement-visitors-and-clients/#policy", "name": "Privacy Statement: Visitors & Clients (Website and Office)\u00a0", "description": "", "text": "TCC is committed to your privacy and adheres to the General Data Protection Regulations (GDPR) and the Data Protection Act 2018 to ensure protection of your personal data. We also adhere to the Privacy and Electronic Communications Regulations (PECR) to protect your privacy rights when carrying out direct marketing activities.\u00a0\n\nYour personal information will be held by TCC, registered as The Consulting Consortium Ltd.\u00a0\n\nTCC is the Controller of personal data relating to the professional individuals within its client or prospective client firms. We use this data\u00a0in the process of providing\u00a0our services to clients and for the purposes of relationship management, direct\u00a0marketing\u00a0and business development. This statement relates to personal data used for this purpose only.\u00a0Please refer to our other statements if you are an associate or prospective employee.\u00a0\n\nPersonal Data We Collect\u00a0\n\nTCC collects your personal data, including information provided in\u00a0various ways. Some of this data is obtained directly from you, including:\u00a0\n\u2022 In emails, during telephone calls and conversations, from business cards, when registering for services, as part of providing our services, when\u00a0participating\u00a0in surveys and webinars, and when using TCC\u2019s websites.\u00a0\n\nSome personal data may also be obtained indirectly, such as:\u00a0\n\u2022 From other organisations and public sources, for example LinkedIn.\u00a0Learn more here.\n\n\u2022 From your use of, and interaction with, our website and the devices you use to access them, using technology such as cookies.\u00a0\n\nThe data that we collect will depend upon our interactions with you and the privacy settings and features that you choose. You can change these preferences at any time by contacting dpo@tcc.group. The personal data we collect normally includes names, job title, company, IP addresses, cookie strings and contact details such as phone numbers and email addresses.\u00a0\n\nHow We Use Personal Data\u00a0\n\nTCC will only process your data where we have a legal basis for doing so. TCC uses the data collected to communicate with you, carry out our services and to conduct direct marketing of our services and services related to our sister company Record Sure Limited, which offers technology systems and services that are complementary to the services provided by TCC.\u00a0We will also use your data to improve or maintain the services we offer to you and our website.\u00a0We will never share your data with any other third party, other than those\u00a0stated\u00a0in this policy, nor use your data for any other purpose, unless we\u00a0firstly\u00a0obtain your explicit consent to do so.\u00a0\n\nWe may use your data for profiling. This means we may use the personal data we hold about you from a variety of sources to build a picture of your interests,\u00a0behaviours\u00a0and preferences. This profile may combine personal data such as job title,\u00a0sector\u00a0and company with your interactions with our website and marketing communications obtained through cookies. We may also enrich this information with other intelligence derived from social media, conversations we have with\u00a0you\u00a0or inferred insights from people\u00a0similar to\u00a0you. We use these profiles to segment you into audience types for direct marketing, enabling us to provide information and promotions likely to be relevant to you. These profiles are not solely automated; both human analysis and technology are used.\u00a0\n\nWe may also use data such as your name and job title to\u00a0personalise\u00a0communications you receive from TCC and our website.\u00a0\n\nYour Rights\u00a0\n\nYou have the right to access, rectify, erase, object to and restrict the processing of your personal data. You also have the right to object to profiling and enrichment activities and can opt out of receiving marketing communications at any time.\u00a0\n\nOur Legal Basis for Processing Personal Data\u00a0\n\nOur legal basis for processing your personal data may rely upon our Legitimate Interest or Legal Obligation.\u00a0Further information is here.\n\nRecipients of Personal Data\u00a0\n\nTCC shares your data with the following third-party service providers. The data storage and processing systems are protected by access controls, to minimise any risk to the integrity or security of your personal data, and the data is stored in servers in the UK, EU and USA. Where the data is stored in the USA, the company (i.e. Salesforce) is certified by the EU-US Data Privacy Framework.\n\nTCC shares your data with the following third-party service providers. The data storage and processing systems are protected by access controls, to minimise any risk to the integrity or security of your personal data, and the data is stored in servers in the UK, EU and USA. Where the data is stored in the USA, the company (i.e. Salesforce) is certified by the EU-US Data Privacy Framework.\n\u2022 Salesforce / Hubspot\u00a0\u2013 customer relationship management and marketing automation software that is necessary to process your data securely.\n\u2022 Typeform\u00a0\u2013 survey software necessary to gather responses to questionnaires used as part of marketing activities or feedback.\n\u2022 Webinar Software: Zoom/GoogleMeet\u00a0\u2013 webinar software necessary to host webinars and manage attendance.\n\u2022 Zapier\u00a0\u2013 workflow automation apps necessary to transfer data from software we use, such as from Typeform to Salesforce.\n\u2022 Microsoft Sharepoint\u00a0\u2013 intranet and file storage and management for TCC projects. This is necessary to store some of your data securely, particularly as part of the services we are providing.\n\u2022 Replicon:\u00a0Sales Invoicing\n\u2022 Lightyear:\u00a0Purchasing invoice approval\n\u2022 Xero:\u00a0Accounting\n\u2022 HSBC:\u00a0Banking\n\nTCC will ensure that any third-party processor has adequate data protection measures in place that align with the requirements of the GDPR by conducting periodic due diligence.\n\nTCC will not share your data with any third-party processor outside of the UK, EU or USA.\n\nTCC does not sell your personal data or other information to any third-party.\n\nTCC stores personal information on a secure database which is shared with our sister company Record Sure Ltd (Recordsure). Although data is stored centrally, communication is segmented between the separate companies. To unsubscribe from Recordsure or TCC emails or update your preferences at any time, use the unsubscribe link within the email.\n\nWhere possible we will tailor the content we send subscribers to keep it relevant, for example, if you work in compliance we will share compliance specific material with you.\n\nOnce TCC has received your information we are committed to ensuring we have all necessary technical and organisational controls in place to keep your information secure. In order to prevent unauthorised access or disclosure TCC has put in place suitable physical, electronic and managerial procedures to safeguard and secure the information TCC collects.\n\nRetention Period\u00a0\n\nTCC will only keep your personal data for as long as necessary for the purposes for which it was obtained. Personal data will be retained for the purposes of direct marketing, relationship management and business development, or where we have another legal basis for processing (such as your consent or where we have a contract to provide our services to you). TCC will review the personal data we hold on you every 12 months to check for accuracy and relevancy and to ensure that we continue to have a legal basis for processing. If the personal data is no longer necessary, or where we no longer have the legal basis for processing, we will delete or fully anonymise the data we hold on you, in line with our GDPR Policy. If your data becomes inaccurate, we will update it accordingly.\n\nThe exception is information collected from surveys, feedback and questionnaires, which are held only for the duration of its usefulness i.e. the duration of a campaign. The data is then anonymised and retained for internal evidential purposes, or deleted.\n\nComplaints\u00a0\n\nTCC will be more than happy to help you should you have any complaints about the processing of your personal data.\u00a0\n\nUnder the GDPR, you have the right to lodge a complaint with the Supervisory Authority, the Information Commissioner\u2019s Office (ICO), who are the national authority responsible for the protection of personal data. A complaint can be made to the ICO via their website:\u00a0ico.org.uk\u00a0or through their helpline: 0303 123 1113.\n\nChanges to This Privacy Statement\u00a0\n\nWe reserve the right to change this statement. Changes will be published on our website and we\u00a0recommend that you also check this statement regularly so that you are informed of any changes.", "url": "https://tcc.group/privacy-statement-visitors-and-clients/", "publisher": { "@id": "https://tcc.group/#organization" }, "reviewedBy": { "@id": "https://tcc.group/privacy-statement-visitors-and-clients/#editorial-team" }, "additionalProperty": [ { "@type": "PropertyValue", "name": "owner", "value": "TCC Group" } ] }, { "@type": "ItemList", "@id": "https://tcc.group/privacy-statement-visitors-and-clients/#related-policies", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Privacy and Policies", "url": "https://tcc.group/privacy-statement/" }, { "@type": "ListItem", "position": 2, "name": "Privacy: Employees", "url": "https://tcc.group/privacy-statement-tcc-employees/" }, { "@type": "ListItem", "position": 3, "name": "Privacy: Associates", "url": "https://tcc.group/privacy-statement-tcc-associates/" }, { "@type": "ListItem", "position": 4, "name": "Privacy: Legal basis", "url": "https://tcc.group/privacy-statement-legal-basis/" }, { "@type": "ListItem", "position": 5, "name": "Privacy: Third parties", "url": "https://tcc.group/privacy-third-party-list/" }, { "@type": "ListItem", "position": 6, "name": "Cookies", "url": "https://tcc.group/cookies/" } ] }, { "@type": "ContactPoint", "@id": "https://tcc.group/privacy-statement-visitors-and-clients/#contact-point", "contactType": "Data protection", "email": "dataprotection@tcc.group", "telephone": "020 3772 7230" } ] } ``` ### Privacy Statement: TCC Employees - URL: https://tcc.group/privacy-statement-tcc-employees/ - Published: 2026-09-03 - Modified: 2026-09-03 ## Policy title and summary Privacy Statement: TCC Employees ## Key facts panel TCC Group ## Full policy content ### Introduction TCC is the controller of personal data for its employees, and prospective employees, for the purposes of managing the employment or prospective employment relationship. TCC is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations. This privacy statement explains what personal data TCC collects from you through our interactions with you, and sets out how we use that data. This statement also explains how TCC protects any personal data that we obtain directly or passively from you, or which we obtain indirectly from other sources. You can be assured that it will only be used in accordance with this privacy statement. Data Controller: TCC & Recordsure 10 Lower Thames Street London EC3R 6EN Email: dpo@tcc.group Telephone: 020 3772 7230 **How do we collect your data?** TCC collects your personal data in a variety of ways directly from you, or indirectly for the purposes of recruitment and employment. #### What information do we collect? TCC collects and processes a range of information about you. This may include: - Your name, address and contact details, including email address and telephone number, date of birth and gender; - The terms and conditions of your employment; - Details of your qualifications, skills, experience and employment history, including start and end dates (with previous employers and within TCC) and documents relating to gaps in employment; - Information about your remuneration, including entitlement to benefits such as pensions or insurance cover; - Information with respect to credit inconsistencies, for example county court judgements; - Information with respect to previously committed fraudulent acts; - Information with respect to sanction checks where applicable; - Information about any criminal record where applicable; - Information about your nationality and entitlement to work in the UK; - Details of your bank account and national insurance number; - Information about your marital status, next of kin, dependants and emergency contacts; - Details of your schedule (days of work and working hours) and attendance at work; - Details of periods of leave taken by you, including holiday, sickness absence, family leave and the reasons for the leave; - Details of any disciplinary or grievance procedures in which you have been involved, including any warnings issued to you and related correspondence; - Assessments of your performance, including: appraisals, performance reviews and ratings, training you have participated in, performance improvement plans and related correspondence; - Information about medical or health conditions, including whether or not you have a disability for which TCC needs to make reasonable adjustments; and - Information about why you left TCC, for example exit interview and resignation confirmation letter. - Photographs, filming and any other type of image for marketing purposes for example– hard copy brochures or for the website. Data is stored in your personnel file within the HR database and in other IT systems, including TCC email. #### Why and how does TCC process your personal data? Our basis for processing your personal data may rely upon our Legitimate Interest, Legal obligation, or Contractual obligation or consent. TCC needs to process your data to complete the recruitment process with the objective of entering into an employment contract. The data is collected on the basis of legitimate interest so that we can ascertain whether you are the most appropriate individual for the position. This will involve pre-vetting checks in accordance with TCC’s Recruitment Policy. Processing this data allows TCC to provide you with an offer of employment. TCC has a contractual requirement to process data to enter into an employment contract with you and to meet its obligations under this contract. For example, to pay you in accordance with your employment contract and to administer employee benefits, including your pension. In addition, TCC needs to process data to ensure it is complying with its legal obligations. For example, it is required to check an employee’s entitlement to work in the UK, to deduct tax, to comply with health and safety laws and to enable employees to take periods of leave to which they are entitled. In other cases, TCC has a legitimate interest in processing personal data in respect of employees before, during and after the end of the employment relationship. Processing employee data allows TCC to: - Maintain accurate and up-to-date employment records and contact details (including details of who to contact in the event of an emergency) including employee contractual and statutory rights; - Operate and keep a record of disciplinary and grievance processes, or a change in your criminal record, to ensure acceptable conduct within the workplace; - Operate and keep a record of employee performance and related processes, to plan for career development and for succession planning and workforce management purposes; - Run recruitment and client promotion processes; - Operate and keep a record of absence and absence management procedures, to allow effective workforce management and ensure that employees are receiving the pay or other benefits to which they are entitled; - Obtain occupational health advice, to ensure it complies with duties in relation to individuals with disabilities, meet its obligations under health and safety law and ensure employees are receiving the pay or other benefits to which they are entitled; - Operate and keep a record of other types of leave (including maternity, paternity, adoption, parental and shared parental leave) to allow effective workforce management, to ensure TCC complies with its duties in relation to leave entitlement and to ensure that employees are receiving the pay or other benefits to which they are entitled; - Ensure effective general HR and business administration; - Provide references on request for current or former employees; and - Respond to and defend against legal claims Where TCC relies on legitimate interest as a reason for processing data, it has considered whether or not those interests are overridden by the rights and freedoms of employees or workers and has concluded they are not. We will always gain your freely given, specific, unambiguous explicit and informed consent for any sharing of photographs or images on marketing materials (hard copies, soft copies or on the website) or for sharing your personal data with any third-party clients for the purposes of marketing or proposals. #### Your rights Whenever we process your personal data, we take reasonable steps to ensure your data is kept accurate and up-to date for the purposes for which it was collected. As a data subject, you have a number of rights. You can: - Access and obtain a copy of your data on request; - Require TCC to change incorrect or incomplete data; - Require TCC to delete or stop processing your data where the data is no longer necessary for the purposes of processing; - Object to the processing of your data where TCC is relying on its legitimate interests as the legal ground for processing; and - Withdraw consent on which the processing is based, and where there is no other legal ground for processing. - Ask TCC to stop processing data for a period if the data is inaccurate or there is a dispute about whether or not your interests override TCC’s legitimate grounds for processing data. Should you wish to obtain a copy (free of charge) of the personal data being processed, TCC is required to respond to your request within one month from receipt of the request. For added security, we may ask you to provide proof of your identity before releasing any data. All requests must be sent to the following address: TCC 6th Floor 10 Lower Thames Street London EC3R 6EN Email: [dpo@tcc.group](http://dpo@tcc.group) Telephone: 0203 772 7230 #### What if you do not provide personal data? You have some obligations under your employment contract to provide TCC with data. In particular, you are required to report absences from work and may be required to provide information about disciplinary or other matters under the implied duty of good faith. You may also have to provide TCC with data in order to exercise your statutory rights (statutory leave entitlements, for example). Failing to provide the data may mean you are unable to exercise your statutory rights. Certain information, such as contact details, your right to work in the UK, criminal record check, fraud check and payment details have to be provided to enable TCC to enter into a contract of employment with you. If you do not provide other information, this will hinder TCC’s ability to efficiently administer the rights and obligations arising as a result of the employment relationship. #### Who has access to your data? Where necessary, your information will be shared internally with Finance, your line manager, managers in the business area in which you work and IT staff, if access to the data is necessary for performance of their roles. The information shared is limited to that required for the purposes of the processing. TCC shares your data with third parties as part of the recruitment process and to obtain pre-employment references from other employers and providers, and to obtain necessary criminal records checks from the Disclosure and Barring Service. These are: ― Recruitment agencies. ― Disclosure and Barring Service check (Criminal Record check) and credit check. ― Fraud check. Cifas will use the data to prevent fraud, other unlawful or dishonest conduct, malpractice and other seriously improper conduct. If any of these are detected, you could be refused certain services or employment. Your personal information will also be used to verify your identity. Further details of how your information will be used by us and Cifas, and your data protection rights, can be found in the company’s Fraud Policy. TCC may use the following third-party providers to process your data on our behalf: - HR Information System and payroll processing - Benefit providers: Pension Provider, Death in Service benefits, Private Medical Insurance, Income Protection Scheme and Health Cash Plan. - Vetting check providers with respect to onboarding processing including fraud, right to work and credit check - CRM system providers, such as Salesforce - Backup systems provider - Purchasing, invoicing, timesheets and payroll processing providers - Accounting and banking providers - Email and file storage provider - Expenses: Hotel and travel bookings and expense management - Lawyers: Employment legal advice - Company clients: for fulfilling the contractual requirement including billing, workflow systems, systems, access and laptop builds where required. - Third party auditors: Company accountants or auditing for ISO certificates. - Third Party meeting room providers - Occupational health consultant(s), GPs and other medical experts: if your health needs to be managed in the context of a return to work or where we need to consider reasonable adjustments to your role. - The UK’s Fit for Work programme, in the event that you become unwell and your health needs to be managed in the context of a return to work. TCC may also share limited data about you on TCC’s website and with prospective clients for the purposes of tendering for new contracts and marketing. TCC will ensure that any third-party processor has adequate data protection measures in place that align with GDPR requirements by conducting periodic due diligence. TCC will not use any third-party processor outside of the UK, EU or USA. The data storage and processing systems are protected by access controls, to minimise any risk to the integrity or security of your personal data, and the data is stored in servers in the UK, EU and USA. TCC does not sell your personal data or other information to any third party. #### Retention period TCC will only keep your personal data for as long as necessary for the purposes for which it was collected. This varies depending on the nature of your relationship with TCC: - Prospective employees. TCC will hold your personal data for the purposes of the recruitment process, and where this does not result in employment your data will be held for up to 12 months for future employment in line with TCC’s Data Controls Policy. At the 12 month period your data will be deleted. - TCC will hold your personal data for six years after the end of your employment contract I line with the Data Control Policy unless a variation is required for legal reasons for example health and safety. If the personal data is no longer necessary, or where we no longer have the legal basis for processing, we will delete or fully anonymise the data we hold on you, in line with our Data Protection Policy. If during your employment we become aware your data has become inaccurate, we will update it accordingly. #### How do we protect your data? TCC takes the security of your data seriously. TCC has internal policies and controls in place to try to ensure your data is kept securely to protect against accidental or unlawful destruction, loss, alteration, disclosure or access and is not accessed except by its employees in the performance of their duties. - Anti-virus controls and firewalls; - Back up and Recovery Policy; - Cryptographic Policy; - Disposal of Media Policy; - Risk Management Framework; - Data Loss Prevention, Cloud App Security alert and enforcing policies. Where TCC engages third parties to process personal data on its behalf, they do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of the data. #### Automated decision making Employment and recruitment decisions may incorporate, but are not based solely on, automated decision making. #### If you wish to complain TCC will be more than happy to help you should you have any complaints about the processing of your personal data. If you have any queries about this privacy notice, or should you wish to make a complaint, please email [dpo@tcc.group](http://dpo@tcc.group). In addition, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO), which is the national authority responsible for the protection of personal data. A complaint can be made to the ICO via its website: [ico.org.uk](https://ico.org.uk/) or through its helpline: 0303 123 1113. ### Do you use TCC's website and/or receive email communications from TCC? If so, you should read our standard** [Privacy Statement](/privacy-statement-visitors-and-clients/),** which sets out how we will process your data in order to effectively communicate with you and enable you to use our website. ### Changes to this Privacy Notice We reserve the right to change this Privacy Notice. The up-to-date version will be on Sharepoint and TCC’s website. Previous versions will continue to be available on request, please email to hr@tcc.group. We recommend that you check this notice regularly so that you are informed of any changes. ## Related policies - Privacy and Policies — /privacy-statement/ - Privacy: Visitors and clients — /privacy-statement-visitors-and-clients/ - Privacy: Associates — /privacy-statement-tcc-associates/ - Privacy: Legal basis — /privacy-statement-legal-basis/ - Privacy: Third parties — /privacy-third-party-list/ - Cookies — /cookies/ ## Privacy / compliance contact Data protection dataprotection@tcc.group 020 3772 7230 ## Editorial byline TCC Group Editorial Team /meet-the-team/ ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/privacy-statement-tcc-employees/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Privacy Statement: TCC Employees", "item": "https://tcc.group/privacy-statement-tcc-employees/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/privacy-statement-tcc-employees/#webpage", "url": "https://tcc.group/privacy-statement-tcc-employees/", "name": "Privacy Statement: TCC Employees", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-09-03T17:39:27+01:00", "dateModified": "2026-09-03T17:53:25+01:00", "breadcrumb": { "@id": "https://tcc.group/privacy-statement-tcc-employees/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "Organization", "@id": "https://tcc.group/privacy-statement-tcc-employees/#editorial-team", "name": "TCC Group Editorial Team", "url": "https://tcc.group/meet-the-team/" }, { "@type": "DigitalDocument", "@id": "https://tcc.group/privacy-statement-tcc-employees/#policy", "name": "Privacy Statement: TCC Employees", "description": "", "text": "Introduction\n\nTCC is the controller of personal data for its employees, and prospective employees, for the purposes of managing the employment or prospective employment relationship. TCC is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.\n\nThis privacy statement explains what personal data TCC collects from you through our interactions with you, and sets out how we use that data. This statement also explains how TCC protects any personal data that we obtain directly or passively from you, or which we obtain indirectly from other sources. You can be assured that it will only be used in accordance with this privacy statement.\n\nData Controller:\nTCC & Recordsure\n10 Lower Thames Street\nLondon\nEC3R 6EN\nEmail: dpo@tcc.group Telephone: 020 3772 7230\n\nHow do we collect your data?\n\nTCC collects your personal data in a variety of ways directly from you, or indirectly for the purposes of recruitment and employment.\nWhat information do we collect?\n\nTCC collects and processes a range of information about you. This may include:\n\u2022 Your name, address and contact details, including email address and telephone number, date of birth and gender;\n\u2022 The terms and conditions of your employment;\n\u2022 Details of your qualifications, skills, experience and employment history, including start and end dates (with previous employers and within TCC) and documents relating to gaps in employment;\n\u2022 Information about your remuneration, including entitlement to benefits such as pensions or insurance cover;\n\u2022 Information with respect to credit inconsistencies, for example county court judgements;\n\u2022 Information with respect to previously committed fraudulent acts;\n\u2022 Information with respect to sanction checks where applicable;\n\u2022 Information about any criminal record where applicable;\n\u2022 Information about your nationality and entitlement to work in the UK;\n\u2022 Details of your bank account and national insurance number;\n\u2022 Information about your marital status, next of kin, dependants and emergency contacts;\n\u2022 Details of your schedule (days of work and working hours) and attendance at work;\n\u2022 Details of periods of leave taken by you, including holiday, sickness absence, family leave and the reasons for the leave;\n\u2022 Details of any disciplinary or grievance procedures in which you have been involved, including any warnings issued to you and related correspondence;\n\u2022 Assessments of your performance, including: appraisals, performance reviews and ratings, training you have participated in, performance improvement plans and related correspondence;\n\u2022 Information about medical or health conditions, including whether or not you have a disability for which TCC needs to make reasonable adjustments; and\n\u2022 Information about why you left TCC, for example exit interview and resignation confirmation letter.\n\u2022 Photographs, filming and any other type of image for marketing purposes for example\u2013 hard copy brochures or for the website.\n\nData is stored in your personnel file within the HR database and in other IT systems, including TCC email.\nWhy and how does TCC process your personal data?\n\nOur basis for processing your personal data may rely upon our Legitimate Interest, Legal obligation, or Contractual obligation or consent.\n\nTCC needs to process your data to complete the recruitment process with the objective of entering into an employment contract. The data is collected on the basis of legitimate interest so that we can ascertain whether you are the most appropriate individual for the position. This will involve pre-vetting checks in accordance with TCC\u2019s Recruitment Policy. Processing this data allows TCC to provide you with an offer of employment.\n\nTCC has a contractual requirement to process data to enter into an employment contract with you and to meet its obligations under this contract. For example, to pay you in accordance with your employment contract and to administer employee benefits, including your pension.\n\nIn addition, TCC needs to process data to ensure it is complying with its legal obligations. For example, it is required to check an employee\u2019s entitlement to work in the UK, to deduct tax, to comply with health and safety laws and to enable employees to take periods of leave to which they are entitled.\n\nIn other cases, TCC has a legitimate interest in processing personal data in respect of employees before, during and after the end of the employment relationship. Processing employee data allows TCC to:\n\u2022 Maintain accurate and up-to-date employment records and contact details (including details of who to contact in the event of an emergency) including employee contractual and statutory rights;\n\u2022 Operate and keep a record of disciplinary and grievance processes, or a change in your criminal record, to ensure acceptable conduct within the workplace;\n\u2022 Operate and keep a record of employee performance and related processes, to plan for career development and for succession planning and workforce management purposes;\n\u2022 Run recruitment and client promotion processes;\n\u2022 Operate and keep a record of absence and absence management procedures, to allow effective workforce management and ensure that employees are receiving the pay or other benefits to which they are entitled;\n\u2022 Obtain occupational health advice, to ensure it complies with duties in relation to individuals with disabilities, meet its obligations under health and safety law and ensure employees are receiving the pay or other benefits to which they are entitled;\n\u2022 Operate and keep a record of other types of leave (including maternity, paternity, adoption, parental and shared parental leave) to allow effective workforce management, to ensure TCC complies with its duties in relation to leave entitlement and to ensure that employees are receiving the pay or other benefits to which they are entitled;\n\u2022 Ensure effective general HR and business administration;\n\u2022 Provide references on request for current or former employees; and\n\u2022 Respond to and defend against legal claims\n\nWhere TCC relies on legitimate interest as a reason for processing data, it has considered whether or not those interests are overridden by the rights and freedoms of employees or workers and has concluded they are not.\n\nWe will always gain your freely given, specific, unambiguous explicit and informed consent for any sharing of photographs or images on marketing materials (hard copies, soft copies or on the website) or for sharing your personal data with any third-party clients for the purposes of marketing or proposals.\nYour rights\n\nWhenever we process your personal data, we take reasonable steps to ensure your data is kept accurate and up-to date for the purposes for which it was collected. As a data subject, you have a number of rights. You can:\n\u2022 Access and obtain a copy of your data on request;\n\u2022 Require TCC to change incorrect or incomplete data;\n\u2022 Require TCC to delete or stop processing your data where the data is no longer necessary for the purposes of processing;\n\u2022 Object to the processing of your data where TCC is relying on its legitimate interests as the legal ground for processing; and\n\u2022 Withdraw consent on which the processing is based, and where there is no other legal ground for processing.\n\u2022 Ask TCC to stop processing data for a period if the data is inaccurate or there is a dispute about whether or not your interests override TCC\u2019s legitimate grounds for processing data.\n\nShould you wish to obtain a copy (free of charge) of the personal data being processed, TCC is required to respond to your request within one month from receipt of the request. For added security, we may ask you to provide proof of your identity before releasing any data. All requests must be sent to the following address:\n\nTCC\n6th\u00a0Floor\n\n10 Lower Thames Street\nLondon\nEC3R 6EN\nEmail:\u00a0dpo@tcc.group\nTelephone: 0203 772 7230\nWhat if you do not provide personal data?\n\nYou have some obligations under your employment contract to provide TCC with data. In particular, you are required to report absences from work and may be required to provide information about disciplinary or other matters under the implied duty of good faith. You may also have to provide TCC with data in order to exercise your statutory rights (statutory leave entitlements, for example). Failing to provide the data may mean you are unable to exercise your statutory rights.\n\nCertain information, such as contact details, your right to work in the UK, criminal record check, fraud check and payment details have to be provided to enable TCC to enter into a contract of employment with you. If you do not provide other information, this will hinder TCC\u2019s ability to efficiently administer the rights and obligations arising as a result of the employment relationship.\nWho has access to your data?\n\nWhere necessary, your information will be shared internally with Finance, your line manager, managers in the business area in which you work and IT staff, if access to the data is necessary for performance of their roles. The information shared is limited to that required for the purposes of the processing.\n\nTCC shares your data with third parties as part of the recruitment process and to obtain pre-employment references from other employers and providers, and to obtain necessary criminal records checks from the Disclosure and Barring Service.\n\nThese are:\n\n\u2015 Recruitment agencies.\n\n\u2015 Disclosure and Barring Service check (Criminal Record check) and credit check.\n\n\u2015 Fraud check. Cifas will use the data to prevent fraud, other unlawful or dishonest conduct, malpractice and other seriously improper conduct. If any of these are detected, you could be refused certain services or employment. Your personal information will also be used to verify your identity. Further details of how your information will be used by us and Cifas, and your data protection rights, can be found in the company\u2019s Fraud Policy.\n\nTCC may use the following third-party providers to process your data on our behalf:\n\u2022 HR Information System and payroll processing\n\u2022 Benefit providers: Pension Provider, Death in Service benefits, Private Medical Insurance, Income Protection Scheme and Health Cash Plan.\n\u2022 Vetting check providers with respect to onboarding processing including fraud, right to work and credit check\n\u2022 CRM system providers, such as Salesforce\n\u2022 Backup systems provider\n\u2022 Purchasing, invoicing, timesheets and payroll processing\u00a0providers\n\u2022 Accounting and banking\u00a0providers\n\u2022 Email and file storage provider\n\u2022 Expenses: Hotel and travel bookings and expense management\n\u2022 Lawyers: Employment legal advice\n\u2022 Company clients: for fulfilling the contractual requirement including billing, workflow systems, systems, access and laptop builds where required.\n\u2022 Third party auditors: Company accountants or auditing for ISO certificates.\n\u2022 Third Party meeting room providers\n\u2022 Occupational health consultant(s), GPs and other medical experts: if your health needs to be managed in the context of a return to work or where we need to consider reasonable adjustments to your role.\n\u2022 The UK\u2019s Fit for Work programme, in the event that you become unwell and your health needs to be managed in the context of a return to work.\n\nTCC may also share limited data about you on TCC\u2019s website and with prospective clients for the purposes of tendering for new contracts and marketing.\n\nTCC will ensure that any third-party processor has adequate data protection measures in place that align with GDPR requirements by conducting periodic due diligence.\n\nTCC will not use any third-party processor outside of the UK, EU or USA. The data storage and processing systems are protected by access controls, to minimise any risk to the integrity or security of your personal data, and the data is stored in servers in the UK, EU and USA.\n\nTCC does not sell your personal data or other information to any third party.\nRetention period\n\nTCC will only keep your personal data for as long as necessary for the purposes for which it was collected. This varies depending on the nature of your relationship with TCC:\n\u2022 Prospective employees. TCC will hold your personal data for the purposes of the recruitment process, and where this does not result in employment your data will be held for up to 12 months for future employment in line with TCC\u2019s Data Controls Policy. At the 12 month period your data will be deleted.\n\u2022 TCC will hold your personal data for six years after the end of your employment contract I line with the Data Control Policy unless a variation is required for legal reasons for example health and safety.\n\nIf the personal data is no longer necessary, or where we no longer have the legal basis for processing, we will delete or fully anonymise the data we hold on you, in line with our Data Protection Policy. If during your employment we become aware your data has become inaccurate, we will update it accordingly.\nHow do we protect your data?\n\nTCC takes the security of your data seriously. TCC has internal policies and controls in place to try to ensure your data is kept securely to protect against accidental or unlawful destruction, loss, alteration, disclosure or access and is not accessed except by its employees in the performance of their duties.\n\u2022 Anti-virus controls and firewalls;\n\u2022 Back up and Recovery Policy;\n\u2022 Cryptographic Policy;\n\u2022 Disposal of Media Policy;\n\u2022 Risk Management Framework;\n\u2022 Data Loss Prevention, Cloud App Security alert and enforcing policies.\n\nWhere TCC engages third parties to process personal data on its behalf, they do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of the data.\nAutomated decision making\n\nEmployment and recruitment decisions may incorporate, but are not based solely on, automated decision making.\nIf you wish to complain\n\nTCC will be more than happy to help you should you have any complaints about the processing of your personal data. If you have any queries about this privacy notice, or should you wish to make a complaint, please email\u00a0dpo@tcc.group. In addition, you have the right to lodge a complaint with the Information Commissioner\u2019s Office (ICO), which is the national authority responsible for the protection of personal data. A complaint can be made to the ICO via its website:\u00a0ico.org.uk\u00a0or through its helpline: 0303 123 1113.\nDo you use TCC's website and/or receive email communications from TCC?\n\nIf so, you should read our standard\u00a0Privacy Statement,\u00a0which sets out how we will process your data in order to effectively communicate with you and enable you to use our website.\nChanges to this Privacy Notice\n\nWe reserve the right to change this Privacy Notice. The up-to-date version will be on Sharepoint and TCC\u2019s website. Previous versions will continue to be available on request, please email to hr@tcc.group. 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We may use this data to enrich the data we hold on you from directly acquired sources to build a profile on you. [Find out more](/privacy-statement-visitors-and-clients/) about how we use data for profiling. The publicly available sources we may obtain personal data from you include: - LinkedIn - Your company websites - The FCA register - The media Your colleagues, associates and acquaintances may pass on your personal data to TCC’s employees by way of referral because they think TCC and/or Recordsure’s services may be relevant to you. TCC will process this data to make contact with you. We may process a range of personal work-related data from these sources such as: - Names - Job title - Company - Qualifications - Email address - Phone Number - Significant function - Company Address - Indications of your challenges and interests from your social media posts, likes, comments and shares - Indications of your challenges, interests and opinions from media articles We protect the data obtained from third parties according to the practices described [in this statement](/privacy-statement-visitors-and-clients/). **Third Party Processors** Our carefully selected partners and service providers may process personal information about you on our behalf as described below: **Digital Marketing Service Providers** We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information. Our appointed data processors include: (i) Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact Sopro and view their privacy policy here: [http://sopro.io](http://sopro.io/). Sopro are registered with the ICO Reg: ZA346877 their Data Protection Officer can be emailed at: [dpo@sopro.io](mailto:dpo@sopro.io). ## Related policies - Privacy and Policies — /privacy-statement/ - Privacy: Visitors and clients — /privacy-statement-visitors-and-clients/ - Privacy: Employees — /privacy-statement-tcc-employees/ - Privacy: Associates — /privacy-statement-tcc-associates/ - Privacy: Legal basis — /privacy-statement-legal-basis/ - Cookies — /cookies/ ## Privacy / compliance contact Data protection dataprotection@tcc.group 020 3772 7230 ## Editorial byline TCC Group Editorial Team /meet-the-team/ ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/privacy-third-party-list/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Privacy Statement: 3rd Party List", "item": "https://tcc.group/privacy-third-party-list/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/privacy-third-party-list/#webpage", "url": "https://tcc.group/privacy-third-party-list/", "name": "Privacy Statement: 3rd Party List", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-09-03T17:27:23+01:00", "dateModified": "2026-09-03T18:06:44+01:00", "breadcrumb": { "@id": "https://tcc.group/privacy-third-party-list/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "Organization", "@id": "https://tcc.group/privacy-third-party-list/#editorial-team", "name": "TCC Group Editorial Team", "url": "https://tcc.group/meet-the-team/" }, { "@type": "DigitalDocument", "@id": "https://tcc.group/privacy-third-party-list/#policy", "name": "Privacy Statement: Indirect Data Sources \u2013 3rd Party List", "description": "", "text": "TCC may obtain personal data indirectly about you from publicly available sources and via referrals from third party individuals and companies. We may use this data to enrich the data we hold on you from directly acquired sources to build a profile on you.\u00a0Find out more\u00a0about how we use data for profiling.\n\nThe publicly available sources we may obtain personal data from you include:\n\u2022 LinkedIn\n\u2022 Your company websites\n\u2022 The FCA register\n\u2022 The media\n\nYour colleagues, associates and acquaintances may pass on your personal data to TCC\u2019s employees by way of referral because they think TCC and/or Recordsure\u2019s services may be relevant to you. TCC will process this data to make contact with you.\n\nWe may process a range of personal work-related data from these sources such as:\n\u2022 Names\n\u2022 Job title\n\u2022 Company\n\u2022 Qualifications\n\u2022 Email address\n\u2022 Phone Number\n\u2022 Significant function\n\u2022 Company Address\n\u2022 Indications of your challenges and interests from your social media posts, likes, comments and shares\n\u2022 Indications of your challenges, interests and opinions from media articles\n\nWe protect the data obtained from third parties according to the practices described\u00a0in this statement.\n\nThird Party Processors\n\nOur carefully selected partners and service providers may process personal information about you on our behalf as described below:\n\nDigital Marketing Service Providers\n\nWe periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information. Our appointed data processors include:\n\n(i) Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact Sopro and view their privacy policy here:\u00a0http://sopro.io. Sopro are registered with the ICO Reg: ZA346877 their Data Protection Officer can be emailed at:\u00a0dpo@sopro.io.", "url": "https://tcc.group/privacy-third-party-list/", "publisher": { "@id": "https://tcc.group/#organization" }, "reviewedBy": { "@id": "https://tcc.group/privacy-third-party-list/#editorial-team" }, "additionalProperty": [ { "@type": "PropertyValue", "name": "owner", "value": "TCC Group" } ] }, { "@type": "ItemList", "@id": "https://tcc.group/privacy-third-party-list/#related-policies", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Privacy and Policies", "url": "https://tcc.group/privacy-statement/" }, { "@type": "ListItem", "position": 2, "name": "Privacy: Visitors and clients", "url": "https://tcc.group/privacy-statement-visitors-and-clients/" }, { "@type": "ListItem", "position": 3, "name": "Privacy: Employees", "url": "https://tcc.group/privacy-statement-tcc-employees/" }, { "@type": "ListItem", "position": 4, "name": "Privacy: Associates", "url": "https://tcc.group/privacy-statement-tcc-associates/" }, { "@type": "ListItem", "position": 5, "name": "Privacy: Legal basis", "url": "https://tcc.group/privacy-statement-legal-basis/" }, { "@type": "ListItem", "position": 6, "name": "Cookies", "url": "https://tcc.group/cookies/" } ] }, { "@type": "ContactPoint", "@id": "https://tcc.group/privacy-third-party-list/#contact-point", "contactType": "Data protection", "email": "dataprotection@tcc.group", "telephone": "020 3772 7230" } ] } ``` ### Modern Slavery Statement - URL: https://tcc.group/modern-slavery/ - Published: 2026-09-01 - Modified: 2026-09-04 ## Policy title and summary Modern Slavery Statement This policy commits TCC Group to uphold the principles of the **Modern Slavery Act 2015** and prevent both modern slavery and child labour in all operations and supply chains. We share our processes for recruitment checks, reporting suspicions, training, supplier due diligence, monitoring, and compliance. Our policy is embedded within the company’s management systems and is reviewed annually and audited under ISO standards. [ View TCC Group's Modern day slavery and child labour company statement here](https://25194947.fs1.hubspotusercontent-eu1.net/hubfs/25194947/TCC%20Recordsure%20Modern%20Day%20Slavery%20Policy%202025.pdf) ## Key facts panel TCC Group ## Related policies - Privacy and Policies — /privacy-statement/ - Privacy: Visitors and clients — /privacy-statement-visitors-and-clients/ - Privacy: Employees — /privacy-statement-tcc-employees/ - Privacy: Associates — /privacy-statement-tcc-associates/ - Privacy: Legal basis — /privacy-statement-legal-basis/ - Privacy: Third parties — /privacy-third-party-list/ ## Privacy / compliance contact Data protection / GDPR dpo@tcc.group 020 3772 7230 ## Editorial byline TCC Group Editorial Team /meet-the-team/ ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/modern-slavery/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Modern Slavery Statement", "item": "https://tcc.group/modern-slavery/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/modern-slavery/#webpage", "url": "https://tcc.group/modern-slavery/", "name": "Modern Slavery Statement", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-09-01T17:10:19+01:00", "dateModified": "2026-09-04T10:29:12+01:00", "breadcrumb": { "@id": "https://tcc.group/modern-slavery/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "Organization", "@id": "https://tcc.group/modern-slavery/#editorial-team", "name": "TCC Group Editorial Team", "url": "https://tcc.group/meet-the-team/" }, { "@type": "DigitalDocument", "@id": "https://tcc.group/modern-slavery/#policy", "name": "Modern Slavery Statement", "description": "This policy commits TCC Group to uphold the principles of the Modern Slavery Act 2015\u00a0and prevent both modern slavery and child labour in all operations and supply chains. 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Analytics and advertising storage start in a denied state on every visit and are only enabled once you consent, using Google Consent Mode v2. If your browser sends a recognised privacy signal, advertising consent stays off regardless of any banner interaction. ## Cookie categories We group cookies into four categories. Only the first is always on. Category Default What it is for Necessary Always active Required for the website to function, including security, load balancing and remembering your cookie choices. These cannot be switched off. Functional Off until you allow it Remembers your preferences and enables enhanced website features. Analytics Off until you allow it Helps us understand how visitors interact with our website so we can improve it. Advertising Off until you allow it Enables personalised advertising based on your browsing behaviour. ## Cookies we may set Third-party cookies are only set once you have allowed the relevant category. Retention periods are set by the provider and may change. Cookie Provider Category Purpose Typical retention tcc-consent tcc.group Necessary Stores your cookie choices and the version of this policy you saw, so we do not ask again on every page. 12 months _ga, _ga_* Google Analytics Analytics Distinguishes visitors and measures how the site is used. Up to 24 months _gid Google Analytics Analytics Distinguishes visitors for short-term usage reporting. 24 hours _gcl_* Google Ads Advertising Measures whether an advert led to a useful visit. Up to 90 days IDE, test_cookie DoubleClick / Google Ads Advertising Used to show and measure adverts across other websites. Up to 13 months li_sugr, UserMatchHistory, bcookie LinkedIn Advertising Supports LinkedIn advertising and conversion measurement. Up to 6 months __hs*, hubspotutk HubSpot Analytics Recognises returning visitors and links enquiry form submissions. Up to 13 months wordpress_*, wp-settings-* tcc.group Necessary Set only for signed-in site administrators to keep them authenticated. Session to 12 months ## Changing your choices You can review or change your choices at any time on the [cookie settings](/cookie-settings/) page. Withdrawing consent is as easy as giving it, and takes effect immediately for any further storage. Cookies already stored by a provider can also be cleared through your browser settings. ## How long your choice is remembered Your choices are stored in a cookie named `tcc-consent`, which is scoped to this site, marked Secure and set with SameSite=Lax. It records the categories you allowed and the policy version you were shown. If we materially change this policy, we will ask you again. ## Questions If you have a question about how we use cookies or wish to exercise your data protection rights, please [contact us](/contact/). ## Cookie preference panel 1 Your cookie preferences ## Related policies - Privacy and Policies — /privacy-statement/ - Privacy: Visitors and clients — /privacy-statement-visitors-and-clients/ - Privacy: Employees — /privacy-statement-tcc-employees/ - Privacy: Associates — /privacy-statement-tcc-associates/ - Privacy: Legal basis — /privacy-statement-legal-basis/ - Privacy: Third parties — /privacy-third-party-list/ ## Privacy / compliance contact Data protection dataprotection@tcc.group 020 3772 7230 ## Editorial byline TCC Group Editorial Team /meet-the-team/ ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/cookies/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Cookies", "item": "https://tcc.group/cookies/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/cookies/#webpage", "url": "https://tcc.group/cookies/", "name": "Cookies", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-09-01T17:10:19+01:00", "dateModified": "2026-09-03T17:50:57+01:00", "breadcrumb": { "@id": "https://tcc.group/cookies/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "Organization", "@id": "https://tcc.group/cookies/#editorial-team", "name": "TCC Group Editorial Team", "url": "https://tcc.group/meet-the-team/" }, { "@type": "DigitalDocument", "@id": "https://tcc.group/cookies/#policy", "name": "Cookies", "description": "This page explains how tcc.group uses cookies and similar technologies, what each category is for, and how you can change your choices at any time.", "text": "Our default is off\n\nExcept for cookies that are strictly necessary, nothing is set until you choose to allow it. Analytics and advertising storage start in a denied state on every visit and are only enabled once you consent, using Google Consent Mode v2. If your browser sends a recognised privacy signal, advertising consent stays off regardless of any banner interaction.\n\nCookie categories\n\nWe group cookies into four categories. Only the first is always on.\n\nCategory\nDefault\nWhat it is for\n\nNecessary\nAlways active\nRequired for the website to function, including security, load balancing and remembering your cookie choices. These cannot be switched off.\n\nFunctional\nOff until you allow it\nRemembers your preferences and enables enhanced website features.\n\nAnalytics\nOff until you allow it\nHelps us understand how visitors interact with our website so we can improve it.\n\nAdvertising\nOff until you allow it\nEnables personalised advertising based on your browsing behaviour.\n\nCookies we may set\n\nThird-party cookies are only set once you have allowed the relevant category. Retention periods are set by the provider and may change.\n\nCookie\nProvider\nCategory\nPurpose\nTypical retention\n\ntcc-consent\ntcc.group\nNecessary\nStores your cookie choices and the version of this policy you saw, so we do not ask again on every page.\n12 months\n\n_ga, _ga_\nGoogle Analytics\nAnalytics\nDistinguishes visitors and measures how the site is used.\nUp to 24 months\n\n_gid\nGoogle Analytics\nAnalytics\nDistinguishes visitors for short-term usage reporting.\n24 hours\n\n_gcl_\nGoogle Ads\nAdvertising\nMeasures whether an advert led to a useful visit.\nUp to 90 days\n\nIDE, test_cookie\nDoubleClick / Google Ads\nAdvertising\nUsed to show and measure adverts across other websites.\nUp to 13 months\n\nli_sugr, UserMatchHistory, bcookie\nLinkedIn\nAdvertising\nSupports LinkedIn advertising and conversion measurement.\nUp to 6 months\n\n__hs, hubspotutk\nHubSpot\nAnalytics\nRecognises returning visitors and links enquiry form submissions.\nUp to 13 months\n\nwordpress_, wp-settings-\ntcc.group\nNecessary\nSet only for signed-in site administrators to keep them authenticated.\nSession to 12 months\n\nChanging your choices\n\nYou can review or change your choices at any time on the cookie settings page. Withdrawing consent is as easy as giving it, and takes effect immediately for any further storage. Cookies already stored by a provider can also be cleared through your browser settings.\n\nHow long your choice is remembered\n\nYour choices are stored in a cookie named tcc-consent, which is scoped to this site, marked Secure and set with SameSite=Lax. It records the categories you allowed and the policy version you were shown. If we materially change this policy, we will ask you again.\n\nQuestions\n\nIf you have a question about how we use cookies or wish to exercise your data protection rights, please contact us.", "url": "https://tcc.group/cookies/", "publisher": { "@id": "https://tcc.group/#organization" }, "reviewedBy": { "@id": "https://tcc.group/cookies/#editorial-team" }, "additionalProperty": [ { "@type": "PropertyValue", "name": "owner", "value": "TCC Group" } ] }, { "@type": "ItemList", "@id": "https://tcc.group/cookies/#related-policies", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Privacy and Policies", "url": "https://tcc.group/privacy-statement/" }, { "@type": "ListItem", "position": 2, "name": "Privacy: Visitors and clients", "url": "https://tcc.group/privacy-statement-visitors-and-clients/" }, { "@type": "ListItem", "position": 3, "name": "Privacy: Employees", "url": "https://tcc.group/privacy-statement-tcc-employees/" }, { "@type": "ListItem", "position": 4, "name": "Privacy: Associates", "url": "https://tcc.group/privacy-statement-tcc-associates/" }, { "@type": "ListItem", "position": 5, "name": "Privacy: Legal basis", "url": "https://tcc.group/privacy-statement-legal-basis/" }, { "@type": "ListItem", "position": 6, "name": "Privacy: Third parties", "url": "https://tcc.group/privacy-third-party-list/" } ] }, { "@type": "ContactPoint", "@id": "https://tcc.group/cookies/#contact-point", "contactType": "Data protection", "email": "dataprotection@tcc.group", "telephone": "020 3772 7230" } ] } ``` ### Talk to Us - URL: https://tcc.group/talk-to-us/ - Published: 2026-09-01 - Modified: 2026-09-04 ## Hero (H1 and answer-first summary) Contact TCC Group Speak to the right expert, directly Our specialists answer you themselves. There is no call centre and no triage queue. Tell us what you are working on and we will put you in front of the practitioner best placed to help. ## Credibility metrics - Typical response time — Under 4 hours - FCA market experience — 30+ years - Active client firms — 100+ ## What to expect What to expect - Send your enquiry — Use the form on this page and tell us what you are working on. It takes about a minute. - A senior specialist reads it — A senior TCC specialist reviews your message personally and replies within four business hours. - We arrange a call if it helps — Where it is useful we set up a short introductory call at a time that suits you. There is no commitment. - You get a tailored response — We scope a response around your situation across advisory, managed delivery, resourcing and technology. Never a generic proposal. ## Direct contact details, address and hours Direct contact hello@tcc.group +44 20 3772 7230 Enquiries 10 Lower Thames Street London EC3R 6EN GB - Monday to Friday — 08:30 — 18:00 ## What sets TCC apart What sets TCC apart - Senior-led — Every engagement is led by experienced practitioners and industry experts, not account managers or junior analysts. - FCA methodology — We make it our business to know the FCA methodology and frameworks, so we deliver outcomes that matter. - Rapid mobilisation — We scope and mobilise within days of instruction, which matters when a regulatory timeline is already running. - Certified and trusted — ISO 27001 certified, EcoVadis rated and FSQS registered, with more than 25 years of experience behind our governance. ## TCC Group companies Three specialists, one trusted group ## Common questions (FAQ) Common questions - How quickly will someone respond to my enquiry? — A senior specialist reviews your message and replies personally, normally within four business hours. Our office hours are Monday to Friday, 8:30am to 6:00pm UK time, so an enquiry sent outside those hours is answered the next working morning. - Who will handle my enquiry? — An experienced practitioner, not an account manager or a junior analyst. We read what you have sent, then route it to the specialist best placed to help, whether that sits in advisory, managed services, specialist resourcing or compliance technology. - Is there any commitment involved in getting in touch? — None. An enquiry is a conversation, not an engagement. Where it is useful we arrange a short introductory call, and we scope any response around your situation before there is anything to agree to. - Can I request an introductory call at a specific time? — Yes. Tell us when suits you in your message and we will work to that. If the time you have asked for is not possible we will offer the closest alternative rather than sending a scheduling link and leaving it there. - What happens to the information I send? — We process it to respond to your enquiry and for related direct marketing, on the basis of our legitimate interests. We share it only with our sister company Recordsure, with whom we share resources, and never with unrelated third parties. You can object to this processing or opt out of marketing at any time. 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Combining advisory expertise, delivery capability and specialist resource, we support clients through transformation, remediation and long-term improvement programmes.  ## What makes TCC different What makes TCC different - Specialist expertise — Deep regulatory expertise and access to specialist resource  - Practical delivery — Practical implementation support and Flexible delivery models  - Measurable outcomes — Technology-enabled assurance and Support across the compliance lifecycle  ## Trust statement Built on trust We've worked alongside regulated firms to help manage risk, navigate change and deliver better customer outcomes. Our approach is built on independence, accountability, collaboration and measurable results.  ## Industries we support Industries we support ## Proof strip - 25+ — years of FCA expertise - 4,000+ — regulatory engagements - 40,000+ — specialist associates - 5m+ — compliance delivery days ## Responsible business Delivering positive outcomes beyond regulation As a business operating in a highly regulated environment, we recognise our responsibility to clients, colleagues, communities and the wider environment.  ## Environmental responsibility and carbon reduction Environmental responsibility We recognise that addressing climate change requires sustained action from businesses of all sizes. TCC Group is a signatory of the **UK Business Climate Leaders** campaign and a member of the **SME Climate Hub**, supporting collective action towards a lower-carbon economy and more sustainable business practices.  Our approach focuses on understanding and reducing our environmental impact, promoting responsible resource use and continually improving environmental performance across our operations View our Environmental Policy https://25194947.fs1.hubspotusercontent-eu1.net/hubfs/25194947/EnvironmentalPolicy.pdf Carbon reduction commitment Our Carbon Reduction Plan outlines the practical steps we are taking to measure, manage and reduce emissions across our operations and supply chain, supporting our commitment to work towards net zero by 2030.  View our Carbon Reduction Plan https://25194947.fs1.hubspotusercontent-eu1.net/hubfs/25194947/CarbonReductionPlan2026.pdf ## Governance, standards and accreditations Governance, standards and accreditations Trust is fundamental to our business.  We maintain robust policies, controls and assurance processes designed to support high standards of conduct, information security and operational effectiveness.  Our certifications, accreditations and internal practices help demonstrate our commitment to quality, accountability and continual improvement. Certified standards and accreditations Our certifications and independent assessments help demonstrate our commitment to quality, information security, sustainability and responsible business practices.  - ISO/IEC 27001:2022 — Our Information Security Management System is certified to ISO/IEC 27001:2022, providing an independently verified framework for managing and protecting information assets and helping ensure the confidentiality, integrity and availability of data. - FSQS Registered — TCC is registered with the Financial Services Qualification System (FSQS), demonstrating compliance with the standards and requirements expected by participating financial services organisations.  - EcoVadis Bronze — TCC has been awarded a Bronze EcoVadis rating in recognition of our approach to environmental, social and governance (ESG) performance, including sustainable procurement, labour and human rights, ethics and environmental management.  - ISO 14001:2015 — Our ISO 14001 certification reflects our commitment to environmental management and continual improvement, helping us manage environmental impacts across our operations and supply chain Modern slavery and human rights We are committed to operating responsibly and ethically across our business and supply chain.  Our Modern Slavery and Child Labour Statement outlines the measures we take to uphold the principles of the Modern Slavery Act 2015 and help prevent modern slavery, forced labour and child labour in our operations and supplier relationships. This includes recruitment and right-to-work checks, colleague training, supplier due diligence, reporting procedures and ongoing monitoring activities.  These commitments form part of our wider governance framework and are embedded within our management systems, which are subject to regular review and audit.  View our Modern Slavery and Child Labour Statement /modern-slavery/ ## Community, social impact, inclusion and diversity Community and social impact We support charitable initiatives, fundraising activities and community programmes that create meaningful and lasting impact.  We encourage colleagues to contribute their skills, experience and time to initiatives that support the communities in which we operate.  Creating an environment where everyone can thrive We are committed to building an inclusive workplace where talented people can develop, contribute and succeed regardless of background.  Diversity of thought, experience and perspective strengthens decision-making, improves collaboration and helps us deliver better outcomes for clients.  We aim to foster a culture where people feel respected, supported and able to perform at their best.  ## Part of TCC Group Part of a broader ecosystem TCC is part of TCC Group, a specialist compliance group comprising three complementary businesses. ## Common questions (FAQ) - What does TCC do? — TCC provides regulatory advisory, managed services and specialist support for FCA-regulated firms. - Which sectors does TCC support?  — We support organisations across wealth management, pensions, banking, lending, insurance, payments and other regulated sectors.  - Does TCC provide delivery support as well as advisory services?  — Yes. Alongside advisory services, we provide managed services, specialist resource and delivery support for complex regulatory programmes.  - What regulatory areas does TCC support? — Our expertise spans Consumer Duty, financial crime, operational resilience, governance, conduct risk, remediation, regulatory change and transformation.  - How does TCC work with Momenta and Recordsure?  — As part of TCC Group, we can combine advisory expertise, specialist resource capability and technology-enabled assurance where required.  - Where can I find TCC's environmental and sustainability commitments?  — Our environmental policies and carbon reduction commitments are available through our responsible business documentation.  ## Get help CTA Need support with a regulatory or transformation challenge? 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Three specialist businesses — advisory expertise, compliance delivery at scale, and AI-powered assurance technology — working as one compliance group for FCA-regulated firms. Get in touch /talk-to-us/ See our work /case-studies/ ## Group proof statistics - 30+ — years of FCA expertise - 4,000+ — regulatory engagements - 40,000+ — specialist associates - 5m+ — compliance delivery days ## Group proposition Why the group is structured this way TCC Group brings together three businesses that a regulated firm would otherwise have to buy separately: regulatory advisory, compliance delivery capacity, and assurance technology. Each is a specialist in its own right and can be appointed independently. Together they cover the full compliance lifecycle — designing the methodology, staffing and running the work, and evidencing the outcome to the standard the FCA expects — without the handover risk that comes from stitching separate suppliers together. ## Business entities Three specialist businesses. One compliance framework. Engagements are led by whichever business sits closest to the problem, with the others providing complementary capability under one agreed framework. ## Service capabilities Four ways TCC Group delivers compliance outcomes Every engagement draws on one or more of these four capability areas, often in combination across TCC, Momenta and Recordsure. - Advisory — Expert regulatory advice from senior FCA-experienced practitioners, helping firms assess, challenge and strengthen compliance frameworks. — /advisory/ - Managed Services — End-to-end outsourced compliance delivery, from file review programmes to Consumer Duty MI and financial crime managed functions. — /managed-services/ - Specialist Resourcing — Experienced compliance professionals deployed at pace: interim officers, s166 teams, remediation specialists and regulatory change managers. — /specialist-resourcing/ - Tech-Enabled Compliance — AI-powered monitoring and assurance turning regulatory oversight into measurable, auditable evidence. — /tech-enabled-compliance/ ## Sectors served We work across ## Get help CTA Have a compliance challenge for TCC Group? Tell us about your regulatory programme. We will identify which TCC Group business is best placed to help, and come back with a proposal within 24 hours. Get in touch /talk-to-us/ View case studies /case-studies/ ## Common questions (FAQ) Questions about TCC Group - What is TCC Group? — TCC Group is the parent organisation of three specialist compliance businesses: TCC (advisory and managed services), Momenta (specialist resourcing) and Recordsure (AI-powered compliance technology). Together they cover the full compliance lifecycle for FCA-regulated firms. - What is the difference between TCC, Momenta and Recordsure? — TCC provides regulatory advisory and managed compliance services. Momenta deploys specialist compliance professionals and delivery teams at pace. Recordsure provides AI-powered call monitoring, outcome testing and compliance assurance technology. All three businesses can be engaged independently or in combination. - Which sectors does TCC Group serve? — TCC Group serves FCA-regulated sectors including wealth management, financial advice, retail banking, consumer lending, insurance and fintech. The group has over 30 years of experience across Consumer Duty, financial crime, remediation and regulatory transformation. - How do the three TCC Group businesses work together? — Clients typically engage one business as a lead, with the others providing complementary capability. For example, TCC provides the advisory methodology, Momenta deploys the delivery team, and Recordsure technology provides the assurance evidence, all operating to a single agreed FCA framework. ## Freshness and last reviewed 2026-09-02 Latest insights ## Editorial byline TCC Group Editorial Team ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/tcc-group/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "TCC Group", "item": "https://tcc.group/tcc-group/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/tcc-group/#webpage", "url": "https://tcc.group/tcc-group/", "name": "TCC Group", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-09-01T17:10:18+01:00", "dateModified": "2026-09-02T00:00:00+00:00", "breadcrumb": { "@id": "https://tcc.group/tcc-group/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] }, "mainEntity": { "@id": "https://tcc.group/tcc-group/#tcc-group" }, "lastReviewed": "2026-09-02" }, { "@type": "FAQPage", "@id": "https://tcc.group/tcc-group/#faq", "url": "https://tcc.group/tcc-group/", "mainEntity": [ { "@type": "Question", "name": "What is TCC Group?", "acceptedAnswer": { "@type": "Answer", "text": "TCC Group is the parent organisation of three specialist compliance businesses: TCC (advisory and managed services), Momenta (specialist resourcing) and Recordsure (AI-powered compliance technology). 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URL: https://tcc.group/contact/ - Published: 2026-08-05 - Modified: 2026-08-05 Talk to TCC Group about regulatory advice, managed compliance delivery, specialist resourcing and compliance technology. ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/contact/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Contact", "item": "https://tcc.group/contact/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/contact/#webpage", "url": "https://tcc.group/contact/", "name": "Contact", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-08-05T04:51:07+01:00", "dateModified": "2026-08-05T04:51:07+01:00", "breadcrumb": { "@id": "https://tcc.group/contact/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } } ] } ``` ### Utilities - URL: https://tcc.group/sectors/utilities/ - Published: 2026-08-03 - Modified: 2026-09-03 #### How can utilities providers improve complaint performance, vulnerable customers support and fair outcomes? Utilities providers must support customers facing financial or personal difficulty while managing billing concerns, service interruptions, complaint volumes and demanding service standards. TCC helps energy, water and other regulated utilities strengthen vulnerability arrangements, improve complaint resolution and increase operational capacity, combining specialist advice, managed delivery, experienced resources and technology-enabled assurance.  #### Regulatory pressure map - [Identifying and supporting customers in vulnerable circumstances](https://tcc.group/vulnerable-customers/) - [Affordability, debt and payment difficulty](https://tcc.group/consumer-duty/) - [Billing disputes and complaint resolution](https://tcc.group/redress-and-remediation/) - [Service interruptions and customer communication](https://tcc.group/complaints-claims-handling/) - [Contact-centre demand and operational backlogs](https://tcc.group/complaints-claims-handling/) #### Relevant solutions - Complaints & Claims Handling - Compliance AI & RegTech - Consumer Duty - Regulatory Change & Transformation - Vulnerable Customers #### What we help with Utilities providers come to TCC when customer demand, complaint volumes or regulatory expectations expose weaknesses in existing operations. We help organisations understand the underlying issues, strengthen oversight and provide the additional capability needed to restore performance. #### Frequently asked questions ##### What are the key regulatory priorities for utilities providers? Many regulated utilities are focused on customer outcomes, vulnerability, complaint handling, affordability pressures and demonstrating fair treatment through effective governance and monitoring. ##### What makes an effective vulnerability framework? An effective framework helps organisations identify vulnerable customers, understand support needs, adapt communications and monitor resulting outcomes. Governance, training and management information are all critical components. ##### How can utilities improve complaint handling performance? Strong complaint handling combines clear governance, quality assurance, root cause analysis, operational oversight and a commitment to continuous improvement. Complaint insights should help improve wider customer experiences. ##### How can organisations demonstrate good customer outcomes? Good outcomes can be evidenced through customer feedback, complaint trends, quality assurance activity, vulnerability monitoring and management information that shows how issues are identified and addressed. ##### How does TCC support customer review programmes? TCC provides diagnostics, governance reviews, operational support, specialist resource and managed delivery models that help organisations improve customer outcomes while maintaining effective oversight. ##### Can TCC provide additional delivery capacity? Yes. 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TCC can deploy experienced specialists to support complaint handling programmes, customer reviews, vulnerability initiatives and broader operational improvement projects." } } ] } ] } ``` ### Motor Finance - URL: https://tcc.group/sectors/motor-finance/ - Published: 2026-08-03 - Modified: 2026-09-03 #### How can motor finance firms evidence fair customer outcomes, prepare for redress and stay ahead of FCA scrutiny? TCC helps motor finance lenders, brokers and providers assess redress exposure, prepare for large-scale customer reviews and strengthen complaints, affordability and Consumer Duty frameworks. We combine regulatory advisory, managed operations, specialist resource and technology-enabled assurance to deliver consistent customer outcomes, robust governance and regulator-ready evidence under heightened FCA scrutiny. #### Regulatory pressure map - [Discretionary commission arrangements and potential redress](https://tcc.group/redress-and-remediation/) - [Consumer Duty and fair customer outcomes](https://tcc.group/consumer-duty/) - [Affordability and responsible lending](https://tcc.group/consumer-duty/) - [Complaints handling and operational resilience](https://tcc.group/complaints-claims-handling/) - [Vulnerable customers](https://tcc.group/vulnerable-customers/) - [FCA intervention and regulatory readiness](https://tcc.group/section-166-skilled-person-reviews-fca-intervention/) #### Relevant solutions - Complaints & Claims Handling - Compliance AI & RegTech - Consolidation, Acquisition & Regulatory Due Diligence - Consumer Duty - Financial Crime Compliance - Redress & Remediation - Regulatory Change & Transformation - Section 166, Skilled Person Reviews & FCA Intervention - Vulnerable Customers #### What we help with TCC helps motor finance providers assess exposure, prepare for customer review programmes, mobilise remediation activity, manage redress risk and strengthen customer outcomes with confidence. #### Frequently asked questions ##### How should motor finance firms prepare for potential redress programmes? Preparation starts with understanding customer populations, available data, governance arrangements and operational capability. Firms should assess how customer reviews could be delivered, how quality assurance would operate and whether management information can provide regulator-ready evidence throughout the programme lifecycle. ##### What does good Consumer Duty evidence look like in motor finance? Good evidence demonstrates how firms monitor customer outcomes across affordability, customer support, complaints, vulnerability and communications. The FCA expects firms to show how monitoring identifies issues, drives decision-making and leads to tangible improvements for customers. ##### How can motor finance firms manage large complaint volumes effectively? Sustainable complaint handling requires clear governance, consistent review methodology, quality assurance controls, effective root cause analysis and scalable operational capacity. Firms should be able to evidence fair and consistent outcomes while maintaining regulatory service standards. ##### What are the FCA's expectations around vulnerable customers in motor finance? The FCA expects firms to identify vulnerable customers, adapt support where appropriate and monitor resulting outcomes. Vulnerability considerations should be embedded across sales, servicing, collections, complaints and remediation activities rather than treated as a standalone process. ##### How can firms assess their readiness for FCA scrutiny? Firms should understand where regulatory risks exist, how decisions are evidenced, whether governance arrangements remain effective and whether customer outcomes can be demonstrated through robust management information and documentation. Independent assessments often help identify gaps before regulatory engagement occurs. ##### How does TCC support motor finance remediation programmes? TCC supports firms across programme mobilisation, methodology design, customer population analysis, case review operations, quality assurance, governance oversight and regulatory reporting. Our specialists help organisations maintain control while delivering complex customer review programmes at scale. ##### What's the difference between TCC's advisory, managed service and resourcing models? Advisory engagements provide independent expertise and strategic guidance. Managed services deliver operational programmes on your behalf. Specialist resourcing provides experienced professionals who integrate into your existing teams. 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We assess product governance, claims performance, distribution oversight and vulnerability risks, helping firms create regulator-ready evidence, improve operational performance and demonstrate that products and services deliver value throughout the customer lifecycle. #### Regulatory pressure map - [Fair value assessments](https://tcc.group/consumer-duty/) - [Claims handling and customer outcomes](https://tcc.group/complaints-claims-handling/) - [Vulnerable customers](https://tcc.group/vulnerable-customers/) - [Product governance and distribution oversight](https://tcc.group/consumer-duty/) - [Complaints management and root-cause analysis](https://tcc.group/complaints-claims-handling/) - [Consumer Duty and outcomes monitoring](https://tcc.group/consumer-duty/) #### Relevant solutions - Complaints & Claims Handling - Compliance AI & RegTech - Consolidation, Acquisition & Regulatory Due Diligence - Consumer Duty - Redress & Remediation - Regulatory Change & Transformation - Section 166, Skilled Person Reviews & FCA Intervention - Suitability, Advice Quality & File Reviews - Vulnerable Customers #### What we help with TCC supports insurers, brokers, MGAs and protection providers through advisory, managed service, specialist resourcing and technology-enabled compliance models. We help firms move beyond retrospective reporting and gain a clearer understanding of customer outcomes, product performance and conduct risk.  #### Frequently asked questions ##### How do insurers demonstrate fair value in practice? Fair value assessments typically combine product performance data, customer outcomes, complaints analysis, claims experience, distribution information and governance oversight. Firms should be able to demonstrate how assessments lead to product improvements and better customer outcomes. ##### What does good claims governance look like? Effective claims governance includes quality assurance, outcome monitoring, root-cause analysis, customer feedback, management information and clear accountability for customer outcomes throughout the claims journey. ##### How should firms monitor vulnerable customer outcomes? Monitoring should assess not only identification rates but also whether vulnerable customers receive appropriate support and achieve comparable outcomes to other customer groups. ##### What are the FCA's expectations around distributor oversight? Insurers are expected to maintain meaningful oversight of distribution arrangements, understand customer outcomes and take action where products or distribution channels are not delivering expected results. ##### Why are complaints important for Consumer Duty? Complaints often provide the earliest indication of customer harm, poor product performance or operational weaknesses. Firms should use complaints data proactively rather than treating it only as a reporting requirement. ##### How can firms identify emerging customer harm earlier? 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We support lenders with practical, regulator-ready compliance programmes that improve governance, customer treatment and operational resilience.  #### Regulatory pressure map - [Affordability and responsible lending](https://tcc.group/consumer-duty/) - [Buy Now, Pay Later and short-term credit](https://tcc.group/consumer-duty/) - [Consumer Duty and customer outcomes](https://tcc.group/consumer-duty/) - [Financial difficulty and vulnerability](https://tcc.group/vulnerable-customers/) - [Remediation and customer review programmes](https://tcc.group/redress-and-remediation/) - [Complaints handling and operational performance](https://tcc.group/complaints-claims-handling/) #### Relevant solutions - Complaints & Claims Handling - Compliance AI & RegTech - Consolidation, Acquisition & Regulatory Due Diligence - Consumer Duty - Financial Crime Compliance - Redress & Remediation - Regulatory Change & Transformation - Section 166, Skilled Person Reviews & FCA Intervention - Suitability, Advice Quality & File Reviews - Vulnerable Customers #### What we help with TCC supports lenders through advisory, managed services, specialist resourcing and technology-enabled compliance models. We help firms strengthen customer outcomes, manage operational pressures and respond effectively to regulatory expectations. #### Frequently asked questions ##### What does Consumer Duty mean for consumer credit firms? Consumer Duty requires firms to demonstrate that customers receive good outcomes throughout the lending lifecycle. This includes product suitability, affordability assessments, customer support, communications and complaint handling. Evidence should show how monitoring activities lead to continuous improvement. ##### What are the FCA's expectations around affordability? Firms should be able to demonstrate proportionate affordability assessments, effective governance, ongoing monitoring and appropriate oversight. Lending decisions should reflect customers' circumstances and support good customer outcomes. ##### How should lenders support vulnerable customers? The FCA expects firms to identify vulnerability, adapt support where appropriate and monitor resulting outcomes. Vulnerability considerations should be embedded throughout customer journeys rather than treated as a standalone process. ##### How can firms improve collections and forbearance outcomes? Effective collections strategies combine customer-centred support, robust governance, staff training, quality assurance and clear management information. Firms should be able to evidence fair treatment throughout the customer relationship. ##### How can TCC support remediation programmes? TCC supports customer population assessments, methodology design, governance arrangements, review operations, quality assurance and regulator-ready reporting throughout the remediation lifecycle. ##### What's the difference between advisory, managed services and specialist resourcing? Advisory provides specialist expertise and independent challenge. Managed services deliver operational programmes on your behalf. Specialist resourcing augments your team with experienced professionals. 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With more than 25 years of experience supporting FCA-regulated firms, we help banks respond confidently to regulatory scrutiny while strengthening operational resilience and customer trust. #### Regulatory pressure map - [Consumer Duty and outcomes monitoring](https://tcc.group/consumer-duty/) - [Financial crime, fraud and AML controls](https://tcc.group/financial-crime-compliance/) - [Savings, Current Accounts & Fair Value](https://tcc.group/consumer-duty/) - [Retail Banking Customer Journeys](https://tcc.group/consumer-duty/) - [Section 166 reviews and regulatory intervention](https://tcc.group/section-166-skilled-person-reviews-fca-intervention/) - [Complaints, vulnerable customers and customer support](https://tcc.group/complaints-claims-handling/) #### Relevant solutions - Complaints & Claims Handling - Compliance AI & RegTech - Consolidation, Acquisition & Regulatory Due Diligence - Consumer Duty - Financial Crime Compliance - Redress & Remediation - Redress calculations - Regulatory Change & Transformation - Section 166, Skilled Person Reviews & FCA Intervention - Vulnerable Customers #### What we help with TCC supports banks through advisory, managed service, specialist resourcing and technology-enabled compliance models. We mobilise quickly and tailor our approach to your regulatory priorities, operational challenges and customer obligations. #### Frequently asked questions ##### What does the FCA expect banks to demonstrate under Consumer Duty? Banks must be able to evidence good customer outcomes across savings accounts, current accounts, lending products, communications and customer support. This includes fair value assessments, customer outcome monitoring, governance oversight and board reporting that demonstrates continuous improvement.  ##### How can banks assess customer outcomes across onboarding and account servicing journeys? Banks should monitor customer journeys from onboarding through to ongoing account servicing, complaints and support interactions. Management information, quality assurance activity, vulnerability monitoring and customer feedback can help identify areas where outcomes may deteriorate and where improvements are required.  ##### How can banks demonstrate good outcomes for savings and current account customers? Banks need evidence that products deliver fair value, communications are clear, customer support is effective and customers can achieve their financial objectives without unreasonable barriers or foreseeable harm.  ##### How can banks strengthen their financial crime controls? Effective programmes typically combine risk assessments, governance, customer due diligence, sanctions screening, transaction monitoring, fraud prevention, quality assurance and ongoing control testing.  ##### How should banks support customers in vulnerable circumstances? Banks should identify vulnerability risks throughout onboarding, servicing, complaints and support journeys. Monitoring outcomes, staff capability and support arrangements helps demonstrate compliance with Consumer Duty expectations.  ##### How can banks prepare for FCA reviews or Section 166 assessments? Preparation typically involves reviewing governance arrangements, management information, customer outcome evidence, financial crime controls and remediation activity. 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TCC helps payment institutions, e-money firms, FinTechs, challenger businesses and regulated technology providers strengthen compliance, manage regulatory change and demonstrate effective customer outcomes. From financial crime controls and APP fraud prevention to operational resilience, safeguarding and Consumer Duty governance, we help firms build regulator-ready frameworks that support growth without compromising control. For more than 25 years, TCC has helped FCA-regulated firms navigate evolving regulatory expectations with confidence.  #### Regulatory pressure map - [Financial crime, fraud and APP fraud](https://tcc.group/financial-crime-compliance/) - [Consumer Duty and customer outcomes](https://tcc.group/consumer-duty/) - [Safeguarding of customer funds](https://tcc.group/financial-crime-compliance/) - [Operational resilience](https://tcc.group/consumer-duty/) - [Regulatory change and innovation](https://tcc.group/regulatory-change-transformation/) - [Complaints, remediation and customer harm](https://tcc.group/complaints-claims-handling/) #### Relevant solutions - Complaints & Claims Handling - Compliance AI & RegTech - Consolidation, Acquisition & Regulatory Due Diligence - Consumer Duty - Financial Crime Compliance - Redress & Remediation - Regulatory Change & Transformation - Section 166, Skilled Person Reviews & FCA Intervention - Vulnerable Customers #### What we help with TCC supports payments and fintech organisations through advisory, managed service, specialist resourcing and technology-enabled compliance models. We help firms respond quickly to regulatory pressure while strengthening long-term governance and operational resilience. #### Frequently asked questions ##### What are the FCA's biggest areas of focus for payment firms? The FCA's current priorities include financial crime controls, APP fraud prevention, safeguarding customer funds, Consumer Duty, operational resilience and governance. Firms are expected to demonstrate evidence of effective oversight rather than relying solely on policies and procedures. ##### How can Payment firms demonstrate Consumer Duty compliance? Consumer Duty evidence should combine customer outcomes monitoring, management information, customer journey reviews, complaints data, vulnerability analysis and board reporting. Firms need to show how monitoring leads to continuous improvement over time. ##### What does a financial crime assurance review involve? Financial crime reviews typically assess governance, AML risk assessments, KYC controls, sanctions screening, transaction monitoring effectiveness, fraud controls, management information and escalation processes. The objective is to identify weaknesses before they become regulatory issues. ##### What does operational resilience mean for payment firms? Payment firms must identify important business services, understand dependencies, set impact tolerances and demonstrate resilience against severe but plausible disruptions. Regulators expect testing, governance and clear remediation planning. ##### How can fintech firms adopt AI while remaining compliant? AI adoption should be supported by governance frameworks, explainability controls, audit trails, human oversight and documented accountability. Firms must be able to demonstrate that innovation does not compromise customer outcomes or regulatory obligations. ##### How quickly can TCC mobilise support? 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Consumer outcomes evidence remains critical.", "url": "/complaints-claims-handling/" }, { "@type": "Thing", "name": "Complaints & Claims Handling", "url": "https://tcc.group/complaints-claims-handling/" }, { "@type": "Thing", "name": "Compliance AI, Governace & RegTech", "url": "https://tcc.group/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Consolidation, Acquisition & Regulatory Due Diligence", "url": "https://tcc.group/consolidation-acquisition-regulatory-due-diligence/" }, { "@type": "Thing", "name": "Consumer Duty", "url": "https://tcc.group/consumer-duty/" }, { "@type": "Thing", "name": "Financial Crime Compliance", "url": "https://tcc.group/financial-crime-compliance/" }, { "@type": "Thing", "name": "Redress and Remediation", "url": "https://tcc.group/redress-and-remediation/" }, { "@type": "Thing", "name": "Regulatory Change & Transformation", "url": "https://tcc.group/regulatory-change-transformation/" }, { "@type": "Thing", "name": "Section 166, Skilled Person Reviews & FCA Intervention", "url": "https://tcc.group/section-166-skilled-person-reviews-fca-intervention/" }, { "@type": "Thing", "name": "Vulnerable Customers", "url": "https://tcc.group/vulnerable-customers/" } ], "reviewedBy": { "@type": "Organization", "name": "TCC Group regulatory specialists" } }, { "@type": "FAQPage", "@id": "https://tcc.group/sectors/payments-fintech/#faqpage", "isPartOf": { "@id": "https://tcc.group/sectors/payments-fintech/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What are the FCA's biggest areas of focus for payment firms?", "acceptedAnswer": { "@type": "Answer", "text": "The FCA's current priorities include financial crime controls, APP fraud prevention, safeguarding customer funds, Consumer Duty, operational resilience and governance. Firms are expected to demonstrate evidence of effective oversight rather than relying solely on policies and procedures." } }, { "@type": "Question", "name": "How can Payment firms demonstrate Consumer Duty compliance?", "acceptedAnswer": { "@type": "Answer", "text": "Consumer Duty evidence should combine customer outcomes monitoring, management information, customer journey reviews, complaints data, vulnerability analysis and board reporting. Firms need to show how monitoring leads to continuous improvement over time." } }, { "@type": "Question", "name": "What does a financial crime assurance review involve?", "acceptedAnswer": { "@type": "Answer", "text": "Financial crime reviews typically assess governance, AML risk assessments, KYC controls, sanctions screening, transaction monitoring effectiveness, fraud controls, management information and escalation processes. The objective is to identify weaknesses before they become regulatory issues." } }, { "@type": "Question", "name": "What does operational resilience mean for payment firms?", "acceptedAnswer": { "@type": "Answer", "text": "Payment firms must identify important business services, understand dependencies, set impact tolerances and demonstrate resilience against severe but plausible disruptions. Regulators expect testing, governance and clear remediation planning." } }, { "@type": "Question", "name": "How can fintech firms adopt AI while remaining compliant?", "acceptedAnswer": { "@type": "Answer", "text": "AI adoption should be supported by governance frameworks, explainability controls, audit trails, human oversight and documented accountability. Firms must be able to demonstrate that innovation does not compromise customer outcomes or regulatory obligations." } }, { "@type": "Question", "name": "How quickly can TCC mobilise support?", "acceptedAnswer": { "@type": "Answer", "text": "TCC provides advisory support, managed services, specialist compliance professionals and technology-enabled solutions that can be tailored to regulatory deadlines, remediation programmes and growth initiatives across the payments and fintech sector." } } ] } ] } ``` ### Pensions & Retirement Income - URL: https://tcc.group/sectors/pensions-retirement-income/ - Published: 2026-08-03 - Modified: 2026-09-03 #### How do pension and retirement income firms manage evolving customer needs, suitability and regulatory expectations? TCC 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.  #### Regulatory pressure map - [Consumer Duty and outcomes evidence](https://tcc.group/consumer-duty/) - [Retirement income sustainability and governance](https://tcc.group/outsourced-suitability-reviews/) - [Later-life customer needs and financial resilience](https://tcc.group/consumer-duty/) - [Legacy advice, Defined Benefits transfers and historic risk](https://tcc.group/redress-and-remediation/) - [Complaints and redress](https://tcc.group/complaints-claims-handling/) - [Regulatory change and governance](https://tcc.group/regulatory-change-transformation/) #### Relevant solutions - Complaints & Claims Handling - Compliance AI & RegTech - Consolidation, Acquisition & Regulatory Due Diligence - Consumer Duty - Redress & Remediation - Redress calculations - Regulatory Change & Transformation - Section 166, Skilled Person Reviews & FCA Intervention - Suitability, Advice Quality & File Reviews - Vulnerable Customers #### What we help with TCC supports pension and retirement income firms through advisory, managed service, specialist resourcing and technology-enabled compliance models. We tailor delivery to the complexity of your proposition, customer base and regulatory obligations. #### Frequently asked questions ##### Does Consumer Duty change how firms oversee retirement propositions? Consumer Duty requires firms to demonstrate that retirement products, services and support arrangements deliver good customer outcomes. Firms need evidence that governance, monitoring and customer support remain effective over time. ##### What should firms review within their ongoing servicing proposition? Firms should assess service delivery, customer engagement, value provided and outcome monitoring. Ongoing servicing arrangements should continue to support customer needs throughout retirement. ##### What are the FCA's expectations around vulnerable customers in retirement? The FCA expects firms to identify vulnerability, understand customer needs, adapt communications and support arrangements, and monitor outcomes. This is particularly important for retirement and later-life customer groups. ##### How can firms assess retirement advice quality? Advice quality reviews assess customer information gathering, suitability, disclosures, record keeping and recommendation rationale. Independent reviews help firms improve consistency and strengthen governance. ##### Can TCC support retirement-related review and remediation programmes? Yes. TCC supports review and remediation programmes through methodology design, quality assurance, governance support, case review and customer outcome assessment. ##### How can firms evidence good retirement outcomes? Effective evidence combines management information, customer reviews, suitability assessments, outcome testing, vulnerability monitoring, complaints analysis and board reporting. 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TCC 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.  #### Regulatory pressure map - [Consumer Duty and outcomes evidence](https://tcc.group/consumer-duty/) - [Suitability and ongoing advice](https://tcc.group/outsourced-suitability-reviews/) - [Ongoing servicing and fee value](https://tcc.group/consumer-duty/) - [Vulnerable customers](https://tcc.group/vulnerable-customers/) - [Consolidation and acquisition risk](https://tcc.group/consolidation-acquisition-regulatory-due-diligence/) - [Financial crime and AML controls](https://tcc.group/financial-crime-compliance/) #### Relevant solutions - Complaints & Claims Handling - Compliance AI & RegTech - Consolidation, Acquisition & Regulatory Due Diligence - Consumer Duty - Redress & Remediation - Redress calculations - Regulatory Change & Transformation - Section 166, Skilled Person Reviews & FCA Intervention - Suitability, Advice Quality & File Reviews - Vulnerable Customers #### What we help with TCC supports wealth managers through advisory, managed service, specialist resourcing and technology-enabled compliance models. We tailor engagements to the scale and complexity of your challenge. #### Frequently asked questions ##### Does Consumer Duty apply differently to wealth managers? Consumer Duty applies across the wealth management sector, but firms must consider how advice models, ongoing servicing arrangements, charges and client outcomes align to the Duty's requirements. The FCA expects firms to demonstrate evidence of good outcomes, not simply policy compliance. ##### What does an FCA suitability review involve? Suitability reviews typically assess client information gathering, risk profiling, recommendations, disclosures, documentation quality and record keeping. Firms need a consistent methodology and clear evidence supporting all conclusions reached.  ##### How can firms evidence good customer outcomes? Effective evidence combines management information, customer journey reviews, file assessments, outcome testing, complaints analysis, vulnerability data and board reporting. Firms should be able to show how monitoring activities drive improvement over time. ##### What are the FCA's expectations around vulnerable customers? The FCA expects firms to identify vulnerable customers, understand their needs, adapt support where necessary and monitor outcomes. Vulnerable customers should experience outcomes comparable to other customer groups. ##### What should firms assess before acquiring another advice business? Regulatory due diligence should include permissions, advice quality, complaints experience, governance arrangements, Consumer Duty maturity, remediation exposure and financial crime controls. Early assessment helps identify risk before integration begins. ##### How does TCC support ongoing advice propositions? TCC supports firms through suitability reviews, ongoing service assessments, governance reviews, Consumer Duty evidence frameworks, monitoring programmes and specialist compliance resource deployment. ##### How can firms demonstrate that ongoing advice services provide value? Firms should be able to evidence that clients receive the services they are paying for, that ongoing reviews are delivered consistently and that charging structures remain appropriate. Effective value assessments typically combine service delivery data, client outcomes, engagement metrics, quality assurance findings and Consumer Duty monitoring.  **Audience:** Wealth managers, financial advisers and advice networks - Reviewed by: TCC Group regulatory specialists **Last reviewed:** 2026-09-02 ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/sectors/wealth-management-financial-advice/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Wealth Management & Financial Advice", "item": "https://tcc.group/sectors/wealth-management-financial-advice/" } ] }, { "@type": "CollectionPage", "@id": "https://tcc.group/sectors/wealth-management-financial-advice/#webpage", "url": "https://tcc.group/sectors/wealth-management-financial-advice/", "name": "Wealth Management & Financial Advice", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-08-03T14:57:12+01:00", "dateModified": "2026-09-02", "breadcrumb": { "@id": "https://tcc.group/sectors/wealth-management-financial-advice/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] }, "description": "TCC helps wealth managers, financial advisers, networks,\u00a0platforms\u00a0and consolidators strengthen compliance,\u00a0evidence\u00a0customer\u00a0outcomes\u00a0and manage regulatory risk. 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The FCA expects firms to demonstrate evidence of good outcomes, not simply policy compliance." } }, { "@type": "Question", "name": "What does an FCA suitability review involve?", "acceptedAnswer": { "@type": "Answer", "text": "Suitability reviews typically assess client information gathering, risk profiling, recommendations, disclosures, documentation quality and record keeping. Firms need a consistent methodology and clear evidence supporting all conclusions reached.\u00a0" } }, { "@type": "Question", "name": "How can firms evidence good customer outcomes?", "acceptedAnswer": { "@type": "Answer", "text": "Effective evidence combines management information, customer journey reviews, file assessments, outcome testing, complaints analysis, vulnerability data and board reporting. Firms should be able to show how monitoring activities drive improvement over time." } }, { "@type": "Question", "name": "What are the FCA's expectations around vulnerable customers?", "acceptedAnswer": { "@type": "Answer", "text": "The FCA expects firms to identify vulnerable customers, understand their needs, adapt support where necessary and monitor outcomes. Vulnerable customers should experience outcomes comparable to other customer groups." } }, { "@type": "Question", "name": "What should firms assess before acquiring another advice business?", "acceptedAnswer": { "@type": "Answer", "text": "Regulatory due diligence should include permissions, advice quality, complaints experience, governance arrangements, Consumer Duty maturity, remediation exposure and financial crime controls. Early assessment helps identify risk before integration begins." } }, { "@type": "Question", "name": "How does TCC support ongoing advice propositions?", "acceptedAnswer": { "@type": "Answer", "text": "TCC supports firms through suitability reviews, ongoing service assessments, governance reviews, Consumer Duty evidence frameworks, monitoring programmes and specialist compliance resource deployment." } }, { "@type": "Question", "name": "How can firms demonstrate that ongoing advice services provide value?", "acceptedAnswer": { "@type": "Answer", "text": "Firms should be able to\u00a0evidence\u00a0that clients receive the services they are paying for, that ongoing reviews are delivered\u00a0consistently\u00a0and that charging structures\u00a0remain\u00a0appropriate. Effective value assessments typically combine service delivery data, client outcomes, engagement metrics, quality assurance\u00a0findings\u00a0and Consumer Duty monitoring.\u00a0" } } ] } ] } ``` ### Sectors - URL: https://tcc.group/sectors/ - Published: 2026-08-03 - Modified: 2026-08-03 Explore our sector expertise and the regulatory, operational and customer challenges we help firms address. ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/sectors/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Sectors", "item": "https://tcc.group/sectors/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/sectors/#webpage", "url": "https://tcc.group/sectors/", "name": "Sectors", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-08-03T14:57:12+01:00", "dateModified": "2026-08-03T14:57:12+01:00", "breadcrumb": { "@id": "https://tcc.group/sectors/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "WebPageElement", "@id": "https://tcc.group/sectors/#page-content", "headline": "Sectors", "text": "Explore our sector expertise and the regulatory, operational and customer challenges we help firms address.", "position": 1, "isPartOf": { "@id": "https://tcc.group/sectors/#webpage" }, "inLanguage": "en-GB" } ] } ``` ### Terms - URL: https://tcc.group/terms/ - Published: 2026-08-01 - Modified: 2026-08-02 ## Policy title and summary Terms The website provides general information about regulatory topics, services and the experience of TCC Group. It is not legal advice, investment advice or a substitute for advice based on a firm's circumstances. Regulation, guidance and supervisory expectations can change, and published material may not reflect developments after its stated publication or review date. ## Key facts panel TCC Group ## Full policy content These terms explain how visitors may use the TCC Group website. By using the site, you agree to use it lawfully and to respect the rights, content and systems of The Consulting Consortium Ltd and other TCC Group companies. ## Information, not regulated advice You should obtain appropriate professional advice before acting on information from the site. No client relationship, duty of care or contract is created merely by visiting the site, downloading material or sending an initial enquiry. Any engagement is governed by separately agreed terms. ## Acceptable use - Do not attempt to gain unauthorised access to the website, accounts, infrastructure or data. - Do not introduce malware, automate abusive requests or interfere with availability or security. - Do not use site content unlawfully, misleadingly or in a way that implies an endorsement that has not been given. - Do not submit confidential, special category or sensitive financial information through a general enquiry channel. ## Copyright and permitted use Unless stated otherwise, website text, design, branding and original materials are owned by or licensed to the relevant TCC Group company. You may view and print reasonable extracts for internal, non-commercial reference, provided the source is acknowledged and the material is not changed. Republishing, commercial reuse, systematic extraction or use of logos and trade marks requires prior permission. ## Links, availability and liability Links to third-party websites are provided for context and convenience. TCC Group does not control their content, availability or privacy practices. We aim to keep this website accurate and available but do not promise uninterrupted access or that every item will be complete and error-free. Nothing in these terms excludes liability that cannot lawfully be excluded. Subject to that restriction, use of general website information is at the visitor's own risk. ## Governing law and changes These website terms are governed by the laws of England and Wales, and disputes are subject to the jurisdiction of its courts unless mandatory law requires otherwise. We may update the terms when the website, services or legal requirements change. The version published on this page is the current version. ## Related policies - Privacy and Policies — /privacy-statement/ - Privacy: Visitors and clients — /privacy-statement-visitors-and-clients/ - Privacy: Employees — /privacy-statement-tcc-employees/ - Privacy: Associates — /privacy-statement-tcc-associates/ - Privacy: Legal basis — /privacy-statement-legal-basis/ - Privacy: Third parties — /privacy-third-party-list/ ## Privacy / compliance contact Data protection dataprotection@tcc.group 020 3772 7230 ## Editorial byline TCC Group Editorial Team /meet-the-team/ ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/terms/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Terms", "item": "https://tcc.group/terms/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/terms/#webpage", "url": "https://tcc.group/terms/", "name": "Terms", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-08-01T07:27:02+01:00", "dateModified": "2026-08-02T22:12:07+01:00", "breadcrumb": { "@id": "https://tcc.group/terms/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "Organization", "@id": "https://tcc.group/terms/#editorial-team", "name": "TCC Group Editorial Team", "url": "https://tcc.group/meet-the-team/" }, { "@type": "DigitalDocument", "@id": "https://tcc.group/terms/#policy", "name": "Terms", "description": "The website provides general information about regulatory topics, services and the experience of TCC Group. It is not legal advice, investment advice or a substitute for advice based on a firm's circumstances. Regulation, guidance and supervisory expectations can change, and published material may not reflect developments after its stated publication or review date.", "text": "These terms explain how visitors may use the TCC Group website. By using the site, you agree to use it lawfully and to respect the rights, content and systems of The Consulting Consortium Ltd and other TCC Group companies.\n\nInformation, not regulated advice\n\nYou should obtain appropriate professional advice before acting on information from the site. No client relationship, duty of care or contract is created merely by visiting the site, downloading material or sending an initial enquiry. Any engagement is governed by separately agreed terms.\n\nAcceptable use\n\n\u2022 Do not attempt to gain unauthorised access to the website, accounts, infrastructure or data.\n\u2022 Do not introduce malware, automate abusive requests or interfere with availability or security.\n\u2022 Do not use site content unlawfully, misleadingly or in a way that implies an endorsement that has not been given.\n\u2022 Do not submit confidential, special category or sensitive financial information through a general enquiry channel.\n\nCopyright and permitted use\n\nUnless stated otherwise, website text, design, branding and original materials are owned by or licensed to the relevant TCC Group company. You may view and print reasonable extracts for internal, non-commercial reference, provided the source is acknowledged and the material is not changed. Republishing, commercial reuse, systematic extraction or use of logos and trade marks requires prior permission.\n\nLinks, availability and liability\n\nLinks to third-party websites are provided for context and convenience. TCC Group does not control their content, availability or privacy practices. We aim to keep this website accurate and available but do not promise uninterrupted access or that every item will be complete and error-free. Nothing in these terms excludes liability that cannot lawfully be excluded. Subject to that restriction, use of general website information is at the visitor's own risk.\n\nGoverning law and changes\n\nThese website terms are governed by the laws of England and Wales, and disputes are subject to the jurisdiction of its courts unless mandatory law requires otherwise. We may update the terms when the website, services or legal requirements change. The version published on this page is the current version.", "url": "https://tcc.group/terms/", "publisher": { "@id": "https://tcc.group/#organization" }, "reviewedBy": { "@id": "https://tcc.group/terms/#editorial-team" }, "additionalProperty": [ { "@type": "PropertyValue", "name": "owner", "value": "TCC Group" } ] }, { "@type": "ItemList", "@id": "https://tcc.group/terms/#related-policies", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Privacy and Policies", "url": "https://tcc.group/privacy-statement/" }, { "@type": "ListItem", "position": 2, "name": "Privacy: Visitors and clients", "url": "https://tcc.group/privacy-statement-visitors-and-clients/" }, { "@type": "ListItem", "position": 3, "name": "Privacy: Employees", "url": "https://tcc.group/privacy-statement-tcc-employees/" }, { "@type": "ListItem", "position": 4, "name": "Privacy: Associates", "url": "https://tcc.group/privacy-statement-tcc-associates/" }, { "@type": "ListItem", "position": 5, "name": "Privacy: Legal basis", "url": "https://tcc.group/privacy-statement-legal-basis/" }, { "@type": "ListItem", "position": 6, "name": "Privacy: Third parties", "url": "https://tcc.group/privacy-third-party-list/" } ] }, { "@type": "ContactPoint", "@id": "https://tcc.group/terms/#contact-point", "contactType": "Data protection", "email": "dataprotection@tcc.group", "telephone": "020 3772 7230" } ] } ``` ### Accessibility - URL: https://tcc.group/accessibility/ - Published: 2026-08-01 - Modified: 2026-08-02 ## Policy title and summary Accessibility You should be able to navigate the main interface with a keyboard, identify visible focus, zoom text and page content, use headings and landmarks to understand structure, and access meaningful text alternatives for informative images. Interactive controls should have accessible names and communicate state. Motion is reduced where the operating system preference requests it. ## Key facts panel TCC Group ## Full policy content TCC Group aims to make this website usable by as many people as possible, including people who use keyboards, screen readers, magnification, voice input or reduced-motion settings. Our target is WCAG 2.2 Level AA. ## Using this website The website uses responsive layouts so content reflows on smaller screens. Text is intended to maintain sufficient contrast against its background, and links should remain identifiable without relying on colour alone. Forms should provide labels and clear error information rather than using placeholder text as the only instruction. ## Known limitations Some older documents, third-party embeds or externally hosted destinations may not meet the same standard as the current theme. Complex regulatory tables and downloadable documents can also require additional work to provide an equivalent structure. Where an inaccessible format remains necessary, we aim to provide the information in another reasonable format on request. ## How accessibility is maintained - Reusable components are checked for keyboard operation, focus behaviour and semantic structure. - New colour combinations are assessed against WCAG contrast requirements. - Block templates and content are validated so editor markup does not leak into the page. - Content authors are expected to use descriptive headings, links and image alternatives. - Material changes are reviewed at desktop and mobile widths with reduced motion considered. ## Reporting a problem If you cannot access information or complete a task, write to The Consulting Consortium Ltd, 10 Lower Thames Street, London EC3R 6EN. Include the page address, what you were trying to do, the assistive technology or browser used where relevant, and the format you need. Please do not include confidential client or financial information in an accessibility report. ## Assessment and review This statement describes the intended standard for the current TCC Group theme and content. It should be reviewed after significant design, navigation, form or platform changes and when a reported barrier is resolved. Accessibility is an ongoing responsibility rather than a one-off certification, so verified issues should be prioritised according to user impact. ## Related policies - Privacy and Policies — /privacy-statement/ - Privacy: Visitors and clients — /privacy-statement-visitors-and-clients/ - Privacy: Employees — /privacy-statement-tcc-employees/ - Privacy: Associates — /privacy-statement-tcc-associates/ - Privacy: Legal basis — /privacy-statement-legal-basis/ - Privacy: Third parties — /privacy-third-party-list/ ## Privacy / compliance contact Data protection dataprotection@tcc.group 020 3772 7230 ## Editorial byline TCC Group Editorial Team /meet-the-team/ ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/accessibility/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Accessibility", "item": "https://tcc.group/accessibility/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/accessibility/#webpage", "url": "https://tcc.group/accessibility/", "name": "Accessibility", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-08-01T07:27:02+01:00", "dateModified": "2026-08-02T22:26:08+01:00", "breadcrumb": { "@id": "https://tcc.group/accessibility/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "Organization", "@id": "https://tcc.group/accessibility/#editorial-team", "name": "TCC Group Editorial Team", "url": "https://tcc.group/meet-the-team/" }, { "@type": "DigitalDocument", "@id": "https://tcc.group/accessibility/#policy", "name": "Accessibility", "description": "You should be able to navigate the main interface with a keyboard, identify visible focus, zoom text and page content, use headings and landmarks to understand structure, and access meaningful text alternatives for informative images. Interactive controls should have accessible names and communicate state. Motion is reduced where the operating system preference requests it.", "text": "TCC Group aims to make this website usable by as many people as possible, including people who use keyboards, screen readers, magnification, voice input or reduced-motion settings. Our target is WCAG 2.2 Level AA.\n\nUsing this website\n\nThe website uses responsive layouts so content reflows on smaller screens. Text is intended to maintain sufficient contrast against its background, and links should remain identifiable without relying on colour alone. Forms should provide labels and clear error information rather than using placeholder text as the only instruction.\n\nKnown limitations\n\nSome older documents, third-party embeds or externally hosted destinations may not meet the same standard as the current theme. Complex regulatory tables and downloadable documents can also require additional work to provide an equivalent structure. Where an inaccessible format remains necessary, we aim to provide the information in another reasonable format on request.\n\nHow accessibility is maintained\n\n\u2022 Reusable components are checked for keyboard operation, focus behaviour and semantic structure.\n\u2022 New colour combinations are assessed against WCAG contrast requirements.\n\u2022 Block templates and content are validated so editor markup does not leak into the page.\n\u2022 Content authors are expected to use descriptive headings, links and image alternatives.\n\u2022 Material changes are reviewed at desktop and mobile widths with reduced motion considered.\n\nReporting a problem\n\nIf you cannot access information or complete a task, write to The Consulting Consortium Ltd, 10 Lower Thames Street, London EC3R 6EN. Include the page address, what you were trying to do, the assistive technology or browser used where relevant, and the format you need. Please do not include confidential client or financial information in an accessibility report.\n\nAssessment and review\n\nThis statement describes the intended standard for the current TCC Group theme and content. It should be reviewed after significant design, navigation, form or platform changes and when a reported barrier is resolved. Accessibility is an ongoing responsibility rather than a one-off certification, so verified issues should be prioritised according to user impact.", "url": "https://tcc.group/accessibility/", "publisher": { "@id": "https://tcc.group/#organization" }, "reviewedBy": { "@id": "https://tcc.group/accessibility/#editorial-team" }, "additionalProperty": [ { "@type": "PropertyValue", "name": "owner", "value": "TCC Group" } ] }, { "@type": "ItemList", "@id": "https://tcc.group/accessibility/#related-policies", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Privacy and Policies", "url": "https://tcc.group/privacy-statement/" }, { "@type": "ListItem", "position": 2, "name": "Privacy: Visitors and clients", "url": "https://tcc.group/privacy-statement-visitors-and-clients/" }, { "@type": "ListItem", "position": 3, "name": "Privacy: Employees", "url": "https://tcc.group/privacy-statement-tcc-employees/" }, { "@type": "ListItem", "position": 4, "name": "Privacy: Associates", "url": "https://tcc.group/privacy-statement-tcc-associates/" }, { "@type": "ListItem", "position": 5, "name": "Privacy: Legal basis", "url": "https://tcc.group/privacy-statement-legal-basis/" }, { "@type": "ListItem", "position": 6, "name": "Privacy: Third parties", "url": "https://tcc.group/privacy-third-party-list/" } ] }, { "@type": "ContactPoint", "@id": "https://tcc.group/accessibility/#contact-point", "contactType": "Data protection", "email": "dataprotection@tcc.group", "telephone": "020 3772 7230" } ] } ``` ### Cookie Settings - URL: https://tcc.group/cookie-settings/ - Published: 2026-08-01 - Modified: 2026-08-02 ## Policy title and summary Cookie Settings You can accept, reject or change optional cookie categories through the cookie control shown on the website. Necessary cookies cannot be switched off through that control because they support core functions such as security, administration and remembering your consent preference. Withdrawing optional consent does not affect processing that took place while a valid choice was active. ## Key facts panel TCC Group ## Full policy content TCC Group uses necessary cookies to operate and protect this WordPress website. Optional analytics, advertising and functional storage remain denied unless you choose the relevant category through the CookieYes consent controls. ## Your choices ## Cookie categories - **Necessary:** WordPress session and settings cookies, PHP session handling where used, and the CookieYes consent preference. - **Analytics:** Google Analytics cookies such as `_ga`, `_ga_*` and `_gid`, used only after analytics consent. - **Advertising:** cookies such as `_gcl_*` or `_fbp`, used only where advertising consent has been given and the relevant service is active. - **Functional:** optional features that require storage. No functional cookies are currently declared by the theme. ## Consent Mode and tags Google Consent Mode starts with analytics storage, advertising storage, advertising user data, advertising personalisation, functionality storage and personalisation storage denied. CookieYes communicates an update when you make or change a choice. Google Tag Manager is managed through the site's consent configuration; optional tags must not load before the relevant permission is available. ## Campaign parameters and session storage If you arrive through a campaign link, parameters such as UTM values or click identifiers may be kept temporarily in `sessionStorage` under the key `tcc_utm_params`. They can be added to a form submitted during that browser session to help identify how the enquiry reached us. This is not a cookie, is not stored in persistent `localStorage` by the theme and is cleared when the tab or browser session ends. ## Browser controls and further information Your browser can also block or delete cookies, although blocking necessary cookies may affect site functions or administration. Browser controls operate separately from the website consent control. For information about personal data, lawful bases, sharing, retention and rights, read the [Privacy Statement](/privacy-statement/). The cookie declaration and this page should be reviewed whenever a tag, plugin or service changes the site's storage behaviour. ## Related policies - Privacy and Policies — /privacy-statement/ - Privacy: Visitors and clients — /privacy-statement-visitors-and-clients/ - Privacy: Employees — /privacy-statement-tcc-employees/ - Privacy: Associates — /privacy-statement-tcc-associates/ - Privacy: Legal basis — /privacy-statement-legal-basis/ - Privacy: Third parties — /privacy-third-party-list/ ## Privacy / compliance contact Data protection dataprotection@tcc.group 020 3772 7230 ## Editorial byline TCC Group Editorial Team /meet-the-team/ ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/cookie-settings/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Cookie Settings", "item": "https://tcc.group/cookie-settings/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/cookie-settings/#webpage", "url": "https://tcc.group/cookie-settings/", "name": "Cookie Settings", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-08-01T07:27:02+01:00", "dateModified": "2026-08-02T22:12:07+01:00", "breadcrumb": { "@id": "https://tcc.group/cookie-settings/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "Organization", "@id": "https://tcc.group/cookie-settings/#editorial-team", "name": "TCC Group Editorial Team", "url": "https://tcc.group/meet-the-team/" }, { "@type": "DigitalDocument", "@id": "https://tcc.group/cookie-settings/#policy", "name": "Cookie Settings", "description": "You can accept, reject or change optional cookie categories through the cookie control shown on the website. Necessary cookies cannot be switched off through that control because they support core functions such as security, administration and remembering your consent preference. Withdrawing optional consent does not affect processing that took place while a valid choice was active.", "text": "TCC Group uses necessary cookies to operate and protect this WordPress website. Optional analytics, advertising and functional storage remain denied unless you choose the relevant category through the CookieYes consent controls.\n\nYour choices\n\nCookie categories\n\n\u2022 Necessary: WordPress session and settings cookies, PHP session handling where used, and the CookieYes consent preference.\n\u2022 Analytics: Google Analytics cookies such as _ga, _ga_ and _gid, used only after analytics consent.\n\u2022 Advertising: cookies such as _gcl_ or _fbp, used only where advertising consent has been given and the relevant service is active.\n\u2022 Functional: optional features that require storage. No functional cookies are currently declared by the theme.\n\nConsent Mode and tags\n\nGoogle Consent Mode starts with analytics storage, advertising storage, advertising user data, advertising personalisation, functionality storage and personalisation storage denied. CookieYes communicates an update when you make or change a choice. Google Tag Manager is managed through the site's consent configuration; optional tags must not load before the relevant permission is available.\n\nCampaign parameters and session storage\n\nIf you arrive through a campaign link, parameters such as UTM values or click identifiers may be kept temporarily in sessionStorage under the key tcc_utm_params. They can be added to a form submitted during that browser session to help identify how the enquiry reached us. This is not a cookie, is not stored in persistent localStorage by the theme and is cleared when the tab or browser session ends.\n\nBrowser controls and further information\n\nYour browser can also block or delete cookies, although blocking necessary cookies may affect site functions or administration. Browser controls operate separately from the website consent control. For information about personal data, lawful bases, sharing, retention and rights, read the Privacy Statement. The cookie declaration and this page should be reviewed whenever a tag, plugin or service changes the site's storage behaviour.", "url": "https://tcc.group/cookie-settings/", "publisher": { "@id": "https://tcc.group/#organization" }, "reviewedBy": { "@id": "https://tcc.group/cookie-settings/#editorial-team" }, "additionalProperty": [ { "@type": "PropertyValue", "name": "owner", "value": "TCC Group" } ] }, { "@type": "ItemList", "@id": "https://tcc.group/cookie-settings/#related-policies", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Privacy and Policies", "url": "https://tcc.group/privacy-statement/" }, { "@type": "ListItem", "position": 2, "name": "Privacy: Visitors and clients", "url": "https://tcc.group/privacy-statement-visitors-and-clients/" }, { "@type": "ListItem", "position": 3, "name": "Privacy: Employees", "url": "https://tcc.group/privacy-statement-tcc-employees/" }, { "@type": "ListItem", "position": 4, "name": "Privacy: Associates", "url": "https://tcc.group/privacy-statement-tcc-associates/" }, { "@type": "ListItem", "position": 5, "name": "Privacy: Legal basis", "url": "https://tcc.group/privacy-statement-legal-basis/" }, { "@type": "ListItem", "position": 6, "name": "Privacy: Third parties", "url": "https://tcc.group/privacy-third-party-list/" } ] }, { "@type": "ContactPoint", "@id": "https://tcc.group/cookie-settings/#contact-point", "contactType": "Data protection", "email": "dataprotection@tcc.group", "telephone": "020 3772 7230" } ] } ``` ### Awards & Recognition - URL: https://tcc.group/awards-recognition/ - Published: 2026-08-01 - Modified: 2026-09-03 # Recognised for compliance excellence since 2013 Over a decade of industry awards reflecting our commitment to outstanding compliance consultancy, regulatory innovation, and the people who make it happen. ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/awards-recognition/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Awards & Recognition", "item": "https://tcc.group/awards-recognition/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/awards-recognition/#webpage", "url": "https://tcc.group/awards-recognition/", "name": "Awards & Recognition", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-08-01T07:21:35+01:00", "dateModified": "2026-09-03T14:08:40+01:00", "breadcrumb": { "@id": "https://tcc.group/awards-recognition/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "WebPageElement", "@id": "https://tcc.group/awards-recognition/#page-content", "headline": "Awards & Recognition", "text": "Recognised for compliance excellence since 2013\n\nOver a decade of industry awards reflecting our commitment to outstanding compliance consultancy, regulatory innovation, and the people who make it happen.", "position": 1, "isPartOf": { "@id": "https://tcc.group/awards-recognition/#webpage" }, "inLanguage": "en-GB" } ] } ``` ### Careers - URL: https://tcc.group/careers/ - Published: 2026-08-01 - Modified: 2026-08-02 A career with TCC Group is an opportunity to solve meaningful regulatory problems alongside people who understand financial services, operational delivery and the importance of better customer outcomes. ## Work that has a clear purpose Our clients turn to us when the issue matters: a regulatory review, a complex remediation programme, a change in conduct expectations, a need for specialist capacity or a requirement to improve oversight through technology. The work calls for sound judgement, curiosity and the ability to turn detailed regulation into practical action. Roles across the group can include regulatory consulting, managed service delivery, programme and project leadership, quality assurance, data and technology, business operations and specialist resourcing. Opportunities vary over time and may sit within TCC, Recordsure or Momenta. ## How we work together - **Be evidence-led:** understand the facts before reaching a conclusion. - **Make compliance practical:** connect regulatory intent to decisions, controls and customer experience. - **Share expertise:** help colleagues and clients build lasting capability. - **Take ownership:** communicate clearly and follow work through to a defensible outcome. ## Finding current opportunities Current vacancies and associate opportunities are published through the relevant TCC Group company channels. Role descriptions set out the employing company, location or working pattern, required experience and application process. We do not ask applicants to submit sensitive identity or financial information through this website. TCC Group values relevant experience and different professional perspectives. Recruitment decisions should be based on the requirements of the role and a fair assessment of each applicant's capability. Applicants who need a reasonable adjustment should use the contact route stated in the vacancy so the recruitment team can support the process. ## Professional development Regulation, technology and customer expectations continue to change, so learning is part of delivery rather than a separate exercise. Colleagues develop through project experience, feedback, shared methods and exposure to specialists across the group. We expect people to ask careful questions, explain their reasoning and raise concerns early. In return, they should have the context and support needed to make sound decisions. The result is stronger individual judgement and a more consistent service for clients. ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/careers/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Careers", "item": "https://tcc.group/careers/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/careers/#webpage", "url": "https://tcc.group/careers/", "name": "Careers", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-08-01T07:21:35+01:00", "dateModified": "2026-08-02T22:12:06+01:00", "breadcrumb": { "@id": "https://tcc.group/careers/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "WebPageElement", "@id": "https://tcc.group/careers/#page-content", "headline": "Careers", "text": "A career with TCC Group is an opportunity to solve meaningful regulatory problems alongside people who understand financial services, operational delivery and the importance of better customer outcomes.\n\nWork that has a clear purpose\n\nOur clients turn to us when the issue matters: a regulatory review, a complex remediation programme, a change in conduct expectations, a need for specialist capacity or a requirement to improve oversight through technology. The work calls for sound judgement, curiosity and the ability to turn detailed regulation into practical action.\n\nRoles across the group can include regulatory consulting, managed service delivery, programme and project leadership, quality assurance, data and technology, business operations and specialist resourcing. Opportunities vary over time and may sit within TCC, Recordsure or Momenta.\n\nHow we work together\n\n\u2022 Be evidence-led: understand the facts before reaching a conclusion.\n\u2022 Make compliance practical: connect regulatory intent to decisions, controls and customer experience.\n\u2022 Share expertise: help colleagues and clients build lasting capability.\n\u2022 Take ownership: communicate clearly and follow work through to a defensible outcome.\n\nFinding current opportunities\n\nCurrent vacancies and associate opportunities are published through the relevant TCC Group company channels. Role descriptions set out the employing company, location or working pattern, required experience and application process. We do not ask applicants to submit sensitive identity or financial information through this website.\n\nTCC Group values relevant experience and different professional perspectives. Recruitment decisions should be based on the requirements of the role and a fair assessment of each applicant's capability. Applicants who need a reasonable adjustment should use the contact route stated in the vacancy so the recruitment team can support the process.\n\nProfessional development\n\nRegulation, technology and customer expectations continue to change, so learning is part of delivery rather than a separate exercise. Colleagues develop through project experience, feedback, shared methods and exposure to specialists across the group. We expect people to ask careful questions, explain their reasoning and raise concerns early. In return, they should have the context and support needed to make sound decisions. The result is stronger individual judgement and a more consistent service for clients.", "position": 1, "isPartOf": { "@id": "https://tcc.group/careers/#webpage" }, "inLanguage": "en-GB" } ] } ``` ### Meet the Team - URL: https://tcc.group/meet-the-team/ - Published: 2026-08-01 - Modified: 2026-08-02 TCC Group brings together regulatory specialists, programme leaders, operational experts, technologists and experienced associates. Clients get a team shaped around the challenge rather than a fixed consulting model. ## A multidisciplinary compliance team Effective regulatory work rarely sits within one discipline. A Consumer Duty review may need customer-outcome specialists, data analysis and governance expertise. A remediation programme may also require methodology design, operational delivery, quality assurance and clear reporting. Our group model connects those capabilities while keeping accountability clear. TCC colleagues lead advisory and managed compliance engagements. Recordsure teams develop and apply AI-enabled monitoring and assurance technology. Momenta connects firms with specialist professionals and scalable delivery teams. Together, they provide continuity from initial diagnosis through implementation and ongoing evidence. ## What clients can expect - People with relevant regulatory, sector and delivery experience. - A named team with clear responsibilities and escalation routes. - Direct communication about progress, risk, evidence and decisions. - Knowledge transfer that strengthens the client team after the engagement. ## Editorial expertise Our published insights are reviewed by the TCC Group Editorial Team, drawing on more than 25 years of FCA market experience. The team focuses on what regulatory developments mean in practice: the decisions firms need to make, the evidence they should retain and the customer outcomes they need to monitor. Individual engagement teams vary according to scope, timing and required expertise. This avoids presenting a static directory that may quickly become inaccurate and lets clients meet the people responsible for their work at the right point in the process. ## How teams are selected Team selection starts with the outcome and the evidence required, not a predetermined hierarchy. We consider the regulatory subject, sector, scale, delivery timetable, technology needs and the client capability that will remain after handover. That may call for a small senior advisory team, a blended programme with managed operations, or specialist professionals embedded alongside the client. Clear roles and proportionate governance help every contributor understand where decisions sit and how their work connects to the overall outcome. ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/meet-the-team/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Meet the Team", "item": "https://tcc.group/meet-the-team/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/meet-the-team/#webpage", "url": "https://tcc.group/meet-the-team/", "name": "Meet the Team", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-08-01T07:21:34+01:00", "dateModified": "2026-08-02T22:12:06+01:00", "breadcrumb": { "@id": "https://tcc.group/meet-the-team/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "WebPageElement", "@id": "https://tcc.group/meet-the-team/#page-content", "headline": "Meet the Team", "text": "TCC Group brings together regulatory specialists, programme leaders, operational experts, technologists and experienced associates. Clients get a team shaped around the challenge rather than a fixed consulting model.\n\nA multidisciplinary compliance team\n\nEffective regulatory work rarely sits within one discipline. A Consumer Duty review may need customer-outcome specialists, data analysis and governance expertise. A remediation programme may also require methodology design, operational delivery, quality assurance and clear reporting. Our group model connects those capabilities while keeping accountability clear.\n\nTCC colleagues lead advisory and managed compliance engagements. Recordsure teams develop and apply AI-enabled monitoring and assurance technology. Momenta connects firms with specialist professionals and scalable delivery teams. Together, they provide continuity from initial diagnosis through implementation and ongoing evidence.\n\nWhat clients can expect\n\n\u2022 People with relevant regulatory, sector and delivery experience.\n\u2022 A named team with clear responsibilities and escalation routes.\n\u2022 Direct communication about progress, risk, evidence and decisions.\n\u2022 Knowledge transfer that strengthens the client team after the engagement.\n\nEditorial expertise\n\nOur published insights are reviewed by the TCC Group Editorial Team, drawing on more than 25 years of FCA market experience. The team focuses on what regulatory developments mean in practice: the decisions firms need to make, the evidence they should retain and the customer outcomes they need to monitor.\n\nIndividual engagement teams vary according to scope, timing and required expertise. This avoids presenting a static directory that may quickly become inaccurate and lets clients meet the people responsible for their work at the right point in the process.\n\nHow teams are selected\n\nTeam selection starts with the outcome and the evidence required, not a predetermined hierarchy. We consider the regulatory subject, sector, scale, delivery timetable, technology needs and the client capability that will remain after handover. That may call for a small senior advisory team, a blended programme with managed operations, or specialist professionals embedded alongside the client. Clear roles and proportionate governance help every contributor understand where decisions sit and how their work connects to the overall outcome.", "position": 1, "isPartOf": { "@id": "https://tcc.group/meet-the-team/#webpage" }, "inLanguage": "en-GB" } ] } ``` ### About TCC Group - URL: https://tcc.group/about-tcc-group/ - Published: 2026-08-01 - Modified: 2026-08-02 TCC Group is a specialist compliance partner for FCA-regulated firms. We bring together regulatory advice, managed services, specialist resourcing and compliance technology so organisations can understand regulatory expectations, deliver change and evidence better customer outcomes. ## Compliance expertise in one group For more than 25 years, our teams have supported regulated businesses through complex conduct, risk and operational challenges. Our work spans financial crime, complaints and claims, redress and remediation, Consumer Duty, Section 166 reviews, vulnerable customers, advice quality and regulatory transformation. We work across wealth management and financial advice, pensions, payments and fintech, banking, lending, insurance, motor finance and utilities. The group combines three complementary specialists. TCC provides regulatory advisory, outsourced compliance and managed programmes. Recordsure provides AI-enabled compliance technology for monitoring, quality assurance and evidencing outcomes. Momenta provides experienced contingent professionals and delivery teams that can be mobilised at pace. ## How we work - **Understand the challenge:** establish the regulatory context, customer impact and evidence base. - **Design the response:** build a proportionate approach with clear governance, controls and measures. - **Deliver with confidence:** combine specialists, managed capacity and technology around the required outcome. - **Evidence sustainable improvement:** leave firms with transparent reporting, stronger capability and defensible records. Our role can range from independent advice on a defined issue to ownership of a large delivery programme. In every case, the aim is the same: practical compliance that works for customers, stands up to scrutiny and becomes part of how the organisation operates. ## What good delivery means Good delivery is specific and testable. At the outset, we agree the intended outcome, decision rights, dependencies and evidence needed to demonstrate progress. During delivery, we make risks visible and adapt the plan when facts change. At handover, clients should understand not only what was completed, but how to operate the resulting controls, monitor performance and respond when outcomes fall outside tolerance. That combination of expertise, ownership and usable evidence is central to the way TCC Group works. ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/about-tcc-group/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "About TCC Group", "item": "https://tcc.group/about-tcc-group/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/about-tcc-group/#webpage", "url": "https://tcc.group/about-tcc-group/", "name": "About TCC Group", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-08-01T07:21:34+01:00", "dateModified": "2026-08-02T22:12:06+01:00", "breadcrumb": { "@id": "https://tcc.group/about-tcc-group/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "WebPageElement", "@id": "https://tcc.group/about-tcc-group/#page-content", "headline": "About TCC Group", "text": "TCC Group is a specialist compliance partner for FCA-regulated firms. We bring together regulatory advice, managed services, specialist resourcing and compliance technology so organisations can understand regulatory expectations, deliver change and evidence better customer outcomes.\n\nCompliance expertise in one group\n\nFor more than 25 years, our teams have supported regulated businesses through complex conduct, risk and operational challenges. Our work spans financial crime, complaints and claims, redress and remediation, Consumer Duty, Section 166 reviews, vulnerable customers, advice quality and regulatory transformation. We work across wealth management and financial advice, pensions, payments and fintech, banking, lending, insurance, motor finance and utilities.\n\nThe group combines three complementary specialists. TCC provides regulatory advisory, outsourced compliance and managed programmes. Recordsure provides AI-enabled compliance technology for monitoring, quality assurance and evidencing outcomes. Momenta provides experienced contingent professionals and delivery teams that can be mobilised at pace.\n\nHow we work\n\n\u2022 Understand the challenge: establish the regulatory context, customer impact and evidence base.\n\u2022 Design the response: build a proportionate approach with clear governance, controls and measures.\n\u2022 Deliver with confidence: combine specialists, managed capacity and technology around the required outcome.\n\u2022 Evidence sustainable improvement: leave firms with transparent reporting, stronger capability and defensible records.\n\nOur role can range from independent advice on a defined issue to ownership of a large delivery programme. In every case, the aim is the same: practical compliance that works for customers, stands up to scrutiny and becomes part of how the organisation operates.\n\nWhat good delivery means\n\nGood delivery is specific and testable. At the outset, we agree the intended outcome, decision rights, dependencies and evidence needed to demonstrate progress. During delivery, we make risks visible and adapt the plan when facts change. At handover, clients should understand not only what was completed, but how to operate the resulting controls, monitor performance and respond when outcomes fall outside tolerance. That combination of expertise, ownership and usable evidence is central to the way TCC Group works.", "position": 1, "isPartOf": { "@id": "https://tcc.group/about-tcc-group/#webpage" }, "inLanguage": "en-GB" } ] } ``` ### Vulnerable Customers - URL: https://tcc.group/vulnerable-customers/ - Published: 2026-07-31 - Modified: 2026-09-03 #### Can you prove vulnerable customers are receiving good outcomes? The FCA expects firms to do more than identify vulnerability. They must demonstrate that vulnerable customers receive appropriate support, can access products and services effectively, understand communications and achieve outcomes comparable to other customers. TCC helps firms assess, design and strengthen vulnerability frameworks, customer journeys, governance, management information and outcome monitoring. ![Vulnerable customers icons](https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/1617ad9c872042efaf450aff9f4b1795/thumbnail-320-07feb0e32f9964d82f0db395c53eb25de2443ebbeb9525eacccd1bef9ba2c761.png) #### Summary card TCC helps firms strengthen vulnerability frameworks, customer journeys, outcome monitoring and governance to evidence good outcomes for vulnerable customers. #### Relevant sectors - [Banking](https://tcc.group/sectors/banking/) - [General Insurance & Protection](https://tcc.group/sectors/general-insurance-protection/) - [Lending & Consumer Credit](https://tcc.group/sectors/lending-consumer-credit/) - [Motor Finance](https://tcc.group/sectors/motor-finance/) - [Payments & FinTech](https://tcc.group/sectors/payments-fintech/) - [Pensions & Retirement Income](https://tcc.group/sectors/pensions-retirement-income/) - [Utilities](https://tcc.group/sectors/utilities/) - [Wealth Management & Financial Advice](https://tcc.group/sectors/wealth-management-financial-advice/) #### Frequently asked questions ##### What does the FCA mean by a vulnerable customer? The FCA defines vulnerability as a customer who, due to their personal circumstances, is especially susceptible to harm, particularly when a firm is not acting with appropriate levels of care. ##### How does Consumer Duty relate to vulnerable customers? Consumer Duty reinforces the obligation for firms to deliver good outcomes for all customers, including those in vulnerable circumstances. Firms should be able to demonstrate that vulnerable customers are receiving appropriate support and are not experiencing avoidable harm.  ##### What are the most common weaknesses firms identify in vulnerability reviews? Common issues include inconsistent identification processes, poor recording of vulnerability characteristics, weak management information, ineffective customer journeys, insufficient colleague training and limited evidence of customer outcomes.  ##### How can firms evidence good outcomes for vulnerable customers? Firms should combine customer outcome testing, management information, customer journey reviews, complaints analysis, quality assurance and governance reporting to understand whether vulnerable customers are receiving the support they need.  ##### How often should firms review their vulnerability framework? The FCA expects firms to keep vulnerability arrangements under regular review. Reviews should be undertaken whenever significant regulatory, business, customer or operational changes occur and should form part of wider Consumer Duty governance.  ##### Can TCC assess customer journeys through a vulnerability lens? Yes. We review end-to-end customer journeys to identify barriers, friction points, communication weaknesses and support gaps that may disproportionately affect vulnerable customers.  ##### Can TCC help improve vulnerability governance and board reporting? Yes. We help firms develop meaningful management information, outcome metrics and board reporting frameworks that provide clear oversight of vulnerability risks and customer outcomes.  ##### Which sectors does TCC support? We support firms across wealth management, pensions, banking, consumer credit, payments, insurance, motor finance and utilities, tailoring our reviews to sector-specific customer risks and regulatory expectations.  - Reviewed by: TCC Group regulatory specialists, Regulatory compliance specialists **Last reviewed:** 2026-09-03 #### Concerned that vulnerable customers may be falling through the gaps? Our specialists help firms create practical frameworks that improve customer outcomes and regulatory confidence. [Get in touch](https://tcc.group/talk-to-us/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/vulnerable-customers/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Vulnerable Customers", "item": "https://tcc.group/vulnerable-customers/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/vulnerable-customers/#webpage", "url": "https://tcc.group/vulnerable-customers/", "name": "Vulnerable Customers", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-07-31T10:05:53+01:00", "dateModified": "2026-09-03T00:00:00+00:00", "breadcrumb": { "@id": "https://tcc.group/vulnerable-customers/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] }, "lastReviewed": "2026-09-03" }, { "@type": "Service", "@id": "https://tcc.group/vulnerable-customers/#service", "name": "Vulnerable Customers", "provider": { "@id": "https://tcc.group/#organization" }, "areaServed": "GB", "url": "https://tcc.group/vulnerable-customers/", "isPartOf": { "@id": "https://tcc.group/vulnerable-customers/#webpage" }, "description": "The FCA expects firms to do more than identify vulnerability. They must demonstrate that vulnerable customers receive appropriate support, can access products and services effectively, understand communications and achieve outcomes comparable to other customers. TCC helps firms assess, design and strengthen vulnerability frameworks, customer journeys, governance, management information and outcome monitoring.", "audience": [ { "@type": "Audience", "audienceType": "Banking", "name": "Banking", "url": "https://tcc.group/sectors/banking/" }, { "@type": "Audience", "audienceType": "General Insurance & Protection", "name": "General Insurance & Protection", "url": "https://tcc.group/sectors/general-insurance-protection/" }, { "@type": "Audience", "audienceType": "Lending & Consumer Credit", "name": "Lending & Consumer Credit", "url": "https://tcc.group/sectors/lending-consumer-credit/" }, { "@type": "Audience", "audienceType": "Motor Finance", "name": "Motor Finance", "url": "https://tcc.group/sectors/motor-finance/" }, { "@type": "Audience", "audienceType": "Payments & FinTech", "name": "Payments & FinTech", "url": "https://tcc.group/sectors/payments-fintech/" }, { "@type": "Audience", "audienceType": "Pensions & Retirement Income", "name": "Pensions & Retirement Income", "url": "https://tcc.group/sectors/pensions-retirement-income/" }, { "@type": "Audience", "audienceType": "Utilities", "name": "Utilities", "url": "https://tcc.group/sectors/utilities/" }, { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/sectors/wealth-management-financial-advice/" } ], "disambiguatingDescription": "30+ Years regulatory expertise \u2014 Supporting FCA-regulated firms improve vulnerable customer outcomes. Outcome Evidence \u2014 Demonstrating vulnerable customers receive appropriate support and achieve good outcomes. Customer Journeys \u2014 Assessing vulnerability risks across every stage of the customer lifecycle. Governance & Oversight \u2014 Helping boards monitor vulnerability risks and turn insights into meaningful action.", "additionalProperty": [ { "@type": "PropertyValue", "@id": "https://tcc.group/vulnerable-customers/#fact-1", "name": "Citable fact 1", "value": "30+ Years regulatory expertise", "description": "30+ Years regulatory expertise \u2014 Supporting FCA-regulated firms improve vulnerable customer outcomes." }, { "@type": "PropertyValue", "@id": "https://tcc.group/vulnerable-customers/#fact-2", "name": "Citable fact 2", "value": "Outcome Evidence", "description": "Outcome Evidence \u2014 Demonstrating vulnerable customers receive appropriate support and achieve good outcomes." }, { "@type": "PropertyValue", "@id": "https://tcc.group/vulnerable-customers/#fact-3", "name": "Citable fact 3", "value": "Customer Journeys", "description": "Customer Journeys \u2014 Assessing vulnerability risks across every stage of the customer lifecycle." }, { "@type": "PropertyValue", "@id": "https://tcc.group/vulnerable-customers/#fact-4", "name": "Citable fact 4", "value": "Governance & Oversight", "description": "Governance & Oversight \u2014 Helping boards monitor vulnerability risks and turn insights into meaningful action." } ], "alternateName": "Vulnerable Customers", "serviceType": [ "Advisory", "Managed Services", "Specialist Resourcing", "Tech-enabled Compliance" ], "abstract": "TCC helps firms strengthen vulnerability frameworks, customer journeys, outcome monitoring and governance to evidence good outcomes for vulnerable customers.", "image": { "@type": "ImageObject", "@id": "https://tcc.group/vulnerable-customers/#card-image", "url": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/1617ad9c872042efaf450aff9f4b1795/thumbnail-320-07feb0e32f9964d82f0db395c53eb25de2443ebbeb9525eacccd1bef9ba2c761.png" }, "potentialAction": { "@type": "ContactAction", "name": "Get in touch", "target": { "@type": "EntryPoint", "urlTemplate": "/talk-to-us/" } } }, { "@type": "Person", "@id": "https://tcc.group/vulnerable-customers/#practice-lead", "name": "TCC Group regulatory specialists", "worksFor": { "@id": "https://tcc.group/#organization" }, "jobTitle": "Regulatory compliance specialists" }, { "@type": "FAQPage", "@id": "https://tcc.group/vulnerable-customers/#faqpage", "isPartOf": { "@id": "https://tcc.group/vulnerable-customers/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What does the FCA mean by a vulnerable customer?", "acceptedAnswer": { "@type": "Answer", "text": "The FCA defines vulnerability as a customer who, due to their personal circumstances, is especially susceptible to harm, particularly when a firm is not acting with appropriate levels of care." } }, { "@type": "Question", "name": "How does Consumer Duty relate to vulnerable customers?", "acceptedAnswer": { "@type": "Answer", "text": "Consumer Duty reinforces the obligation for firms to deliver good outcomes for all customers, including those in vulnerable circumstances. Firms should be able to\u00a0demonstrate\u00a0that vulnerable customers are receiving\u00a0appropriate support\u00a0and are not experiencing avoidable harm.\u00a0" } }, { "@type": "Question", "name": "What are the most common weaknesses firms identify in vulnerability reviews?", "acceptedAnswer": { "@type": "Answer", "text": "Common issues include inconsistent identification processes, poor recording of vulnerability characteristics, weak management information, ineffective customer journeys, insufficient colleague\u00a0training\u00a0and limited evidence of customer outcomes.\u00a0" } }, { "@type": "Question", "name": "How can firms evidence good outcomes for vulnerable customers?", "acceptedAnswer": { "@type": "Answer", "text": "Firms should combine customer outcome testing, management information, customer journey reviews, complaints analysis, quality assurance and governance reporting to understand whether vulnerable customers are receiving the support they need.\u00a0" } }, { "@type": "Question", "name": "How often should firms review their vulnerability framework?", "acceptedAnswer": { "@type": "Answer", "text": "The FCA expects firms to keep vulnerability arrangements under regular review. Reviews should be undertaken whenever significant regulatory, business, customer or operational changes occur and should form part of wider Consumer Duty governance.\u00a0" } }, { "@type": "Question", "name": "Can TCC assess customer journeys through a vulnerability lens?", "acceptedAnswer": { "@type": "Answer", "text": "Yes. We review end-to-end customer journeys to\u00a0identify\u00a0barriers, friction points, communication\u00a0weaknesses\u00a0and support gaps that may disproportionately affect vulnerable customers.\u00a0" } }, { "@type": "Question", "name": "Can TCC help improve vulnerability governance and board reporting?", "acceptedAnswer": { "@type": "Answer", "text": "Yes. We help firms develop meaningful management information, outcome metrics and board reporting frameworks that provide clear oversight of vulnerability risks and customer outcomes.\u00a0" } }, { "@type": "Question", "name": "Which sectors does TCC support?", "acceptedAnswer": { "@type": "Answer", "text": "We support firms across wealth management, pensions, banking, consumer credit, payments, insurance, motor\u00a0finance\u00a0and utilities, tailoring our reviews to sector-specific customer risks and regulatory expectations.\u00a0" } } ] } ] } ``` ### Consolidation, Acquisition & Regulatory Due Diligence - URL: https://tcc.group/consolidation-acquisition-regulatory-due-diligence/ - Published: 2026-07-31 - Modified: 2026-09-03 #### Growing through acquisition? Make sure regulatory risk doesn't become tomorrow's liability. TCC helps consolidators, acquirers and investors assess, acquire and integrate FCA-regulated businesses. We support every stage of the acquisition lifecycle – we provide regulatory due diligence, integration planning and post-acquisition assurance to help organisations understand risk, identify liabilities and achieve successful integration outcomes.  ![Consolidation, acquisition and regulatory due diligence icon](https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/a783aa4220634d2b96f30e75c5208c2d/thumbnail-320-aca140dc84231328132e8a6bd0a6b72d1920a2ae131a842f20e5b617c40eb761.png) #### Summary card TCC supports regulatory due diligence, acquisition risk assessment, Consumer Duty reviews, integration planning and post-acquisition assurance for FCA-regulated firms. #### Relevant sectors - [Banking](https://tcc.group/sectors/banking/) - [General Insurance & Protection](https://tcc.group/sectors/general-insurance-protection/) - [Lending & Consumer Credit](https://tcc.group/sectors/lending-consumer-credit/) - [Motor Finance](https://tcc.group/sectors/motor-finance/) - [Payments & FinTech](https://tcc.group/sectors/payments-fintech/) - [Pensions & Retirement Income](https://tcc.group/sectors/pensions-retirement-income/) - [Wealth Management & Financial Advice](https://tcc.group/sectors/wealth-management-financial-advice/) #### Frequently asked questions ##### What is regulatory due diligence in a financial services acquisition? Regulatory due diligence assesses whether a target firm has potential compliance, conduct, governance, Consumer Duty, prudential or customer outcome risks that could affect future value, integration complexity or regulatory exposure. ##### Why is regulatory due diligence important for consolidators? The FCA has stated that firms should undertake proportionate due diligence that genuinely identifies and evaluates risk, rather than relying on a tick-box approach. Effective due diligence helps prevent hidden liabilities and integration issues from emerging after completion.   ##### Can TCC review advice quality before an acquisition? Yes. Our specialists undertake advice file reviews, suitability assessments and provisional redress calculations to help buyers understand potential liabilities before entering into a transaction. ##### Can TCC help integrate acquired firms? Yes. We support integration planning, governance enhancement, client novation, compliance centralisation, operating model design and regulatory oversight throughout the post-acquisition period.  ##### Does TCC support Change in Control applications and FCA engagement? Yes. Our specialists support firms with FCA communications, Change in Control applications and broader regulatory engagement activities associated with acquisition programmes. ##### How does Consumer Duty affect acquisitions? Acquirers need to understand whether target firms are delivering good customer outcomes and whether legacy advice, products or servicing arrangements could create future remediation risk. The FCA has reinforced the importance of customer outcomes throughout the consolidation lifecycle. ##### Can TCC help identify legacy liabilities? Yes. We assess historic advice risks, remediation exposure, governance weaknesses and operational issues that could affect value after acquisition. We can also help firms design and implement remediation programmes where required. ##### What sectors does TCC support? We support consolidators operating across wealth management, financial advice, pensions, banking, consumer credit, payments and insurance markets, providing both transaction support and post-acquisition regulatory assurance. - Reviewed by: TCC Group regulatory specialists, Regulatory compliance specialists **Last reviewed:** 2026-09-03 #### Planning your next acquisition? Regulatory due diligence is only the beginning. Talk to our consolidation specialists about reducing transaction risk, protecting customer outcomes and building a scalable operating model for future growth.  [Get in touch](https://tcc.group/talk-to-us/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/consolidation-acquisition-regulatory-due-diligence/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Consolidation, Acquisition & Regulatory Due Diligence", "item": "https://tcc.group/consolidation-acquisition-regulatory-due-diligence/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/consolidation-acquisition-regulatory-due-diligence/#webpage", "url": "https://tcc.group/consolidation-acquisition-regulatory-due-diligence/", "name": "Consolidation, Acquisition & Regulatory Due Diligence", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-07-31T10:05:53+01:00", "dateModified": "2026-09-03T00:00:00+00:00", "breadcrumb": { "@id": "https://tcc.group/consolidation-acquisition-regulatory-due-diligence/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] }, "lastReviewed": "2026-09-03" }, { "@type": "Service", "@id": "https://tcc.group/consolidation-acquisition-regulatory-due-diligence/#service", "name": "Consolidation, Acquisition & Regulatory Due Diligence", "provider": { "@id": "https://tcc.group/#organization" }, "areaServed": "GB", "url": "https://tcc.group/consolidation-acquisition-regulatory-due-diligence/", "isPartOf": { "@id": "https://tcc.group/consolidation-acquisition-regulatory-due-diligence/#webpage" }, "description": "TCC helps consolidators, acquirers and investors assess,\u00a0acquire\u00a0and\u00a0integrate FCA-regulated businesses. 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Our specialists support firms with FCA communications, Change in Control applications and broader regulatory engagement activities associated with acquisition programmes." } }, { "@type": "Question", "name": "How does Consumer Duty affect acquisitions?", "acceptedAnswer": { "@type": "Answer", "text": "Acquirers need to understand whether target firms are delivering good customer outcomes and whether legacy advice, products or servicing arrangements could create future remediation risk. The FCA has reinforced the importance of customer outcomes throughout the consolidation lifecycle." } }, { "@type": "Question", "name": "Can TCC help identify legacy liabilities?", "acceptedAnswer": { "@type": "Answer", "text": "Yes. We assess historic advice risks, remediation exposure, governance weaknesses and operational issues that could affect value after acquisition. We can also help firms design and implement remediation programmes where required." } }, { "@type": "Question", "name": "What sectors does TCC support?", "acceptedAnswer": { "@type": "Answer", "text": "We support consolidators operating across wealth management, financial advice, pensions, banking, consumer credit, payments and insurance markets, providing both transaction support and post-acquisition regulatory assurance." } } ] } ] } ``` ### Regulatory Change & Transformation - URL: https://tcc.group/regulatory-change-transformation/ - Published: 2026-07-31 - Modified: 2026-09-03 #### How do firms deliver regulatory change while strengthening governance, controls and operational resilience? Regulatory change often requires more than regulatory interpretation. Firms must mobilise programmes, redesign operating models, strengthen governance frameworks, enhance controls and implement change across people, processes and technology. TCC helps organisations deliver complex regulatory and business transformation programmes, providing the leadership, expertise and delivery capability needed to move from planning to implementation with confidence. ![Regulatory -change-and-transformation](https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/52e0e2a153534bf5b1af7eea77b9f9a3/thumbnail-320-5554d98158e966584164065b8da1935d1d03dffe02b55efc00ba99d8f2dd1180.png) #### Summary card TCC helps financial services firms deliver regulatory change, operating model redesign, governance improvement, operational resilience and transformation programmes. #### Relevant sectors - [Banking](https://tcc.group/sectors/banking/) - [General Insurance & Protection](https://tcc.group/sectors/general-insurance-protection/) - [Lending & Consumer Credit](https://tcc.group/sectors/lending-consumer-credit/) - [Motor Finance](https://tcc.group/sectors/motor-finance/) - [Payments & FinTech](https://tcc.group/sectors/payments-fintech/) - [Pensions & Retirement Income](https://tcc.group/sectors/pensions-retirement-income/) - [Utilities](https://tcc.group/sectors/utilities/) - [Wealth Management & Financial Advice](https://tcc.group/sectors/wealth-management-financial-advice/) #### Frequently asked questions ##### What is regulatory transformation? Regulatory transformation is the process of implementing regulatory requirements in a way that improves governance, controls, operating models, customer outcomes and organisational performance.  ##### How is regulatory transformation different from regulatory compliance? Compliance focuses on meeting regulatory requirements. Transformation focuses on embedding those requirements into processes, systems and culture to create sustainable business improvement.  ##### What types of regulatory change programmes does TCC support? We support Consumer Duty programmes, governance transformation, operating model redesign, remediation initiatives, conduct risk programmes, regulatory change projects and large-scale business transformation. ##### Can TCC provide interim leadership for regulatory change programmes? Yes. We provide change and transformation leaders, senior compliance leaders, project delivery leaders and specialist regulatory experts who can integrate quickly into existing teams. ##### Can TCC build and manage delivery teams? Yes. We can deploy programme leaders, project managers, business analysts, compliance professionals and specialist resources to supplement existing teams or build complete delivery functions. ##### How can firms ensure regulatory change delivers business value? Successful firms focus not only on compliance but also on governance, customer outcomes, operational resilience and long-term capability. Regulatory change should strengthen the business, not simply satisfy regulatory requirements. ##### Which sectors does TCC support? We support organisations across banking, payments, lending, wealth management, pensions, insurance and motor finance, helping firms navigate both regulatory change and business transformation. ##### Why do firms use TCC for regulatory transformation? TCC combines regulatory expertise, transformation leadership, specialist resourcing and delivery capability. This allows firms to move beyond strategy and achieve measurable outcomes at pace. - Reviewed by: TCC Group regulatory specialists, Regulatory compliance specialists **Last reviewed:** 2026-09-03 #### Facing a major regulatory change programme? Whether you're implementing new regulation, redesigning operating models or leading organisation-wide transformation, our specialists can help you move from strategy to execution with confidence. [Get in touch](https://tcc.group/talk-to-us/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/regulatory-change-transformation/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Regulatory Change & Transformation", "item": "https://tcc.group/regulatory-change-transformation/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/regulatory-change-transformation/#webpage", "url": "https://tcc.group/regulatory-change-transformation/", "name": "Regulatory Change & Transformation", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-07-31T10:05:52+01:00", "dateModified": "2026-09-03T00:00:00+00:00", "breadcrumb": { "@id": "https://tcc.group/regulatory-change-transformation/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] }, "lastReviewed": "2026-09-03" }, { "@type": "Service", "@id": "https://tcc.group/regulatory-change-transformation/#service", "name": "Regulatory Change & Transformation", "provider": { "@id": "https://tcc.group/#organization" }, "areaServed": "GB", "url": "https://tcc.group/regulatory-change-transformation/", "isPartOf": { "@id": "https://tcc.group/regulatory-change-transformation/#webpage" }, "description": "Regulatory change often requires more than regulatory interpretation. Firms must mobilise programmes, redesign operating models, strengthen governance frameworks, enhance\u00a0controls\u00a0and implement change across people,\u00a0processes\u00a0and technology. 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We can deploy programme leaders, project managers, business analysts, compliance professionals and specialist resources to supplement existing teams or build complete delivery functions." } }, { "@type": "Question", "name": "How can firms ensure regulatory change delivers business value?", "acceptedAnswer": { "@type": "Answer", "text": "Successful firms focus not only on compliance but also on governance, customer outcomes, operational resilience and long-term capability. 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The FCA expects firms to demonstrate good customer outcomes, not simply compliance. TCC helps organisations evidence outcomes, assess customer journeys, strengthen governance and monitor foreseeable harm. We support boards with the insight and assurance needed to oversee Products & Services, Price & Value, Consumer Understanding and Consumer Support.  ![Consumer duty icon](https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/aa644995110f44ed9a0610885305a717/thumbnail-320-c8984f3dac83375ef31ae33ae54a4f454e8be44fa67d019fe0bf4a1e0e53c960.png) #### Summary card TCC helps FCA-regulated firms assess Consumer Duty, evidence good customer outcomes, strengthen governance, monitor foreseeable harm and support annual board assessments.  #### Relevant sectors - [Banking](https://tcc.group/sectors/banking/) - [General Insurance & Protection](https://tcc.group/sectors/general-insurance-protection/) - [Lending & Consumer Credit](https://tcc.group/sectors/lending-consumer-credit/) - [Motor Finance](https://tcc.group/sectors/motor-finance/) - [Payments & FinTech](https://tcc.group/sectors/payments-fintech/) - [Pensions & Retirement Income](https://tcc.group/sectors/pensions-retirement-income/) - [Utilities](https://tcc.group/sectors/utilities/) - [Wealth Management & Financial Advice](https://tcc.group/sectors/wealth-management-financial-advice/) #### Frequently asked questions ##### What does the FCA expect firms to evidence under Consumer Duty? The FCA expects firms to demonstrate that customers are receiving good outcomes in practice. This includes evidence covering products and services, price and value, consumer understanding and consumer support.  ##### What is a Consumer Duty annual assessment? A Consumer Duty annual assessment is a documented review that helps boards evaluate whether the firm's Consumer Duty arrangements are delivering good customer outcomes and identify areas for improvement.  ##### How can firms evidence good customer outcomes? Evidence may include customer outcome testing, complaints analysis, management information, vulnerability monitoring, quality assurance reviews, customer journey testing and fair value assessments.  ##### What is foreseeable harm under Consumer Duty? Foreseeable harm refers to harm that firms could reasonably anticipate customers may experience throughout the lifecycle of a product or service, and which can often be mitigated through appropriate controls, communications or support.  ##### Why are customer journeys important under Consumer Duty? Customer journeys help firms understand how customers interact with products and services in practice. Testing customer journeys can identify barriers, confusion, poor support experiences and potential outcome risks.  ##### How does Consumer Duty affect vulnerable customers? Consumer Duty reinforces the requirement to achieve good outcomes for all customers, including those in vulnerable circumstances. Firms should be able to demonstrate that vulnerable customers receive appropriate support and are not experiencing avoidable harm.  ##### How often should Consumer Duty frameworks be reviewed? Consumer Duty should be subject to ongoing monitoring and regular review. Annual assessments, significant business changes, new products, regulatory developments and changing customer needs may all trigger further reviews.  ##### How can TCC help with Consumer Duty? TCC supports firms with Consumer Duty assessments, outcome testing, customer journey reviews, fair value assessments, annual board reporting, vulnerability reviews, governance frameworks and ongoing monitoring programmes.  - Reviewed by: TCC Group regulatory specialists, Regulatory compliance specialists **Last reviewed:** 2026-09-03 #### Need confidence that your Consumer Duty framework is working in practice? Talk to our specialists about building outcome-focused frameworks that support board confidence and regulatory expectations. We help firms test outcomes, challenge assumptions and evidence compliance through robust monitoring and governance.  [Get in touch](https://tcc.group/talk-to-us/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/consumer-duty/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Consumer Duty", "item": "https://tcc.group/consumer-duty/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/consumer-duty/#webpage", "url": "https://tcc.group/consumer-duty/", "name": "Consumer Duty", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-07-31T10:05:52+01:00", "dateModified": "2026-09-03T00:00:00+00:00", "breadcrumb": { "@id": "https://tcc.group/consumer-duty/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] }, "lastReviewed": "2026-09-03" }, { "@type": "Service", "@id": "https://tcc.group/consumer-duty/#service", "name": "Consumer Duty", "provider": { "@id": "https://tcc.group/#organization" }, "areaServed": "GB", "url": "https://tcc.group/consumer-duty/", "isPartOf": { "@id": "https://tcc.group/consumer-duty/#webpage" }, "description": "The FCA expects firms to\u00a0demonstrate\u00a0good customer outcomes, not simply compliance. 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Annual assessments, significant business changes, new products, regulatory\u00a0developments\u00a0and changing customer needs may all trigger further reviews.\u00a0" } }, { "@type": "Question", "name": "How can TCC help with Consumer Duty?", "acceptedAnswer": { "@type": "Answer", "text": "TCC supports firms with Consumer Duty assessments, outcome testing, customer journey reviews, fair value assessments, annual board reporting, vulnerability reviews, governance\u00a0frameworks\u00a0and ongoing monitoring programmes.\u00a0" } } ] } ] } ``` ### Section 166, Skilled Person Reviews & FCA Intervention - URL: https://tcc.group/section-166-skilled-person-reviews-fca-intervention/ - Published: 2026-07-31 - Modified: 2026-09-03 #### Facing a Section 166 review or FCA intervention? Regulatory concerns rarely begin with a Section 166 review. More often, they start with supervisory engagement, governance weaknesses, customer outcome concerns or gaps in regulatory evidence. TCC helps firms prepare for, respond to and recover from FCA intervention through independent assurance, evidence reviews, governance assessments and practical remediation support. From early-stage regulatory concerns through to Skilled Person reviews and complex remediation programmes, we help firms reduce uncertainty, demonstrate meaningful progress and strengthen regulatory confidence. ![Section 166 icon](https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/b7415c53aacc477487a9eb183f122acf/thumbnail-320-531ae48ec8a36676b311c51f6d2a5c97ef700d1f0a9a5e1abc5eab4fac206365.png) #### Summary card TCC helps firms prepare for Section 166 reviews, Skilled Person investigations, FCA scrutiny and regulatory remediation through independent assurance and governance reviews. #### Relevant sectors - [Banking](https://tcc.group/sectors/banking/) - [General Insurance & Protection](https://tcc.group/sectors/general-insurance-protection/) - [Lending & Consumer Credit](https://tcc.group/sectors/lending-consumer-credit/) - [Motor Finance](https://tcc.group/sectors/motor-finance/) - [Payments & FinTech](https://tcc.group/sectors/payments-fintech/) - [Pensions & Retirement Income](https://tcc.group/sectors/pensions-retirement-income/) - [Wealth Management & Financial Advice](https://tcc.group/sectors/wealth-management-financial-advice/) #### Frequently asked questions ##### What is a section 166 skilled person review? A Section 166 review is an independent assessment commissioned under the Financial Services and Markets Act when the FCA requires additional assurance about specific aspects of a firm's activities, governance or controls. ##### What typically leads to a Section 166 review? Section 166 reviews may arise where the FCA has concerns relating to customer outcomes, governance, financial crime controls, advice suitability, operational resilience, complaints handling or wider conduct risks. ##### Can firms prepare for a Section 166 review? Yes. Independent assurance reviews, governance assessments and evidence testing can help firms identify weaknesses and address risks before regulatory intervention escalates.  ##### How can TCC support firms during FCA intervention? TCC helps firms assess regulatory concerns, prepare evidence, challenge assumptions where appropriate, strengthen governance and deliver practical remediation programmes.  ##### What happens after a Section 166 review? Most firms are expected to address findings through remediation activities, governance improvements, enhanced oversight and strengthened controls. The FCA may continue supervisory engagement until concerns have been addressed.  ##### Can TCC support remediation programmes following regulatory findings? Yes. We support remediation planning, programme governance, customer reviews, outcome testing, specialist resourcing and ongoing assurance activities.  ##### Does Section 166 support only apply to large financial institutions? No. FCA intervention can affect firms of all sizes across banking, lending, payments, wealth management, pensions, insurance and motor finance.  ##### How does Consumer Duty relate to FCA intervention? The FCA increasingly focuses on whether firms can evidence good customer outcomes. Weaknesses in Consumer Duty governance, customer support, fair value, consumer understanding or outcome monitoring may contribute to wider regulatory concerns.  - Reviewed by: TCC Group regulatory specialists, Regulatory compliance specialists **Last reviewed:** 2026-09-03 #### Need confidence your firm would stand up to regulatory scrutiny? We help firms identify weaknesses early, strengthen controls and how to deliver meaningful remediation. Our specialists help you prepare, engage and remediate with confidence.  [Get in touch](https://tcc.group/talk-to-us/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/section-166-skilled-person-reviews-fca-intervention/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Section 166, Skilled Person Reviews & FCA Intervention", "item": "https://tcc.group/section-166-skilled-person-reviews-fca-intervention/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/section-166-skilled-person-reviews-fca-intervention/#webpage", "url": "https://tcc.group/section-166-skilled-person-reviews-fca-intervention/", "name": "Section 166, Skilled Person Reviews & FCA Intervention", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-07-31T10:05:52+01:00", "dateModified": "2026-09-03T00:00:00+00:00", "breadcrumb": { "@id": "https://tcc.group/section-166-skilled-person-reviews-fca-intervention/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] }, "lastReviewed": "2026-09-03" }, { "@type": "Service", "@id": "https://tcc.group/section-166-skilled-person-reviews-fca-intervention/#service", "name": "Section 166, Skilled Person Reviews & FCA Intervention", "provider": { "@id": "https://tcc.group/#organization" }, "areaServed": "GB", "url": "https://tcc.group/section-166-skilled-person-reviews-fca-intervention/", "isPartOf": { "@id": "https://tcc.group/section-166-skilled-person-reviews-fca-intervention/#webpage" }, "description": "Regulatory concerns rarely begin with a Section 166 review. 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The FCA may continue supervisory engagement until concerns have been addressed.\u00a0" } }, { "@type": "Question", "name": "Can TCC support remediation programmes following regulatory findings?", "acceptedAnswer": { "@type": "Answer", "text": "Yes. We support remediation planning, programme governance, customer reviews, outcome testing, specialist\u00a0resourcing\u00a0and ongoing assurance activities.\u00a0" } }, { "@type": "Question", "name": "Does Section 166 support only apply to large financial institutions?", "acceptedAnswer": { "@type": "Answer", "text": "No. FCA intervention can affect firms of all sizes across banking, lending, payments, wealth management, pensions,\u00a0insurance\u00a0and motor finance.\u00a0" } }, { "@type": "Question", "name": "How does Consumer Duty relate to FCA intervention?", "acceptedAnswer": { "@type": "Answer", "text": "The FCA increasingly focuses on whether firms can\u00a0evidence\u00a0good customer outcomes. Weaknesses in Consumer Duty governance, customer support, fair value, consumer\u00a0understanding\u00a0or outcome monitoring may contribute to wider regulatory concerns.\u00a0" } } ] } ] } ``` ### Compliance AI, Governace & RegTech - URL: https://tcc.group/compliance-ai-regtech/ - Published: 2026-07-31 - Modified: 2026-09-03 #### How can you adopt AI in compliance without creating new regulatory risk? AI has the potential to transform compliance monitoring, quality assurance and operational efficiency, but firms must balance innovation with governance, oversight and accountability. TCC combines regulatory expertise with AI-enabled technology to help organisations improve compliance outcomes, evidence generation and operational performance. Through governance frameworks, assurance reviews and technology-enabled monitoring, we help firms adopt AI confidently and responsibly. ![TCC Compliance AI and RegTech Solution icon](https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/7ed68164b0134cb797b5daf832d79188/thumbnail-320-1923e66fcbb084a3a6ab8960551e20410e41661e6f11597940c5f266d56ff4b3.png) #### Summary card TCC helps financial services firms deliver regulatory change, operating model redesign, governance improvement, operational resilience and transformation programmes. #### Relevant sectors - [Banking](https://tcc.group/sectors/banking/) - [General Insurance & Protection](https://tcc.group/sectors/general-insurance-protection/) - [Lending & Consumer Credit](https://tcc.group/sectors/lending-consumer-credit/) - [Motor Finance](https://tcc.group/sectors/motor-finance/) - [Payments & FinTech](https://tcc.group/sectors/payments-fintech/) - [Pensions & Retirement Income](https://tcc.group/sectors/pensions-retirement-income/) - [Utilities](https://tcc.group/sectors/utilities/) - [Wealth Management & Financial Advice](https://tcc.group/sectors/wealth-management-financial-advice/) #### Frequently asked questions ##### How can AI support compliance functions? AI can help firms improve monitoring, quality assurance, evidence collection, workflow efficiency and management information, allowing teams to focus their expertise where it adds the most value. ##### What is AI governance? AI governance is the framework of policies, controls, oversight and accountability mechanisms used to ensure AI technologies operate safely, effectively and in line with regulatory expectations. ##### What does explainability mean in AI? Explainability refers to a firm's ability to understand, evidence and justify how AI-supported decisions or outputs are generated, supporting transparency and accountability. ##### Can AI improve compliance monitoring? Yes. AI can enhance monitoring activities by increasing coverage, improving consistency and providing evidence at a scale that is often difficult to achieve through manual reviews alone. ##### How can firms adopt AI responsibly? Successful adoption requires strong governance, human oversight, clear accountability, ongoing monitoring and assurance that technology remains aligned to business objectives and regulatory expectations. ##### Does TCC provide AI technology as well as advisory support? Yes. TCC combines regulatory expertise with technology-enabled compliance solutions provided through Recordsure and broader RegTech capabilities. - Reviewed by: TCC Group regulatory specialists, Regulatory compliance specialists **Last reviewed:** 2026-09-03 #### Looking to unlock the benefits of AI without increasing compliance risk? Our specialists help firms implement AI-enabled solutions that improve efficiency, strengthen oversight and support regulatory confidence. [Get in touch](https://tcc.group/talk-to-us/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/compliance-ai-regtech/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Compliance AI, Governace & RegTech", "item": "https://tcc.group/compliance-ai-regtech/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/compliance-ai-regtech/#webpage", "url": "https://tcc.group/compliance-ai-regtech/", "name": "Compliance AI, Governace & RegTech", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-07-31T10:05:51+01:00", "dateModified": "2026-09-03T00:00:00+00:00", "breadcrumb": { "@id": "https://tcc.group/compliance-ai-regtech/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] }, "lastReviewed": "2026-09-03" }, { "@type": "Service", "@id": "https://tcc.group/compliance-ai-regtech/#service", "name": "Compliance AI & RegTech", "provider": { "@id": "https://tcc.group/#organization" }, "areaServed": "GB", "url": "https://tcc.group/compliance-ai-regtech/", "isPartOf": { "@id": "https://tcc.group/compliance-ai-regtech/#webpage" }, "description": "AI has the potential to transform compliance monitoring, quality assurance and operational efficiency, but firms must balance innovation with governance, oversight and accountability. 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AI can enhance monitoring activities by increasing coverage, improving consistency and providing evidence at a scale that is often difficult to achieve through manual reviews alone." } }, { "@type": "Question", "name": "How can firms adopt AI responsibly?", "acceptedAnswer": { "@type": "Answer", "text": "Successful adoption requires strong governance, human oversight, clear accountability, ongoing monitoring and assurance that technology remains aligned to business objectives and regulatory expectations." } }, { "@type": "Question", "name": "Does TCC provide AI technology as well as advisory support?", "acceptedAnswer": { "@type": "Answer", "text": "Yes. TCC combines regulatory expertise with technology-enabled compliance solutions provided through Recordsure and broader RegTech capabilities." } } ] } ] } ``` ### Complaints & Claims Handling - URL: https://tcc.group/complaints-claims-handling/ - Published: 2026-07-31 - Modified: 2026-09-03 #### Are your complaints and claims operations equipped to handle increasing volumes and regulatory scrutiny? TCC helps firms manage complaint and claims operations at scale. From complaint backlogs, service-level pressures and quality assurance challenges to claims administration, root cause analysis and complaint transformation, we provide the expertise, capacity and governance needed to improve operational performance whilst delivering fair customer outcomes.  ![TCC Complaints icon](https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/ec2fc0ede77942a1a8e7fbd0b36de182/thumbnail-320-ff4fa90d41bc5a5a9670f3213458a7aa510d87b10095775b41de0d0fe5a941cf.png) #### Summary card TCC helps financial services firms deliver regulatory change, operating model redesign, governance improvement, operational resilience and transformation programmes. #### Relevant sectors - [Banking](https://tcc.group/sectors/banking/) - [General Insurance & Protection](https://tcc.group/sectors/general-insurance-protection/) - [Lending & Consumer Credit](https://tcc.group/sectors/lending-consumer-credit/) - [Motor Finance](https://tcc.group/sectors/motor-finance/) - [Payments & FinTech](https://tcc.group/sectors/payments-fintech/) - [Pensions & Retirement Income](https://tcc.group/sectors/pensions-retirement-income/) - [Utilities](https://tcc.group/sectors/utilities/) - [Wealth Management & Financial Advice](https://tcc.group/sectors/wealth-management-financial-advice/) #### Frequently asked questions ##### Why are complaints important under Consumer Duty? Complaints provide valuable insight into customer experiences, foreseeable harm and the effectiveness of customer support. Firms should use complaints data to identify trends, monitor outcomes and drive continuous improvement. ##### Can TCC manage complaint handling on behalf of firms? Yes. We provide fully managed complaint handling services, specialist complaint teams and operational support tailored to your requirements. ##### Can TCC help clear complaint backlogs? Yes. We can rapidly deploy experienced complaint handlers, quality reviewers and operational leads to reduce backlogs whilst maintaining quality and regulatory standards. ##### Does TCC provide complaint handling resources? Yes. Through our specialist resourcing capability, we can provide complaint handlers, team leaders, quality assurance specialists, operational managers and subject matter experts to support short-term peaks or long-term programmes. ##### How can complaint data support Consumer Duty? Complaint trends can help firms identify customer outcome risks, assess foreseeable harm, review customer journeys and improve support arrangements across the product lifecycle. ##### Can TCC support complaint transformation programmes? Yes. We help organisations redesign complaint operating models, improve governance, strengthen quality assurance frameworks and enhance management information to deliver better customer outcomes. ##### Does TCC support claims handling as well as complaints? Yes. We support both complaint and claims operations, helping firms improve consistency, quality, efficiency and regulatory compliance. ##### Can TCC support vulnerable customer reviews? Yes. Vulnerable customer considerations are embedded into our complaint and claims assessment methodologies and quality assurance frameworks. - Reviewed by: TCC Group regulatory specialists, Regulatory compliance specialists **Last reviewed:** 2026-09-03 #### Complaint volumes rising or service levels under pressure? We provide managed services, specialist resources and operational expertise to help firms respond quickly and effectively. [Get in touch](https://tcc.group/talk-to-us/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/complaints-claims-handling/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Complaints & Claims Handling", "item": "https://tcc.group/complaints-claims-handling/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/complaints-claims-handling/#webpage", "url": "https://tcc.group/complaints-claims-handling/", "name": "Complaints & Claims Handling", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-07-31T10:05:50+01:00", "dateModified": "2026-09-03T00:00:00+00:00", "breadcrumb": { "@id": "https://tcc.group/complaints-claims-handling/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] }, "lastReviewed": "2026-09-03" }, { "@type": "Service", "@id": "https://tcc.group/complaints-claims-handling/#service", "name": "Complaints & Claims Handling", "provider": { "@id": "https://tcc.group/#organization" }, "areaServed": "GB", "url": "https://tcc.group/complaints-claims-handling/", "isPartOf": { "@id": "https://tcc.group/complaints-claims-handling/#webpage" }, "description": "TCC helps firms manage complaint and claims operations at scale. 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Financial crime compliance requires more than policies and procedures. Firms need effective controls, strong governance and the ability to respond quickly as risks evolve. TCC combines specialist expertise, managed services, flexible resourcing and technology-enabled solutions to help organisations strengthen oversight, improve control effectiveness and build resilient financial crime frameworks.  ![Financial crime ICON](https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/22dc2014bcd94833ba00f32ba28bf009/thumbnail-320-c53cb083a9ca3e32f9f4c480feab36e508d2d556ba09ac1e3f8a58c5bac2e024.png) #### Summary card TCC helps firms strengthen AML, KYC, sanctions, fraud prevention and financial crime governance through advisory, managed services and remediation support.  #### When you need support Rapid growth, a control failure, regulatory scrutiny or an ageing alert population can expose gaps between documented policy and day-to-day practice. Independent support helps establish the scale of the issue and protects higher-risk decisions while corrective work proceeds. #### What we assess We examine the business-wide risk assessment, customer due diligence, screening, transaction monitoring, investigations, escalation, quality assurance and management information. Testing connects control design to customer and transaction evidence rather than relying on policy review alone. #### How delivery works Specialists can work alongside existing teams or provide a governed delivery capability. Risk-based triage, calibrated decision standards, daily quality feedback and clear capacity measures keep remediation progress separate from business-as-usual control performance. #### What you receive You receive a prioritised findings record, practical control improvements, evidence of completed testing and governance reporting that shows residual risk, accountable owners and the effect of remediation. #### Relevant sectors - [Banking](https://tcc.group/sectors/banking/) - [Lending & Consumer Credit](https://tcc.group/sectors/lending-consumer-credit/) - [Motor Finance](https://tcc.group/sectors/motor-finance/) - [Payments & FinTech](https://tcc.group/sectors/payments-fintech/) #### Frequently asked questions ##### What financial crime services does TCC provide? We support AML, KYC, sanctions, fraud prevention, transaction monitoring, governance, assurance, remediation and financial crime transformation programmes.  ##### Can TCC provide interim financial crime specialists? Yes. We provide experienced financial crime leaders, compliance professionals, subject matter experts and specialist resources to address capability gaps and support critical programmes.   ##### Can TCC help clear AML and KYC backlogs? Yes. We deliver managed remediation programmes supporting AML reviews, KYC backlogs, customer due diligence and enhanced due diligence activities.   ##### Can TCC support firms preparing for FCA scrutiny? Yes. We help firms strengthen governance, evidence controls, prepare assurance reviews and respond confidently to regulatory engagement.   ##### How can firms improve financial crime governance? Effective governance requires clear accountability, robust risk assessments, effective oversight and evidence that controls are operating as intended. TCC helps firms review and strengthen each of these areas.   ##### Does TCC provide financial crime technology solutions? Yes. We support technology-enabled workflows covering sanctions screening, customer due diligence, enhanced due diligence and AI-supported review processes with full audit trails.   ##### What sectors does TCC support? We support banking, payments, wealth management, lending, pensions, insurance and motor finance firms.  ##### Why do firms choose TCC for financial crime support? Because we combine specialist expertise, managed delivery, flexible resourcing and technology-enabled solutions to help organisations strengthen controls, improve resilience and maintain confidence under scrutiny.  - Reviewed by: TCC, Editorial Team **Last reviewed:** 2026-09-03 #### Facing increasing financial crime risk, regulatory scrutiny or operational backlogs? Our financial crime specialists provide interim leadership, managed remediation, governance expertise and technology-enabled solutions that help firms strengthen controls, improve resilience and maintain effective oversight.  [Get in touch](https://tcc.group/talk-to-us/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/financial-crime-compliance/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Financial Crime Compliance", "item": "https://tcc.group/financial-crime-compliance/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/financial-crime-compliance/#webpage", "url": "https://tcc.group/financial-crime-compliance/", "name": "Financial Crime Compliance", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-07-31T10:05:50+01:00", "dateModified": "2026-09-03T00:00:00+00:00", "breadcrumb": { "@id": "https://tcc.group/financial-crime-compliance/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] }, "lastReviewed": "2026-09-03" }, { "@type": "Service", "@id": "https://tcc.group/financial-crime-compliance/#service", "name": "Financial Crime Compliance", "provider": { "@id": "https://tcc.group/#organization" }, "areaServed": "GB", "url": "https://tcc.group/financial-crime-compliance/", "isPartOf": { "@id": "https://tcc.group/financial-crime-compliance/#webpage" }, "description": "Financial crime compliance requires more than policies and procedures. 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Testing connects control design to customer and transaction evidence rather than relying on policy review alone." }, { "@type": "WebPageElement", "@id": "https://tcc.group/financial-crime-compliance/#service-body-3", "position": 3, "about": { "@id": "https://tcc.group/financial-crime-compliance/#service" }, "isPartOf": { "@id": "https://tcc.group/financial-crime-compliance/#webpage" }, "inLanguage": "en-GB", "headline": "How delivery works", "text": "Specialists can work alongside existing teams or provide a governed delivery capability. 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We provide experienced financial crime leaders, compliance professionals, subject matter\u00a0experts\u00a0and specialist resources to address capability gaps and support critical programmes.\u00a0\u00a0" } }, { "@type": "Question", "name": "Can TCC help clear AML and KYC backlogs?", "acceptedAnswer": { "@type": "Answer", "text": "Yes. We deliver managed remediation programmes supporting AML reviews, KYC backlogs, customer due diligence and enhanced due diligence activities.\u00a0\u00a0" } }, { "@type": "Question", "name": "Can TCC support firms preparing for FCA scrutiny?", "acceptedAnswer": { "@type": "Answer", "text": "Yes. We help firms strengthen governance, evidence controls, prepare assurance reviews and respond confidently to regulatory engagement.\u00a0\u00a0" } }, { "@type": "Question", "name": "How can firms improve financial crime governance?", "acceptedAnswer": { "@type": "Answer", "text": "Effective governance requires clear accountability, robust risk assessments, effective\u00a0oversight\u00a0and evidence that controls are\u00a0operating\u00a0as intended. TCC helps firms review and strengthen each of these areas.\u00a0\u00a0" } }, { "@type": "Question", "name": "Does TCC provide financial crime technology solutions?", "acceptedAnswer": { "@type": "Answer", "text": "Yes. We support technology-enabled workflows covering sanctions screening, customer due diligence, enhanced due diligence and AI-supported review processes with full audit trails.\u00a0\u00a0" } }, { "@type": "Question", "name": "What sectors does TCC support?", "acceptedAnswer": { "@type": "Answer", "text": "We support banking, payments, wealth management, lending, pensions,\u00a0insurance\u00a0and motor finance firms.\u00a0" } }, { "@type": "Question", "name": "Why do firms choose TCC for financial crime support?", "acceptedAnswer": { "@type": "Answer", "text": "Because we combine specialist\u00a0expertise, managed delivery, flexible resourcing and technology-enabled solutions to help organisations strengthen controls, improve\u00a0resilience\u00a0and\u00a0maintain\u00a0confidence under scrutiny.\u00a0" } } ] } ] } ``` ### Momenta - URL: https://tcc.group/momenta/ - Published: 2026-07-31 - Modified: 2026-07-31 #### Momenta **Company shorthand:** Interim Resourcing Contingent compliance professionals and contract teams deployed at pace — from single specialists to 300-person review squads. **Company website:** [Momenta](https://momentagroup.com/) - Reviewed by: [TCC Group Editorial Team](https://www.linkedin.com/company/tcc-group), Compliance and regulatory specialists with over 25 years of FCA market experience ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/momenta/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Momenta", "item": "https://tcc.group/momenta/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/momenta/#webpage", "url": "https://tcc.group/momenta/", "name": "Momenta", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-07-31T09:50:31+01:00", "dateModified": "2025-07-01T00:00:00+00:00", "breadcrumb": { "@id": "https://tcc.group/momenta/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] }, "description": "Contingent compliance professionals and contract teams deployed at pace \u2014 from single specialists to 300-person review squads.", "about": { "@id": "https://momentagroup.com/#organization" }, "reviewedBy": { "@type": "Person", "name": "TCC Group Editorial Team", "jobTitle": "Compliance and regulatory specialists with over 25 years of FCA market experience", "url": "https://www.linkedin.com/company/tcc-group" }, "lastReviewed": "2025-07-01" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "mainEntityOfPage": { "@id": "https://tcc.group/momenta/#webpage" }, "parentOrganization": { "@id": "https://tcc.group/#organization" }, "name": "Momenta", "legalName": "Momenta Interim Management Limited", "description": "Contingent compliance professionals and contract teams deployed at pace \u2014 from single specialists to 300-person review squads.", "additionalType": "RESOURCING", "url": "https://momentagroup.com/" } ] } ``` ### Recordsure - URL: https://tcc.group/recordsure/ - Published: 2026-07-31 - Modified: 2026-07-31 #### Recordsure **Company shorthand:** Compliance AI & RegTech Industry-proven, regulator-trusted AI-powered technology — turning regulatory compliance into a measurable, auditable process. **Company website:** [Recordsure](https://recordsure.com/) - Reviewed by: [TCC Group Editorial Team](https://www.linkedin.com/company/tcc-group), Compliance and regulatory specialists with over 25 years of FCA market experience ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/recordsure/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Recordsure", "item": "https://tcc.group/recordsure/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/recordsure/#webpage", "url": "https://tcc.group/recordsure/", "name": "Recordsure", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-07-31T09:50:30+01:00", "dateModified": "2025-07-01T00:00:00+00:00", "breadcrumb": { "@id": "https://tcc.group/recordsure/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] }, "description": "Industry-proven, regulator-trusted AI-powered technology \u2014 turning regulatory compliance into a measurable, auditable process.", "about": { "@id": "https://recordsure.com/#organization" }, "reviewedBy": { "@type": "Person", "name": "TCC Group Editorial Team", "jobTitle": "Compliance and regulatory specialists with over 25 years of FCA market experience", "url": "https://www.linkedin.com/company/tcc-group" }, "lastReviewed": "2025-07-01" }, { "@type": "Organization", "@id": "https://recordsure.com/#organization", "mainEntityOfPage": { "@id": "https://tcc.group/recordsure/#webpage" }, "parentOrganization": { "@id": "https://tcc.group/#organization" }, "name": "Recordsure", "legalName": "Record Sure Limited", "description": "Industry-proven, regulator-trusted AI-powered technology \u2014 turning regulatory compliance into a measurable, auditable process.", "additionalType": "AI & REGTECH", "url": "https://recordsure.com/" } ] } ``` ### TCC - URL: https://tcc.group/tcc/ - Published: 2026-07-31 - Modified: 2026-07-31 #### TCC **Company shorthand:** Advisory, Managed Services & Specialist Resourcing Regulatory advisory, outsourced compliance, and managed programmes across every FCA-regulated sector. Delivering outcomes that matter. **Company website:** [TCC](https://tcc.group/) - Reviewed by: [TCC Group Editorial Team](https://www.linkedin.com/company/tcc-group), Compliance and regulatory specialists with over 25 years of FCA market experience ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org", "additionalType": "COMPLIANCE" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/tcc/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "TCC", "item": "https://tcc.group/tcc/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/tcc/#webpage", "url": "https://tcc.group/tcc/", "name": "TCC", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-07-31T09:50:30+01:00", "dateModified": "2025-07-01T00:00:00+00:00", "breadcrumb": { "@id": "https://tcc.group/tcc/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] }, "description": "Regulatory advisory, outsourced compliance, and managed programmes across every FCA-regulated sector. 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Monitor customer outcomes, identify risks earlier and generate stronger compliance assurance through intelligent monitoring. ![TCC Compliance AI and RegTech Service](https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/c174feaa64554e3885d1281136e9617f/thumbnail-1024-3d645c4bd62ceed5439ac8220af1d4dbf0b1433227bd7b4f1838b897f036877e.jpg) #### Summary card TCC's regulatory expertise combined with Recordsure's Compliance AI, providing stronger oversight and measurable evidence. #### How technology enables better outcomes Firms need the right monitoring framework, quality standards, governance structures and regulatory interpretation. TCC combines technology and compliance expertise to deliver meaningful assurance rather than simply more data. Recordsure's AI-powered interaction monitoring, conversation intelligence and compliance assurance technology to help firms monitor customer outcomes, identify risks earlier and generate stronger regulatory evidence. #### Frequently asked questions ##### What is technology-enabled compliance? Technology-enabled compliance combines specialist regulatory expertise with monitoring, analytics and automation tools to improve compliance oversight, assurance and governance. ##### How can AI support compliance monitoring? AI can help identify trends, risks and customer outcome indicators across large volumes of customer interactions, enabling more targeted review and oversight. ##### Can technology help evidence Consumer Duty outcomes? Yes. Monitoring, analytics and assurance tools can support outcome testing, management information and governance reporting designed around Consumer Duty requirements. ##### Is technology-enabled compliance a replacement for compliance specialists? No. Technology enhances visibility and efficiency, but regulatory judgement, governance and expert oversight remain essential. ##### Which firms use technology-enabled compliance solutions? Technology-enabled compliance is used across wealth management, banking, insurance, lending, payments, consumer credit and other regulated sectors. ##### How does Tech-Enabled Compliance differ from Managed Services? Managed Services focuses on operational delivery. Tech-Enabled Compliance focuses on monitoring, oversight, assurance and evidence generation that supports better decision-making and governance. ##### What is interaction intelligence? Interaction intelligence uses AI to analyse customer conversations and communications at scale, helping firms identify risks, monitor outcomes and improve compliance oversight.  ##### What is conversation monitoring in financial services? Conversation monitoring enables firms to review customer interactions across phone, video and digital channels to identify conduct risks, vulnerability indicators and evidence of customer outcomes.  ##### Can speech analytics support Consumer Duty? Yes. Speech analytics can help firms identify customer understanding, vulnerability indicators, complaints, support needs and potential conduct concerns across customer interactions.  - Reviewed by: [TCC Group Editorial Team](https://www.linkedin.com/company/tcc-group), Compliance and regulatory specialists with over 25 years of FCA market experience ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/tech-enabled-compliance/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Tech-enabled Compliance", "item": "https://tcc.group/tech-enabled-compliance/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/tech-enabled-compliance/#webpage", "url": "https://tcc.group/tech-enabled-compliance/", "name": "See more. 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Recordsure's\u00a0AI-powered interaction monitoring, conversation intelligence and compliance assurance technology to help firms\u00a0monitor\u00a0customer outcomes,\u00a0identify\u00a0risks\u00a0earlier\u00a0and generate stronger regulatory evidence.", "isPartOf": { "@id": "https://tcc.group/tech-enabled-compliance/#webpage" } }, { "@type": "FAQPage", "@id": "https://tcc.group/tech-enabled-compliance/#faqpage", "isPartOf": { "@id": "https://tcc.group/tech-enabled-compliance/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What is technology-enabled compliance?", "acceptedAnswer": { "@type": "Answer", "text": "Technology-enabled compliance combines specialist regulatory expertise with monitoring, analytics and automation tools to improve compliance oversight, assurance and governance." } }, { "@type": "Question", "name": "How can AI support compliance monitoring?", "acceptedAnswer": { "@type": "Answer", "text": "AI can help identify trends, risks and customer outcome indicators across large volumes of customer interactions, enabling more targeted review and oversight." } }, { "@type": "Question", "name": "Can technology help evidence Consumer Duty outcomes?", "acceptedAnswer": { "@type": "Answer", "text": "Yes. Monitoring, analytics and assurance tools can support outcome testing, management information and governance reporting designed around Consumer Duty requirements." } }, { "@type": "Question", "name": "Is technology-enabled compliance a replacement for compliance specialists?", "acceptedAnswer": { "@type": "Answer", "text": "No. Technology enhances visibility and efficiency, but regulatory judgement, governance and expert oversight remain essential." } }, { "@type": "Question", "name": "Which firms use technology-enabled compliance solutions?", "acceptedAnswer": { "@type": "Answer", "text": "Technology-enabled compliance is used across wealth management, banking, insurance, lending, payments, consumer credit and other regulated sectors." } }, { "@type": "Question", "name": "How does Tech-Enabled Compliance differ from Managed Services?", "acceptedAnswer": { "@type": "Answer", "text": "Managed Services focuses on operational delivery. 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Speech analytics can help firms\u00a0identify\u00a0customer understanding, vulnerability indicators, complaints, support\u00a0needs\u00a0and potential conduct concerns across customer interactions.\u00a0" } } ] } ] } ``` ### Specialist Resourcing - URL: https://tcc.group/specialist-resourcing/ - Published: 2026-07-31 - Modified: 2026-09-03 #### The specialist expertise you need, when you need it Access proven regulatory, compliance and transformation professionals when programmes cannot wait. Individual experts or complete delivery teams, mobilised rapidly. ![Specialist interims](https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/12825fee056a4b92a36c8d79e448204c/thumbnail-1024-a69061cba9d21d39fd117342f74abe4655d7c2f59549156572387497d064281a.jpg) #### Summary card TCC deploys experienced professionals and delivery teams rapidly across complex regulatory programmes - no recruitment lag. #### Delivery from day one When critical programmes need to move quickly, firms cannot always wait for permanent recruitment. They need access to proven regulatory expertise that can deliver from day one. TCC combines one of the UK's largest specialist compliance networks with deep FCA-market experience, helping organisations access the capability they need without compromising quality or delivery momentum. #### Frequently asked questions ##### What types of specialist resource can TCC provide? TCC provides interim compliance leaders, project managers, business analysts, Consumer Duty specialists, financial crime professionals, remediation teams, review specialists and programme delivery experts. ##### How is Specialist Resourcing different from recruitment? TCC takes a strategic resourcing approach, helping firms build capability around defined outcomes and regulatory requirements rather than simply filling vacancies. ##### Can TCC provide complete project or review teams? Yes. We can provide individual specialists, dedicated teams or complete programme structures depending on the size and complexity of the requirement. ##### Does TCC support Section 166 and FCA intervention programmes? Yes. We regularly provide programme leaders, reviewers, subject matter experts and operational teams to support FCA reviews, remediation initiatives and regulatory interventions. ##### How quickly can resource be deployed? Resourcing requirements vary by role and programme complexity, but TCC maintains a network of more than 40,000 pre-approved associates to support rapid mobilisation - in some case, within 48-hours. ##### Can Specialist Resourcing be combined with other TCC services? Yes. Resource deployments can be supported by Advisory, Managed Services or Tech-Enabled Compliance capabilities where additional expertise, governance or operational support is required. ##### What makes TCC different from other specialist resourcing providers? TCC combines specialist compliance expertise, a large pre-approved associate network and practical FCA-market experience. This means firms get more than additional capacity: they get specialists who understand regulatory expectations, programme delivery and the standards needed to achieve defensible outcomes. - Reviewed by: [TCC Group Editorial Team](https://www.linkedin.com/company/tcc-group), Compliance and regulatory specialists with over 25 years of FCA market experience ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/specialist-resourcing/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Specialist Resourcing", "item": "https://tcc.group/specialist-resourcing/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/specialist-resourcing/#webpage", "url": "https://tcc.group/specialist-resourcing/", "name": "The specialist expertise you need, when you need it", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-07-31T09:49:54+01:00", "dateModified": "2026-09-03T00:00:00+00:00", "breadcrumb": { "@id": "https://tcc.group/specialist-resourcing/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] }, "description": "Access proven regulatory, compliance and transformation professionals when programmes cannot wait. 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TCC delivers governed reviews, complaints handling, remediation programmes and quality assurance at scale. ![Managed service](https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/df6e89c1614347338e1378ddbec0d0c8/thumbnail-640-3e1ef1d1e3b2d5ff64629f20c7b2ea7cc061fea757a2d8690e35061222d354fd.jpg) #### Summary card TCC designs and delivers managed compliance services for FCA-regulated firms - governed for quality, control and scale. #### Compliance delivery with accountability built in TCC operates outsourced and co-sourced compliance services for FCA-regulated firms. We take responsibility for delivering defined activities, from complaints handling and file reviews to remediation programmes and quality assurance. Clients retain visibility and accountability while we provide the people, processes, governance and operational leadership needed to deliver consistently and at scale.  #### Frequently asked questions ##### What is a managed compliance service? A managed compliance service is an outsourced delivery model where TCC takes responsibility for defined compliance activity, governance, quality assurance and agreed performance outcomes.  ##### Which managed services does TCC provide? TCC provides managed services across suitability and file reviews, complaints handling, redress calculations, remediation programmes, paraplanning support, QA and Consumer Duty outcome testing. ##### Can TCC manage part of a process rather than the whole activity? Yes. TCC can provide modular support for specific backlogs, review workstreams or operational pressure points, or manage a full end-to-end service depending on the firm's needs. ##### How is quality controlled? Each engagement is supported by agreed methodology, calibration, QA, escalation routes, MI and governance reporting, helping firms evidence consistency, control and oversight. ##### How does Managed Services differ from Specialist Resourcing? Specialist Resourcing provides skilled individuals or teams to support internal delivery. Managed Services gives TCC responsibility for running defined compliance activity, including workflow, governance, reporting and delivery performance. ##### Can technology support managed services delivery? Yes. Where appropriate, TCC can use RegTech, analytics and workflow tools to support managed file reviews, complaints processes, monitoring and outcome testing, with specialist human oversight built in. ##### Can managed services scale quickly? Yes. TCC's operating models can flex to support changing volumes, urgent backlogs or defined programmes while maintaining quality standards, governance controls and customer outcome requirements. - Reviewed by: [TCC Group Editorial Team](https://www.linkedin.com/company/tcc-group), Compliance and regulatory specialists with over 25 years of FCA market experience ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/managed-services/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Managed Services", "item": "https://tcc.group/managed-services/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/managed-services/#webpage", "url": "https://tcc.group/managed-services/", "name": "Deliver compliance without increasing complexity", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-07-31T09:49:53+01:00", "dateModified": "2026-09-03T00:00:00+00:00", "breadcrumb": { "@id": "https://tcc.group/managed-services/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] }, "description": "Outsource compliance activities without losing visibility or control. 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TCC can provide modular support for specific backlogs, review workstreams or operational pressure points, or manage a full end-to-end service depending on the firm's needs." } }, { "@type": "Question", "name": "How is quality controlled?", "acceptedAnswer": { "@type": "Answer", "text": "Each engagement is supported by agreed methodology, calibration, QA, escalation routes, MI and governance reporting, helping firms evidence consistency, control and oversight." } }, { "@type": "Question", "name": "How does Managed Services differ from Specialist Resourcing?", "acceptedAnswer": { "@type": "Answer", "text": "Specialist Resourcing provides skilled individuals or teams to support internal delivery. Managed Services gives TCC responsibility for running defined compliance activity, including workflow, governance, reporting and delivery performance." } }, { "@type": "Question", "name": "Can technology support managed services delivery?", "acceptedAnswer": { "@type": "Answer", "text": "Yes. Where appropriate, TCC can use RegTech, analytics and workflow tools to support managed file reviews, complaints processes, monitoring and outcome testing, with specialist human oversight built in." } }, { "@type": "Question", "name": "Can managed services scale quickly?", "acceptedAnswer": { "@type": "Answer", "text": "Yes. TCC's operating models can flex to support changing volumes, urgent backlogs or defined programmes while maintaining quality standards, governance controls and customer outcome requirements." } } ] } ] } ``` ### Advisory - URL: https://tcc.group/advisory/ - Published: 2026-07-31 - Modified: 2026-09-03 #### Independent expertise for critical regulatory decisions Navigate complex regulatory challenges with confidence. TCC provides expert assessment, independent advice and practical guidance across governance, Consumer Duty, financial crime, FCA engagement and regulatory transformation. ![Advisory](https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/792df90fb2444d7f97578590ce330aec/thumbnail-1024-362673beedea125ea30575dd75d4f18ee7a153c228e45178563ade4d852d31e4.jpg) #### Summary card TCC helps FCA-regulated firms assess regulatory risk, strengthen governance and make informed compliance decisions. #### When regulatory decisions demand greater confidence Regulatory challenges are rarely resolved by interpretation alone. Firms must understand how requirements apply to their business, identify the risks that matter and translate their conclusions into practical action. TCC combines regulatory expertise with experience of implementing change and delivering complex compliance programmes. We help boards, senior leaders and compliance teams make informed decisions, test their position and establish a clear, evidence-based response.  #### Frequently asked questions ##### What types of regulatory advisory support does TCC provide? TCC provides regulatory advice across Consumer Duty, financial crime, vulnerable customers, regulatory change, remediation, regulatory due diligence, governance and FCA intervention.  ##### When should a firm engage a regulatory adviser? Firms commonly seek external support when a decision is complex, carries significant regulatory risk, requires specialist expertise or would benefit from independent challenge.  ##### How does Advisory differ from Managed Services? Advisory helps firms understand regulatory issues, evaluate options and decide what action to take. Managed Services involves TCC taking responsibility for delivering defined compliance activities or operational processes.  ##### Can TCC support an FCA review or regulatory engagement? Yes. We help firms understand regulatory concerns, prepare relevant evidence, assess their position and develop appropriate response and remediation plans. ##### Can TCC undertake an independent compliance review? Yes. TCC can independently assess regulatory frameworks, governance, controls, processes and supporting evidence, then provide prioritised findings and practical recommendations.  ##### Can TCC help implement its recommendations? Yes. TCC can support implementation through continued advisory input, managed services, specialist resources or technology-enabled monitoring and assurance.  - Reviewed by: [TCC Group Editorial Team](https://www.linkedin.com/company/tcc-group), Compliance and regulatory specialists with over 25 years of FCA market experience ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/advisory/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Advisory", "item": "https://tcc.group/advisory/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/advisory/#webpage", "url": "https://tcc.group/advisory/", "name": "Independent expertise for critical regulatory decisions", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-07-31T09:49:53+01:00", "dateModified": "2026-09-03T00:00:00+00:00", "breadcrumb": { "@id": "https://tcc.group/advisory/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] }, "description": "Navigate complex regulatory challenges with confidence. 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TCC can support implementation through continued advisory input, managed services, specialist\u00a0resources\u00a0or technology-enabled monitoring and assurance.\u00a0" } } ] } ] } ``` ### Redress and Remediation - URL: https://tcc.group/redress-and-remediation/ - Published: 2026-07-13 - Modified: 2026-09-03 #### Need to deliver a redress programme customers, boards and regulators can trust? TCC helps FCA-regulated firms identify, assess and remediate customers with confidence. We design redress methodologies, identify affected customer populations, calculate liabilities, conduct customer reviews and provide the governance, quality assurance and operational capacity needed to deliver fair customer outcomes. Combining regulatory expertise, managed services, specialist resourcing and technology-enabled solutions, we help firms execute remediation programmes efficiently and at scale. ![Redress icon](https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/77f0b61aff0544c0b7c43916182d4a77/thumbnail-320-4353e4e2c613da832fb097a2404af1faac34427cf44611942043d1e53bb9d8bb.png) #### Summary card TCC supports redress calculations, customer reviews, remediation programmes, governance, quality assurance and regulatory engagement across financial services. #### Relevant sectors - [Banking](https://tcc.group/sectors/banking/) - [General Insurance & Protection](https://tcc.group/sectors/general-insurance-protection/) - [Lending & Consumer Credit](https://tcc.group/sectors/lending-consumer-credit/) - [Motor Finance](https://tcc.group/sectors/motor-finance/) - [Payments & FinTech](https://tcc.group/sectors/payments-fintech/) - [Pensions & Retirement Income](https://tcc.group/sectors/pensions-retirement-income/) - [Wealth Management & Financial Advice](https://tcc.group/sectors/wealth-management-financial-advice/) #### Frequently asked questions ##### What is a redress programme? A redress programme is a structured process for identifying affected customers, assessing potential harm and delivering fair compensation or corrective action where appropriate.  ##### How do firms identify customers who may require redress? This typically involves customer population analysis, file reviews, data assessments and agreed methodologies that determine which customers may have been impacted.  ##### Can TCC calculate customer redress? Yes. We support firms with redress methodologies, calculations, quality assurance and governance, helping ensure outcomes are fair, consistent and well evidenced.  ##### Can TCC manage remediation programmes on behalf of firms? Yes. We provide managed services, specialist resources and operational delivery support across every stage of remediation and redress programmes. ##### Can TCC support large-scale customer review exercises? Yes. We can rapidly mobilise trained review teams, quality assurance specialists, operational managers and subject matter experts to support programmes of all sizes. ##### Can TCC support FCA engagement? Yes. We regularly help firms prepare methodologies, governance documentation, reporting packs and evidence to support regulatory engagement and programme oversight. ##### How does TCC ensure consistency across large programmes? We combine governance frameworks, quality assurance controls, documented methodologies and experienced delivery teams to help ensure consistent and defensible outcomes. ##### Which sectors does TCC support? We support firms across wealth management, pensions, banking, lending, payments, insurance and motor finance sectors. ##### Can TCC support discretionary commission redress programmes? Yes. TCC supports firms with discretionary commission redress methodologies, customer population identification, redress calculations, quality assurance, governance and operational delivery, helping organisations manage large-scale remediation programmes with confidence.  - Reviewed by: [Practice Lead](https://tcc.group/about/meet-the-team/), Head of Redress & Remediation **Last reviewed:** 2026-09-03 #### Managing a redress programme, customer review or remediation exercise? Our specialists help firms identify liabilities, calculate redress, mobilise delivery teams and achieve fair customer outcomes with confidence. 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We support firms with redress methodologies, calculations, quality\u00a0assurance\u00a0and governance, helping ensure outcomes are fair,\u00a0consistent\u00a0and well\u00a0evidenced.\u00a0" } }, { "@type": "Question", "name": "Can TCC manage remediation programmes on behalf of firms?", "acceptedAnswer": { "@type": "Answer", "text": "Yes. We provide managed services, specialist resources and operational delivery support across every stage of remediation and redress programmes." } }, { "@type": "Question", "name": "Can TCC support large-scale customer review exercises?", "acceptedAnswer": { "@type": "Answer", "text": "Yes. We can rapidly mobilise trained review teams, quality assurance specialists, operational managers and subject matter experts to support programmes of all sizes." } }, { "@type": "Question", "name": "Can TCC support FCA engagement?", "acceptedAnswer": { "@type": "Answer", "text": "Yes. We regularly help firms prepare methodologies, governance documentation, reporting packs and evidence to support regulatory engagement and programme oversight." } }, { "@type": "Question", "name": "How does TCC ensure consistency across large programmes?", "acceptedAnswer": { "@type": "Answer", "text": "We combine governance frameworks, quality assurance controls, documented methodologies and experienced delivery teams to help ensure consistent and defensible outcomes." } }, { "@type": "Question", "name": "Which sectors does TCC support?", "acceptedAnswer": { "@type": "Answer", "text": "We support firms across wealth management, pensions, banking, lending, payments, insurance and motor finance sectors." } }, { "@type": "Question", "name": "Can TCC support discretionary commission redress programmes?", "acceptedAnswer": { "@type": "Answer", "text": "Yes. TCC supports firms with discretionary commission redress methodologies, customer population identification, redress calculations, quality assurance,\u00a0governance\u00a0and operational delivery, helping\u00a0organisations\u00a0manage large-scale remediation\u00a0programmes\u00a0with confidence.\u00a0" } } ] } ] } ``` ### Suitability Advice, Quality & File reviews - URL: https://tcc.group/suitability-advice-quality-file-reviews/ - Published: 2026-07-12 - Modified: 2026-09-03 #### Are your advice quality frameworks delivering consistent customer outcomes? TCC helps firms assess, improve and evidence advice quality through independent suitability reviews, file assessments, quality assurance programmes and technology-enabled monitoring. We support wealth managers, financial advisers and retirement income businesses seeking greater confidence in customer outcomes, regulatory compliance and the consistency of advice delivered across their organisation. ![Suitability review icon](https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/7c63a626a8f34d6b82196c69491aeea0/thumbnail-320-7d67d45d13b6595893a90544ac427f05720d3477613923090c467f8c0674d895.png) #### Summary card TCC helps wealth, advice and retirement firms assess suitability, improve advice quality, conduct file reviews and evidence good customer outcomes. #### Relevant sectors - [General Insurance & Protection](https://tcc.group/sectors/general-insurance-protection/) - [Lending & Consumer Credit](https://tcc.group/sectors/lending-consumer-credit/) - [Pensions & Retirement Income](https://tcc.group/sectors/pensions-retirement-income/) - [Wealth Management & Financial Advice](https://tcc.group/sectors/wealth-management-financial-advice/) #### Frequently asked questions ##### What is a suitability review? A suitability review assesses whether advice recommendations align with a customer's objectives, circumstances, attitude to risk and regulatory requirements. Suitability reviews help firms identify risks, improve consistency and evidence good customer outcomes.   ##### How can firms evidence advice quality? Advice quality can be evidenced through suitability reviews, file assessments, quality assurance frameworks, adviser monitoring, customer outcome testing and management information that demonstrates consistent standards across the business.   ##### What is the difference between suitability reviews and compliance monitoring? Suitability reviews focus on the quality and appropriateness of advice delivered to customers. Compliance monitoring typically assesses broader regulatory obligations, controls and business processes. Together, they provide a more complete view of regulatory and customer outcome risks. ##### Can TCC provide outsourced file review services? Yes. We provide independent suitability reviews, outsourced file review programmes and managed quality assurance services that help firms increase review capacity and maintain consistent standards. ##### Can TCC support ongoing advice and servicing reviews? Yes. We help firms assess ongoing servicing propositions, review client outcomes and evaluate whether ongoing advice arrangements remain appropriate, documented and deliver value to customers. ##### Does TCC provide paraplanning support? Yes. TCC provides paraplanning support as part of wider suitability, advice quality and review programmes, helping firms maintain service standards and operational efficiency.   ##### Can TCC deploy review teams at scale? Yes. Our specialists can provide review capacity for business-as-usual monitoring, thematic reviews, remediation programmes and large-scale customer review exercises.   ##### How can technology support advice quality monitoring? Technology can improve consistency, increase review coverage, strengthen evidencing and provide additional insight into advice quality trends and customer outcome risks. TCC combines expert review with technology-enabled monitoring and assurance.   ##### Why are suitability reviews important? Suitability reviews provide independent assurance that advice remains appropriate, consistent and aligned to regulatory expectations. They help firms identify risks early, improve adviser standards and strengthen confidence in customer outcomes. - Reviewed by: [Practice Lead](https://tcc.group/about/meet-the-team/), Head of Suitability Reviews **Last reviewed:** 2026-09-03 #### Need greater confidence in advice quality and customer outcomes? Our specialists help firms assess suitability, strengthen oversight and build evidence that advice standards remain consistent across the organisation. [Get in touch](https://tcc.group/talk-to-us/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/suitability-advice-quality-file-reviews/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Suitability Advice, Quality & File reviews", "item": "https://tcc.group/suitability-advice-quality-file-reviews/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/suitability-advice-quality-file-reviews/#webpage", "url": "https://tcc.group/suitability-advice-quality-file-reviews/", "name": "Suitability Advice, Quality & File reviews", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-07-12T23:54:56+01:00", "dateModified": "2026-09-03T00:00:00+00:00", "breadcrumb": { "@id": "https://tcc.group/suitability-advice-quality-file-reviews/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] }, "lastReviewed": "2026-09-03" }, { "@type": "Service", "@id": "https://tcc.group/suitability-advice-quality-file-reviews/#service", "name": "Suitability, Advice Quality & File Reviews", "provider": { "@id": "https://tcc.group/#organization" }, "areaServed": "GB", "url": "https://tcc.group/suitability-advice-quality-file-reviews/", "isPartOf": { "@id": "https://tcc.group/suitability-advice-quality-file-reviews/#webpage" }, "description": "TCC helps firms assess, improve and evidence advice quality through independent suitability reviews, file assessments, quality assurance programmes and technology-enabled monitoring. 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TCC combines expert review with technology-enabled monitoring and assurance.\u00a0\u00a0" } }, { "@type": "Question", "name": "Why are suitability reviews important?", "acceptedAnswer": { "@type": "Answer", "text": "Suitability reviews provide independent assurance that advice remains appropriate, consistent and aligned to regulatory expectations. They help firms identify risks early, improve adviser standards and strengthen confidence in customer outcomes." } } ] } ] } ``` ### Home - URL: https://tcc.group/ - Published: 2026-07-12 - Modified: 2026-09-03 > REGULATED COMPLIANCE #### Regulatory expertise. Operational delivery. Assured outcomes. In one place. TCC combines regulatory expertise, managed compliance services, specialist resourcing and AI-powered assurance to help regulated firms solve compliance challenges. #### Routes - [Solutions](#solutions) - [Sectors](#sectors) - [Services](#delivery) #### Evidence - **4,000+** — Individual client projects: solving FCA challenges at pace - **5 million+** — Days delivering compliance: with outstanding client outcomes - **40,000** — Highly-skilled associates: bring experience, flexibility and efficiency - **30+** — Years of regulatory expertise: across a wide range of sectors > Why firms choose TCC? #### End-to-end compliance for every regulatory challenge TCC combines independent regulatory expertise, managed compliance delivery, specialist resourcing and AI-powered assurance. From strategic advice through to programme delivery, rapid mobilisation and ongoing oversight, we help regulated firms deliver complex compliance projects and evidence better outcomes. > SERVICES #### One partner across every stage of the regulatory lifecycle Independent regulatory expertise. Delivery capability at scale. Specialist resource mobilised in days. AI-powered oversight and evidence. TCC brings together the right mix of capabilities firms need to manage risk and meet regulatory expectations. > Sectors #### Specialist expertise across regulated markets > Case Studies #### Results that speak for themselves [View all case studies](https://tcc.group/case-studies/) > The TCC Group #### Three specialists. One trusted group. We assess a problem, design a solution, deploy 300 reviewers, run the programme and provide AI-enabled assurance from the same compliance group. > FAQs #### Common questions Can’t find what you’re looking for? [Get in touch](https://tcc.group/talk-to-us/) #### Under pressure to deliver change, manage risk or satisfy the regulator? Let's discuss your next challenge. [Contact us today](https://tcc.group/talk-to-us/) #### Frequently asked questions ##### What types of FCA-regulated firms does TCC work with? TCC works with the full spectrum of FCA-regulated businesses – from global banks and major insurers to wealth managers, investment platforms, consumer credit lenders and emerging FinTech firms. We bring deep sector expertise across retail and consumer markets, helping clients navigate regulatory change, manage FCA intervention, and deliver better outcomes for consumers. ##### How quickly can TCC mobilise a compliance team? We typically mobilise within days. Our specialist resourcing team maintain a pre-vetted network of compliance, risk and regulatory professionals – from individual specialists to 300-person review squads – ready to deploy at pace. For managed service programmes, we work with clients to agree a structured mobilisation plan tailored to their timeline and regulatory deadlines. ##### What is Recordsure and how does it support compliance? Recordsure is TCC Group’s Compliance AI business. It provides AI-powered technology that monitors customer conversations and analyses advice quality at scale and turns regulatory compliance into a measurable, auditable process. Used by wealth managers, major banks and UK government, Recordsure flags cases at risk and replaces inefficient manual sampling with comprehensive, evidence-based oversight. ##### How does TCC approach Consumer Duty compliance? We offer end-to-end Consumer Duty support – from initial gap analysis and board MI design through to product and pricing assessments, vulnerable customer frameworks and ongoing outcome monitoring. Our advisers have worked directly with the FCA on Consumer Duty policy, giving our clients a practical, regulator-informed perspective on what good looks like. ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": [ "LocalBusiness", "ProfessionalService" ], "@id": "https://tcc.group/#localbusiness", "name": "TCC Group", "image": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png", "url": "https://tcc.group/", "telephone": "", "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "geo": { "@type": "GeoCoordinates", "latitude": 51.5072, "longitude": -0.0853 }, "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Financial regulation", "Consumer Duty", "Financial crime", "Regulatory technology" ] }, { "@type": "WebPage", "@id": "https://tcc.group/#webpage", "url": "https://tcc.group/", "name": "Regulatory expertise. 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Evidence more. Act sooner.", "url": "https://tcc.group/tech-enabled-compliance/" } ] }, { "@type": "ItemList", "@id": "https://tcc.group/#itemlist-cases", "name": "Results that speak for themselves", "isPartOf": { "@id": "https://tcc.group/#webpage" }, "inLanguage": "en-GB", "numberOfItems": 6, "itemListOrder": "https://schema.org/ItemListOrderAscending", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Remediation of ongoing services under section 166", "url": "https://tcc.group/case-studies/wealth-manager-remediation-of-ongoing-services-under-section166/" }, { "@type": "ListItem", "position": 2, "name": "Comprehensive UCIS review without the cost burden", "url": "https://tcc.group/case-studies/ucis-past-business-review/" }, { "@type": "ListItem", "position": 3, "name": "Top-end consultancy deployment: Strategic compliance leadership", "url": "https://tcc.group/case-studies/top-end-consultancy-deployment/" }, { "@type": "ListItem", "position": 4, "name": "Strategic resourcing: Complex claims handling", "url": "https://tcc.group/case-studies/strategic-resourcing-complex-claims/" }, { "@type": "ListItem", "position": 5, "name": "Specialist resourcing: Strategic partnership", "url": "https://tcc.group/case-studies/specialist-resourcing-strategic-partnership/" }, { "@type": "ListItem", "position": 6, "name": "Specialist resourcing", "url": "https://tcc.group/case-studies/specialist-resourcing-large-projects/" } ] }, { "@type": "ItemList", "@id": "https://tcc.group/#itemlist-group", "name": "Three specialists. One trusted group.", "isPartOf": { "@id": "https://tcc.group/#webpage" }, "inLanguage": "en-GB", "numberOfItems": 3, "itemListOrder": "https://schema.org/ItemListOrderAscending", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "TCC", "url": "https://tcc.group/tcc/" }, { "@type": "ListItem", "position": 2, "name": "Momenta", "url": "https://tcc.group/momenta/" }, { "@type": "ListItem", "position": 3, "name": "Recordsure", "url": "https://tcc.group/recordsure/" } ] }, { "@type": "ItemList", "@id": "https://tcc.group/#itemlist-sectors", "name": "Specialist expertise across regulated markets", "isPartOf": { "@id": "https://tcc.group/#webpage" }, "inLanguage": "en-GB", "numberOfItems": 8, "itemListOrder": "https://schema.org/ItemListOrderAscending", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/sectors/wealth-management-financial-advice/" }, { "@type": "ListItem", "position": 2, "name": "Pensions & Retirement Income", "url": "https://tcc.group/sectors/pensions-retirement-income/" }, { "@type": "ListItem", "position": 3, "name": "Payments & FinTech", "url": "https://tcc.group/sectors/payments-fintech/" }, { "@type": "ListItem", "position": 4, "name": "Banking", "url": "https://tcc.group/sectors/banking/" }, { "@type": "ListItem", "position": 5, "name": "Lending & Consumer Credit", "url": "https://tcc.group/sectors/lending-consumer-credit/" }, { "@type": "ListItem", "position": 6, "name": "General Insurance & Protection", "url": "https://tcc.group/sectors/general-insurance-protection/" }, { "@type": "ListItem", "position": 7, "name": "Motor Finance", "url": "https://tcc.group/sectors/motor-finance/" }, { "@type": "ListItem", "position": 8, "name": "Utilities", "url": "https://tcc.group/sectors/utilities/" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/#faqpage", "isPartOf": { "@id": "https://tcc.group/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What types of FCA-regulated firms does TCC work with?", "acceptedAnswer": { "@type": "Answer", "text": "TCC works with the full spectrum of FCA-regulated businesses \u2013 from global banks and major insurers to wealth managers, investment platforms, consumer credit lenders and emerging FinTech firms. We bring deep sector expertise across retail and consumer markets, helping clients navigate regulatory change, manage FCA intervention, and deliver better outcomes for consumers." } }, { "@type": "Question", "name": "How quickly can TCC mobilise a compliance team?", "acceptedAnswer": { "@type": "Answer", "text": "We typically mobilise within days. Our specialist resourcing team maintain a pre-vetted network of compliance, risk and regulatory professionals \u2013 from individual specialists to 300-person review squads \u2013 ready to deploy at pace. For managed service programmes, we work with clients to agree a structured mobilisation plan tailored to their timeline and regulatory deadlines." } }, { "@type": "Question", "name": "What is Recordsure and how does it support compliance?", "acceptedAnswer": { "@type": "Answer", "text": "Recordsure is TCC Group\u2019s Compliance AI business. It provides AI-powered technology that monitors customer conversations and analyses advice quality at scale and turns regulatory compliance into a measurable, auditable process. Used by wealth managers, major banks and UK government, Recordsure flags cases at risk and replaces inefficient manual sampling with comprehensive, evidence-based oversight." } }, { "@type": "Question", "name": "How does TCC approach Consumer Duty compliance?", "acceptedAnswer": { "@type": "Answer", "text": "We offer end-to-end Consumer Duty support \u2013 from initial gap analysis and board MI design through to product and pricing assessments, vulnerable customer frameworks and ongoing outcome monitoring. Our advisers have worked directly with the FCA on Consumer Duty policy, giving our clients a practical, regulator-informed perspective on what good looks like." } } ] } ] } ``` ### Privacy and Policies - URL: https://tcc.group/privacy-statement/ - Published: 2026-07-12 - Modified: 2026-09-03 ## Policy title and summary Privacy and Policies We may receive information that you choose to provide when you contact us, respond to a vacancy or communicate with a TCC Group company. This can include your name, organisation, role, contact details and the content of your enquiry. Please do not send special category information, identity documents or financial details unless an authorised TCC Group contact has explained why they are required and how they will be handled. ## Key facts panel TCC Group ## Full policy content The Consulting Consortium Ltd is responsible for the personal information processed through this TCC Group website. This statement explains what information may be collected, why it is used and the choices available to visitors. ## Information we process The website may also process technical information needed to provide and protect the service, such as request logs, security events and cookie preferences. Campaign parameters in a visited URL may be held in browser session storage for attribution and added to forms submitted during that browser session. This information is cleared when the tab or browser session ends and is not placed in persistent local storage by the theme. ## Cookies and analytics Necessary cookies support WordPress, security, administration and your consent preferences. Analytics and advertising storage are denied by default. Google Analytics or advertising cookies are used only where the relevant consent has been given through CookieYes. You can review or change your choices through the [cookie settings](/cookie-settings/). ## Why information is used - To respond to enquiries and take steps requested before entering a contract. - To deliver services and manage relationships with clients, suppliers and professional contacts. - To operate, secure, diagnose and improve the website. - To measure communications where consent is required and has been given. - To meet legal, regulatory and record-keeping obligations. The lawful basis depends on the context and may be contract, steps before a contract, legal obligation, legitimate interests or consent. Where processing relies on consent, you can withdraw it at any time without affecting earlier lawful processing. ## Sharing, retention and international access Information may be shared with the relevant TCC Group company and trusted service providers that support hosting, security, communications, recruitment or professional services. It may also be disclosed where required by law or a competent regulator. Providers are expected to process information only for agreed purposes and with appropriate safeguards. Where information is accessed outside the UK, an approved transfer mechanism and suitable protections must be used. Personal information is retained only for as long as it is needed for the purpose collected, including applicable legal, regulatory, contractual and dispute-resolution requirements. Retention periods vary by record type and relationship; information is deleted or anonymised when it is no longer required. ## Your rights Depending on the circumstances, you may ask for access to your personal information, correction, deletion, restriction, objection or portability. You may also complain to the UK Information Commissioner's Office. To make a privacy request, write to The Consulting Consortium Ltd, 10 Lower Thames Street, London EC3R 6EN, describing the request and how we can identify the relevant records. We may need proportionate information to verify identity before responding. ## Changes to this statement We review this statement when the website, service providers or legal requirements change. The published version is the current version. Material changes should be explained clearly rather than applied retrospectively to information already processed on another basis. ## Related policies - Privacy: Visitors and clients — /privacy-statement-visitors-and-clients/ - Privacy: Employees — /privacy-statement-tcc-employees/ - Privacy: Associates — /privacy-statement-tcc-associates/ - Privacy: Legal basis — /privacy-statement-legal-basis/ - Privacy: Third parties — /privacy-third-party-list/ - Cookies — /cookies/ ## Privacy / compliance contact Data protection dataprotection@tcc.group 020 3772 7230 ## Editorial byline TCC Group Editorial Team /meet-the-team/ ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/privacy-statement/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Privacy and Policies", "item": "https://tcc.group/privacy-statement/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/privacy-statement/#webpage", "url": "https://tcc.group/privacy-statement/", "name": "Privacy and Policies", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-07-12T13:37:28+01:00", "dateModified": "2026-09-03T18:27:11+01:00", "breadcrumb": { "@id": "https://tcc.group/privacy-statement/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "Organization", "@id": "https://tcc.group/privacy-statement/#editorial-team", "name": "TCC Group Editorial Team", "url": "https://tcc.group/meet-the-team/" }, { "@type": "DigitalDocument", "@id": "https://tcc.group/privacy-statement/#policy", "name": "Privacy and Policies", "description": "We may receive information that you choose to provide when you contact us, respond to a vacancy or communicate with a TCC Group company. This can include your name, organisation, role, contact details and the content of your enquiry. Please do not send special category information, identity documents or financial details unless an authorised TCC Group contact has explained why they are required and how they will be handled.", "text": "The Consulting Consortium Ltd is responsible for the personal information processed through this TCC Group website. This statement explains what information may be collected, why it is used and the choices available to visitors.\n\nInformation we process\n\nThe website may also process technical information needed to provide and protect the service, such as request logs, security events and cookie preferences. Campaign parameters in a visited URL may be held in browser session storage for attribution and added to forms submitted during that browser session. This information is cleared when the tab or browser session ends and is not placed in persistent local storage by the theme.\n\nCookies and analytics\n\nNecessary cookies support WordPress, security, administration and your consent preferences. Analytics and advertising storage are denied by default. Google Analytics or advertising cookies are used only where the relevant consent has been given through CookieYes. You can review or change your choices through the cookie settings.\n\nWhy information is used\n\n\u2022 To respond to enquiries and take steps requested before entering a contract.\n\u2022 To deliver services and manage relationships with clients, suppliers and professional contacts.\n\u2022 To operate, secure, diagnose and improve the website.\n\u2022 To measure communications where consent is required and has been given.\n\u2022 To meet legal, regulatory and record-keeping obligations.\n\nThe lawful basis depends on the context and may be contract, steps before a contract, legal obligation, legitimate interests or consent. Where processing relies on consent, you can withdraw it at any time without affecting earlier lawful processing.\n\nSharing, retention and international access\n\nInformation may be shared with the relevant TCC Group company and trusted service providers that support hosting, security, communications, recruitment or professional services. It may also be disclosed where required by law or a competent regulator. Providers are expected to process information only for agreed purposes and with appropriate safeguards. Where information is accessed outside the UK, an approved transfer mechanism and suitable protections must be used.\n\nPersonal information is retained only for as long as it is needed for the purpose collected, including applicable legal, regulatory, contractual and dispute-resolution requirements. Retention periods vary by record type and relationship; information is deleted or anonymised when it is no longer required.\n\nYour rights\n\nDepending on the circumstances, you may ask for access to your personal information, correction, deletion, restriction, objection or portability. You may also complain to the UK Information Commissioner's Office. 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This is your first post. Edit or delete it, then start writing! Welcome to WordPress. This is your first post. Edit or delete it, then start writing! ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/blog/2026/07/17/hello-world/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Hello world!", "item": "https://tcc.group/blog/2026/07/17/hello-world/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/blog/2026/07/17/hello-world/#webpage", "url": "https://tcc.group/blog/2026/07/17/hello-world/", "name": "Hello world!", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-07-17T22:47:16+01:00", "dateModified": "2026-07-17T23:59:10+01:00", "breadcrumb": { "@id": "https://tcc.group/blog/2026/07/17/hello-world/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "Article", "@id": "https://tcc.group/blog/2026/07/17/hello-world/#article", "isPartOf": { "@id": "https://tcc.group/blog/2026/07/17/hello-world/#webpage" }, "author": { "@type": "Person", "name": "" }, "headline": "Hello world!", "datePublished": "2026-07-17T22:47:16+01:00", "dateModified": "2026-07-17T23:59:10+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/blog/2026/07/17/hello-world/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": null, "description": "Welcome to WordPress. This is your first post. Edit or delete it, then start writing!", "inLanguage": "en-GB", "articleBody": "Welcome to WordPress. This is your first post. Edit or delete it, then start writing!", "wordCount": 15 } ] } ``` ## Case Studies ### Remediation of ongoing services under section 166 - URL: https://tcc.group/case-studies/wealth-manager-remediation-of-ongoing-services-under-section166/ - Published: 2026-09-02 - Modified: 2026-09-02 **Service:** Managed services Discover how TCC Group supported a wealth management firm through a Section 166 investigation and remediation programme, providing a managed service that delivered large-scale case preparation, evidence gathering and operational support. #### The challenge A wealth management firm received a Section 166 (s.166) notification, prompting an investigatory review of issues related to ongoing services. The firm required external support to manage the scale and complexity of the upcoming remediation programme . The firm sought a partner that could offer flexibility in engagement and depth of service – from initial investigation to complete case remediation. #### Our approach TCC was engaged during the investigatory stage to provide tailored support in line with a clearly defined scope. Our team provided a managed service which included: - System interrogation and file building - Sourcing additional evidence via contact with third parties - Adviser contact and customer mailings - Validation of evidential documents to determine ongoing service activity - Managing pipeline activities to ensure timely responses - Responding to Skilled Person queries to ensure comprehensive evidence was provided - Case file preparation, resulting in the delivery of circa 4,000 complete case files over six months - Preparation of an additional 2,000 cases in readiness for remediation We also delivered wider programme support through: - Implementation of a case management system for workflow tracking - Engagement with the MI and Reporting departments to produce targeted MI - Data transfer coordination to a third-party provider - Full Managed Service ownership , including planning, client engagement, training, operational delivery and quality assurance #### Outcomes TCC’s comprehensive, flexible approach ensured the highest quality outputs were delivered on time and in line with agreed standards. The programme’s success led to a further engagement, this time supporting the client’s business-as-usual (BAU) operations. Our continued involvement included: - Policy and practice reviews - Investigation of BAU complaints - Ongoing BAU oversight and support Our adaptable delivery model, strong client relationships, and consistent performance have made TCC a trusted partner for this firm. We ensured that the client’s evolving needs are met with efficiency and satisfaction. [**Download case study**](https://25194947.fs1.hubspotusercontent-eu1.net/hubfs/25194947/TCC%20Case%20Studies/Case%20Study%20Remediation%20of%20ongoing%20services%20(S166)%20for%20a%20wealth%20management%20firm.pdf) #### Key facts - Completed case files delivered: 4000 cases - Remediation cases prepared: 2000 cases **Classifications:** Suitability, Advice Quality & File Reviews, Pensions & Retirement Income, Managed services - Reviewed by: TCC Editorial Team **Last reviewed:** 2026-09-02 #### Facing a Section 166 or Skilled Person review? Our managed services team offers end-to-end support, from initial investigation to complete case remediation, satisfying regulatory scrutiny. [Get in touch](https://staging.tcc.group/contact/) [Canonical source](https://staging.tcc.group/blog/2025/11/24/wealth-manager-remediation-of-ongoing-services-under-section166/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", 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"Service", "name": "Managed services", "provider": { "@id": "https://tcc.group/#organization" } }, { "@type": "Thing", "name": "Suitability, Advice Quality & File Reviews", "url": "https://tcc.group/blog/solution/outsourced-suitability-reviews/" }, { "@type": "Thing", "name": "Pensions & Retirement Income", "url": "https://tcc.group/blog/sector/pensions-retirement-income/" }, { "@type": "Thing", "name": "Managed services", "url": "https://tcc.group/blog/service/managed-services/" } ], "abstract": "Discover how TCC Group supported a wealth management firm through a Section 166 investigation and remediation programme, providing a managed service that delivered large-scale case preparation, evidence gathering and operational support.", "description": "Discover how TCC Group supported a wealth management firm through a Section 166 investigation and remediation programme, providing a managed service that delivered large-scale case preparation, evidence gathering and operational support.", "articleBody": "The challenge\n\nA wealth management firm received a Section 166 (s.166) notification, prompting an investigatory review of issues related to ongoing services. The firm required external support to manage the scale and complexity of the upcoming remediation programme . The firm sought a partner that could offer flexibility in engagement and depth of service \u2013 from initial investigation to complete case remediation.\n\nOur approach\n\nTCC was engaged during the investigatory stage to provide tailored support in line with a clearly defined scope.\n\nOur team provided a managed service which included:\n\u2022 System interrogation and file building\n\u2022 Sourcing additional evidence via contact with third parties\n\u2022 Adviser contact and customer mailings\n\u2022 Validation of evidential documents to determine ongoing service activity\n\u2022 Managing pipeline activities to ensure timely responses\n\u2022 Responding to Skilled Person queries to ensure comprehensive evidence was provided\n\u2022 Case file preparation, resulting in the delivery of circa 4,000 complete case files over six months\n\u2022 Preparation of an additional 2,000 cases in readiness for remediation\n\nWe also delivered wider programme support through:\n\u2022 Implementation of a case management system for workflow tracking\n\u2022 Engagement with the MI and Reporting departments to produce targeted MI\n\u2022 Data transfer coordination to a third-party provider\n\u2022 Full Managed Service ownership , including planning, client engagement, training, operational delivery and quality assurance\n\nOutcomes\n\nTCC\u2019s comprehensive, flexible approach ensured the highest quality outputs were delivered on time and in line with agreed standards. The programme\u2019s success led to a further engagement, this time supporting the client\u2019s business-as-usual (BAU) operations.\n\nOur continued involvement included:\n\u2022 Policy and practice reviews\n\u2022 Investigation of BAU complaints\n\u2022 Ongoing BAU oversight and support\n\nOur adaptable delivery model, strong client relationships, and consistent performance have made TCC a trusted partner for this firm. We ensured that the client\u2019s evolving needs are met with efficiency and satisfaction.\n\nDownload case study%20for%20a%20wealth%20management%20firm.pdf)", "wordCount": 313, "keywords": [ "Suitability, Advice Quality & File Reviews", "Pensions & Retirement Income", "Managed services" ], "articleSection": [ "Suitability, Advice Quality & File Reviews" ], "reviewedBy": { "@type": "Person", "name": "TCC Editorial Team" }, "potentialAction": { "@type": "ContactAction", "name": "Get in touch", "target": { "@type": "EntryPoint", "urlTemplate": "https://staging.tcc.group/contact/" } }, "mentions": [ { "@type": "QuantitativeValue", "name": "Completed case files delivered", "value": 4000, "unitText": "cases" }, { "@type": "QuantitativeValue", "name": "Remediation cases prepared", "value": 2000, "unitText": "cases" } ] } ] } ``` ### Comprehensive UCIS review without the cost burden - URL: https://tcc.group/case-studies/ucis-past-business-review/ - Published: 2026-09-02 - Modified: 2026-09-03 **Service:** Advisory Services Discover how TCC Group helped an IFA remediate unsuitable UCIS business following FCA findings, delivering specialist review expertise, cost-effective remediation support and sustainable improvements to future compliance oversight. #### The challenge An IFA had found significant problems with its past business – specifically with its UCIS cases. An FCA review had uncovered that there was no clear procedure for the classification of customers, meaning that in over 10% of cases the marketing of UCIS products was potentially unsuitable. Despite having a strong internal compliance team, they lacked specific knowledge on UCIS, so they asked us to review the FCA’s findings and determine the scale of the problem. #### Our approach We quickly identified a number of issues within the UCIS sales process, confirming what the FCA had found. Committed to delivering positive customer outcomes, our client asked us to handle the remediation phase which included producing loss adjustment reports, extensive product provider contact and customer contact. What’s more, we highlighted several measures that our client could build into their sales process and adviser training to ensure history wouldn’t repeat itself. Suspecting that the problem was more widespread, we extended the review to a larger population of cases. We knew our client would be concerned about the impact on the business, so we created a bespoke solution which minimised costs. This involved upskilling our client’s existing resource so they could handle UCIS cases in-house, while we provided quality assurance. As well as comprehensive training, we also provided licenses to our work-flow management system, making managing large-scale remediation projects much easier for our client. Our knowledge and operational expertise ensured that costs could be reduced without sacrificing quality, time or volume. Thanks to our consultative approach, our client not only dealt quickly with unsuitable past business and avoided regulatory action in the future, but also now has a cost-effective process for reviewing the suitability of UCIS cases on an ongoing basis. #### Outcomes - Our proactive approach meant that our client not only dealt with the issue at hand but also improved customer outcomes and futureproofed the compliance function - We knew that ongoing outsourcing wasn’t the right approach for our client. Because of our focus on their commercial and operational needs, we designed a bespoke solution that went above and beyond expectations while controlling costs - Rather than finding a quick fix, we went to lengths to fully understand the client’s needs and strike a balance between their commercial and regulatory requirements [**Download case study**](https://25194947.fs1.hubspotusercontent-eu1.net/hubfs/25194947/TCC%20Case%20Studies/TCC%20Case%20Study%20-%20Comprehensive%20UCIS%20Review.pdf) **Classifications:** Consolidation, Acquisition & Regulatory Due Diligence, Redress & Remediation, Regulatory Change & Transformation, Suitability, Advice Quality & File Reviews, Wealth Management & Financial Advice, Advisory, Managed services #### Is your firm facing a UCIS suitability review? Learn how our hybrid resourcing and workflow solutions can help you resolve legacy UCIS issues while upskilling your team. [Get in touch](https://staging.tcc.group/contact/) [Canonical source](https://staging.tcc.group/blog/2024/08/07/case-study-ucis-review-2/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", 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"@type": "Thing", "name": "Regulatory Change & Transformation", "url": "https://tcc.group/blog/solution/regulatory-change-transformation/" }, { "@type": "Thing", "name": "Suitability, Advice Quality & File Reviews", "url": "https://tcc.group/blog/solution/outsourced-suitability-reviews/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Advisory", "url": "https://tcc.group/blog/service/advisory/" }, { "@type": "Thing", "name": "Managed services", "url": "https://tcc.group/blog/service/managed-services/" } ], "abstract": "Discover how TCC Group helped an IFA remediate unsuitable UCIS business following FCA findings, delivering specialist review expertise, cost-effective remediation support and sustainable improvements to future compliance oversight.", "description": "Discover how TCC Group helped an IFA remediate unsuitable UCIS business following FCA findings, delivering specialist review expertise, cost-effective remediation support and sustainable improvements to future compliance oversight.", "articleBody": "The challenge\n\nAn IFA had found significant problems with its past business \u2013 specifically with its UCIS cases. An FCA review had uncovered that there was no clear procedure for the classification of customers, meaning that in over 10% of cases the marketing of UCIS products was potentially unsuitable. Despite having a strong internal compliance team, they lacked specific knowledge on UCIS, so they asked us to review the FCA\u2019s findings and determine the scale of the problem.\n\nOur approach\n\nWe quickly identified a number of issues within the UCIS sales process, confirming what the FCA had found. Committed to delivering positive customer outcomes, our client asked us to handle the remediation phase which included producing loss adjustment reports, extensive product provider contact and customer contact. What\u2019s more, we highlighted several measures that our client could build into their sales process and adviser training to ensure history wouldn\u2019t repeat itself.\r\n\r\nSuspecting that the problem was more widespread, we extended the review to a larger population of cases. We knew our client would be concerned about the impact on the business, so we created a bespoke solution which minimised costs. This involved upskilling our client\u2019s existing resource so they could handle UCIS cases in-house, while we provided quality assurance. As well as comprehensive training, we also provided licenses to our work-flow management system, making managing large-scale remediation projects much easier for our client. Our knowledge and operational expertise ensured that costs could be reduced without sacrificing quality, time or volume.\r\n\r\nThanks to our consultative approach, our client not only dealt quickly with unsuitable past business and avoided regulatory action in the future, but also now has a cost-effective process for reviewing the suitability of UCIS cases on an ongoing basis.\n\nOutcomes\n\n\u2022 Our proactive approach meant that our client not only dealt with the issue at hand but also improved customer outcomes and futureproofed the compliance function\n\u2022 We knew that ongoing outsourcing wasn\u2019t the right approach for our client. Because of our focus on their commercial and operational needs, we designed a bespoke solution that went above and beyond expectations while controlling costs\n\u2022 Rather than finding a quick fix, we went to lengths to fully understand the client\u2019s needs and strike a balance between their commercial and regulatory requirements\n\nDownload case study", "wordCount": 383, "keywords": [ "Consolidation, Acquisition & Regulatory Due Diligence", "Redress & Remediation", "Regulatory Change & Transformation", "Suitability, Advice Quality & File Reviews", "Wealth Management & Financial Advice", "Advisory", "Managed services" ], "articleSection": [ "Consolidation, Acquisition & Regulatory Due Diligence", "Redress & Remediation", "Regulatory Change & Transformation", "Suitability, Advice Quality & File Reviews" ], "potentialAction": { "@type": "ContactAction", "name": "Get in touch", "target": { "@type": "EntryPoint", "urlTemplate": "https://staging.tcc.group/contact/" } } } ] } ``` ### Top-end consultancy deployment: Strategic compliance leadership - URL: https://tcc.group/case-studies/top-end-consultancy-deployment/ - Published: 2026-09-02 - Modified: 2026-09-02 **Service:** Specialist resourcing Discover how TCC Group strengthened a financial services group's risk and compliance framework by providing interim compliance leadership, enhancing governance structures and establishing an effective assurance function across the UK and Republic of Ireland #### The challenge The client was looking for an interim Head of Compliance to review the Group’s risk and compliance arrangements. #### Our approach The TCC recommendations included: - Strengthen controls with the first line of defence (1LOD) - Establish a compliance function as an effective assurance function operating within the second line of defence (2LOD). TCC introduced an interim Head of Compliance for the UK and Republic of Ireland operations to implement our recommendations. In particular, the operational organisation of the compliance function that supports and guides the group to improve its risk and control environment (within 1LOD). Delivery objectives were set within a six-month delivery timetable. #### Outcomes The work delivered within the compliance function: - Set out how the compliance would be organised to support the Group and provide assurance to senior management - Identified resources needed and hired suitable experts and skilled teams - Reorganised the day-to-day operation and allocated tasks and responsibilities - Overseen the implementation of new ways of working and the embedding of new operational practices - Established and delivered a suitable risk-based programme of assurance - Supported the Group to achieve its strategic objectives, including the implementation of operational change, and the acquisition and integration of new businesses. [**Download case study**](https://25194947.fs1.hubspotusercontent-eu1.net/hubfs/25194947/TCC%20Case%20Studies/TCC%20Case%20Study%20-%20Top-end%20consultancy%20deployment%20Strategic%20compliance%20leadership.pdf) #### Key facts - Delivery timetable: 6 months **Classifications:** Consolidation, Acquisition & Regulatory Due Diligence, Regulatory Change & Transformation, Banking, General Insurance & Protection, Wealth Management & Financial Advice, Advisory, Specialist resourcing #### Need experienced interim compliance leadership? Speak to our advisory specialists to deploy senior interim heads of compliance and risk leaders to guide your organisation. 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"url": "https://staging.tcc.group/blog/2026/01/21/case-study-top-end-consultancy-deployment/", "isPartOf": { "@id": "https://tcc.group/case-studies/top-end-consultancy-deployment/#webpage" }, "mainEntityOfPage": { "@id": "https://tcc.group/case-studies/top-end-consultancy-deployment/#webpage" }, "datePublished": "2026-01-21", "dateModified": "2026-09-02T15:37:01+01:00", "inLanguage": "en-GB", "author": { "@id": "https://tcc.group/#organization" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/0fde6a5791e1488188e0133573e2a09d/thumbnail-1600-020f39b468e65eede0343ed7de91faf74b5d23f0e2cb29a63ab5fb07584df2cd.jpg", "about": [ { "@type": "Service", "name": "Specialist resourcing", "provider": { "@id": "https://tcc.group/#organization" } }, { "@type": "Thing", "name": "Consolidation, Acquisition & Regulatory Due Diligence", "url": "https://tcc.group/blog/solution/consolidation-acquisition-regulatory-due-diligence/" }, { "@type": "Thing", "name": "Regulatory Change & Transformation", "url": "https://tcc.group/blog/solution/regulatory-change-transformation/" }, { "@type": "Thing", "name": "Banking", "url": "https://tcc.group/blog/sector/banking/" }, { "@type": "Thing", "name": "General Insurance & Protection", "url": "https://tcc.group/blog/sector/general-insurance-protection/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Advisory", "url": "https://tcc.group/blog/service/advisory/" }, { "@type": "Thing", "name": "Specialist resourcing", "url": "https://tcc.group/blog/service/specialist-resourcing/" } ], "abstract": "Discover how TCC Group strengthened a financial services group's risk and compliance framework by providing interim compliance leadership, enhancing governance structures and establishing an effective assurance function across the UK and Republic of Ireland", "description": "Discover how TCC Group strengthened a financial services group's risk and compliance framework by providing interim compliance leadership, enhancing governance structures and establishing an effective assurance function across the UK and Republic of Ireland", "articleBody": "The challenge\n\nThe client was looking for an interim Head of Compliance to review the Group\u2019s risk and compliance arrangements.\n\nOur approach\n\nThe TCC recommendations included:\n\u2022 Strengthen controls with the first line of defence (1LOD)\n\u2022 Establish a compliance function as an effective assurance function operating within the second line of defence (2LOD).\n\nTCC introduced an interim Head of Compliance for the UK and Republic of Ireland operations to implement our recommendations. In particular, the operational organisation of the compliance function that supports and guides the group to improve its risk and control environment (within 1LOD).\n\nDelivery objectives were set within a six-month delivery timetable.\n\nOutcomes\n\nThe work delivered within the compliance function:\n\u2022 Set out how the compliance would be organised to support the Group and provide assurance to senior management\n\u2022 Identified resources needed and hired suitable experts and skilled teams\n\u2022 Reorganised the day-to-day operation and allocated tasks and responsibilities\n\u2022 Overseen the implementation of new ways of working and the embedding of new operational practices\n\u2022 Established and delivered a suitable risk-based programme of assurance\n\u2022 Supported the Group to achieve its strategic objectives, including the implementation of operational change, and the acquisition and integration of new businesses.\n\nDownload case study", "wordCount": 206, "keywords": [ "Consolidation, Acquisition & Regulatory Due Diligence", "Regulatory Change & Transformation", "Banking", "General Insurance & Protection", "Wealth Management & Financial Advice", "Advisory", "Specialist resourcing" ], "articleSection": [ "Consolidation, Acquisition & Regulatory Due Diligence", "Regulatory Change & Transformation" ], "potentialAction": { "@type": "ContactAction", "name": "Get in touch", "target": { "@type": "EntryPoint", "urlTemplate": "https://staging.tcc.group/contact/" } }, "mentions": [ { "@type": "QuantitativeValue", "name": "Delivery timetable", "value": 6, "unitText": "months" } ] } ] } ``` ### Strategic resourcing: Complex claims handling - URL: https://tcc.group/case-studies/strategic-resourcing-complex-claims/ - Published: 2026-09-02 - Modified: 2026-09-02 **Service:** Specialist resourcing Discover how TCC Group supported a complex claims handling programme in the wealth sector, providing specialist resource, technical expertise and quality assurance through a long-term resourcing partnership. #### The challenge The client engaged TCC to operate as the resource augmentation partner for the Managed Services division of a big four firm to provide specialist resource and assist in the delivery of a multiyear, outsourced complex claims handling programme across numerous workstreams in the wealth sector. #### Our approach TCC’s resourcing specialists consulted with the client, provided key market demographics and commercial information during the tender process – and played a vital role in assisting the client in securing the contract. - The client leveraged TCC’s extensive market knowledge and network of skilled associates with advice suitability experience and relevant qualifications - TCC identified and deployed two technical subject matter experts (SMEs) at the outset of the programme to build the quality assurance framework, and be on hand to address all technical product queries - We deployed a large team of skilled reviewers and claims handlers across all key claims workstreams, including SIPPs, defined benefit (DB) pensions, investments, shares, mortgage advice and protection insurance. #### Outcomes - Enabled the client to ramp up with skilled specialist resource within weeks to be able to successfully deal with all incoming claims volumes - Established the core reviewer and claims handling team within the programme. Driving productivity and skills sharing across the programme - Continued to provide additional key resource in all areas to deal with spikes in volume throughout the duration of the programme [**Download case study**](https://25194947.fs1.hubspotusercontent-eu1.net/hubfs/25194947/TCC%20Case%20Studies/TCC%20Case%20Study%20-%20Strategic%20resourcing%20Complex%20claims%20handling.pdf) #### Key facts - Technical SMEs deployed: 2 SMEs **Classifications:** Complaints & Claims Handling, Redress & Remediation, Suitability, Advice Quality & File Reviews, Vulnerable Customers, Banking, General Insurance & Protection, Lending & Consumer Credit, Pensions & Retirement Income, Wealth Management & Financial Advice, Managed services, Specialist resourcing #### Need specialist complex claims handlers? Partner with our resourcing team to secure qualified SIPP, pensions, and investments claims reviewers for your managed services. [Get in touch](https://staging.tcc.group/contact/) [Canonical source](https://staging.tcc.group/blog/2026/01/21/case-study-strategic-resourcing-complex-claims/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ 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"https://staging.tcc.group/blog/2026/01/21/case-study-strategic-resourcing-complex-claims/", "isPartOf": { "@id": "https://tcc.group/case-studies/strategic-resourcing-complex-claims/#webpage" }, "mainEntityOfPage": { "@id": "https://tcc.group/case-studies/strategic-resourcing-complex-claims/#webpage" }, "datePublished": "2026-01-21", "dateModified": "2026-09-02T14:34:39+01:00", "inLanguage": "en-GB", "author": { "@id": "https://tcc.group/#organization" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/4056cdc74c554e818b095a38138dc562/thumbnail-1600-f4d318d71c0c08dc29fcdbee54750d25d50b01920dda242d982cfe25fdc03ecd.jpg", "about": [ { "@type": "Service", "name": "Specialist resourcing", "provider": { "@id": "https://tcc.group/#organization" } }, { "@type": "Thing", "name": "Complaints & Claims Handling", "url": "https://tcc.group/blog/solution/complaints-claims-handling/" }, { "@type": "Thing", "name": "Redress & Remediation", "url": "https://tcc.group/blog/solution/redress-and-remediation/" }, { "@type": "Thing", "name": "Suitability, Advice Quality & File Reviews", "url": "https://tcc.group/blog/solution/outsourced-suitability-reviews/" }, { "@type": "Thing", "name": "Vulnerable Customers", "url": "https://tcc.group/blog/solution/vulnerable-customers/" }, { "@type": "Thing", "name": "Banking", "url": "https://tcc.group/blog/sector/banking/" }, { "@type": "Thing", "name": "General Insurance & Protection", "url": "https://tcc.group/blog/sector/general-insurance-protection/" }, { "@type": "Thing", "name": "Lending & Consumer Credit", "url": "https://tcc.group/blog/sector/lending-consumer-credit/" }, { "@type": "Thing", "name": "Pensions & Retirement Income", "url": "https://tcc.group/blog/sector/pensions-retirement-income/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Managed services", "url": "https://tcc.group/blog/service/managed-services/" }, { "@type": "Thing", "name": "Specialist resourcing", "url": "https://tcc.group/blog/service/specialist-resourcing/" } ], "abstract": "Discover how TCC Group supported a complex claims handling programme in the wealth sector, providing specialist resource, technical expertise and quality assurance through a long-term resourcing partnership.", "description": "Discover how TCC Group supported a complex claims handling programme in the wealth sector, providing specialist resource, technical expertise and quality assurance through a long-term resourcing partnership.", "articleBody": "The challenge\n\nThe client engaged TCC to operate as the resource augmentation partner for the Managed Services division of a big four firm to provide specialist resource and assist in the delivery of a multiyear, outsourced complex claims handling programme across numerous workstreams in the wealth sector.\n\nOur approach\n\nTCC\u2019s resourcing specialists consulted with the client, provided key market demographics and commercial information during the tender process \u2013 and played a vital role in assisting the client in securing the contract.\n\u2022 The client leveraged TCC\u2019s extensive market knowledge and network of skilled associates with advice suitability experience and relevant qualifications\n\u2022 TCC identified and deployed two technical subject matter experts (SMEs) at the outset of the programme to build the quality assurance framework, and be on hand to address all technical product queries\n\u2022 We deployed a large team of skilled reviewers and claims handlers across all key claims workstreams, including SIPPs, defined benefit (DB) pensions, investments, shares, mortgage advice and protection insurance.\n\nOutcomes\n\n\u2022 Enabled the client to ramp up with skilled specialist resource within weeks to be able to successfully deal with all incoming claims volumes\n\u2022 Established the core reviewer and claims handling team within the programme. Driving productivity and skills sharing across the programme\n\u2022 Continued to provide additional key resource in all areas to deal with spikes in volume throughout the duration of the programme\n\nDownload case study", "wordCount": 234, "keywords": [ "Complaints & Claims Handling", "Redress & Remediation", "Suitability, Advice Quality & File Reviews", "Vulnerable Customers", "Banking", "General Insurance & Protection", "Lending & Consumer Credit", "Pensions & Retirement Income", "Wealth Management & Financial Advice", "Managed services", "Specialist resourcing" ], "articleSection": [ "Complaints & Claims Handling", "Redress & Remediation", "Suitability, Advice Quality & File Reviews", "Vulnerable Customers" ], "potentialAction": { "@type": "ContactAction", "name": "Get in touch", "target": { "@type": "EntryPoint", "urlTemplate": "https://staging.tcc.group/contact/" } }, "mentions": [ { "@type": "QuantitativeValue", "name": "Technical SMEs deployed", "value": 2, "unitText": "SMEs" } ] } ] } ``` ### Specialist resourcing: Strategic partnership - URL: https://tcc.group/case-studies/specialist-resourcing-strategic-partnership/ - Published: 2026-09-02 - Modified: 2026-09-02 **Service:** Specialist resourcing Learn how TCC Group has supported over 50 clients across the UK, EMEA and APAC, providing specialist interim resource to meet complex operational, regulatory and transformation demands. #### Our approach For over two decades, we’ve been providing specialist interim resource to support our client’s countless business functions, including: - Risk - Remediation - Past business review - Change and transformation - Technology - Complaints servicing - Financial crime - Training and development, and many more. In addition to the financial services sector, our capability spans multiple industries, supporting clients across IT and software, public sector, healthcare, pharmaceuticals, automotive and legal sectors. **Major high street bank: Large volume resource scale-up** Operating to rigorous standards, TCC Group carefully designed an intake plan of 50+ interim resource per week across two locations, to achieve and sustain a headcount of 1,100 resource. Working closely with the end client and our Big 4 partner, the TCC Group team consistently met the client’s stringent productivity and quality targets. The project closed after 61 months of successful operation. **Wealth management: Pensions and investments reviews** With increasing levels of scrutiny in the wealth advice sector, TCC Group deployed an initial team of 20 associates with mixed qualification levels to support reviews of both pensions and investments. Following the initial success, the project continues to expand **Tier 1 Bank: Financial difficulties – case handlers** TCC Group is actively resourcing experienced financial difficulties case handlers to support vulnerable customers who have fallen into arrears. At its peak, we were deploying a team of 200 associates. Following operational improvements, a consistent headcount of 160 resources is maintained. **Automation robotics** TCC Group has resourced 50 specialist roles across a wide range of technology areas, including automation engineering, software development, dev-ops, project and change management, and service desk support. The success of this project enabled our partner to significantly expand its client base. **Superannuation early release** Under the backdrop of COVID-19, TCC Group created a bespoke work-from-home solution for our partner, consisting of 15 associates – and the team was operational within one week. #### Outcomes **Working with TCC Group** - 20+ years of strategic alliance - 300+ individual projects serviced - Worked with 50+ clients in the UK, EMEA and APAC - 8,000+ resource deployed - 500+ different role functions resourced Delivered in partnership with Momenta, a TCC Group company. [**Download case study**](https://25194947.fs1.hubspotusercontent-eu1.net/hubfs/25194947/TCC%20Case%20Studies/TCC%20Case%20Study%20-%20Specialist%20resourcing%20Strategic%20partnership.pdf) #### Key facts - Resources deployed: 8000+ associates - Individual projects serviced: 300 projects - Strategic alliance duration: 20 years - Different role functions: 500+ resourced **Classifications:** Complaints & Claims Handling, Financial Crime Compliance, Redress & Remediation, Regulatory Change & Transformation, Suitability, Advice Quality & File Reviews, Vulnerable Customers, Banking, General Insurance & Protection, Lending & Consumer Credit, Motor Finance, Payments & FinTech, Pensions & Retirement Income, Wealth Management & Financial Advice, Advisory, Specialist resourcing #### Looking for an enterprise-grade resourcing partner? Contact our strategic partnership team today to access high-quality, pre-vetted resource pools for large-scale operations. [Get in touch](https://staging.tcc.group/contact/) [Canonical source](https://staging.tcc.group/blog/2026/01/21/case-study-specialist-resourcing-strategic-partnership/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 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"https://tcc.group/blog/solution/complaints-claims-handling/" }, { "@type": "Thing", "name": "Financial Crime Compliance", "url": "https://tcc.group/blog/solution/financial-crime-compliance/" }, { "@type": "Thing", "name": "Redress & Remediation", "url": "https://tcc.group/blog/solution/redress-and-remediation/" }, { "@type": "Thing", "name": "Regulatory Change & Transformation", "url": "https://tcc.group/blog/solution/regulatory-change-transformation/" }, { "@type": "Thing", "name": "Suitability, Advice Quality & File Reviews", "url": "https://tcc.group/blog/solution/outsourced-suitability-reviews/" }, { "@type": "Thing", "name": "Vulnerable Customers", "url": "https://tcc.group/blog/solution/vulnerable-customers/" }, { "@type": "Thing", "name": "Banking", "url": "https://tcc.group/blog/sector/banking/" }, { "@type": "Thing", "name": "General Insurance & Protection", "url": "https://tcc.group/blog/sector/general-insurance-protection/" }, { "@type": "Thing", "name": "Lending & Consumer Credit", "url": "https://tcc.group/blog/sector/lending-consumer-credit/" }, { "@type": "Thing", "name": "Motor Finance", "url": "https://tcc.group/blog/sector/motor-finance/" }, { "@type": "Thing", "name": "Payments & FinTech", "url": "https://tcc.group/blog/sector/payments-fintech/" }, { "@type": "Thing", "name": "Pensions & Retirement Income", "url": "https://tcc.group/blog/sector/pensions-retirement-income/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Advisory", "url": "https://tcc.group/blog/service/advisory/" }, { "@type": "Thing", "name": "Specialist resourcing", "url": "https://tcc.group/blog/service/specialist-resourcing/" } ], "abstract": "Learn how TCC Group has supported over 50 clients across the UK, EMEA and APAC, providing specialist interim resource to meet complex operational, regulatory and transformation demands.", "description": "Learn how TCC Group has supported over 50 clients across the UK, EMEA and APAC, providing specialist interim resource to meet complex operational, regulatory and transformation demands.", "articleBody": "Our approach\n\nFor over two decades, we\u2019ve been providing specialist interim resource to support our client\u2019s countless business functions, including:\n\u2022 Risk\n\u2022 Remediation\n\u2022 Past business review\n\u2022 Change and transformation\n\u2022 Technology\n\u2022 Complaints servicing\n\u2022 Financial crime\n\u2022 Training and development, and many more.\n\nIn addition to the financial services sector, our capability spans multiple industries, supporting clients across IT and software, public sector, healthcare, pharmaceuticals, automotive and legal sectors.\n\nMajor high street bank: Large volume resource scale-up\nOperating to rigorous standards, TCC Group carefully designed an intake plan of 50+ interim resource per week across two locations, to achieve and sustain a headcount of 1,100 resource. Working closely with the end client and our Big 4 partner, the TCC Group team consistently met the client\u2019s stringent productivity and quality targets. The project closed after 61 months of successful operation.\n\nWealth management: Pensions and investments reviews\nWith increasing levels of scrutiny in the wealth advice sector, TCC Group deployed an initial team of 20 associates with mixed qualification levels to support reviews of both pensions and investments. Following the initial success, the project continues to expand\n\nTier 1 Bank: Financial difficulties \u2013 case handlers\nTCC Group is actively resourcing experienced financial difficulties case handlers to support vulnerable customers who have fallen into arrears. At its peak, we were deploying a team of 200 associates. Following operational improvements, a consistent headcount of 160 resources is maintained.\n\nAutomation robotics\nTCC Group has resourced 50 specialist roles across a wide range of technology areas, including automation engineering, software development, dev-ops, project and change management, and service desk support. The success of this project enabled our partner to significantly expand its client base.\n\nSuperannuation early release\nUnder the backdrop of COVID-19, TCC Group created a bespoke work-from-home solution for our partner, consisting of 15 associates \u2013 and the team was operational within one week.\n\nOutcomes\n\nWorking with TCC Group\n\u2022 20+ years of strategic alliance\n\u2022 300+ individual projects serviced\n\u2022 Worked with 50+ clients in the UK, EMEA and APAC\n\u2022 8,000+ resource deployed\n\u2022 500+ different role functions resourced\n\nDelivered in partnership with Momenta, a TCC Group company.\n\nDownload case study", "wordCount": 362, "keywords": [ "Complaints & Claims Handling", "Financial Crime Compliance", "Redress & Remediation", "Regulatory Change & Transformation", "Suitability, Advice Quality & File Reviews", "Vulnerable Customers", "Banking", "General Insurance & Protection", "Lending & Consumer Credit", "Motor Finance", "Payments & FinTech", "Pensions & Retirement Income", "Wealth Management & Financial Advice", "Advisory", "Specialist resourcing" ], "articleSection": [ "Complaints & Claims Handling", "Financial Crime Compliance", "Redress & Remediation", "Regulatory Change & Transformation", "Suitability, Advice Quality & File Reviews", "Vulnerable Customers" ], "potentialAction": { "@type": "ContactAction", "name": "Get in touch", "target": { "@type": "EntryPoint", "urlTemplate": "https://staging.tcc.group/contact/" } }, "mentions": [ { "@type": "PropertyValue", "name": "Resources deployed", "value": "8000+", "unitText": "associates" }, { "@type": "QuantitativeValue", "name": "Individual projects serviced", "value": 300, "unitText": "projects" }, { "@type": "QuantitativeValue", "name": "Strategic alliance duration", "value": 20, "unitText": "years" }, { "@type": "PropertyValue", "name": "Different role functions", "value": "500+", "unitText": "resourced" } ] } ] } ``` ### Specialist resourcing - URL: https://tcc.group/case-studies/specialist-resourcing-large-projects/ - Published: 2026-09-02 - Modified: 2026-09-03 **Service:** Advisory Services Discover how TCC Group helped a leading advice and investment management firm launch a large scale defined benefit pension transfer remediation programme by rapidly providing specialist resource, infrastructure and operational support to meet FCA deadlines. #### The challenge Following an FCA review, a leading advice and investment management firm uncovered widespread unsuitable advice around defined benefit (DB) pension transfers. With regulatory pressure mounting, it needed to set up a large-scale remediation project as soon as possible. To complete the project within the FCA’s tight timescales, our client needed a 70-strong team, but finding first-rate compliance resource at such short notice was proving to be a drain on time and budget. #### Our approach It was a largescale and complex project, but thankfully for our client, we took care of the resource, systems and infrastructure needed to get it up and running as quickly as possible. Thanks to our extensive pool of over 5,000 pre-vetted contractors, finding appropriately qualified candidates was no problem. We handled the entire onboarding process for our client, from initial interview through to induction training. As compliance experts, we knew exactly what our client needed and our rigorous route to competency framework meant that our contractors were ready to hit the ground running from day one. What’s more, when we identified that our client would need a whole new team of contractors at the last minute, our scalable resourcing model meant we could provide them quickly and smoothly integrate them into the team. The nature of the project meant that it was highly confidential and all activity needed to be conducted on a secure site. So as well as providing the resource, we gave our client exclusive use of our remediation centre in Leeds along with IT and telephony infrastructure, including our RegTech supported customer contact system. Our flexible and responsive approach meant that our client had its project up and running in no time and was able to meet the FCA’s timescales for delivery. #### Outcomes - With access to an extensive pool of qualified contractors, we could provide the necessary resource much quicker than any other provider - As compliance experts first and foremost, we knew that our client needed high-quality, experienced contractors, and we designed a rigorous assessment and onboarding process to make sure they were up to scratch - Our flexible approach meant we could quickly respond to our client’s changing needs, including scaling up the infrastructure and additional resource [**Download case study**](https://25194947.fs1.hubspotusercontent-eu1.net/hubfs/25194947/TCC%20Case%20Studies/TCC%20Case%20Study%20-%20Specialist%20Resourcing.pdf) #### Key facts - Contractor network size: 5,000 associates - Remediation team size: 70 specialists **Classifications:** Redress & Remediation, Regulatory Change & Transformation, Suitability, Advice Quality & File Reviews, Wealth Management & Financial Advice, Advisory, Specialist resourcing #### Running a large-scale compliance resourcing project? Speak to our team today to discover how our extensive pool of contractors can accelerate your project. [Get in touch](https://staging.tcc.group/contact/) [Canonical source](https://staging.tcc.group/blog/2024/07/29/case-study-specialist-resourcing-large-projects/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 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& Transformation", "url": "https://tcc.group/blog/solution/regulatory-change-transformation/" }, { "@type": "Thing", "name": "Suitability, Advice Quality & File Reviews", "url": "https://tcc.group/blog/solution/outsourced-suitability-reviews/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Advisory", "url": "https://tcc.group/blog/service/advisory/" }, { "@type": "Thing", "name": "Specialist resourcing", "url": "https://tcc.group/blog/service/specialist-resourcing/" } ], "abstract": "Discover how TCC Group helped a leading advice and investment management firm launch a large scale defined benefit pension transfer remediation programme by rapidly providing specialist resource, infrastructure and operational support to meet FCA deadlines.", "description": "Discover how TCC Group helped a leading advice and investment management firm launch a large scale defined benefit pension transfer remediation programme by rapidly providing specialist resource, infrastructure and operational support to meet FCA deadlines.", "articleBody": "The challenge\n\nFollowing an FCA review, a leading advice and investment management firm uncovered widespread unsuitable advice around defined benefit (DB) pension transfers. 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With regulatory pressure mounting, it needed to set up a large-scale remediation project as soon as possible. To complete the project within the FCA’s tight timescales, our client needed a 70-strong team, but finding first-rate compliance resource at such short notice was proving to be a drain on time and budget. #### Our approach It was a largescale and complex project, but thankfully for our client, we took care of the resource, systems and infrastructure needed to get it up and running as quickly as possible. Thanks to our extensive pool of over 5,000 pre-vetted contractors, finding appropriately qualified candidates was no problem. We handled the entire onboarding process for our client, from initial interview through to induction training. As compliance experts, we knew exactly what our client needed and our rigorous route to competency framework meant that our contractors were ready to hit the ground running from day one. What’s more, when we identified that our client would need a whole new teams of contractors at the last minute, our scalable resourcing model meant we could provide them quickly and smoothly integrate them into the team. The nature of the project meant that it was highly confidential and all activity needed to be conducted on a secure site. So as well as providing the resource, we gave our client exclusive use of our remediation centre in Leeds along with IT and telephony infrastructure, including our RegTech supported customer contact system. Our flexible and responsive approach meant that our client had its project up and running in no time and was able to meet the FCA’s timescales for delivery. #### Outcomes With access to an extensive pool of qualified contractors, we could provide the necessary resource much quicker than any other provider. As compliance experts first and foremost, we knew that our client needed high-quality, experienced contractors, and we designed a rigorous assessment and onboarding process to make sure they were up to scratch. Our flexible approach meant we could quickly respond to our client’s changing needs, including scaling up the infrastructure and additional resource. Number of first-rate compliance professionals sourced Number of pre-vetted professionals we have at our fingertips Learn about our leading resourcing solution #### Key facts - Contractor network size: 5000 associates - Remediation team size: 70 specialists **Classifications:** Redress & Remediation, Regulatory Change & Transformation, Suitability, Advice Quality & File Reviews, Pensions & Retirement Income, Wealth Management & Financial Advice, Specialist resourcing #### Need specialized resourcing at scale? Partner with our resourcing specialists to quickly secure pre-vetted compliance professionals and full project infrastructure. [Get in touch](https://staging.tcc.group/contact/) [Canonical source](https://tcc.group/blog/2018/11/14/case-study-specialist-resourcing/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", 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"https://tcc.group/blog/solution/outsourced-suitability-reviews/" }, { "@type": "Thing", "name": "Pensions & Retirement Income", "url": "https://tcc.group/blog/sector/pensions-retirement-income/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Specialist resourcing", "url": "https://tcc.group/blog/service/specialist-resourcing/" } ], "abstract": "TCC Group provided comprehensive resourcing, systems, and secure infrastructure in Leeds to help a leading advice firm establish a 70-strong team and address unsuitable pension advice timescales.", "description": "TCC Group provided comprehensive resourcing, systems, and secure infrastructure in Leeds to help a leading advice firm establish a 70-strong team and address unsuitable pension advice timescales.", "articleBody": "The challenge\n\nFollowing an FCA review, a leading advice and investment management firm uncovered widespread unsuitable advice around defined benefit (DB) pension transfers. With regulatory pressure mounting, it needed to set up a large-scale remediation project as soon as possible. To complete the project within the FCA\u2019s tight timescales, our client needed a 70-strong team, but finding first-rate compliance resource at such short notice was proving to be a drain on time and budget.\n\nOur approach\n\nIt was a largescale and complex project, but thankfully for our client, we took care of the resource, systems and infrastructure needed to get it up and running as quickly as possible. Thanks to our extensive pool of over 5,000 pre-vetted contractors, finding appropriately qualified candidates was no problem. We handled the entire onboarding process for our client, from initial interview through to induction training. As compliance experts, we knew exactly what our client needed and our rigorous route to competency framework meant that our contractors were ready to hit the ground running from day one. What\u2019s more, when we identified that our client would need a whole new teams of contractors at the last minute, our scalable resourcing model meant we could provide them quickly and smoothly integrate them into the team. The nature of the project meant that it was highly confidential and all activity needed to be conducted on a secure site. So as well as providing the resource, we gave our client exclusive use of our remediation centre in Leeds along with IT and telephony infrastructure, including our RegTech supported customer contact system. Our flexible and responsive approach meant that our client had its project up and running in no time and was able to meet the FCA\u2019s timescales for delivery.\n\nOutcomes\n\nWith access to an extensive pool of qualified contractors, we could provide the necessary resource much quicker than any other provider. As compliance experts first and foremost, we knew that our client needed high-quality, experienced contractors, and we designed a rigorous assessment and onboarding process to make sure they were up to scratch. Our flexible approach meant we could quickly respond to our client\u2019s changing needs, including scaling up the infrastructure and additional resource. 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Having already invested heavily into getting the business SMCR ready, our client wanted to be sure there were no areas of non-compliance that could unravel all the good work it had already done. But, it was also in the midst of dealing with the fallout of the Covid-19 crisis and simply didn’t have the time or available resource to do this itself. #### Our approach First, we took the time to truly understand our client’s business, its commercial drivers and challenges. Then, we designed a review process that balanced this with FCA expectations, taking into account industry best practice. This included a thorough review of its SMCR arrangements and a remote desk-based review of its documentation – all backed up by video interviews with key stakeholders. We considered: How appropriately our client had identified the senior management and certified population, and allocated responsibilities. Whether the statements of responsibility and certification process were up to scratch.—The effectiveness of our client’s process for assessing fitness and propriety. The effectiveness of the governance arrangements, including oversight, monitoring and record keeping relating to the implementation and ongoing maintenance of the SMCR framework. The quality of the scheduled training plan, process and record keeping arrangements for the conduct rules. The effectiveness of policies and procedures to assess adherence with the relevant rules and guidance. Having presented our findings in a high-level written report, we worked collaboratively with our client to discuss the findings and outline improvements that could be made. What’s more, as culture experts, we also provided insight on how they could improve their culture to support their SMCR efforts, taking their approach to the next level. #### Outcomes Taking a collaborative approach, we designed a comprehensive but unobtrusive review process that could flex around our client’s busy workload. Our regulatory expertise, combined with our commercial approach and industry exposure, helped our client to take action that really made a difference. Because we understand the link between SMCR and culture, we identified areas for cultural improvement to support our client’s wider SMCR framework and ensure ongoing compliance. Taking a collaborative approach, we designed a comprehensive but unobtrusive review Keep on top of regulatory change and unlock commercial success. **Classifications:** Regulatory Change & Transformation, Section 166, Skilled Person Reviews & FCA Intervention, General Insurance & Protection, Pensions & Retirement Income, Wealth Management & Financial Advice, Advisory #### Need a post-implementation SMCR review? Speak to our compliance experts today to ensure your SMCR framework remains robust, compliant, and culturally aligned. [Get in touch](https://staging.tcc.group/contact/) [Canonical source](https://tcc.group/blog/2020/07/06/case-study-smcr-post-implementation-review/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person 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"https://tcc.group/blog/solution/section-166-skilled-person-reviews-fca-intervention/" }, { "@type": "Thing", "name": "General Insurance & Protection", "url": "https://tcc.group/blog/sector/general-insurance-protection/" }, { "@type": "Thing", "name": "Pensions & Retirement Income", "url": "https://tcc.group/blog/sector/pensions-retirement-income/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Advisory", "url": "https://tcc.group/blog/service/advisory/" } ], "abstract": "We delivered a collaborative, remote SMCR post-implementation review for a leading general insurance firm, verifying their governance frameworks and providing recommendations for cultural enhancement.", "description": "We delivered a collaborative, remote SMCR post-implementation review for a leading general insurance firm, verifying their governance frameworks and providing recommendations for cultural enhancement.", "articleBody": "The challenge\n\nOur client, a leading general insurance firm, wanted extra assurance around its post-implementation SMCR position. Having already invested heavily into getting the business SMCR ready, our client wanted to be sure there were no areas of non-compliance that could unravel all the good work it had already done. But, it was also in the midst of dealing with the fallout of the Covid-19 crisis and simply didn\u2019t have the time or available resource to do this itself.\n\nOur approach\n\nFirst, we took the time to truly understand our client\u2019s business, its commercial drivers and challenges. Then, we designed a review process that balanced this with FCA expectations, taking into account industry best practice. This included a thorough review of its SMCR arrangements and a remote desk-based review of its documentation \u2013 all backed up by video interviews with key stakeholders. We considered: How appropriately our client had identified the senior management and certified population, and allocated responsibilities. 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Taking a collaborative approach, we designed a comprehensive but unobtrusive review Keep on top of regulatory change and unlock commercial success.", "wordCount": 379, "keywords": [ "Regulatory Change & Transformation", "Section 166, Skilled Person Reviews & FCA Intervention", "General Insurance & Protection", "Pensions & Retirement Income", "Wealth Management & Financial Advice", "Advisory" ], "articleSection": [ "Regulatory Change & Transformation", "Section 166, Skilled Person Reviews & FCA Intervention" ], "potentialAction": { "@type": "ContactAction", "name": "Get in touch", "target": { "@type": "EntryPoint", "urlTemplate": "https://staging.tcc.group/contact/" } } } ] } ``` ### SMCR assurance - URL: https://tcc.group/case-studies/smcr-assurance/ - Published: 2026-09-02 - Modified: 2026-09-02 **Service:** Advisory services We conducted an independent SMCR assurance review for a leading insurance broker, identifying key gaps in documentation and responsibilities to ensure compliance prior to FCA submission. #### The challenge A leading insurance broker had been busy preparing for the new Senior Managers and Certification Regime (SMCR). Its in-house team had spent a lot of time doing a comprehensive gap analysis and making the necessary changes to the firm’s policies and procedures. With all the time and resources they had already invested, they needed to make sure they'd covered all bases before submitting their evidence to the FCA. #### Our approach Having worked with us before, they knew we had the right experience of managing regulatory change programmes. Our review included: An in-depth analysis of our client’s implementation programme, looking for potential gaps in the allocation of responsibilities, missing documentation and deficiencies in new and existing policies and procedures. Interviews with key managers. Benchmarking our client’s approach against other similar firms we had worked with and advising our client what they needed to do to meet industry standards. Benchmarking against common misunderstandings and issues identified from intel from the banking sector implementation approach. We identified some gaps and overlaps in allocation of responsibilities and recommended where reasonable steps could be better evidenced. We also suggested updates to existing policies that had originally been missed, including the recruitment and selection and performance management policies. Because we spotted these issues early, our client could take action immediately, before submission. SMCR is not just a box ticking exercise but a holistic rethink of internal culture. So, as well as giving our client peace of mind about their SMCR compliance, we also outlined the wider implications of the accountability regime and made recommendations on how they could foster a healthy culture that promoted a successful and sustainable future. #### Outcomes Our wide industry knowledge and regulatory expertise meant we spotted weaknesses in our client’s approach, which were missed by its in-house team. By engaging us to review their SMCR implementation early, our client could quickly make changes before the approach was embedded, saving them from costly reworks. Because we understand the link between culture and SMCR, we identified areas of the client’s internal culture that could be enhanced, ultimately bringing about better long-term customer and commercial outcomes. Turn disruptive regulatory change into commercial benefit. Discover how we can partner with firms like yours. **Classifications:** Regulatory Change & Transformation, Section 166, Skilled Person Reviews & FCA Intervention, Pensions & Retirement Income, Wealth Management & Financial Advice, Advisory #### Is your SMCR framework fully compliant? Our regulatory specialists can review your SMCR implementation and help you evidence reasonable steps with confidence. [Get in touch](https://staging.tcc.group/contact/) [Canonical source](https://tcc.group/blog/2019/12/19/case-study-smcr-assurance/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor 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"@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Advisory", "url": "https://tcc.group/blog/service/advisory/" } ], "abstract": "We conducted an independent SMCR assurance review for a leading insurance broker, identifying key gaps in documentation and responsibilities to ensure compliance prior to FCA submission.", "description": "We conducted an independent SMCR assurance review for a leading insurance broker, identifying key gaps in documentation and responsibilities to ensure compliance prior to FCA submission.", "articleBody": "The challenge\n\nA leading insurance broker had been busy preparing for the new Senior Managers and Certification Regime (SMCR). Its in-house team had spent a lot of time doing a comprehensive gap analysis and making the necessary changes to the firm\u2019s policies and procedures. With all the time and resources they had already invested, they needed to make sure they'd covered all bases before submitting their evidence to the FCA.\n\nOur approach\n\nHaving worked with us before, they knew we had the right experience of managing regulatory change programmes. Our review included: An in-depth analysis of our client\u2019s implementation programme, looking for potential gaps in the allocation of responsibilities, missing documentation and deficiencies in new and existing policies and procedures. Interviews with key managers. Benchmarking our client\u2019s approach against other similar firms we had worked with and advising our client what they needed to do to meet industry standards. Benchmarking against common misunderstandings and issues identified from intel from the banking sector implementation approach. 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By engaging us to review their SMCR implementation early, our client could quickly make changes before the approach was embedded, saving them from costly reworks. Because we understand the link between culture and SMCR, we identified areas of the client\u2019s internal culture that could be enhanced, ultimately bringing about better long-term customer and commercial outcomes. Turn disruptive regulatory change into commercial benefit. Discover how we can partner with firms like yours.", "wordCount": 369, "keywords": [ "Regulatory Change & Transformation", "Section 166, Skilled Person Reviews & FCA Intervention", "Pensions & Retirement Income", "Wealth Management & Financial Advice", "Advisory" ], "articleSection": [ "Regulatory Change & Transformation", "Section 166, Skilled Person Reviews & FCA Intervention" ], "potentialAction": { "@type": "ContactAction", "name": "Get in touch", "target": { "@type": "EntryPoint", "urlTemplate": "https://staging.tcc.group/contact/" } } } ] } ``` ### Responsive resourcing - URL: https://tcc.group/case-studies/responsive-resourcing-keeps-compliance-audit-on-track/ - Published: 2026-09-02 - Modified: 2026-09-03 **Service:** Specialist Resourcing Discover how TCC Group helped a growing financial advice firm complete a critical annual monitoring audit by rapidly deploying specialist regulatory consultants, strengthening audit processes and providing expert oversight under tight deadlines. #### The challenge A leading financial advice firm had experienced some recent growth and senior staff changes. It was struggling with a heavier workload and lacked the expertise to deliver the annual monitoring audit. Having tried and failed to recruit and upskill internally, and the deadline for the audit looming, the client turned to us to come up with a suitable solution as quickly as possible. #### Our approach As the business had acquired other firms, the review was centred on assessing the effectiveness of the compliance and risk management framework and making sure it was practical and consistent across the entire business. We sourced, vetted and appointed three experienced regulatory consultants within one week from our network, and within one month they had already completed the first audit visit under the supervision of a senior TCC team member. We immediately noticed that there was some uncertainty within many of the offices due to the recent changes. The audit needed to be carefully managed, so we arranged for our team to go through intensive training on the client’s existing approach. This meant they could ensure continuity with previous audits, better understand our client’s culture and effectively manage relationships for the smooth running of the audit programme. As the audit progressed, we also saw that some key areas of the process could be improved. Our experts recommended that certain core tasks be centralised. Not only did this drastically speed up the entire audit process, saving our client time and money, it also reduced avoidable risk by ensuring a consistent approach. Thanks to our quick, responsive resourcing, our client was able to complete their annual monitoring audit on time, and got the added value of improving the process for future audits. #### Outcomes - Having access to known, pre-vetted expert resource got the audit team up and running within a week – far quicker than any other solution - The combination of smart resource with strategic TCC oversight resulted in us identifying and recommending several process improvements in the audit programme, saving our client time and money, now and in the future. [**Download case study**](https://25194947.fs1.hubspotusercontent-eu1.net/hubfs/25194947/TCC%20Case%20Studies/TCC%20Case%20Study%20-%20Responsive%20Resourcing.pdf) #### Key facts - Regulatory consultants deployed: 3 consultants - Time to appoint resource: 1 week - Time to first audit visit: 1 month **Classifications:** Consolidation, Acquisition & Regulatory Due Diligence, Regulatory Change & Transformation, Wealth Management & Financial Advice, Specialist resourcing #### Facing urgent gaps in your compliance team? Contact our responsive resourcing specialists today to secure pre-vetted compliance experts for your business within days. [Get in touch](https://staging.tcc.group/contact/) [Canonical source](https://staging.tcc.group/blog/2024/07/29/responsive-resourcing-keeps-compliance-audit-on-track/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 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under tight deadlines.", "articleBody": "The challenge\n\nA leading financial advice firm had experienced some recent growth and senior staff changes. It was struggling with a heavier workload and lacked the expertise to deliver the annual monitoring audit. Having tried and failed to recruit and upskill internally, and the deadline for the audit looming, the client turned to us to come up with a suitable solution as quickly as possible.\n\nOur approach\n\nAs the business had acquired other firms, the review was centred on assessing the effectiveness of the compliance and risk management framework and making sure it was practical and consistent across the entire business. We sourced, vetted and appointed three experienced regulatory consultants within one week from our network, and within one month they had already completed the first audit visit under the supervision of a senior TCC team member.\r\n\r\nWe immediately noticed that there was some uncertainty within many of the offices due to the recent changes. 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The firm needed the right combination of technical resource and operational clout to deliver a large-scale remediation project to avoid any further reputational damage #### Our approach The firm selected TCC to partner with a big four firm in a joint-delivery model to meet the project’s challenging needs. We were chosen for our industry reputation, strategic partnership approach, trusted expertise and operational breadth – supported by in-depth sector knowledge and an agile resource delivery model. Utilising our capability as a leading provider of skilled, high-quality interim resource to the financial services industry, we rapidly deployed the skilled resource, at all levels, required to augment our partner’s team and ensure timely programme delivery. The success of the client’s project depended on the flexibility of our agile resourcing model. - Our extensive, 30,000+ resource pool includes some of the most experienced and highly qualified pensions and investments technical reviewers in the UK - Along with our specialist file reviewers, we provided exactly the right skills and experience needed to augment our partner’s existing team and hit the ground running Our subject matter experts (SMEs) were on hand to provide technical oversight and lead quality control, ensuring the highest standards were met and eliminating the risk of rework. #### Outcomes Our collaborative approach, technical expertise and smart allocation of resource led to a integrated project delivery. - The entire remediation programme saw an unexpectedly low level of complaints (less than 3%) and a customer satisfaction rating of 94%. - Our client consistently provided positive feedback, noting the high levels of customer service our combined team delivered. - Our flexible and scalable resourcing model enabled us to provide resource with the right knowledge and experience needed to deliver the project, including highly skilled pensions technical SMEs who were crucial to successful delivery. Thanks to our complementary skills and successful collaboration, this partnership delivered the right outcomes for our client and its customers. [**Download case study**](https://25194947.fs1.hubspotusercontent-eu1.net/hubfs/25194947/TCC%20Case%20Studies/TCC%20Case%20Study%20-%20Resourcing%20partnership%20with%20a%20Big%204%20firm%20Large-scale%20remediation%20project.pdf) #### Key facts - Customer satisfaction rating: 94 % - Pensions contractor pool: 30000 associates - Remediation complaint level: 3 % **Classifications:** Redress & Remediation, Regulatory Change & Transformation, Suitability, Advice Quality & File Reviews, Pensions & Retirement Income, Wealth Management & Financial Advice, Specialist resourcing #### Looking for a strategic resourcing partner? Speak to our specialist resourcing team to learn how we partner with leading firms to deliver large-scale remediation projects. [Get in touch](https://staging.tcc.group/contact/) [Canonical source](https://staging.tcc.group/blog/2026/01/21/case-study-resourcing-partnership-large-scale-remediation/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", 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Group helped deliver a complex pensions remediation programme, combining specialist resource and technical expertise to achieve high customer satisfaction and low complaint levels.", "articleBody": "The challenge\n\nA global wealth and asset manager had found potential issues with members\u2019 Protected Tax Free Cash in some of its pension schemes. 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The success of the client\u2019s project depended on the flexibility of our agile resourcing model.\n\u2022 Our extensive, 30,000+ resource pool includes some of the most experienced and highly qualified pensions and investments technical reviewers in the UK\n\u2022 Along with our specialist file reviewers, we provided exactly the right skills and experience needed to augment our partner\u2019s existing team and hit the ground running\n\nOur subject matter experts (SMEs) were on hand to provide technical oversight and lead quality control, ensuring the highest standards were met and eliminating the risk of rework.\n\nOutcomes\n\nOur collaborative approach, technical expertise and smart allocation of resource led to a integrated project delivery.\n\u2022 The entire remediation programme saw an unexpectedly low level of complaints (less than 3%) and a customer satisfaction rating of 94%.\n\u2022 Our client consistently provided positive feedback, noting the high levels of customer service our combined team delivered.\n\u2022 Our flexible and scalable resourcing model enabled us to provide resource with the right knowledge and experience needed to deliver the project, including highly skilled pensions technical SMEs who were crucial to successful delivery.\n\nThanks to our complementary skills and successful collaboration, this partnership delivered the right outcomes for our client and its customers.\n\nDownload case study", "wordCount": 343, "keywords": [ "Redress & Remediation", "Regulatory Change & Transformation", "Suitability, Advice Quality & File Reviews", "Pensions & Retirement Income", "Wealth Management & Financial Advice", "Specialist resourcing" ], "articleSection": [ "Redress & Remediation", "Regulatory Change & Transformation", "Suitability, Advice Quality & File Reviews" ], "potentialAction": { "@type": "ContactAction", "name": "Get in touch", "target": { "@type": "EntryPoint", "urlTemplate": "https://staging.tcc.group/contact/" } }, "mentions": [ { "@type": "QuantitativeValue", "name": "Customer satisfaction rating", "value": 94, "unitText": "%" }, { "@type": "QuantitativeValue", "name": "Pensions contractor pool", "value": 30000, "unitText": "associates" }, { "@type": "QuantitativeValue", "name": "Remediation complaint level", "value": 3, "unitText": "%" } ] } ] } ``` ### Regulatory due diligence - URL: https://tcc.group/case-studies/regulatory-due-diligence/ - Published: 2026-09-02 - Modified: 2026-09-02 **Service:** Advisory services We conducted a comprehensive regulatory due diligence assessment and cultural review of a target independent financial planning firm, creating an action plan to mitigate conduct risk before acquisition. #### The challenge A large financial planner and discretionary fund manager was rapidly expanding and was on the cusp of acquiring an independent financial planning firm. But our client had come across some instances in the target firm’s past business where customer detriment could have occurred. Our client knew it needed a clear picture of the material risks but didn’t have the resource or expertise to spare. Having worked with us before, our client knew we had the experience needed for a full regulatory due diligence assessment, as well as a discreet look at the target firm’s back book. #### Our approach Having taken the time to understand our client’s risk appetite and business needs, we recommended a review that focused on the effectiveness of the target firm’s senior management team and compliance oversight and controls. With the focus agreed, we took a two-phase approach to the due diligence project: In-depth review: we analysed the target firm’s business model, conflict management, advice proposition, systems and controls, documented policies and procedures, and reviewed some past business files. Site visit: we visited the firm’s site for two full days to understand the day-to-day operations and internal culture, and how closely this aligned with FCA expectations. Having dug a little deeper, we saw that many of the past business issues stemmed from cultural influencers, such as inadequate adviser controls and oversight. This could cause a real issue for our client, potentially exposing them to expensive rectification should they go ahead with the acquisition. So, we created a detailed action plan that would bring the firm up to scratch prior to acquisition and reduce conduct risk further down the road. Our client now had a clear picture of the risks of acquisition. What’s more, we also advised our client on how it could address some of the mismatches between the two company cultures, making for better integration and a less disruptive transition. #### Outcomes Our deep understanding of how culture affects conduct risk meant we immediately saw that culture was the root cause of the unsuitable advice. By establishing a detailed action plan before acquisition, we saved our client time, money and disruption in the long run. Every firm is different. Taking a flexible approach, we tailored our review to our client’s risk appetite and specific business needs, so we could focus on what’s most important. **Classifications:** Consolidation, Acquisition & Regulatory Due Diligence, Section 166, Skilled Person Reviews & FCA Intervention, Pensions & Retirement Income, Wealth Management & Financial Advice, Advisory #### Planning an acquisition in the financial services sector? Contact our due diligence team today to identify regulatory risks and cultural mismatches before finalizing your acquisition. [Get in touch](https://staging.tcc.group/contact/) [Canonical source](https://tcc.group/blog/2019/06/07/regulatory-due-diligence/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor 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{ "@type": "Thing", "name": "Pensions & Retirement Income", "url": "https://tcc.group/blog/sector/pensions-retirement-income/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Advisory", "url": "https://tcc.group/blog/service/advisory/" } ], "abstract": "We conducted a comprehensive regulatory due diligence assessment and cultural review of a target independent financial planning firm, creating an action plan to mitigate conduct risk before acquisition.", "description": "We conducted a comprehensive regulatory due diligence assessment and cultural review of a target independent financial planning firm, creating an action plan to mitigate conduct risk before acquisition.", "articleBody": "The challenge\n\nA large financial planner and discretionary fund manager was rapidly expanding and was on the cusp of acquiring an independent financial planning firm. But our client had come across some instances in the target firm\u2019s past business where customer detriment could have occurred. Our client knew it needed a clear picture of the material risks but didn\u2019t have the resource or expertise to spare. Having worked with us before, our client knew we had the experience needed for a full regulatory due diligence assessment, as well as a discreet look at the target firm\u2019s back book.\n\nOur approach\n\nHaving taken the time to understand our client\u2019s risk appetite and business needs, we recommended a review that focused on the effectiveness of the target firm\u2019s senior management team and compliance oversight and controls. With the focus agreed, we took a two-phase approach to the due diligence project: In-depth review: we analysed the target firm\u2019s business model, conflict management, advice proposition, systems and controls, documented policies and procedures, and reviewed some past business files. Site visit: we visited the firm\u2019s site for two full days to understand the day-to-day operations and internal culture, and how closely this aligned with FCA expectations. Having dug a little deeper, we saw that many of the past business issues stemmed from cultural influencers, such as inadequate adviser controls and oversight. This could cause a real issue for our client, potentially exposing them to expensive rectification should they go ahead with the acquisition. So, we created a detailed action plan that would bring the firm up to scratch prior to acquisition and reduce conduct risk further down the road. Our client now had a clear picture of the risks of acquisition. What\u2019s more, we also advised our client on how it could address some of the mismatches between the two company cultures, making for better integration and a less disruptive transition.\n\nOutcomes\n\nOur deep understanding of how culture affects conduct risk meant we immediately saw that culture was the root cause of the unsuitable advice. By establishing a detailed action plan before acquisition, we saved our client time, money and disruption in the long run. Every firm is different. Taking a flexible approach, we tailored our review to our client\u2019s risk appetite and specific business needs, so we could focus on what\u2019s most important.", "wordCount": 389, "keywords": [ "Consolidation, Acquisition & Regulatory Due Diligence", "Section 166, Skilled Person Reviews & FCA Intervention", "Pensions & Retirement Income", "Wealth Management & Financial Advice", "Advisory" ], "articleSection": [ "Consolidation, Acquisition & Regulatory Due Diligence", "Section 166, Skilled Person Reviews & FCA Intervention" ], "potentialAction": { "@type": "ContactAction", "name": "Get in touch", "target": { "@type": "EntryPoint", "urlTemplate": "https://staging.tcc.group/contact/" } } } ] } ``` ### RegTech remediation project - URL: https://tcc.group/case-studies/regtech-remediation/ - Published: 2026-09-02 - Modified: 2026-09-03 **Service:** Managed Services Discover how TCC Group helped a growing financial advice firm accelerate a large-scale replacement business review by combining remediation expertise with RegTech automation, delivering faster reviews, greater accuracy and significant cost savings. #### The challenge With the recent acquisition of a number of firms, our client had experienced significant growth over a 24 month period. But its in-house compliance team had raised concerns about the quality of replacement business conducted, highlighting instances of higher charges, lost benefits and inconsistent fund recommendations. The acquisition history of the firm meant that information was held across both paper and electronic files in two separate systems, and the client’s team was finding the manual case review process overly burdensome. Each file was taking up to four hours to review and the team often unearthed various unrelated issues, causing further delays. #### Our approach Our client was under significant time pressure from its own Risk & Compliance Committee, and it needed extra support. Thanks to our blend of regulatory and technology-focused subject matter specialists, we designed a bespoke automated solution to help them tackle the workload. We agreed on a consistent file type and scanned all paper files to a SharePoint site hosted by the client. Taking a flexible approach, we worked with our client to agree the rules for determining which files were in-scope and which could be safely closed. We ran an initial pilot over two weeks, further refining the rules until both we and our client were happy. We then used our innovative RegTech solution which automates traditionally manually intensive tasks and processes to significantly reduce the time it took to review a file. We rattled through an impressive 5,000 case reviews in four days, while maintaining an accuracy level of 97%. #### Outcomes - Our unique use of technology combined with our remediation expertise meant we significantly reduced inefficiencies and completed the full project in just over six weeks from start to finish - By automating processes and saving time, we were able to deliver great commercial outcomes for our client including a cost saving of £1.2m (80% of the original budget) - Our flexible and personable approach meant the client could provide feedback at all stages, and had full trust and confidence in our RegTech solution. [**Download case study**](https://25194947.fs1.hubspotusercontent-eu1.net/hubfs/25194947/TCC%20Case%20Studies/TCC%20Case%20Study%20RegTech%20Remediation%20Project.pdf) #### Key facts - Cases reviewed in four days: 5000 cases - Accuracy rate maintained: 97 % - Project cost savings: 1.2m £ - Acquisition growth period: 24 months **Classifications:** Compliance AI & RegTech, Consolidation, Acquisition & Regulatory Due Diligence, Redress & Remediation, Suitability, Advice Quality & File Reviews, Wealth Management & Financial Advice, Managed services #### Need to automate and accelerate your remediation project? Speak to our RegTech specialists to learn how our automated case management solutions can slash your review times. [Get in touch](https://staging.tcc.group/contact/) [Canonical source](https://staging.tcc.group/blog/2024/07/24/regtech-remediation-2/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", 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"https://tcc.group/blog/solution/redress-and-remediation/" }, { "@type": "Thing", "name": "Suitability, Advice Quality & File Reviews", "url": "https://tcc.group/blog/solution/outsourced-suitability-reviews/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Managed services", "url": "https://tcc.group/blog/service/managed-services/" } ], "abstract": "Discover how TCC Group helped a growing financial advice firm accelerate a large-scale replacement business review by combining remediation expertise with RegTech automation, delivering faster reviews, greater accuracy and significant cost savings.", "description": "Discover how TCC Group helped a growing financial advice firm accelerate a large-scale replacement business review by combining remediation expertise with RegTech automation, delivering faster reviews, greater accuracy and significant cost savings.", "articleBody": "The challenge\n\nWith the recent acquisition of a number of firms, our client had experienced significant growth over a 24 month period. But its in-house compliance team had raised concerns about the quality of replacement business conducted, highlighting instances of higher charges, lost benefits and inconsistent fund recommendations.\r\n\r\nThe acquisition history of the firm meant that information was held across both paper and electronic files in two separate systems, and the client\u2019s team was finding the manual case review process overly burdensome. Each file was taking up to four hours to review and the team often unearthed various unrelated issues, causing further delays.\n\nOur approach\n\nOur client was under significant time pressure from its own Risk & Compliance Committee, and it needed extra support. Thanks to our blend of regulatory and technology-focused subject matter specialists, we designed a bespoke automated solution to help them tackle the workload.\r\n\r\nWe agreed on a consistent file type and scanned all paper files to a SharePoint site hosted by the client. Taking a flexible approach, we worked with our client to agree the rules for determining which files were in-scope and which could be safely closed. We ran an initial pilot over two weeks, further refining the rules until both we and our client were happy.\r\n\r\nWe then used our innovative RegTech solution which automates traditionally manually intensive tasks and processes to significantly reduce the time it took to review a file. We rattled through an impressive 5,000 case reviews in four days, while maintaining an accuracy level of 97%.\n\nOutcomes\n\n\u2022 Our unique use of technology combined with our remediation expertise meant we significantly reduced inefficiencies and completed the full project in just over six weeks from start to finish\n\u2022 By automating processes and saving time, we were able to deliver great commercial outcomes for our client including a cost saving of \u00a31.2m (80% of the original budget)\n\u2022 Our flexible and personable approach meant the client could provide feedback at all stages, and had full trust and confidence in our RegTech solution.\n\nDownload case study", "wordCount": 344, "keywords": [ "Compliance AI & RegTech", "Consolidation, Acquisition & Regulatory Due Diligence", "Redress & Remediation", "Suitability, Advice Quality & File Reviews", "Wealth Management & Financial Advice", "Managed services" ], "articleSection": [ "Compliance AI & RegTech", "Consolidation, Acquisition & Regulatory Due Diligence", "Redress & Remediation", "Suitability, Advice Quality & File Reviews" ], "potentialAction": { "@type": "ContactAction", "name": "Get in touch", "target": { "@type": "EntryPoint", "urlTemplate": "https://staging.tcc.group/contact/" } }, "mentions": [ { "@type": "QuantitativeValue", "name": "Cases reviewed in four days", "value": 5000, "unitText": "cases" }, { "@type": "QuantitativeValue", "name": "Accuracy rate maintained", "value": 97, "unitText": "%" }, { "@type": "PropertyValue", "name": "Project cost savings", "value": "1.2m", "unitText": "\u00a3" }, { "@type": "QuantitativeValue", "name": "Acquisition growth period", "value": 24, "unitText": "months" } ] } ] } ``` ### RegTech enabled Past Business Review - URL: https://tcc.group/case-studies/regtech-enabled-past-business-review/ - Published: 2026-09-02 - Modified: 2026-09-03 **Service:** Compliance AI & RegTech Discover how TCC Group helped a global insurance and pensions provider accelerate a large-scale defined benefit pension transfer review by combining regulatory expertise with RegTech, AI and automation to meet demanding FCA deadlines. #### The challenge Following an FCA thematic review, a global insurance and pensions provider was tasked with reviewing the advice it had provided around defined benefit (DB) pension transfers, among other issues. The FCA had set a tight timescale to deliver the review and the scale of the project was huge, with the data set spanning more than a decade and covering multiple brands. Our client was feeling the pressure and was struggling to balance this with its other regulatory obligations. #### Our approach We immediately saw that the review process was simply taking too long. We knew that the right blend of regulatory experts and smart technology was needed to maximise efficiency and enable our client to meet FCA deadlines. We recommended a unique combination of robotics, Artificial Intelligence (AI) and bespoke case flow management to support the entire review process. We split this into two stages: data analysis and AI were performed off-site on our secure servers, while our expert team provided case flow management and manual second stage file reviews on the client’s site. Our RegTech solution significantly reduced the administrative burden of the data gathering process. What’s more, by combining unique evidential bookmarking capability with some basic robotics, we also reduced the average time taken for a second stage manual file review from six hours down to just one hour. Overall, we saved over 25,000 project hours and delivered cost savings to our client of £3m. #### Outcomes - By creating a bespoke tech solution to augment our experienced file checking team, we significantly sped up the review process and enabled our client to meet tight FCA deadlines - Outsourcing the review to us meant that our client was free to focus on other areas of concern that were highlighted during the thematic review - As well as avoiding the financial impact of regulatory action, our client also benefitted from unexpected cost savings of £3m by using our RegTech enabled solution as opposed to a people-only approach. [**Download case study **](https://25194947.fs1.hubspotusercontent-eu1.net/hubfs/25194947/TCC%20Case%20Studies/TCC%20Case%20Study%20-%20RegTech%20enabled%20Past%20Business%20Review.pdf) #### Key facts - Project hours saved: 25000 hours - Cost savings achieved: £ 3m - Review time per file reduced to: 1 hour **Classifications:** Compliance AI & RegTech, Redress & Remediation, Suitability, Advice Quality & File Reviews, General Insurance & Protection, Pensions & Retirement Income, Advisory, Managed services #### Running a large-scale past business review? Contact our RegTech team to discover how our AI and robotics solutions can accelerate your review timelines and reduce costs. [Get in touch](https://staging.tcc.group/contact/) [Canonical source](https://staging.tcc.group/blog/2024/07/24/regtech-enabled-past-business-review/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person 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"https://staging.tcc.group/blog/2024/07/24/regtech-enabled-past-business-review/", "isPartOf": { "@id": "https://tcc.group/case-studies/regtech-enabled-past-business-review/#webpage" }, "mainEntityOfPage": { "@id": "https://tcc.group/case-studies/regtech-enabled-past-business-review/#webpage" }, "datePublished": "2024-07-24", "dateModified": "2026-09-03T12:03:10+01:00", "inLanguage": "en-GB", "author": { "@id": "https://tcc.group/#organization" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/3aa97fae72684c78a18defd48e41e8a8/thumbnail-1024-6aaf1c5bc7eb4090212225b44a07f4a41454fa5eebfe3cb036be6e7047088250.jpg", "about": [ { "@type": "Service", "name": "Compliance AI & RegTech", "provider": { "@id": "https://tcc.group/#organization" } }, { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/service/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Redress & Remediation", "url": "https://tcc.group/blog/solution/redress-and-remediation/" }, { "@type": "Thing", "name": "Suitability, Advice Quality & File Reviews", "url": "https://tcc.group/blog/solution/outsourced-suitability-reviews/" }, { "@type": "Thing", "name": "General Insurance & Protection", "url": "https://tcc.group/blog/sector/general-insurance-protection/" }, { "@type": "Thing", "name": "Pensions & Retirement Income", "url": "https://tcc.group/blog/sector/pensions-retirement-income/" }, { "@type": "Thing", "name": "Advisory", "url": "https://tcc.group/blog/service/advisory/" }, { "@type": "Thing", "name": "Managed services", "url": "https://tcc.group/blog/service/managed-services/" } ], "abstract": "Discover how TCC Group helped a global insurance and pensions provider accelerate a large-scale defined benefit pension transfer review by combining regulatory expertise with RegTech, AI and automation to meet demanding FCA deadlines.", "description": "Discover how TCC Group helped a global insurance and pensions provider accelerate a large-scale defined benefit pension transfer review by combining regulatory expertise with RegTech, AI and automation to meet demanding FCA deadlines.", "articleBody": "The challenge\n\nFollowing an FCA thematic review, a global insurance and pensions provider was tasked with reviewing the advice it had provided around defined benefit (DB) pension transfers, among other issues. The FCA had set a tight timescale to deliver the review and the scale of the project was huge, with the data set spanning more than a decade and covering multiple brands. Our client was feeling the pressure and was struggling to balance this with its other regulatory obligations.\n\nOur approach\n\nWe immediately saw that the review process was simply taking too long. We knew that the right blend of regulatory experts and smart technology was needed to maximise efficiency and enable our client to meet FCA deadlines.\r\n\r\nWe recommended a unique combination of robotics, Artificial Intelligence (AI) and bespoke case flow management to support the entire review process. We split this into two stages: data analysis and AI were performed off-site on our secure servers, while our expert team provided case flow management and manual second stage file reviews on the client\u2019s site.\r\n\r\nOur RegTech solution significantly reduced the administrative burden of the data gathering process. What\u2019s more, by combining unique evidential bookmarking capability with some basic robotics, we also reduced the average time taken for a second stage manual file review from six hours down to just one hour. Overall, we saved over 25,000 project hours and delivered cost savings to our client of \u00a33m.\n\nOutcomes\n\n\u2022 By creating a bespoke tech solution to augment our experienced file checking team, we significantly sped up the review process and enabled our client to meet tight FCA deadlines\n\u2022 Outsourcing the review to us meant that our client was free to focus on other areas of concern that were highlighted during the thematic review\n\u2022 As well as avoiding the financial impact of regulatory action, our client also benefitted from unexpected cost savings of \u00a33m by using our RegTech enabled solution as opposed to a people-only approach.\n\nDownload case study\u00a0", "wordCount": 331, "keywords": [ "Compliance AI & RegTech", "Redress & Remediation", "Suitability, Advice Quality & File Reviews", "General Insurance & Protection", "Pensions & Retirement Income", "Advisory", "Managed services" ], "articleSection": [ "Compliance AI & RegTech", "Redress & Remediation", "Suitability, Advice Quality & File Reviews" ], "potentialAction": { "@type": "ContactAction", "name": "Get in touch", "target": { "@type": "EntryPoint", "urlTemplate": "https://staging.tcc.group/contact/" } }, "mentions": [ { "@type": "QuantitativeValue", "name": "Project hours saved", "value": 25000, "unitText": "hours" }, { "@type": "PropertyValue", "name": "Cost savings achieved", "value": "\u00a3", "unitText": "3m" }, { "@type": "QuantitativeValue", "name": "Review time per file reduced to", "value": 1, "unitText": "hour" } ] } ] } ``` ### Project rescued by RegTech - URL: https://tcc.group/case-studies/project-regtech-review/ - Published: 2026-09-02 - Modified: 2026-09-03 **Service:** Compliance AI & RegTech Discover how TCC Group helped a leading retail bank rescue a stalled arrears remediation programme by combining regulatory expertise with RegTech automation, reducing remediation volumes and accelerating customer outcome reviews at scale. #### The challenge A leading retail bank found extensive issues with its treatment of customers in arrears, following an FCA thematic review. The bank had a project underway to review the forbearance that had been offered to customers. But the bank’s internal reviewers were facing serious challenges, and in the 12 months since the review started, it had failed to get past initial planning. The initial in-scope population included over one million customers, with more than 12 potential treatment strategies. #### Our approach Our client was under intense regulatory scrutiny. We immediately saw that the review process was inefficient and full of barriers, including the volume of information coming from a lot of different sources. We knew the review needed an approach that focused on the most important aspects of each case, was clear for reviewers and delivered consistently fair outcomes. We saw that appropriate forbearance hadn’t been provided in nearly all of the files reviewed. Calling on our regulatory experience, we advised that they shift the focus from compliance failings to customer outcomes. This meant reducing the number of cases being remediated by more than 60%. We used RegTech to identify the in-scope population, automatically build case files and gather relevant data points from various sources in the customer records. This massively reduced the amount of time spent on handling cases. What’s more, we created a process to spot the cases eligible for auto-remediation. This was about 30% of all the cases, so the burden of the review was reduced even more. #### Outcomes - We understand the powerful way technology can transform a project. This, paired with our regulatory insight, brought momentum to a floundering project - We advised it would be more beneficial to shift the review’s focus towards customer outcomes, thus reducing the number of remediation cases by 60% - By saving time, and delivering a project that prioritised fairness and customer outcomes, we were able to bring about great customer, compliance; and therefore commercial; outcomes for our client. [**Download case study**](https://25194947.fs1.hubspotusercontent-eu1.net/hubfs/25194947/TCC%20Case%20Studies/TCC%20Case%20Study%20-%20Regtech%20Project%20-%20October%202024.pdf) #### Key facts - Remediation population reduction: 60 % - Auto-remediation cases: 30 % - Struggling project planning delay: 12 months - Initial in-scope population: 1m+ customers **Classifications:** Compliance AI & RegTech, Consumer Duty, Redress & Remediation, Regulatory Change & Transformation, Section 166, Skilled Person Reviews & FCA Intervention, Vulnerable Customers, Banking, Lending & Consumer Credit, Managed services #### Is your remediation project struggling to deliver? Speak to our RegTech and remediation specialists to discover how we can streamline and accelerate your project. [Get in touch](https://staging.tcc.group/contact/) [Canonical source](https://staging.tcc.group/blog/2024/07/24/project-regtech-review/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", 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& Transformation", "url": "https://tcc.group/blog/solution/regulatory-change-transformation/" }, { "@type": "Thing", "name": "Section 166, Skilled Person Reviews & FCA Intervention", "url": "https://tcc.group/blog/solution/section-166-skilled-person-reviews-fca-intervention/" }, { "@type": "Thing", "name": "Vulnerable Customers", "url": "https://tcc.group/blog/solution/vulnerable-customers/" }, { "@type": "Thing", "name": "Banking", "url": "https://tcc.group/blog/sector/banking/" }, { "@type": "Thing", "name": "Lending & Consumer Credit", "url": "https://tcc.group/blog/sector/lending-consumer-credit/" }, { "@type": "Thing", "name": "Managed services", "url": "https://tcc.group/blog/service/managed-services/" } ], "abstract": "Discover how TCC Group helped a leading retail bank rescue a stalled arrears remediation programme by combining regulatory expertise with RegTech automation, reducing remediation volumes and accelerating customer outcome reviews at scale.", "description": 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This meant reducing the number of cases being remediated by more than 60%.\r\n\r\nWe used RegTech to identify the in-scope population, automatically build case files and gather relevant data points from various sources in the customer records. This massively reduced the amount of time spent on handling cases. What\u2019s more, we created a process to spot the cases eligible for auto-remediation. This was about 30% of all the cases, so the burden of the review was reduced even more.\n\nOutcomes\n\n\u2022 We understand the powerful way technology can transform a project. 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The focus was on stabilising delivery, strengthening governance, and providing credible senior leadership across a complex, regulator-facing change agenda. #### Our approach TCC Group placed a senior Programme Director who took end-to-end accountability for programme governance, delivery oversight, management information and senior stakeholder engagement, including regulatory and audit stakeholders. - Established clear programme structures that cover scope, milestones, dependencies, budgets and risks, ensuring delivery aligned to agreed business objectives, quality standards and regulatory expectations - Led the capture and validation of requirements to ensure solutions were appropriate, defensible and supported comprehensive business cases - Directed and supported multiple Project Managers, providing both strategic oversight and hands-on guidance where needed to unblock issues and maintain delivery momentum - Put in place consistent MI and reporting to give senior stakeholders clear visibility of progress, risks and decision points - Actively managed programme risks, issues and dependencies, intervening early to address delays, cost pressures or quality concerns - Built strong working relationships across the business, acted as a trusted adviser to sponsors and senior leaders, and ensured effective engagement across first and second line teams. #### Outcomes - Stabilised a complex regulatory remediation portfolio and restored confidence in delivery and governance - Ensured regulatory and Skilled Person activity management in a structured, controlled and auditable way - Improved clarity of ownership, decision-making and prioritisation across competing remediation demands. Established a clear operating model, governance framework and handover to support ongoing delivery in the future. [**Download case study**](https://25194947.fs1.hubspotusercontent-eu1.net/hubfs/25194947/TCC%20Case%20Studies/TCC%20Case%20Study%20-%20Programme%20management%20of%20regulatory%20risk%20and%20remediation%20Pensions%20and%20financial%20crime.pdf) **Classifications:** Redress & Remediation, Section 166, Skilled Person Reviews & FCA Intervention, General Insurance & Protection, Pensions & Retirement Income, Wealth Management & Financial Advice, Advisory, Managed services, Specialist resourcing #### Need senior oversight for complex regulatory remediation? Contact our advisory team to access experienced programme directors and specialists to manage your regulator-facing change agenda. 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Remediation", "url": "https://tcc.group/blog/solution/redress-and-remediation/" }, { "@type": "Thing", "name": "Section 166, Skilled Person Reviews & FCA Intervention", "url": "https://tcc.group/blog/solution/section-166-skilled-person-reviews-fca-intervention/" }, { "@type": "Thing", "name": "General Insurance & Protection", "url": "https://tcc.group/blog/sector/general-insurance-protection/" }, { "@type": "Thing", "name": "Pensions & Retirement Income", "url": "https://tcc.group/blog/sector/pensions-retirement-income/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Advisory", "url": "https://tcc.group/blog/service/advisory/" }, { "@type": "Thing", "name": "Managed services", "url": "https://tcc.group/blog/service/managed-services/" }, { "@type": "Thing", "name": "Specialist resourcing", "url": "https://tcc.group/blog/service/specialist-resourcing/" } ], "abstract": "Discover how TCC Group provided senior programme leadership and governance oversight across a complex portfolio of pensions and financial crime remediation activities, helping a major life and pensions provider strengthen control, delivery and regulatory engagement.", "description": "Discover how TCC Group provided senior programme leadership and governance oversight across a complex portfolio of pensions and financial crime remediation activities, helping a major life and pensions provider strengthen control, delivery and regulatory engagement.", "articleBody": "The challenge\n\nTCC Group was engaged by the client to provide senior oversight and control across multiple regulatory remediation workstreams in the pensions and financial crime space, including Section 166 activity, skilled person reviews, and defined benefit remediation frameworks.\r\n\r\nThe focus was on stabilising delivery, strengthening governance, and providing credible senior leadership across a complex, regulator-facing change agenda.\n\nOur approach\n\nTCC Group placed a senior Programme Director who took end-to-end accountability for programme governance, delivery oversight, management information and senior stakeholder engagement, including regulatory and audit stakeholders.\n\u2022 Established clear programme structures that cover scope, milestones, dependencies, budgets and risks, ensuring delivery aligned to agreed business objectives, quality standards and regulatory expectations\n\u2022 Led the capture and validation of requirements to ensure solutions were appropriate, defensible and supported comprehensive business cases\n\u2022 Directed and supported multiple Project Managers, providing both strategic oversight and hands-on guidance where needed to unblock issues and maintain delivery momentum\n\u2022 Put in place consistent MI and reporting to give senior stakeholders clear visibility of progress, risks and decision points\n\u2022 Actively managed programme risks, issues and dependencies, intervening early to address delays, cost pressures or quality concerns\n\u2022 Built strong working relationships across the business, acted as a trusted adviser to sponsors and senior leaders, and ensured effective engagement across first and second line teams.\n\nOutcomes\n\n\u2022 Stabilised a complex regulatory remediation portfolio and restored confidence in delivery and governance\n\u2022 Ensured regulatory and Skilled Person activity management in a structured, controlled and auditable way\n\u2022 Improved clarity of ownership, decision-making and prioritisation across competing remediation demands. Established a clear operating model, governance framework and handover to support ongoing delivery in the future.\n\nDownload case study", "wordCount": 281, "keywords": [ "Redress & Remediation", "Section 166, Skilled Person Reviews & FCA Intervention", "General Insurance & Protection", "Pensions & Retirement Income", "Wealth Management & Financial Advice", "Advisory", "Managed services", "Specialist resourcing" ], "articleSection": [ "Redress & Remediation", "Section 166, Skilled Person Reviews & FCA Intervention" ], "potentialAction": { "@type": "ContactAction", "name": "Get in touch", "target": { "@type": "EntryPoint", "urlTemplate": "https://staging.tcc.group/contact/" } } } ] } ``` ### Past business review - URL: https://tcc.group/case-studies/past-bus-review/ - Published: 2026-09-02 - Modified: 2026-09-02 **Service:** Managed Services TCC Group rescued and managed a major past business review for a leading adviser network, redesigning workstreams and implementing a workflow solution to review 22,000 cases and calculate £13m in redress. #### The challenge The FCA had found widespread issues with controls and record keeping within a leading adviser network. Suspecting that this had led to unsuitable advice around pension transfers and switches, it told our client to carry out a largescale review of business conducted by its advisers and Appointed Representatives (ARs). Owing to a number of conflicts of interest, we took over the project from a ‘Big 4’ firm, quickly scaling up to make sure the project stayed on track and met strict FCA timelines. #### Our approach We immediately realised that the review and loss calculation methodologies that we’d inherited weren’t up to scratch. Redress calculations hadn’t been tested and there wasn’t sufficient data to properly calculate redress in any case. What’s more, process inefficiencies meant there was a huge backlog of unclear cases waiting for product provider details. We completely redesigned the core workstreams and end-to-end processes to get the project moving. This included: Changes made to the calculation methodology by our experienced actuarial team Introduction of a triage process to improve the data set Adaption of the review methodology to cut out inefficiencies, having identified the four key unsuitable outcomes Building a bespoke workflow technology solution to manage caseload, improve efficiency, and provide full MI reporting. With the new processes agreed with the client and FCA, we rolled out a training programme for project staff to ensure the highest possible standards, as well as drawing on our large pool of contractors to augment the existing team when needed. Our innovative approach and focus on finding efficiencies meant that once the project was underway, we reviewed a total of 22,000 cases and calculated £13m of redress within the 18 month timeframe, wrapping the project up as quickly as possible for our client and meeting tight FCA deadlines. #### Outcomes By finding a number of efficiencies in the review process and implementing a bespoke workflow technology solution, we completed the project as quickly as possible. This saved our client time and money, and by avoiding further unnecessary delays, we helped them avoid further regulatory action. Our flexible, agile resourcing model meant we could quickly add to the team when needed, ensuring there were no gaps in knowledge or expertise. #### Key facts - Cases reviewed: 22000 cases - Redress calculated: 13000000 £ - Project timeline: 18 months **Classifications:** Redress & Remediation, Pensions & Retirement Income, Wealth Management & Financial Advice, Managed services, Specialist resourcing #### Preparing for a large-scale past business review? Get in touch with our past business review specialists to learn how we can deliver efficient and defensible reviews. [Get in touch](https://staging.tcc.group/contact/) [Canonical source](https://tcc.group/blog/2024/06/24/case-study-past-bus-review/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor 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"@type": "Thing", "name": "Managed services", "url": "https://tcc.group/blog/service/managed-services/" }, { "@type": "Thing", "name": "Specialist resourcing", "url": "https://tcc.group/blog/service/specialist-resourcing/" } ], "abstract": "TCC Group rescued and managed a major past business review for a leading adviser network, redesigning workstreams and implementing a workflow solution to review 22,000 cases and calculate \u00a313m in redress.", "description": "TCC Group rescued and managed a major past business review for a leading adviser network, redesigning workstreams and implementing a workflow solution to review 22,000 cases and calculate \u00a313m in redress.", "articleBody": "The challenge\n\nThe FCA had found widespread issues with controls and record keeping within a leading adviser network. Suspecting that this had led to unsuitable advice around pension transfers and switches, it told our client to carry out a largescale review of business conducted by its advisers and Appointed Representatives (ARs). Owing to a number of conflicts of interest, we took over the project from a \u2018Big 4\u2019 firm, quickly scaling up to make sure the project stayed on track and met strict FCA timelines.\n\nOur approach\n\nWe immediately realised that the review and loss calculation methodologies that we\u2019d inherited weren\u2019t up to scratch. Redress calculations hadn\u2019t been tested and there wasn\u2019t sufficient data to properly calculate redress in any case. What\u2019s more, process inefficiencies meant there was a huge backlog of unclear cases waiting for product provider details. We completely redesigned the core workstreams and end-to-end processes to get the project moving. 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It’d had trouble recruiting suitably qualified staff and was experiencing a severe backlog that was resulting in loss of business. The pressure on the in-house team was also creating quality issues, with a number of cases being passed that were actually unsuitable. #### Our approach Our client was finding maintaining an in-house team a real headache so sought an outsourcing partner it could trust. Committed to driving quality and reducing business risk, our client was happy to move to the standard TCC file checking methodology which we had proven yielded exemplary results. With the new process in place, we quickly dealt with the backlog. Using a temporarily augmented team and our advanced RegTech, we turned around the case load three times faster than the client could have managed in-house. Once we moved to business as usual we improved the case check rate twofold. Our high-performance solution sped up the process exponentially by reducing the manual work required to identify document types and missing documents, and manage the workflow. This allowed us to review as many cases as the in-house team, but in half the time. Quality also improved due to combination of our methodology, an experienced team and our high-performance solution providing more targeted, superior quality assurance. #### Outcomes - Outsourcing business assurance to us removed the burden of recruiting and training an in-house team and ensured consistent quality - Using our winning combination of tech-powered assurance and file checking expertise, we sped up file checking exponentially, resulting in a more cost-effective and higher quality function. This also meant we could deal with increases in case load with ease - Moving to the TCC standard file checking methodology immediately improved quality of advice and suitability. The methodology also improved communication between business assurance and the client’s advice team, which meant issues were dealt with quicker and training implemented sooner. [**Download case study**](https://25194947.fs1.hubspotusercontent-eu1.net/hubfs/25194947/TCC%20Case%20Studies/TCC%20Case%20Study%20-%20Outsourced%20business%20assurance.pdf) #### Key facts - Case processing speed improvement: 3x faster - BAU case check rate improvement: 2x increase - Review efficiency: 50% faster **Classifications:** Compliance AI & RegTech, Suitability, Advice Quality & File Reviews, Wealth Management & Financial Advice, Managed services #### Struggling with file checking or business assurance backlog? Contact our managed services team to see how our RegTech-enabled file checking can accelerate your business assurance. [Get in touch](https://staging.tcc.group/contact/) [Canonical source](https://staging.tcc.group/blog/2024/07/24/outsourced-business-assurance-accelerated-by-regtech-2/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 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& RegTech", "provider": { "@id": "https://tcc.group/#organization" } }, { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/service/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Suitability, Advice Quality & File Reviews", "url": "https://tcc.group/blog/solution/outsourced-suitability-reviews/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Managed services", "url": "https://tcc.group/blog/service/managed-services/" } ], "abstract": "Discover how TCC Group helped a national financial advisory firm transform its business assurance function through outsourced expertise and RegTech-enabled file checking, improving quality, increasing capacity and reducing operational pressure.", "description": "Discover how TCC Group helped a national financial advisory firm transform its business assurance function through outsourced expertise and RegTech-enabled file checking, improving quality, increasing capacity and reducing operational pressure.", "articleBody": "The challenge\n\nA leading national financial advisory firm providing whole of market advice to high net worth clients was struggling to conduct assurance over new business using its in-house team. It\u2019d had trouble recruiting suitably qualified staff and was experiencing a severe backlog that was resulting in loss of business. The pressure on the in-house team was also creating quality issues, with a number of cases being passed that were actually unsuitable.\n\nOur approach\n\nOur client was finding maintaining an in-house team a real headache so sought an outsourcing partner it could trust. Committed to driving quality and reducing business risk, our client was happy to move to the standard TCC file checking methodology which we had proven yielded exemplary results.\r\n\r\nWith the new process in place, we quickly dealt with the backlog. Using a temporarily augmented team and our advanced RegTech, we turned around the case load three times faster than the client could have managed in-house.\r\n\r\nOnce we moved to business as usual we improved the case check rate twofold. Our high-performance solution sped up the process exponentially by reducing the manual work required to identify document types and missing documents, and manage the workflow. This allowed us to review as many cases as the in-house team, but in half the time.\r\n\r\nQuality also improved due to combination of our methodology, an experienced team and our high-performance solution providing more targeted, superior quality assurance.\n\nOutcomes\n\n\u2022 Outsourcing business assurance to us removed the burden of recruiting and training an in-house team and ensured consistent quality\n\u2022 Using our winning combination of tech-powered assurance and file checking expertise, we sped up file checking exponentially, resulting in a more cost-effective and higher quality function. This also meant we could deal with increases in case load with ease\n\u2022 Moving to the TCC standard file checking methodology immediately improved quality of advice and suitability. The methodology also improved communication between business assurance and the client\u2019s advice team, which meant issues were dealt with quicker and training implemented sooner.\n\nDownload case study", "wordCount": 340, "keywords": [ "Compliance AI & RegTech", "Suitability, Advice Quality & File Reviews", "Wealth Management & Financial Advice", "Managed services" ], "articleSection": [ "Compliance AI & RegTech", "Suitability, Advice Quality & File Reviews" ], "potentialAction": { "@type": "ContactAction", "name": "Get in touch", "target": { "@type": "EntryPoint", "urlTemplate": "https://staging.tcc.group/contact/" } }, "mentions": [ { "@type": "PropertyValue", "name": "Case processing speed improvement", "value": "3x", "unitText": "faster" }, { "@type": "PropertyValue", "name": "BAU case check rate improvement", "value": "2x", "unitText": "increase" }, { "@type": "PropertyValue", "name": "Review efficiency", "value": "50%", "unitText": "faster" } ] } ] } ``` ### Rapidly scaling an expert team for ongoing advice reviews - URL: https://tcc.group/case-studies/ongoing-advice-reviews/ - Published: 2026-09-02 - Modified: 2026-09-03 **Service:** Specialist resourcing Discover how TCC Group helped a wealth management firm respond to large-scale ongoing advice servicing complaints by rapidly building a specialist suitability review operation and providing the expertise needed to support complaint investigations and redress assessments. #### The challenge The client initially engaged TCC to support the firm with business-as-usual complaints, and TCC provided a team of approximately 20 contract associates. In theory, this should have been a straightforward engagement, but in practice, the client needed additional support with refining its processes. The initial TCC team had been successfully delivering this project. However, the client faced a huge spike in ongoing advice servicing complaints, so TCC was asked to step in and provide additional resource on a much larger scale. The client had been targeted by a complaints management company, representing the firm’s 15,000 customers, which claimed the client had charged its customers for annual ongoing advice service reviews which were never offered. The client had engaged a big four consultancy to support with the complaints management, but the consultancy failed to fully understand the brief and engaged the wrong type of resource that couldn’t deliver the project. The client asked TCC to outline our understanding of the problem, and we presented the view that the client needed a suitability of advice review programme rather than a simple complaints project. #### Our approach The client had initially received and logged the complaints to be reviewed but needed to rapidly assemble a team of suitability of advice reviewers to handle the FCA regulated complaints and investigate whether the ongoing advice review requirements had been met. If the requirements were not fulfilled, the team were to conduct provisional calculations to determine the level of redress to be paid to customers. This engagement began with a team of 50 suitability of advice reviewers alongside five team leaders and a project manager. The programme was supplemented with a comprehensive quality control function, made up of 12 quality controllers and a team leader. The resource requirements continued to grow, with the project peaking at around 200 roles, which is still ongoing. With our deep market expertise, TCC swiftly shortlisted suitable contract associates and implemented rigorous processes, including thorough technical interviews, to ensure only the highest-calibre candidates were selected for this project. The overall project manager, provided by TCC, developed a comprehensive route to competency and training schedule, which took candidates approximately six weeks to complete. This academy style of training ensured that the candidates could deliver exactly what was needed for this specific type of complaint. Due to the large scale of this project, we placed diploma level 4 qualified candidates along with level 3 qualified resource with experience in suitability advice reviews. To ensure that our level 3 qualified candidates could efficiently deliver the tasks, the associates undertook competency training and with the support of the team leaders, all candidates were rapidly upskilled to successfully deliver the project. The length of the project also meant that contract associates could be promoted to more senior roles, encouraging them to stay for its full duration and keeping attrition rates low. #### Outcomes TCC has a proven track record in delivering some of the most technically complex projects in the market. Our trusted reputation allowed us to rapidly assemble a knowledgeable, experienced team of professionals, many of whom had worked together before, and begin successfully delivering the project within a few weeks. As the project gained momentum, it began to attract interest from contract associates who had not previously worked with TCC, allowing us to expand our associates pool. This external interest reflected the project’s well-regarded reputation and high profile within the industry.   #### Evidence The client benefited from TCC’s developed bespoke processes that aligned with the project’s specific needs and supported the client to shape its approach to complaint handling. We added significant value by helping refine the firm’s internal processes and methodology – which the client truly valued. We successfully displaced the incumbent provider and scaled the operation significantly to manage the project even at its peak. We’re now in the process of scaling down the operations. The work has continued to evolve and due to the strength of our delivery, we’ve been entrusted with new related projects. [**Download case study **](https://25194947.fs1.hubspotusercontent-eu1.net/hubfs/25194947/TCC_SPR%20Campaign_Case%20Study.pdf) #### Key facts - Peak specialist team size: 200 associates - Affected customers reviewed: 15,000 customers - Academy training duration: 6 weeks - Initial suitability: 50 reviewers **Classifications:** Complaints & Claims Handling, Redress & Remediation, Suitability, Advice Quality & File Reviews, Wealth Management & Financial Advice, Specialist resourcing #### Need to rapidly scale your compliance resource? Partner with our specialist resourcing team to scale your projects quickly with highly qualified compliance professionals. [Get in touch](https://staging.tcc.group/contact/) [Canonical source](https://staging.tcc.group/blog/2025/07/04/case-study-ongoing-advice-reviews/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person 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"https://tcc.group/blog/solution/redress-and-remediation/" }, { "@type": "Thing", "name": "Suitability, Advice Quality & File Reviews", "url": "https://tcc.group/blog/solution/outsourced-suitability-reviews/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Specialist resourcing", "url": "https://tcc.group/blog/service/specialist-resourcing/" } ], "abstract": "Discover how TCC Group helped a wealth management firm respond to large-scale ongoing advice servicing complaints by rapidly building a specialist suitability review operation and providing the expertise needed to support complaint investigations and redress assessments.", "description": "Discover how TCC Group helped a wealth management firm respond to large-scale ongoing advice servicing complaints by rapidly building a specialist suitability review operation and providing the expertise needed to support complaint investigations and redress assessments.", "articleBody": "The challenge\n\nThe client initially engaged TCC to support the firm with business-as-usual complaints, and TCC provided a team of approximately 20 contract associates. In theory, this should have been a straightforward engagement, but in practice, the client needed additional support with refining its processes. The initial TCC team had been successfully delivering this project. However, the client faced a huge spike in ongoing advice servicing complaints, so TCC was asked to step in and provide additional resource on a much larger scale.\n\nThe client had been targeted by a complaints management company, representing the firm\u2019s 15,000 customers, which claimed the client had charged its customers for annual ongoing advice service reviews which were never offered. The client had engaged a big four consultancy to support with the complaints management, but the consultancy failed to fully understand the brief and engaged the wrong type of resource that couldn\u2019t deliver the project. The client asked TCC to outline our understanding of the problem, and we presented the view that the client needed a suitability of advice review programme rather than a simple complaints project.\n\nOur approach\n\nThe client had initially received and logged the complaints to be reviewed but needed to rapidly assemble a team of suitability of advice reviewers to handle the FCA regulated complaints and investigate whether the ongoing advice review requirements had been met. If the requirements were not fulfilled, the team were to conduct provisional calculations to determine the level of redress to be paid to customers.\r\n\r\nThis engagement began with a team of 50 suitability of advice reviewers alongside five team leaders and a project manager. The programme was supplemented with a comprehensive quality control function, made up of 12 quality controllers and a team leader. The resource requirements continued to grow, with the project peaking at around 200 roles, which is still ongoing.\r\n\r\nWith our deep market expertise, TCC swiftly shortlisted suitable contract associates and implemented rigorous processes, including thorough technical interviews, to ensure only the highest-calibre candidates were selected for this project.\r\n\r\nThe overall project manager, provided by TCC, developed a comprehensive route to competency and training schedule, which took candidates approximately six weeks to complete. This academy style of training ensured that the candidates could deliver exactly what was needed for this specific type of complaint.\r\n\r\nDue to the large scale of this project, we placed diploma level 4 qualified candidates along with level 3 qualified resource with experience in suitability advice reviews. To ensure that our level 3 qualified candidates could efficiently deliver the tasks, the associates undertook competency training and with the support of the team leaders, all candidates were rapidly upskilled to successfully deliver the project.\r\n\r\nThe length of the project also meant that contract associates could be promoted to more senior roles, encouraging them to stay for its full duration and keeping attrition rates low.\n\nOutcomes\n\nTCC has a proven track record in delivering some of the most technically complex projects in the market. Our trusted reputation allowed us to rapidly assemble a knowledgeable, experienced team of professionals, many of whom had worked together before, and begin successfully delivering the project within a few weeks.\r\n\r\nAs the project gained momentum, it began to attract interest from contract associates who had not previously worked with TCC, allowing us to expand our associates pool. This external interest reflected the project\u2019s well-regarded reputation and high profile within the industry.\r\n\r\n\u00a0\n\nEvidence\n\nThe client benefited from TCC\u2019s developed bespoke processes that aligned with the project\u2019s specific needs and supported the client to shape its approach to complaint handling. We added significant value by helping refine the firm\u2019s internal processes and methodology \u2013 which the client truly valued.\n\nWe successfully displaced the incumbent provider and scaled the operation significantly to manage the project even at its peak. We\u2019re now in the process of scaling down the operations. The work has continued to evolve and due to the strength of our delivery, we\u2019ve been entrusted with new related projects.\n\nDownload case study\u00a0", "wordCount": 666, "keywords": [ "Complaints & Claims Handling", "Redress & Remediation", "Suitability, Advice Quality & File Reviews", "Wealth Management & Financial Advice", "Specialist resourcing" ], "articleSection": [ "Complaints & Claims Handling", "Redress & Remediation", "Suitability, Advice Quality & File Reviews" ], "potentialAction": { "@type": "ContactAction", "name": "Get in touch", "target": { "@type": "EntryPoint", "urlTemplate": "https://staging.tcc.group/contact/" } }, "mentions": [ { "@type": "QuantitativeValue", "name": "Peak specialist team size", "value": 200, "unitText": "associates" }, { "@type": "QuantitativeValue", "name": "Affected customers reviewed", "value": 15000, "unitText": "customers" }, { "@type": "QuantitativeValue", "name": "Academy training duration", "value": 6, "unitText": "weeks" }, { "@type": "QuantitativeValue", "name": "Initial suitability", "value": 50, "unitText": "reviewers" } ] } ] } ``` ### Global compliance operating model - URL: https://tcc.group/case-studies/global-compliance-operating-model/ - Published: 2026-09-02 - Modified: 2026-09-02 **Service:** Specilaist Resourcing We re-engineered the complex compliance structures of a top global Asset Manager, designing and deploying a unified global compliance operating model across three international jurisdictions within 18 months. #### The challenge A top five global Asset Manager wanted to input a new order management system but its complex operating model was a barrier to efficient implementation. At the heart of the problem lay the complex business structure which was made up of a number of legacy boutique businesses, all set up with different processes and systems that had been quickly patched together. We recommended a full re-engineering of the structure and a smooth transition to a single global compliance operating model. #### Our approach Our client had set a tight deadline of just 18 months for project delivery. We immediately saw that its complex organisational structure and number of stakeholders was a major roadblock, so we set about creating a detailed project plan that would break down barriers in communication. We also held global workshops to bring together stakeholders from each office and key function. Then we delved deep into the existing systems and specific challenges of each area, creating a bespoke global operating model that would iron out the existing inconsistencies across locations. We not only made sure our client’s systems and controls were comprehensive enough to meet regulatory standards in each jurisdiction, we tackled the structural inefficiency that was proving to be a huge burden for our client – both financially and operationally. But our work wasn’t over. A new compliance operating model of this scale needs careful and strategic implementation. Drawing on our unique mix of compliance and technology expertise, we rolled out comprehensive testing of the new systems and processes, taking the pressure off our client’s small internal IT team. What’s more, we spent a lot of time on the ground to train key staff and respond quickly to any teething issues. #### Outcomes Experienced in delivering large-scale change management programmes, we easily achieved the 18 month deadline for a fully operational compliance model. We know working smarter makes processes more efficient, teams more productive and reduces duplication. Our solution reduced operational risk and created a more cost-effective compliance model that would work for the client’s commercial goals. **Classifications:** Regulatory Change & Transformation, Pensions & Retirement Income, Wealth Management & Financial Advice, Specialist resourcing #### Designing a global compliance operating model? Get in touch with our advisory team to learn how we can streamline your global compliance structures and reduce risk. [Get in touch](https://staging.tcc.group/contact/) [Canonical source](https://tcc.group/blog/2018/02/14/case-study-global-compliance-operating-model/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person 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"name": "Pensions & Retirement Income", "url": "https://tcc.group/blog/sector/pensions-retirement-income/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Specialist resourcing", "url": "https://tcc.group/blog/service/specialist-resourcing/" } ], "abstract": "We re-engineered the complex compliance structures of a top global Asset Manager, designing and deploying a unified global compliance operating model across three international jurisdictions within 18 months.", "description": "We re-engineered the complex compliance structures of a top global Asset Manager, designing and deploying a unified global compliance operating model across three international jurisdictions within 18 months.", "articleBody": "The challenge\n\nA top five global Asset Manager wanted to input a new order management system but its complex operating model was a barrier to efficient implementation. At the heart of the problem lay the complex business structure which was made up of a number of legacy boutique businesses, all set up with different processes and systems that had been quickly patched together. We recommended a full re-engineering of the structure and a smooth transition to a single global compliance operating model.\n\nOur approach\n\nOur client had set a tight deadline of just 18 months for project delivery. We immediately saw that its complex organisational structure and number of stakeholders was a major roadblock, so we set about creating a detailed project plan that would break down barriers in communication. We also held global workshops to bring together stakeholders from each office and key function. Then we delved deep into the existing systems and specific challenges of each area, creating a bespoke global operating model that would iron out the existing inconsistencies across locations. We not only made sure our client\u2019s systems and controls were comprehensive enough to meet regulatory standards in each jurisdiction, we tackled the structural inefficiency that was proving to be a huge burden for our client \u2013 both financially and operationally. But our work wasn\u2019t over. A new compliance operating model of this scale needs careful and strategic implementation. Drawing on our unique mix of compliance and technology expertise, we rolled out comprehensive testing of the new systems and processes, taking the pressure off our client\u2019s small internal IT team. What\u2019s more, we spent a lot of time on the ground to train key staff and respond quickly to any teething issues.\n\nOutcomes\n\nExperienced in delivering large-scale change management programmes, we easily achieved the 18 month deadline for a fully operational compliance model. We know working smarter makes processes more efficient, teams more productive and reduces duplication. Our solution reduced operational risk and created a more cost-effective compliance model that would work for the client\u2019s commercial goals.", "wordCount": 341, "keywords": [ "Regulatory Change & Transformation", "Pensions & Retirement Income", "Wealth Management & Financial Advice", "Specialist resourcing" ], "articleSection": [ "Regulatory Change & Transformation" ], "potentialAction": { "@type": "ContactAction", "name": "Get in touch", "target": { "@type": "EntryPoint", "urlTemplate": "https://staging.tcc.group/contact/" } } } ] } ``` ### Getting GDPR ready - URL: https://tcc.group/case-studies/getting-gdpr-ready/ - Published: 2026-09-02 - Modified: 2026-09-02 **Service:** Advisory services We supported a leading mortgage provider in achieving GDPR compliance by mapping complex data-flows, conducting governance reviews, and resolving digital data management deficiencies before the regulatory deadline. #### The challenge A leading mortgage provider was struggling to prepare for GDPR. Data was stored both electronically and in hard copy, with many historical records stored off-site. What’s more, records were generally stored without a time limit. Our client knew its data management systems weren’t up to scratch, but it didn’t have the expertise or extra resource to dedicate to the project. With the GDPR implementation date looming and limited help from the ICO, it needed expert guidance on where it should focus its efforts. #### Our approach Initially, we carried out a thorough data review to understand on our client’s current standing. This included: Inventory and data mapping to give an accurate overview of the pattern of data-flows. Review of governance structure, controls and relevant policies and procedures. On site interviews with key members of staff as well as the senior management team. Review of the new digital data management system that our client had selected. When we benchmarked our findings against GDPR requirements, we uncovered a host of issues that needed to be addressed, primarily: Inconsistencies across the business in the way data and data breaches are handled. Outdated privacy statements and policies. Gaps in the process for recording and managing consent, and in the data subject access request process. Deficiencies in the new digital data management system around effective data minimisation, anonymisation, portability and deletion. Having identified the key priorities, we then created a detailed implementation plan. Our clear game plan took the pressure off our client’s team, allowing it to easily make the required changes before the GDPR deadline and ultimately better protect its customers’ data. #### Outcomes Our experience of helping firms navigate regulatory change meant that our client could adequately prepare for GDPR without stretching its existing resource. Because of our expert advice, our client made a number of improvements to the way it handles customer data. By default this makes it more efficient, brings about better customer outcomes and avoids regulatory action in the future. **Classifications:** Regulatory Change & Transformation, Lending & Consumer Credit, Advisory #### Is your data management framework compliant? Contact our data privacy team today to discuss how we can align your data processes with regulatory standards. [Get in touch](https://staging.tcc.group/contact/) [Canonical source](https://tcc.group/blog/2018/04/01/case-study-getting-gdpr-ready/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", 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mortgage provider in achieving GDPR compliance by mapping complex data-flows, conducting governance reviews, and resolving digital data management deficiencies before the regulatory deadline.", "description": "We supported a leading mortgage provider in achieving GDPR compliance by mapping complex data-flows, conducting governance reviews, and resolving digital data management deficiencies before the regulatory deadline.", "articleBody": "The challenge\n\nA leading mortgage provider was struggling to prepare for GDPR. Data was stored both electronically and in hard copy, with many historical records stored off-site. What\u2019s more, records were generally stored without a time limit. Our client knew its data management systems weren\u2019t up to scratch, but it didn\u2019t have the expertise or extra resource to dedicate to the project. With the GDPR implementation date looming and limited help from the ICO, it needed expert guidance on where it should focus its efforts.\n\nOur approach\n\nInitially, we carried out a thorough data review to understand on our client\u2019s current standing. This included: Inventory and data mapping to give an accurate overview of the pattern of data-flows. Review of governance structure, controls and relevant policies and procedures. On site interviews with key members of staff as well as the senior management team. Review of the new digital data management system that our client had selected. When we benchmarked our findings against GDPR requirements, we uncovered a host of issues that needed to be addressed, primarily: Inconsistencies across the business in the way data and data breaches are handled. Outdated privacy statements and policies. Gaps in the process for recording and managing consent, and in the data subject access request process. Deficiencies in the new digital data management system around effective data minimisation, anonymisation, portability and deletion. Having identified the key priorities, we then created a detailed implementation plan. Our clear game plan took the pressure off our client\u2019s team, allowing it to easily make the required changes before the GDPR deadline and ultimately better protect its customers\u2019 data.\n\nOutcomes\n\nOur experience of helping firms navigate regulatory change meant that our client could adequately prepare for GDPR without stretching its existing resource. 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The scale and complexity of the portfolio made it critical to deliver accurate and defensible calculations to support strategic planning. #### Our approach TCC developed a bespoke calculator that reproduced actual mortgage cash flows and generated a notional mortgage representing what should have happened. Fees and payments were rolled forward to determine refunds due, with extensive testing conducted to ensure accuracy to within a 10p tolerance. This approach allowed redress to be calculated precisely across the entire customer base.   #### Outcomes By combining technical modelling expertise with rigorous testing and validation, TCC’s experts enabled the bank to produce defensible redress calculations covering tens of millions in exposure. This gave the client confidence in understanding the financial impact of legacy liabilities and informed strategic decision-making with clarity and assurance. [**Download case study**](https://25194947.fs1.hubspotusercontent-eu1.net/hubfs/25194947/TCC%20Case%20Studies/TCC%20Case%20Study%20-%20Equity%20release%20redress.pdf) #### Key facts - Calculation accuracy tolerance: 10 pence **Classifications:** Redress & Remediation, Suitability, Advice Quality & File Reviews, Vulnerable Customers, Banking, Lending & Consumer Credit, Pensions & Retirement Income, Managed services #### Managing complex redress calculation portfolios? Learn how our bespoke modelling solutions and technical experts can deliver accurate and defensible redress calculations for your firm. [Get in touch](https://staging.tcc.group/contact/) [Canonical source](https://staging.tcc.group/blog/2026/01/07/case-study-equity-release-redress/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person 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"https://tcc.group/blog/solution/vulnerable-customers/" }, { "@type": "Thing", "name": "Banking", "url": "https://tcc.group/blog/sector/banking/" }, { "@type": "Thing", "name": "Lending & Consumer Credit", "url": "https://tcc.group/blog/sector/lending-consumer-credit/" }, { "@type": "Thing", "name": "Pensions & Retirement Income", "url": "https://tcc.group/blog/sector/pensions-retirement-income/" }, { "@type": "Thing", "name": "Managed services", "url": "https://tcc.group/blog/service/managed-services/" } ], "abstract": "Discover how TCC Group helped a major high-street bank recalculate equity release redress across a complex customer portfolio by developing a bespoke modelling solution that delivered accurate, defensible outcomes.", "description": "Discover how TCC Group helped a major high-street bank recalculate equity release redress across a complex customer portfolio by developing a bespoke modelling solution that delivered accurate, defensible outcomes.", "articleBody": "The 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The scale and complexity of the portfolio made it critical to deliver accurate and defensible calculations to support strategic planning.\n\nOur approach\n\nTCC developed a bespoke calculator that reproduced actual mortgage cash flows and generated a notional mortgage representing what should have happened.\r\n\r\nFees and payments were rolled forward to determine refunds due, with extensive testing conducted to ensure accuracy to within a 10p tolerance. This approach allowed redress to be calculated precisely across the entire customer base.\r\n\r\n\u00a0\n\nOutcomes\n\nBy combining technical modelling expertise with rigorous testing and validation, TCC\u2019s experts enabled the bank to produce defensible redress calculations covering tens of millions in exposure.\n\nThis gave the client confidence in understanding the financial impact of legacy liabilities and informed strategic decision-making with clarity and assurance.\n\nDownload case study", "wordCount": 152, "keywords": [ "Redress & Remediation", "Suitability, Advice Quality & File Reviews", "Vulnerable Customers", "Banking", "Lending & Consumer Credit", "Pensions & Retirement Income", "Managed services" ], "articleSection": [ "Redress & Remediation", "Suitability, Advice Quality & File Reviews", "Vulnerable Customers" ], "potentialAction": { "@type": "ContactAction", "name": "Get in touch", "target": { "@type": "EntryPoint", "urlTemplate": "https://staging.tcc.group/contact/" } }, "mentions": [ { "@type": "QuantitativeValue", "name": "Calculation accuracy tolerance", "value": 10, "unitText": "pence" } ] } ] } ``` ### Defined benefit transfers - URL: https://tcc.group/case-studies/defined-benefit-transfers/ - Published: 2026-09-02 - Modified: 2026-09-02 **Service:** Managed Services We supported a national financial planning network by delivering rapid, high-quality defined benefit transfer loss assessment calculations and resolving complex data gaps within a strict two-week window. #### The challenge A national financial planning and investment management network faced a strategic challenge requiring accelerated redress calculations. The firm found themselves in urgent need of several defined benefit transfer loss assessment calculations. In order to overcome the additional challenge of strict time constraints, reasonable assumptions needed to be taken regarding the surrendered benefits, coupled with utilising the available data to allocate values within the receiving scheme funds. #### Our approach The TCC team took a proactive approach in overcoming the initial hurdle of unavailable data sets and introduced a tailor-made method to solve the firm’s problem, which exemplifies our dedication to finding bespoke solutions swiftly and effectively. By utilising our specialists’ expertise, we were able to make informed assumptions that paved the way for successful project delivery within a tight timeframe of just two weeks. This meticulous process not only allowed us to allocate the necessary funds accurately but also enabled us to anticipate and address any potential challenges that could arise from regulatory scrutiny. Our commitment to providing a sustainable and efficient solution for the firm ensured that we delivered results that will stand the test of time. #### Outcomes Our in-house redress team is unparalleled in the industry, excelling with our proactive strategies and extensive actuarial knowledge Our adaptable and versatile models enabled us to efficiently handle and challenge any potential regulatory issue Utilising our industry expertise, we swiftly pinpointed valuable assets that paved the way for a integrated and effective resolution “TCC has collaborated closely with us since 2019, and the partnership has thrived over the years. Recently, our firm urgently requested a number of loss assessments for defined benefit transfers, and TCC's response was outstanding. The assessments were completed swiftly and within the agreed timeframe. TCC not only delivered high-quality work but also identified issues and challenged certain assumptions to ensure the best possible outcome for our business." **Classifications:** Redress & Remediation, Pensions & Retirement Income, Wealth Management & Financial Advice, Advisory, Managed services #### Need rapid and defensible redress calculations? Our in-house actuarial team provides fast, compliant loss assessments and redress calculations to support your regulatory needs. [Get in touch](https://staging.tcc.group/contact/) [Canonical source](https://tcc.group/blog/2024/06/24/case-study-defined-benefit-transfers/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person 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Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Advisory", "url": "https://tcc.group/blog/service/advisory/" }, { "@type": "Thing", "name": "Managed services", "url": "https://tcc.group/blog/service/managed-services/" } ], "abstract": "We supported a national financial planning network by delivering rapid, high-quality defined benefit transfer loss assessment calculations and resolving complex data gaps within a strict two-week window.", "description": "We supported a national financial planning network by delivering rapid, high-quality defined benefit transfer loss assessment calculations and resolving complex data gaps within a strict two-week window.", "articleBody": "The challenge\n\nA national financial planning and investment management network faced a strategic challenge requiring accelerated redress calculations. The firm found themselves in urgent need of several defined benefit transfer loss assessment calculations. In order to overcome the additional challenge of strict time constraints, reasonable assumptions needed to be taken regarding the surrendered benefits, coupled with utilising the available data to allocate values within the receiving scheme funds.\n\nOur approach\n\nThe TCC team took a proactive approach in overcoming the initial hurdle of unavailable data sets and introduced a tailor-made method to solve the firm\u2019s problem, which exemplifies our dedication to finding bespoke solutions swiftly and effectively. By utilising our specialists\u2019 expertise, we were able to make informed assumptions that paved the way for successful project delivery within a tight timeframe of just two weeks. This meticulous process not only allowed us to allocate the necessary funds accurately but also enabled us to anticipate and address any potential challenges that could arise from regulatory scrutiny. Our commitment to providing a sustainable and efficient solution for the firm ensured that we delivered results that will stand the test of time.\n\nOutcomes\n\nOur in-house redress team is unparalleled in the industry, excelling with our proactive strategies and extensive actuarial knowledge Our adaptable and versatile models enabled us to efficiently handle and challenge any potential regulatory issue Utilising our industry expertise, we swiftly pinpointed valuable assets that paved the way for a integrated and effective resolution \u201cTCC has collaborated closely with us since 2019, and the partnership has thrived over the years. Recently, our firm urgently requested a number of loss assessments for defined benefit transfers, and TCC's response was outstanding. The assessments were completed swiftly and within the agreed timeframe. TCC not only delivered high-quality work but also identified issues and challenged certain assumptions to ensure the best possible outcome for our business.\"", "wordCount": 311, "keywords": [ "Redress & Remediation", "Pensions & Retirement Income", "Wealth Management & Financial Advice", "Advisory", "Managed services" ], "articleSection": [ "Redress & Remediation" ], "potentialAction": { "@type": "ContactAction", "name": "Get in touch", "target": { "@type": "EntryPoint", "urlTemplate": "https://staging.tcc.group/contact/" } } } ] } ``` ### Customer remediation: Defined benefit pensions - URL: https://tcc.group/case-studies/customer-remediation-defined-benefit/ - Published: 2026-09-02 - Modified: 2026-09-02 **Service:** Specialist resourcing Discover how TCC Group helped a leading advice and investment management firm deliver a large-scale defined benefit pension transfer remediation programme, rapidly deploying specialist resource and operational infrastructure to meet FCA-driven timescales. #### The challenge Following an FCA review, the firm uncovered widespread issues of unsuitable advice around defined benefit (DB) pension transfers. With regulatory pressure mounting, the firm needed to set up a largescale remediation project at speed. To complete the project within the FCA’s tight timescales, our client needed a 70-strong team with immediate availability. As the firm struggled to find a first-rate compliance resource at short notice, this programme proved to be a drain on the firm’s time and budget. #### Our approach Thanks to our extensive pool of over 30,000+ pre-vetted contractors, we rapidly ramped up a highly skilled team of 78 pension reviewers, team managers and quality checkers. TCC handled the entire onboarding process for our client, from initial interview through to induction training. As compliance experts, we knew exactly what our client needed and our rigorous competency framework ensured our associates were ready to hit the ground running from day one. When we identified that the client needed another eight contractors at the last minute, our scalable resourcing model enabled us to provide the additional resource quickly and integrate them smoothly into the team. The nature of the project meant high confidentiality and all activity had to be conducted on a secure site. So, as well as providing the resource, we gave our client exclusive use of our remediation centre in Leeds – along with IT and telephony infrastructure, and our RegTech-supported customer contact system. #### Outcomes TCC’s flexible and responsive approach meant that the client had the project up and running very quickly and was able to meet the FCA’s timescales for remediation delivery. - Crucial resource deployed much quicker than any other provider - As compliance experts first and foremost, we knew that our client needed high-quality, experienced contractors. We designed a rigorous assessment and onboarding process to make sure the team was ready from day one. - Our flexible approach to resourcing delivered a quick response to our client’s changing needs, including scaling up the infrastructure and additional resource. [**Download case study**](https://25194947.fs1.hubspotusercontent-eu1.net/hubfs/25194947/TCC%20Case%20Studies/TCC%20Case%20Study%20-%20Customer%20remediation%20Defined%20Benefit%20pensions.pdf) #### Key facts - Remediation team size: 78 specialists - Contractor network size: 30000 contractors - Initial target team: 70 people **Classifications:** Complaints & Claims Handling, Redress & Remediation, Suitability, Advice Quality & File Reviews, Vulnerable Customers, Pensions & Retirement Income, Wealth Management & Financial Advice, Advisory, Specialist resourcing #### Scale your remediation projects with expert resource Speak to our specialist resourcing team to access over 30,000 pre-vetted compliance professionals for your project. [Get in touch](https://staging.tcc.group/contact/) [Canonical source](https://staging.tcc.group/blog/2026/01/21/case-study-customer-remediation-defined-benefit/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ 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"Redress & Remediation", "url": "https://tcc.group/blog/solution/redress-and-remediation/" }, { "@type": "Thing", "name": "Suitability, Advice Quality & File Reviews", "url": "https://tcc.group/blog/solution/outsourced-suitability-reviews/" }, { "@type": "Thing", "name": "Vulnerable Customers", "url": "https://tcc.group/blog/solution/vulnerable-customers/" }, { "@type": "Thing", "name": "Pensions & Retirement Income", "url": "https://tcc.group/blog/sector/pensions-retirement-income/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Advisory", "url": "https://tcc.group/blog/service/advisory/" }, { "@type": "Thing", "name": "Specialist resourcing", "url": "https://tcc.group/blog/service/specialist-resourcing/" } ], "abstract": "Discover how TCC Group helped a leading advice and investment management firm deliver a large-scale defined benefit pension transfer remediation programme, rapidly deploying specialist resource and operational infrastructure to meet FCA-driven timescales.", "description": "Discover how TCC Group helped a leading advice and investment management firm deliver a large-scale defined benefit pension transfer remediation programme, rapidly deploying specialist resource and operational infrastructure to meet FCA-driven timescales.", "articleBody": "The challenge\n\nFollowing an FCA review, the firm uncovered widespread issues of unsuitable advice around defined benefit (DB) pension transfers. With regulatory pressure mounting, the firm needed to set up a largescale remediation project at speed. To complete the project within the FCA\u2019s tight timescales, our client needed a 70-strong team with immediate availability. As the firm struggled to find a first-rate compliance resource at short notice, this programme proved to be a drain on the firm\u2019s time and budget.\n\nOur approach\n\nThanks to our extensive pool of over 30,000+ pre-vetted contractors, we rapidly ramped up a highly skilled team of 78 pension reviewers, team managers and quality checkers. TCC handled the entire onboarding process for our client, from initial interview through to induction training.\r\n\r\nAs compliance experts, we knew exactly what our client needed and our rigorous competency framework ensured our associates were ready to hit the ground running from day one.\r\n\r\nWhen we identified that the client needed another eight contractors at the last minute, our scalable resourcing model enabled us to provide the additional resource quickly and integrate them smoothly into the team.\r\n\r\nThe nature of the project meant high confidentiality and all activity had to be conducted on a secure site. So, as well as providing the resource, we gave our client exclusive use of our remediation centre in Leeds \u2013 along with IT and telephony infrastructure, and our RegTech-supported customer contact system.\n\nOutcomes\n\nTCC\u2019s flexible and responsive approach meant that the client had the project up and running very quickly and was able to meet the FCA\u2019s timescales for remediation delivery.\n\u2022 Crucial resource deployed much quicker than any other provider\n\u2022 As compliance experts first and foremost, we knew that our client needed high-quality, experienced contractors. We designed a rigorous assessment and onboarding process to make sure the team was ready from day one.\n\u2022 Our flexible approach to resourcing delivered a quick response to our client\u2019s changing needs, including scaling up the infrastructure and additional resource.\n\nDownload case study", "wordCount": 336, "keywords": [ "Complaints & Claims Handling", "Redress & Remediation", "Suitability, Advice Quality & File Reviews", "Vulnerable Customers", "Pensions & Retirement Income", "Wealth Management & Financial Advice", "Advisory", "Specialist resourcing" ], "articleSection": [ "Complaints & Claims Handling", "Redress & Remediation", "Suitability, Advice Quality & File Reviews", "Vulnerable Customers" ], "potentialAction": { "@type": "ContactAction", "name": "Get in touch", "target": { "@type": "EntryPoint", "urlTemplate": "https://staging.tcc.group/contact/" } }, "mentions": [ { "@type": "QuantitativeValue", "name": "Remediation team size", "value": 78, "unitText": "specialists" }, { "@type": "QuantitativeValue", "name": "Contractor network size", "value": 30000, "unitText": "contractors" }, { "@type": "QuantitativeValue", "name": "Initial target team", "value": 70, "unitText": "people" } ] } ] } ``` ### Culture & conduct risk assessment - URL: https://tcc.group/case-studies/culture-conduct-risk-assessment/ - Published: 2026-09-02 - Modified: 2026-09-02 **Service:** Advisory services We conducted a culture and conduct risk assessment for a rapidly growing financial firm following multiple acquisitions, designing an actionable plan to unify practices and track cultural indicators. #### The challenge A vertically integrated firm was on the acquisition trail and growing quickly. But with two material acquisitions under its belt, our client had concerns about some cultural practices in each firm which were making it difficult to manage conduct risk effectively. As part of the embedding process, it was keen to understand each firm's unique culture and how it could create a healthier, more consistent one post-acquisition. As the only compliance experts who link culture and compliance to drive better outcomes, our client knew we had the expertise they needed. #### Our approach We know FCA regulation inside out, so we knew that if our client wanted to meet expectations, they'd not only have to create cultural change but track and evidence it too. We started by reviewing the culture of each firm to determine strengths and weaknesses, the top down controls in play, and how culture manifested itself in practice. This included a desk-based review, a cultural survey, staff interviews and an in-depth look at customer outcomes. After that, we laid out a clear action plan for improvement, including: Creation of overarching culture policies and procedures Training plan for all levels in the organisation Enhanced MI to report on cultural indicators, enabling effective measurement and reporting on cultural change and the impact on customer outcomes. The client was fully committed to driving cultural change but recognised that it had to convince hearts and minds, so that it wasn't perceived as a token effort. Thanks to our focused approach and the successful delivery of our review, our client asked us to provide ongoing support and to oversee the implementation of our recommendations. We ensured that it became an ongoing, evolving and self-fulfilling initiative rather than a single piece of programme change. As a result, our client saw a vastly improved and aligned culture across all acquired firms, better customer service levels and outcomes. #### Outcomes We connected the dots between culture and compliance, making it easier for our client to manage conduct risk and ensure the right outcomes for their customers during a hectic time. Ultimately, they'll reap the commercial rewards further down the line. Effective cultural change can be a tough nut to crack. We keep things simple by setting out a clear action plan and taking a focused approach so our client only had to focus on actions that would make a tangible difference. Connect the dots between conduct risk and culture **Classifications:** Regulatory Change & Transformation, Pensions & Retirement Income, Wealth Management & Financial Advice, Advisory #### Are you managing conduct risk effectively post-acquisition? Get in touch with our culture and conduct risk specialists to learn how we can help align your organisation's values. [Get in touch](https://staging.tcc.group/contact/) [Canonical source](https://tcc.group/blog/2020/05/19/case-study-culture-conduct-risk-assessment/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person 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"Pensions & Retirement Income", "url": "https://tcc.group/blog/sector/pensions-retirement-income/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Advisory", "url": "https://tcc.group/blog/service/advisory/" } ], "abstract": "We conducted a culture and conduct risk assessment for a rapidly growing financial firm following multiple acquisitions, designing an actionable plan to unify practices and track cultural indicators.", "description": "We conducted a culture and conduct risk assessment for a rapidly growing financial firm following multiple acquisitions, designing an actionable plan to unify practices and track cultural indicators.", "articleBody": "The challenge\n\nA vertically integrated firm was on the acquisition trail and growing quickly. But with two material acquisitions under its belt, our client had concerns about some cultural practices in each firm which were making it difficult to manage conduct risk effectively. As part of the embedding process, it was keen to understand each firm's unique culture and how it could create a healthier, more consistent one post-acquisition. As the only compliance experts who link culture and compliance to drive better outcomes, our client knew we had the expertise they needed.\n\nOur approach\n\nWe know FCA regulation inside out, so we knew that if our client wanted to meet expectations, they'd not only have to create cultural change but track and evidence it too. We started by reviewing the culture of each firm to determine strengths and weaknesses, the top down controls in play, and how culture manifested itself in practice. This included a desk-based review, a cultural survey, staff interviews and an in-depth look at customer outcomes. 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As a result, our client saw a vastly improved and aligned culture across all acquired firms, better customer service levels and outcomes.\n\nOutcomes\n\nWe connected the dots between culture and compliance, making it easier for our client to manage conduct risk and ensure the right outcomes for their customers during a hectic time. Ultimately, they'll reap the commercial rewards further down the line. Effective cultural change can be a tough nut to crack. We keep things simple by setting out a clear action plan and taking a focused approach so our client only had to focus on actions that would make a tangible difference. Connect the dots between conduct risk and culture", "wordCount": 404, "keywords": [ "Regulatory Change & Transformation", "Pensions & Retirement Income", "Wealth Management & Financial Advice", "Advisory" ], "articleSection": [ "Regulatory Change & Transformation" ], "potentialAction": { "@type": "ContactAction", "name": "Get in touch", "target": { "@type": "EntryPoint", "urlTemplate": "https://staging.tcc.group/contact/" } } } ] } ``` ### Compliance review and remediation - URL: https://tcc.group/case-studies/compliance-review-remediation/ - Published: 2026-09-02 - Modified: 2026-09-03 **Service:** Advisory Services Discover how TCC Group helped a growing asset management firm strengthen its compliance framework through a comprehensive review and remediation programme, delivering governance improvements, updated policies and enhanced risk management capabilities under tight timescales. #### The challenge A leading UK-based Asset Manager had grown significantly, but its internal systems and processes had not kept pace. An initial review by the firm’s newly appointed CRO showed a lack of policies and procedures for key business areas, an out-of-date risk management framework and poor controls. Our client knew it had a big job on its hands but didn’t have the resource to deal with it. Having worked with us before, our client knew we had the full spectrum of experience and knowledge it needed, so asked us to help out. #### Our approach We started with an in-depth review of the business and mapped our client’s control framework, key systems and operational processes against regulatory requirements. Inevitably, this revealed a host of new issues and made the scope of the project much bigger. But our regulatory expertise meant we knew exactly where our client needed to focus its resources. We outlined the top priorities in a detailed action plan, including: - Creating a new compliance monitoring plan and risk management framework - Creating new policies and procedures and bringing existing ones up to date - Implementing a new market abuse policy and staff training plan - Introducing a new training and competency framework The timescales were tight – our client needed to deliver the plan within a couple of months to avoid any customer detriment. But its compliance team was already inundated with BAU work, so we recommended that we manage the roll out. Impressed with our swift delivery of a comprehensive plan, our client agreed. Having taken the pressure off our client’s team, all the required actions were completed on time. Our client even reported an increase in skills and knowledge among its internal compliance team – a direct result of working closely with our experienced consultants, who regularly shared market and horizon scanning insight. #### Outcomes - Our in-depth knowledge across the full spectrum of regulatory matters meant we knew exactly what was expected of our client and where it needed to direct resource - Our tailored plan focused only on the most important areas, bringing our client’s compliance function in-line with industry standards in the most efficient and cost-effective way - We know that culture is often the root cause of compliance issues. By making training and competency a priority, our client could get the basics right and reduce conduct risk from the start [**Download case study**](https://25194947.fs1.hubspotusercontent-eu1.net/hubfs/25194947/TCC%20Case%20Studies/TCC%20Case%20Study%20-%20Compliance%20Review%20and%20Remediation.pdf) **Classifications:** Consolidation, Acquisition & Regulatory Due Diligence, Redress & Remediation, Regulatory Change & Transformation, Wealth Management & Financial Advice, Advisory, Managed services #### Facing urgent compliance or remediation deadlines? Our experienced consultants can help you identify policy gaps and implement robust remediation plans rapidly and cost-effectively. [Get in touch](https://staging.tcc.group/contact/) [Canonical source](https://staging.tcc.group/blog/2024/08/07/case-study-compliance-review-remediation-2/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled 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"@type": "Thing", "name": "Redress & Remediation", "url": "https://tcc.group/blog/solution/redress-and-remediation/" }, { "@type": "Thing", "name": "Regulatory Change & Transformation", "url": "https://tcc.group/blog/solution/regulatory-change-transformation/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Advisory", "url": "https://tcc.group/blog/service/advisory/" }, { "@type": "Thing", "name": "Managed services", "url": "https://tcc.group/blog/service/managed-services/" } ], "abstract": "Discover how TCC Group helped a growing asset management firm strengthen its compliance framework through a comprehensive review and remediation programme, delivering governance improvements, updated policies and enhanced risk management capabilities under tight timescales.", "description": "Discover how TCC Group helped a growing asset management firm strengthen its compliance framework through a comprehensive review and remediation programme, delivering governance improvements, updated policies and enhanced risk management capabilities under tight timescales.", "articleBody": "The challenge\n\nA leading UK-based Asset Manager had grown significantly, but its internal systems and processes had not kept pace. An initial review by the firm\u2019s newly appointed CRO showed a lack of policies and procedures for key business areas, an out-of-date risk management framework and poor controls. Our client knew it had a big job on its hands but didn\u2019t have the resource to deal with it. Having worked with us before, our client knew we had the full spectrum of experience and knowledge it needed, so asked us to help out.\n\nOur approach\n\nWe started with an in-depth review of the business and mapped our client\u2019s control framework, key systems and operational processes against regulatory requirements. Inevitably, this revealed a host of new issues and made the scope of the project much bigger. But our regulatory expertise meant we knew exactly where our client needed to focus its resources. We outlined the top priorities in a detailed action plan, including:\n\u2022 Creating a new compliance monitoring plan and risk management framework\n\u2022 Creating new policies and procedures and bringing existing ones up to date\n\u2022 Implementing a new market abuse policy and staff training plan\n\u2022 Introducing a new training and competency framework\n\nThe timescales were tight \u2013 our client needed to deliver the plan within a couple of months to avoid any customer detriment. But its compliance team was already inundated with BAU work, so we recommended that we manage the roll out. Impressed with our swift delivery of a comprehensive plan, our client agreed.\n\nHaving taken the pressure off our client\u2019s team, all the required actions were completed on time. Our client even reported an increase in skills and knowledge among its internal compliance team \u2013 a direct result of working closely with our experienced consultants, who regularly shared market and horizon scanning insight.\n\nOutcomes\n\n\u2022 Our in-depth knowledge across the full spectrum of regulatory matters meant we knew exactly what was expected of our client and where it needed to direct resource\n\u2022 Our tailored plan focused only on the most important areas, bringing our client\u2019s compliance function in-line with industry standards in the most efficient and cost-effective way\n\u2022 We know that culture is often the root cause of compliance issues. By making training and competency a priority, our client could get the basics right and reduce conduct risk from the start\n\nDownload case study", "wordCount": 401, "keywords": [ "Consolidation, Acquisition & Regulatory Due Diligence", "Redress & Remediation", "Regulatory Change & Transformation", "Wealth Management & Financial Advice", "Advisory", "Managed services" ], "articleSection": [ "Consolidation, Acquisition & Regulatory Due Diligence", "Redress & Remediation", "Regulatory Change & Transformation" ], "potentialAction": { "@type": "ContactAction", "name": "Get in touch", "target": { "@type": "EntryPoint", "urlTemplate": "https://staging.tcc.group/contact/" } } } ] } ``` ### Improving compliance monitoring with conduct risk reviews - URL: https://tcc.group/case-studies/compliance-monitoring-support/ - Published: 2026-09-02 - Modified: 2026-09-02 **Service:** Advisory services We supported a leading insurer under heightened regulatory pressure by augmenting its compliance monitoring team, conducting thematic conduct reviews, and embedding industry best practices across customer-facing processes. #### The challenge A leading insurer was subject to enhanced FCA scrutiny following failures in treating customers fairly and complaints handling. Our client was feeling the pressure. It needed to show how it planned to address the FCA's concerns, but lacked the resource and expertise in-house to do it. We suggested augmenting the in-house compliance monitoring team with our support and oversight, upskilling the team in the process. #### Our approach The essential first step was to put together a clear action plan. This covered independent assessments of our client's processes, procedures, systems and controls. We knew that business-as-usual (BAU) quality assurance monitoring, along with broader thematic conduct risk reviews in line with the firm’s annual compliance monitoring plan, would ease the FCA's concerns. Working collaboratively with the compliance monitoring team and key stakeholders, we conducted on-site and desk-based reviews, including: complaint quality assurance, third party due diligence, financial promotions, digital communications, post-sales servicing, product governance, conflicts of interest and whistleblowing, training & competence, GDPR, fees & charges, smarter communications, vulnerable customers, and regulatory notifications & reporting. We immediately unearthed some key non-conformances that were driving poor customer outcomes. Taking a proactive approach, we gave recommendations for how our client should amend policies and procedures to address the weaknesses, introduce industry best practices and ultimately, provide better experiences and outcomes for customers. As a result, the FCA was satisfied with the improvements our client had made and reduced their supervision. Not only that, but our client saw increased customer satisfaction and loyalty as a result of an improved customer journey. #### Outcomes With the help of our expertise, our client improved the quality of its compliance monitoring. Not only did this keep the regulator happy, but reduced the risk of future non-conformances, saving our client from expensive regulatory action further down the line. We link culture and compliance to drive commercial success. We ensured our client's business was fit for the future by recommending changes that would improve the customer experience and, ultimately, drive customer loyalty. **Classifications:** Section 166, Skilled Person Reviews & FCA Intervention, General Insurance & Protection, Advisory #### Need to strengthen your compliance monitoring capabilities? Partner with our regulatory specialists to design and embed proactive compliance monitoring frameworks that protect your business. [Get in touch](https://staging.tcc.group/contact/) [Canonical source](https://tcc.group/blog/2017/12/02/compliance-monitoring-support/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", 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Our client was feeling the pressure. It needed to show how it planned to address the FCA's concerns, but lacked the resource and expertise in-house to do it. We suggested augmenting the in-house compliance monitoring team with our support and oversight, upskilling the team in the process.\n\nOur approach\n\nThe essential first step was to put together a clear action plan. This covered independent assessments of our client's processes, procedures, systems and controls. We knew that business-as-usual (BAU) quality assurance monitoring, along with broader thematic conduct risk reviews in line with the firm\u2019s annual compliance monitoring plan, would ease the FCA's concerns. Working collaboratively with the compliance monitoring team and key stakeholders, we conducted on-site and desk-based reviews, including: complaint quality assurance, third party due diligence, financial promotions, digital communications, post-sales servicing, product governance, conflicts of interest and whistleblowing, training & competence, GDPR, fees & charges, smarter communications, vulnerable customers, and regulatory notifications & reporting. We immediately unearthed some key non-conformances that were driving poor customer outcomes. Taking a proactive approach, we gave recommendations for how our client should amend policies and procedures to address the weaknesses, introduce industry best practices and ultimately, provide better experiences and outcomes for customers. As a result, the FCA was satisfied with the improvements our client had made and reduced their supervision. Not only that, but our client saw increased customer satisfaction and loyalty as a result of an improved customer journey.\n\nOutcomes\n\nWith the help of our expertise, our client improved the quality of its compliance monitoring. Not only did this keep the regulator happy, but reduced the risk of future non-conformances, saving our client from expensive regulatory action further down the line. We link culture and compliance to drive commercial success. 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The business had also recently acquired an online lending business, which had been integrated into it’s branch based offering. This had led to a variance in standards and practices despite being under the same governance structure. The FCA was concerned that the pace of change had left our client’s compliance controls weak and that there wasn’t adequate oversight in place. It had imposed a deadline by which the firm’s compliance and quality monitoring activities needed to be strengthened. #### Our approach To remedy, we recommended a full assessment of the compliance function, highlighting any weaknesses or improvements to be made. A key aspect of this was to provide independent opinion on the adequacy of our client’s governance and oversight arrangements. Initially, our consumer credit team spent time with the senior management team to gain a thorough understanding of the business model and to enable all regulatory requirements to be mapped to their activities. We then reviewed the existing policies and procedures, highlighting gaps or weaknesses within the existing policy suite. Once new policies were drafted, or existing ones updated, any changes were consistently embedded and communicated, ensuring alignment with existing activity and training requirements. We also reviewed the quality monitoring framework across the business. Our findings showed that the call monitoring process didn’t meet the lending and debt management requirements of CONC, so this was redesigned to incorporate the necessary standards. As a result of the function assessment and redesign, the FCA was satisfied and the client was left with a compliance department that was more efficient and effective. #### Outcomes Our relationship with the FCA meant we could maintain an open dialogue, which ensured quick approval of our plans and a shorter review time for our client. Committed to adding value, we knew that knowledge transfer between our consumer credit experts and our client’s compliance team would set the function up for a successful and effective future. **Classifications:** Consolidation, Acquisition & Regulatory Due Diligence, Section 166, Skilled Person Reviews & FCA Intervention, Lending & Consumer Credit, Pensions & Retirement Income, Wealth Management & Financial Advice, Advisory #### Is your compliance function ready for regulatory scrutiny? Contact our expert advisory team today to discuss how we can strengthen your governance and oversight frameworks. 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"url": "https://tcc.group/blog/2019/05/09/case-study-compliance-effectiveness-review/", "isPartOf": { "@id": "https://tcc.group/case-studies/compliance-effectiveness-review/#webpage" }, "mainEntityOfPage": { "@id": "https://tcc.group/case-studies/compliance-effectiveness-review/#webpage" }, "datePublished": "2026-09-02T03:10:32+01:00", "dateModified": "2026-09-02T03:47:23+01:00", "inLanguage": "en-GB", "author": { "@id": "https://tcc.group/#organization" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/16ac4af5143d4428a0211cc198857d2d/thumbnail-1024-201de52d116704264fb14bdd1dc31fdc61486638a05c7e8b0ecb2d16d5200384.jpg", "about": [ { "@type": "Service", "name": "Advisory services", "provider": { "@id": "https://tcc.group/#organization" } }, { "@type": "Thing", "name": "Consolidation, Acquisition & Regulatory Due Diligence", "url": "https://tcc.group/blog/solution/consolidation-acquisition-regulatory-due-diligence/" }, { "@type": "Thing", "name": "Section 166, Skilled Person Reviews & FCA Intervention", "url": "https://tcc.group/blog/solution/section-166-skilled-person-reviews-fca-intervention/" }, { "@type": "Thing", "name": "Lending & Consumer Credit", "url": "https://tcc.group/blog/sector/lending-consumer-credit/" }, { "@type": "Thing", "name": "Pensions & Retirement Income", "url": "https://tcc.group/blog/sector/pensions-retirement-income/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Advisory", "url": "https://tcc.group/blog/service/advisory/" } ], "abstract": "TCC Group redesigned and strengthened the compliance and quality monitoring functions for a medium-sized UK short-term lender, ensuring full alignment with FCA CONC requirements and resolving regulatory concerns.", "description": "TCC Group redesigned and strengthened the compliance and quality monitoring functions for a medium-sized UK short-term lender, ensuring full alignment with FCA CONC requirements and resolving regulatory concerns.", "articleBody": "The challenge\n\nFollowing a period of growth, a medium-sized UK-based high-cost short-term lender (HCSTL) and money services business had undergone a significant restructure. The business had also recently acquired an online lending business, which had been integrated into it\u2019s branch based offering. This had led to a variance in standards and practices despite being under the same governance structure. The FCA was concerned that the pace of change had left our client\u2019s compliance controls weak and that there wasn\u2019t adequate oversight in place. It had imposed a deadline by which the firm\u2019s compliance and quality monitoring activities needed to be strengthened.\n\nOur approach\n\nTo remedy, we recommended a full assessment of the compliance function, highlighting any weaknesses or improvements to be made. A key aspect of this was to provide independent opinion on the adequacy of our client\u2019s governance and oversight arrangements. Initially, our consumer credit team spent time with the senior management team to gain a thorough understanding of the business model and to enable all regulatory requirements to be mapped to their activities. We then reviewed the existing policies and procedures, highlighting gaps or weaknesses within the existing policy suite. Once new policies were drafted, or existing ones updated, any changes were consistently embedded and communicated, ensuring alignment with existing activity and training requirements. We also reviewed the quality monitoring framework across the business. Our findings showed that the call monitoring process didn\u2019t meet the lending and debt management requirements of CONC, so this was redesigned to incorporate the necessary standards. As a result of the function assessment and redesign, the FCA was satisfied and the client was left with a compliance department that was more efficient and effective.\n\nOutcomes\n\nOur relationship with the FCA meant we could maintain an open dialogue, which ensured quick approval of our plans and a shorter review time for our client. Committed to adding value, we knew that knowledge transfer between our consumer credit experts and our client\u2019s compliance team would set the function up for a successful and effective future.", "wordCount": 339, "keywords": [ "Consolidation, Acquisition & Regulatory Due Diligence", "Section 166, Skilled Person Reviews & FCA Intervention", "Lending & Consumer Credit", "Pensions & Retirement Income", "Wealth Management & Financial Advice", "Advisory" ], "articleSection": [ "Consolidation, Acquisition & Regulatory Due Diligence", "Section 166, Skilled Person Reviews & FCA Intervention" ], "potentialAction": { "@type": "ContactAction", "name": "Get in touch", "target": { "@type": "EntryPoint", "urlTemplate": "https://staging.tcc.group/contact/" } } } ] } ``` ### Challenging an FOS judgment - URL: https://tcc.group/case-studies/challenging-an-fos-judgement/ - Published: 2026-09-02 - Modified: 2026-09-02 **Service:** Managed services Discover how TCC Group helped a client challenge a Financial Ombudsman Service (FOS) redress calculation by identifying flaws in the original methodology and developing a more accurate, defensible approach to managing financial exposure #### The challenge A client faced a final Financial Ombudsman Service (FOS) judgement and required an accurate calculation of redress. The initial methodology used did not fairly account for past payments or interest, creating the risk of overstated liabilities. #### Our approach TCC identified the flaws in the original approach, advised the client to challenge the methodology and proposed a revised calculation. This updated approach produced a significantly lower redress amount while remaining defensible under scrutiny. #### Outcomes By applying detailed analysis and regulatory insight, TCC’s experts helped the client manage exposure accurately and mitigate unnecessary financial and operational risk.   #### Evidence For acquirers, understanding these nuances before or after a transaction helped ensure legacy issues were addressed effectively, supporting informed decision-making and confidence in strategic outcomes. [**Download case study**](https://25194947.fs1.hubspotusercontent-eu1.net/hubfs/25194947/TCC%20Case%20Studies/TCC%20Case%20Study%20-%20Challenging%20a%20FOS%20judgment.pdf) **Classifications:** Complaints & Claims Handling, Redress & Remediation, Suitability, Advice Quality & File Reviews, Wealth Management & Financial Advice, Managed services #### Facing a complex FOS redress challenge? Discover how our regulatory and actuarial specialists can review and refine your redress calculations to ensure fair outcomes and protect your firm from overstated liabilities. [Get in touch](https://staging.tcc.group/contact/) [Canonical source](https://staging.tcc.group/blog/2026/01/07/case-study-challenging-an-fos-judgement/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled 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Advice Quality & File Reviews", "url": "https://tcc.group/blog/solution/outsourced-suitability-reviews/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Managed services", "url": "https://tcc.group/blog/service/managed-services/" } ], "abstract": "Discover how TCC Group helped a client challenge a Financial Ombudsman Service (FOS) redress calculation by identifying flaws in the original methodology and developing a more accurate, defensible approach to managing financial exposure", "description": "Discover how TCC Group helped a client challenge a Financial Ombudsman Service (FOS) redress calculation by identifying flaws in the original methodology and developing a more accurate, defensible approach to managing financial exposure", "articleBody": "The challenge\n\nA client faced a final Financial Ombudsman Service (FOS) judgement and required an accurate calculation of redress. The initial methodology used did not fairly account for past payments or interest, creating the risk of overstated liabilities.\n\nOur approach\n\nTCC identified the flaws in the original approach, advised the client to challenge the methodology and proposed a revised calculation.\r\n\r\nThis updated approach produced a significantly lower redress amount while remaining defensible under scrutiny.\n\nOutcomes\n\nBy applying detailed analysis and regulatory insight, TCC\u2019s experts helped the client manage exposure accurately and mitigate unnecessary financial and operational risk.\r\n\r\n\u00a0\n\nEvidence\n\nFor acquirers, understanding these nuances before or after a transaction helped ensure legacy issues were addressed effectively, supporting informed decision-making and confidence in strategic outcomes.\n\nDownload case study", "wordCount": 126, "keywords": [ "Complaints & Claims Handling", "Redress & Remediation", "Suitability, Advice Quality & File Reviews", "Wealth Management & Financial Advice", "Managed services" ], "articleSection": [ "Complaints & Claims Handling", "Redress & Remediation", "Suitability, Advice Quality & File Reviews" ], "potentialAction": { "@type": "ContactAction", "name": "Get in touch", "target": { "@type": "EntryPoint", "urlTemplate": "https://staging.tcc.group/contact/" } } } ] } ``` ### Calculator build and assurance - URL: https://tcc.group/case-studies/calculator-build-and-assurance/ - Published: 2026-09-02 - Modified: 2026-09-02 **Service:** Managed Services Our actuarial team built and assured bespoke, post-Plevin single premium loan, credit card, and mortgage calculators for a leading retail bank, delivering thorough quality assurance, coding tests, and operational user documentation to streamline their PPI redress programme. #### The challenge Following the landmark Plevin vs Paragon Personal Finance Ltd Supreme Court judgment, a leading retail bank needed to quickly adapt its Payment Protection Insurance (PPI) redress calculators. This update had to span multiple complex financial products, including single premium loans, credit cards, and mortgages. Although the bank possessed sufficient internal resource, they lacked the specialized technical skills and actuarial expertise required for such intricate calculation shifts. Furthermore, their existing calculator systems were poorly documented and lacked proper operational controls, severely complicating the build. #### Our approach We analysed the client's operational requirements, existing calculators, and available data structures. Our actuarial consultants then executed a comprehensive three-stage delivery process consisting of calculation engine build, quality assurance, and deployment. We successfully adapted three calculators and built a new one from scratch to match client preferences. A separate, independent TCC team undertook rigorous quality assurance, performing extensive coding and scenario testing. Finally, we delivered walk-through sessions, detailed user guides, and a comprehensive methodology paper. #### Outcomes The delivery of the customized, post-Plevin calculators streamlined the bank's redress operations and resolved calculation backlogs. The user guides and methodology papers empowered internal teams to maximize the engines' capabilities confidently and accurately. Following this successful project, we reviewed the client's legacy stage 1 calculators and replaced them with streamlined, highly intuitive engines. This intervention significantly increased their daily calculation throughput and improved overall operational efficiency. #### Evidence The engagement was evidenced by the successful replacement of legacy stage 1 systems with streamlined calculators, which directly increased the client's daily calculation capacity and processing speed. **Classifications:** Redress & Remediation, Banking, Managed services #### Need bespoke, regulatory-compliant calculators? Contact our actuarial and managed services specialists to learn how we can build, assure, and deploy custom calculation engines tailored to your firm's specific redress needs. [Get in touch](https://staging.tcc.group/contact/) [Canonical source](https://tcc.group/blog/2024/08/07/case-study-calculator-build-and-assurance-2/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person 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"url": "https://tcc.group/blog/service/managed-services/" } ], "abstract": "Our actuarial team built and assured bespoke, post-Plevin single premium loan, credit card, and mortgage calculators for a leading retail bank, delivering thorough quality assurance, coding tests, and operational user documentation to streamline their PPI redress programme.", "description": "Our actuarial team built and assured bespoke, post-Plevin single premium loan, credit card, and mortgage calculators for a leading retail bank, delivering thorough quality assurance, coding tests, and operational user documentation to streamline their PPI redress programme.", "articleBody": "The challenge\n\nFollowing the landmark Plevin vs Paragon Personal Finance Ltd Supreme Court judgment, a leading retail bank needed to quickly adapt its Payment Protection Insurance (PPI) redress calculators. This update had to span multiple complex financial products, including single premium loans, credit cards, and mortgages.\n\nAlthough the bank possessed sufficient internal resource, they lacked the specialized technical skills and actuarial expertise required for such intricate calculation shifts. Furthermore, their existing calculator systems were poorly documented and lacked proper operational controls, severely complicating the build.\n\nOur approach\n\nWe analysed the client's operational requirements, existing calculators, and available data structures. Our actuarial consultants then executed a comprehensive three-stage delivery process consisting of calculation engine build, quality assurance, and deployment.\n\nWe successfully adapted three calculators and built a new one from scratch to match client preferences. A separate, independent TCC team undertook rigorous quality assurance, performing extensive coding and scenario testing. Finally, we delivered walk-through sessions, detailed user guides, and a comprehensive methodology paper.\n\nOutcomes\n\nThe delivery of the customized, post-Plevin calculators streamlined the bank's redress operations and resolved calculation backlogs. The user guides and methodology papers empowered internal teams to maximize the engines' capabilities confidently and accurately.\n\nFollowing this successful project, we reviewed the client's legacy stage 1 calculators and replaced them with streamlined, highly intuitive engines. This intervention significantly increased their daily calculation throughput and improved overall operational efficiency.\n\nEvidence\n\nThe engagement was evidenced by the successful replacement of legacy stage 1 systems with streamlined calculators, which directly increased the client's daily calculation capacity and processing speed.", "wordCount": 257, "keywords": [ "Redress & Remediation", "Banking", "Managed services" ], "articleSection": [ "Redress & Remediation" ], "potentialAction": { "@type": "ContactAction", "name": "Get in touch", "target": { "@type": "EntryPoint", "urlTemplate": "https://staging.tcc.group/contact/" } } } ] } ``` ### Flexible overflow business assurance relieves internal pressure - URL: https://tcc.group/case-studies/business-assurance-overflow/ - Published: 2026-09-02 - Modified: 2026-09-03 **Service:** Specialist resourcing Discover how TCC Group helped a rapidly growing financial advice firm manage peaks in business assurance demand through a flexible overflow service, providing independent oversight and maintaining quality during periods of high growth. #### The challenge A major national financial advice firm was growing rapidly and had recently increased its adviser numbers but its in-house business assurance team was struggling to keep up with the workflow. At times of particularly high demand, the team was under a lot of pressure and quality started to suffer as a result. As with any scaling business going through operational and strategic changes, we knew our client needed to be able to manage the fluctuations in demand but without the hefty investment needed for sourcing, training and managing extra resource. Our flexible overflow service offered just that. #### Our approach Before getting to work, we spent a lot of time with our client’s internal team to understand its business standards and agree SLAs and turnaround times. We adopted our client’s file checking methodology and procedures to ensure consistency with the internal team and become a seamless extension of its business assurance function. To test it and iron out any issues, we carried out a pilot exercise. With the processes in place, cases were then referred to us on an ongoing basis. The number of files to be checked varied month by month, but our flexible resource model meant we could quickly expand and contract to suit our client’s business needs. Best of all, outsourcing the overflow meant the client got a regular independent view on the business written. To date, we’ve helped to identify trends where customers have not been treated fairly and where certain advisers have deviated from the firm’s business standards. As a result of our insights and recommendations, our client made changes to its adviser training programme, avoiding future regulatory action. #### Outcomes - Our flexibility means that our client can keep business flowing during busy times while retaining high-quality assurance. This gives the client bandwidth and confidence to write even more business - Our client only pays for what it needs, helping it budget more effectively - As experts on the FCA’s expectations, we helped our client to manage risk by identifying emerging trends and potential threats within the sales process [**Download case study**](https://25194947.fs1.hubspotusercontent-eu1.net/hubfs/25194947/TCC%20Case%20Studies/TCC%20Case%20-%20Study%20Flexible%20overflow%20business%20assurance%20relieves%20internal%20pressure.pdf) **Classifications:** Consolidation, Acquisition & Regulatory Due Diligence, Consumer Duty, Suitability, Advice Quality & File Reviews, Wealth Management & Financial Advice, Specialist resourcing #### Is your internal file review team under pressure? Learn how our flexible overflow business assurance services can provide the scalable capacity and independent oversight you need to maintain high advice standards. [Get in touch](https://staging.tcc.group/contact/) [Canonical source](https://staging.tcc.group/blog/2024/08/07/case-study-business-assurance-overflow-2/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled 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"@type": "Thing", "name": "Consumer Duty", "url": "https://tcc.group/blog/solution/consumer-duty/" }, { "@type": "Thing", "name": "Suitability, Advice Quality & File Reviews", "url": "https://tcc.group/blog/solution/outsourced-suitability-reviews/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Specialist resourcing", "url": "https://tcc.group/blog/service/specialist-resourcing/" } ], "abstract": "Discover how TCC Group helped a rapidly growing financial advice firm manage peaks in business assurance demand through a flexible overflow service, providing independent oversight and maintaining quality during periods of high growth.", "description": "Discover how TCC Group helped a rapidly growing financial advice firm manage peaks in business assurance demand through a flexible overflow service, providing independent oversight and maintaining quality during periods of high growth.", "articleBody": "The challenge\n\nA major national financial advice firm was growing rapidly and had recently increased its adviser numbers but its in-house business assurance team was struggling to keep up with the workflow. At times of particularly high demand, the team was under a lot of pressure and quality started to suffer as a result.\r\n\r\nAs with any scaling business going through operational and strategic changes, we knew our client needed to be able to manage the fluctuations in demand but without the hefty investment needed for sourcing, training and managing extra resource. Our flexible overflow service offered just that.\n\nOur approach\n\nBefore getting to work, we spent a lot of time with our client\u2019s internal team to understand its business standards and agree SLAs and turnaround times. We adopted our client\u2019s file checking methodology and procedures to ensure consistency with the internal team and become a seamless extension of its business assurance function. To test it and iron out any issues, we carried out a pilot exercise.\r\n\r\nWith the processes in place, cases were then referred to us on an ongoing basis. The number of files to be checked varied month by month, but our flexible resource model meant we could quickly\u00a0expand and contract to suit our client\u2019s business needs.\r\n\r\nBest of all, outsourcing the overflow meant the client got a regular independent view on the business written. To date, we\u2019ve helped to identify trends where customers have not been treated fairly and where certain advisers have deviated from the firm\u2019s business standards. As a result of our insights and recommendations, our client made changes to its adviser training programme, avoiding future regulatory action.\n\nOutcomes\n\n\u2022 Our flexibility means that our client can keep business flowing during busy times while retaining high-quality assurance. This gives the client bandwidth and confidence to write even more business\n\u2022 Our client only pays for what it needs, helping it budget more effectively\n\u2022 As experts on the FCA\u2019s expectations, we helped our client to manage risk by identifying emerging trends and potential threats within the sales process\n\nDownload case study", "wordCount": 348, "keywords": [ "Consolidation, Acquisition & Regulatory Due Diligence", "Consumer Duty", "Suitability, Advice Quality & File Reviews", "Wealth Management & Financial Advice", "Specialist resourcing" ], "articleSection": [ "Consolidation, Acquisition & Regulatory Due Diligence", "Consumer Duty", "Suitability, Advice Quality & File Reviews" ], "potentialAction": { "@type": "ContactAction", "name": "Get in touch", "target": { "@type": "EntryPoint", "urlTemplate": "https://staging.tcc.group/contact/" } } } ] } ``` ### AML Review & Remediation - URL: https://tcc.group/case-studies/aml-review-and-remediation/ - Published: 2026-09-02 - Modified: 2026-09-03 **Service:** Advisory Services Discover how TCC Group helped a global bank strengthen its anti-money laundering controls through a comprehensive customer due diligence review, identifying process weaknesses and recommending targeted improvements to reduce regulatory and financial crime risk. #### The challenge A UK-based retail bank had attracted the attention of the FCA because of the number of high-risk clients on its books. An internal review had also shown that client files in certain business units were missing know your customer (KYC) due diligence information. Concerned about potential reputational damage, our client knew it needed an independent third party to review its files and assess the risk. ​ #### Our approach We initially focused on a randomly selected sample of correspondent banking client files. Our solution included reviews of:​ - Customer due diligence.​​ - Ongoing monitoring reviews.​​ - Use of enhanced due diligence and its monitoring of higher risk situations.​​​​ - Monitoring processes relating to correspondent banking relationships and third-party payments In addition, we assessed: - The levels of monitoring of transactions.​​​​ - The appropriateness of these controls.​​​​ We then designed a file review template that could be used to benchmark the bank’s anti-money laundering (AML) controls against regulatory requirements and published guidance, which was then approved by FCA. In addition to submitting the file review findings via this template, we also prepared a summary review of findings. ​Our comprehensive review quickly uncovered a number of reoccurring issues. Having widened the review scope to uncover the full scale of the problem, we recommended ways our client could strengthen its AML processes. This included designing a staff training framework for frontline staff to reinforce their important role in AML. ​​​ #### Outcomes - Because we pinpointed the specific issues, our client could take appropriate action ​to implement stronger processes and better protect its business and customers in ​the future - By partnering with an independent third party, our client could be sure that its new controls were robust and avoided any potential reputational damage associated with not taking AML responsibilities seriously - With focus on culture, we know that inadequate staff understanding is often a root cause of failings, so we helped our client tackle this head on with a new AML training framework for frontline staff.​ [**Download case study**](https://25194947.fs1.hubspotusercontent-eu1.net/hubfs/25194947/TCC%20Case%20Studies/TCC%20Case%20Study%20-%20AML%20Review%20-%20October%202024.pdf) **Classifications:** Financial Crime Compliance, Redress & Remediation, Regulatory Change & Transformation, Suitability, Advice Quality & File Reviews, Banking, Advisory #### Is your bank facing regulatory AML scrutiny? Find out how our FCA-approved benchmarking templates and independent file review services can help you remediate compliance gaps and secure your operations. [Get in touch](https://staging.tcc.group/contact/) [Canonical source](https://staging.tcc.group/blog/2024/07/18/case-study-aml-review-and-remediation/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled 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Transformation", "url": "https://tcc.group/blog/solution/regulatory-change-transformation/" }, { "@type": "Thing", "name": "Suitability, Advice Quality & File Reviews", "url": "https://tcc.group/blog/solution/outsourced-suitability-reviews/" }, { "@type": "Thing", "name": "Banking", "url": "https://tcc.group/blog/sector/banking/" }, { "@type": "Thing", "name": "Advisory", "url": "https://tcc.group/blog/service/advisory/" } ], "abstract": "Discover how TCC Group helped a global bank strengthen its anti-money laundering controls through a comprehensive customer due diligence review, identifying process weaknesses and recommending targeted improvements to reduce regulatory and financial crime risk.", "description": "Discover how TCC Group helped a global bank strengthen its anti-money laundering controls through a comprehensive customer due diligence review, identifying process weaknesses and recommending targeted improvements to reduce regulatory and financial crime risk.", "articleBody": "The challenge\n\nA UK-based retail bank had attracted the attention of the FCA because of the number of high-risk clients on its books. An internal review had also shown that client files in certain business units were missing know your customer (KYC) due diligence information. Concerned about potential reputational damage, our client knew it needed an independent third party to review its files and assess the risk. \u200b\n\nOur approach\n\nWe initially focused on a randomly selected sample of correspondent banking client files. Our solution included reviews of:\u200b\n\u2022 Customer due diligence.\u200b\u200b\n\u2022 Ongoing monitoring reviews.\u200b\u200b\n\u2022 Use of enhanced due diligence and its monitoring of higher risk situations.\u200b\u200b\u200b\u200b\n\u2022 Monitoring processes relating to correspondent banking relationships and third-party payments\n\nIn addition, we assessed:\n\u2022 The levels of monitoring of transactions.\u200b\u200b\u200b\u200b\n\u2022 The appropriateness of these controls.\u200b\u200b\u200b\u200b\n\nWe then designed a file review template that could be used to benchmark the bank\u2019s anti-money laundering (AML) controls against regulatory requirements and published guidance, which was then approved by FCA. In addition to submitting the file review findings via this template, we also prepared a summary review of findings.\n\n\u200bOur comprehensive review quickly uncovered a number of reoccurring issues. 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To understand the scope of the problem and ensure it could stand up against FCA investigation, we recommended the bank review its customer due diligence procedures. Independent assurance was a must in this case. Trusting our expertise, our client asked us to undertake a comprehensive review. #### Our approach Because of our deep understanding of FCA standards, we knew our review needed to consider both the initial customer due diligence undertaken and also the process for monitoring the ongoing client relationship and transactions. We took a phased approach: - Phase one – We started by reviewing past cases to find out whether our client was collecting sufficient information. Did our client fully understand their customer intentions? Had it properly verified identities, including identifying the beneficial owner(s)? Does it enter into, or continue, relationships even if it can’t conduct customer due diligence? - Phase two – We reviewed the customer due diligence procedures and processes, testing them against what we were seeing in practice. In particular, we wanted to know whether the procedures were flexible enough to cope with customers who needed enhanced due diligence, such as PEPs or those who can’t provide the most common forms of ID. We left no stone unturned. And thanks to the depth of our review, our client had a complete view of their customer due diligence processes, inherent weaknesses, and the outcomes they resulted in. We then suggested a number of improvements they could make to ensure their processes could stand up to regulatory scrutiny and reduce risk. #### Outcomes - We’re experts in FCA regulation. We used our in-depth knowledge to target the areas we know the FCA cares most about, uncovering areas for improvement in the most efficient way possible. - Thanks to our comprehensive review, our client gained a true picture of the risks of inadequate customer due diligence, plus steps they could take to reduce it. Ultimately, this means less chance of falling foul to money laundering and regulatory action. [**Download case study**](https://25194947.fs1.hubspotusercontent-eu1.net/hubfs/25194947/TCC%20Case%20Studies/TCC%20Case%20Study%20-%20AML%20customer%20due%20diligence%20review%20-%20October%202024.pdf) **Classifications:** Financial Crime Compliance, Section 166, Skilled Person Reviews & FCA Intervention, Suitability, Advice Quality & File Reviews, Banking, Advisory #### Are your AML controls ready for scrutiny? Talk to our AML advisory specialists today to schedule an independent review of your customer due diligence and transaction monitoring frameworks. [Get in touch](https://staging.tcc.group/contact/) [Canonical source](https://staging.tcc.group/blog/2024/07/18/case-study-aml-customer-due-diligence-review-2/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 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Customer Due Diligence Review", "item": "https://tcc.group/case-studies/aml-customer-due-diligence-review/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/case-studies/aml-customer-due-diligence-review/#webpage", "url": "https://tcc.group/case-studies/aml-customer-due-diligence-review/", "name": "AML Customer Due Diligence Review", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-09-02T03:09:27+01:00", "dateModified": "2026-09-03T14:17:02+01:00", "breadcrumb": { "@id": "https://tcc.group/case-studies/aml-customer-due-diligence-review/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "Article", "@id": "https://tcc.group/case-studies/aml-customer-due-diligence-review/#case-study", "genre": "Case study", "headline": "AML Customer Due Diligence Review", "url": "https://staging.tcc.group/blog/2024/07/18/case-study-aml-customer-due-diligence-review-2/", "isPartOf": { "@id": "https://tcc.group/case-studies/aml-customer-due-diligence-review/#webpage" }, "mainEntityOfPage": { "@id": "https://tcc.group/case-studies/aml-customer-due-diligence-review/#webpage" }, "datePublished": "2024-07-18", "dateModified": "2026-09-03T14:17:02+01:00", "inLanguage": "en-GB", "author": { "@id": "https://tcc.group/#organization" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/16005c7975e2424b890a2ac79495eba6/thumbnail-1024-7cb52389ef383b30651c054a1f5d08b50427f4d3b0d9bade88ea721b51faea45.jpg", "about": [ { "@type": "Service", "name": "Advisory Services", "provider": { "@id": "https://tcc.group/#organization" } }, { "@type": "Thing", "name": "Financial Crime Compliance", "url": "https://tcc.group/blog/solution/financial-crime-compliance/" }, { "@type": "Thing", "name": "Section 166, Skilled Person Reviews & FCA Intervention", "url": "https://tcc.group/blog/solution/section-166-skilled-person-reviews-fca-intervention/" }, { "@type": "Thing", "name": "Suitability, Advice Quality & File Reviews", "url": "https://tcc.group/blog/solution/outsourced-suitability-reviews/" }, { "@type": "Thing", "name": "Banking", "url": "https://tcc.group/blog/sector/banking/" }, { "@type": "Thing", "name": "Advisory", "url": "https://tcc.group/blog/service/advisory/" } ], "abstract": "Discover how TCC Group helped a global bank strengthen its anti-money laundering controls through a comprehensive customer due diligence review, identifying key risks and recommending improvements to support regulatory compliance.", "description": "Discover how TCC Group helped a global bank strengthen its anti-money laundering controls through a comprehensive customer due diligence review, identifying key risks and recommending improvements to support regulatory compliance.", "articleBody": "The challenge\n\nA leading global bank was coming under regulatory scrutiny on its AML processes. To understand the scope of the problem and ensure it could stand up against FCA investigation, we recommended the bank review its customer due diligence procedures. Independent assurance was a must in this case. Trusting our expertise, our client asked us to undertake a comprehensive review.\n\nOur approach\n\nBecause of our deep understanding of FCA standards, we knew our review needed to consider both the initial customer due diligence undertaken and also the process for monitoring the ongoing client relationship and transactions. We took a phased approach:\n\u2022 Phase one \u2013 We started by reviewing past cases to find out whether our client was collecting sufficient information. Did our client fully understand their customer intentions? Had it properly verified identities, including identifying the beneficial owner(s)? Does it enter into, or continue, relationships even if it can\u2019t conduct customer due diligence?\n\u2022 Phase two \u2013 We reviewed the customer due diligence procedures and processes, testing them against what we were seeing in practice. In particular, we wanted to know whether the procedures were flexible enough to cope with customers who needed enhanced due diligence, such as PEPs or those who can\u2019t provide the most common forms of ID.\n\nWe left no stone unturned. And thanks to the depth of our review, our client had a complete view of their customer due diligence processes, inherent weaknesses, and the outcomes they resulted in. We then suggested a number of improvements they could make to ensure their processes could stand up to regulatory scrutiny and reduce risk.\n\nOutcomes\n\n\u2022 We\u2019re experts in FCA regulation. We used our in-depth knowledge to target the areas we know the FCA cares most about, uncovering areas for improvement in the most efficient way possible.\n\u2022 Thanks to our comprehensive review, our client gained a true picture of the risks of inadequate customer due diligence, plus steps they could take to reduce it. Ultimately, this means less chance of falling foul to money laundering and regulatory action.\n\nDownload case study", "wordCount": 346, "keywords": [ "Financial Crime Compliance", "Section 166, Skilled Person Reviews & FCA Intervention", "Suitability, Advice Quality & File Reviews", "Banking", "Advisory" ], "articleSection": [ "Financial Crime Compliance", "Section 166, Skilled Person Reviews & FCA Intervention", "Suitability, Advice Quality & File Reviews" ], "potentialAction": { "@type": "ContactAction", "name": "Get in touch", "target": { "@type": "EntryPoint", "urlTemplate": "https://staging.tcc.group/contact/" } } } ] } ``` ### Acquisition due diligence - URL: https://tcc.group/case-studies/acquisition-due-diligence/ - Published: 2026-09-02 - Modified: 2026-09-02 **Service:** Advisory services Discover how TCC Group helped a client assess potential redress liabilities during the acquisition of an independent financial adviser, providing the insight and assurance needed to support pricing, deal negotiations and strategic decision-making. #### The challenge A client negotiating the acquisition of an independent financial adviser (IFA) needed clear visibility into potential back-book redress liabilities. While the firm possessed a large portfolio of client files, conducting a manual review of every single case was operationally and commercially impractical. Without a reliable estimate of legacy exposure, the client could not establish a fair purchase price or negotiate the deal confidently. They required independent assurance to identify data gaps and quantify risk within tight transactional timeframes. #### Our approach TCC developed a structured, pragmatic sampling methodology, selecting a targeted sample of 30 cases that balanced high-risk factors with a representative spread of the portfolio. We prioritised cases based on key risk indicators, including transfer values, customer ages and scheme dates. To overcome the challenge of incomplete point-of-sale documentation, we utilised data from our extensive library of similar projects and drawing on our deep expertise with comparable financial advice schemes to reconstruct missing details and ensure thorough analysis. #### Outcomes Our risk-prioritised approach enabled the client to accurately quantify potential redress liabilities without the cost or delay of a full portfolio audit. This critical assessment identified legacy file gaps and established a defensible, evidence-backed risk model. Armed with these insights, the client gained the necessary assurance to proceed with deal negotiations. This analytical support allowed them to make informed strategic decisions and negotiate the final transaction pricing with high confidence. #### Evidence The engagement was evidenced by the successful assessment and reporting of a representative 30-case sample, which identified key data gaps and quantified liabilities to support transaction negotiations. [**Download case study**](https://25194947.fs1.hubspotusercontent-eu1.net/hubfs/25194947/TCC%20Case%20Studies/TCC%20Case%20Study%20-%20Acquisition%20Due%20Diligence.pdf) #### Key facts - Portfolio sample size: 30 cases **Classifications:** Complaints & Claims Handling, Consolidation, Acquisition & Regulatory Due Diligence, Suitability, Advice Quality & File Reviews, Wealth Management & Financial Advice, Advisory #### Planning an acquisition in the wealth sector? Contact our due diligence specialists to learn how our risk-based portfolio sampling can protect your business and support confident negotiations. [Get in touch](https://staging.tcc.group/contact/) [Canonical source](https://staging.tcc.group/blog/2026/01/07/case-study-acquisition-due-diligence/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person 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"https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/case-studies/acquisition-due-diligence/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Case Studies", "item": "https://tcc.group/case-studies/" }, { "@type": "ListItem", "position": 3, "name": "Acquisition 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"https://tcc.group/blog/solution/consolidation-acquisition-regulatory-due-diligence/" }, { "@type": "Thing", "name": "Suitability, Advice Quality & File Reviews", "url": "https://tcc.group/blog/solution/outsourced-suitability-reviews/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Advisory", "url": "https://tcc.group/blog/service/advisory/" } ], "abstract": "Discover how TCC Group helped a client assess potential redress liabilities during the acquisition of an independent financial adviser, providing the insight and assurance needed to support pricing, deal negotiations and strategic decision-making.", "description": "Discover how TCC Group helped a client assess potential redress liabilities during the acquisition of an independent financial adviser, providing the insight and assurance needed to support pricing, deal negotiations and strategic decision-making.", "articleBody": "The challenge\n\nA client negotiating the acquisition of an independent financial adviser (IFA) needed clear visibility into potential back-book redress liabilities. While the firm possessed a large portfolio of client files, conducting a manual review of every single case was operationally and commercially impractical.\r\n\r\nWithout a reliable estimate of legacy exposure, the client could not establish a fair purchase price or negotiate the deal confidently. They required independent assurance to identify data gaps and quantify risk within tight transactional timeframes.\n\nOur approach\n\nTCC developed a structured, pragmatic sampling methodology, selecting a targeted sample of 30 cases that balanced high-risk factors with a representative spread of the portfolio. We prioritised cases based on key risk indicators, including transfer values, customer ages and scheme dates.\r\n\r\nTo overcome the challenge of incomplete point-of-sale documentation, we utilised data from our extensive library of similar projects and drawing on our deep expertise with comparable financial advice schemes to reconstruct missing details and ensure thorough analysis.\n\nOutcomes\n\nOur risk-prioritised approach enabled the client to accurately quantify potential redress liabilities without the cost or delay of a full portfolio audit. This critical assessment identified legacy file gaps and established a defensible, evidence-backed risk model.\r\n\r\nArmed with these insights, the client gained the necessary assurance to proceed with deal negotiations. This analytical support allowed them to make informed strategic decisions and negotiate the final transaction pricing with high confidence.\n\nEvidence\n\nThe engagement was evidenced by the successful assessment and reporting of a representative 30-case sample, which identified key data gaps and quantified liabilities to support transaction negotiations.\n\nDownload case study", "wordCount": 262, "keywords": [ "Complaints & Claims Handling", "Consolidation, Acquisition & Regulatory Due Diligence", "Suitability, Advice Quality & File Reviews", "Wealth Management & Financial Advice", "Advisory" ], "articleSection": [ "Complaints & Claims Handling", "Consolidation, Acquisition & Regulatory Due Diligence", "Suitability, Advice Quality & File Reviews" ], "potentialAction": { "@type": "ContactAction", "name": "Get in touch", "target": { "@type": "EntryPoint", "urlTemplate": "https://staging.tcc.group/contact/" } }, "mentions": [ { "@type": "QuantitativeValue", "name": "Portfolio sample size", "value": 30, "unitText": "cases" } ] } ] } ``` ### Meeting MiFID II rules with help from expert team - URL: https://tcc.group/case-studies/achieving-mifid-ii-compliance/ - Published: 2026-09-02 - Modified: 2026-09-02 **Service:** Advisory services Our experts delivered a bespoke MiFID II readiness programme for a large advisory network and portfolio manager, identifying key operational gaps and enabling the client to implement necessary changes cost-effectively using their internal resource under our professional assurance. #### The challenge A prominent advisory network and portfolio manager was struggling to navigate the complex requirements of MiFID II. Because both of its core business lines were affected, the firm faced a significant challenge in understanding how the regulation intersected with other impending changes such as the Insurance Distribution Directive (IDD). Additionally, the client faced difficulties in prioritising their mounting workload and launching the required change programmes. Without specialized regulatory expertise, they risked missing the strict statutory implementation deadline, potentially exposing the business to severe compliance failures. #### Our approach Our consultants performed an in-depth review of the client's business model and investment propositions. We conducted a detailed side-by-side analysis of the existing rules and the new MiFID II requirements to isolate material changes affecting them as an Article 3 firm, ensuring other forthcoming regulations were fully aligned. We designed a comprehensive action plan tailored for the client's internal teams to roll out in-house. To safeguard quality and keep the project on track, we provided ongoing independent assurance, verified procedural updates, and delivered targeted training sessions for key stakeholders. #### Outcomes The client achieved full compliance with the Financial Conduct Authority (FCA) requirements well before the implementation deadline. By applying our structured planning and clear guidance, the firm successfully de-risked their compliance journey and established up-to-date systems and controls. Utilising our flexible resource model allowed the client to execute the majority of the implementation work using their existing team. This strategic approach delivered substantial cost savings while maintaining exceptionally high compliance standards and regulatory confidence. #### Evidence The client successfully met all regulatory obligations ahead of the implementation deadline, with all internal procedures, systems, and controls independently verified as fully compliant with the FCA rules. **Classifications:** Regulatory Change & Transformation, Wealth Management & Financial Advice, Advisory #### Need help navigating complex regulatory changes? Speak to our compliance experts to discover how our tailored support can de-risk your transition and keep your change programmes on schedule. [Get in touch](https://staging.tcc.group/contact/) [Canonical source](https://tcc.group/blog/2017/03/29/case-study-achieving-mifid-ii-compliance/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person 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Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Advisory", "url": "https://tcc.group/blog/service/advisory/" } ], "abstract": "Our experts delivered a bespoke MiFID II readiness programme for a large advisory network and portfolio manager, identifying key operational gaps and enabling the client to implement necessary changes cost-effectively using their internal resource under our professional assurance.", "description": "Our experts delivered a bespoke MiFID II readiness programme for a large advisory network and portfolio manager, identifying key operational gaps and enabling the client to implement necessary changes cost-effectively using their internal resource under our professional assurance.", "articleBody": "The challenge\n\nA prominent advisory network and portfolio manager was struggling to navigate the complex requirements of MiFID II. Because both of its core business lines were affected, the firm faced a significant challenge in understanding how the regulation intersected with other impending changes such as the Insurance Distribution Directive (IDD).\n\nAdditionally, the client faced difficulties in prioritising their mounting workload and launching the required change programmes. Without specialized regulatory expertise, they risked missing the strict statutory implementation deadline, potentially exposing the business to severe compliance failures.\n\nOur approach\n\nOur consultants performed an in-depth review of the client's business model and investment propositions. We conducted a detailed side-by-side analysis of the existing rules and the new MiFID II requirements to isolate material changes affecting them as an Article 3 firm, ensuring other forthcoming regulations were fully aligned.\n\nWe designed a comprehensive action plan tailored for the client's internal teams to roll out in-house. To safeguard quality and keep the project on track, we provided ongoing independent assurance, verified procedural updates, and delivered targeted training sessions for key stakeholders.\n\nOutcomes\n\nThe client achieved full compliance with the Financial Conduct Authority (FCA) requirements well before the implementation deadline. By applying our structured planning and clear guidance, the firm successfully de-risked their compliance journey and established up-to-date systems and controls.\n\nUtilising our flexible resource model allowed the client to execute the majority of the implementation work using their existing team. This strategic approach delivered substantial cost savings while maintaining exceptionally high compliance standards and regulatory confidence.\n\nEvidence\n\nThe client successfully met all regulatory obligations ahead of the implementation deadline, with all internal procedures, systems, and controls independently verified as fully compliant with the FCA rules.", "wordCount": 282, "keywords": [ "Regulatory Change & Transformation", "Wealth Management & Financial Advice", "Advisory" ], "articleSection": [ "Regulatory Change & Transformation" ], "potentialAction": { "@type": "ContactAction", "name": "Get in touch", "target": { "@type": "EntryPoint", "urlTemplate": "https://staging.tcc.group/contact/" } } } ] } ``` ### Redress calculations - URL: https://tcc.group/case-studies/redress-calculations/ - Published: 2024-07-18 - Modified: 2026-09-02 **Service:** Managed Services We supported a large IFA with suitability and redress calculations for 3,000 customers, proposing a streamlined data methodology that saved over 20% in costs and completed four months early. #### The challenge Our client had come under fire from the FCA as it was concerned about suitability failures following the firm’s introduction of an alternative private pension arrangement. Under direction from the FCA, our client needed to carry out an initial review of 50 files to determine if this was the case. They knew only an independent review would give them the unbiased clarity they needed to satisfy the regulator, so they asked us at TCC. #### Our approach We undertook the initial review seeking out for instances where customers had been given poor advice. We immediately noticed cases where the customer had suffered financial detriment, so we offered up our expert redress team for support. Skilled in dealing with complex and nuanced cases, our actuarial experts calculated an appropriate amount of compensation. Inevitably, the scope of the review was expanded to a population of 3,000 customers, but our flexible and responsive model meant we could scale up operations quickly to deal with the drastic increase in caseload. We identified at an early stage that data gathering was taking a long time. Committed to driving efficiencies, we proposed a new data calculation methodology that avoided reviewing every single case in great detail. This reduced the data-gathering burden and simplified the loss calculation. As a result, the client paid out slightly more in compensation but far greater savings were generated from reducing the time to complete the project. We proposed the new methodology to the regulator and it was accepted by all parties. Once implemented, we rattled through cases in double-quick time, eventually completing the project four months earlier than predicted. Better yet, by finding the most efficient route, we saved our client over 20% of original estimate of costs. #### Outcomes We’re committed to driving value. We developed an alternative approach that saved our client time and generated 20% in overall cost savings. Our in-house redress team are the best in the business. Thanks to our proactive approach and deep actuarial expertise, end customers were swiftly compensated and the regulator satisfied, avoiding any further enforcement action for our client. Our model is scalable and flexible, meaning we could easily tackle the increase in caseload quickly. #### Key facts - Cost savings achieved: 20 % - Remediation project population: 3000 customers - Initial file review size: 50 files - Project duration reduction: 4 months **Classifications:** Redress & Remediation, Suitability, Advice Quality & File Reviews, Pensions & Retirement Income, Wealth Management & Financial Advice, Managed services - Reviewed by: TCC Group regulatory specialists **Last reviewed:** 2026-09-01 #### Looking to reduce the cost of redress calculations? Partner with our actuarial and redress specialists to design efficient, regulator-approved loss calculation methodologies. [Get in touch](https://staging.tcc.group/contact/) [Canonical source](https://tcc.group/blog/2024/07/18/case-study-redress-calculations-2/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", 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"https://tcc.group/blog/sector/pensions-retirement-income/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Managed services", "url": "https://tcc.group/blog/service/managed-services/" } ], "abstract": "We supported a large IFA with suitability and redress calculations for 3,000 customers, proposing a streamlined data methodology that saved over 20% in costs and completed four months early.", "description": "We supported a large IFA with suitability and redress calculations for 3,000 customers, proposing a streamlined data methodology that saved over 20% in costs and completed four months early.", "articleBody": "The challenge\n\nOur client had come under fire from the FCA as it was concerned about suitability failures following the firm\u2019s introduction of an alternative private pension arrangement. Under direction from the FCA, our client needed to carry out an initial review of 50 files to determine if this was the case. They knew only an independent review would give them the unbiased clarity they needed to satisfy the regulator, so they asked us at TCC.\n\nOur approach\n\nWe undertook the initial review seeking out for instances where customers had been given poor advice. We immediately noticed cases where the customer had suffered financial detriment, so we offered up our expert redress team for support. Skilled in dealing with complex and nuanced cases, our actuarial experts calculated an appropriate amount of compensation. Inevitably, the scope of the review was expanded to a population of 3,000 customers, but our flexible and responsive model meant we could scale up operations quickly to deal with the drastic increase in caseload. We identified at an early stage that data gathering was taking a long time. 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The FCA has published Consultation Paper CP26/27, proposing to replace the existing AIFM, UCITS and MIFIDPRU remuneration codes with a single remuneration framework for in-scope solo-regulated firms. The proposed regime aims to simplify the current landscape, reduce duplication and create a more proportionate approach that reflects the size, activities and risk profile of firms. While the proposals could reduce prescriptive requirements, the FCA has made clear that remuneration governance, accountability and risk management will remain important supervisory priorities. The consultation closes on 16 September 2026, with a policy statement expected in Q1 2027. #### Why does it matter? The consultation signals more than a technical consolidation of remuneration rules. It reflects the FCA's broader shift towards outcomes-based regulation, where firms are expected to demonstrate that governance arrangements lead to appropriate behaviours, sound decision-making and good customer outcomes. Although firms may gain greater flexibility under a simplified framework, they may also face increased expectations to evidence how remuneration supports appropriate conduct, effective risk management and organisational culture. #### Who is affected? The proposals are primarily relevant to solo-regulated firms currently subject to the AIFM, UCITS or MIFIDPRU remuneration regimes. The impact will vary depending on a firm's classification, whether it remains within scope under the new framework and how remuneration is managed across its wider group structure. Senior managers, governance committees, HR functions, compliance teams and SMCR accountable individuals may all have a role in assessing the implications. #### Key risks - Assuming simplification means reduced regulatory scrutiny. - Treating the consultation proposals as final rules before publication of the FCA's policy statement. - Being unable to evidence how remuneration supports customer interests and good outcomes. - Weak governance oversight of incentives, conduct risks and non-financial performance measures. - Misalignment between remuneration practices, organisational culture and Consumer Duty objectives. - Overlooking interactions between remuneration governance and SMCR responsibilities. #### Actions to take 1. Determine whether the proposed framework applies to your firm or group structure. 2. Review current remuneration policies, controls and governance arrangements. 3. Identify areas of unnecessary complexity within existing remuneration frameworks. 4. Assess how remuneration supports conduct, culture, risk management and customer outcomes. 5. Evaluate how remuneration governance aligns with Consumer Duty and wider regulatory expectations. 6. Monitor consultation developments ahead of the FCA's final policy statement. #### Wider implications CP26/27 reinforces a growing regulatory theme across the FCA's supervisory work. Whether considering Consumer Duty, governance reviews or outcomes monitoring, the regulator is increasingly focused on evidence of effectiveness rather than adherence to detailed processes alone. For firms, this suggests that governance frameworks will continue to be judged not only on their design but also on their ability to demonstrate positive outcomes, effective challenge and sound decision-making. #### Recommendations Firms should avoid wholesale implementation while the proposals remain under consultation. Instead, this is an opportunity to assess the strength of existing governance arrangements and the quality of evidence available to support remuneration decisions. Senior management should be able to explain: - How remuneration arrangements support customer interests. - How conduct risks are reflected in reward decisions. - How non-financial performance measures influence remuneration outcomes. - How inappropriate incentives are identified and challenged. - How remuneration supports the firm's culture and Consumer Duty objectives. #### Supporting sources - [Consultation Paper CP26/27](https://www.fca.org.uk/publication/consultation/cp26-27.pdf) #### Next step TCC supports firms in assessing the regulatory implications of consultation papers, reviewing governance and remuneration frameworks, evaluating Consumer Duty and conduct risk implications, and preparing for future regulatory change.   [Talk to us](https://tcc.group/talk-to-us/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": 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The proposed regime\u2026", "inLanguage": "en-GB", "articleBody": "The FCA has published Consultation Paper CP26/27, proposing to replace the existing AIFM, UCITS and MIFIDPRU remuneration codes with a single remuneration framework for in-scope solo-regulated firms. The proposed regime aims to simplify the current landscape, reduce duplication and create a more proportionate approach that reflects the size, activities and risk profile of firms.\nWhile the proposals could reduce prescriptive requirements, the FCA has made clear that remuneration governance, accountability and risk management will remain important supervisory priorities. The consultation closes on 16 September 2026, with a policy statement expected in Q1 2027.\n\nThe consultation signals more than a technical consolidation of remuneration rules. It reflects the FCA's broader shift towards outcomes-based regulation, where firms are expected to demonstrate that governance arrangements lead to appropriate behaviours, sound decision-making and good customer outcomes.\r\n\r\nAlthough firms may gain greater flexibility under a simplified framework, they may also face increased expectations to evidence how remuneration supports appropriate conduct, effective risk management and organisational culture.\n\nThe proposals are primarily relevant to solo-regulated firms currently subject to the AIFM, UCITS or MIFIDPRU remuneration regimes.\r\n\r\nThe impact will vary depending on a firm's classification, whether it remains within scope under the new framework and how remuneration is managed across its wider group structure. Senior managers, governance committees, HR functions, compliance teams and SMCR accountable individuals may all have a role in assessing the implications.\n\n\u2022 Assuming simplification means reduced regulatory scrutiny.\n\u2022 Treating the consultation proposals as final rules before publication of the FCA's policy statement.\n\u2022 Being unable to evidence how remuneration supports customer interests and good outcomes.\n\u2022 Weak governance oversight of incentives, conduct risks and non-financial performance measures.\n\u2022 Misalignment between remuneration practices, organisational culture and Consumer Duty objectives.\n\u2022 Overlooking interactions between remuneration governance and SMCR responsibilities.\n\n1. Determine whether the proposed framework applies to your firm or group structure.\n2. Review current remuneration policies, controls and governance arrangements.\n3. Identify areas of unnecessary complexity within existing remuneration frameworks.\n4. Assess how remuneration supports conduct, culture, risk management and customer outcomes.\n5. Evaluate how remuneration governance aligns with Consumer Duty and wider regulatory expectations.\n6. Monitor consultation developments ahead of the FCA's final policy statement.\n\nCP26/27 reinforces a growing regulatory theme across the FCA's supervisory work. Whether considering Consumer Duty, governance reviews or outcomes monitoring, the regulator is increasingly focused on evidence of effectiveness rather than adherence to detailed processes alone.\r\n\r\nFor firms, this suggests that governance frameworks will continue to be judged not only on their design but also on their ability to demonstrate positive outcomes, effective challenge and sound decision-making.\n\nFirms should avoid wholesale implementation while the proposals remain under consultation. Instead, this is an opportunity to assess the strength of existing governance arrangements and the quality of evidence available to support remuneration decisions.\n\nSenior management should be able to explain:\n\u2022 How remuneration arrangements support customer interests.\n\u2022 How conduct risks are reflected in reward decisions.\n\u2022 How non-financial performance measures influence remuneration outcomes.\n\u2022 How inappropriate incentives are identified and challenged.\n\u2022 How remuneration supports the firm's culture and Consumer Duty objectives.", "wordCount": 514, "keywords": [ "Consumer Duty", "Regulatory Change & Transformation", "Section 166, Skilled Person Reviews & FCA Intervention", "Banking", "Payments & FinTech", "Pensions & Retirement Income", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Consumer Duty", "url": "https://tcc.group/blog/solution/consumer-duty/" }, { "@type": "Thing", "name": "Regulatory Change & Transformation", "url": "https://tcc.group/blog/solution/regulatory-change-transformation/" }, { "@type": "Thing", "name": "Section 166, Skilled Person Reviews & FCA Intervention", "url": "https://tcc.group/blog/solution/section-166-skilled-person-reviews-fca-intervention/" }, { "@type": "Thing", "name": "Banking", "url": "https://tcc.group/blog/sector/banking/" }, { "@type": "Thing", "name": "Payments & FinTech", "url": "https://tcc.group/blog/sector/payments-fintech/" }, { "@type": "Thing", "name": "Pensions & Retirement Income", "url": "https://tcc.group/blog/sector/pensions-retirement-income/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "FCA remuneration reform explained: what CP26/27 could mean for firms" } ], "articleSection": [ "Consumer Duty", "Regulatory Change & Transformation", "Section 166, Skilled Person Reviews & FCA Intervention" ], "audience": [ { "@type": "Audience", "audienceType": "Banking" }, { "@type": "Audience", "audienceType": "Payments & FinTech" }, { "@type": "Audience", "audienceType": "Pensions & Retirement Income" }, { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" } ], "citation": [ { "@type": "CreativeWork", "name": "Consultation Paper CP26/27", "url": "https://www.fca.org.uk/publication/consultation/cp26-27.pdf" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/analysis-perspectives/fca-remuneration-reform-explained-what-cp26-27-could-mean-for-firms/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/fca-remuneration-reform-explained-what-cp26-27-could-mean-for-firms/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "Which firms are affected by FCA\u2019s CP26/27?", "acceptedAnswer": { "@type": "Answer", "text": "FCA\u2019s\u00a0CP26/27 is relevant to solo-regulated firms currently within the AIFM, UCITS or MIFIDPRU\u00a0remuneration\u00a0regimes. The precise effect will depend on a firm\u2019s existing classification, whether it\u00a0remains\u00a0in scope under the proposals and, where relevant, its group structure.\u00a0" } }, { "@type": "Question", "name": "Is the FCA\u2019s CP26/27 removing remuneration requirements?", "acceptedAnswer": { "@type": "Answer", "text": "No. The FCA\u2019s\u00a0CP26/27\u00a0is proposing a simpler and more proportionate framework, but\u00a0remuneration\u00a0governance, accountability and alignment with\u00a0appropriate outcomes\u00a0will\u00a0remain\u00a0important regulatory expectations.\u00a0\u00a0" } }, { "@type": "Question", "name": "FCA\u2019s CP26/27, what is the expected timetable?", "acceptedAnswer": { "@type": "Answer", "text": "The\u00a0FCA\u2019s CP26/27\u00a0consultation closes on 16 September 2026. The FCA currently expects to publish a policy statement in Q1 2027.\u00a0" } }, { "@type": "Question", "name": "What does FCA CP26/27 tell us about the FCA\u2019s wider supervisory approach?", "acceptedAnswer": { "@type": "Answer", "text": "The\u00a0wider regulatory message\u00a0on the back of the\u00a0FCA\u2019s CP26/27\u00a0remuneration\u00a0proposals\u00a0is\u00a0that\u00a0outcomes,\u00a0governance\u00a0and accountability\u00a0remain central to the FCA\u2019s supervisory approach.\u00a0Across\u00a0the\u00a0Consumer Duty, governance and outcomes\u00a0monitoring\u00a0reviews, firms are increasingly expected to\u00a0evidence\u00a0how decisions, controls and governance arrangements lead to good customer outcomes.\u00a0\u00a0" } }, { "@type": "Question", "name": "What remuneration codes would CP26/27 replace?", "acceptedAnswer": { "@type": "Answer", "text": "The FCA proposes replacing the AIFM, UCITS and MIFIDPRU\u00a0remuneration\u00a0codes with a single\u00a0remuneration\u00a0framework (CP26/27) for firms\u00a0remaining\u00a0in scope.\u00a0" } }, { "@type": "Question", "name": "What should firms do before the FCA finalises the remuneration rules?", "acceptedAnswer": { "@type": "Answer", "text": "Firms can assess whether the proposals apply to their business, review existing\u00a0remuneration\u00a0governance arrangements,\u00a0identify\u00a0unnecessary\u00a0complexity\u00a0and\u00a0monitor\u00a0developments ahead of the FCA\u2019s policy statement. As CP26/27\u00a0remains\u00a0a consultation, firms should avoid treating the proposals as final requirements.\u00a0" } } ] } ] } ``` ### IBS Intelligence: Why financial services firms face growing AI governance scrutiny - URL: https://tcc.group/insights/analysis-perspectives/ibs-intelligence-why-financial-services-firms-face-growing-ai-governance-scrutiny/ - Published: 2026-09-02 - Modified: 2026-09-02 **Topic:** IBS Intelligence: Why financial services firms face growing AI governance scrutiny As AI becomes more deeply embedded across financial services, firms face growing pressure to demonstrate clear accountability, oversight and governance. While existing frameworks such as Consumer Duty, SMCR and operational resilience requirements remain relevant, firms must ensure they can evidence where AI is being used, who remains responsible for decisions and how customer outcomes are being monitored as adoption accelerates. #### What happened? Recently featured in [IBS Intelligence](https://ibsintelligence.com/ibsi-news/financial-services-firms-face-growing-ai-governance-scrutiny/), TCC Group CEO Joe Norburn shared his views on the increasing need for accountability as AI becomes more widely adopted across retail banking, payments, lending, insurance and investment services. The comments follow a recent review examining how AI could reshape retail financial services through 2030 and beyond. The review found that AI is moving beyond basic assistance, with consumers becoming more comfortable relying on automated systems for financial decision-making. Research cited in the review showed that one in five UK adults would be open to AI making financial decisions on their behalf, particularly in areas such as debt advice, pensions and investments. The review also highlighted a potential disconnect between trust and understanding. Around 26% of consumers said they trust general-purpose AI tools such as ChatGPT, Claude and Gemini for financial advice, despite limited awareness that formal routes to recourse may not apply if those tools provide incorrect guidance. #### Why does it matter? The findings suggest that AI governance is becoming a key area of focus for financial services firms. As consumers place greater trust in AI-driven tools and services, firms must be able to demonstrate that appropriate oversight, accountability and controls remain in place. The review identifies several risks associated with increased AI adoption, including opaque decision-making, algorithmic bias, AI-enabled fraud and operational vulnerabilities. Firms are therefore under growing pressure to strengthen governance, improve data quality and maintain clear lines of responsibility while continuing to benefit from AI-driven efficiency and innovation. As AI becomes more influential in customer interactions and financial decision-making, firms may also need to consider whether customers fully understand when decisions are being supported or influenced by automated systems, and how this affects customer outcomes and trust. #### Supporting sources - [Financial services firms face growing AI governance scrutiny](https://ibsintelligence.com/ibsi-news/financial-services-firms-face-growing-ai-governance-scrutiny/) #### Can your firm demonstrate where AI is being used, who is accountable for decisions, and how customer outcomes are being monitored? TCC Group helps firms strengthen AI governance by assessing accountability frameworks, oversight processes and outcome monitoring capabilities, ensuring AI adoption aligns with regulatory expectations while supporting good customer outcomes. [Talk to us](https://tcc.group/talk-to-us/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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While existing frameworks such as Consumer Duty, SMCR and operational\u2026", "inLanguage": "en-GB", "articleBody": "As AI becomes more deeply embedded across financial services, firms face growing pressure to demonstrate clear accountability, oversight and governance. While existing frameworks such as Consumer Duty, SMCR and operational resilience requirements remain relevant, firms must ensure they can evidence where AI is being used, who remains responsible for decisions and how customer outcomes are being monitored as adoption accelerates.\n\nRecently featured in IBS Intelligence, TCC Group CEO Joe Norburn shared his views on the increasing need for accountability as AI becomes more widely adopted across retail banking, payments, lending, insurance and investment services.\nThe comments follow a recent review examining how AI could reshape retail financial services through 2030 and beyond. The review found that AI is moving beyond basic assistance, with consumers becoming more comfortable relying on automated systems for financial decision-making. Research cited in the review showed that one in five UK adults would be open to AI making financial decisions on their behalf, particularly in areas such as debt advice, pensions and investments.\n\nThe review also highlighted a potential disconnect between trust and understanding. Around 26% of consumers said they trust general-purpose AI tools such as ChatGPT, Claude and Gemini for financial advice, despite limited awareness that formal routes to recourse may not apply if those tools provide incorrect guidance.\n\nThe findings suggest that AI governance is becoming a key area of focus for financial services firms. 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Firms must strengthen oversight and controls to manage these risks while benefiting from AI-driven innovation." } } ] } ] } ``` ### FCA CP26/28: What the AIFM regime reforms mean for wealth managers and firms - URL: https://tcc.group/insights/regulatory-horizon/fca-cp26-28-what-the-aifm-regime-reforms-mean-for-wealth-managers-and-firms/ - Published: 2026-09-02 - Modified: 2026-09-02 **Topic:** FCA CP26/28: What the AIFM regime reforms mean for wealth managers and firms The FCA’s proposed AIFM reforms highlight a wider regulatory shift towards proportionate regulation, stronger governance and better-quality reporting. While the direct impact on many wealth managers may be limited, the changes could enhance the information firms use to support due diligence, Consumer Duty oversight and evidence-based decision-making. #### What happened? The FCA has launched consultation CP26/28, proposing significant reforms to the UK Alternative Investment Fund Manager (AIFM) regime. The proposals aim to create a more proportionate, flexible and UK-specific framework, replacing elements of the existing regime inherited from the EU. The reforms would introduce a more tailored approach based on firm size, activities and risk profile, alongside changes to reporting, disclosures, governance expectations and oversight arrangements. Implementation is currently envisaged for 2028 following consultation, further FCA rulemaking and supporting Treasury legislation. #### Why does it matter? Although implementation is not currently envisaged until 2028, the consultation provides an important indication of the FCA's regulatory direction. The proposals reflect a broader regulatory trend towards proportionate regulation, improved governance, better quality reporting and stronger evidence-based decision-making. Firms should view the reforms not just as an asset management issue, but as part of a wider shift towards demonstrating effective oversight and customer outcomes. #### Who is affected? The reforms will directly affect UK-authorised and UK-registered AIFMs, firms marketing alternative investment funds in the UK, depositaries, prime brokers, delegates of AIFMs and investors in alternative investment funds. However, wealth managers, advisers and governance teams may also see indirect impacts through changes to the reporting, disclosures and governance information provided by asset managers. #### Key risks - Missing early signals about future regulatory expectations and governance standards. - Failing to assess how reporting and disclosure changes could affect due diligence processes. - Reliance on governance and management information that may not evolve in line with regulatory expectations. - Insufficient consideration of how future reporting enhancements could support Consumer Duty oversight. - Governance committees being unprepared for changes in the wider regulatory landscape. #### Actions to take 1. Monitor consultation developments and implementation timelines. 2. Engage with asset management providers to understand potential reporting and disclosure changes. 3. Review how current provider information supports governance, due diligence and oversight activities. 4. Assess whether future reporting enhancements could strengthen Consumer Duty monitoring. 5. Keep governance committees informed about the likely direction of regulatory travel. 6. Track developments in both FCA reforms and related Treasury legislative changes.   #### Wider implications The consultation reinforces the FCA's broader focus on simplifying regulation while maintaining regulatory outcomes. Across multiple supervisory themes, firms are increasingly expected to demonstrate how governance bodies use management information to identify risks, challenge assumptions and evidence decision-making. Improved reporting and oversight information could help firms strengthen governance frameworks, value assessments, product oversight and Consumer Duty reviews. However, simplification should not be mistaken for reduced accountability. Firms will still be expected to demonstrate sound judgement, effective controls and robust governance. #### Recommendations The consultation closes on 14th October 2026, with implementation currently envisaged for 2028 following consultation feedback, a further FCA consultation on remaining areas, final rules and associated Treasury legislative reforms. In the meantime, firms should consider: - Monitoring consultation developments and implementation timelines - Engaging with key asset management providers to understand potential changes - Reviewing how provider reporting currently supports governance and due diligence activities - Assessing whether future reporting enhancements could strengthen Consumer Duty oversight - Keeping governance committees informed about the likely direction of travel #### Supporting sources - [The UK AIFM Regime](https://www.fca.org.uk/publications/consultation-papers/cp26-28-uk-aifm-regime) #### Turn regulatory change into practical action TCC helps firms interpret regulatory change, assess governance implications and prepare for evolving FCA expectations. 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"item": "https://tcc.group/insights/regulatory-horizon/fca-cp26-28-what-the-aifm-regime-reforms-mean-for-wealth-managers-and-firms/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/regulatory-horizon/fca-cp26-28-what-the-aifm-regime-reforms-mean-for-wealth-managers-and-firms/#webpage", "url": "https://tcc.group/insights/regulatory-horizon/fca-cp26-28-what-the-aifm-regime-reforms-mean-for-wealth-managers-and-firms/", "name": "FCA CP26/28: What the AIFM regime reforms mean for wealth managers and firms", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-09-02T15:35:39+01:00", "dateModified": "2026-09-02T15:38:07+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/regulatory-horizon/fca-cp26-28-what-the-aifm-regime-reforms-mean-for-wealth-managers-and-firms/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "Article", "@id": "https://tcc.group/insights/regulatory-horizon/fca-cp26-28-what-the-aifm-regime-reforms-mean-for-wealth-managers-and-firms/#article", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/fca-cp26-28-what-the-aifm-regime-reforms-mean-for-wealth-managers-and-firms/#webpage" }, "author": { "@type": "Person", "name": "May York" }, "headline": "FCA CP26/28: What the AIFM regime reforms mean for wealth managers and firms", "datePublished": "2026-09-02T15:35:39+01:00", "dateModified": "2026-09-02T15:38:07+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/regulatory-horizon/fca-cp26-28-what-the-aifm-regime-reforms-mean-for-wealth-managers-and-firms/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/24783ef6fef345d6ab2ebdf4535c459c/thumbnail-1024-30b6e8ba59203cbfe11d212c25c26755df8d3787606a8ad4ce483b7eb15ae4ae.jpg", "description": "The FCA has launched consultation CP26/28, proposing significant reforms to the UK Alternative Investment Fund Manager (AIFM) regime. The proposals aim to create a more proportionate, flexible and UK-specific framework,\u2026", "inLanguage": "en-GB", "articleBody": "The FCA\u2019s proposed AIFM reforms highlight a wider regulatory shift towards proportionate regulation, stronger governance and better-quality reporting. While the direct impact on many wealth managers may be limited, the changes could enhance the information firms use to support due diligence, Consumer Duty oversight and evidence-based decision-making.\n\nThe FCA has launched consultation CP26/28, proposing significant reforms to the UK Alternative Investment Fund Manager (AIFM) regime. The proposals aim to create a more proportionate, flexible and UK-specific framework, replacing elements of the existing regime inherited from the EU. The reforms would introduce a more tailored approach based on firm size, activities and risk profile, alongside changes to reporting, disclosures, governance expectations and oversight arrangements. Implementation is currently envisaged for 2028 following consultation, further FCA rulemaking and supporting Treasury legislation.\n\nAlthough implementation is not currently envisaged until 2028, the consultation provides an important indication of the FCA's regulatory direction. The proposals reflect a broader regulatory trend towards proportionate regulation, improved governance, better quality reporting and stronger evidence-based decision-making. Firms should view the reforms not just as an asset management issue, but as part of a wider shift towards demonstrating effective oversight and customer outcomes.\n\nThe reforms will directly affect UK-authorised and UK-registered AIFMs, firms marketing alternative investment funds in the UK, depositaries, prime brokers, delegates of AIFMs and investors in alternative investment funds. However, wealth managers, advisers and governance teams may also see indirect impacts through changes to the reporting, disclosures and governance information provided by asset managers.\n\n\u2022 Missing early signals about future regulatory expectations and governance standards.\n\u2022 Failing to assess how reporting and disclosure changes could affect due diligence processes.\n\u2022 Reliance on governance and management information that may not evolve in line with regulatory expectations.\n\u2022 Insufficient consideration of how future reporting enhancements could support Consumer Duty oversight.\n\u2022 Governance committees being unprepared for changes in the wider regulatory landscape.\n\n1. Monitor consultation developments and implementation timelines.\n2. Engage with asset management providers to understand potential reporting and disclosure changes.\n3. Review how current provider information supports governance, due diligence and oversight activities.\n4. Assess whether future reporting enhancements could strengthen Consumer Duty monitoring.\n5. Keep governance committees informed about the likely direction of regulatory travel.\n6. Track developments in both FCA reforms and related Treasury legislative changes.\n\n\u00a0\n\nThe consultation reinforces the FCA's broader focus on simplifying regulation while maintaining regulatory outcomes. Across multiple supervisory themes, firms are increasingly expected to demonstrate how governance bodies use management information to identify risks, challenge assumptions and evidence decision-making. Improved reporting and oversight information could help firms strengthen governance frameworks, value assessments, product oversight and Consumer Duty reviews. However, simplification should not be mistaken for reduced accountability. Firms will still be expected to demonstrate sound judgement, effective controls and robust governance.\n\nThe consultation closes on 14th October 2026, with implementation currently envisaged for 2028 following consultation feedback, a further FCA consultation on remaining areas, final rules and associated Treasury legislative reforms.\n\nIn the meantime, firms should consider:\n\u2022 Monitoring consultation developments and implementation timelines\n\u2022 Engaging with key asset management providers to understand potential changes\n\u2022 Reviewing how provider reporting currently supports governance and due diligence activities\n\u2022 Assessing whether future reporting enhancements could strengthen Consumer Duty oversight\n\u2022 Keeping governance committees informed about the likely direction of travel", "wordCount": 548, "keywords": [ "Consolidation, Acquisition & Regulatory Due Diligence", "Consumer Duty", "Regulatory Change & Transformation", "Pensions & Retirement Income", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Consolidation, Acquisition & Regulatory Due Diligence", "url": "https://tcc.group/blog/solution/consolidation-acquisition-regulatory-due-diligence/" }, { "@type": "Thing", "name": "Consumer Duty", "url": "https://tcc.group/blog/solution/consumer-duty/" }, { "@type": "Thing", "name": "Regulatory Change & Transformation", "url": "https://tcc.group/blog/solution/regulatory-change-transformation/" }, { "@type": "Thing", "name": "Pensions & Retirement Income", "url": "https://tcc.group/blog/sector/pensions-retirement-income/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "FCA CP26/28: What the AIFM regime reforms mean for wealth managers and firms" } ], "articleSection": [ "Consolidation, Acquisition & Regulatory Due Diligence", "Consumer Duty", "Regulatory Change & Transformation" ], "audience": [ { "@type": "Audience", "audienceType": "Pensions & Retirement Income" }, { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" } ], "citation": [ { "@type": "CreativeWork", "name": "The UK AIFM Regime", "url": "https://www.fca.org.uk/publications/consultation-papers/cp26-28-uk-aifm-regime" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/regulatory-horizon/fca-cp26-28-what-the-aifm-regime-reforms-mean-for-wealth-managers-and-firms/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/fca-cp26-28-what-the-aifm-regime-reforms-mean-for-wealth-managers-and-firms/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What is CP26/28?", "acceptedAnswer": { "@type": "Answer", "text": "CP26/28 is the FCA\u2019s consultation on a new UK regulatory framework for Alternative Investment Fund Managers. The proposals are intended to create a more proportionate and flexible regime while\u00a0maintaining\u00a0appropriate consumer\u00a0and market protections.\u00a0" } }, { "@type": "Question", "name": "Who is directly affected?", "acceptedAnswer": { "@type": "Answer", "text": "UK-authorised\u00a0and UK-registered AIFMs, firms marketing alternative investment funds in the UK, residual collective investment scheme operators, depositaries, prime brokers, delegates of AIFMs, firms considering entering the UK alternative investment market, trade\u00a0bodies\u00a0and investors in alternative investment funds.\u00a0" } }, { "@type": "Question", "name": "When could the new regime take effect?", "acceptedAnswer": { "@type": "Answer", "text": "The FCA currently envisages implementation in 2028, following consultation feedback, further\u00a0rulemaking\u00a0and associated Treasury reforms.\u00a0" } }, { "@type": "Question", "name": "Why should wealth managers care about an AIFM consultation?", "acceptedAnswer": { "@type": "Answer", "text": "The reforms could influence the reporting,\u00a0governance\u00a0information and disclosures provided by asset managers, which may support stronger product governance, due\u00a0diligence\u00a0and Consumer Duty oversight processes.\u00a0" } }, { "@type": "Question", "name": "Is the FCA changing the AIFM regime now?", "acceptedAnswer": { "@type": "Answer", "text": "No. CP26/28 is a consultation. The FCA is seeking feedback on proposed reforms before introducing final rules. Implementation is currently envisaged for 2028, subject to consultation feedback and legislative changes.\u00a0" } } ] } ] } ``` ### Will Value for Money assessments change how advisers compare pension providers? - URL: https://tcc.group/insights/regulatory-horizon/will-value-for-money-assessments-change-how-advisers-compare-pension-providers/ - Published: 2026-09-02 - Modified: 2026-09-02 **Topic:** Will Value for Money assessments change how advisers compare pension providers? The FCA's proposed Value for Money (VFM) Framework could reshape how workplace pension schemes are assessed, introducing greater transparency, benchmarking and scrutiny by measuring value across investment performance, service quality, costs and member outcomes, rather than charges alone. #### What happened? The FCA, Department for Work and Pensions (DWP) and The Pensions Regulator (TPR) have proposed a new Value for Money (VFM) Framework for workplace pensions. The consultation, open until 15 September 2026, sets out plans for standardised assessments, common performance metrics, public disclosures and industry benchmarking. The objective is to make it easier for pension savers, advisers, governance bodies and employers to compare workplace pension schemes and understand the value they deliver. #### Why does it matter? The proposals could significantly change how pension schemes are assessed and compared. Historically, assessments have relied on provider research, due diligence, governance reviews and performance analysis, often using different methodologies. The VFM Framework aims to create a more consistent and transparent approach, potentially introducing a central database and publicly available assessment outcomes. This means firms may need to support decisions with both internal research and externally published value assessments. #### Who is affected? The proposals are likely to impact pension providers, pension advisers, employee benefit consultants, governance bodies, employers and workplace pension savers. Providers may face greater scrutiny over the value they deliver, while advisers and consultants may need to incorporate new VFM assessments into provider research, suitability reviews and ongoing monitoring. Governance committees and employers are also likely to have access to more transparent comparative data when reviewing pension arrangements. #### Key risks - Increased scrutiny of provider selection decisions. - Difficulty justifying recommendations where preferred providers perform poorly against published benchmarks. - Greater expectations around documenting governance and suitability decisions. - Potential regulatory intervention for schemes unable to demonstrate sufficient value. - Market and reputational pressures resulting from publicly available assessment results. - Challenges integrating VFM data into existing research and monitoring frameworks. #### Actions to take Firms should consider: - Reviewing provider research methodologies. - Assessing how VFM assessments will be incorporated into suitability and governance processes. - Updating ongoing monitoring and benchmarking frameworks. - Strengthening documentation supporting provider recommendations. - Preparing governance committees and decision-makers for increased transparency. - Establishing clear processes for challenging and responding to poor value indicators. #### Wider implications While positioned as a pensions initiative, the VFM Framework reflects a broader regulatory trend towards evidence-based decision-making and accountability. The proposals place greater emphasis on demonstrating value, challenging outcomes and evidencing why decisions have been made. As transparency increases, firms may face heightened expectations to explain how value is assessed and monitored on an ongoing basis. The framework could ultimately influence governance, oversight and suitability standards across the pensions market. #### Recommendations Advisers and consultants may want to begin reviewing governance arrangements, provider research methodologies and suitability frameworks before the first assessments are published. The proposed framework is likely to place greater emphasis on firms’ ability to explain how value is assessed, challenged, and evidenced as part of everyday decision-making processes. TCC supports pension providers and advisers with regulatory assurance, governance reviews, Consumer Duty assessments and monitoring frameworks. Our specialists help firms assess regulatory change, strengthen oversight arrangements and build the evidence needed to demonstrate value, suitability and good customer outcomes. #### Supporting sources - [CP26/25: The Value for Money Framework: consultation](https://www.fca.org.uk/publications/consultation-papers/cp26-25-value-money-framework-consultation) #### Need to evidence value, suitability and good customer outcomes under the new Value for Money framework? TCC supports pension providers and advisers with regulatory assurance, suitability reviews, governance assessments and Consumer Duty oversight. [Talk to us](https://tcc.group/talk-to-us/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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".wp-block-excerpt" ] } }, { "@type": "Article", "@id": "https://tcc.group/insights/regulatory-horizon/will-value-for-money-assessments-change-how-advisers-compare-pension-providers/#article", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/will-value-for-money-assessments-change-how-advisers-compare-pension-providers/#webpage" }, "author": { "@type": "Person", "name": "May York" }, "headline": "Will Value for Money assessments change how advisers compare pension providers?", "datePublished": "2026-09-02T15:10:09+01:00", "dateModified": "2026-09-02T15:41:46+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/regulatory-horizon/will-value-for-money-assessments-change-how-advisers-compare-pension-providers/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/2b838c6f7e0b4c7bbde1eced7a2ae94f/thumbnail-1024-80ad6beb36737bbdba2d29ad71c5bc04213e6ef5bc26d8c5b4b486af698dfef2.jpg", "description": "The FCA's proposed Value for Money (VFM) Framework could reshape how workplace pension schemes are assessed, introducing greater transparency, benchmarking and scrutiny by measuring value across investment performance, service quality,\u2026", "inLanguage": "en-GB", "articleBody": "The FCA's proposed Value for Money (VFM) Framework could reshape how workplace pension schemes are assessed, introducing greater transparency, benchmarking and scrutiny by measuring value across investment performance, service quality, costs and member outcomes, rather than charges alone.\n\nThe FCA, Department for Work and Pensions (DWP) and The Pensions Regulator (TPR) have proposed a new Value for Money (VFM) Framework for workplace pensions. The consultation, open until 15 September 2026, sets out plans for standardised assessments, common performance metrics, public disclosures and industry benchmarking.\r\n\r\nThe objective is to make it easier for pension savers, advisers, governance bodies and employers to compare workplace pension schemes and understand the value they deliver.\n\nThe proposals could significantly change how pension schemes are assessed and compared.\r\n\r\nHistorically, assessments have relied on provider research, due diligence, governance reviews and performance analysis, often using different methodologies. The VFM Framework aims to create a more consistent and transparent approach, potentially introducing a central database and publicly available assessment outcomes.\r\n\r\nThis means firms may need to support decisions with both internal research and externally published value assessments.\n\nThe proposals are likely to impact pension providers, pension advisers, employee benefit consultants, governance bodies, employers and workplace pension savers. Providers may face greater scrutiny over the value they deliver, while advisers and consultants may need to incorporate new VFM assessments into provider research, suitability reviews and ongoing monitoring. Governance committees and employers are also likely to have access to more transparent comparative data when reviewing pension arrangements.\n\n\u2022 Increased scrutiny of provider selection decisions.\n\u2022 Difficulty justifying recommendations where preferred providers perform poorly against published benchmarks.\n\u2022 Greater expectations around documenting governance and suitability decisions.\n\u2022 Potential regulatory intervention for schemes unable to demonstrate sufficient value.\n\u2022 Market and reputational pressures resulting from publicly available assessment results.\n\u2022 Challenges integrating VFM data into existing research and monitoring frameworks.\n\nFirms should consider:\n\u2022 Reviewing provider research methodologies.\n\u2022 Assessing how VFM assessments will be incorporated into suitability and governance processes.\n\u2022 Updating ongoing monitoring and benchmarking frameworks.\n\u2022 Strengthening documentation supporting provider recommendations.\n\u2022 Preparing governance committees and decision-makers for increased transparency.\n\u2022 Establishing clear processes for challenging and responding to poor value indicators.\n\nWhile positioned as a pensions initiative, the VFM Framework reflects a broader regulatory trend towards evidence-based decision-making and accountability.\nThe proposals place greater emphasis on demonstrating value, challenging outcomes and evidencing why decisions have been made. As transparency increases, firms may face heightened expectations to explain how value is assessed and monitored on an ongoing basis.\n\nThe framework could ultimately influence governance, oversight and suitability standards across the pensions market.\n\nAdvisers and consultants may want to begin reviewing governance arrangements, provider research methodologies and suitability frameworks before the first assessments are published. The proposed framework is likely to place greater emphasis on firms\u2019 ability to explain how value is assessed, challenged, and evidenced as part of everyday decision-making processes.\n\nTCC supports pension providers and advisers with regulatory assurance, governance reviews, Consumer Duty assessments and monitoring frameworks. Our specialists help firms assess regulatory change, strengthen oversight arrangements and build the evidence needed to demonstrate value, suitability and good customer outcomes.", "wordCount": 522, "keywords": [ "Consolidation, Acquisition & Regulatory Due Diligence", "Consumer Duty", "Regulatory Change & Transformation", "Suitability, Advice Quality & File Reviews", "Pensions & Retirement Income", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Consolidation, Acquisition & Regulatory Due Diligence", "url": "https://tcc.group/blog/solution/consolidation-acquisition-regulatory-due-diligence/" }, { "@type": "Thing", "name": "Consumer Duty", "url": "https://tcc.group/blog/solution/consumer-duty/" }, { "@type": "Thing", "name": "Regulatory Change & Transformation", "url": "https://tcc.group/blog/solution/regulatory-change-transformation/" }, { "@type": "Thing", "name": "Suitability, Advice Quality & File Reviews", "url": "https://tcc.group/blog/solution/outsourced-suitability-reviews/" }, { "@type": "Thing", "name": "Pensions & Retirement Income", "url": "https://tcc.group/blog/sector/pensions-retirement-income/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Will Value for Money assessments change how advisers compare pension providers?" } ], "articleSection": [ "Consolidation, Acquisition & Regulatory Due Diligence", "Consumer Duty", "Regulatory Change & Transformation", "Suitability, Advice Quality & File Reviews" ], "audience": [ { "@type": "Audience", "audienceType": "Pensions & Retirement Income" }, { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" } ], "citation": [ { "@type": "CreativeWork", "name": "CP26/25: The Value for Money Framework: consultation", "url": "https://www.fca.org.uk/publications/consultation-papers/cp26-25-value-money-framework-consultation" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/regulatory-horizon/will-value-for-money-assessments-change-how-advisers-compare-pension-providers/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/will-value-for-money-assessments-change-how-advisers-compare-pension-providers/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What is the FCA\u2019s proposed Value for Money Framework?", "acceptedAnswer": { "@type": "Answer", "text": "The proposed Value for Money Framework\u00a0(VFM)\u00a0is designed to create a more consistent approach to\u00a0assessing\u00a0workplace pension schemes using common metrics covering investment performance, service quality,\u00a0costs\u00a0and charges.\u00a0" } }, { "@type": "Question", "name": "Why is the FCA introducing a Value for Money Framework?", "acceptedAnswer": { "@type": "Answer", "text": "The FCA,\u00a0DWP\u00a0and TPR want to support a significant shift in how the workplace pensions market\u00a0operates\u00a0and competes, with greater emphasis on the value delivered to pension savers rather than charges alone.\u00a0" } }, { "@type": "Question", "name": "What could the Value for Money framework mean for advisers?", "acceptedAnswer": { "@type": "Answer", "text": "Advisers and employee benefit consultants may need to incorporate\u00a0Value for Money Framework\u00a0(VFM)\u00a0assessments into provider research, suitability reviews, governance\u00a0processes\u00a0and ongoing monitoring activities.\u00a0" } }, { "@type": "Question", "name": "How will value be assessed under the Value for Money Framework framework?", "acceptedAnswer": { "@type": "Answer", "text": "The proposals include assessment of investment performance, costs,\u00a0charges\u00a0and service quality, supported by\u00a0standardised\u00a0metrics and industry comparators.\u00a0" } }, { "@type": "Question", "name": "Could some pension schemes be forced to consolidate?", "acceptedAnswer": { "@type": "Answer", "text": "The proposals include the possibility of regulatory intervention and consolidation where schemes cannot\u00a0demonstrate\u00a0that they are delivering sufficient value to members.\u00a0" } } ] } ] } ``` ### Why firms need to prove customer outcomes not just report them - URL: https://tcc.group/insights/analysis-perspectives/why-firms-need-to-prove-customer-outcomes-not-just-report-them/ - Published: 2026-09-02 - Modified: 2026-09-02 **Topic:** Why firms need to prove customer outcomes not just report them The FCA’s latest review of outcomes monitoring reinforces that Consumer Duty compliance is about more than producing management information (MI). Firms must be able to demonstrate how they identify customer risks, act on those risks and evidence whether interventions have led to better customer outcomes. #### What happened? The FCA published findings from its review of firms’ outcomes monitoring arrangements, highlighting examples of good practice and areas for improvement. While many firms have invested significantly in Consumer Duty frameworks, dashboards and MI, the regulator found that some continue to focus on reporting activity rather than evidencing outcomes. The review emphasises the importance of defining what good customer outcomes look like, monitoring outcomes across customer journeys, assessing outcomes for vulnerable customers and demonstrating how governance processes lead to meaningful action and improved outcomes. #### Why does it matter? The FCA expects firms to move beyond collecting data and producing reports. Firms need to show how monitoring identifies potential harm, what actions have been taken in response and whether those actions have improved customer outcomes. As regulatory scrutiny of Consumer Duty continues, firms that cannot evidence this connection between insight, intervention and outcome may struggle to demonstrate the effectiveness of their Consumer Duty framework. #### Who is affected? 1. Wealth and asset managers 2. Banks and building societies 3. Insurers 4. Consumer finance firms 5. Mortgage and lending providers 6. Financial advisers and intermediaries 7. Board members and senior managers 8. Consumer Duty, compliance, risk and governance teams #### Key risks - Management information measures activity rather than customer outcomes. - Firms cannot clearly define what a good customer outcome looks like. - Customer journey monitoring fails to identify emerging risks and foreseeable harm. - Vulnerable customer outcomes are not adequately assessed or evidenced. - Governance forums review information but cannot demonstrate action or improvement. - Firms are unable to evidence the effectiveness of interventions during FCA scrutiny. #### Actions to take 1. Define clear and measurable customer outcome expectations across key customer journeys. 2. Review existing MI to ensure metrics are linked directly to customer outcomes. 3. Test whether monitoring identifies emerging customer risks and foreseeable harm. 4. Embed vulnerability monitoring throughout the customer journey. 5. Strengthen governance processes to evidence challenge, decision-making and intervention. 6. Establish clear evidence trails linking insights, actions and improved outcomes. #### Wider implications The FCA's findings signal a continued shift from framework implementation to evidencing effectiveness. Firms are increasingly expected to demonstrate not only that monitoring processes exist but that they deliver tangible benefits for customers. The review also reflects greater regulatory focus on vulnerability, customer journey analysis and governance accountability. Firms that can evidence outcomes effectively are likely to be better positioned for future Consumer Duty reviews and supervisory engagement. #### Recommendations TCC Group supports firms in assessing, challenging and enhancing their Consumer Duty frameworks to ensure outcomes monitoring goes beyond reporting and delivers meaningful evidence of good customer outcomes.   Our experts are supporting firms with:  - independent reviews  - outcomes testing  - file assessments  - governance assurance  - customer journey analysis  - identifying potential gaps in compliance frameworks  - building stronger evidence for FCA scrutiny  - assessing how AI and technology can strengthen outcomes monitoring and emerging risk identification  #### Supporting sources - [Outcomes monitoring: good practice and areas for improvement](https://www.fca.org.uk/publications/good-and-poor-practice/outcomes-monitoring-good-practice-and-areas-improvement) #### Can you confidently evidence that your outcomes monitoring framework improves customer outcomes? TCC Group helps firms assess, challenge and strengthen their Consumer Duty frameworks by moving outcomes monitoring beyond reporting and towards evidencing real customer impact. [Talk to us](https://tcc.group/talk-to-us/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/insights/analysis-perspectives/why-firms-need-to-prove-customer-outcomes-not-just-report-them/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Insights", "item": "https://tcc.group/insights/" }, { "@type": "ListItem", "position": 3, "name": "Why firms need to prove customer outcomes not just report them", "item": "https://tcc.group/insights/analysis-perspectives/why-firms-need-to-prove-customer-outcomes-not-just-report-them/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/analysis-perspectives/why-firms-need-to-prove-customer-outcomes-not-just-report-them/#webpage", "url": "https://tcc.group/insights/analysis-perspectives/why-firms-need-to-prove-customer-outcomes-not-just-report-them/", "name": "Why firms need to prove customer outcomes not just report them", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-09-02T14:56:18+01:00", "dateModified": "2026-09-02T15:45:24+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/analysis-perspectives/why-firms-need-to-prove-customer-outcomes-not-just-report-them/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "Article", "@id": "https://tcc.group/insights/analysis-perspectives/why-firms-need-to-prove-customer-outcomes-not-just-report-them/#article", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/why-firms-need-to-prove-customer-outcomes-not-just-report-them/#webpage" }, "author": { "@type": "Person", "name": "May York" }, "headline": "Why firms need to prove customer outcomes not just report them", "datePublished": "2026-09-02T14:56:18+01:00", "dateModified": "2026-09-02T15:45:24+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/analysis-perspectives/why-firms-need-to-prove-customer-outcomes-not-just-report-them/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/b2e7baa9de544b63ae33cf931f671392/thumbnail-1024-ccfe2abda7c9af1f51b871990f13cfc448c39e1dce9168896ec92a7c7b28c114.jpg", "description": "The FCA\u2019s latest review of outcomes monitoring reinforces that Consumer Duty compliance is about more than producing management information (MI). Firms must be able to demonstrate how they identify customer\u2026", "inLanguage": "en-GB", "articleBody": "The FCA\u2019s latest review of outcomes monitoring reinforces that Consumer Duty compliance is about more than producing management information (MI). Firms must be able to demonstrate how they identify customer risks, act on those risks and evidence whether interventions have led to better customer outcomes.\n\nThe FCA published findings from its review of firms\u2019 outcomes monitoring arrangements, highlighting examples of good practice and areas for improvement. While many firms have invested significantly in Consumer Duty frameworks, dashboards and MI, the regulator found that some continue to focus on reporting activity rather than evidencing outcomes.\r\n\r\nThe review emphasises the importance of defining what good customer outcomes look like, monitoring outcomes across customer journeys, assessing outcomes for vulnerable customers and demonstrating how governance processes lead to meaningful action and improved outcomes.\n\nThe FCA expects firms to move beyond collecting data and producing reports. Firms need to show how monitoring identifies potential harm, what actions have been taken in response and whether those actions have improved customer outcomes.\r\n\r\nAs regulatory scrutiny of Consumer Duty continues, firms that cannot evidence this connection between insight, intervention and outcome may struggle to demonstrate the effectiveness of their Consumer Duty framework.\n\n1. Wealth and asset managers\n2. Banks and building societies\n3. Insurers\n4. Consumer finance firms\n5. Mortgage and lending providers\n6. Financial advisers and intermediaries\n7. Board members and senior managers\n8. Consumer Duty, compliance, risk and governance teams\n\n\u2022 Management information measures activity rather than customer outcomes.\n\u2022 Firms cannot clearly define what a good customer outcome looks like.\n\u2022 Customer journey monitoring fails to identify emerging risks and foreseeable harm.\n\u2022 Vulnerable customer outcomes are not adequately assessed or evidenced.\n\u2022 Governance forums review information but cannot demonstrate action or improvement.\n\u2022 Firms are unable to evidence the effectiveness of interventions during FCA scrutiny.\n\n1. Define clear and measurable customer outcome expectations across key customer journeys.\n2. Review existing MI to ensure metrics are linked directly to customer outcomes.\n3. Test whether monitoring identifies emerging customer risks and foreseeable harm.\n4. Embed vulnerability monitoring throughout the customer journey.\n5. Strengthen governance processes to evidence challenge, decision-making and intervention.\n6. Establish clear evidence trails linking insights, actions and improved outcomes.\n\nThe FCA's findings signal a continued shift from framework implementation to evidencing effectiveness. Firms are increasingly expected to demonstrate not only that monitoring processes exist but that they deliver tangible benefits for customers.\r\n\r\nThe review also reflects greater regulatory focus on vulnerability, customer journey analysis and governance accountability. 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Firms should be able to explain how monitoring identifies customer risks, what actions have been taken in response and whether those actions have improved customer outcomes." } }, { "@type": "Question", "name": "Why are customer journeys important for outcomes monitoring?", "acceptedAnswer": { "@type": "Answer", "text": "Monitoring outcomes across customer journeys helps firms identify where customers may experience friction, confusion, delays or potential harm. This provides a more complete view of customer outcomes than relying solely on high-level performance metrics." } }, { "@type": "Question", "name": "How should firms assess outcomes for vulnerable customers?", "acceptedAnswer": { "@type": "Answer", "text": "Firms should be able to demonstrate whether customers in vulnerable circumstances experience different outcomes to the wider customer base. Where differences exist, firms should understand the causes, assess potential harm and implement appropriate improvements." } }, { "@type": "Question", "name": "What are boards and senior leaders expected to demonstrate?", "acceptedAnswer": { "@type": "Answer", "text": "Boards and senior leaders should be able to show that governance challenge leads to action and that actions are monitored through to improved customer outcomes. Oversight alone is unlikely to be sufficient." } } ] } ] } ``` ### Mills Review signals the future direction of AI governance in financial services - URL: https://tcc.group/insights/analysis-perspectives/mills-review-signals-the-future-direction-of-ai-governance-in-financial-services/ - Published: 2026-09-02 - Modified: 2026-09-02 **Topic:** Mills Review signals the future direction of AI governance in financial services Recently featured in European Business Magazine, TCC Group CEO Joe Norburn explores why the FCA's Mills Review deserves close attention from financial services firms as AI becomes increasingly embedded in customer journeys, decision-making and operational processes. #### What happened? The Mills Review examined the opportunities and risks associated with the increasing adoption of artificial intelligence across the UK economy. While aimed at supporting innovation and growth, the review also emphasises the importance of governance, transparency and accountability to ensure AI is deployed responsibly. For financial services firms, it provides a valuable indication of the regulatory and supervisory themes that may shape future expectations. #### Why does it matter? As AI becomes more deeply integrated into products, services and operational processes, firms will need to demonstrate that they have appropriate governance frameworks, clear ownership and effective oversight in place. The direction of travel outlined by the Mills Review suggests that regulators and stakeholders will expect organisations to be able to evidence how AI-related risks are identified, managed and monitored. Firms that strengthen their governance approach now will be better positioned to balance innovation with regulatory expectations as the AI landscape continues to evolve. As Joe Norburn notes “Boards now need a practical account of where AI affects decisions, who carries responsibility and how the firm knows customers are being treated fairly.”   #### Are your AI governance arrangements ready for increased regulatory scrutiny? TCC helps firms assess governance frameworks, strengthen oversight and establish clear accountability for AI-enabled processes, ensuring they are prepared for evolving regulatory expectations. 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"https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/850a38bca29241b5b2211081c2d2a9ab/thumbnail-1024-1628bd78a486817d3f431726738acd0c5357f233f2c1ed63f5c7024777845158.jpg", "description": "Recently featured in European Business Magazine, TCC Group CEO Joe Norburn explores why the FCA's Mills Review deserves close attention from financial services firms as AI becomes increasingly embedded in\u2026", "inLanguage": "en-GB", "articleBody": "Recently featured in European Business Magazine, TCC Group CEO Joe Norburn explores why the FCA's Mills Review deserves close attention from financial services firms as AI becomes increasingly embedded in customer journeys, decision-making and operational processes.\n\nThe Mills Review examined the opportunities and risks associated with the increasing adoption of artificial intelligence across the UK economy. While aimed at supporting innovation and growth, the review also emphasises the importance of governance, transparency and accountability to ensure AI is deployed responsibly. For financial services firms, it provides a valuable indication of the regulatory and supervisory themes that may shape future expectations.\n\nAs AI becomes more deeply integrated into products, services and operational processes, firms will need to demonstrate that they have appropriate governance frameworks, clear ownership and effective oversight in place. The direction of travel outlined by the Mills Review suggests that regulators and stakeholders will expect organisations to be able to evidence how AI-related risks are identified, managed and monitored. Firms that strengthen their governance approach now will be better positioned to balance innovation with regulatory expectations as the AI landscape continues to evolve.\n\nAs Joe Norburn notes \u201cBoards now need a practical account of where AI affects decisions, who carries responsibility and how the firm knows customers are being treated fairly.\u201d\u00a0\u00a0", "wordCount": 212, "keywords": [ "Compliance AI & RegTech", "Consumer Duty", "Regulatory Change & Transformation", "Banking", "Payments & FinTech", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Consumer Duty", "url": "https://tcc.group/blog/solution/consumer-duty/" }, { "@type": "Thing", "name": "Regulatory Change & Transformation", "url": "https://tcc.group/blog/solution/regulatory-change-transformation/" }, { "@type": "Thing", "name": "Banking", "url": "https://tcc.group/blog/sector/banking/" }, { "@type": "Thing", "name": "Payments & FinTech", "url": "https://tcc.group/blog/sector/payments-fintech/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Mills Review signals the future direction of AI governance in financial services" } ], "articleSection": [ "Compliance AI & RegTech", "Consumer Duty", "Regulatory Change & Transformation" ], "audience": [ { "@type": "Audience", "audienceType": "Banking" }, { "@type": "Audience", "audienceType": "Payments & FinTech" }, { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/analysis-perspectives/mills-review-signals-the-future-direction-of-ai-governance-in-financial-services/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/mills-review-signals-the-future-direction-of-ai-governance-in-financial-services/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What is the Mills Review?", "acceptedAnswer": { "@type": "Answer", "text": "The Mills Review examines the opportunities and risks associated with artificial intelligence and outlines recommendations to support innovation while ensuring appropriate governance and oversight. It provides an indication of how expectations around AI accountability, transparency and risk management may evolve in the future." } }, { "@type": "Question", "name": "Why should financial services firms pay attention to the Mills Review?", "acceptedAnswer": { "@type": "Answer", "text": "As AI becomes increasingly embedded in customer journeys, decision-making and operational processes, firms are likely to face greater scrutiny around how AI is governed and controlled. The review highlights the importance of robust oversight, clear accountability and effective risk management, all of which align with existing regulatory priorities in financial services." } }, { "@type": "Question", "name": "What can firms do now to prepare?", "acceptedAnswer": { "@type": "Answer", "text": "Firms can begin by reviewing their AI governance arrangements, identifying accountability for AI-related decisions and ensuring appropriate controls are in place to manage risks. Strengthening oversight and maintaining clear evidence of how AI is monitored and governed will help firms remain prepared as expectations continue to develop." } } ] } ] } ``` ### Insurance Edge: Consumer Duty three years on - URL: https://tcc.group/insights/analysis-perspectives/insurance-edge-consumer-duty-three-years-on/ - Published: 2026-08-05 - Modified: 2026-09-02 **Topic:** Consumer Duty Three Years On TCC Group CEO Joe Norburn comments in Insurance Edge on the progress of the Consumer Duty, highlighting transparency and fair value, while addressing remaining gaps. #### What happened? Three years after its introduction, industry experts in [Insurance Edge](https://insurance-edge.net/2026/02/06/pure-protection-in-focus-fca-market-study-raises-regulatory-expectations-for-2026/) reviewed the impact of the FCA's Consumer Duty. TCC Group CEO Joe Norburn highlighted significant progress in transparency, fair value assessments, and vulnerable customer treatment, with customer outcomes now firmly embedded in strategic planning. However, substantial variation remains; while leaders use data and behavioural insights to prevent customer harm, laggards still treat the Duty primarily as a documentation exercise. #### Why does it matter? The FCA is increasing its oversight, as evidenced by a rise in Consumer Duty investigations and whistleblowing reports. Proactive general insurance firms must move beyond static compliance frameworks to continuously test and evidence that customer outcomes are consistently positive throughout the product life cycle. #### Supporting sources - [Insurance Edge: Consumer Duty three years on](https://insurance-edge.net/2026/02/06/pure-protection-in-focus-fca-market-study-raises-regulatory-expectations-for-2026/) (2026-08-06) - Reviewed by: [Joe Norburn](https://tcc.group/meet-the-team/), CEO - TCC Group #### Are you demonstrating real Consumer Duty outcomes? Speak to our insurance compliance team today to help you review your fair value assessments, customer data analytics, and risk frameworks. [Get in touch](https://tcc.group/talk-to-us/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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customer outcomes.", "inLanguage": "en-GB", "articleBody": "TCC Group CEO Joe Norburn comments in Insurance Edge on the progress of the Consumer Duty, highlighting transparency and fair value, while addressing remaining gaps.\n\nThree years after its introduction, industry experts in Insurance Edge reviewed the impact of the FCA's Consumer Duty. 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The Financial Conduct Authority (FCA) has urged pension providers to review legacy unit-linked non-workplace pensions and savings products. The regulator's review indicated that consumers holding these older, closed products frequently receive poorer value than those invested in modern alternatives. Key issues highlighted include complex fee structures, outdated product designs, and poor quality or incomplete data, which directly hinder firms' ability to assess and guarantee fair value. #### Why does it matter? The findings carry significant weight under the Consumer Duty, which mandates that all products—including closed books—must consistently deliver good outcomes. When product data is weak or incomplete, firms cannot reliably evidence that their historical charging models represent fair value today, leaving customers exposed to poor financial outcomes. Firms are expected to adopt good practice examples from the review, such as simplifying ranges, capping legacy fees, and proactively transferring clients to modern, high-value alternative products. #### Who is affected? Providers of unit-linked pensions, life insurance companies holding closed-book portfolios, trustees, and retirement wealth managers are affected. #### Key risks Firms ignoring legacy pension reviews face substantial compliance and commercial risks: - Severe regulatory penalties for breaches of the Consumer Duty price and value outcome. - Reputational damage and loss of client assets due to poor value disclosures and complex charges. - Operational bottlenecks in correcting incomplete or low-quality historical customer records. #### Actions to take Pension and wealth providers must take immediate corrective measures: 1. Conduct a rigorous price and value audit across all legacy and closed-book portfolios. 2. Implement data-remediation projects to address incomplete or poor-quality historical customer records. 3. Develop clear plans to simplify charging structures, cap fees, or transition savers to modern alternatives. #### Wider implications This review aligns with the FCA's broader modernising agenda for retirement savings, including pensions dashboards and targeted advice reforms, indicating that closed-book portfolios will remain under intense regulatory scrutiny indefinitely. #### Recommendations We recommend establishing an independent, data-driven fair value assessment framework and deploying specialist resources to execute legacy book simplification and data remediation. TCC’s experts help firms assess fair value, evidence customer outcomes and understand what the FCA’s findings may mean for legacy pension and savings products. We support firms in identifying where action may be needed across closed-book and legacy portfolios and in shaping practical responses aligned with Consumer Duty expectations.  #### Supporting sources - [FCA highlights value concerns in legacy pension products](https://www.fca.org.uk/news/press-releases/pension-firms-must-do-more-customers-older-pensions-fund-savings) (2026-07-27) #### Are your legacy pensions delivering fair value? Contact our pension and Consumer Duty advisory specialists today to audit your closed-book portfolios and ensure complete compliance. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/insights/regulatory-horizon/fca-highlights-value-concerns-in-legacy-pension-products/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Insights", "item": "https://tcc.group/insights/" }, { "@type": "ListItem", "position": 3, "name": "FCA highlights value concerns in legacy pension products", "item": "https://tcc.group/insights/regulatory-horizon/fca-highlights-value-concerns-in-legacy-pension-products/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/regulatory-horizon/fca-highlights-value-concerns-in-legacy-pension-products/#webpage", "url": "https://tcc.group/insights/regulatory-horizon/fca-highlights-value-concerns-in-legacy-pension-products/", "name": "FCA highlights value concerns in legacy pension products", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-07-27T00:00:00+01:00", "dateModified": "2026-09-02T15:51:23+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/regulatory-horizon/fca-highlights-value-concerns-in-legacy-pension-products/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "NewsArticle", "@id": "https://tcc.group/insights/regulatory-horizon/fca-highlights-value-concerns-in-legacy-pension-products/#article", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/fca-highlights-value-concerns-in-legacy-pension-products/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "FCA highlights value concerns in legacy pension products", "datePublished": "2026-07-27T00:00:00+01:00", "dateModified": "2026-09-02T15:51:23+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/regulatory-horizon/fca-highlights-value-concerns-in-legacy-pension-products/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/061271e5134b46ee90d4ec05cfd4c8cb/thumbnail-1024-8e82d3433db586027282f391aa461024ea0a34a87d69987d9ce46cc1c3283ee0.jpg", "description": "The FCA has urged pension providers to review legacy unit-linked products. Under the Consumer Duty, firms must address complex charging structures, poor data, and outdated designs to ensure fair value.", "inLanguage": "en-GB", "articleBody": "The FCA's review of legacy non-workplace pensions reveals that many older, closed products offer poor value due to complex charges and weak data, requiring urgent review under the Consumer Duty.\n\nThe Financial Conduct Authority (FCA) has urged pension providers to review legacy unit-linked non-workplace pensions and savings products. The regulator's review indicated that consumers holding these older, closed products frequently receive poorer value than those invested in modern alternatives.\r\n\r\nKey issues highlighted include complex fee structures, outdated product designs, and poor quality or incomplete data, which directly hinder firms' ability to assess and guarantee fair value.\n\nThe findings carry significant weight under the Consumer Duty, which mandates that all products\u2014including closed books\u2014must consistently deliver good outcomes. When product data is weak or incomplete, firms cannot reliably evidence that their historical charging models represent fair value today, leaving customers exposed to poor financial outcomes.\r\n\r\nFirms are expected to adopt good practice examples from the review, such as simplifying ranges, capping legacy fees, and proactively transferring clients to modern, high-value alternative products.\n\nProviders of unit-linked pensions, life insurance companies holding closed-book portfolios, trustees, and retirement wealth managers are affected.\n\nFirms ignoring legacy pension reviews face substantial compliance and commercial risks:\n\u2022 Severe regulatory penalties for breaches of the Consumer Duty price and value outcome.\n\u2022 Reputational damage and loss of client assets due to poor value disclosures and complex charges.\n\u2022 Operational bottlenecks in correcting incomplete or low-quality historical customer records.\n\nPension and wealth providers must take immediate corrective measures:\n1. Conduct a rigorous price and value audit across all legacy and closed-book portfolios.\n2. Implement data-remediation projects to address incomplete or poor-quality historical customer records.\n3. Develop clear plans to simplify charging structures, cap fees, or transition savers to modern alternatives.\n\nThis review aligns with the FCA's broader modernising agenda for retirement savings, including pensions dashboards and targeted advice reforms, indicating that closed-book portfolios will remain under intense regulatory scrutiny indefinitely.\n\nWe recommend establishing an independent, data-driven fair value assessment framework and deploying specialist resources to execute legacy book simplification and data remediation.\n\nTCC\u2019s\u00a0experts help\u00a0firms assess\u00a0fair\u00a0value, evidence customer outcomes and\u00a0understand what\u00a0the FCA\u2019s findings\u00a0may mean for\u00a0legacy pension and savings products.\u00a0We support firms in\u00a0identifying\u00a0where action may be needed across closed-book and legacy portfolios\u00a0and in shaping practical responses\u00a0aligned\u00a0with Consumer Duty expectations.\u00a0", "wordCount": 391, "keywords": [ "Consumer Duty", "Banking", "General Insurance & Protection", "Lending & Consumer Credit", "Motor Finance", "Payments & FinTech", "Pensions & Retirement Income", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Consumer Duty", "url": "https://tcc.group/blog/solution/consumer-duty/" }, { "@type": "Thing", "name": "Banking", "url": "https://tcc.group/blog/sector/banking/" }, { "@type": "Thing", "name": "General Insurance & Protection", "url": "https://tcc.group/blog/sector/general-insurance-protection/" }, { "@type": "Thing", "name": "Lending & Consumer Credit", "url": "https://tcc.group/blog/sector/lending-consumer-credit/" }, { "@type": "Thing", "name": "Motor Finance", "url": "https://tcc.group/blog/sector/motor-finance/" }, { "@type": "Thing", "name": "Payments & FinTech", "url": "https://tcc.group/blog/sector/payments-fintech/" }, { "@type": "Thing", "name": "Pensions & Retirement Income", "url": "https://tcc.group/blog/sector/pensions-retirement-income/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Legacy Pension Value" } ], "articleSection": [ "Consumer Duty" ], "audience": [ { "@type": "Audience", "audienceType": "Banking" }, { "@type": "Audience", "audienceType": "General Insurance & Protection" }, { "@type": "Audience", "audienceType": "Lending & Consumer Credit" }, { "@type": "Audience", "audienceType": "Motor Finance" }, { "@type": "Audience", "audienceType": "Payments & FinTech" }, { "@type": "Audience", "audienceType": "Pensions & Retirement Income" }, { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Pension providers, trustees, wealth managers, and life insurance compliance directors holding legacy or closed books." } ], "citation": [ { "@type": "CreativeWork", "name": "FCA highlights value concerns in legacy pension products", "url": "https://www.fca.org.uk/news/press-releases/pension-firms-must-do-more-customers-older-pensions-fund-savings", "datePublished": "2026-07-27" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/regulatory-horizon/fca-highlights-value-concerns-in-legacy-pension-products/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/fca-highlights-value-concerns-in-legacy-pension-products/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What did the FCA review of legacy pension products find?", "acceptedAnswer": { "@type": "Answer", "text": "The review found that older, closed unit-linked pensions often deliver poorer value than modern equivalents, driven by complex fees, legacy designs, and incomplete firm data." } }, { "@type": "Question", "name": "What actions can firms take to improve legacy pension value?", "acceptedAnswer": { "@type": "Answer", "text": "Firms can simplify product ranges, cap or reduce charges, audit historical data, and transfer customers to newer, better-value products." } } ] } ] } ``` ### BNPL regulation has arrived: the compliance challenge now is proving good customer outcomes - URL: https://tcc.group/insights/regulatory-horizon/bnpl-regulation-has-arrived-the-compliance-challenge-now-is-proving-good-customer-outcomes/ - Published: 2026-07-15 - Modified: 2026-09-02 **Topic:** Buy Now Pay Later regulation The FCA's Consumer Duty and new affordability rules now apply in full to Buy Now Pay Later providers, and the regulator's focus is shifting from implementation to evidencing good customer outcomes in practice. #### What happened? Buy Now Pay Later (BNPL) has moved fully within the[FCA's regulatory perimeter](https://www.fca.org.uk/news/press-releases/new-protections-confirmed-buy-now-pay-later-borrowers), bringing affordability assessments, disclosure requirements and Consumer Duty obligations into scope from day one. Firms are no longer judged on policy documents and governance frameworks alone. They are expected to show, through ongoing monitoring of customer behaviour, complaints, arrears and vulnerability indicators, that controls are delivering good outcomes in practice. The reforms are the result of several years of consultation and follow earlier FCA announcements on tighter rules for BNPL lending and the timetable for bringing the sector under regulation. #### Why does it matter? BNPL has grown quickly through simple, integrated digital journeys, and the FCA is clear that convenience must not come at the expense of customer understanding or informed borrowing decisions. As with other newly regulated markets, supervisory attention is expected to move from rule implementation towards close assessment of outcomes, meaning firms that cannot evidence their decision-making and governance oversight are exposed to regulatory challenge. Boards and senior management will increasingly need meaningful management information, not just operational metrics, to demonstrate that affordability, vulnerability and complaints controls are working as intended. #### Who is affected? BNPL providers and the lenders, retailers and payment businesses that offer point-of-sale credit across consumer lending, payments and motor finance are directly affected. The requirements also touch firms in wealth management, pensions, banking and insurance where BNPL-style products or embedded credit journeys sit alongside other lending or protection offerings. #### Key risks - Relying on governance documentation rather than evidence that controls deliver good customer outcomes. - Digital journeys that prioritise convenience over customer understanding at the point of borrowing. - Affordability assessments that are not proportionate or do not adapt as customer behaviour changes. - Vulnerability frameworks that are not tailored or accessible enough once financial difficulty emerges. - Management information that tracks operational activity but does not evidence outcomes or harm. #### Actions to take 1. Review and test customer journeys to confirm consumers receive the right information before completing a transaction. 2. Assess Consumer Duty compliance against actual customer outcomes rather than policy intent. 3. Strengthen affordability and vulnerability frameworks so they remain effective as customer behaviour evolves. 4. Develop management information and board reporting that covers understanding, affordability outcomes and complaints. 5. Commission independent assurance and gap assessments ahead of supervisory engagement. #### Wider implications The BNPL reforms sit within a broader regulatory pattern of extending consumer protection, transparency and accountability into markets that grew up outside full regulation. Firms that treat authorisation as the end point, rather than the start of ongoing outcomes testing, risk falling behind supervisory expectations as the FCA's focus matures. #### Recommendations Firms should prioritise evidence over documentation: testing journeys, affordability decisions and vulnerability support against real customer outcomes rather than assuming policies are sufficient. Independent assurance and gap analysis can help identify where controls look sound on paper but do not yet produce the management information boards need to respond to FCA enquiries with confidence. TCC supports firms across consumer credit, conduct risk and Consumer Duty implementation, helping organisations:  - Review and test customer journeys  - Assess Consumer Duty compliance and outcomes  - Strengthen affordability and vulnerability frameworks  - Develop meaningful MI and board reporting  - Conduct independent assurance and gap assessments  - Prepare for FCA supervisory engagement  As the FCA continues to place greater emphasis on outcomes, evidence and effective oversight, firms are expected to demonstrate that they have controls in place, and that those controls work as intended in practice. That is where TCC’s independent challenge and assurance can add real value.  #### Supporting sources - [BNPL regulation has arrived: the compliance challenge now is proving good customer outcomes](https://www.fca.org.uk/news/press-releases/new-protections-confirmed-buy-now-pay-later-borrowers) (2026-07-16) #### Need help evidencing BNPL customer outcomes? TCC supports consumer credit and BNPL providers with Consumer Duty assurance, affordability and vulnerability reviews, and board-ready management information. [Get in touch](https://tcc.group/talk-to-us/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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"https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/4ff31333d6c04de19b9a04de7b868ea5/thumbnail-1024-220909b1248265941e976d3e7b18c935cd9c012b7f846996c764a8f6c5713b0d.jpg", "description": "BNPL is now fully regulated, but authorisation is only the start: firms must evidence affordability, vulnerability support and customer understanding to show the Consumer Duty is delivering good outcomes in practice, not just on paper.", "inLanguage": "en-GB", "articleBody": "The FCA's Consumer Duty and new affordability rules now apply in full to Buy Now Pay Later providers, and the regulator's focus is shifting from implementation to evidencing good customer outcomes in practice.\n\nBuy Now Pay Later (BNPL) has moved fully within theFCA's regulatory perimeter, bringing affordability assessments, disclosure requirements and Consumer Duty obligations into scope from day one.\n\nFirms are no longer judged on policy documents and governance frameworks alone. They are expected to show, through ongoing monitoring of customer behaviour, complaints, arrears and vulnerability indicators, that controls are delivering good outcomes in practice.\n\nThe reforms are the result of several years of consultation and follow earlier FCA announcements on tighter rules for BNPL lending and the timetable for bringing the sector under regulation.\n\nBNPL has grown quickly through simple, integrated digital journeys, and the FCA is clear that convenience must not come at the expense of customer understanding or informed borrowing decisions.\r\n\r\nAs with other newly regulated markets, supervisory attention is expected to move from rule implementation towards close assessment of outcomes, meaning firms that cannot evidence their decision-making and governance oversight are exposed to regulatory challenge.\r\n\r\nBoards and senior management will increasingly need meaningful management information, not just operational metrics, to demonstrate that affordability, vulnerability and complaints controls are working as intended.\n\nBNPL providers and the lenders, retailers and payment businesses that offer point-of-sale credit across consumer lending, payments and motor finance are directly affected.\r\n\r\nThe requirements also touch firms in wealth management, pensions, banking and insurance where BNPL-style products or embedded credit journeys sit alongside other lending or protection offerings.\n\n\u2022 Relying on governance documentation rather than evidence that controls deliver good customer outcomes.\n\u2022 Digital journeys that prioritise convenience over customer understanding at the point of borrowing.\n\u2022 Affordability assessments that are not proportionate or do not adapt as customer behaviour changes.\n\u2022 Vulnerability frameworks that are not tailored or accessible enough once financial difficulty emerges.\n\u2022 Management information that tracks operational activity but does not evidence outcomes or harm.\n\n1. Review and test customer journeys to confirm consumers receive the right information before completing a transaction.\n2. Assess Consumer Duty compliance against actual customer outcomes rather than policy intent.\n3. Strengthen affordability and vulnerability frameworks so they remain effective as customer behaviour evolves.\n4. Develop management information and board reporting that covers understanding, affordability outcomes and complaints.\n5. Commission independent assurance and gap assessments ahead of supervisory engagement.\n\nThe BNPL reforms sit within a broader regulatory pattern of extending consumer protection, transparency and accountability into markets that grew up outside full regulation.\r\n\r\nFirms that treat authorisation as the end point, rather than the start of ongoing outcomes testing, risk falling behind supervisory expectations as the FCA's focus matures.\n\nFirms should prioritise evidence over documentation: testing journeys, affordability decisions and vulnerability support against real customer outcomes rather than assuming policies are sufficient.\n\nIndependent assurance and gap analysis can help identify where controls look sound on paper but do not yet produce the management information boards need to respond to FCA enquiries with confidence.\n\nTCC supports firms across consumer credit, conduct risk and Consumer Duty implementation, helping\u00a0organisations:\u00a0\n\u2022 Review and test customer journeys\u00a0\n\n\u2022 Assess Consumer Duty compliance and outcomes\u00a0\n\n\u2022 Strengthen affordability and vulnerability frameworks\u00a0\n\n\u2022 Develop meaningful MI and board reporting\u00a0\n\n\u2022 Conduct independent assurance and gap assessments\u00a0\n\n\u2022 Prepare for FCA supervisory engagement\u00a0\n\nAs the FCA continues to place greater emphasis on outcomes, evidence and effective oversight, firms\u00a0are expected\u00a0to\u00a0demonstrate\u00a0that\u00a0they have controls in place, and\u00a0that those controls work\u00a0as intended\u00a0in practice. That is where\u00a0TCC\u2019s\u00a0independent challenge and assurance can add real value.\u00a0", "wordCount": 607, "keywords": [ "Complaints & Claims Handling", "Consumer Duty", "Regulatory Change & Transformation", "Vulnerable Customers", "Banking", "General Insurance & Protection", "Lending & Consumer Credit", "Motor Finance", "Payments & FinTech", "Pensions & Retirement Income", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Complaints & Claims Handling", "url": "https://tcc.group/blog/solution/complaints-claims-handling/" }, { "@type": "Thing", "name": "Consumer Duty", "url": "https://tcc.group/blog/solution/consumer-duty/" }, { "@type": "Thing", "name": "Regulatory Change & Transformation", "url": "https://tcc.group/blog/solution/regulatory-change-transformation/" }, { "@type": "Thing", "name": "Vulnerable Customers", "url": "https://tcc.group/blog/solution/vulnerable-customers/" }, { "@type": "Thing", "name": "Banking", "url": "https://tcc.group/blog/sector/banking/" }, { "@type": "Thing", "name": "General Insurance & Protection", "url": "https://tcc.group/blog/sector/general-insurance-protection/" }, { "@type": "Thing", "name": "Lending & Consumer Credit", "url": "https://tcc.group/blog/sector/lending-consumer-credit/" }, { "@type": "Thing", "name": "Motor Finance", "url": "https://tcc.group/blog/sector/motor-finance/" }, { "@type": "Thing", "name": "Payments & FinTech", "url": "https://tcc.group/blog/sector/payments-fintech/" }, { "@type": "Thing", "name": "Pensions & Retirement Income", "url": "https://tcc.group/blog/sector/pensions-retirement-income/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Buy Now Pay Later regulation" } ], "articleSection": [ "Complaints & Claims Handling", "Consumer Duty", "Regulatory Change & Transformation", "Vulnerable Customers" ], "audience": [ { "@type": "Audience", "audienceType": "Banking" }, { "@type": "Audience", "audienceType": "General Insurance & Protection" }, { "@type": "Audience", "audienceType": "Lending & Consumer Credit" }, { "@type": "Audience", "audienceType": "Motor Finance" }, { "@type": "Audience", "audienceType": "Payments & FinTech" }, { "@type": "Audience", "audienceType": "Pensions & Retirement Income" }, { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Compliance, risk and product teams at BNPL providers and lenders offering point-of-sale credit." } ], "citation": [ { "@type": "CreativeWork", "name": "BNPL regulation has arrived: the compliance challenge now is proving good customer outcomes", "url": "https://www.fca.org.uk/news/press-releases/new-protections-confirmed-buy-now-pay-later-borrowers", "datePublished": "2026-07-16" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/regulatory-horizon/bnpl-regulation-has-arrived-the-compliance-challenge-now-is-proving-good-customer-outcomes/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/bnpl-regulation-has-arrived-the-compliance-challenge-now-is-proving-good-customer-outcomes/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "Does the Consumer Duty apply to BNPL providers immediately?", "acceptedAnswer": { "@type": "Answer", "text": "Yes, the Consumer Duty applies to BNPL providers from day one of the new regulatory regime, so firms must be able to evidence good customer outcomes rather than relying on policy documents alone." } }, { "@type": "Question", "name": "What should firms prioritise first?", "acceptedAnswer": { "@type": "Answer", "text": "Firms should focus on testing customer journeys, affordability assessments and vulnerable customer support, since these are the areas where the FCA expects to see clear evidence of good outcomes." } }, { "@type": "Question", "name": "How is FCA scrutiny expected to change?", "acceptedAnswer": { "@type": "Answer", "text": "The FCA's focus is expected to shift from rule implementation to supervisory assessment, so firms should be ready to evidence their decision-making and governance oversight." } }, { "@type": "Question", "name": "What kind of management information is expected?", "acceptedAnswer": { "@type": "Answer", "text": "Boards need management information that goes beyond operational metrics to show customer understanding, affordability outcomes, complaints and any indicators of potential harm." } } ] } ] } ``` ### How foreseeable harm is changing under Consumer Duty - URL: https://tcc.group/insights/analysis-perspectives/money-marketing-how-foreseeable-harm-is-changing-under-consumer-duty/ - Published: 2026-07-13 - Modified: 2026-09-02 Consumer Duty is shifting the focus from reacting to harm to anticipating it. As customer circumstances change, firms should continuously assess whether products remain suitable, deliver fair value and achieve good customer outcomes. #### What happened? Featured [Money Marketing](https://www.moneymarketing.co.uk/opinion/joe-norburn-preventing-foreseeable-harm-in-an-evolving-consumer-duty-landscape/), Joe Norburn, CEO of TCC Group, explored how the FCA's latest guidance on supporting customers through challenging times reinforces the principle of preventing foreseeable harm under Consumer Duty. The article highlights that firms should look beyond conventional measures of customer detriment and consider emerging behavioural indicators, such as customers delaying financial decisions, reducing cover or disengaging from communications. The article also examines how fair value assessments need to evolve over time. A product that delivered fair outcomes when it was launched may no longer meet customers' needs if their financial circumstances have changed, even where the product itself has not. #### Why does it matter? The FCA's direction of travel suggests that firms must take a more proactive and dynamic approach to Consumer Duty. Rather than waiting for evidence of harm to emerge, organisations are expected to monitor customer outcomes continuously and respond to changing risks as market and economic conditions evolve. Firms that regularly review suitability, fair value and customer outcomes, while acting on early warning signs of potential harm, will be better positioned to demonstrate Consumer Duty compliance and deliver good outcomes for customers. This reflects a broader shift in regulatory expectations: preventing foreseeable harm is no longer just about addressing known issues, but about identifying and mitigating emerging risks before customers are adversely affected. #### Supporting sources - [Money Marketing: How foreseeable harm is changing under Consumer Duty](https://www.moneymarketing.co.uk/opinion/joe-norburn-preventing-foreseeable-harm-in-an-evolving-consumer-duty-landscape/) - Reviewed by: [Joe Norburn](https://tcc.group/meet-the-team/), CEO - TCC Group #### Turn Consumer Duty insight into proactive action TCC helps firms assess customer outcomes, strengthen monitoring frameworks and evidence compliance through a proactive approach to Consumer Duty. [Get in touch](https://tcc.group/talk-to-us/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/insights/analysis-perspectives/money-marketing-how-foreseeable-harm-is-changing-under-consumer-duty/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Insights", "item": "https://tcc.group/insights/" }, { "@type": "ListItem", "position": 3, "name": "How foreseeable harm is changing under Consumer Duty", "item": "https://tcc.group/insights/analysis-perspectives/money-marketing-how-foreseeable-harm-is-changing-under-consumer-duty/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/analysis-perspectives/money-marketing-how-foreseeable-harm-is-changing-under-consumer-duty/#webpage", "url": "https://tcc.group/insights/analysis-perspectives/money-marketing-how-foreseeable-harm-is-changing-under-consumer-duty/", "name": "How foreseeable harm is changing under Consumer Duty", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-07-14T00:00:00+01:00", "dateModified": "2026-09-02T16:07:47+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/analysis-perspectives/money-marketing-how-foreseeable-harm-is-changing-under-consumer-duty/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "Article", "@id": "https://tcc.group/insights/analysis-perspectives/money-marketing-how-foreseeable-harm-is-changing-under-consumer-duty/#article", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/money-marketing-how-foreseeable-harm-is-changing-under-consumer-duty/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "How foreseeable harm is changing under Consumer Duty", "datePublished": "2026-07-14T00:00:00+01:00", "dateModified": "2026-09-02T16:07:47+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/analysis-perspectives/money-marketing-how-foreseeable-harm-is-changing-under-consumer-duty/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/a887adee3d794a1f97b1c323700407a5/thumbnail-1024-2bd49154f057e1e6f0e14cd14a5c006da24f12b364b9d9db62bafa60c9d2704d.jpg", "description": "Consumer Duty is shifting the focus from reacting to harm to anticipating it. Firms are increasingly expected to identify signs of potential customer harm before they appear through traditional indicators\u2026", "inLanguage": "en-GB", "articleBody": "Consumer Duty is shifting the focus from reacting to harm to anticipating it. As customer circumstances change, firms should continuously assess whether products remain suitable, deliver fair value and achieve good customer outcomes.\n\nFeatured Money Marketing, Joe Norburn, CEO of TCC Group, explored how the FCA's latest guidance on supporting customers through challenging times reinforces the principle of preventing foreseeable harm under Consumer Duty. The article highlights that firms should look beyond conventional measures of customer detriment and consider emerging behavioural indicators, such as customers delaying financial decisions, reducing cover or disengaging from communications.\n\nThe article also examines how fair value assessments need to evolve over time. 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On 7 July 2026, the FCA announced that [nine of the UK's largest banks and building societies had committed to improving how they offer basic bank accounts](https://www.fca.org.uk/news/press-releases/banks-told-improve-access-basic-accounts), following a mystery shopping exercise. Basic bank accounts are designed to give people without access to standard current accounts essential banking services, without fees or overdraft facilities. Across 298 mystery shopping interactions, around a third were rated poor or very poor. Customers who may have benefited from a basic bank account were not always told the product existed, and some vulnerable customers were directed towards online application journeys unsuited to their circumstances. The FCA identified particular challenges for customers experiencing financial hardship, those without standard forms of identification, and individuals with no fixed address. #### Why does it matter? The review shows that although basic bank accounts exist, the customers they are intended for may not always be able to complete a successful journey to access them. Under the Consumer Duty, this matters because good outcomes depend on whether products, communications, processes and people work together in practice, not simply on whether a suitable product is available. Just days before the announcement, the FCA also proposed reforms to simplify investment disclosures, noting that only 6% of the investment disclosure documents it reviewed for readability were written in plain English. Both findings reflect the FCA's growing focus on what customers actually experience, rather than what firms intend them to experience. #### Who is affected? Banks and building societies offering basic bank accounts are directly affected, particularly those serving customers experiencing financial hardship, previous bankruptcy, or difficulties providing standard identification. The lessons extend more broadly to any firm whose products depend on a customer completing an onboarding or application journey, especially where vulnerability characteristics may affect a customer's ability to do so. #### Key risks - Customers who could benefit from a basic bank account not being told the product exists. - Vulnerable customers being directed towards online-only application journeys unsuited to their circumstances. - Frontline staff not recognising when a customer could benefit from a basic bank account, causing the journey to break down at the first interaction. - Assuming that a compliant product, governance framework and communications are sufficient without testing the actual customer journey. #### Actions to take 1. Test customer journeys directly, using mystery shopping, customer testing or outcome monitoring, rather than assuming intended outcomes are being delivered. 2. Review onboarding routes for customers with no fixed address, limited identification, or financial hardship, and offer alternative routes where needed. 3. Ensure frontline staff understand which products exist, who they are designed for, and when to raise them with customers. 4. Confirm ownership and accountability for monitoring and improving customer access and support outcomes. #### Wider implications The review reinforces that good customer outcomes are rarely determined by products alone; they are shaped by the quality of the journeys surrounding them, the effectiveness of communications, and staff capability to recognise and respond to customer needs. This lesson extends beyond basic bank accounts and beyond banking: a product can be suitable, communications technically compliant and governance robust, yet customers can still experience poor outcomes if they encounter friction during the journey itself. #### Recommendations Firms should look beyond individual products and consider the entire end-to-end customer journey, testing it from the customer's perspective rather than relying solely on governance reviews. Vulnerability frameworks should be assessed not only on whether they identify vulnerable characteristics, but on whether the process remains accessible once those characteristics are present. At TCC, we help firms deliver effective compliance that connects regulatory expectations, operational reality and customer outcomes.   #### Supporting sources - [Customer journeys and vulnerability lessons from the FCA's basic bank account review](https://www.fca.org.uk/news/press-releases/banks-told-improve-access-basic-accounts) (2026-07-14) - [Financial regulator to simplify investment disclosure regime](https://www.fca.org.uk/news/press-releases/financial-regulator-simplify-investment-disclosure-regime) #### Reviewing your customer journeys for vulnerability? TCC can help you test and strengthen customer journeys so vulnerable customers can access the products and support they need. [Get in touch](https://tcc.group/talk-to-us/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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Under the Consumer Duty, this matters because good outcomes depend on whether products, communications, processes and people work together in practice, not simply on whether a suitable product is available.\r\n\r\nJust days before the announcement, the FCA also proposed reforms to simplify investment disclosures, noting that only 6% of the investment disclosure documents it reviewed for readability were written in plain English. Both findings reflect the FCA's growing focus on what customers actually experience, rather than what firms intend them to experience.\n\nBanks and building societies offering basic bank accounts are directly affected, particularly those serving customers experiencing financial hardship, previous bankruptcy, or difficulties providing standard identification.\r\n\r\nThe lessons extend more broadly to any firm whose products depend on a customer completing an onboarding or application journey, especially where vulnerability characteristics may affect a customer's ability to do so.\n\n\u2022 Customers who could benefit from a basic bank account not being told the product exists.\n\u2022 Vulnerable customers being directed towards online-only application journeys unsuited to their circumstances.\n\u2022 Frontline staff not recognising when a customer could benefit from a basic bank account, causing the journey to break down at the first interaction.\n\u2022 Assuming that a compliant product, governance framework and communications are sufficient without testing the actual customer journey.\n\n1. 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characteristics are present.\n\nAt TCC, we\u00a0help firms deliver\u00a0effective compliance\u00a0that\u00a0connects regulatory expectations, operational\u00a0reality\u00a0and customer outcomes.\u00a0\u00a0", "wordCount": 612, "keywords": [ "Complaints & Claims Handling", "Consumer Duty", "Regulatory Change & Transformation", "Suitability, Advice Quality & File Reviews", "Vulnerable Customers", "Banking", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Complaints & Claims Handling", "url": "https://tcc.group/blog/solution/complaints-claims-handling/" }, { "@type": "Thing", "name": "Consumer Duty", "url": "https://tcc.group/blog/solution/consumer-duty/" }, { "@type": "Thing", "name": "Regulatory Change & Transformation", "url": "https://tcc.group/blog/solution/regulatory-change-transformation/" }, { "@type": "Thing", "name": "Suitability, Advice Quality & File Reviews", "url": "https://tcc.group/blog/solution/outsourced-suitability-reviews/" }, { 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governance in financial services - URL: https://tcc.group/insights/regulatory-horizon/how-the-mills-review-could-reshape-ai-governance-in-financial-services/ - Published: 2026-07-09 - Modified: 2026-09-02 **Topic:** AI Governance and Compliance The FCA's final findings of the Mills Review detail how the shift from AI assistance to AI delegation will impact accountability and governance in financial services by 2030. #### What happened? The Financial Conduct Authority (FCA) has published the final findings of the [Mills Review](https://www.fca.org.uk/publication/corporate/the-mills-review.pdf), assessing how advances in artificial intelligence (AI) could reshape financial services by 2030 and beyond. Commissioned by the FCA Board, the review draws on 140 written submissions and consumer research involving over 5,000 UK adults. The review concludes that the industry is moving from a world where AI primarily supports human decision-making to one where it increasingly influences, recommends, and carries out actions autonomously on behalf of businesses and consumers. #### Why does it matter? This represents a critical shift from AI assistance to AI delegation. As firms move from using AI as a simple productivity tool to delegating complex tasks (such as automated rate switching or vulnerability assessments), the traditional lines of accountability under the Senior Managers Regime (SMR) and Consumer Duty will be tested. Continuous monitoring and testing of model drift are vital. A model that performs accurately during testing may behave differently months later when customer behaviour, data inputs, or market conditions change, potentially producing unfair outcomes for different customer groups. #### Who is affected? This regulatory focus directly impacts all financial institutions utilizing AI technologies, particularly compliance, risk, and IT teams responsible for managing automated decision systems, customer support channels, and claims-handling tools. #### Key risks - **Accountability Dilution:** Difficulty in tracing responsibility across complex AI supply chains and third-party models. - **Model Drift:** AI models producing unintended or unfair outcomes over time as real-world data and conditions deviate from testing baselines. - **Deepfake and Fraud Threats:** Growing exposure to AI-enabled fraud, synthetic identities, and sophisticated social engineering attacks. #### Actions to take 1. **Map AI Supply Chains:** Establish clear ownership and documentation of all third-party models and data integrations. 2. **Implement Model Drift Monitoring:** Conduct continuous testing and outcome-based audits on active AI models to ensure fair customer treatment. 3. **Align with SMR and Consumer Duty:** Integrate AI decision-making parameters within existing governance and senior management accountability frameworks. #### Wider implications The FCA is actively preparing for an AI-driven system by developing its own AI-enabled 'Agentic Supervisory Model'. This will allow the regulator to identify cross-firm trends and emerging harms across the entire financial ecosystem using automated supervision. #### Recommendations Firms should not wait for fully autonomous AI systems to emerge. Compliance and risk teams must proactively assess their current AI governance, ensuring human oversight is meaningful rather than just a rubber-stamping exercise. At TCC, we work with firms to navigate regulatory change, strengthen governance frameworks and ensure evolving technologies are implemented in ways that support both regulatory compliance and customer trust. Through our technology partner [Recordsure](https://recordsure.com/?__hstc=221717383.3ebb4e3154d32affa47b54a834fab91d.1777456804712.1788340461297.1788345560172.139&__hssc=221717383.3.1788345560172&__hsfp=48d636dcf1ef4da6ae60e3f39141de7c), firms can also access AI-powered tools that help monitor customer interactions, oversee evidence, identify risks, and support better outcomes at scale. Whether reviewing AI governance, assessing Consumer Duty implications or building robust oversight frameworks, we can help firms prepare for an increasingly AI-enabled financial system with confidence.  #### Supporting sources - [The Mills Review could reshape AI governance in financial services](https://www.fca.org.uk/publication/corporate/the-mills-review.pdf) (2026-07-06) #### Is your AI governance ready for regulatory scrutiny? Speak to our RegTech and compliance specialists today to review your AI frameworks, risk controls, and Consumer Duty alignment. [Talk to our experts](https://tcc.group/talk-to-us/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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"https://tcc.group/insights/regulatory-horizon/how-the-mills-review-could-reshape-ai-governance-in-financial-services/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/regulatory-horizon/how-the-mills-review-could-reshape-ai-governance-in-financial-services/#webpage", "url": "https://tcc.group/insights/regulatory-horizon/how-the-mills-review-could-reshape-ai-governance-in-financial-services/", "name": "The Mills Review could reshape AI governance in financial services", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-07-10T00:00:00+01:00", "dateModified": "2026-09-02T16:10:48+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/regulatory-horizon/how-the-mills-review-could-reshape-ai-governance-in-financial-services/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "AnalysisNewsArticle", "@id": 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intelligence could reshape compliance, governance, and accountability frameworks in financial services as AI moves from assistance to delegation.", "inLanguage": "en-GB", "articleBody": "The FCA's final findings of the Mills Review detail how the shift from AI assistance to AI delegation will impact accountability and governance in financial services by 2030.\n\nThe Financial Conduct Authority (FCA) has published the final findings of the Mills Review, assessing how advances in artificial intelligence (AI) could reshape financial services by 2030 and beyond. Commissioned by the FCA Board, the review draws on 140 written submissions and consumer research involving over 5,000 UK adults.\n\nThe review concludes that the industry is moving from a world where AI primarily supports human decision-making to one where it increasingly influences, recommends, and carries out actions autonomously on behalf of businesses and consumers.\n\nThis represents a critical shift from AI assistance to AI delegation. As firms move from using AI as a simple productivity tool to delegating complex tasks (such as automated rate switching or vulnerability assessments), the traditional lines of accountability under the Senior Managers Regime (SMR) and Consumer Duty will be tested.\r\n\r\nContinuous monitoring and testing of model drift are vital. A model that performs accurately during testing may behave differently months later when customer behaviour, data inputs, or market conditions change, potentially producing unfair outcomes for different customer groups.\n\nThis regulatory focus directly impacts all financial institutions utilizing AI technologies, particularly compliance, risk, and IT teams responsible for managing automated decision systems, customer support channels, and claims-handling tools.\n\n\u2022 Accountability Dilution: Difficulty in tracing responsibility across complex AI supply chains and third-party models.\n\u2022 Model Drift: AI models producing unintended or unfair outcomes over time as real-world data and conditions deviate from testing baselines.\n\u2022 Deepfake and Fraud Threats: Growing exposure to AI-enabled fraud, synthetic identities, and sophisticated social engineering attacks.\n\n1. Map AI Supply Chains: Establish clear ownership and documentation of all third-party models and data integrations.\n2. Implement Model Drift Monitoring: Conduct continuous testing and outcome-based audits on active AI models to ensure fair customer treatment.\n3. Align with SMR and Consumer Duty: Integrate AI decision-making parameters within existing governance and senior management accountability frameworks.\n\nThe FCA is actively preparing for an AI-driven system by developing its own AI-enabled 'Agentic Supervisory Model'. This will allow the regulator to identify cross-firm trends and emerging harms across the entire financial ecosystem using automated supervision.\n\nFirms should not wait for fully autonomous AI systems to emerge. 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On 2nd July 2026, the Financial Conduct Authority partially suspended its proposed [motor finance compensation scheme](https://www.fca.org.uk/news/statements/motor-finance-scheme-partially-suspended). This suspension followed an Upper Tribunal decision while legal challenges brought by four commercial parties (Consumer Voice, Volkswagen Financial Services, Mercedes Benz Financial Services, and Crédit Agricole Auto Finance) are heard. The legal challenges are scheduled for consideration by the Upper Tribunal in either December 2026 or February 2027, depending on whether the parties apply for further disclosure or expert opinions. #### Why does it matter? While motor finance firms are temporarily excused from calculating or paying compensation and issuing formal scheme communications, this is not a complete pause on activity. The FCA continues to support the scheme as its preferred redress route. It is defending its position robustly to avoid duplication of effort if the challenge fails. Firms are expected to use this suspension window to address information gaps, organize historical data, and plan for potential contingencies, including handling complaints under standard rules if the scheme is quashed. #### Who is affected? This suspension directly impacts motor finance lenders, dealership brokers, compliance managers, and legal representatives handling historic commission agreements. #### Key risks - **Complacency:** Treating the legal suspension as a complete pause on compliance preparation, leading to severe resource bottlenecks later. - **Poor Customer Communication:** Failing to keep complainants updated on the suspension's meaning and the impact on handling timelines. - **Lack of Operational Flexibility:** Underinvesting in standard complaint-handling processes in case the compensation scheme is discarded. #### Actions to take 1. **Continue Data Gathering:** Keep identifying relevant complaints, compiling commission arrangements, and resolving historical data gaps. 2. **Update Complainants:** Actively communicate with customers regarding the suspension, legal timelines, and complaint-handling impacts. 3. **Plan Contingencies:** Establish operational procedures to handle historic commissions under standard FOS and internal dispute rules if required. 4. **Cooperate with FOS:** Maintain active communication and data-sharing protocols for complaints that have already been escalated to the Ombudsman. #### Wider implications This legal challenge underscores the high stakes of motor finance remediation. Regulatory and legal uncertainty requires firms to maintain a flexible, dual-pathway approach to complaints management. #### Recommendations 1. **The compensation scheme remains the FCA’s preferred route** Despite the legal challenge, the FCA continues to back the compensation scheme as the quickest way to deliver redress. The suspension is designed to avoid duplicated work while allowing firms to continue preparing. 2. **Preparation continues to matter** Firms should keep identifying affected complaints and agreements, gathering information on commission arrangements, and addressing data gaps. Understanding historic lending practices and customer populations remains important regardless of the outcome. 3. **Keeping customers informed remains important** Lenders must continue updating complainants on the suspension, the legal challenge timetable, and potential impacts on complaint and compensation timelines. Customers who are not eligible for compensation should also be informed. 4. **Flexibility is as important as preparedness** While preparing for the scheme, firms should also plan for the possibility that it may be amended or overturned. Maintaining flexibility will help firms respond effectively once the legal process concludes. TCC Group (incorporating [Momenta](https://momentagroup.com/?__hstc=221717383.3ebb4e3154d32affa47b54a834fab91d.1777456804712.1788340461297.1788345560172.139&__hssc=221717383.5.1788345560172&__hsfp=48d636dcf1ef4da6ae60e3f39141de7c)) supports financial services firms with complaint handling, customer remediation, redress preparedness and specialist resource solutions. As the motor finance landscape continues to evolve, an independent view of operational readiness can help firms understand their current position, assess potential delivery challenges and prepare for the next phase of activity.  #### Supporting sources - [FCA partially suspends motor finance scheme: four key takeaways](https://www.fca.org.uk/news/statements/motor-finance-scheme-partially-suspended) (2026-07-03) #### Need support with motor finance redress preparation? Utilize the suspension period to strengthen your data, train team resources, and secure operational readiness with our remediation specialists. [Get in touch](https://tcc.group/talk-to-us/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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Discover four essential takeaways on complaint identification, client comms, and contingency planning.", "inLanguage": "en-GB", "articleBody": "The FCA's motor finance compensation scheme has been partially suspended following an Upper Tribunal ruling, but the regulator expects firms to continue preparation and complaint gathering.\n\nOn 2nd July 2026, the Financial Conduct Authority partially suspended its proposed motor finance compensation scheme. This suspension followed an Upper Tribunal decision while legal challenges brought by four commercial parties (Consumer Voice, Volkswagen Financial Services, Mercedes Benz Financial Services, and Cr\u00e9dit Agricole Auto Finance) are heard.\n\nThe legal challenges are scheduled for consideration by the Upper Tribunal in either December 2026 or February 2027, depending on whether the parties apply for further disclosure or expert opinions.\n\nWhile motor finance firms are temporarily excused from calculating or paying compensation and issuing formal scheme communications, this is not a complete pause on activity. The FCA continues to support the scheme as its preferred redress route. It is defending its position robustly to avoid duplication of effort if the challenge fails.\r\n\r\nFirms are expected to use this suspension window to address information gaps, organize historical data, and plan for potential contingencies, including handling complaints under standard rules if the scheme is quashed.\n\nThis suspension directly impacts motor finance lenders, dealership brokers, compliance managers, and legal representatives handling historic commission agreements.\n\n\u2022 Complacency: Treating the legal suspension as a complete pause on compliance preparation, leading to severe resource bottlenecks later.\n\u2022 Poor Customer Communication: Failing to keep complainants updated on the suspension's meaning and the impact on handling timelines.\n\u2022 Lack of Operational Flexibility: Underinvesting in standard complaint-handling processes in case the compensation scheme is discarded.\n\n1. Continue Data Gathering: Keep identifying relevant complaints, compiling commission arrangements, and resolving historical data gaps.\n2. Update Complainants: Actively communicate with customers regarding the suspension, legal timelines, and complaint-handling impacts.\n3. Plan Contingencies: Establish operational procedures to handle historic commissions under standard FOS and internal dispute rules if required.\n4. Cooperate with FOS: Maintain active communication and data-sharing protocols for complaints that have already been escalated to the Ombudsman.\n\nThis legal challenge underscores the high stakes of motor finance remediation. Regulatory and legal uncertainty requires firms to maintain a flexible, dual-pathway approach to complaints management.\n\n1. The compensation scheme remains the FCA\u2019s preferred route\nDespite the legal challenge, the FCA continues to back the compensation scheme as the quickest way to deliver redress. The suspension is designed to avoid duplicated work while allowing firms to continue preparing.\n2. Preparation continues to matter\nFirms should keep identifying affected complaints and agreements, gathering information on commission arrangements, and addressing data gaps. Understanding historic lending practices and customer populations remains important regardless of the outcome.\n3. Keeping customers informed remains important\nLenders must continue updating complainants on the suspension, the legal challenge timetable, and potential impacts on complaint and compensation timelines. Customers who are not eligible for compensation should also be informed.\n4. Flexibility is as important as preparedness\nWhile preparing for the scheme, firms should also plan for the possibility that it may be amended or overturned. Maintaining flexibility will help firms respond effectively once the legal process concludes.\n\nTCC\u00a0Group (incorporating\u00a0Momenta)\u00a0supports financial services firms with complaint handling, customer remediation, redress\u00a0preparedness\u00a0and specialist resource solutions. As the motor finance landscape continues to evolve, an independent view of operational readiness can help firms understand their current position, assess potential delivery\u00a0challenges\u00a0and prepare for the next phase of activity.\u00a0", "wordCount": 559, "keywords": [ "Complaints & Claims Handling", "Compliance AI & RegTech", "Redress & Remediation", "Regulatory Change & Transformation", "Lending & Consumer Credit", "Motor Finance" ], "about": [ { "@type": "Thing", "name": "Complaints & Claims Handling", "url": "https://tcc.group/blog/solution/complaints-claims-handling/" }, { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Redress & Remediation", "url": "https://tcc.group/blog/solution/redress-and-remediation/" }, { "@type": "Thing", "name": "Regulatory Change & Transformation", "url": "https://tcc.group/blog/solution/regulatory-change-transformation/" }, { "@type": "Thing", "name": "Lending & Consumer Credit", "url": "https://tcc.group/blog/sector/lending-consumer-credit/" }, { "@type": "Thing", "name": "Motor Finance", "url": "https://tcc.group/blog/sector/motor-finance/" }, { "@type": "Thing", "name": "Motor Finance Scheme" } ], "articleSection": [ "Complaints & Claims Handling", "Compliance AI & RegTech", "Redress & Remediation", "Regulatory Change & Transformation" ], "audience": [ { "@type": "Audience", "audienceType": "Lending & Consumer Credit" }, { "@type": "Audience", "audienceType": "Motor Finance" }, { "@type": "Audience", "audienceType": "Lenders, brokers, and compliance specialists in the motor finance sector." } ], "citation": [ { "@type": "CreativeWork", "name": "FCA partially suspends motor finance scheme: four key takeaways", "url": "https://www.fca.org.uk/news/statements/motor-finance-scheme-partially-suspended", "datePublished": "2026-07-03" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/regulatory-horizon/four-key-takeaways-following-the-fcas-partial-suspension-of-proposed-motor-finance-scheme/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/four-key-takeaways-following-the-fcas-partial-suspension-of-proposed-motor-finance-scheme/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What is the reason behind the partial suspension?", "acceptedAnswer": { "@type": "Answer", "text": "The scheme is suspended following an Upper Tribunal decision, allowing legal challenges from four commercial lenders and Consumer Voice to be heard first." } }, { "@type": "Question", "name": "Are motor finance firms required to pay compensation now?", "acceptedAnswer": { "@type": "Answer", "text": "No. Lenders are not currently required to calculate or pay compensation under the scheme timetable while the Upper Tribunal reviews the case." } }, { "@type": "Question", "name": "When will the legal challenge be decided?", "acceptedAnswer": { "@type": "Answer", "text": "The Upper Tribunal is scheduled to hear the challenges in either mid-December 2026 or late February 2027." } } ] } ] } ``` ### FPS: Fragmented Financial Crime Oversight is Creating New Risks - URL: https://tcc.group/insights/analysis-perspectives/fps-fragmented-financial-crime-oversight-is-creating-new-risks-for-firms/ - Published: 2026-07-01 - Modified: 2026-09-02 **Topic:** Financial Crime Oversight TCC Group's Joe Norburn warns that fragmented compliance operating models are creating inconsistent controls and regulatory vulnerabilities in financial crime prevention. #### What happened? In an article published for the [Fraud Prevention Summit](https://fpsummit.co.uk/briefing/why-fragmented-financial-crime-oversight-is-creating-new-risks-for-firms/) (FPS), TCC Group CEO Joe Norburn addresses a growing operational challenge: fragmentation in financial crime oversight. Traditional siloed operating models, where fraud, anti-money laundering (AML), scams, and crypto risk are managed by separate teams and systems, are failing to keep pace with interconnected modern threats. This fragmented approach leads to inconsistent controls, communication gaps, and limited executive visibility over emerging financial crime risks across the enterprise. #### Why does it matter? As threats converge, the FCA is placing greater emphasis on collective coordination and systemic resilience. Without an integrated, enterprise-wide approach to financial crime, firms risk missing critical threat signals, delaying incident responses, and failing to satisfy regulatory expectations. Firms must move beyond compliance silos, treating financial crime not merely as an isolated cost function, but as a system-wide discipline that dictates long-term organizational trust, security, and market competitiveness. #### Who is affected? This media commentary is highly relevant for money laundering reporting officers, compliance leaders, and risk management directors at financial services firms. #### Supporting sources - [FPS: Fragmented financial crime oversight is creating new risks](https://fpsummit.co.uk/briefing/why-fragmented-financial-crime-oversight-is-creating-new-risks-for-firms/) (2026-07-02) - Reviewed by: [Joe Norburn](https://tcc.group/meet-the-team/), CEO - TCC Group #### Are your financial crime controls fragmented? Bridge communication gaps, unify your compliance systems, and build an integrated financial crime defense with our expert advisory team. [Get in touch](https://tcc.group/talk-to-us/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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"@id": "https://tcc.group/insights/analysis-perspectives/fps-fragmented-financial-crime-oversight-is-creating-new-risks-for-firms/#article", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/fps-fragmented-financial-crime-oversight-is-creating-new-risks-for-firms/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "FPS: Fragmented Financial Crime Oversight is Creating New Risks", "datePublished": "2026-07-02T00:00:00+01:00", "dateModified": "2026-09-02T16:16:02+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/analysis-perspectives/fps-fragmented-financial-crime-oversight-is-creating-new-risks-for-firms/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/4bac3dd2aebc4ddc84e10691fd058854/thumbnail-1024-be5f7302eb3e0ad2896718bb791623e86da9503520cf2cb32c2f39b84347c351.jpg", "description": "At the Fraud Prevention Summit, TCC Group CEO Joe Norburn highlights why fragmented financial crime oversight has become a material operational risk. Discover why an enterprise-wide approach is essential.", "inLanguage": "en-GB", "articleBody": "TCC Group's Joe Norburn warns that fragmented compliance operating models are creating inconsistent controls and regulatory vulnerabilities in financial crime prevention.\n\nIn an article published for the Fraud Prevention Summit (FPS), TCC Group CEO Joe Norburn addresses a growing operational challenge: fragmentation in financial crime oversight. Traditional siloed operating models, where fraud, anti-money laundering (AML), scams, and crypto risk are managed by separate teams and systems, are failing to keep pace with interconnected modern threats.\n\nThis fragmented approach leads to inconsistent controls, communication gaps, and limited executive visibility over emerging financial crime risks across the enterprise.\n\nAs threats converge, the FCA is placing greater emphasis on collective coordination and systemic resilience. 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The FCA continues to use the Consumer Duty as its principal lens for assessing whether financial services firms are delivering good outcomes across the customer lifecycle. Having spent considerable time building governance structures, oversight arrangements and reporting frameworks, firms are now expected to demonstrate that these arrangements are actually driving positive outcomes rather than simply existing on paper. Supervisory activity is examining whether products and services reflect clear customer needs, whether price and value are justified over time, whether communications support real customer understanding, and whether customers receive support without unnecessary friction. These four areas map directly to the Duty's outcomes framework. #### Why does it matter? The FCA has been explicit that Consumer Duty is designed to raise standards without adding prescriptive rules, which means firms must be able to demonstrate how their governance and decision-making support customer outcomes and can withstand scrutiny. Stable metrics or low complaint volumes are not, on their own, evidence that customers understand products, receive fair value or get appropriate support. The emphasis has shifted from what firms have built to how those arrangements perform, which means stronger management information, greater internal challenge and clearer accountability for outcomes are now the areas under the most scrutiny. #### Who is affected? The findings apply across retail financial services, including wealth management and financial advice, pensions and retirement income, payments and fintech, banking, consumer credit and lending, general insurance and protection, and motor finance. #### Key risks - Board reporting that describes structures but does not evidence outcomes - Reliance on incomplete or evolving data when boards are asked to exercise judgement - Weak data quality and limited challenge in existing monitoring arrangements - Insights identified through monitoring not translating into action #### Actions to take 1. Review whether current frameworks deliver measurable, evidenced customer outcomes 2. Reassess fair value and product governance approaches against recent FCA findings 3. Strengthen outcome monitoring and the management information that supports it 4. Produce board reports that focus on outcomes, use good-quality data and link findings to action 5. Review customer journeys and communications against FCA expectations #### Wider implications The FCA's review of Consumer Duty board reports found that stronger firms focus clearly on outcomes, use good-quality data, analyse different customer groups and link findings to actions and strategy. Areas for improvement identified by the regulator include data quality, board challenge and taking effective action based on insights. Consumer Duty is not a one-off implementation exercise. Firms are expected to continuously assess outcomes, challenge assumptions and adapt governance as products, customer needs and regulatory expectations evolve. #### Recommendations Firms should consider whether independent challenge, additional specialist resource or periodic assurance reviews would strengthen oversight and give greater confidence in the effectiveness of their Consumer Duty framework. Some firms are also exploring how technology can supplement traditional monitoring: TCC works with technology partner Recordsure to help firms analyse customer interactions at scale, identify emerging risks and build richer evidence for outcome monitoring and board reporting.   #### Supporting sources - [Consumer Duty: outcomes, oversight and governance](https://www.fca.org.uk/firms/consumer-duty) (2026-07-01) - [About Consumer Duty](https://www.fca.org.uk/firms/consumer-duty/about) #### Need help evidencing Consumer Duty outcomes? TCC provides practical support across Consumer Duty governance, fair value, board reporting, customer outcomes and regulatory assurance. [Get in touch](https://tcc.group/talk-to-us/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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outcomes, and what boards need to show about monitoring, challenge and action to withstand supervisory review.", "inLanguage": "en-GB", "articleBody": "Most firms now have Consumer Duty governance and reporting in place, but the FCA's focus has moved to whether those arrangements can be shown to deliver good customer outcomes in practice.\n\nThe FCA continues to use the Consumer Duty as its principal lens for assessing whether financial services firms are delivering good outcomes across the customer lifecycle. Having spent considerable time building governance structures, oversight arrangements and reporting frameworks, firms are now expected to demonstrate that these arrangements are actually driving positive outcomes rather than simply existing on paper.\r\n\r\nSupervisory activity is examining whether products and services reflect clear customer needs, whether price and value are justified over time, whether communications support real customer understanding, and whether customers receive support without unnecessary friction. These four areas map directly to the Duty's outcomes framework.\n\nThe FCA has been explicit that Consumer Duty is designed to raise standards without adding prescriptive rules, which means firms must be able to demonstrate how their governance and decision-making support customer outcomes and can withstand scrutiny. Stable metrics or low complaint volumes are not, on their own, evidence that customers understand products, receive fair value or get appropriate support.\r\n\r\nThe emphasis has shifted from what firms have built to how those arrangements perform, which means stronger management information, greater internal challenge and clearer accountability for outcomes are now the areas under the most scrutiny.\n\nThe findings apply across retail financial services, including wealth management and financial advice, pensions and retirement income, payments and fintech, banking, consumer credit and lending, general insurance and protection, and motor finance.\n\n\u2022 Board reporting that describes structures but does not evidence outcomes\n\u2022 Reliance on incomplete or evolving data when boards are asked to exercise judgement\n\u2022 Weak data quality and limited challenge in existing monitoring arrangements\n\u2022 Insights identified through monitoring not translating into action\n\n1. Review whether current frameworks deliver measurable, evidenced customer outcomes\n2. Reassess fair value and product governance approaches against recent FCA findings\n3. Strengthen outcome monitoring and the management information that supports it\n4. Produce board reports that focus on outcomes, use good-quality data and link findings to action\n5. Review customer journeys and communications against FCA expectations\n\nThe FCA's review of Consumer Duty board reports found that stronger firms focus clearly on outcomes, use good-quality data, analyse different customer groups and link findings to actions and strategy. Areas for improvement identified by the regulator include data quality, board challenge and taking effective action based on insights.\r\n\r\nConsumer Duty is not a one-off implementation exercise. Firms are expected to continuously assess outcomes, challenge assumptions and adapt governance as products, customer needs and regulatory expectations evolve.\n\nFirms should consider whether independent challenge, additional specialist resource or periodic assurance reviews would strengthen oversight and give greater confidence in the effectiveness of their Consumer Duty framework. 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The Financial Conduct Authority conducted a comprehensive [multi-firm review of insurers' financial crime controls](https://www.fca.org.uk/publications/multi-firm-reviews/insurance-financial-crime-controls-multi-firm-review#lf-chapter-id-what-we-found-cross-sector-findings), requiring a selection of large firms to submit detailed documentation across ten key risk areas. While basic frameworks are largely in place, the regulator concluded that these controls are not consistently embedded in daily insurance operations. Scrutiny is shifting from theoretical control design to actual operational effectiveness. Insurers must now prove that their frameworks actively mitigate risks across business units, product lines, and third-party relationships. #### Why does it matter? The financial crime risks facing retail insurers, wholesale intermediaries, and life insurers vary significantly. To withstand regulatory scrutiny, firms must provide tailored, documented evidence of their risk decisions. Proportional due diligence approaches must be guided by clear operational rationales and explicit escalation triggers. Furthermore, insurers cannot outsource their compliance obligations. Robust, active oversight of third-party distribution chains and claims management is an essential element of a firm's financial crime framework. #### Who is affected? This regulatory review directly impacts senior managers, money laundering reporting officers (MLROs), and risk leaders within the retail, wholesale, and life insurance sectors. #### Key risks - **Generic Risk Assessments:** Relying on high-level or standardized assessments that fail to connect to a firm's actual operating model. - **Undocumented Due Diligence:** Inability to justify why different levels of client or partner scrutiny are applied in various business scenarios. - **Weak Outsource Oversight:** Failing to actively monitor, manage, and escalate financial crime risks embedded within outsourced operations. #### Actions to take 1. **Ground Risk Assessments:** Review and update risk assessments to reflect specific product structures, payment flows, and operating models. 2. **Document Due Diligence:** Establish explicit, recorded rationales for customer risk ratings, escalation thresholds, and due diligence boundaries. 3. **Provide Practical Guidance:** Equip operational teams (underwriting, claims, and sales) with detailed, scenario-specific compliance guidance. 4. **Map Governance Controls:** Map financial crime obligations directly to specific controls, accountable owners, and comprehensive management information. #### Wider implications The FCA expects an integrated approach to financial crime compliance. Individual components, such as risk assessments, governance, and third-party oversight, must operate seamlessly as a single, defensible framework. #### Recommendations Insurers should conduct independent reviews of their existing financial crime controls to verify consistency and deploy specialist resource to close any operational gaps rapidly. TCC works with insurance firms to assess how financial crime controls operate across their full framework. We also support insurers through financial crime interim resourcing, providing external specialists who can embed within teams to strengthen controls, improve consistency and help evidence how frameworks operate. #### Supporting sources - [Five priorities for insurers following the FCA's financial crime review](https://www.fca.org.uk/publications/multi-firm-reviews/insurance-financial-crime-controls-multi-firm-review#lf-chapter-id-what-we-found-cross-sector-findings) (2026-06-26) #### Are your insurance financial crime controls robust? Audit your financial crime frameworks, align governance, and deploy specialist resource to secure compliant operations with our advisory experts. [Get in touch](https://tcc.group/talk-to-us/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/insights/regulatory-horizon/five-priorities-for-insurers-following-the-fcas-financial-crime-review/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Insights", "item": "https://tcc.group/insights/" }, { "@type": "ListItem", "position": 3, "name": "Five priorities for insurers following the FCA’s financial crime review", "item": "https://tcc.group/insights/regulatory-horizon/five-priorities-for-insurers-following-the-fcas-financial-crime-review/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/regulatory-horizon/five-priorities-for-insurers-following-the-fcas-financial-crime-review/#webpage", "url": "https://tcc.group/insights/regulatory-horizon/five-priorities-for-insurers-following-the-fcas-financial-crime-review/", "name": "Five priorities for insurers following the FCA’s financial crime review", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-06-26T00:00:00+01:00", "dateModified": "2026-09-02T16:18:54+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/regulatory-horizon/five-priorities-for-insurers-following-the-fcas-financial-crime-review/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "NewsArticle", "@id": "https://tcc.group/insights/regulatory-horizon/five-priorities-for-insurers-following-the-fcas-financial-crime-review/#article", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/five-priorities-for-insurers-following-the-fcas-financial-crime-review/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "Five priorities for insurers following the FCA’s financial crime review", "datePublished": "2026-06-26T00:00:00+01:00", "dateModified": "2026-09-02T16:18:54+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/regulatory-horizon/five-priorities-for-insurers-following-the-fcas-financial-crime-review/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/4a7c564baf1244449399c60f127e6345/thumbnail-1024-ea6f6dbec703b6687cd80ef2838a1d2079388ca7763ece4e986cc9de5413000e.jpg", "description": "The FCA's review of insurers' financial crime controls reveals critical gaps. Explore five strategic priorities to strengthen risk assessments, due diligence processes, and third-party oversight frameworks.", "inLanguage": "en-GB", "articleBody": "The FCA's multi-firm review of insurers highlights that financial crime frameworks are often established but not sufficiently tailored or embedded in daily operational practice.\n\nThe Financial Conduct Authority conducted a comprehensive multi-firm review of insurers' financial crime controls, requiring a selection of large firms to submit detailed documentation across ten key risk areas. While basic frameworks are largely in place, the regulator concluded that these controls are not consistently embedded in daily insurance operations.\n\nScrutiny is shifting from theoretical control design to actual operational effectiveness. Insurers must now prove that their frameworks actively mitigate risks across business units, product lines, and third-party relationships.\n\nThe financial crime risks facing retail insurers, wholesale intermediaries, and life insurers vary significantly. To withstand regulatory scrutiny, firms must provide tailored, documented evidence of their risk decisions. Proportional due diligence approaches must be guided by clear operational rationales and explicit escalation triggers.\r\n\r\nFurthermore, insurers cannot outsource their compliance obligations. Robust, active oversight of third-party distribution chains and claims management is an essential element of a firm's financial crime framework.\n\nThis regulatory review directly impacts senior managers, money laundering reporting officers (MLROs), and risk leaders within the retail, wholesale, and life insurance sectors.\n\n\u2022 Generic Risk Assessments: Relying on high-level or standardized assessments that fail to connect to a firm's actual operating model.\n\u2022 Undocumented Due Diligence: Inability to justify why different levels of client or partner scrutiny are applied in various business scenarios.\n\u2022 Weak Outsource Oversight: Failing to actively monitor, manage, and escalate financial crime risks embedded within outsourced operations.\n\n1. Ground Risk Assessments: Review and update risk assessments to reflect specific product structures, payment flows, and operating models.\n2. Document Due Diligence: Establish explicit, recorded rationales for customer risk ratings, escalation thresholds, and due diligence boundaries.\n3. Provide Practical Guidance: Equip operational teams (underwriting, claims, and sales) with detailed, scenario-specific compliance guidance.\n4. Map Governance Controls: Map financial crime obligations directly to specific controls, accountable owners, and comprehensive management information.\n\nThe FCA expects an integrated approach to financial crime compliance. Individual components, such as risk assessments, governance, and third-party oversight, must operate seamlessly as a single, defensible framework.\n\nInsurers should conduct independent reviews of their existing financial crime controls to verify consistency and deploy specialist resource to close any operational gaps rapidly.\n\nTCC works with insurance firms to assess how financial crime controls operate\u00a0across\u00a0their full framework.\u00a0We also support insurers\u00a0through financial crime interim resourcing, providing external\u00a0specialists who can embed within teams to strengthen controls, improve\u00a0consistency\u00a0and help evidence how frameworks\u00a0operate.", "wordCount": 422, "keywords": [ "Compliance AI & RegTech", "Financial Crime Compliance", "Regulatory Change & Transformation", "Banking", "General Insurance & Protection", "Payments & FinTech" ], "about": [ { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Financial Crime Compliance", "url": "https://tcc.group/blog/solution/financial-crime-compliance/" }, { "@type": "Thing", "name": "Regulatory Change & Transformation", "url": "https://tcc.group/blog/solution/regulatory-change-transformation/" }, { "@type": "Thing", "name": "Banking", "url": "https://tcc.group/blog/sector/banking/" }, { "@type": "Thing", "name": "General Insurance & Protection", "url": "https://tcc.group/blog/sector/general-insurance-protection/" }, { "@type": "Thing", "name": "Payments & FinTech", "url": "https://tcc.group/blog/sector/payments-fintech/" }, { "@type": "Thing", "name": "Financial Crime Controls" } ], "articleSection": [ "Compliance AI & RegTech", "Financial Crime Compliance", "Regulatory Change & Transformation" ], "audience": [ { "@type": "Audience", "audienceType": "Banking" }, { "@type": "Audience", "audienceType": "General Insurance & Protection" }, { "@type": "Audience", "audienceType": "Payments & FinTech" }, { "@type": "Audience", "audienceType": "Compliance officers, risk managers, and board members across retail, wholesale, and life insurance." } ], "citation": [ { "@type": "CreativeWork", "name": "Five priorities for insurers following the FCA's financial crime review", "url": "https://www.fca.org.uk/publications/multi-firm-reviews/insurance-financial-crime-controls-multi-firm-review#lf-chapter-id-what-we-found-cross-sector-findings", "datePublished": "2026-06-26" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/regulatory-horizon/five-priorities-for-insurers-following-the-fcas-financial-crime-review/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/five-priorities-for-insurers-following-the-fcas-financial-crime-review/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What is the key takeaway from the FCA's insurance review?", "acceptedAnswer": { "@type": "Answer", "text": "Frameworks are generally established but lack deep operational integration, meaning firms must now prove that their financial crime controls work in practice." } }, { "@type": "Question", "name": "How should insurers handle due diligence decisions?", "acceptedAnswer": { "@type": "Answer", "text": "Firms must define and document clear, defensible boundaries and rationales for why different levels of customer scrutiny are applied in different scenarios." } }, { "@type": "Question", "name": "Does outsourcing transfer financial crime responsibility?", "acceptedAnswer": { "@type": "Answer", "text": "No. Insurers remain fully accountable for their financial crime controls when outsourcing activities, making active third-party oversight and evidence critical." } } ] } ] } ``` ### Fragmented controls raise financial crime risk for firms - URL: https://tcc.group/insights/analysis-perspectives/business-accountancy-daily-fragmented-controls-raise-financial-crime-risk-for-firms/ - Published: 2026-06-24 - Modified: 2026-09-02 **Topic:** Financial crime controls TCC Group's CEO Joe Norburn explains why fragmented financial crime controls are becoming a system-wide risk, and why firms need enterprise-wide oversight rather than siloed processes. #### What happened? Speaking to [Business & Accountancy Daily](https://www.accountancydaily.co/fragmented-controls-raise-financial-crime-risk-firms), Joe Norburn, CEO at TCC Group, explains that financial crime is no longer a discrete compliance issue but a system-wide risk that shapes a firm's resilience and trust. He notes that as fraud, scams and money laundering become more interconnected, many firms are still responding through fragmented operating models, with responsibility split across separate teams, systems and data. #### Why does it matter? Joe highlights that this fragmentation is itself a risk, creating gaps in visibility, weakening controls and slowing firms' ability to respond to emerging threats. With the FCA emphasising collective defence, the Consumer Duty and outcome-focused regulation, firms are expected to move beyond siloed controls and demonstrate clear, enterprise-wide oversight of financial crime risk. “Financial crime is no longer just a function to manage, but a system-wide discipline that shapes resilience, trust and long-term competitiveness”. #### Supporting sources - [Fragmented controls raise financial crime risk for firms](https://www.accountancydaily.co/fragmented-controls-raise-financial-crime-risk-firms) (2026-06-25) - Reviewed by: Joe Norburn, CEO - TCC Group #### Want to strengthen financial crime oversight? TCC helps firms connect governance, technology and operations to build a clear, enterprise-wide understanding of financial crime risk. [Get in touch](https://tcc.group/talk-to-us/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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"description": "TCC Group's CEO explains why treating financial crime as a fragmented, siloed problem is now a resilience risk in itself, and why firms need connected governance, technology and operations instead.", "inLanguage": "en-GB", "articleBody": "TCC Group's CEO Joe Norburn explains why fragmented financial crime controls are becoming a system-wide risk, and why firms need enterprise-wide oversight rather than siloed processes.\n\nSpeaking to Business & Accountancy Daily, Joe Norburn, CEO at TCC Group, explains that financial crime is no longer a discrete compliance issue but a system-wide risk that shapes a firm's resilience and trust.\n\nHe notes that as fraud, scams and money laundering become more interconnected, many firms are still responding through fragmented operating models, with responsibility split across separate teams, systems and data.\n\nJoe highlights that this fragmentation is itself a risk, creating gaps in visibility, weakening controls and slowing firms' 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"https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Financial crime controls" } ], "articleSection": [ "Compliance AI & RegTech", "Financial Crime Compliance", "Regulatory Change & Transformation" ], "audience": [ { "@type": "Audience", "audienceType": "Banking" }, { "@type": "Audience", "audienceType": "General Insurance & Protection" }, { "@type": "Audience", "audienceType": "Lending & Consumer Credit" }, { "@type": "Audience", "audienceType": "Motor Finance" }, { "@type": "Audience", "audienceType": "Payments & FinTech" }, { "@type": "Audience", "audienceType": "Pensions & Retirement Income" }, { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Financial crime, risk and compliance leaders responsible for enterprise-wide oversight." } ], "citation": [ { "@type": "CreativeWork", "name": "Fragmented controls raise financial crime risk for firms", "url": "https://www.accountancydaily.co/fragmented-controls-raise-financial-crime-risk-firms", "datePublished": "2026-06-25" } ], "reviewedBy": { "@type": "Person", "name": "Joe Norburn", "jobTitle": "CEO - TCC Group" } }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/analysis-perspectives/business-accountancy-daily-fragmented-controls-raise-financial-crime-risk-for-firms/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/business-accountancy-daily-fragmented-controls-raise-financial-crime-risk-for-firms/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "Why does fragmentation increase financial crime risk?", "acceptedAnswer": { "@type": "Answer", "text": "Joe Norburn explains that fragmented operating models create gaps in visibility, weaken controls and slow firms' ability to respond, turning fragmentation itself into a risk." } }, { "@type": "Question", "name": "What does the FCA expect from firms?", "acceptedAnswer": { "@type": "Answer", "text": "With its focus on collective defence, the Consumer Duty and outcome-focused regulation, the FCA expects firms to move beyond siloed controls and demonstrate enterprise-wide oversight." } } ] } ] } ``` ### Rethinking financial crime controls in a system-wide risk environment - URL: https://tcc.group/insights/regulatory-horizon/rethinking-financial-crime-controls-in-a-system-wide-risk-environment/ - Published: 2026-06-18 - Modified: 2026-09-02 **Topic:** System-Wide Financial Crime Risk The FCA is raising expectations for financial crime controls, focusing on whether firms can evidence that they reduce real-world risk as fraud, money laundering, sanctions evasion and cyber-enabled crime become more interconnected. #### What happened? The FCA's recent speech on [working together against financial crime](https://www.fca.org.uk/news/speeches/working-together-against-financial-crime) calls for greater collaboration between firms, regulators and law enforcement. Taken in context, it points to a broader shift: financial crime can no longer be understood as something contained within a single firm, but as a system-level issue shaped by how risks move across firms, sectors and jurisdictions. The regulator highlights the increasingly organised, technologically enabled and cross-border nature of financial crime, where fraud, money laundering, sanctions evasion and cyber-enabled activity often form part of the same chain of events. #### Why does it matter? Suspicious activity rarely presents in neat categories. A fraud case may raise anti-money laundering concerns, while a cyber incident can expose weaknesses in due diligence or transaction monitoring. Many financial crime frameworks are still structured around separate risk types with different systems, processes and governance, which can create blind spots where no single view of risk exists. The FCA is also moving beyond checking whether appropriate policies and processes are in place, to asking whether those controls actually reduce financial crime risk in practice. A framework can be technically compliant and still fall short if it does not reflect how financial crime is occurring today. #### Who is affected? The message applies across banking, wealth management, payments, lending, general insurance and motor finance, and to any firm relying on financial crime frameworks built around separate risk categories rather than a connected view of risk. #### Key risks - Financial crime frameworks structured around separate risk types, with no single view of how risks connect. - Risk assessments that are static or refreshed only periodically, creating a disconnect between documented risk and reality. - Reliance on external intelligence and industry information-sharing that is not embedded in day-to-day monitoring and escalation decisions. - Controls that remain technically compliant on paper but have not been revisited in light of changing threats. #### Actions to take 1. Review financial crime risk assessments to ensure they reflect evolving threats and capture how different risk types connect. 2. Assess whether external intelligence and information-sharing initiatives are embedded in day-to-day monitoring, escalation and risk decisions. 3. Confirm that policies and controls remain effective against how financial crime is occurring today, not how it was previously understood. 4. Check that staff training reflects how different types of financial crime interact in practice. #### Wider implications The FCA's direction of travel suggests financial crime effectiveness will increasingly be judged at a system level, depending not only on what an individual firm does but on how well the wider ecosystem functions. Firms will need to show how they decide which risks matter most and how they direct resources accordingly, rather than simply demonstrating that a broad framework exists. #### Recommendations Firms should review their financial crime risk assessments and controls now, rather than waiting for a regulatory request, and should be able to evidence how they prioritise risks and adapt frameworks as threats evolve. Where internal teams are stretched or oversight gaps have emerged, specialist support can help stabilise and strengthen financial crime programmes through senior interim leadership, managed remediation, framework strengthening and technology-enabled workflows. TCC’s financial crime solutions help firms stabilise, scale and improve their financial crime programmes through senior interim leadership, managed remediation, framework strengthening and tech‑enabled workflows. Whether internal teams are stretched, backlogs are growing or oversight gaps need urgent attention, TCC can provide pre‑vetted interim professionals, trained analysts and experienced specialists to support effective, compliant delivery.  #### Supporting sources - [Rethinking financial crime controls in a system-wide risk environment](https://www.fca.org.uk/news/speeches/working-together-against-financial-crime) (2026-06-19) - [Why financial crime needs a team sport approach](https://europeanbusinessmagazine.com/financial-crime-no-longer-compliance) #### Need support with financial crime controls? Get in touch to find out how we can help you stabilise, scale and improve your financial crime programme. [Get in touch](https://tcc.group/talk-to-us/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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be judged on real-world effectiveness, not just documented policies. This explains what the shift means for firms across banking, wealth management, payments and lending.", "inLanguage": "en-GB", "articleBody": "The FCA is raising expectations for financial crime controls, focusing on whether firms can evidence that they reduce real-world risk as fraud, money laundering, sanctions evasion and cyber-enabled crime become more interconnected.\n\nThe FCA's recent speech on working together against financial crime calls for greater collaboration between firms, regulators and law enforcement. Taken in context, it points to a broader shift: financial crime can no longer be understood as something contained within a single firm, but as a system-level issue shaped by how risks move across firms, sectors and jurisdictions.\n\nThe regulator highlights the increasingly organised, technologically enabled and cross-border nature of financial crime, where fraud, money laundering, sanctions evasion and cyber-enabled activity often form part of the same chain of events.\n\nSuspicious activity rarely presents in neat categories. A fraud case may raise anti-money laundering concerns, while a cyber incident can expose weaknesses in due diligence or transaction monitoring. Many financial crime frameworks are still structured around separate risk types with different systems, processes and governance, which can create blind spots where no single view of risk exists.\r\n\r\nThe FCA is also moving beyond checking whether appropriate policies and processes are in place, to asking whether those controls actually reduce financial crime risk in practice. A framework can be technically compliant and still fall short if it does not reflect how financial crime is occurring today.\n\nThe message applies across banking, wealth management, payments, lending, general insurance and motor finance, and to any firm relying on financial crime frameworks built around separate risk categories rather than a connected view of risk.\n\n\u2022 Financial crime frameworks structured around separate risk types, with no single view of how risks connect.\n\u2022 Risk assessments that are static or refreshed only periodically, creating a disconnect between documented risk and reality.\n\u2022 Reliance on external intelligence and industry information-sharing that is not embedded in day-to-day monitoring and escalation decisions.\n\u2022 Controls that remain technically compliant on paper but have not been revisited in light of changing threats.\n\n1. Review financial crime risk assessments to ensure they reflect evolving threats and capture how different risk types connect.\n2. Assess whether external intelligence and information-sharing initiatives are embedded in day-to-day monitoring, escalation and risk decisions.\n3. Confirm that policies and controls remain effective against how financial crime is occurring today, not how it was previously understood.\n4. Check that staff training reflects how different types of financial crime interact in practice.\n\nThe FCA's direction of travel suggests financial crime effectiveness will increasingly be judged at a system level, depending not only on what an individual firm does but on how well the wider ecosystem functions.\r\n\r\nFirms will need to show how they decide which risks matter most and how they direct resources accordingly, rather than simply demonstrating that a broad framework exists.\n\nFirms should review their financial crime risk assessments and controls now, rather than waiting for a regulatory request, and should be able to evidence how they prioritise risks and adapt frameworks as threats evolve.\n\nWhere internal teams are stretched or oversight gaps have emerged, specialist support can help stabilise and strengthen financial crime programmes through senior interim leadership, managed remediation, framework strengthening and technology-enabled workflows.\n\nTCC\u2019s financial crime solutions\u00a0help firms stabilise, scale and improve their financial crime programmes through senior interim leadership, managed remediation, framework strengthening and\u00a0tech\u2011enabled\u00a0workflows. Whether internal teams are stretched, backlogs are growing or oversight gaps need urgent attention, TCC can provide\u00a0pre\u2011vetted\u00a0interim professionals, trained\u00a0analysts\u00a0and experienced specialists to support effective, compliant delivery.\u00a0", "wordCount": 586, "keywords": [ "Compliance AI & RegTech", "Financial Crime Compliance", "Regulatory Change & Transformation", "Banking", "General Insurance & Protection", "Lending & Consumer Credit", "Motor Finance", "Payments & FinTech", "Pensions & Retirement Income", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Financial Crime Compliance", "url": "https://tcc.group/blog/solution/financial-crime-compliance/" }, { "@type": "Thing", "name": "Regulatory Change & Transformation", "url": "https://tcc.group/blog/solution/regulatory-change-transformation/" }, { "@type": "Thing", "name": "Banking", "url": "https://tcc.group/blog/sector/banking/" }, { "@type": "Thing", "name": "General Insurance & Protection", "url": "https://tcc.group/blog/sector/general-insurance-protection/" }, { "@type": "Thing", "name": "Lending & Consumer Credit", "url": "https://tcc.group/blog/sector/lending-consumer-credit/" }, { "@type": "Thing", "name": "Motor Finance", "url": "https://tcc.group/blog/sector/motor-finance/" }, { "@type": "Thing", "name": "Payments & FinTech", "url": "https://tcc.group/blog/sector/payments-fintech/" }, { "@type": "Thing", "name": "Pensions & Retirement Income", "url": "https://tcc.group/blog/sector/pensions-retirement-income/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "System-Wide Financial Crime Risk" } ], "articleSection": [ "Compliance AI & RegTech", "Financial Crime Compliance", "Regulatory Change & Transformation" ], "audience": [ { "@type": "Audience", "audienceType": "Banking" }, { "@type": "Audience", "audienceType": "General Insurance & Protection" }, { "@type": "Audience", "audienceType": "Lending & Consumer Credit" }, { "@type": "Audience", "audienceType": "Motor Finance" }, { "@type": "Audience", "audienceType": "Payments & FinTech" }, { "@type": "Audience", "audienceType": "Pensions & Retirement Income" }, { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Compliance and financial crime teams across banking, wealth management, payments, lending, insurance and motor finance firms." } ], "citation": [ { "@type": "CreativeWork", "name": "Rethinking financial crime controls in a system-wide risk environment", "url": "https://www.fca.org.uk/news/speeches/working-together-against-financial-crime", "datePublished": "2026-06-19" }, { "@type": "CreativeWork", "name": "Why financial crime needs a team sport approach", "url": "https://europeanbusinessmagazine.com/financial-crime-no-longer-compliance" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/regulatory-horizon/rethinking-financial-crime-controls-in-a-system-wide-risk-environment/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/rethinking-financial-crime-controls-in-a-system-wide-risk-environment/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What is the FCA's key message on financial crime?", "acceptedAnswer": { "@type": "Answer", "text": "That financial crime is a system-level issue and firms need to show that their controls reduce real-world risk, not just that a framework exists." } }, { "@type": "Question", "name": "Why are firm-level controls no longer enough?", "acceptedAnswer": { "@type": "Answer", "text": "Because financial crime increasingly moves across firms, sectors and jurisdictions, so effectiveness depends on collaboration and information-sharing as well as internal controls." } }, { "@type": "Question", "name": "What should firms do about static risk assessments?", "acceptedAnswer": { "@type": "Answer", "text": "Move to a more dynamic approach that reflects evolving threats and captures how different risks connect, rather than relying on periodic reviews." } } ] } ] } ``` ### Financial crime needs a team approach - URL: https://tcc.group/insights/analysis-perspectives/european-business-magazine-financial-crime-needs-a-team-sport-approach/ - Published: 2026-06-16 - Modified: 2026-09-02 **Topic:** Financial Crime Compliance TCC Group CEO Joe Norburn warns that fragmented compliance operating models create critical control gaps, urging firms to connect governance, technology, and operations for a collective financial crime defence. #### What happened? TCC Group CEO Joe Norburn was featured in [European Business Magazine](https://europeanbusinessmagazine.com/financial-crime-no-longer-compliance), outlining how financial crime has evolved into a complex, system-wide risk rather than a siloed compliance issue. He noted that as fraud, scams, and money laundering become increasingly interconnected, many firms are still responding with fragmented operating models. #### Why does it matter? Operating in silos splits responsibility across different teams, databases, and compliance systems. This fragmentation is itself a critical risk, creating visibility gaps, weakening controls, and slowing down response times. With regulators placing greater emphasis on outcomes and collective defence, firms must demonstrate integrated, enterprise-wide oversight to protect consumers and meet standards. #### Supporting sources - [Financial crime needs a team approach](https://europeanbusinessmagazine.com/financial-crime-no-longer-compliance) (2026-06-17) - Reviewed by: [Joe Norburn](https://tcc.group/meet-the-team/), CEO - TCC Group #### Are fragmented systems leaving you exposed? Speak to our financial crime specialists to discover how we can help you integrate your governance, technology, and operations for a unified defence. 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sophisticated financial crime requires an integrated, enterprise-wide defense rather than fragmented, siloed operating models.", "inLanguage": "en-GB", "articleBody": "TCC Group CEO Joe Norburn warns that fragmented compliance operating models create critical control gaps, urging firms to connect governance, technology, and operations for a collective financial crime defence.\n\nTCC Group CEO Joe Norburn was featured in European Business Magazine, outlining how financial crime has evolved into a complex, system-wide risk rather than a siloed compliance issue. He noted that as fraud, scams, and money laundering become increasingly interconnected, many firms are still responding with fragmented operating models.\n\nOperating in silos splits responsibility across different teams, databases, and compliance systems. This fragmentation is itself a critical risk, creating visibility gaps, weakening controls, and slowing down response times. 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A recent episode of [Mailock's 'Beyond Encryption'](https://www.mailock.com/blog/ai-review-more-conversations) podcast highlighted a critical challenge for regulated firms: how to move beyond narrow file sampling to achieve a complete, defensible understanding of customer outcomes. Under the Consumer Duty, the FCA expects firms to not only monitor client interactions but to actively assess, test, understand, and evidence positive customer outcomes consistently and at scale. #### Why does it matter? Traditional compliance sampling, which reviews only a tiny fraction of calls or advice files, is no longer sufficient. Small samples surface isolated anecdotes but fail to detect systemic issues relating to disclosures, vulnerable clients, or poor customer understanding. This creates a significant compliance gap. To satisfy the regulator, firms must transition to continuous, evidence-based oversight. This involves the ability to analyze massive volumes of interactions, identify emerging conduct risks early, and produce structured, defensible proof of compliance. This is not just about deploying AI, but applying the right capabilities: - **Generative AI **can support summarisation of interactions  - **Predictive AI **enables firms to analyse datasets at scale, detect patterns of risk and prioritise action  This distinction is important. Compliance challenges are not solved by producing more outputs – they are addressed by generating meaningful insight, identifying risk earlier and supporting informed decision-making.  Without this capability, oversight remains reactive. Reviews become slower, remediation becomes more complex, and evidencing outcomes becomes harder to defend under regulatory scrutiny.  By contrast, scalable, data-driven oversight enables firms to:  - Gain complete visibility across customer interactions  - Identify and assess conduct risk proactively  - Evidence good customer outcomes with greater confidence  - Reduce the cost, complexity, and disruption of remediation  Ultimately, the FCA is raising the bar for compliance. Firms must move from partial visibility to comprehensive, outcome-based assurance, and be able to demonstrate that assurance clearly.  Sampling alone cannot deliver this, and generic AI approaches will not provide the depth of insight required. What is needed is a structured, scalable approach to oversight that combines the right technology with a clear focus on compliance and customer outcomes. #### Who is affected? This update is designed for risk officers, compliance heads, and digital transformation leads in wealth management, banking, pensions, and insurance. #### Key risks - **Isolated Anecdotes:** Relying on narrow, retrospective sampling that fails to provide a comprehensive, statistically sound view of customer outcomes. - **Undetected Vulnerabilities:** Missing critical risk signals regarding vulnerable customer support or unclear disclosures due to lack of comprehensive coverage. - **Reactive Oversight:** Managing compliance after harm has occurred, leading to slower, highly complex, and disruptive customer remediation programmes. #### Actions to take 1. **Move Beyond Sampling:** Audit your existing review volumes to establish a transition plan towards comprehensive, population-level oversight. 2. **Differentiate AI Capabilities:** Use generative AI for drafting summaries, while deploying predictive AI to detect risk patterns and prioritize complex files. 3. **Implement Active Monitoring:** Build systems capable of continuously tracking customer interactions to identify issues before they escalate. 4. **Unify Advisory and Tech:** Partner with compliance specialists and RegTech providers to deploy purpose-built, regulatory-trained AI models. #### Wider implications The FCA is continuously raising the bar for outcome-based assurance. Generic AI tools are not enough; firms must deploy specialized, structured systems designed for rigorous compliance auditing. #### Recommendations Firms should evaluate purpose-built AI tools like Recordsure to automate document processing and secure reliable, scalable compliance evidence with confidence. #### Supporting sources - [From sampling to evidence: scaling oversight for Consumer Duty](https://www.beyondencryption.com/blog/ai-review-more-conversations) (2026-06-10) #### Is your compliance oversight scalable? Move beyond limited sampling. Partner with our advisory experts and Recordsure to deploy purpose-built AI for continuous compliance assurance. [Get in touch](https://tcc.group/talk-to-us/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/insights/analysis-perspectives/from-sampling-to-evidence-scaling-oversight-for-consumer-duty/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Insights", "item": "https://tcc.group/insights/" }, { "@type": "ListItem", "position": 3, "name": "From Sampling to Evidence: Scaling Oversight for Consumer Duty", "item": "https://tcc.group/insights/analysis-perspectives/from-sampling-to-evidence-scaling-oversight-for-consumer-duty/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/analysis-perspectives/from-sampling-to-evidence-scaling-oversight-for-consumer-duty/#webpage", "url": "https://tcc.group/insights/analysis-perspectives/from-sampling-to-evidence-scaling-oversight-for-consumer-duty/", "name": "From Sampling to Evidence: Scaling Oversight for Consumer Duty", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-06-10T00:00:00+01:00", "dateModified": "2026-09-02T16:28:21+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/analysis-perspectives/from-sampling-to-evidence-scaling-oversight-for-consumer-duty/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "AnalysisNewsArticle", "@id": "https://tcc.group/insights/analysis-perspectives/from-sampling-to-evidence-scaling-oversight-for-consumer-duty/#article", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/from-sampling-to-evidence-scaling-oversight-for-consumer-duty/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "From Sampling to Evidence: Scaling Oversight for Consumer Duty", "datePublished": "2026-06-10T00:00:00+01:00", "dateModified": "2026-09-02T16:28:21+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/analysis-perspectives/from-sampling-to-evidence-scaling-oversight-for-consumer-duty/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/693b9cd680f6415c943d6d93dcfbac0d/thumbnail-1024-d782ee4c2246e59a828741cfb3c53c96a6024e82c8dfefcef3ae628780eba471.jpg", "description": "Traditional file sampling creates significant regulatory blind spots. Discover how to scale compliance oversight under Consumer Duty, moving from selective reviews to continuous, data-driven assurance.", "inLanguage": "en-GB", "articleBody": "TCC Group explores the necessity of moving beyond narrow call and file sampling, partnering with Recordsure to deploy scalable AI-driven compliance oversight.\n\nA recent episode of Mailock's 'Beyond Encryption' podcast highlighted a critical challenge for regulated firms: how to move beyond narrow file sampling to achieve a complete, defensible understanding of customer outcomes.\n\nUnder the Consumer Duty, the FCA expects firms to not only monitor client interactions but to actively assess, test, understand, and evidence positive customer outcomes consistently and at scale.\n\nTraditional compliance sampling, which reviews only a tiny fraction of calls or advice files, is no longer sufficient. Small samples surface isolated anecdotes but fail to detect systemic issues relating to disclosures, vulnerable clients, or poor customer understanding. This creates a significant compliance gap.\n\nTo satisfy the regulator, firms must transition to continuous, evidence-based oversight. This involves the ability to analyze massive volumes of interactions, identify emerging conduct risks early, and produce structured, defensible proof of compliance.\n\nThis is not just about deploying AI, but applying the right capabilities:\n\u2022 Generative AI\u00a0can support summarisation of interactions\u00a0\n\n\u2022 Predictive AI\u00a0enables firms to analyse datasets at scale, detect patterns of risk and prioritise action\u00a0\n\nThis distinction is important. Compliance challenges are not solved by producing more outputs\u00a0\u2013\u00a0they are addressed by generating meaningful insight,\u00a0identifying\u00a0risk earlier and supporting informed decision-making.\u00a0\n\nWithout this capability, oversight\u00a0remains\u00a0reactive. Reviews become slower, remediation becomes more complex, and evidencing outcomes becomes harder to defend under regulatory scrutiny.\u00a0\n\nBy contrast, scalable, data-driven oversight enables firms to:\u00a0\n\u2022 Gain complete visibility across customer interactions\u00a0\n\n\u2022 Identify\u00a0and assess conduct risk proactively\u00a0\n\n\u2022 Evidence good customer outcomes with greater confidence\u00a0\n\n\u2022 Reduce the cost, complexity, and disruption of remediation\u00a0\n\nUltimately,\u00a0the\u00a0FCA\u00a0is raising the bar for compliance. Firms must move from partial visibility to comprehensive, outcome-based assurance,\u00a0and be able to\u00a0demonstrate\u00a0that assurance clearly.\u00a0\n\nSampling alone cannot deliver this, and generic AI approaches will not provide the depth of insight\u00a0required. What is needed is a structured, scalable approach to oversight that combines the right technology with a clear focus on compliance and customer outcomes.\n\nThis update is designed for risk officers, compliance heads, and digital transformation leads in wealth management, banking, pensions, and insurance.\n\n\u2022 Isolated Anecdotes: Relying on narrow, retrospective sampling that fails to provide a comprehensive, statistically sound view of customer outcomes.\n\u2022 Undetected Vulnerabilities: Missing critical risk signals regarding vulnerable customer support or unclear disclosures due to lack of comprehensive coverage.\n\u2022 Reactive Oversight: Managing compliance after harm has occurred, leading to slower, highly complex, and disruptive customer remediation programmes.\n\n1. Move Beyond Sampling: Audit your existing review volumes to establish a transition plan towards comprehensive, population-level oversight.\n2. Differentiate AI Capabilities: Use generative AI for drafting summaries, while deploying predictive AI to detect risk patterns and prioritize complex files.\n3. Implement Active Monitoring: Build systems capable of continuously tracking customer interactions to identify issues before they escalate.\n4. Unify Advisory and Tech: Partner with compliance specialists and RegTech providers to deploy purpose-built, regulatory-trained AI models.\n\nThe FCA is continuously raising the bar for outcome-based assurance. 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Over the past three years, rising gilt yields have materially changed redress outcomes in many historic defined benefit transfer cases. Cases that might once have produced substantial compensation are now generating no-loss results, a shift driven by market conditions rather than any change in the underlying advice assessment. On paper, that can make a back book look very different to how it looked a few years ago. Redress considerations are also appearing earlier in decision-making, featuring in acquisition activity, consolidation planning and ongoing portfolio management rather than sitting solely at the end of a complaints process. [**Watch our full redress lens recording here:**](https://vimeo.com/1159689635?fl=pl&fe=sh)** ‘Expert insight every wealth manager needs to know’**  #### Why does it matter? A redress outcome is not a fixed statement of fact. It is a calculation built from the data available, the assumptions applied and the market conditions at the time it is carried out, and it can move if any of those inputs move. That dependency is well understood in defined benefit transfer work, where outcomes track market movements closely. A return to the low-inflation conditions of the 2010s, when some real yields were negative, would increase the value placed on the benefits given up and could generate large loss results from the same case set. #### Who is affected? The issue is most relevant to firms holding legacy or acquired defined benefit transfer books, including wealth managers, pension specialists and any organisation assessing exposure ahead of acquisition or consolidation activity. #### Key risks - Treating a current no-loss position as permanent rather than sensitive to market movement. - Incomplete or inconsistent legacy data leading to assumptions that are not properly tested. - Methodology differences producing different outcomes from the same portfolio. - Understating exposure during due diligence for acquisitions or consolidation. #### Actions to take 1. Sense-check existing redress methodology against current FCA expectations. 2. Run sensitivity analysis to test how outcomes respond to different market and assumption scenarios. 3. Prioritise testing of the areas of a portfolio most likely to carry exposure, rather than reviewing every file. 4. Document the data gaps and assumptions behind each calculation so the result can be defended. #### Wider implications As firms increasingly treat redress as an ongoing assessment of risk rather than a one-off exercise, the ability to explain what sits behind a result is becoming as important as the result itself, particularly where portfolios are changing hands. #### Recommendations Firms handling acquisitions, consolidation or a legacy portfolio review should sense-check their redress approach, ensure methodology stands up to scrutiny and quantify exposure where data is incomplete, rather than relying on a single point-in-time figure. At TCC, we help firms sense-check existing redress approaches, design methodologies that stand up to scrutiny and quantify exposure where data is incomplete. Get in touch to find out more about how our redress experts can help.  #### Supporting sources - [Why no-loss outcomes still signal risk in defined benefit transfer redress](https://vimeo.com/1159689635?fl=pl&fe=sh) (2026-06-09) - [Redress liabilities](https://www.fca.org.uk/firms/redress-liabilities-polluter-pays) #### Unsure how stable your redress outcomes are? Speak to our redress specialists about sense-checking methodology and quantifying exposure across legacy defined benefit transfer books. [Talk to our redress team](https://tcc.group/talk-to-us/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", 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"url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/insights/regulatory-horizon/why-no-loss-outcomes-still-signal-risk-in-defined-benefit-transfer-redress/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Insights", "item": "https://tcc.group/insights/" }, { "@type": "ListItem", "position": 3, "name": "Why no-loss outcomes still signal risk in defined benefit transfer redress", "item": "https://tcc.group/insights/regulatory-horizon/why-no-loss-outcomes-still-signal-risk-in-defined-benefit-transfer-redress/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/regulatory-horizon/why-no-loss-outcomes-still-signal-risk-in-defined-benefit-transfer-redress/#webpage", "url": "https://tcc.group/insights/regulatory-horizon/why-no-loss-outcomes-still-signal-risk-in-defined-benefit-transfer-redress/", "name": "Why no-loss outcomes still signal risk in defined benefit transfer redress", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-06-09T00:00:00+01:00", "dateModified": "2026-09-02T16:31:54+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/regulatory-horizon/why-no-loss-outcomes-still-signal-risk-in-defined-benefit-transfer-redress/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "NewsArticle", "@id": "https://tcc.group/insights/regulatory-horizon/why-no-loss-outcomes-still-signal-risk-in-defined-benefit-transfer-redress/#article", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/why-no-loss-outcomes-still-signal-risk-in-defined-benefit-transfer-redress/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "Why no-loss outcomes still signal risk in defined benefit transfer redress", "datePublished": "2026-06-09T00:00:00+01:00", "dateModified": "2026-09-02T16:31:54+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/regulatory-horizon/why-no-loss-outcomes-still-signal-risk-in-defined-benefit-transfer-redress/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/693b9cd680f6415c943d6d93dcfbac0d/thumbnail-1024-d782ee4c2246e59a828741cfb3c53c96a6024e82c8dfefcef3ae628780eba471.jpg", "description": "Rising gilt yields have turned many defined benefit transfer cases into no-loss results, but that outcome can shift again. Learn why methodology, data quality and market sensitivity still matter for legacy portfolio exposure.", "inLanguage": "en-GB", "articleBody": "Rising gilt yields have pushed many historic defined benefit transfer redress cases towards no-loss outcomes, but the result reflects a point-in-time calculation rather than a permanent conclusion.\n\nOver the past three years, rising gilt yields have materially changed redress outcomes in many historic defined benefit transfer cases. Cases that might once have produced substantial compensation are now generating no-loss results, a shift driven by market conditions rather than any change in the underlying advice assessment.\n\nOn paper, that can make a back book look very different to how it looked a few years ago. Redress considerations are also appearing earlier in decision-making, featuring in acquisition activity, consolidation planning and ongoing portfolio management rather than sitting solely at the end of a complaints process.\n\nWatch our full redress lens recording here:\u00a0\u2018Expert insight every wealth\u00a0manager\u00a0needs to\u00a0know\u2019\u00a0\n\nA redress outcome is not a fixed statement of fact. It is a calculation built from the data available, the assumptions applied and the market conditions at the time it is carried out, and it can move if any of those inputs move.\r\n\r\nThat dependency is well understood in defined benefit transfer work, where outcomes track market movements closely. A return to the low-inflation conditions of the 2010s, when some real yields were negative, would increase the value placed on the benefits given up and could generate large loss results from the same case set.\n\nThe issue is most relevant to firms holding legacy or acquired defined benefit transfer books, including wealth managers, pension specialists and any organisation assessing exposure ahead of acquisition or consolidation activity.\n\n\u2022 Treating a current no-loss position as permanent rather than sensitive to market movement.\n\u2022 Incomplete or inconsistent legacy data leading to assumptions that are not properly tested.\n\u2022 Methodology differences producing different outcomes from the same portfolio.\n\u2022 Understating exposure during due diligence for acquisitions or consolidation.\n\n1. Sense-check existing redress methodology against current FCA expectations.\n2. Run sensitivity analysis to test how outcomes respond to different market and assumption scenarios.\n3. Prioritise testing of the areas of a portfolio most likely to carry exposure, rather than reviewing every file.\n4. Document the data gaps and assumptions behind each calculation so the result can be defended.\n\nAs firms increasingly treat redress as an ongoing assessment of risk rather than a one-off exercise, the ability to explain what sits behind a result is becoming as important as the result itself, particularly where portfolios are changing hands.\n\nFirms handling acquisitions, consolidation or a legacy portfolio review should sense-check their redress approach, ensure methodology stands up to scrutiny and quantify exposure where data is incomplete, rather than relying on a single point-in-time figure.\n\nAt TCC, we help firms sense-check existing redress approaches, design methodologies that stand up to scrutiny and quantify exposure where data is incomplete.\u00a0Get in touch to find out more\u00a0about how\u00a0our redress experts can help.\u00a0", "wordCount": 482, "keywords": [ "Consumer Duty", "Redress & Remediation", "Suitability, Advice Quality & File Reviews", "Pensions & Retirement Income", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Consumer Duty", "url": "https://tcc.group/blog/solution/consumer-duty/" }, { "@type": "Thing", "name": "Redress & Remediation", "url": "https://tcc.group/blog/solution/redress-and-remediation/" }, { "@type": "Thing", "name": "Suitability, Advice Quality & File Reviews", "url": "https://tcc.group/blog/solution/outsourced-suitability-reviews/" }, { "@type": "Thing", "name": "Pensions & Retirement Income", "url": "https://tcc.group/blog/sector/pensions-retirement-income/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Defined Benefit Transfer Redress" } ], "articleSection": [ "Consumer Duty", "Redress & Remediation", "Suitability, Advice Quality & File Reviews" ], "audience": [ { "@type": "Audience", "audienceType": "Pensions & Retirement Income" }, { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Wealth management and pensions firms assessing exposure across legacy or acquired defined benefit transfer books." } ], "citation": [ { "@type": "CreativeWork", "name": "Why no-loss outcomes still signal risk in defined benefit transfer redress", "url": "https://vimeo.com/1159689635?fl=pl&fe=sh", "datePublished": "2026-06-09" }, { "@type": "CreativeWork", "name": "Redress liabilities", "url": "https://www.fca.org.uk/firms/redress-liabilities-polluter-pays" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/regulatory-horizon/why-no-loss-outcomes-still-signal-risk-in-defined-benefit-transfer-redress/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/why-no-loss-outcomes-still-signal-risk-in-defined-benefit-transfer-redress/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What does a 'no-loss' redress outcome mean?", "acceptedAnswer": { "@type": "Answer", "text": "It means that, based on current data, assumptions and market conditions, the calculation shows no compensation is due, though the same case could produce a different result if conditions change." } }, { "@type": "Question", "name": "Why can redress outcomes change over time?", "acceptedAnswer": { "@type": "Answer", "text": "Because the calculation depends on inputs such as gilt yields and inflation assumptions, and defined benefit transfer results are particularly sensitive to market movements." } }, { "@type": "Question", "name": "How should firms handle incomplete legacy data in redress reviews?", "acceptedAnswer": { "@type": "Answer", "text": "Firms typically supplement missing data with tested assumptions and use sampling to build a view of exposure where a full review is not realistic." } }, { "@type": "Question", "name": "When should firms revisit a no-loss position?", "acceptedAnswer": { "@type": "Answer", "text": "Ahead of acquisitions, consolidation or any exercise assessing exposure across a portfolio, since methodology and market sensitivity can change the outcome." } } ] } ] } ``` ### Bereavement support under scrutiny for investment firms - URL: https://tcc.group/insights/regulatory-horizon/bereavement-support-under-scrutiny-for-investment-firms/ - Published: 2026-05-31 - Modified: 2026-09-02 **Topic:** Bereavement Support and Consumer Duty The FCA has announced a review into whether consumer investment firms are doing enough to support bereaved customers, after finding fewer than half felt they received the support they needed. The review tests whether Consumer Duty outcomes are evidenced in practice, not just described in policy. #### What happened? The FCA has announced a [review](https://www.fca.org.uk/news/press-releases/fca-reviews-whether-investment-firms-are-doing-enough-support-bereaved-customers) into whether consumer investment firms are doing enough to support bereaved customers, after finding that fewer than half of bereaved customers (47%) felt they received the support they needed. The review will assess the customer experience from the point a bereavement is notified through to the settlement or transfer of investments, including communication, support for vulnerable customers, service standards and how fees are applied on bereaved accounts. It follows earlier 2024 multi-firm reviews into life insurers' bereavement claims processes and the treatment of vulnerable customers in retail banking, in which the FCA said it wanted to see a "step change" improvement and that "no firm can afford to be complacent in this area". #### Why does it matter? As Consumer Duty supervision matures, the FCA's focus is moving beyond whether firms have made an effort towards whether they can prove their approach actually works. Bereavement is a real test of a firm's culture: poorly designed journeys, with unclear letters, repeated requests for information and avoidable delays, compound distress at an already difficult time. The FCA has been explicit that this review sits within a wider, outcomes-focused supervisory direction for 2026/27, in which vulnerable customers, fair value and customer understanding are core supervisory points rather than secondary considerations. #### Who is affected? Consumer investment and advice firms handling bereaved customers' accounts and transfers, and the boards and executive teams accountable for how those journeys are designed, monitored and improved. #### Key risks - Bereavement journeys that rely on unclear communications, repeated information requests or avoidable delays, compounding customer distress. - Policies that describe good intentions on paper without evidence that outcomes are actually being delivered. - Governance gaps where boards cannot show how bereavement outcomes are measured or where weaknesses exist. #### Actions to take 1. Map the end-to-end bereavement journey and identify where communication, delay or repeated requests cause friction. 2. Introduce a single point of contact and streamlined information requests to reduce repetition for bereaved customers. 3. Record how quickly cases are resolved, where delays arise, and what feedback customers give. 4. Brief the board on outcomes evidence and the changes made where those outcomes fall short. #### Wider implications The bereavement review is best understood as a marker of where Consumer Duty supervision is heading: the FCA is increasingly testing firms against real customer experiences rather than abstract frameworks, and bereavement is unlikely to be the last customer journey to face this level of scrutiny. #### Recommendations Firms should independently review and test their bereavement and other vulnerable-customer journeys end-to-end, covering governance, process, data and outcomes, so they can evidence effectiveness rather than simply describing policy intent. Boards should satisfy themselves that they understand how these journeys work, how outcomes are measured, and what action has been taken in response to earlier FCA findings. We’re supporting firms that are taking a closer look at how effectively their Consumer Duty frameworks operate in practice, particularly for vulnerable customer journeys such as bereavement. TCC independently reviews and tests these journeys end‑to‑end, helping firms assess whether governance, processes, data and outcomes stand up to regulatory scrutiny. From board level challenge and outcomes assurance through to targeted reviews of customer support models and evidence of effectiveness, we help firms move beyond policy intent to demonstrable, regulator ready outcomes. Get in touch to discover how we can help your firm. #### Supporting sources - [Bereavement support under scrutiny for investment firms](https://www.fca.org.uk/news/press-releases/fca-reviews-whether-investment-firms-are-doing-enough-support-bereaved-customers) (2026-06-01) - [Review of life insurers’ bereavement claim process](https://www.fca.org.uk/publications/multi-firm-reviews/findings-our-multi-firm-review-life-insurers-bereavement-claim-process) - [Retail banks’ treatment of customers in vulnerable circumstances Multi-Firm Review](https://www.fca.org.uk/publications/multi-firm-reviews/retail-banks-treatment-customers-vulnerable-circumstances-multi-firm-review) #### Is your bereavement support regulator-ready? Contact us to discuss an independent, end-to-end review of your bereavement support and wider vulnerable-customer journeys. [Get in touch](https://tcc.group/talk-to-us/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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vulnerable-customer journeys against real outcomes, not just policy.", "inLanguage": "en-GB", "articleBody": "The FCA has announced a review into whether consumer investment firms are doing enough to support bereaved customers, after finding fewer than half felt they received the support they needed. The review tests whether Consumer Duty outcomes are evidenced in practice, not just described in policy.\n\nThe FCA has announced a review into whether consumer investment firms are doing enough to support bereaved customers, after finding that fewer than half of bereaved customers (47%) felt they received the support they needed. The review will assess the customer experience from the point a bereavement is notified through to the settlement or transfer of investments, including communication, support for vulnerable customers, service standards and how fees are applied on bereaved accounts.\n\nIt follows earlier 2024 multi-firm reviews into life insurers' bereavement claims processes and the treatment of vulnerable customers in retail banking, in which the FCA said it wanted to see a \"step change\" improvement and that \"no firm can afford to be complacent in this area\".\n\nAs Consumer Duty supervision matures, the FCA's focus is moving beyond whether firms have made an effort towards whether they can prove their approach actually works. Bereavement is a real test of a firm's culture: poorly designed journeys, with unclear letters, repeated requests for information and avoidable delays, compound distress at an already difficult time.\r\n\r\nThe FCA has been explicit that this review sits within a wider, outcomes-focused supervisory direction for 2026/27, in which vulnerable customers, fair value and customer understanding are core supervisory points rather than secondary considerations.\n\nConsumer investment and advice firms handling bereaved customers' accounts and transfers, and the boards and executive teams accountable for how those journeys are designed, monitored and improved.\n\n\u2022 Bereavement journeys that rely on unclear communications, repeated information requests or avoidable delays, compounding customer distress.\n\u2022 Policies that describe good intentions on paper without evidence that outcomes are actually being delivered.\n\u2022 Governance gaps where boards cannot show how bereavement outcomes are measured or where weaknesses exist.\n\n1. Map the end-to-end bereavement journey and identify where communication, delay or repeated requests cause friction.\n2. Introduce a single point of contact and streamlined information requests to reduce repetition for bereaved customers.\n3. Record how quickly cases are resolved, where delays arise, and what feedback customers give.\n4. Brief the board on outcomes evidence and the changes made where those outcomes fall short.\n\nThe bereavement review is best understood as a marker of where Consumer Duty supervision is heading: the FCA is increasingly testing firms against real customer experiences rather than abstract frameworks, and bereavement is unlikely to be the last customer journey to face this level of scrutiny.\n\nFirms should independently review and test their bereavement and other vulnerable-customer journeys end-to-end, covering governance, process, data and outcomes, so they can evidence effectiveness rather than simply describing policy intent.\n\nBoards should satisfy themselves that they understand how these journeys work, how outcomes are measured, and what action has been taken in response to earlier FCA findings.\n\nWe\u2019re supporting firms that are taking a closer look at how effectively their Consumer Duty frameworks operate in practice, particularly for vulnerable customer journeys such as bereavement. TCC independently reviews and tests these journeys end\u2011to\u2011end, helping firms assess whether governance, processes, data and outcomes stand up to regulatory scrutiny. From board level challenge and outcomes assurance through to targeted reviews of customer support models and evidence of effectiveness, we help firms move beyond policy intent to demonstrable, regulator ready outcomes. 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TCC Group's CEO, Joe Norburn, is featured in the latest [A-Team Insight](https://a-teaminsight.com/blog/ai-in-financial-services-where-the-real-challenges-are-starting-to-emerge/) article, which argues that as AI is now widely embedded across financial services, the industry's focus is shifting from adoption to governance. The article notes that governance approaches remain uneven, with many firms still relying on control frameworks designed for more deterministic systems, where decision paths could be more easily traced and explained. #### Why does it matter? As AI becomes more complex and embedded, tracing and explaining decisions becomes harder to achieve. Existing regulatory frameworks such as Consumer Duty, SM&CR and operational resilience remain central, but the emphasis is moving towards how firms apply them when decisions are less visible and outcomes are shaped by complex systems. Regulators are increasing their engagement with the industry, with a growing focus on how firms evidence outcomes, manage risk and maintain accountability as AI scales, and the most difficult challenges tend to emerge after deployment, once AI is embedded in critical processes. #### Supporting sources - [A-Team insight: AI in financial services](https://a-teaminsight.com/blog/ai-in-financial-services-where-the-real-challenges-are-starting-to-emerge/) (2026-05-21) - Reviewed by: [Joe Norburn](https://tcc.group/meet-the-team/), CEO - TCC Group #### Reviewing your firm's AI governance? Get in touch to discuss how to evidence outcomes, risk and accountability as AI scales across your business. [Get in touch](https://tcc.group/talk-to-us/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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In an article featured in [IFA Magazine](https://ifamagazine.com/the-fcas-consumer-duty-challenge-is-changing-shape/), TCC Group CEO Joe Norburn explores how the FCA's Consumer Duty is entering a mature phase. Compliance is moving beyond initial implementation to a stage where the regulator demands clear, demonstrable evidence of positive client outcomes in daily practice. This shift requires boards and executive teams to apply deeper subjective judgement, actively interrogate their management information, and move away from over-reliance on process-based checklists. #### Why does it matter? The mature phase of Consumer Duty means firms cannot rely on the strength of their written policies alone. Boards must apply rigorous judgement to prove that customers are receiving fair value and appropriate support, requiring highly detailed, empirical management information to back up any compliance assertions. #### Supporting sources - [Consumer Duty Outcomes: From Frameworks to Judgement](https://ifamagazine.com/the-fcas-consumer-duty-challenge-is-changing-shape/) (2026-05-20) #### Can you evidence your Consumer Duty outcomes? Speak to our advisory team today to help you structure your board reports and strengthen your empirical outcome evidence trail. 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Boards must apply rigorous judgement to prove that customers are receiving fair value and appropriate support, requiring highly detailed, empirical management information to back up any compliance assertions.", "wordCount": 140, "keywords": [ "Compliance AI & RegTech", "Consumer Duty", "Regulatory Change & Transformation", "Banking", "General Insurance & Protection", "Lending & Consumer Credit", "Motor Finance", "Payments & FinTech", "Pensions & Retirement Income", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Consumer Duty", "url": "https://tcc.group/blog/solution/consumer-duty/" }, { "@type": "Thing", "name": "Regulatory Change & Transformation", "url": "https://tcc.group/blog/solution/regulatory-change-transformation/" }, { "@type": "Thing", "name": "Banking", "url": "https://tcc.group/blog/sector/banking/" }, { "@type": "Thing", "name": "General Insurance & Protection", "url": "https://tcc.group/blog/sector/general-insurance-protection/" }, { "@type": "Thing", "name": "Lending & Consumer Credit", "url": "https://tcc.group/blog/sector/lending-consumer-credit/" }, { "@type": "Thing", "name": "Motor Finance", "url": "https://tcc.group/blog/sector/motor-finance/" }, { "@type": "Thing", "name": "Payments & FinTech", "url": "https://tcc.group/blog/sector/payments-fintech/" }, { "@type": "Thing", "name": "Pensions & Retirement Income", "url": "https://tcc.group/blog/sector/pensions-retirement-income/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Consumer Duty Outcomes" } ], "articleSection": [ "Compliance AI & RegTech", "Consumer Duty", "Regulatory Change & Transformation" ], "audience": [ { "@type": "Audience", "audienceType": "Banking" }, { "@type": "Audience", "audienceType": "General Insurance & Protection" }, { "@type": "Audience", "audienceType": "Lending & Consumer Credit" }, { "@type": "Audience", "audienceType": "Motor Finance" }, { "@type": "Audience", "audienceType": "Payments & FinTech" }, { "@type": "Audience", "audienceType": "Pensions & Retirement Income" }, { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Financial advisory firm directors, wealth managers, and compliance leaders preparing board reports." } ], "citation": [ { "@type": "CreativeWork", "name": "Consumer Duty Outcomes: From Frameworks to Judgement", "url": "https://ifamagazine.com/the-fcas-consumer-duty-challenge-is-changing-shape/", "datePublished": "2026-05-20" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/analysis-perspectives/ifa-the-fcas-consumer-duty-challenge-is-changing-shape/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/ifa-the-fcas-consumer-duty-challenge-is-changing-shape/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "How is the FCA's approach to the Consumer Duty changing?", "acceptedAnswer": { "@type": "Answer", "text": "The FCA is moving from evaluating implementation frameworks to checking for demonstrable, data-backed evidence of actual customer outcomes in day-to-day operations." } }, { "@type": "Question", "name": "What is the board's responsibility in the mature phase of Consumer Duty?", "acceptedAnswer": { "@type": "Answer", "text": "Boards must move beyond reviewing process metrics and apply robust judgement, actively challenging management information to ensure and prove that customer outcomes are consistently positive." } } ] } ] } ``` ### What the FCA’s latest ongoing advice focus means for firms - URL: https://tcc.group/insights/regulatory-horizon/what-the-fcas-latest-ongoing-advice-focus-means-for-firms/ - Published: 2026-05-18 - Modified: 2026-09-02 **Topic:** Ongoing advice supervision The FCA is moving away from process-led oversight of ongoing advice towards evidence that services genuinely deliver value. Its CP26/10 proposals would replace the mandatory annual suitability review with a more flexible, needs-based approach. #### What happened? Ongoing advice has moved further into the regulatory spotlight, driven by FCA supervisory work, Consumer Duty expectations and proposed changes to the advice framework. The FCA’s CP26/10 consultation proposes replacing the mandatory annual suitability review with a more flexible, periodic approach based on client needs and circumstances, rather than a fixed calendar cycle. Alongside this, the regulator continues to highlight the issue of disengaged clients who pay for ongoing services but do not actively use them. #### Why does it matter? The central shift is away from activity-led thinking, where completing a review was treated as confirmation the service requirement had been met, towards demonstrating that the defined service is actually being delivered and continues to meet client needs. If the annual review is no longer the anchor point, firms need another way to determine when engagement is appropriate, based on complexity and how a client’s circumstances evolve. Low engagement makes it harder to demonstrate that a service is being delivered meaningfully, which in turn makes it harder to evidence fair value. #### Who is affected? Wealth management and advice firms whose business model relies on ongoing advice services are most directly affected, since scrutiny is following the revenue this model generates. Firms with clients who pay for ongoing services but rarely engage face the most immediate pressure to show they are managing that risk. #### Key risks - Relying on a completed annual review as proof that the service requirement has been met. - Management information, quality assurance and monitoring that are not aligned to give a reliable view of delivery. - Disengaged clients whose lack of interaction undermines evidence of fair value. - Review cycles and engagement approaches that reflect internal process rather than client need. #### Actions to take 1. Review how your firm defines its ongoing service and whether that definition is genuinely being delivered. 2. Check that MI, quality assurance and monitoring are aligned to give a consistent view of delivery and outcomes. 3. Identify disengaged clients and consider re-engagement strategies or changes to how the service is delivered. 4. Prepare for CP26/10 by designing triggers for client engagement based on need rather than a fixed annual date. #### Wider implications This points to a more outcome-led model of ongoing advice, in line with the Consumer Duty’s emphasis on good outcomes rather than completed activity. For most firms this does not mean redesigning the operating model from scratch, but it does mean strengthening how that model is governed, monitored and evidenced. #### Recommendations Take a closer look at how consistently your ongoing service is delivered across the client base, and whether MI genuinely reflects what happens in practice. Reconsider whether review cycles and engagement approaches reflect client needs rather than internal process, ahead of any change to the annual review requirement. TCC Group supports firms in reviewing ongoing advice models, assessing whether services are operating as intended and helping build the governance, monitoring and practical frameworks needed to demonstrate value with confidence. Get in touch today to learn how we can help.  #### Supporting sources - [Understanding the advice market](https://www.fca.org.uk/data/understanding-financial-advice-market) (2026-05-19) - [Consumer Duty](https://www.fca.org.uk/firms/consumer-duty) - [Ongoing financial advice services](https://www.fca.org.uk/publications/multi-firm-reviews/ongoing-financial-advice-services) - [CP26/10: Simplifying the pensions and investment advice rules](https://www.fca.org.uk/publications/consultation-papers/cp26-10-simplifying-pensions-investment-advice-rules) - [Ongoing financial advice services](https://www.fca.org.uk/publications/multi-firm-reviews/ongoing-financial-advice-services) #### Ready to strengthen your ongoing advice model? Talk to us about reviewing your ongoing advice governance, monitoring and evidence frameworks. [Get in touch](https://tcc.group/talk-to-us/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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CP26/10's proposed changes to annual suitability reviews mean, and how to respond to disengaged clients before your next supervisory conversation.", "inLanguage": "en-GB", "articleBody": "The FCA is moving away from process-led oversight of ongoing advice towards evidence that services genuinely deliver value. Its CP26/10 proposals would replace the mandatory annual suitability review with a more flexible, needs-based approach.\n\nOngoing advice has moved further into the regulatory spotlight, driven by FCA supervisory work, Consumer Duty expectations and proposed changes to the advice framework.\r\n\r\nThe FCA\u2019s CP26/10 consultation proposes replacing the mandatory annual suitability review with a more flexible, periodic approach based on client needs and circumstances, rather than a fixed calendar cycle.\r\n\r\nAlongside this, the regulator continues to highlight the issue of disengaged clients who pay for ongoing services but do not actively use them.\n\nThe central shift is away from activity-led thinking, where completing a review was treated as confirmation the service requirement had been met, towards demonstrating that the defined service is actually being delivered and continues to meet client needs.\r\n\r\nIf the annual review is no longer the anchor point, firms need another way to determine when engagement is appropriate, based on complexity and how a client\u2019s circumstances evolve.\r\n\r\nLow engagement makes it harder to demonstrate that a service is being delivered meaningfully, which in turn makes it harder to evidence fair value.\n\nWealth management and advice firms whose business model relies on ongoing advice services are most directly affected, since scrutiny is following the revenue this model generates.\r\n\r\nFirms with clients who pay for ongoing services but rarely engage face the most immediate pressure to show they are managing that risk.\n\n\u2022 Relying on a completed annual review as proof that the service requirement has been met.\n\u2022 Management information, quality assurance and monitoring that are not aligned to give a reliable view of delivery.\n\u2022 Disengaged clients whose lack of interaction undermines evidence of fair value.\n\u2022 Review cycles and engagement approaches that reflect internal process rather than client need.\n\n1. Review how your firm defines its ongoing service and whether that definition is genuinely being delivered.\n2. Check that MI, quality assurance and monitoring are aligned to give a consistent view of delivery and outcomes.\n3. Identify disengaged clients and consider re-engagement strategies or changes to how the service is delivered.\n4. Prepare for CP26/10 by designing triggers for client engagement based on need rather than a fixed annual date.\n\nThis points to a more outcome-led model of ongoing advice, in line with the Consumer Duty\u2019s emphasis on good outcomes rather than completed activity.\r\n\r\nFor most firms this does not mean redesigning the operating model from scratch, but it does mean strengthening how that model is governed, monitored and evidenced.\n\nTake a closer look at how consistently your ongoing service is delivered across the client base, and whether MI genuinely reflects what happens in practice.\n\nReconsider whether review cycles and engagement approaches reflect client needs rather than internal process, ahead of any change to the annual review requirement.\n\nTCC Group supports firms in reviewing ongoing advice models, assessing whether services are operating as intended and helping build the governance, monitoring and practical frameworks needed to demonstrate value with confidence. Get in touch today to learn how we can help.\u00a0", "wordCount": 520, "keywords": [ "Compliance AI & RegTech", "Consumer Duty", "Suitability, Advice Quality & File Reviews", "Pensions & Retirement Income", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Consumer Duty", "url": "https://tcc.group/blog/solution/consumer-duty/" }, { "@type": "Thing", "name": "Suitability, Advice Quality & File Reviews", "url": "https://tcc.group/blog/solution/outsourced-suitability-reviews/" }, { "@type": "Thing", "name": "Pensions & Retirement Income", "url": "https://tcc.group/blog/sector/pensions-retirement-income/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Ongoing advice supervision" } ], "articleSection": [ "Compliance AI & RegTech", "Consumer Duty", "Suitability, Advice Quality & File Reviews" ], "audience": [ { "@type": "Audience", "audienceType": "Pensions & Retirement Income" }, { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Wealth management and financial advice firms delivering ongoing advice services." } ], "citation": [ { "@type": "CreativeWork", "name": "Understanding the advice market", "url": "https://www.fca.org.uk/data/understanding-financial-advice-market", "datePublished": "2026-05-19" }, { "@type": "CreativeWork", "name": "Consumer Duty", "url": "https://www.fca.org.uk/firms/consumer-duty" }, { "@type": "CreativeWork", "name": "Ongoing financial advice services", "url": "https://www.fca.org.uk/publications/multi-firm-reviews/ongoing-financial-advice-services" }, { "@type": "CreativeWork", "name": "CP26/10: Simplifying the pensions and investment advice rules", "url": "https://www.fca.org.uk/publications/consultation-papers/cp26-10-simplifying-pensions-investment-advice-rules" }, { "@type": "CreativeWork", "name": "Ongoing financial advice services", "url": "https://www.fca.org.uk/publications/multi-firm-reviews/ongoing-financial-advice-services" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/regulatory-horizon/what-the-fcas-latest-ongoing-advice-focus-means-for-firms/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/what-the-fcas-latest-ongoing-advice-focus-means-for-firms/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What does the FCA's CP26/10 consultation propose?", "acceptedAnswer": { "@type": "Answer", "text": "Replacing the mandatory annual suitability review with a more flexible, periodic approach based on client needs and circumstances." } }, { "@type": "Question", "name": "Why is client disengagement a risk for ongoing advice?", "acceptedAnswer": { "@type": "Answer", "text": "Low engagement makes it harder to demonstrate that a service is being delivered meaningfully, which affects whether it represents fair value." } }, { "@type": "Question", "name": "Does this mean firms need a completely new operating model?", "acceptedAnswer": { "@type": "Answer", "text": "Not necessarily; for most firms the foundations already exist, but how they are governed, monitored and evidenced needs to be strengthened." } }, { "@type": "Question", "name": "What should firms focus on now?", "acceptedAnswer": { "@type": "Answer", "text": "Reviewing how consistently services are delivered, whether MI reflects real practice, and how engagement approaches align with client needs." } } ] } ] } ``` ### What the FCA motor finance redress scheme update means for lenders - URL: https://tcc.group/insights/regulatory-horizon/what-the-fca-motor-finance-redress-scheme-update-means-for-lenders/ - Published: 2026-05-12 - Modified: 2026-09-02 **Topic:** Motor finance redress scheme The FCA has issued a[further update on its motor finance redress scheme](https://www.fca.org.uk/news/statements/legal-challenges-motor-finance-compensation-scheme-update-firms-consumers) following four legal challenges to its design. It continues to defend the scheme while asking lenders to keep preparing regardless of how the legal process unfolds. #### What happened? The FCA has confirmed it received [four legal challenges](https://www.fca.org.uk/news/statements/fca-statement-legal-challenges-motor-finance-scheme) to its proposed motor finance redress scheme: three from lenders and one from a consumer group. The regulator says it will defend the scheme as lawful and as the most effective way to address a widespread, long-running issue, though it has acknowledged uncertainty around the timing and final structure while the legal process runs its course. This latest update gives firms further clarity on what the FCA expects them to be doing now, even while that process continues. #### Why does it matter? The challenges go to the design of the scheme as a whole, questioning the FCA’s legal authority to apply it to older agreements written before April 2014, how it defines customer loss, and how it calculates compensation. Because the arguments run in different directions, some claiming the scheme favours consumers too much and others claiming it favours lenders too much, the eventual outcome could reshape the scheme rather than simply confirm it. For lenders, that means the practical scope and cost of the scheme cannot yet be treated as fixed. #### Who is affected? Motor finance firms and lenders with discretionary commission arrangements or exclusive dealer relationships remain squarely in scope, regardless of how the legal challenges are resolved. Complaint-handling, remediation and data teams are most directly affected, since they are being asked to keep working while the final shape of the scheme is still open. #### Key risks - Pausing preparation while the legal position is unresolved, then facing a compressed timeline once it is settled. - Complaints being held indefinitely rather than processed through standard channels. - Being unprepared for a more complaint-led route if elements of the scheme do not proceed as designed. #### Actions to take 1. Continue identifying relevant agreements and gathering data on commission and disclosure. 2. Progress implementation planning that can flex across multiple possible scheme outcomes. 3. Keep complaint-handling processes ready to deal with cases through standard routes as the position develops. #### Wider implications The FCA’s insistence that firms keep preparing, despite the legal uncertainty, signals that it does not expect the challenges to remove the underlying obligation to address the issue. Firms that treat the legal process as a reason to wait risk being caught out if the scheme proceeds broadly as planned, or if a complaint-led alternative arrives with less notice. #### Recommendations Keep advancing data gathering and refining remediation approaches so that work already done remains usable under different scenarios. Build complaint-handling frameworks that can adapt as the position evolves, rather than waiting for a single final version of the scheme. At TCC, we support firms in translating regulatory expectations into practical delivery – from assessing exposure and designing remediation frameworks, through to building the operational capability needed to handle complaints at scale. Our focus is on helping firms move forward with confidence, ensuring they are ready to respond, whatever direction the final scheme takes.   #### Supporting sources - [What the FCA motor finance redress scheme update means for lenders](https://www.fca.org.uk/news/statements/legal-challenges-motor-finance-compensation-scheme-update-firms-consumers) (2026-05-13) #### Need help maintaining redress readiness? Talk to our team about translating the FCA's expectations into practical delivery for your firm. 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"https://tcc.group/insights/regulatory-horizon/what-the-fca-motor-finance-redress-scheme-update-means-for-lenders/#article", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/what-the-fca-motor-finance-redress-scheme-update-means-for-lenders/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "What the FCA motor finance redress scheme update means for lenders", "datePublished": "2026-05-13T00:00:00+01:00", "dateModified": "2026-09-02T14:31:09+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/regulatory-horizon/what-the-fca-motor-finance-redress-scheme-update-means-for-lenders/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/6c7be0c8f9fd47faaeb93f272fad506a/thumbnail-1024-d9f8f788da4e140924d9363c715d6582f43155ce7e0bae8d4f794cc222ff6e58.jpg", "description": "Understand what the FCA's latest motor finance redress update means for lenders, including the four legal challenges now underway, and why firms should keep preparing data and complaint-handling capability regardless of the outcome.", "inLanguage": "en-GB", "articleBody": "The FCA has issued afurther update on its motor finance redress scheme following four legal challenges to its design. It continues to defend the scheme while asking lenders to keep preparing regardless of how the legal process unfolds.\n\nThe FCA has confirmed it received four legal challenges to its proposed motor finance redress scheme: three from lenders and one from a consumer group.\n\nThe regulator says it will defend the scheme as lawful and as the most effective way to address a widespread, long-running issue, though it has acknowledged uncertainty around the timing and final structure while the legal process runs its course.\n\nThis latest update gives firms further clarity on what the FCA expects them to be doing now, even while that process continues.\n\nThe challenges go to the design of the scheme as a whole, questioning the FCA\u2019s legal authority to apply it to older agreements written before April 2014, how it defines customer loss, and how it calculates compensation.\r\n\r\nBecause the arguments run in different directions, some claiming the scheme favours consumers too much and others claiming it favours lenders too much, the eventual outcome could reshape the scheme rather than simply confirm it.\r\n\r\nFor lenders, that means the practical scope and cost of the scheme cannot yet be treated as fixed.\n\nMotor finance firms and lenders with discretionary commission arrangements or exclusive dealer relationships remain squarely in scope, regardless of how the legal challenges are resolved.\r\n\r\nComplaint-handling, remediation and data teams are most directly affected, since they are being asked to keep working while the final shape of the scheme is still open.\n\n\u2022 Pausing preparation while the legal position is unresolved, then facing a compressed timeline once it is settled.\n\u2022 Complaints being held indefinitely rather than processed through standard channels.\n\u2022 Being unprepared for a more complaint-led route if elements of the scheme do not proceed as designed.\n\n1. Continue identifying relevant agreements and gathering data on commission and disclosure.\n2. Progress implementation planning that can flex across multiple possible scheme outcomes.\n3. Keep complaint-handling processes ready to deal with cases through standard routes as the position develops.\n\nThe FCA\u2019s insistence that firms keep preparing, despite the legal uncertainty, signals that it does not expect the challenges to remove the underlying obligation to address the issue.\r\n\r\nFirms that treat the legal process as a reason to wait risk being caught out if the scheme proceeds broadly as planned, or if a complaint-led alternative arrives with less notice.\n\nKeep advancing data gathering and refining remediation approaches so that work already done remains usable under different scenarios.\n\nBuild complaint-handling frameworks that can adapt as the position evolves, rather than waiting for a single final version of the scheme.\n\nAt TCC, we support firms in translating regulatory expectations into practical delivery\u00a0\u2013\u00a0from assessing exposure and designing remediation frameworks, through to building the operational capability needed to handle complaints at scale. Our focus is on helping firms move forward with confidence, ensuring they are ready to respond, whatever direction the final scheme takes.\u00a0\u00a0", "wordCount": 506, "keywords": [ "Complaints & Claims Handling", "Compliance AI & RegTech", "Redress & Remediation", "Regulatory Change & Transformation", "Lending & Consumer Credit", "Motor Finance" ], "about": [ { "@type": "Thing", "name": "Complaints & Claims Handling", "url": "https://tcc.group/blog/solution/complaints-claims-handling/" }, { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Redress & Remediation", "url": "https://tcc.group/blog/solution/redress-and-remediation/" }, { "@type": "Thing", "name": "Regulatory Change & Transformation", "url": "https://tcc.group/blog/solution/regulatory-change-transformation/" }, { "@type": "Thing", "name": "Lending & Consumer Credit", "url": "https://tcc.group/blog/sector/lending-consumer-credit/" }, { "@type": "Thing", "name": "Motor Finance", "url": "https://tcc.group/blog/sector/motor-finance/" }, { "@type": "Thing", "name": "Motor finance redress scheme" } ], "articleSection": [ "Complaints & Claims Handling", "Compliance AI & RegTech", "Redress & Remediation", "Regulatory Change & Transformation" ], "audience": [ { "@type": "Audience", "audienceType": "Lending & Consumer Credit" }, { "@type": "Audience", "audienceType": "Motor Finance" }, { "@type": "Audience", "audienceType": "Motor finance lenders and their complaints, remediation and data teams tracking the FCA's redress scheme." } ], "citation": [ { "@type": "CreativeWork", "name": "What the FCA motor finance redress scheme update means for lenders", "url": "https://www.fca.org.uk/news/statements/legal-challenges-motor-finance-compensation-scheme-update-firms-consumers", "datePublished": "2026-05-13" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/regulatory-horizon/what-the-fca-motor-finance-redress-scheme-update-means-for-lenders/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/what-the-fca-motor-finance-redress-scheme-update-means-for-lenders/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "How many legal challenges has the FCA received to the motor finance redress scheme?", "acceptedAnswer": { "@type": "Answer", "text": "Four: three from lenders and one from a consumer group." } }, { "@type": "Question", "name": "Should firms keep preparing while the legal challenges are ongoing?", "acceptedAnswer": { "@type": "Answer", "text": "Yes, the FCA has been clear that firms should continue practical work such as identifying agreements and gathering data rather than pausing activity." } }, { "@type": "Question", "name": "What could happen if elements of the scheme do not proceed?", "acceptedAnswer": { "@type": "Answer", "text": "The FCA has said it would consider alternative approaches, potentially including a more complaint-led route to resolving claims." } }, { "@type": "Question", "name": "What areas do the legal challenges cover?", "acceptedAnswer": { "@type": "Answer", "text": "They cover the FCA's legal authority to apply the scheme to older agreements, its approach to customer loss, and how it calculates compensation." } } ] } ] } ``` ### European Business Magazine: Finance is scaling AI fast – now it has to prove it’s under control - URL: https://tcc.group/insights/analysis-perspectives/european-business-magazine-finance-is-scaling-ai-fast-now-it-has-to-prove-its-under-control/ - Published: 2026-05-07 - Modified: 2026-09-03 **Topic:** AI Governance and Oversight TCC Group CEO Joe Norburn highlights the urgent need for financial services to establish strict oversight, accountability, and data explainability as they rapidly integrate AI into core operations. #### What happened? TCC Group CEO Joe Norburn was recently featured in [European Business Magazine](https://europeanbusinessmagazine.com/business-finance-scaling-ai-control), discussing how financial services firms are rapidly adopting AI across core operations. He notes that these integrations are being driven by commercial pressures and efficiency gains, often ahead of definitive regulatory guidelines. #### Why does it matter? While regulators like the FCA support technological innovation, they expect firms to prove they can maintain complete oversight, accountability, and robust governance as AI is embedded in decision-making. Norburn warns that the main challenge is not AI capability, but ensuring the quality, explainability, and auditability of the underlying data. Generative AI alone is not suitable for regulated financial decisions. Firms must instead combine trusted, structured data with purpose-built predictive AI to scale automation safely while meeting regulatory standards. #### Supporting sources - [European Business Magazine: Finance is scaling AI fast – now it has to prove it’s under control](https://europeanbusinessmagazine.com/business-finance-scaling-ai-control) (2026-05-08) - Reviewed by: [Joe Norburn](https://tcc.group/meet-the-team/), CEO - TCC Group #### Is your AI deployment compliant and controlled? Speak to our compliance AI and regtech experts to learn how you can establish robust governance frameworks and auditability for your automated decision-making. [Get in touch](https://tcc.group/talk-to-us/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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\u2013 now it has to prove it\u2019s under control", "item": "https://tcc.group/insights/analysis-perspectives/european-business-magazine-finance-is-scaling-ai-fast-now-it-has-to-prove-its-under-control/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/analysis-perspectives/european-business-magazine-finance-is-scaling-ai-fast-now-it-has-to-prove-its-under-control/#webpage", "url": "https://tcc.group/insights/analysis-perspectives/european-business-magazine-finance-is-scaling-ai-fast-now-it-has-to-prove-its-under-control/", "name": "European Business Magazine: Finance is scaling AI fast \u2013 now it has to prove it\u2019s under control", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-05-08T00:00:00+01:00", "dateModified": "2026-09-03T09:18:03+01:00", "breadcrumb": { "@id": 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Firms require trusted, structured data and purpose-built predictive AI to maintain compliance." } }, { "@type": "Question", "name": "What are regulators focusing on regarding AI?", "acceptedAnswer": { "@type": "Answer", "text": "Regulators are focused on how firms evidence outcomes, maintain governance, and ensure accountability and explainability in automated decisions." } } ] } ] } ``` ### How FOS reforms will affect financial services firms - URL: https://tcc.group/insights/regulatory-horizon/how-fos-reforms-will-affect-financial-services-firms/ - Published: 2026-05-07 - Modified: 2026-09-03 **Topic:** FOS Reforms The UK government has announced plans to reform the Financial Ombudsman Service, narrowing its discretion under the 'fair and reasonable' test and establishing a formal FCA referral process. #### What happened? Following a [major public consultation](https://assets.publishing.service.gov.uk/media/6a0dc69b5c3c79da61662e28/Consultation_Response_-_FOS_Reform_Updated_May_26.pdf) with over 600 respondents, the UK government has set out plans to reform the Financial Ombudsman Service (FOS). The reforms aim to bring greater clarity and predictability to consumers and firms by introducing significant structural and legislative changes to FOS processes. Key legislative proposals include revising the FOS's 'fair and reasonable' test, creating a formal referral process back to the FCA for rule interpretation, establishing a ten-year absolute time limit for complaints, and empowering the FCA to better manage mass redress events. #### Why does it matter? For years, the 'fair and reasonable' test granted the FOS wide discretion, letting it bypass strict rule compliance to focus on broader interpretations of fairness, which created unpredictability for firms. The proposed reforms narrow this discretion; if a firm complies with relevant FCA rules, the FOS will normally be required to find that it acted reasonably. However, this is not a pure rules-based shift. Firms must still act in line with regulatory intent, and the FOS will apply its test within a tighter, more structured framework. A formal referral mechanism also means the FOS must refer ambiguous rules back to the FCA, cementing the regulator as the sole authority on rule interpretation. #### Who is affected? These reforms direct impact all regulated UK financial services firms, their complaints teams, risk management committees, and legal departments. The changes apply across wealth management, lending, general insurance, and motor finance sectors. #### Key risks - **Regulatory Exposure:** Issue escalation from individual complaints directly to industry-wide FCA scrutiny via the new referral mechanism. - **Misaligned Interpretations:** Over-reliance on a rigid, literal reading of FCA rules rather than aligning internal procedures with the regulator's broader intent. - **Escalation Risk:** Failure to identify and resolve systemic product or customer issues early, before they trigger mass redress actions. #### Actions to take 1. **Reassess Complaints Frameworks:** Evaluate how your complaints-handling processes align with the spirit and intent of FCA regulations. 2. **Document Policy Interpretations:** Evidence and document the regulatory rationale behind internal policy decisions and product terms. 3. **Strengthen Feedback Loops:** Ensure tight integration between complaints data, conduct risk monitoring, and board-level oversight. #### Wider implications The closer alignment between the FOS and FCA signifies a more integrated regulatory regime. Individual complaints can now quickly scale into regulatory scrutiny, meaning compliance and complaints departments can no longer operate in isolation. #### Recommendations Firms should commission independent reviews of their complaint-handling, governance, and conduct risk frameworks to ensure they will withstand the structured oversight of the reformed FOS. TCC supports firms in assessing how their current complaint-handling, governance and conduct frameworks will stand up to regulatory scrutiny – and help to ensure compliant delivery. As the role of the FOS becomes more clearly defined and FCA-aligned, seeking external expertise is a prudent step.   #### Supporting sources - [Review of the Financial Ombudsman Service Consultation response](https://assets.publishing.service.gov.uk/media/6a0dc69b5c3c79da61662e28/Consultation_Response_-_FOS_Reform_Updated_May_26.pdf) (2026-05-08) #### Are your complaints frameworks ready for FOS reform? Speak to our compliance advisory team to audit your current frameworks and align your complaints handling with regulatory intent. [Get in touch](https://tcc.group/talk-to-us/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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'fair and reasonable' test, and learn how to prepare your firm's complaint-handling frameworks.", "inLanguage": "en-GB", "articleBody": "The UK government has announced plans to reform the Financial Ombudsman Service, narrowing its discretion under the 'fair and reasonable' test and establishing a formal FCA referral process.\n\nFollowing a major public consultation with over 600 respondents, the UK government has set out plans to reform the Financial Ombudsman Service (FOS). The reforms aim to bring greater clarity and predictability to consumers and firms by introducing significant structural and legislative changes to FOS processes.\n\nKey legislative proposals include revising the FOS's 'fair and reasonable' test, creating a formal referral process back to the FCA for rule interpretation, establishing a ten-year absolute time limit for complaints, and empowering the FCA to better manage mass redress events.\n\nFor years, the 'fair and reasonable' test granted the FOS wide discretion, letting it bypass strict rule compliance to focus on broader interpretations of fairness, which created unpredictability for firms. The proposed reforms narrow this discretion; if a firm complies with relevant FCA rules, the FOS will normally be required to find that it acted reasonably.\r\n\r\nHowever, this is not a pure rules-based shift. Firms must still act in line with regulatory intent, and the FOS will apply its test within a tighter, more structured framework. A formal referral mechanism also means the FOS must refer ambiguous rules back to the FCA, cementing the regulator as the sole authority on rule interpretation.\n\nThese reforms direct impact all regulated UK financial services firms, their complaints teams, risk management committees, and legal departments. The changes apply across wealth management, lending, general insurance, and motor finance sectors.\n\n\u2022 Regulatory Exposure: Issue escalation from individual complaints directly to industry-wide FCA scrutiny via the new referral mechanism.\n\u2022 Misaligned Interpretations: Over-reliance on a rigid, literal reading of FCA rules rather than aligning internal procedures with the regulator's broader intent.\n\u2022 Escalation Risk: Failure to identify and resolve systemic product or customer issues early, before they trigger mass redress actions.\n\n1. Reassess Complaints Frameworks: Evaluate how your complaints-handling processes align with the spirit and intent of FCA regulations.\n2. Document Policy Interpretations: Evidence and document the regulatory rationale behind internal policy decisions and product terms.\n3. Strengthen Feedback Loops: Ensure tight integration between complaints data, conduct risk monitoring, and board-level oversight.\n\nThe closer alignment between the FOS and FCA signifies a more integrated regulatory regime. Individual complaints can now quickly scale into regulatory scrutiny, meaning compliance and complaints departments can no longer operate in isolation.\n\nFirms should commission independent reviews of their complaint-handling, governance, and conduct risk frameworks to ensure they will withstand the structured oversight of the reformed FOS.\n\nTCC supports firms\u00a0in assessing how their current\u00a0complaint-handling, governance\u00a0and conduct frameworks will stand up to\u00a0regulatory\u00a0scrutiny\u00a0\u2013 and help to ensure\u00a0compliant\u00a0delivery. As the role of the FOS becomes more clearly defined and\u00a0FCA-aligned, seeking external\u00a0expertise\u00a0is a prudent step.\u00a0\u00a0", "wordCount": 474, "keywords": [ "Complaints & Claims Handling", "Compliance AI & RegTech", "Regulatory Change & Transformation", "Section 166, Skilled Person Reviews & FCA Intervention", "Banking", "General Insurance & Protection", "Lending & Consumer Credit", "Motor Finance", "Payments & FinTech", "Pensions & Retirement Income", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Complaints & Claims Handling", "url": "https://tcc.group/blog/solution/complaints-claims-handling/" }, { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Regulatory Change & Transformation", "url": "https://tcc.group/blog/solution/regulatory-change-transformation/" }, { "@type": "Thing", "name": "Section 166, Skilled Person Reviews & FCA Intervention", "url": "https://tcc.group/blog/solution/section-166-skilled-person-reviews-fca-intervention/" }, { "@type": "Thing", "name": "Banking", "url": "https://tcc.group/blog/sector/banking/" }, { "@type": "Thing", "name": "General Insurance & Protection", "url": "https://tcc.group/blog/sector/general-insurance-protection/" }, { "@type": "Thing", "name": "Lending & Consumer Credit", "url": "https://tcc.group/blog/sector/lending-consumer-credit/" }, { "@type": "Thing", "name": "Motor Finance", "url": "https://tcc.group/blog/sector/motor-finance/" }, { "@type": "Thing", "name": "Payments & FinTech", "url": "https://tcc.group/blog/sector/payments-fintech/" }, { "@type": "Thing", "name": "Pensions & Retirement Income", "url": "https://tcc.group/blog/sector/pensions-retirement-income/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "FOS Reforms" } ], "articleSection": [ "Complaints & Claims Handling", "Compliance AI & RegTech", "Regulatory Change & Transformation", "Section 166, Skilled Person Reviews & FCA Intervention" ], "audience": [ { "@type": "Audience", "audienceType": "Banking" }, { "@type": "Audience", "audienceType": "General Insurance & Protection" }, { "@type": "Audience", "audienceType": "Lending & Consumer Credit" }, { "@type": "Audience", "audienceType": "Motor Finance" }, { "@type": "Audience", "audienceType": "Payments & FinTech" }, { "@type": "Audience", "audienceType": "Pensions & Retirement Income" }, { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Heads of compliance, complaints managers, and legal counsel at all regulated financial services firms." } ], "citation": [ { "@type": "CreativeWork", "name": "Review of the Financial Ombudsman Service Consultation response", "url": "https://assets.publishing.service.gov.uk/media/6a0dc69b5c3c79da61662e28/Consultation_Response_-_FOS_Reform_Updated_May_26.pdf", "datePublished": "2026-05-08" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/regulatory-horizon/how-fos-reforms-will-affect-financial-services-firms/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/how-fos-reforms-will-affect-financial-services-firms/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "How will the FOS 'fair and reasonable' test change?", "acceptedAnswer": { "@type": "Answer", "text": "The FOS's discretion is being narrowed. If a firm complies with relevant FCA rules, the FOS will normally be required to conclude that the firm acted fairly and reasonably, reducing unpredictability for firms." } }, { "@type": "Question", "name": "What is the new referral process between FOS and FCA?", "acceptedAnswer": { "@type": "Answer", "text": "Where there is uncertainty about rule interpretation, the FOS will be required to refer those questions back to the FCA, ensuring the FCA remains the primary authority on regulatory intent." } } ] } ] } ``` ### Always Finance News: AI in financial services - URL: https://tcc.group/insights/analysis-perspectives/always-finance-news-ai-in-financial-services-where-the-real-challenges-are-starting-to-emerge/ - Published: 2026-05-07 - Modified: 2026-09-03 **Topic:** AI data governance challenges Joe Norburn, CEO of TCC Group, explains that AI is now widely embedded in financial services, but the key challenge has shifted from adoption to ensuring underlying data is reliable, explainable and auditable. #### What happened? As featured in [Always Finance News](https://alwaysfinance.co.uk/2026/05/01/ai-in-financial-services-where-the-real-challenges-are-starting-to-emerge/), Joe Norburn, CEO of TCC Group, said AI is now widely embedded across financial services, from fraud detection to customer onboarding and credit assessments. While firms have adopted AI to improve efficiency and decision-making, regulators such as the FCA are increasing their focus on governance, accountability and operational resilience as AI becomes more deeply integrated into core processes. #### Why does it matter? Norburn said the main challenge is no longer adopting AI, but ensuring the underlying data is reliable, explainable and auditable. Generative AI tools can process and summarise information effectively, but often struggle to meet regulatory expectations for traceability and oversight. “Inside firms, the conversation is shifting,” Norburn said. “Earlier discussions around AI focused heavily on opportunity. Those conversations have not disappeared, but they now sit alongside more practical concerns about control, governance and accountability.” #### Who is affected? The analysis is relevant to firms using AI in fraud detection, customer onboarding and credit assessment across banking, lending, payments and fintech, wealth management, pensions, general insurance and motor finance. #### Wider implications Norburn notes that purpose-built AI models built on trusted, structured data are helping firms deliver more accurate predictions, reliable reporting and transparent insights that can be clearly traced and explained to regulators, in contrast to generative tools that can struggle with traceability. #### Recommendations Firms moving from opportunity-led AI discussions to control and governance should prioritise data quality and traceability alongside efficiency gains. #### Supporting sources - [Always Finance News: AI in financial services](https://alwaysfinance.co.uk/2026/05/01/ai-in-financial-services-where-the-real-challenges-are-starting-to-emerge/) (2026-05-08) - Reviewed by: [Joe Norburn](https://tcc.group/meet-the-team/), CEO - TCC Group #### Need support governing AI data quality? Get in touch to discuss how we help firms build reliable, explainable and auditable AI processes. [Get in touch](https://tcc.group/talk-to-us/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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"https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/4e57a6d3754f44aab789fcaefa0db44b/thumbnail-1024-c6402e2479b75cd2e92695ae340df8b7ccdae7eb7b2412974de4876f01d3dab7.jpg", "description": "Joe Norburn explains why the real challenge in financial services AI is no longer adoption but ensuring data is reliable, explainable and auditable enough to satisfy regulators.", "inLanguage": "en-GB", "articleBody": "Joe Norburn, CEO of TCC Group, explains that AI is now widely embedded in financial services, but the key challenge has shifted from adoption to ensuring underlying data is reliable, explainable and auditable.\n\nAs featured in Always Finance News, Joe Norburn, CEO of TCC Group, said AI is now widely embedded across financial services, from fraud detection to customer onboarding and credit assessments.\n\nWhile firms have adopted AI to improve efficiency and decision-making, regulators such as the FCA are increasing their focus on governance, accountability and operational 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TCC Group", "url": "/meet-the-team/" } }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/analysis-perspectives/always-finance-news-ai-in-financial-services-where-the-real-challenges-are-starting-to-emerge/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/always-finance-news-ai-in-financial-services-where-the-real-challenges-are-starting-to-emerge/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What does Joe Norburn say is the main AI challenge now?", "acceptedAnswer": { "@type": "Answer", "text": "He says the challenge is no longer adopting AI, but ensuring the underlying data is reliable, explainable and auditable." } }, { "@type": "Question", "name": "Why can generative AI tools be a regulatory concern?", "acceptedAnswer": { "@type": "Answer", "text": "Generative AI tools can process and summarise information effectively but often struggle to meet regulatory expectations for traceability and oversight." } }, { "@type": "Question", "name": "What alternative does the analysis point to?", "acceptedAnswer": { "@type": "Answer", "text": "Purpose-built AI models trained on trusted, structured data are described as helping firms deliver more accurate, transparent and traceable outcomes." } } ] } ] } ``` ### Motor finance redress scheme meets resistance - URL: https://tcc.group/insights/regulatory-horizon/motor-finance-redress-scheme-meets-resistance/ - Published: 2026-05-06 - Modified: 2026-09-03 **Topic:** Motor Finance Redress Challenge The FCA's proposed motor finance redress scheme is now facing four legal challenges, from a consumer representative body and three lenders, introducing uncertainty over timing while the regulator maintains its preferred industry-wide approach. #### What happened? The Financial Conduct Authority (FCA) has confirmed that its [proposed motor finance redress scheme](https://www.fca.org.uk/news/statements/fca-statement-legal-challenges-motor-finance-scheme) is now subject to legal challenge. The regulator says it has received four claims: one from Consumer Voice, represented by Courmacs Legal Ltd, and three from lenders, including Volkswagen Financial Services, Mercedes-Benz Financial Services and Crédit Agricole Auto Finance. The FCA has reiterated that an industry-wide approach remains, in its view, the most effective way to deliver compensation, describing it as the option most likely to be quick, fair and efficient for consumers. #### Why does it matter? The existence of legal challenges introduces a degree of uncertainty for firms and consumers alike. The FCA has acknowledged that this could delay payments and extend the timeframe for resolution, and that prolonged uncertainty is not helpful for investment or wider market stability. The regulator's core position has not shifted: it intends to defend the scheme and continues to see a coordinated, market-wide solution as the best way to address an issue of this scale. It has indicated it is considering its next steps and will provide further updates in the near term. #### Who is affected? Motor finance lenders, including those named in the legal challenges, and firms across the wider motor finance and consumer credit sectors that may be brought within the scope of a future scheme. #### Key risks - Delayed compensation payments to affected consumers. - An extended and less predictable timeframe for resolution. - Wider market uncertainty that may affect investment decisions. #### Actions to take 1. Continue readiness work on data integrity, governance and complaint handling, since the shape of the scheme is largely settled even if timing is not. 2. Monitor FCA updates closely, as the regulator has indicated further announcements are expected shortly. 3. Review governance arrangements so that decisions on scheme readiness can be evidenced if challenged. #### Wider implications For firms, this is a familiar position in large-scale remediation exercises: a defined regulatory intent, but with some uncertainty around timing and execution as external factors, such as litigation, play out. #### Recommendations Firms should treat the legal challenge as a reason to maintain, rather than pause, their preparation. Readiness around data, governance and complaint handling remains the key differentiator between firms that can respond quickly once the scheme is confirmed and those that cannot. #### Supporting sources - [Motor finance redress scheme meets resistance](https://www.fca.org.uk/news/statements/fca-statement-legal-challenges-motor-finance-scheme) (2026-05-07) #### Preparing for the motor finance redress scheme? TCC supports motor finance firms preparing for large-scale redress, from data readiness to complaint handling and governance. [Get in touch](https://tcc.group/talk-to-us/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/insights/regulatory-horizon/motor-finance-redress-scheme-meets-resistance/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Insights", "item": "https://tcc.group/insights/" }, { "@type": "ListItem", "position": 3, "name": "Motor finance redress scheme meets resistance", "item": "https://tcc.group/insights/regulatory-horizon/motor-finance-redress-scheme-meets-resistance/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/regulatory-horizon/motor-finance-redress-scheme-meets-resistance/#webpage", "url": "https://tcc.group/insights/regulatory-horizon/motor-finance-redress-scheme-meets-resistance/", "name": "Motor finance redress scheme meets resistance", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-05-07T00:00:00+01:00", "dateModified": "2026-09-03T14:21:08+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/regulatory-horizon/motor-finance-redress-scheme-meets-resistance/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "NewsArticle", "@id": "https://tcc.group/insights/regulatory-horizon/motor-finance-redress-scheme-meets-resistance/#article", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/motor-finance-redress-scheme-meets-resistance/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "Motor finance redress scheme meets resistance", "datePublished": "2026-05-07T00:00:00+01:00", "dateModified": "2026-09-03T14:21:08+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/regulatory-horizon/motor-finance-redress-scheme-meets-resistance/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/e56812a4133143d39acd781fbf33819f/thumbnail-1024-c4877b58a74b2b6283103313b1c994909cb55db85eaa9f8dbd125717163bd989.jpg", "description": "The FCA's motor finance redress scheme faces four legal challenges from a consumer group and three lenders. Here's what the challenge means for timing, market stability and how firms should keep preparing.", "inLanguage": "en-GB", "articleBody": "The FCA's proposed motor finance redress scheme is now facing four legal challenges, from a consumer representative body and three lenders, introducing uncertainty over timing while the regulator maintains its preferred industry-wide approach.\n\nThe Financial Conduct Authority (FCA) has confirmed that its proposed motor finance redress scheme is now subject to legal challenge. The regulator says it has received four claims: one from Consumer Voice, represented by Courmacs Legal Ltd, and three from lenders, including Volkswagen Financial Services, Mercedes-Benz Financial Services and Cr\u00e9dit Agricole Auto Finance.\n\nThe FCA has reiterated that an industry-wide approach remains, in its view, the most effective way to deliver compensation, describing it as the option most likely to be quick, fair and efficient for consumers.\n\nThe existence of legal challenges introduces a degree of uncertainty for firms and consumers alike. The FCA has acknowledged that this could delay payments and extend the timeframe for resolution, and that prolonged uncertainty is not helpful for investment or wider market stability.\r\n\r\nThe regulator's core position has not shifted: it intends to defend the scheme and continues to see a coordinated, market-wide solution as the best way to address an issue of this scale. It has indicated it is considering its next steps and will provide further updates in the near term.\n\nMotor finance lenders, including those named in the legal challenges, and firms across the wider motor finance and consumer credit sectors that may be brought within the scope of a future scheme.\n\n\u2022 Delayed compensation payments to affected consumers.\n\u2022 An extended and less predictable timeframe for resolution.\n\u2022 Wider market uncertainty that may affect investment decisions.\n\n1. Continue readiness work on data integrity, governance and complaint handling, since the shape of the scheme is largely settled even if timing is not.\n2. Monitor FCA updates closely, as the regulator has indicated further announcements are expected shortly.\n3. Review governance arrangements so that decisions on scheme readiness can be evidenced if challenged.\n\nFor firms, this is a familiar position in large-scale remediation exercises: a defined regulatory intent, but with some uncertainty around timing and execution as external factors, such as litigation, play out.\n\nFirms should treat the legal challenge as a reason to maintain, rather than pause, their preparation. Readiness around data, governance and complaint handling remains the key differentiator between firms that can respond quickly once the scheme is confirmed and those that cannot.", "wordCount": 398, "keywords": [ "Complaints & Claims Handling", "Compliance AI & RegTech", "Redress & Remediation", "Regulatory Change & Transformation", "Lending & Consumer Credit", "Motor Finance" ], "about": [ { "@type": "Thing", "name": "Complaints & Claims Handling", "url": "https://tcc.group/blog/solution/complaints-claims-handling/" }, { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Redress & Remediation", "url": "https://tcc.group/blog/solution/redress-and-remediation/" }, { "@type": "Thing", "name": "Regulatory Change & Transformation", "url": "https://tcc.group/blog/solution/regulatory-change-transformation/" }, { "@type": "Thing", "name": "Lending & Consumer Credit", "url": "https://tcc.group/blog/sector/lending-consumer-credit/" }, { "@type": "Thing", "name": "Motor Finance", "url": "https://tcc.group/blog/sector/motor-finance/" }, { "@type": "Thing", "name": "Motor Finance Redress Challenge" } ], "articleSection": [ "Complaints & Claims Handling", "Compliance AI & RegTech", "Redress & Remediation", "Regulatory Change & Transformation" ], "audience": [ { "@type": "Audience", "audienceType": "Lending & Consumer Credit" }, { "@type": "Audience", "audienceType": "Motor Finance" }, { "@type": "Audience", "audienceType": "Compliance and risk leaders at motor finance lenders and their advisers." } ], "citation": [ { "@type": "CreativeWork", "name": "Motor finance redress scheme meets resistance", "url": "https://www.fca.org.uk/news/statements/fca-statement-legal-challenges-motor-finance-scheme", "datePublished": "2026-05-07" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/regulatory-horizon/motor-finance-redress-scheme-meets-resistance/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/motor-finance-redress-scheme-meets-resistance/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "Why is the FCA's motor finance redress scheme being challenged?", "acceptedAnswer": { "@type": "Answer", "text": "The FCA has received four legal claims against its proposed scheme, one from consumer group Consumer Voice and three from lenders including Volkswagen Financial Services, Mercedes-Benz Financial Services and Cr\u00e9dit Agricole Auto Finance." } }, { "@type": "Question", "name": "Will the legal challenges delay the redress scheme?", "acceptedAnswer": { "@type": "Answer", "text": "The FCA has acknowledged that the challenges could delay payments to some consumers and extend the timeframe for resolution, though it intends to defend the scheme." } }, { "@type": "Question", "name": "Has the FCA changed its approach because of the challenges?", "acceptedAnswer": { "@type": "Answer", "text": "No. The regulator's position remains that an industry-wide, coordinated scheme is the best way to address the issue, and it continues to defend that approach." } }, { "@type": "Question", "name": "What should motor finance firms do while the challenge is resolved?", "acceptedAnswer": { "@type": "Answer", "text": "Firms should continue preparing for the scheme, focusing on data integrity, governance and complaint handling, since the framework is largely established even though timing may shift." } } ] } ] } ``` ### Ongoing advice: Navigating the FCA's areas of focus - URL: https://tcc.group/insights/analysis-perspectives/money-marketing-joe-norburn-ongoing-advice-and-the-fcas-areas-of-focus/ - Published: 2026-05-06 - Modified: 2026-09-02 ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC 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Regulatory Priorities report and its consultation on simplified advice signal a shift towards proportionate, evidence-based supervision. For ongoing advice services, that means firms must show how their model continues to meet client needs and deliver fair value. #### What happened? The FCA has replaced more than [40 portfolio letters with nine Regulatory Priorities reports](https://www.fca.org.uk/publication/regulatory-priorities/consumer-investments-report.pdf) addressed directly to boards and chief executives, setting out a single, coherent view of its supervisory focus. The Consumer Investments report frames sector success as engagement, education and long-term thinking rather than risk avoidance. Alongside this, the FCA is consulting on simplifying pensions and investment advice, proposing greater use of simplified, individualised advice for consumers with more straightforward needs, to sit alongside comprehensive advice and targeted support. #### Why does it matter? In a Consumer Duty environment, ongoing advice can no longer be justified by tradition or routine. The FCA's priorities make clear that supervision is increasingly focused on whether services continue to meet evolving client needs, deliver fair value and adapt as circumstances change. Many ongoing advice models were designed for a different regulatory era, with fixed annual reviews and standardised service definitions once treated as sufficient evidence of good practice. Those features are now being re-examined against actual client behaviour, outcome data and evidence of responsiveness. #### Who is affected? The changes are most relevant to wealth management and financial advice firms that offer ongoing advice services, particularly those relying on fixed review cycles or standardised service definitions rather than client-specific triggers. #### Key risks - Ongoing advice justified by habit or inherited structure rather than evidenced client benefit. - Fair value assessments treated as periodic exercises rather than dynamic ones. - Gaps between formal reviews where changes in client circumstances, vulnerability or risk tolerance go unnoticed. - Governance and monitoring frameworks that exist on paper but do not feed back into service design. #### Actions to take 1. Review how the firm decides when ongoing engagement is genuinely required, rather than defaulting to fixed cycles. 2. Test whether fair value assessments are updated dynamically as client engagement and circumstances change. 3. Strengthen how changes in client circumstances between formal reviews are identified and addressed. 4. Ensure outcome monitoring, complaints and disengagement data feed back into decisions about service structure. #### Wider implications The FCA is not seeking to discourage innovation or constrain access to advice; it is testing whether firms can deliver more flexible, proportionate services while still evidencing good consumer outcomes. Firms that can explain why their model works, for whom and with what safeguards are generally finding supervision constructive. #### Recommendations Firms should reframe ongoing advice around outcomes rather than activities, use triggers and data to inform engagement, and treat fair value assessments as a continuous discipline rather than a periodic report. #### Supporting sources - [Regulatory Priorities consumer investments](https://www.fca.org.uk/publication/regulatory-priorities/consumer-investments-report.pdf) (2026-04-27) - [Regulatory Priorities reports](https://www.fca.org.uk/about/supervision/regulatory-priorities) #### Ready for the ongoing advice evidencing test? Talk to us about Consumer Duty gap assessments and fair value reviews for ongoing advice services. [Get in touch](https://tcc.group/talk-to-us/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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"https://tcc.group/insights/regulatory-horizon/why-ongoing-advice-is-facing-a-regulatory-reset/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "Why ongoing advice is facing a regulatory reset", "datePublished": "2026-04-27T00:00:00+01:00", "dateModified": "2026-09-03T14:26:05+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/regulatory-horizon/why-ongoing-advice-is-facing-a-regulatory-reset/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/cc3af513ea8143d1bb2e6105ecc1446f/thumbnail-1600-fdfe2dcf988494d29aa8490320ee1b0f9b53bc325a0ab21a9f364585e5c0a71a.png", "description": "See why the FCA's new regulatory priorities push ongoing advice into an evidencing phase, and what firms need to demonstrate about fair value, client engagement and outcomes to withstand closer supervisory scrutiny.", "inLanguage": "en-GB", "articleBody": "The FCA's new Consumer Investments Regulatory Priorities report and its consultation on simplified advice signal a shift towards proportionate, evidence-based supervision. For ongoing advice services, that means firms must show how their model continues to meet client needs and deliver fair value.\n\nThe FCA has replaced more than 40 portfolio letters with nine Regulatory Priorities reports addressed directly to boards and chief executives, setting out a single, coherent view of its supervisory focus. The Consumer Investments report frames sector success as engagement, education and long-term thinking rather than risk avoidance.\n\nAlongside this, the FCA is consulting on simplifying pensions and investment advice, proposing greater use of simplified, individualised advice for consumers with more straightforward needs, to sit alongside comprehensive advice and targeted support.\n\nIn a Consumer Duty environment, ongoing advice can no longer be justified by tradition or routine. The FCA's priorities make clear that supervision is increasingly focused on whether services continue to meet evolving client needs, deliver fair value and adapt as circumstances change.\r\n\r\nMany ongoing advice models were designed for a different regulatory era, with fixed annual reviews and standardised service definitions once treated as sufficient evidence of good practice. Those features are now being re-examined against actual client behaviour, outcome data and evidence of responsiveness.\n\nThe changes are most relevant to wealth management and financial advice firms that offer ongoing advice services, particularly those relying on fixed review cycles or standardised service definitions rather than client-specific triggers.\n\n\u2022 Ongoing advice justified by habit or inherited structure rather than evidenced client benefit.\n\u2022 Fair value assessments treated as periodic exercises rather than dynamic ones.\n\u2022 Gaps between formal reviews where changes in client circumstances, vulnerability or risk tolerance go unnoticed.\n\u2022 Governance and monitoring frameworks that exist on paper but do not feed back into service design.\n\n1. Review how the firm decides when ongoing engagement is genuinely required, rather than defaulting to fixed cycles.\n2. Test whether fair value assessments are updated dynamically as client engagement and circumstances change.\n3. Strengthen how changes in client circumstances between formal reviews are identified and addressed.\n4. Ensure outcome monitoring, complaints and disengagement data feed back into decisions about service structure.\n\nThe FCA is not seeking to discourage innovation or constrain access to advice; it is testing whether firms can deliver more flexible, proportionate services while still evidencing good consumer outcomes. Firms that can explain why their model works, for whom and with what safeguards are generally finding supervision constructive.\n\nFirms should reframe ongoing advice around outcomes rather than activities, use triggers and data to inform engagement, and treat fair value assessments as a continuous discipline rather than a periodic report.", "wordCount": 442, "keywords": [ "Compliance AI & RegTech", "Consumer Duty", "Regulatory Change & Transformation", "Suitability, Advice Quality & File Reviews", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Consumer Duty", "url": "https://tcc.group/blog/solution/consumer-duty/" }, { "@type": "Thing", "name": "Regulatory Change & Transformation", "url": "https://tcc.group/blog/solution/regulatory-change-transformation/" }, { "@type": "Thing", "name": "Suitability, Advice Quality & File Reviews", "url": "https://tcc.group/blog/solution/outsourced-suitability-reviews/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Ongoing Advice & Consumer Duty" } ], "articleSection": [ "Compliance AI & RegTech", "Consumer Duty", "Regulatory Change & Transformation", "Suitability, Advice Quality & File Reviews" ], "audience": [ { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Wealth management and financial advice firms that provide ongoing advice services." } ], "citation": [ { "@type": "CreativeWork", "name": "Regulatory Priorities consumer investments", "url": "https://www.fca.org.uk/publication/regulatory-priorities/consumer-investments-report.pdf", "datePublished": "2026-04-27" }, { "@type": "CreativeWork", "name": "Regulatory Priorities reports", "url": "https://www.fca.org.uk/about/supervision/regulatory-priorities" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/regulatory-horizon/why-ongoing-advice-is-facing-a-regulatory-reset/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/why-ongoing-advice-is-facing-a-regulatory-reset/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What are the FCA's new Regulatory Priorities reports?", "acceptedAnswer": { "@type": "Answer", "text": "They are nine reports that replace more than 40 portfolio letters, giving firms a single, coherent view of the FCA's supervisory focus for their sector." } }, { "@type": "Question", "name": "Why is ongoing advice under closer scrutiny?", "acceptedAnswer": { "@type": "Answer", "text": "Because the FCA wants evidence that services continue to meet client needs and deliver fair value, rather than relying on fixed review cycles as a proxy for good practice." } }, { "@type": "Question", "name": "What is the FCA proposing for simplified advice?", "acceptedAnswer": { "@type": "Answer", "text": "The FCA is consulting on greater use of simplified, individualised advice for consumers with straightforward needs, alongside existing comprehensive advice and targeted support." } }, { "@type": "Question", "name": "What should firms do to prepare?", "acceptedAnswer": { "@type": "Answer", "text": "Firms should evidence how their ongoing advice model identifies client needs, assesses fair value dynamically and adapts based on outcome data." } } ] } ] } ``` ### FCA Consumer Understanding: compliance next steps - URL: https://tcc.group/insights/regulatory-horizon/fca-consumer-understanding-moving-from-good-intentions-to-regulator-ready-evidence/ - Published: 2026-04-23 - Modified: 2026-09-03 **Topic:** Consumer Understanding Guidance The FCA's publication on Consumer Understanding emphasizes that firms must move beyond design intent and actively evidence customer comprehension using robust management information and real-world testing. #### What happened? The Financial Conduct Authority (FCA) has published a [comprehensive guidance document](https://www.fca.org.uk/publications/good-and-poor-practice/consumer-understanding-good-practice-areas-improvement), 'Consumer Understanding: good practice and areas for improvement'. This publication highlights that firms can no longer rely on good intentions; they must actively gather robust evidence of customer comprehension across communications and journeys. Good practice firms are those demonstrating an end-to-end control loop: identifying where customers struggle, testing materials with real consumers, making changes, and continually monitoring outcomes. #### Why does it matter? Under the Consumer Duty, the regulator expects firms to actively test communications before and after implementation, rather than relying on proxy indicators like sales volume or the absence of complaints. This shift requires integrating rich, diverse sources of management information to detect consumer friction. Furthermore, vulnerability is a major regulatory concern. Accessibility and tailored communication formats must be integrated into core testing and design, rather than treated as late-stage exceptions. #### Who is affected? All FCA-regulated retail financial services firms, including wealth managers, banks, lenders, insurers, and fintech platforms, are directly affected by these elevated evidence requirements. #### Key risks Firms are exposed to major compliance and enforcement risks if they fail to generate robust proof of understanding: - FCA regulatory action for relying on unproven assumptions about what customers understand. - Critical gaps in senior management oversight and SM&CR accountability due to lack of meaningful, outcome-focused MI. - Failing to support vulnerable customer groups, leading to systemic breaches of the Consumer Duty. #### Actions to take Firms should take immediate, structured steps to align with the FCA's guidance: 1. Conduct a comprehensive review of existing MI sources, integrating call listening, web drop-off rates, and drop-out data. 2. Introduce pre- and post-launch testing of customer communications with representative consumer panels. 3. Embed accessibility and vulnerability considerations directly into product design, testing, and oversight. #### Wider implications The regulator is demanding a shift from tick-box compliance to defensible, outcomes-focused delivery. Governance frameworks must document exactly how customer understanding is evaluated and how insights drive continuous journey improvements. #### Recommendations We recommend engaging independent advisory reviews to benchmark your current consumer understanding MI and testing methodologies against the FCA's good practice standards. #### Supporting sources - [Consumer understanding: good practice and areas for improvement](https://www.fca.org.uk/publications/good-and-poor-practice/consumer-understanding-good-practice-areas-improvement) (2026-04-24) #### Can you prove your customers truly understand? Contact our Consumer Duty experts today to assess your testing frameworks and build a regulator-ready evidence package. [Get in touch](https://tcc.group/talk-to-us/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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"NewsArticle", "@id": "https://tcc.group/insights/regulatory-horizon/fca-consumer-understanding-moving-from-good-intentions-to-regulator-ready-evidence/#article", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/fca-consumer-understanding-moving-from-good-intentions-to-regulator-ready-evidence/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "FCA Consumer Understanding: compliance next steps", "datePublished": "2026-04-24T00:00:00+01:00", "dateModified": "2026-09-03T14:35:00+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/regulatory-horizon/fca-consumer-understanding-moving-from-good-intentions-to-regulator-ready-evidence/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/e47f70a20f6d4c4f8ed6645976334cc0/thumbnail-1024-da7c4d040d70563fe8789b0387a210a608f22f1f194334e9c52c2faf357695e7.jpg", "description": "FCA's latest consumer understanding guidance warns firms that compliance is judged on proven outcomes rather than design intent. Discover the key takeaways and how to build robust, regulator-ready evidence.", "inLanguage": "en-GB", "articleBody": "The FCA's publication on Consumer Understanding emphasizes that firms must move beyond design intent and actively evidence customer comprehension using robust management information and real-world testing.\n\nThe Financial Conduct Authority (FCA) has published a comprehensive guidance document, 'Consumer Understanding: good practice and areas for improvement'. This publication highlights that firms can no longer rely on good intentions; they must actively gather robust evidence of customer comprehension across communications and journeys.\n\nGood practice firms are those demonstrating an end-to-end control loop: identifying where customers struggle, testing materials with real consumers, making changes, and continually monitoring outcomes.\n\nUnder the Consumer Duty, the regulator expects firms to actively test communications before and after implementation, rather than relying on proxy indicators like sales volume or the absence of complaints. This shift requires integrating rich, diverse sources of management information to detect consumer friction.\r\n\r\nFurthermore, vulnerability is a major regulatory concern. Accessibility and tailored communication formats must be integrated into core testing and design, rather than treated as late-stage exceptions.\n\nAll FCA-regulated retail financial services firms, including wealth managers, banks, lenders, insurers, and fintech platforms, are directly affected by these elevated evidence requirements.\n\nFirms are exposed to major compliance and enforcement risks if they fail to generate robust proof of understanding:\n\u2022 FCA regulatory action for relying on unproven assumptions about what customers understand.\n\u2022 Critical gaps in senior management oversight and SM&CR accountability due to lack of meaningful, outcome-focused MI.\n\u2022 Failing to support vulnerable customer groups, leading to systemic breaches of the Consumer Duty.\n\nFirms should take immediate, structured steps to align with the FCA's guidance:\n1. Conduct a comprehensive review of existing MI sources, integrating call listening, web drop-off rates, and drop-out data.\n2. Introduce pre- and post-launch testing of customer communications with representative consumer panels.\n3. Embed accessibility and vulnerability considerations directly into product design, testing, and oversight.\n\nThe regulator is demanding a shift from tick-box compliance to defensible, outcomes-focused delivery. Governance frameworks must document exactly how customer understanding is evaluated and how insights drive continuous journey improvements.\n\nWe recommend engaging independent advisory reviews to benchmark your current consumer understanding MI and testing methodologies against the FCA's good practice standards.", "wordCount": 359, "keywords": [ "Compliance AI & RegTech", "Consumer Duty", "Banking", "General Insurance & Protection", "Lending & Consumer Credit", "Motor Finance", "Payments & FinTech", "Pensions & Retirement Income", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Consumer Duty", "url": "https://tcc.group/blog/solution/consumer-duty/" }, { "@type": "Thing", "name": "Banking", "url": "https://tcc.group/blog/sector/banking/" }, { "@type": "Thing", "name": "General Insurance & Protection", "url": "https://tcc.group/blog/sector/general-insurance-protection/" }, { "@type": "Thing", "name": "Lending & Consumer Credit", "url": "https://tcc.group/blog/sector/lending-consumer-credit/" }, { "@type": "Thing", "name": "Motor Finance", "url": "https://tcc.group/blog/sector/motor-finance/" }, { "@type": "Thing", "name": "Payments & FinTech", "url": "https://tcc.group/blog/sector/payments-fintech/" }, { "@type": "Thing", "name": "Pensions & Retirement Income", "url": "https://tcc.group/blog/sector/pensions-retirement-income/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Consumer Understanding Guidance" } ], "articleSection": [ "Compliance AI & RegTech", "Consumer Duty" ], "audience": [ { "@type": "Audience", "audienceType": "Banking" }, { "@type": "Audience", "audienceType": "General Insurance & Protection" }, { "@type": "Audience", "audienceType": "Lending & Consumer Credit" }, { "@type": "Audience", "audienceType": "Motor Finance" }, { "@type": "Audience", "audienceType": "Payments & FinTech" }, { "@type": "Audience", "audienceType": "Pensions & Retirement Income" }, { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Heads of compliance, customer experience directors, and SM&CR accountable executives across all retail financial services." } ], "citation": [ { "@type": "CreativeWork", "name": "Consumer understanding:\u202fgood practice and areas for improvement", "url": "https://www.fca.org.uk/publications/good-and-poor-practice/consumer-understanding-good-practice-areas-improvement", "datePublished": "2026-04-24" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/regulatory-horizon/fca-consumer-understanding-moving-from-good-intentions-to-regulator-ready-evidence/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/fca-consumer-understanding-moving-from-good-intentions-to-regulator-ready-evidence/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "How does the FCA assess consumer understanding?", "acceptedAnswer": { "@type": "Answer", "text": "The FCA evaluates whether firms actively test communications with real customers, monitor comprehension in real-time, and use robust management information to make continuous improvements." } }, { "@type": "Question", "name": "Why are proxy indicators like low complaints insufficient?", "acceptedAnswer": { "@type": "Answer", "text": "A low number of complaints does not prove that customers understand a product; firms must proactively gather positive evidence of active comprehension and fair outcomes." } } ] } ] } ``` ### What the FCA’s 2026 Regulatory Priorities reports reveal about the direction of supervision - URL: https://tcc.group/insights/regulatory-horizon/what-the-fcas-2026-regulatory-priorities-reports-reveal-about-the-direction-of-supervision/ - Published: 2026-04-23 - Modified: 2026-09-04 **Topic:** FCA Regulatory Priorities reports The FCA has published nine sector Regulatory Priorities reports replacing individual portfolio letters with a single annual reference point. Across every sector the message is consistent: firms must evidence that their frameworks work in practice, not just that they exist on paper. #### What happened? Over recent weeks the FCA has published a full set of Regulatory Priorities reports spanning nine retail and wholesale sectors, replacing dozens of individual portfolio letters with a single annual point of reference for boards and senior management. Insurance focuses on claims handling and evidencing good outcomes across outsourced arrangements; consumer investments on building a stronger investment culture and fair value; pensions on helping consumers plan confidently and improving scheme value for money. Retail banking addresses access to essential services and branch closures; mortgages centre on the Mortgage Rule Review; consumer finance looks at forbearance and affordability; wholesale buy-side, wholesale markets and payments all point to evidence, resilience and third-party oversight. #### Why does it matter? Across all nine reports, the FCA is signalling a move towards more predictable, proportionate supervision, paired with a firmer expectation that firms can evidence how their frameworks operate in practice. The recurring message is that policies, controls and governance documented ‘on paper’ are no longer sufficient; outcomes, data and demonstrable oversight now matter more. For boards, that changes the reports from background commentary into a baseline for evidence, challenge and prioritisation over the year ahead. #### Who is affected? The reports affect firms across all nine sectors named, but the FCA is explicit that boards and senior management, not just compliance functions, are expected to engage with them directly. Firms with outsourced or delegated arrangements, third-party dependencies, or complex product ranges face particular attention given the consistent focus on oversight and evidencing outcomes. #### Key risks - Treating the reports as commentary rather than acting on the ‘what we expect firms to do’ sections. - Relying on documented policies and controls without evidence that they function in practice. - Weak oversight of outsourced, delegated or third-party arrangements. - Boards not engaging directly with sector-specific priorities relevant to their business. #### Actions to take 1. Read the report for your sector and treat the ‘what we expect firms to do’ section as an action list. 2. Review how outcomes are monitored and whether management information supports genuine challenge. 3. Strengthen oversight of third-party and outsourced arrangements where these are flagged. 4. Build or refresh evidence frameworks that can withstand supervisory scrutiny. #### Wider implications The shift to a single annual report per sector suggests the FCA wants supervision to be more predictable and less reliant on ad hoc portfolio letters, but the trade-off is a clearer expectation of evidence. As this evidential discipline becomes standard across sectors, firms that cannot demonstrate how their frameworks operate in practice are likely to face earlier and more focused supervisory attention. #### Recommendations Use each sector report as a structured checklist for self-assessment rather than a one-off read, and revisit it when planning assurance activity for the year. Focus particularly on strengthening how outcomes are monitored and how oversight of third parties and outsourced functions is evidenced, since these themes recur across almost every report. #### Supporting sources - [What the FCA’s 2026 Regulatory Priorities reports reveal about the direction of supervision](https://staging.tcc.group/blog/2026/04/24/what-the-fcas-2026-regulatory-priorities-reports-reveal-about-the-direction-of-supervision/) (2026-04-24) #### Ready to evidence your regulatory priorities? Speak to our team about turning the FCA's priorities into practical governance and evidence frameworks. [Get in touch](https://tcc.group/talk-to-us/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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"SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "NewsArticle", "@id": "https://tcc.group/insights/regulatory-horizon/what-the-fcas-2026-regulatory-priorities-reports-reveal-about-the-direction-of-supervision/#article", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/what-the-fcas-2026-regulatory-priorities-reports-reveal-about-the-direction-of-supervision/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "What the FCA\u2019s 2026 Regulatory Priorities reports reveal about the direction of supervision", "datePublished": "2026-04-24T00:00:00+01:00", "dateModified": "2026-09-04T10:25:58+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/regulatory-horizon/what-the-fcas-2026-regulatory-priorities-reports-reveal-about-the-direction-of-supervision/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/84a1cf76bc564987afd9a12728677929/thumbnail-1024-0a7e457d26c87d23dfd19a0001c5148e8a72c38364ed1e4948102fa8e8f80538.jpg", "description": "See what the FCA's nine 2026 Regulatory Priorities reports reveal across insurance, pensions, banking and more, and learn why boards should treat them as an evidence-based action agenda rather than background reading.", "inLanguage": "en-GB", "articleBody": "The FCA has published nine sector Regulatory Priorities reports replacing individual portfolio letters with a single annual reference point. Across every sector the message is consistent: firms must evidence that their frameworks work in practice, not just that they exist on paper.\n\nOver recent weeks the FCA has published a full set of Regulatory Priorities reports spanning nine retail and wholesale sectors, replacing dozens of individual portfolio letters with a single annual point of reference for boards and senior management.\r\n\r\nInsurance focuses on claims handling and evidencing good outcomes across outsourced arrangements; consumer investments on building a stronger investment culture and fair value; pensions on helping consumers plan confidently and improving scheme value for money.\r\n\r\nRetail banking addresses access to essential services and branch closures; mortgages centre on the Mortgage Rule Review; consumer finance looks at forbearance and affordability; wholesale buy-side, wholesale markets and payments all point to evidence, resilience and third-party oversight.\n\nAcross all nine reports, the FCA is signalling a move towards more predictable, proportionate supervision, paired with a firmer expectation that firms can evidence how their frameworks operate in practice.\r\n\r\nThe recurring message is that policies, controls and governance documented \u2018on paper\u2019 are no longer sufficient; outcomes, data and demonstrable oversight now matter more.\r\n\r\nFor boards, that changes the reports from background commentary into a baseline for evidence, challenge and prioritisation over the year ahead.\n\nThe reports affect firms across all nine sectors named, but the FCA is explicit that boards and senior management, not just compliance functions, are expected to engage with them directly.\r\n\r\nFirms with outsourced or delegated arrangements, third-party dependencies, or complex product ranges face particular attention given the consistent focus on oversight and evidencing outcomes.\n\n\u2022 Treating the reports as commentary rather than acting on the \u2018what we expect firms to do\u2019 sections.\n\u2022 Relying on documented policies and controls without evidence that they function in practice.\n\u2022 Weak oversight of outsourced, delegated or third-party arrangements.\n\u2022 Boards not engaging directly with sector-specific priorities relevant to their business.\n\n1. Read the report for your sector and treat the \u2018what we expect firms to do\u2019 section as an action list.\n2. Review how outcomes are monitored and whether management information supports genuine challenge.\n3. Strengthen oversight of third-party and outsourced arrangements where these are flagged.\n4. Build or refresh evidence frameworks that can withstand supervisory scrutiny.\n\nThe shift to a single annual report per sector suggests the FCA wants supervision to be more predictable and less reliant on ad hoc portfolio letters, but the trade-off is a clearer expectation of evidence.\r\n\r\nAs this evidential discipline becomes standard across sectors, firms that cannot demonstrate how their frameworks operate in practice are likely to face earlier and more focused supervisory attention.\n\nUse each sector report as a structured checklist for self-assessment rather than a one-off read, and revisit it when planning assurance activity for the year.\r\n\r\nFocus particularly on strengthening how outcomes are monitored and how oversight of third parties and outsourced functions is evidenced, since these themes recur across almost every report.", "wordCount": 507, "keywords": [ "Compliance AI & RegTech", "Consumer Duty", "Regulatory Change & Transformation", "Vulnerable Customers", "Banking", "General Insurance & Protection", "Lending & Consumer Credit", "Motor Finance", "Payments & FinTech", "Pensions & Retirement Income", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Consumer Duty", "url": "https://tcc.group/blog/solution/consumer-duty/" }, { "@type": "Thing", "name": "Regulatory Change & Transformation", "url": "https://tcc.group/blog/solution/regulatory-change-transformation/" }, { "@type": "Thing", "name": "Vulnerable Customers", "url": "https://tcc.group/blog/solution/vulnerable-customers/" }, { "@type": "Thing", "name": "Banking", "url": "https://tcc.group/blog/sector/banking/" }, { "@type": "Thing", "name": "General Insurance & Protection", "url": "https://tcc.group/blog/sector/general-insurance-protection/" }, { "@type": "Thing", "name": "Lending & Consumer Credit", "url": "https://tcc.group/blog/sector/lending-consumer-credit/" }, { "@type": "Thing", "name": "Motor Finance", "url": "https://tcc.group/blog/sector/motor-finance/" }, { "@type": "Thing", "name": "Payments & FinTech", "url": "https://tcc.group/blog/sector/payments-fintech/" }, { "@type": "Thing", "name": "Pensions & Retirement Income", "url": "https://tcc.group/blog/sector/pensions-retirement-income/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "FCA Regulatory Priorities reports" } ], "articleSection": [ "Compliance AI & RegTech", "Consumer Duty", "Regulatory Change & Transformation", "Vulnerable Customers" ], "audience": [ { "@type": "Audience", "audienceType": "Banking" }, { "@type": "Audience", "audienceType": "General Insurance & Protection" }, { "@type": "Audience", "audienceType": "Lending & Consumer Credit" }, { "@type": "Audience", "audienceType": "Motor Finance" }, { "@type": "Audience", "audienceType": "Payments & FinTech" }, { "@type": "Audience", "audienceType": "Pensions & Retirement Income" }, { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Boards, compliance leaders and senior management across insurance, consumer investments, pensions, retail banking, mortgages, consumer finance, wholesale and payments firms." } ], "citation": [ { "@type": "CreativeWork", "name": "What the FCA\u2019s 2026 Regulatory Priorities reports reveal about the direction of supervision", "url": "https://staging.tcc.group/blog/2026/04/24/what-the-fcas-2026-regulatory-priorities-reports-reveal-about-the-direction-of-supervision/", "datePublished": "2026-04-24" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/regulatory-horizon/what-the-fcas-2026-regulatory-priorities-reports-reveal-about-the-direction-of-supervision/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/what-the-fcas-2026-regulatory-priorities-reports-reveal-about-the-direction-of-supervision/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "How many Regulatory Priorities reports has the FCA published?", "acceptedAnswer": { "@type": "Answer", "text": "Nine, covering both retail and wholesale sectors." } }, { "@type": "Question", "name": "What do the reports replace?", "acceptedAnswer": { "@type": "Answer", "text": "They replace dozens of individual portfolio letters with a single annual point of reference for each sector." } }, { "@type": "Question", "name": "What is the common theme across all nine reports?", "acceptedAnswer": { "@type": "Answer", "text": "That having policies, controls and governance on paper is not enough; firms must be able to evidence outcomes and demonstrate oversight in practice." } }, { "@type": "Question", "name": "Who should be reading these reports?", "acceptedAnswer": { "@type": "Answer", "text": "Boards and compliance leaders, since the FCA expects direct engagement rather than treating them as background reference material." } } ] } ] } ``` ### FCA Retail Banking Priorities: What Banks Must Do Now - URL: https://tcc.group/insights/regulatory-horizon/what-the-fcas-retail-banking-regulatory-priorities-report-means-for-retail-banks/ - Published: 2026-04-22 - Modified: 2026-09-02 **Topic:** Retail Banking Regulatory Priorities The FCA’s March 2026 Regulatory Priorities report for retail banking sets out four supervisory focus areas: access to cash, Consumer Duty evidencing, financial crime and operational resilience. #### What happened? In March 2026, the FCA published its Regulatory Priorities report for retail banking, aimed squarely at boards and senior executives at retail banks and building societies. It sets out where supervisory and policy focus will sit over the next 12 months. The report identifies four priority areas: access to cash and essential banking services, Consumer Duty governance and evidencing outcomes, fighting fraud and other financial crime, and operational resilience and data security. The regulator is explicit that innovations such as digital-first delivery and open banking must not compromise access to essential services, operational resilience or consumer outcomes, with the Consumer Duty remaining central to every priority area. #### Why does it matter? Boards should treat the report as a practical supervisory benchmark rather than a high-level policy statement. Across all four priorities, the FCA is signalling a move away from policy-led compliance towards demonstrable delivery assurance. Firms that cannot show how outcomes are monitored, challenged and improved over time should expect increased supervisory engagement. #### Who is affected? Retail banks and building societies, particularly boards and senior management overseeing digital transformation, third-party reliance and financial crime controls. #### Key risks - Gaps in local cash access under the Access to Cash regime. - Digitally excluded customers being disadvantaged by changes to service delivery. - Consumer Duty management information and governance that remain insufficiently mature. - Fraud and AML controls that do not keep pace with the scale and complexity of digital banking. - Critical internal and third-party dependencies that are not mapped or tested against tolerance thresholds. #### Actions to take 1. Address gaps in local cash access and ensure alternative arrangements are operational before branch closures occur. 2. Strengthen outcome-focused management information and oversight at senior management and board level. 3. Continuously refine fraud, AML and financial crime controls and remediate weaknesses promptly. 4. Map critical internal and third-party dependencies and remediate vulnerabilities within tolerance thresholds. 5. Re-test Consumer Duty evidence and stress-test operational resilience frameworks, including third-party oversight. #### Wider implications As with other sector priority reports, the FCA is signalling a decisive move towards demonstrable delivery assurance. Institutions able to scale capability quickly while maintaining clear accountability and board-level assurance are best positioned to respond credibly to supervisory engagement. #### Recommendations TCC supports firms across this regulatory spectrum by deploying senior interim leaders and regulatory specialists across governance, risk, compliance, transformation and operational resilience, helping close evidential gaps without placing unsustainable pressure on permanent leadership and control functions. #### Supporting sources - [FCA Retail Banking Priorities: What Banks Must Do Now](https://tcc.group/blog/2026/04/23/what-the-fcas-retail-banking-regulatory-priorities-report-means-for-retail-banks/) (2026-04-23) #### Ready for the FCA’s banking priorities? Talk to our team about strengthening governance, Consumer Duty evidence and operational resilience ahead of the FCA’s retail banking supervisory programme. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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"@id": "https://tcc.group/insights/regulatory-horizon/what-the-fcas-retail-banking-regulatory-priorities-report-means-for-retail-banks/#article", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/what-the-fcas-retail-banking-regulatory-priorities-report-means-for-retail-banks/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "FCA Retail Banking Priorities: What Banks Must Do Now", "datePublished": "2026-04-23T00:00:00+01:00", "dateModified": "2026-09-02T03:49:12+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/regulatory-horizon/what-the-fcas-retail-banking-regulatory-priorities-report-means-for-retail-banks/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/81f0d4a1e89c4b889104633c57d93926/thumbnail-1600-457cbbb60fe7f21e668f721a49a1aeba027497b10d2b8d6cc7ed0751b72cd7c6.jpg", "description": "See what the FCA\u2019s 2026 Regulatory Priorities report requires of retail banks and building societies, from access to cash to Consumer Duty evidencing, fraud controls and operational resilience testing.", "inLanguage": "en-GB", "articleBody": "The FCA\u2019s March 2026 Regulatory Priorities report for retail banking sets out four supervisory focus areas: access to cash, Consumer Duty evidencing, financial crime and operational resilience.\n\nIn March 2026, the FCA published its Regulatory Priorities report for retail banking, aimed squarely at boards and senior executives at retail banks and building societies. It sets out where supervisory and policy focus will sit over the next 12 months.\n\nThe report identifies four priority areas: access to cash and essential banking services, Consumer Duty governance and evidencing outcomes, fighting fraud and other financial crime, and operational resilience and data security.\n\nThe regulator is explicit that innovations such as digital-first delivery and open banking must not compromise access to essential services, operational resilience or consumer outcomes, with the Consumer Duty remaining central to every priority area.\n\nBoards should treat the report as a practical supervisory benchmark rather than a high-level policy statement. Across all four priorities, the FCA is signalling a move away from policy-led compliance towards demonstrable delivery assurance.\n\nFirms that cannot show how outcomes are monitored, challenged and improved over time should expect increased supervisory engagement.\n\nRetail banks and building societies, particularly boards and senior management overseeing digital transformation, third-party reliance and financial crime controls.\n\n\u2022 Gaps in local cash access under the Access to Cash regime.\n\u2022 Digitally excluded customers being disadvantaged by changes to service delivery.\n\u2022 Consumer Duty management information and governance that remain insufficiently mature.\n\u2022 Fraud and AML controls that do not keep pace with the scale and complexity of digital banking.\n\u2022 Critical internal and third-party dependencies that are not mapped or tested against tolerance thresholds.\n\n1. Address gaps in local cash access and ensure alternative arrangements are operational before branch closures occur.\n2. Strengthen outcome-focused management information and oversight at senior management and board level.\n3. Continuously refine fraud, AML and financial crime controls and remediate weaknesses promptly.\n4. Map critical internal and third-party dependencies and remediate vulnerabilities within tolerance thresholds.\n5. Re-test Consumer Duty evidence and stress-test operational resilience frameworks, including third-party oversight.\n\nAs with other sector priority reports, the FCA is signalling a decisive move towards demonstrable delivery assurance. Institutions able to scale capability quickly while maintaining clear accountability and board-level assurance are best positioned to respond credibly to supervisory engagement.\n\nTCC supports firms across this regulatory spectrum by deploying senior interim leaders and regulatory specialists across governance, risk, compliance, transformation and operational resilience, helping close evidential gaps without placing unsustainable pressure on permanent leadership and control functions.", "wordCount": 417, "keywords": [ "Complaints & Claims Handling", "Compliance AI & RegTech", "Consumer Duty", "Financial Crime Compliance", "Regulatory Change & Transformation", "Vulnerable Customers", "Banking", "Payments & FinTech" ], "about": [ { "@type": "Thing", "name": "Complaints & Claims Handling", "url": "https://tcc.group/blog/solution/complaints-claims-handling/" }, { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Consumer Duty", "url": "https://tcc.group/blog/solution/consumer-duty/" }, { "@type": "Thing", "name": "Financial Crime Compliance", "url": "https://tcc.group/blog/solution/financial-crime-compliance/" }, { "@type": "Thing", "name": "Regulatory Change & Transformation", "url": "https://tcc.group/blog/solution/regulatory-change-transformation/" }, { "@type": "Thing", "name": "Vulnerable Customers", "url": "https://tcc.group/blog/solution/vulnerable-customers/" }, { "@type": "Thing", "name": "Banking", "url": "https://tcc.group/blog/sector/banking/" }, { "@type": "Thing", "name": "Payments & FinTech", "url": "https://tcc.group/blog/sector/payments-fintech/" }, { "@type": "Thing", "name": "Retail Banking Regulatory Priorities" } ], "articleSection": [ "Complaints & Claims Handling", "Compliance AI & RegTech", "Consumer Duty", "Financial Crime Compliance", "Regulatory Change & Transformation", "Vulnerable Customers" ], "audience": [ { "@type": "Audience", "audienceType": "Banking" }, { "@type": "Audience", "audienceType": "Payments & FinTech" }, { "@type": "Audience", "audienceType": "Boards and senior executives at retail banks and building societies responsible for governance, Consumer Duty and operational resilience." } ], "citation": [ { "@type": "CreativeWork", "name": "FCA Retail Banking Priorities: What Banks Must Do Now", "url": "https://tcc.group/blog/2026/04/23/what-the-fcas-retail-banking-regulatory-priorities-report-means-for-retail-banks/", "datePublished": "2026-04-23" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/regulatory-horizon/what-the-fcas-retail-banking-regulatory-priorities-report-means-for-retail-banks/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/what-the-fcas-retail-banking-regulatory-priorities-report-means-for-retail-banks/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What are the FCA\u2019s four retail banking priorities?", "acceptedAnswer": { "@type": "Answer", "text": "Access to cash and essential banking services, Consumer Duty governance and evidencing outcomes, fighting fraud and financial crime, and operational resilience and data security." } }, { "@type": "Question", "name": "What must banks demonstrate before closing branches?", "acceptedAnswer": { "@type": "Answer", "text": "That suitable alternative arrangements are operational before closures and that changes do not disadvantage customers who are less digitally capable." } }, { "@type": "Question", "name": "Why is Consumer Duty still a focus for retail banks?", "acceptedAnswer": { "@type": "Answer", "text": "Because the FCA says data, management information and governance across the sector remain insufficiently mature, and firms must show how outcomes are monitored and improved over time." } }, { "@type": "Question", "name": "How does the FCA expect firms to respond overall?", "acceptedAnswer": { "@type": "Answer", "text": "By treating the report as a practical supervisory benchmark and evidencing how the priorities are embedded into day-to-day decision-making and governance oversight." } } ] } ] } ``` ### FCA Regulatory Priorities for Payments: What firms need to act on now - URL: https://tcc.group/insights/regulatory-horizon/fca-regulatory-priorities-for-payments-what-firms-need-to-act-on-now/ - Published: 2026-04-22 - Modified: 2026-09-02 **Topic:** Payments Regulation The FCA's March 2026 report outlines a focused supervisory agenda for payment and e-money firms, emphasizing safeguarding, Consumer Duty, and operational resilience. #### What happened? The Financial Conduct Authority has published its Regulatory Priorities: Payments report for March 2026, setting a clear supervisory agenda. Replacing traditional portfolio letters, this report is intended as a practical guide for boards and senior managers on where regulatory scrutiny will focus over the coming year. The regulator is focusing on four key themes: preparing for future regulation and innovation, delivering the Consumer Duty, protecting financial system integrity, and keeping customer money safe. Scrutiny is shifting from theoretical compliance frameworks to robust, active evidence of day-to-day effectiveness. #### Why does it matter? This regulatory shift represents a direct transition towards outcome-based supervision. Payment firms must prove their compliance, particularly regarding pricing transparency, the treatment of vulnerable customers, and the security of client assets under the upcoming Safeguarding Supplementary Regime. Failure to demonstrate effective governance, resilient safeguarding arrangements, and credible wind-down planning will lead to early intervention. Ineffective controls are now explicitly framed as systemic risks to market confidence and competition. #### Who is affected? This supervisory guidance directly affects senior executives, boards, and compliance teams at payment institutions, e-money firms, and FinTech innovators. Additionally, firms involved in open banking, variable recurring payments, and stablecoins are impacted as they scale up operations. #### Key risks - **Safeguarding Failures:** Inadequate asset protection or weak wind-down planning attracting direct regulatory intervention under the new regime. - **Consumer Duty Gaps:** Ongoing weaknesses in international payments pricing transparency and the identification of vulnerable customers. - **Financial Crime:** Weak internal systems and controls failing to prevent financial crime or support operational resilience. #### Actions to take 1. **Review Safeguarding:** Re-test and validate safeguarding frameworks and wind-down plans against the Safeguarding Supplementary Regime. 2. **Evidence Outcomes:** Document ongoing Consumer Duty assessments, particularly around vulnerable clients and pricing transparency, for board-level review. 3. **Prepare for Reporting:** Upgrade operational resilience and compliance systems to meet new incident and third-party reporting standards. 4. **Align Accountability:** Ensure innovation initiatives like digital payments have clear risk ownership and robust governance controls. #### Wider implications The FCA is establishing a predictable yet demanding supervisory landscape. As payments firms continue to innovate, growth must be matched with equivalent regulatory maturity and robust internal governance controls. #### Recommendations Firms should proactively audit their existing compliance frameworks rather than waiting for regulatory inquiries. Bringing in expert external review or interim leadership can provide the necessary oversight and resourcing to implement required changes rapidly. #### Supporting sources - [FCA Regulatory Priorities for Payments: What firms need to act on now](https://tcc.group/blog/2026/04/23/fca-regulatory-priorities-for-payments-what-firms-need-to-act-on-now/) (2026-04-23) #### Ready to secure your payments compliance framework? Strengthen your governance, operational resilience, and regulatory evidence frameworks with our expert advisory and specialist interim resourcing solutions. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/insights/regulatory-horizon/fca-regulatory-priorities-for-payments-what-firms-need-to-act-on-now/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Insights", "item": "https://tcc.group/insights/" }, { "@type": "ListItem", "position": 3, "name": "FCA Regulatory Priorities for Payments: What firms need to act on now", "item": "https://tcc.group/insights/regulatory-horizon/fca-regulatory-priorities-for-payments-what-firms-need-to-act-on-now/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/regulatory-horizon/fca-regulatory-priorities-for-payments-what-firms-need-to-act-on-now/#webpage", "url": "https://tcc.group/insights/regulatory-horizon/fca-regulatory-priorities-for-payments-what-firms-need-to-act-on-now/", "name": "FCA Regulatory Priorities for Payments: What firms need to act on now", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-04-23T00:00:00+01:00", "dateModified": "2026-09-02T03:47:44+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/regulatory-horizon/fca-regulatory-priorities-for-payments-what-firms-need-to-act-on-now/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "NewsArticle", "@id": "https://tcc.group/insights/regulatory-horizon/fca-regulatory-priorities-for-payments-what-firms-need-to-act-on-now/#article", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/fca-regulatory-priorities-for-payments-what-firms-need-to-act-on-now/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "FCA Regulatory Priorities for Payments: What firms need to act on now", "datePublished": "2026-04-23T00:00:00+01:00", "dateModified": "2026-09-02T03:47:44+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/regulatory-horizon/fca-regulatory-priorities-for-payments-what-firms-need-to-act-on-now/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/a70ba2fc536945b98ee5ec27faea06f7/thumbnail-1024-fcb5f73f3aae924b044210d60002ac074d6c52163c6ab7d614d63f9848ed1828.jpg", "description": "The FCA's March 2026 payments report outlines a direct supervisory agenda for payment and e-money firms. We explore core themes of safeguarding, financial crime, and Consumer Duty compliance, alongside concrete priority actions for boards.", "inLanguage": "en-GB", "articleBody": "The FCA's March 2026 report outlines a focused supervisory agenda for payment and e-money firms, emphasizing safeguarding, Consumer Duty, and operational resilience.\n\nThe Financial Conduct Authority has published its Regulatory Priorities: Payments report for March 2026, setting a clear supervisory agenda. Replacing traditional portfolio letters, this report is intended as a practical guide for boards and senior managers on where regulatory scrutiny will focus over the coming year.\n\nThe regulator is focusing on four key themes: preparing for future regulation and innovation, delivering the Consumer Duty, protecting financial system integrity, and keeping customer money safe. Scrutiny is shifting from theoretical compliance frameworks to robust, active evidence of day-to-day effectiveness.\n\nThis regulatory shift represents a direct transition towards outcome-based supervision. Payment firms must prove their compliance, particularly regarding pricing transparency, the treatment of vulnerable customers, and the security of client assets under the upcoming Safeguarding Supplementary Regime.\n\nFailure to demonstrate effective governance, resilient safeguarding arrangements, and credible wind-down planning will lead to early intervention. Ineffective controls are now explicitly framed as systemic risks to market confidence and competition.\n\nThis supervisory guidance directly affects senior executives, boards, and compliance teams at payment institutions, e-money firms, and FinTech innovators. Additionally, firms involved in open banking, variable recurring payments, and stablecoins are impacted as they scale up operations.\n\n\u2022 Safeguarding Failures: Inadequate asset protection or weak wind-down planning attracting direct regulatory intervention under the new regime.\n\u2022 Consumer Duty Gaps: Ongoing weaknesses in international payments pricing transparency and the identification of vulnerable customers.\n\u2022 Financial Crime: Weak internal systems and controls failing to prevent financial crime or support operational resilience.\n\n1. Review Safeguarding: Re-test and validate safeguarding frameworks and wind-down plans against the Safeguarding Supplementary Regime.\n2. Evidence Outcomes: Document ongoing Consumer Duty assessments, particularly around vulnerable clients and pricing transparency, for board-level review.\n3. Prepare for Reporting: Upgrade operational resilience and compliance systems to meet new incident and third-party reporting standards.\n4. Align Accountability: Ensure innovation initiatives like digital payments have clear risk ownership and robust governance controls.\n\nThe FCA is establishing a predictable yet demanding supervisory landscape. As payments firms continue to innovate, growth must be matched with equivalent regulatory maturity and robust internal governance controls.\n\nFirms should proactively audit their existing compliance frameworks rather than waiting for regulatory inquiries. 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The Financial Conduct Authority has published its inaugural Regulatory Priorities report for the wholesale buy-side, replacing over forty separate portfolio letters with an integrated, annual statement of expectations. The regulator is delivering a direct message: boards and senior management must assess these priorities against their business model and document appropriate action. While the FCA positions itself as a predictable, proportionate, and pro-growth supervisor, it explicitly cautions that firms unable to demonstrate robust governance, operational resilience, and reliable decision-making will face earlier and more decisive intervention. #### Why does it matter? Supervisory scrutiny is shifting from policy interpretation to demonstrable outcomes. The regulator is less concerned with the existence of compliance frameworks on paper, and far more focused on whether they operate effectively under stress. Operational resilience is now an active supervisory test, emphasizing third-party dependencies and outsourced oversight. Additionally, private markets face sustained valuation scrutiny. Valuation judgements, conflict-of-interest controls, and investor transparency must be actively governed, challenged, and recorded rather than handled retrospectively. #### Who is affected? This update directly affects asset managers, alternative investment fund managers (AIFMs), custody providers, and fund services providers, particularly those with retail or downstream investor exposure. #### Key risks - **Ineffective Third-Party Oversight:** Failing to demonstrate robust oversight, data quality control, and incident testing for outsourced services. - **Unsubstantiated Valuations:** Private market asset valuations lacking explicit board-level challenge and clear audit trails. - **Diluted Technology Accountability:** Introducing complex systems like AI or tokenisation without clear post-implementation accountability and risk monitoring. #### Actions to take 1. **Test Operational Resilience:** Review resilience evidence and stress-test third-party oversight mechanisms beyond standard paper-based agreements. 2. **Audit Private Valuations:** Implement robust, documented processes for reviewing and challenging valuation judgements in private markets. 3. **Formalise Tech Governance:** Ensure explicit senior accountability and ongoing oversight controls are active for all newly deployed technologies. 4. **Strengthen Escalation:** Validate delegation frameworks and escalate critical risks directly to board-level management information. #### Wider implications The consolidation of portfolio letters indicates a more coordinated, data-led supervisory strategy. High-growth and innovative practices are encouraged, but only when they are built on a solid foundation of proven internal governance. #### Recommendations Firms should treat operational resilience as a core business driver rather than a check-box task. Investing in evidence-led governance and robust third-party oversight will secure compliance and enable sustainable commercial growth. #### Supporting sources - [FCA Regulatory Priorities for the Wholesale Buy Side: what firms need to evidence now](https://tcc.group/blog/2026/04/23/fca-regulatory-priorities-for-the-wholesale-buy-side-what-firms-need-to-evidence-now/) (2026-04-23) #### Strengthen your wholesale buy-side governance today Embed operational resilience, accountable oversight, and evidence-led compliance frameworks that satisfy evolving FCA expectations. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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The Financial Conduct Authority has released its Regulatory Priorities for Wholesale Markets report, marking a significant transition in how supervisory expectations are communicated. Replacing over forty separate portfolio letters, the single annual report is addressed directly to boards and senior executives rather than compliance delegates, demanding immediate attention and practical action. The supervisory focus remains anchored on operational resilience, technology adoption governance, and conduct. The regulator has made it clear that there is no tolerance for passive compliance strategies that exist solely on paper. #### Why does it matter? The FCA is actively reducing its tolerance for assumptions. Boards must prove they possess operational grip over day-to-day operations, third-party technology dependencies, and complex distribution chains. Technology adoption and modernisation are supported, but only when matched with explicit risk ownership and rigorous pre-deployment testing. Furthermore, wholesale conduct rules, conflict identification, and escalation channels are being re-tested to ensure that real-time management information is actively guiding business decisions. #### Who is affected? This report affects boards, senior management, and heads of compliance across wholesale trading firms, financial institutions, and FinTech innovators in the UK. #### Key risks - **Unproven Operational Resilience:** Treating resilience as a compliance check rather than integrating it into daily operations and third-party oversight. - **Weak Technology Governance:** Advancing technology, like complex analytics or infrastructure modernisation, without explicit senior accountability or risk mitigation. - **Inadequate Management Information:** Relying on passive, retrospective reporting that prevents the board from challenging risks in real time. #### Actions to take 1. **Test Resilience Scenarios:** Stress-test operational resilience using realistic scenario testing that extends beyond basic impact tolerances. 2. **Secure Tech Accountability:** Establish explicit senior executive accountability and record decision-making for all third-party technology integrations. 3. **Upgrade Management Information:** Assess and refine management information channels to ensure leadership is equipped to interrogate risks in real time. 4. **Prepare Evidence Packages:** Compile clear, accessible evidence files demonstrating how controls work in practice under real operational conditions. #### Wider implications Firms must expect increased supervisory intensity and swifter regulatory intervention if they fail to evidence active operational grip. This highlights a clear trend towards proactive, rather than reactive, compliance supervision. #### Recommendations Boards should engage directly with these priorities, ensuring their internal audit and compliance reviews provide robust, documented proof of outcomes rather than intentions. #### Supporting sources - [FCA Regulatory Priorities for Wholesale Markets: why boards should act now](https://tcc.group/blog/2026/04/23/fca-regulatory-priorities-for-wholesale-markets-why-boards-should-act-on-now/) (2026-04-23) #### Ensure your wholesale frameworks withstand regulatory scrutiny Validate your governance, technology controls, and operational resilience with our expert advisory and compliance specialists. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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"item": "https://tcc.group/insights/regulatory-horizon/fca-regulatory-priorities-for-wholesale-markets-why-boards-should-act-on-now/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/regulatory-horizon/fca-regulatory-priorities-for-wholesale-markets-why-boards-should-act-on-now/#webpage", "url": "https://tcc.group/insights/regulatory-horizon/fca-regulatory-priorities-for-wholesale-markets-why-boards-should-act-on-now/", "name": "FCA Regulatory Priorities for Wholesale Markets: why boards should act now", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-04-23T00:00:00+01:00", "dateModified": "2026-09-02T03:47:44+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/regulatory-horizon/fca-regulatory-priorities-for-wholesale-markets-why-boards-should-act-on-now/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "NewsArticle", "@id": "https://tcc.group/insights/regulatory-horizon/fca-regulatory-priorities-for-wholesale-markets-why-boards-should-act-on-now/#article", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/fca-regulatory-priorities-for-wholesale-markets-why-boards-should-act-on-now/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "FCA Regulatory Priorities for Wholesale Markets: why boards should act now", "datePublished": "2026-04-23T00:00:00+01:00", "dateModified": "2026-09-02T03:47:44+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/regulatory-horizon/fca-regulatory-priorities-for-wholesale-markets-why-boards-should-act-on-now/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/b8d511c9984b431db3ef1305b28d9ef2/thumbnail-1600-884efb7ddc66641df5eb049abe157c78bcde6b23fcefe17c916ad109e39e82d3.jpg", "description": "The FCA's Regulatory Priorities report for wholesale markets represents a major shift in supervisor expectations. Boards are urged to act on outcomes, evidence, and operational grip, especially around third-party tech dependencies.", "inLanguage": "en-GB", "articleBody": "The FCA's new annual sector reports for wholesale markets are directed at boards, outlining expectations for direct control, technological accountability, and operational resilience.\n\nThe Financial Conduct Authority has released its Regulatory Priorities for Wholesale Markets report, marking a significant transition in how supervisory expectations are communicated. Replacing over forty separate portfolio letters, the single annual report is addressed directly to boards and senior executives rather than compliance delegates, demanding immediate attention and practical action.\n\nThe supervisory focus remains anchored on operational resilience, technology adoption governance, and conduct. The regulator has made it clear that there is no tolerance for passive compliance strategies that exist solely on paper.\n\nThe FCA is actively reducing its tolerance for assumptions. Boards must prove they possess operational grip over day-to-day operations, third-party technology dependencies, and complex distribution chains. 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Test Resilience Scenarios: Stress-test operational resilience using realistic scenario testing that extends beyond basic impact tolerances.\n2. Secure Tech Accountability: Establish explicit senior executive accountability and record decision-making for all third-party technology integrations.\n3. Upgrade Management Information: Assess and refine management information channels to ensure leadership is equipped to interrogate risks in real time.\n4. Prepare Evidence Packages: Compile clear, accessible evidence files demonstrating how controls work in practice under real operational conditions.\n\nFirms must expect increased supervisory intensity and swifter regulatory intervention if they fail to evidence active operational grip. 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The Financial Conduct Authority (FCA) has published its first Insurance Regulatory Priorities report, replacing over 40 individual portfolio letters. This landmark report serves as the central annual reference point for boards and senior executives across insurers, intermediaries, and price comparison platforms. The regulator signals a highly differentiated supervisory approach, offering a lighter touch to firms that can systematically evidence good consumer outcomes, while taking earlier, more assertive action against those that fail to do so. #### Why does it matter? The FCA is explicit that weaknesses remain in claims handling, consumer understanding, and overall service quality, particularly in home and travel insurance following Which's super-complaint. Furthermore, the regulator is expanding its scrutiny to outsourced and delegated claims arrangements. Boards must demonstrate effective oversight and remuneration controls over third-party providers (TPAs) and delegated authority networks, which have historically been hard to monitor and audit. #### Who is affected? All UK retail and wholesale insurers, insurance intermediaries, life insurers, and delegated claims handlers are directly affected by these new supervisory standards. #### Key risks Firms face major compliance and operational risks under the new insurance supervision framework: - Supervisory intervention due to poor claims-handling oversight or unacceptable consumer friction during the claims journey. - Lack of visibility and weak governance over outsourced claims handlers and delegated authority models. - Inability to provide robust, outcome-based evidence to satisfy Consumer Duty requirements. #### Actions to take Insurance firms and intermediaries should execute the following actions to align with the FCA: 1. Review claims-handling processes against Consumer Duty outcomes rather than outdated speed-of-service metrics. 2. Audit all delegated authority and third-party administration (TPA) contracts to verify governance and remuneration alignment. 3. Improve data collection across legacy systems to establish a joined-up view of consumer outcomes. #### Wider implications The consolidation of portfolio letters into a single reference report reflects the FCA's transition to a more agile, risk-based regulator. It places the burden of proof squarely on firms to continuously demonstrate compliant outcomes across the full product lifecycle. #### Recommendations We recommend conducting a comprehensive regulatory gap assessment of your outsourced claims governance and designing a data-led management information framework to systematically track and report outcomes. #### Supporting sources - [FCA Insurance Priorities: Impact for Insurers & Intermediaries](https://tcc.group/blog/2026/04/22/fca-insurance-regulatory-priorities-report-key-impacts-for-insurers-and-intermediaries/) (2026-04-22) #### Are your outsourced claims processes compliant? Speak to our insurance compliance specialists today to audit your delegated authorities and secure robust, regulator-ready outcome evidence. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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The Financial Conduct Authority's head of consumer policy, Jonathan Pearson, has outlined expectations for the third annual Consumer Duty Board reports. While acknowledging that firms have improved their governance and data usage between years one and two, the regulator is demanding a shift in year three from demonstrating compliance effort to proving actual outcome effectiveness. Boards are expected to move away from simply reviewing prepared reports and instead demonstrate active, documented interrogation of data and management decisions regarding customer experiences. #### Why does it matter? The quality bar has risen significantly. The FCA expects reports to go beyond simple metrics dashboards to explain what the data says about customer outcomes. Furthermore, firms must prove how Consumer Duty insights are directly shaping strategic business decisions, including pausing or modifying underperforming products. Oversight of third-party distribution chains and outsourced activities must also be sharpened, showing how outcome data is acquired and managed when visibility is weak. #### Who is affected? This regulatory update directly impacts boards of directors, senior managers, and compliance leaders across all FCA-regulated financial institutions preparing annual reports. #### Key risks - **Unexplained metrics:** Presenting data dashboards without context or explanation of what they reveal about customer outcomes. - **Invisible Board Challenge:** Failing to document board interrogation, risk testing, or management challenges in official board minutes. - **Weak third-party oversight:** Insufficient outcome monitoring across distribution chains, appointed representatives, or outsourced providers. #### Actions to take 1. **Analyze Outcome Data:** Ensure management reporting explains the real customer story behind the data, including actions taken for negative trends. 2. **Document Board Challenge:** Formally record instances where the board has interrogated assumptions, requested deeper analysis, or rejected proposed actions. 3. **Secure Intermediary Data:** Obtain and assess outcome-related data from third-party distribution channels and appointed representatives. 4. **Deepen Support Analysis:** Utilize behavioral insights and interaction monitoring to evaluate customer understanding across full journeys. #### Wider implications This cycle represents the transition of Consumer Duty from a standalone compliance project to a deeply embedded cultural framework that actively influences strategic corporate governance. #### Recommendations Firms should secure independent, third-party reviews of their draft Board reports to ensure evidence and outcomes are robust enough to withstand intensive FCA scrutiny. #### Supporting sources - [Five Consumer Duty priorities to refine for your third Board report](https://tcc.group/blog/2026/04/22/five-consumer-duty-priorities-to-refine-for-your-third-board-report/) (2026-04-22) #### Is your third Consumer Duty Board report ready? Partner with our senior regulatory advisers to test, refine, and evidence the effectiveness of your Consumer Duty outcomes. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/insights/regulatory-horizon/five-consumer-duty-priorities-to-refine-for-your-third-board-report/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Insights", "item": "https://tcc.group/insights/" }, { "@type": "ListItem", "position": 3, "name": "Five Consumer Duty priorities to refine for your third Board report", "item": "https://tcc.group/insights/regulatory-horizon/five-consumer-duty-priorities-to-refine-for-your-third-board-report/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/regulatory-horizon/five-consumer-duty-priorities-to-refine-for-your-third-board-report/#webpage", "url": "https://tcc.group/insights/regulatory-horizon/five-consumer-duty-priorities-to-refine-for-your-third-board-report/", "name": "Five Consumer Duty priorities to refine for your third Board report", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-04-22T00:00:00+01:00", "dateModified": "2026-09-02T03:47:45+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/regulatory-horizon/five-consumer-duty-priorities-to-refine-for-your-third-board-report/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "NewsArticle", "@id": "https://tcc.group/insights/regulatory-horizon/five-consumer-duty-priorities-to-refine-for-your-third-board-report/#article", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/five-consumer-duty-priorities-to-refine-for-your-third-board-report/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "Five Consumer Duty priorities to refine for your third Board report", "datePublished": "2026-04-22T00:00:00+01:00", "dateModified": "2026-09-02T03:47:45+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/regulatory-horizon/five-consumer-duty-priorities-to-refine-for-your-third-board-report/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/8e5021b38ab9498cb81ac960f631bc2c/thumbnail-1600-ebca33d6693fa7ea8573f9c120cd61769959b60a00752768f43ff99118d4c792.jpg", "description": "As firms prepare their third annual Consumer Duty Board reports, the regulatory focus has shifted from effort to effectiveness. Discover the five crucial priority areas boards must address to satisfy the FCA.", "inLanguage": "en-GB", "articleBody": "As firms prepare for their third annual Consumer Duty Board report, the FCA is focusing on the transition from process-tracking to proving outcome effectiveness and visible board challenge.\n\nThe Financial Conduct Authority's head of consumer policy, Jonathan Pearson, has outlined expectations for the third annual Consumer Duty Board reports. While acknowledging that firms have improved their governance and data usage between years one and two, the regulator is demanding a shift in year three from demonstrating compliance effort to proving actual outcome effectiveness.\n\nBoards are expected to move away from simply reviewing prepared reports and instead demonstrate active, documented interrogation of data and management decisions regarding customer experiences.\n\nThe quality bar has risen significantly. 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Furthermore, firms must prove how Consumer Duty insights are directly shaping strategic business decisions, including pausing or modifying underperforming products.\n\nOversight of third-party distribution chains and outsourced activities must also be sharpened, showing how outcome data is acquired and managed when visibility is weak.\n\nThis regulatory update directly impacts boards of directors, senior managers, and compliance leaders across all FCA-regulated financial institutions preparing annual reports.\n\n\u2022 Unexplained metrics: Presenting data dashboards without context or explanation of what they reveal about customer outcomes.\n\u2022 Invisible Board Challenge: Failing to document board interrogation, risk testing, or management challenges in official board minutes.\n\u2022 Weak third-party oversight: Insufficient outcome monitoring across distribution chains, appointed representatives, or outsourced providers.\n\n1. Analyze Outcome Data: Ensure management reporting explains the real customer story behind the data, including actions taken for negative trends.\n2. Document Board Challenge: Formally record instances where the board has interrogated assumptions, requested deeper analysis, or rejected proposed actions.\n3. Secure Intermediary Data: Obtain and assess outcome-related data from third-party distribution channels and appointed representatives.\n4. 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AI has moved quickly from the margins of financial services into everyday operations, shaping how firms detect fraud, onboard customers, assess creditworthiness and interact with clients. Much of this momentum has been driven by commercial opportunity rather than regulation, with faster decisions, lower costs and richer insight prompting firms to move ahead even as questions about risk, data quality and oversight began to surface. Policy and supervision are now catching up. The UK Government's AI Opportunities Action Plan signals continued support for innovation, while the FCA has set out in its 2026-27 annual work programme its ambition to become a more data-led regulator, including using AI to support supervision, analyse firm submissions and identify harm. Adoption is now widespread, as the Treasury Select Committee's recent inquiry underlines, particularly among larger institutions. What varies far more than adoption is governance maturity, with many firms still relying on control frameworks designed for traditional, rules-based systems. #### Why does it matter? Existing regulatory frameworks, including Consumer Duty, SM&CR and operational resilience, still apply, but the emphasis is shifting towards how firms evidence compliance when decision-making is less visible and outcomes are shaped by systems that evolve over time. The FCA's engagement on AI has been deliberate and iterative, including initiatives such as the Mills Review examining whether existing regimes remain fit for purpose, rather than proposing wholesale new rules. Supervisory tools are also evolving, with greater use of testing environments, deeper dialogue with firms and growing focus on systemic technology risk reflected in regimes such as Critical Third Parties. #### Who is affected? This affects any regulated firm using AI in credit assessment, fraud detection, onboarding or client interactions, along with the senior managers and boards accountable under SM&CR for demonstrating oversight of the systems, suppliers and teams involved. #### Key risks - Mainstream generative AI and large language model tools are effective at text extraction and summarisation, but are not designed to support regulated decision-making. - These models can silently resolve conflicts, obscure data lineage, and produce confident-sounding outputs that are incomplete or wrong. - Firms often end up increasing human oversight rather than reducing it, spending more time validating outputs and evidencing compliance. - Unclear data ownership, inconsistent documentation and fragile oversight models become harder to justify once decisions are made at speed and scale. #### Actions to take 1. Separate the use of generative AI for text extraction and summarisation from purpose-built predictive AI models used for regulated decisions. 2. Invest in a reliable, explainable and auditable data foundation before scaling AI further. 3. Strengthen governance, evidencing and operational oversight through advisory input, interim leadership and managed services as needed. 4. Prepare for closer supervisory engagement, including testing environments and scrutiny under regimes such as Critical Third Parties. #### Wider implications The most difficult challenges rarely appear at the point of adoption; they emerge later, once AI is embedded in business-critical processes, when questions of fairness, oversight and accountability move from policy debate into day-to-day practice. As Joe Norburn, CEO of TCC Group and Recordsure, has noted, the real question for firms is no longer whether AI can deliver value, but whether they can prove to themselves, their boards and their regulators that it is being used safely, transparently and at scale. #### Recommendations TCC supports firms through a combination of advisory services, interim leadership and managed services: advisory teams help boards and senior managers interpret regulatory expectations and design proportionate AI governance, interim leaders embed compliance and controls during periods of change, and managed services provide human-in-the-loop oversight where judgement and evidencing remain critical. This is complemented by Recordsure's AI-driven analytics, built for regulated environments, which operate on trusted, structured data to provide explainable insights, consistent management information and auditable evidence for both regulatory engagement and internal assurance. #### Supporting sources - [AI in financial services: control, evidence and regulation](https://tcc.group/blog/2026/04/20/ai-financial-services-control-governance-evidence/) (2026-04-20) #### Strengthening your firm's AI governance? Speak to TCC about how our advisory, managed services and Recordsure AI capability can help you evidence control, governance and accountability. [Speak to our team](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory 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"isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/ai-financial-services-control-governance-evidence/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "AI in financial services: control, evidence and regulation", "datePublished": "2026-04-20T00:00:00+01:00", "dateModified": "2026-09-02T03:47:30+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/regulatory-horizon/ai-financial-services-control-governance-evidence/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/935ef7b1ff1145e58733ca53e958e093/thumbnail-1600-224860554cdf3cf6aef34902b370656df2fd42e6406e987c3c15b28c05939538.jpg", "description": "Explains why AI governance, not capability, is now the constraint for financial services firms, and sets out what boards need to prove to regulators about control, evidencing and accountability.", "inLanguage": "en-GB", "articleBody": "As AI becomes embedded across financial services, TCC explains why governance maturity, not AI capability, is now the limiting factor, and what firms need to prove to regulators about control and accountability.\n\nAI has moved quickly from the margins of financial services into everyday operations, shaping how firms detect fraud, onboard customers, assess creditworthiness and interact with clients. Much of this momentum has been driven by commercial opportunity rather than regulation, with faster decisions, lower costs and richer insight prompting firms to move ahead even as questions about risk, data quality and oversight began to surface.\n\nPolicy and supervision are now catching up. The UK Government's AI Opportunities Action Plan signals continued support for innovation, while the FCA has set out in its 2026-27 annual work programme its ambition to become a more data-led regulator, including using AI to support supervision, analyse firm submissions and identify harm.\n\nAdoption is now widespread, as the Treasury Select Committee's recent inquiry underlines, particularly among larger institutions. What varies far more than adoption is governance maturity, with many firms still relying on control frameworks designed for traditional, rules-based systems.\n\nExisting regulatory frameworks, including Consumer Duty, SM&CR and operational resilience, still apply, but the emphasis is shifting towards how firms evidence compliance when decision-making is less visible and outcomes are shaped by systems that evolve over time.\n\nThe FCA's engagement on AI has been deliberate and iterative, including initiatives such as the Mills Review examining whether existing regimes remain fit for purpose, rather than proposing wholesale new rules. 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Separate the use of generative AI for text extraction and summarisation from purpose-built predictive AI models used for regulated decisions.\n2. Invest in a reliable, explainable and auditable data foundation before scaling AI further.\n3. Strengthen governance, evidencing and operational oversight through advisory input, interim leadership and managed services as needed.\n4. 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oversight where judgement and evidencing remain critical.\n\nThis is complemented by Recordsure's AI-driven analytics, built for regulated environments, which operate on trusted, structured data to provide explainable insights, consistent management information and auditable evidence for both regulatory engagement and internal assurance.", "wordCount": 640, "keywords": [ "Compliance AI & RegTech", "Regulatory Change & Transformation", "Banking", "General Insurance & Protection", "Lending & Consumer Credit", "Motor Finance", "Payments & FinTech", "Pensions & Retirement Income", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Regulatory Change & Transformation", "url": "https://tcc.group/blog/solution/regulatory-change-transformation/" }, { "@type": "Thing", "name": "Banking", "url": "https://tcc.group/blog/sector/banking/" }, { "@type": "Thing", "name": "General Insurance & Protection", "url": "https://tcc.group/blog/sector/general-insurance-protection/" }, { "@type": "Thing", "name": "Lending & Consumer Credit", "url": "https://tcc.group/blog/sector/lending-consumer-credit/" }, { "@type": "Thing", "name": "Motor Finance", "url": "https://tcc.group/blog/sector/motor-finance/" }, { "@type": "Thing", "name": "Payments & FinTech", "url": "https://tcc.group/blog/sector/payments-fintech/" }, { "@type": "Thing", "name": "Pensions & Retirement Income", "url": "https://tcc.group/blog/sector/pensions-retirement-income/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "AI governance and evidencing" } ], "articleSection": [ "Compliance AI & RegTech", "Regulatory Change & Transformation" ], "audience": [ { "@type": "Audience", "audienceType": "Banking" }, { "@type": "Audience", "audienceType": "General Insurance & Protection" }, { "@type": "Audience", "audienceType": "Lending & Consumer Credit" }, { "@type": "Audience", "audienceType": "Motor Finance" }, { "@type": "Audience", "audienceType": "Payments & FinTech" }, { "@type": "Audience", "audienceType": "Pensions & Retirement Income" }, { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Boards, senior managers and risk and compliance functions overseeing AI deployment in regulated firms." } ], "citation": [ { "@type": "CreativeWork", "name": "AI in financial services: control, evidence and regulation", "url": "https://tcc.group/blog/2026/04/20/ai-financial-services-control-governance-evidence/", "datePublished": "2026-04-20" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/regulatory-horizon/ai-financial-services-control-governance-evidence/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/ai-financial-services-control-governance-evidence/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What is the Mills Review?", "acceptedAnswer": { "@type": "Answer", "text": "An FCA initiative examining whether existing regulatory regimes remain fit for purpose as AI becomes more deeply embedded in financial services." } }, { "@type": "Question", "name": "Why do generative AI and large language model tools struggle with regulated decisions?", "acceptedAnswer": { "@type": "Answer", "text": "They are not designed to support regulated decision-making and can silently resolve conflicts, obscure data lineage and produce confident but incorrect outputs." } }, { "@type": "Question", "name": "What should firms prioritise to prepare for closer AI scrutiny?", "acceptedAnswer": { "@type": "Answer", "text": "A reliable, explainable and auditable data foundation, along with clearer governance and defensible evidencing mechanisms." } }, { "@type": "Question", "name": "Who commented on AI accountability in the article?", "acceptedAnswer": { "@type": "Answer", "text": "Joe Norburn, CEO of TCC Group and Recordsure." } } ] } ] } ``` ### FCA priorities for 2026/27: Consumer Duty and financial crime - URL: https://tcc.group/insights/regulatory-horizon/fca-priorities-for-2026-27-smarter-regulation-growth-consumer-duty-and-financial-crime/ - Published: 2026-04-14 - Modified: 2026-09-02 **Topic:** FCA Annual Work Programme The FCA has published its 2026/27 Annual Work Programme, emphasizing a 'smarter regulator' model that leverages data, digital supervision, and intensified focus on Consumer Duty and financial crime. #### What happened? The Financial Conduct Authority (FCA) has published its Annual Work Programme for 2026/27, detailing its regulatory delivery plan aligned with its 2025-2030 strategy. The programme signals an intensified transition to a smarter, more data-driven supervision model. Key regulatory priorities include enhancing consumer credit frameworks, enforcing the outcomes-based Consumer Duty, and scaling collective defences against financial crime, fraud, and money laundering. #### Why does it matter? The FCA's vision of 'smarter regulation' involves using AI, digital sandboxes, and advanced analytics to rapidly detect consumer harm. For firms, this means there is a reduced tolerance for poor-quality data or late reporting. While the regulator is streamlining authorisations and digital applications, it places a higher burden on firms to submit accurate, right-first-time data. Additionally, the regulator is driving international competitiveness and UK growth while maintaining high regulatory standards. Firms must balance innovation—such as tokenisation and AI integrations—with strict SM&CR accountability and data controls. #### Who is affected? All retail and wholesale financial institutions, banks, fintechs, wealth managers, and insurers holding FCA permissions are directly affected. #### Key risks Firms face severe risks if their compliance and data structures are outdated: - Increased FCA intervention and audit for submitting poor-quality or delayed regulatory returns. - Enforcement actions for failing to actively prevent and detect financial crime across digital channels. - Breaches of the Consumer Duty due to inadequate outcomes-monitoring data or complex, high-barrier customer journeys. #### Actions to take Regulated firms should execute immediate actions to align with the 2026/27 work programme: 1. Strengthen data governance and ensure all regulatory reporting is complete, accurate, and prompt. 2. Integrate fraud, AML, and compliance operating models to build an enterprise-wide financial crime defence. 3. Review product and sales journeys to ensure they represent fair value and promote consumer understanding in practice. #### Wider implications The 2026/27 programme highlights that compliance is no longer a check-box exercise. With a faster, more analytical regulator, firms must match this agility by establishing real-time outcomes monitoring and proactive gap analysis. #### Recommendations We recommend conducting an independent regulatory gap analysis of your current reporting, financial crime controls, and Consumer Duty evidence to identify and resolve vulnerabilities before they trigger automated regulatory alerts. #### Supporting sources - [FCA priorities for 2026/27: Consumer Duty and financial crime](https://tcc.group/blog/2026/04/15/fca-priorities-for-2026-27-consumer-duty-and-financial-crime/) (2026-04-15) #### Is your compliance agile enough for a smarter regulator? Contact our regulatory specialists today to conduct a comprehensive gap analysis and ensure your data and controls meet the FCA's 2026/27 standards. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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"item": "https://tcc.group/insights/regulatory-horizon/fca-priorities-for-2026-27-smarter-regulation-growth-consumer-duty-and-financial-crime/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/regulatory-horizon/fca-priorities-for-2026-27-smarter-regulation-growth-consumer-duty-and-financial-crime/#webpage", "url": "https://tcc.group/insights/regulatory-horizon/fca-priorities-for-2026-27-smarter-regulation-growth-consumer-duty-and-financial-crime/", "name": "FCA priorities for 2026/27: Consumer Duty and financial crime", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-04-15T00:00:00+01:00", "dateModified": "2026-09-02T03:47:44+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/regulatory-horizon/fca-priorities-for-2026-27-smarter-regulation-growth-consumer-duty-and-financial-crime/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "NewsArticle", "@id": "https://tcc.group/insights/regulatory-horizon/fca-priorities-for-2026-27-smarter-regulation-growth-consumer-duty-and-financial-crime/#article", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/fca-priorities-for-2026-27-smarter-regulation-growth-consumer-duty-and-financial-crime/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "FCA priorities for 2026/27: Consumer Duty and financial crime", "datePublished": "2026-04-15T00:00:00+01:00", "dateModified": "2026-09-02T03:47:44+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/regulatory-horizon/fca-priorities-for-2026-27-smarter-regulation-growth-consumer-duty-and-financial-crime/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/267b4064e0f94595a7b6796d97b45a68/thumbnail-1024-c2400e6e04962a386179dd15a684206e9f1732fc7731a707c2f21fcff5e02b28.jpg", "description": "The FCA's 2026/27 Annual Work Programme signals an aggressive shift toward data-driven supervision, smarter regulation, and an unyielding focus on the Consumer Duty, financial crime, and operational resilience.", "inLanguage": "en-GB", "articleBody": "The FCA has published its 2026/27 Annual Work Programme, emphasizing a 'smarter regulator' model that leverages data, digital supervision, and intensified focus on Consumer Duty and financial crime.\n\nThe Financial Conduct Authority (FCA) has published its Annual Work Programme for 2026/27, detailing its regulatory delivery plan aligned with its 2025-2030 strategy. The programme signals an intensified transition to a smarter, more data-driven supervision model.\n\nKey regulatory priorities include enhancing consumer credit frameworks, enforcing the outcomes-based Consumer Duty, and scaling collective defences against financial crime, fraud, and money laundering.\n\nThe FCA's vision of 'smarter regulation' involves using AI, digital sandboxes, and advanced analytics to rapidly detect consumer harm. For firms, this means there is a reduced tolerance for poor-quality data or late reporting. While the regulator is streamlining authorisations and digital applications, it places a higher burden on firms to submit accurate, right-first-time data.\n\nAdditionally, the regulator is driving international competitiveness and UK growth while maintaining high regulatory standards. Firms must balance innovation\u2014such as tokenisation and AI integrations\u2014with strict SM&CR accountability and data controls.\n\nAll retail and wholesale financial institutions, banks, fintechs, wealth managers, and insurers holding FCA permissions are directly affected.\n\nFirms face severe risks if their compliance and data structures are outdated:\n\n\u2022 Increased FCA intervention and audit for submitting poor-quality or delayed regulatory returns.\n\u2022 Enforcement actions for failing to actively prevent and detect financial crime across digital channels.\n\u2022 Breaches of the Consumer Duty due to inadequate outcomes-monitoring data or complex, high-barrier customer journeys.\n\nRegulated firms should execute immediate actions to align with the 2026/27 work programme:\n\n1. Strengthen data governance and ensure all regulatory reporting is complete, accurate, and prompt.\n2. 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AM–Online featured commentary from Joe Norburn, CEO of TCC Group, in its article on industry reaction to the FCA's redress scheme. The FCA has confirmed its final motor finance redress scheme will run as two parallel exercises, covering agreements from 2007–2014 and 2014–2024, prompting lenders and dealers to review the detailed rules and their operational impact. Norburn warned this is “not a simple compensation exercise” but a large-scale delivery challenge, with around 12 million historic agreements expected to be reviewed. #### Why does it matter? Firms will need to move quickly to ensure fair, consistent outcomes while meeting the FCA's expectation to compensate the majority of consumers by 2027. The scale of the exercise, covering nearly two decades of agreements across two parallel processes, means lenders and dealers face significant operational demands alongside the need for consistent customer treatment. #### Who is affected? The scheme affects motor finance lenders and dealers with agreements dating from 2007 to 2024, and by extension the wider lending and consumer credit sector. #### Key risks - Operational strain from reviewing around 12 million historic agreements - Inconsistent outcomes across two parallel redress exercises covering different time periods - Missing the FCA's expectation to compensate the majority of consumers by 2027 #### Actions to take 1. Review the FCA's detailed rules for both the 2007–2014 and 2014–2024 redress exercises. 2. Assess the operational capacity needed to review historic agreements at scale. 3. Put plans in place to deliver fair, consistent outcomes ahead of the FCA's 2027 expectation. #### Wider implications Norburn's comments frame the scheme as a delivery challenge as much as a compensation exercise, meaning firms' operational readiness will be as important to the outcome as the underlying redress rules. #### Recommendations Lenders and dealers should treat the scheme as a large-scale programme requiring dedicated resourcing and consistent processes, rather than a routine compensation exercise. #### Supporting sources - [AM–Online offers industry experts’ reaction to the FCA motor finance redress scheme](https://tcc.group/blog/2026/04/01/am-online-industry-reacts-to-fca-motor-finance-redress-scheme/) (2026-04-01) #### Preparing for the motor finance redress scheme? Get in touch to find out how we can support your redress programme and help you meet the regulator's deadlines. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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finance redress scheme is a major delivery challenge, covering around 12 million agreements, and what lenders and dealers need to do to meet the 2027 deadline.", "inLanguage": "en-GB", "articleBody": "TCC Group's CEO Joe Norburn responds to the FCA's confirmed motor finance redress scheme, warning that it is a large-scale delivery challenge covering around 12 million historic agreements.\n\nAM\u2013Online featured commentary from Joe Norburn, CEO of TCC Group, in its article on industry reaction to the FCA's redress scheme. The FCA has confirmed its final motor finance redress scheme will run as two parallel exercises, covering agreements from 2007\u20132014 and 2014\u20132024, prompting lenders and dealers to review the detailed rules and their operational impact.\n\nNorburn warned this is \u201cnot a simple compensation exercise\u201d but a large-scale delivery challenge, with around 12 million historic agreements expected to be reviewed.\n\nFirms will need to move quickly to ensure fair, consistent outcomes while meeting the FCA's expectation to compensate the majority of consumers by 2027.\n\nThe scale of the exercise, covering nearly two decades of agreements across two parallel processes, means lenders and dealers face significant operational demands alongside the need for consistent customer treatment.\n\nThe scheme affects motor finance lenders and dealers with agreements dating from 2007 to 2024, and by extension the wider lending and consumer credit sector.\n\n\u2022 Operational strain from reviewing around 12 million historic agreements\n\u2022 Inconsistent outcomes across two parallel redress exercises covering different time periods\n\u2022 Missing the FCA's expectation to compensate the majority of consumers by 2027\n\n1. Review the FCA's detailed rules for both the 2007\u20132014 and 2014\u20132024 redress exercises.\n2. Assess the operational capacity needed to review historic agreements at scale.\n3. Put plans in place to deliver fair, consistent outcomes ahead of the FCA's 2027 expectation.\n\nNorburn's comments frame the scheme as a delivery challenge as much as a compensation exercise, meaning firms' operational readiness will be as important to the outcome as the underlying redress rules.\n\nLenders and dealers should treat the scheme as a large-scale programme requiring dedicated resourcing and consistent processes, rather than a routine compensation exercise.", "wordCount": 318, "keywords": [ "Complaints & Claims Handling", "Compliance AI & RegTech", "Consumer Duty", "Redress & Remediation", "Lending & Consumer Credit", "Motor Finance" ], "about": [ { "@type": "Thing", "name": "Complaints & Claims Handling", "url": "https://tcc.group/blog/solution/complaints-claims-handling/" }, { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Consumer Duty", "url": "https://tcc.group/blog/solution/consumer-duty/" }, { "@type": "Thing", "name": "Redress & Remediation", "url": "https://tcc.group/blog/solution/redress-and-remediation/" }, { "@type": "Thing", "name": "Lending & Consumer Credit", "url": "https://tcc.group/blog/sector/lending-consumer-credit/" }, { "@type": "Thing", "name": "Motor Finance", "url": "https://tcc.group/blog/sector/motor-finance/" }, { "@type": "Thing", "name": "Motor finance redress scheme" } ], "articleSection": [ "Complaints & Claims Handling", "Compliance AI & RegTech", "Consumer Duty", "Redress & Remediation" ], "audience": [ { "@type": "Audience", "audienceType": "Lending & Consumer Credit" }, { "@type": "Audience", "audienceType": "Motor Finance" }, { "@type": "Audience", "audienceType": "Compliance and operations leaders at motor finance lenders and dealers preparing for the redress scheme." } ], "citation": [ { "@type": "CreativeWork", "name": "AM\u2013Online offers industry experts\u2019 reaction to the FCA motor finance redress scheme", "url": "https://tcc.group/blog/2026/04/01/am-online-industry-reacts-to-fca-motor-finance-redress-scheme/", "datePublished": "2026-04-01" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/analysis-perspectives/am-online-industry-reacts-to-fca-motor-finance-redress-scheme/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/am-online-industry-reacts-to-fca-motor-finance-redress-scheme/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "How will the FCA's motor finance redress scheme run?", "acceptedAnswer": { "@type": "Answer", "text": "It will run as two parallel exercises, covering agreements from 2007 to 2014 and from 2014 to 2024." } }, { "@type": "Question", "name": "How many agreements are expected to be reviewed?", "acceptedAnswer": { "@type": "Answer", "text": "Around 12 million historic agreements are expected to be reviewed." } }, { "@type": "Question", "name": "By when does the FCA expect most consumers to be compensated?", "acceptedAnswer": { "@type": "Answer", "text": "The FCA expects the majority of consumers to be compensated by 2027." } }, { "@type": "Question", "name": "Is this just a compensation exercise?", "acceptedAnswer": { "@type": "Answer", "text": "No. Joe Norburn describes it as a large-scale delivery challenge, not a simple compensation exercise." } } ] } ] } ``` ### FCA's final motor finance redress scheme: What lenders need to do now - URL: https://tcc.group/insights/regulatory-horizon/fca-final-motor-finance-redress-scheme-next-steps-for-lenders/ - Published: 2026-03-30 - Modified: 2026-09-02 **Topic:** Motor Finance Redress The FCA's publication of PS26/3 sets out the final rules for the Motor Finance Consumer Redress Scheme, dividing the program into two distinct operational schemes with complex cap structures. #### What happened? On 30 March 2026, the Financial Conduct Authority (FCA) published PS26/3, containing the final rules for its motor finance consumer redress scheme. This is the largest structured redress program in the UK retail lending market since PPI, affecting an estimated 12.1 million agreements. The scheme targets widespread inadequate disclosure of discretionary commission arrangements (DCAs), high commission arrangements, and exclusive tie-ins. The regulator has structured this into two parallel schemes: Scheme 1 covers agreements from April 2007 to March 2014, while Scheme 2 covers April 2014 to November 2024. #### Why does it matter? The final rules differ significantly from the original CP25/27 consultation, introducing two parallel schemes with separate rules, de minimis thresholds (£120 for Scheme 1, £150 for Scheme 2), and separate implementation periods (3 months for Scheme 2, 5 months for Scheme 1). Crucially, the high commission threshold was raised to 39%, zero-APR and captive arrangements are excluded, and three complex redress caps were introduced to prevent over-compensation. However, formerly rejected complainants are now reclassified as opt-in, creating serious proactive outreach burdens. #### Who is affected? All motor finance lenders, retail credit brokers, automotive captives, and credit intermediaries in the UK are directly affected by these sweeping changes. #### Key risks Lenders face critical compliance and operational risks if their preparations are insufficient: - Severe backlogs and failure to handle provisional decisions within strict 3-month post-implementation deadlines. - Incorrect redress calculations failing to apply the new triple-cap rules, leading to under- or over-compensation. - Incomplete identification and proactive notification of the opt-in 'rejected complaints' cohort. #### Actions to take Lenders must act immediately to establish compliant operational processes: 1. Notify the FCA by 22 April 2026 of the intent to use the implementation period, naming a designated Senior Manager. 2. Submit a comprehensive Scheme Implementation Plan and delivery forecast with Senior Manager attestation by 6 May 2026. 3. Re-model portfolio exposure using the new 39% threshold, de minimis limits, and hybrid calculation caps. #### Wider implications The shift to a split-scheme format and complex redress caps indicates the regulator's attempt to balance consumer protection with market stability, yet the operational complexity of managing two parallel streams places extreme pressure on internal systems. #### Recommendations Lenders should deploy specialized external managed services and custom redress calculators to automate pre-screening, handle volume spikes, and secure robust, independent audit trails. #### Supporting sources - [FCA's final motor finance redress scheme: What lenders need to do now](https://tcc.group/blog/2026/03/30/fca-final-motor-finance-redress-scheme-next-steps-for-lenders/) (2026-03-30) #### Are your motor finance redress calculators ready? Contact our motor finance compliance and managed services teams to deploy scalable, triple-cap compliant redress calculators and audit frameworks. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/insights/regulatory-horizon/fca-final-motor-finance-redress-scheme-next-steps-for-lenders/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Insights", "item": "https://tcc.group/insights/" }, { "@type": "ListItem", "position": 3, "name": "FCA’s final motor finance redress scheme: What lenders need to do now", "item": "https://tcc.group/insights/regulatory-horizon/fca-final-motor-finance-redress-scheme-next-steps-for-lenders/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/regulatory-horizon/fca-final-motor-finance-redress-scheme-next-steps-for-lenders/#webpage", "url": "https://tcc.group/insights/regulatory-horizon/fca-final-motor-finance-redress-scheme-next-steps-for-lenders/", "name": "FCA’s final motor finance redress scheme: What lenders need to do now", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-03-31T00:00:00+01:00", "dateModified": "2026-09-02T03:47:41+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/regulatory-horizon/fca-final-motor-finance-redress-scheme-next-steps-for-lenders/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "Article", "@id": "https://tcc.group/insights/regulatory-horizon/fca-final-motor-finance-redress-scheme-next-steps-for-lenders/#article", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/fca-final-motor-finance-redress-scheme-next-steps-for-lenders/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "FCA’s final motor finance redress scheme: What lenders need to do now", "datePublished": "2026-03-31T00:00:00+01:00", "dateModified": "2026-09-02T03:47:41+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/regulatory-horizon/fca-final-motor-finance-redress-scheme-next-steps-for-lenders/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/131e7422752c42a983b45ce9dc15241e/thumbnail-1600-6e259dfa292e3fc98c4fbc2ac690c5d14f8c40b69895c2dca54b45ab11f59809.jpg", "description": "The FCA has published its final Motor Finance Consumer Redress Scheme, split into two distinct schemes with strict implementation periods and complex hybrid calculation caps. Learn how lenders must adapt.", "inLanguage": "en-GB", "articleBody": "The FCA's publication of PS26/3 sets out the final rules for the Motor Finance Consumer Redress Scheme, dividing the program into two distinct operational schemes with complex cap structures.\n\nOn 30 March 2026, the Financial Conduct Authority (FCA) published PS26/3, containing the final rules for its motor finance consumer redress scheme. This is the largest structured redress program in the UK retail lending market since PPI, affecting an estimated 12.1 million agreements.\n\nThe scheme targets widespread inadequate disclosure of discretionary commission arrangements (DCAs), high commission arrangements, and exclusive tie-ins. The regulator has structured this into two parallel schemes: Scheme 1 covers agreements from April 2007 to March 2014, while Scheme 2 covers April 2014 to November 2024.\n\nThe final rules differ significantly from the original CP25/27 consultation, introducing two parallel schemes with separate rules, de minimis thresholds (\u00a3120 for Scheme 1, \u00a3150 for Scheme 2), and separate implementation periods (3 months for Scheme 2, 5 months for Scheme 1).\n\nCrucially, the high commission threshold was raised to 39%, zero-APR and captive arrangements are excluded, and three complex redress caps were introduced to prevent over-compensation. However, formerly rejected complainants are now reclassified as opt-in, creating serious proactive outreach burdens.\n\nAll motor finance lenders, retail credit brokers, automotive captives, and credit intermediaries in the UK are directly affected by these sweeping changes.\n\nLenders face critical compliance and operational risks if their preparations are insufficient:\n\n\u2022 Severe backlogs and failure to handle provisional decisions within strict 3-month post-implementation deadlines.\n\u2022 Incorrect redress calculations failing to apply the new triple-cap rules, leading to under- or over-compensation.\n\u2022 Incomplete identification and proactive notification of the opt-in 'rejected complaints' cohort.\n\nLenders must act immediately to establish compliant operational processes:\n\n1. Notify the FCA by 22 April 2026 of the intent to use the implementation period, naming a designated Senior Manager.\n2. Submit a comprehensive Scheme Implementation Plan and delivery forecast with Senior Manager attestation by 6 May 2026.\n3. Re-model portfolio exposure using the new 39% threshold, de minimis limits, and hybrid calculation caps.\n\nThe shift to a split-scheme format and complex redress caps indicates the regulator's attempt to balance consumer protection with market stability, yet the operational complexity of managing two parallel streams places extreme pressure on internal systems.\n\nLenders should deploy specialized external managed services and custom redress calculators to automate pre-screening, handle volume spikes, and secure robust, independent audit trails.", "wordCount": 397, "keywords": [ "Complaints & Claims Handling", "Redress & Remediation", "Regulatory Change & Transformation", "Lending & Consumer Credit", "Motor Finance" ], "about": [ { "@type": "Thing", "name": "Complaints & Claims Handling", "url": "https://tcc.group/blog/solution/complaints-claims-handling/" }, { "@type": "Thing", "name": "Redress & Remediation", "url": "https://tcc.group/blog/solution/redress-and-remediation/" }, { "@type": "Thing", "name": "Regulatory Change & Transformation", "url": "https://tcc.group/blog/solution/regulatory-change-transformation/" }, { "@type": "Thing", "name": "Lending & Consumer Credit", "url": "https://tcc.group/blog/sector/lending-consumer-credit/" }, { "@type": "Thing", "name": "Motor Finance", "url": "https://tcc.group/blog/sector/motor-finance/" }, { "@type": "Thing", "name": "Motor Finance Redress" } ], "articleSection": [ "Complaints & Claims Handling", "Redress & Remediation", "Regulatory Change & Transformation" ], "audience": [ { "@type": "Audience", "audienceType": "Lending & Consumer Credit" }, { "@type": "Audience", "audienceType": "Motor Finance" }, { "@type": "Audience", "audienceType": "Executive boards, compliance heads, operations directors, and risk officers at motor finance lenders." } ], "citation": [ { "@type": "CreativeWork", "name": "FCA's final motor finance redress scheme: What lenders need to do now", "url": "https://tcc.group/blog/2026/03/30/fca-final-motor-finance-redress-scheme-next-steps-for-lenders/", "datePublished": "2026-03-30" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/regulatory-horizon/fca-final-motor-finance-redress-scheme-next-steps-for-lenders/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/fca-final-motor-finance-redress-scheme-next-steps-for-lenders/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "How are Scheme 1 and Scheme 2 differentiated?", "acceptedAnswer": { "@type": "Answer", "text": "Scheme 1 covers agreements from April 2007 to March 2014 with a \u00a3120 de minimis threshold. Scheme 2 covers April 2014 to November 2024 with a \u00a3150 de minimis threshold." } }, { "@type": "Question", "name": "What is the timeline for operational readiness?", "acceptedAnswer": { "@type": "Answer", "text": "Lenders must achieve full operational readiness by 30 June 2026 for Scheme 2, and by 31 August 2026 for Scheme 1." } } ] } ] } ``` ### FCA announced Motor Finance consumer redress scheme - URL: https://tcc.group/insights/regulatory-horizon/fca-motor-redress-announced/ - Published: 2026-03-29 - Modified: 2026-09-02 **Topic:** Confirmed Redress Scheme The FCA has officially confirmed a standardised, industry-wide compensation scheme for car finance customers affected by undisclosed commission arrangements between 2007 and 2024. #### What happened? The Financial Conduct Authority (FCA) has officially confirmed that it will introduce a standardised, industry-wide compensation scheme for millions of motor finance customers. The decision follows extensive evidence of firms failing to comply with legal and regulatory standards regarding commission disclosures on car finance agreements. Lenders will be required to proactively assess affected portfolios from 2007 to 2024 and provide standardised redress where consumers lost out. Payments are anticipated to commence before the end of 2026. #### Why does it matter? This confirmed scheme replaces case-by-case complaints handling with a rigid, standardised set of redress rules, aiming to balance consumer protection with market stability. TCC Group CEO Joe Norburn warns that with implementation timelines active, firms must move immediately from legal debate to operational execution. Firms must validate historical portfolios, clean data, and deploy robust calculation technologies to manage the scheme's massive scale under intense regulatory and public scrutiny. #### Supporting sources - [FCA announced Motor Finance consumer redress scheme](https://tcc.group/blog/2026/03/30/fca-announced-motor-finance-consumer-redress-scheme/) (2026-03-30) #### Is your motor finance redress strategy ready? Contact our compliance and managed services specialists to deploy secure, automated redress technology and scale your complaints operation. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/insights/regulatory-horizon/fca-motor-redress-announced/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Insights", "item": "https://tcc.group/insights/" }, { "@type": "ListItem", "position": 3, "name": "FCA announced Motor Finance consumer redress scheme", "item": "https://tcc.group/insights/regulatory-horizon/fca-motor-redress-announced/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/regulatory-horizon/fca-motor-redress-announced/#webpage", "url": "https://tcc.group/insights/regulatory-horizon/fca-motor-redress-announced/", "name": "FCA announced Motor Finance consumer redress scheme", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-03-30T00:00:00+01:00", "dateModified": "2026-09-02T03:47:43+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/regulatory-horizon/fca-motor-redress-announced/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "NewsArticle", "@id": "https://tcc.group/insights/regulatory-horizon/fca-motor-redress-announced/#article", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/fca-motor-redress-announced/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "FCA announced Motor Finance consumer redress scheme", "datePublished": "2026-03-30T00:00:00+01:00", "dateModified": "2026-09-02T03:47:43+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/regulatory-horizon/fca-motor-redress-announced/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": null, "description": "The FCA has confirmed the introduction of an industry-wide compensation scheme for motor finance customers sold products with undisclosed commissions between 2007 and 2024. Learn how lenders must respond.", "inLanguage": "en-GB", "articleBody": "The FCA has officially confirmed a standardised, industry-wide compensation scheme for car finance customers affected by undisclosed commission arrangements between 2007 and 2024.\n\nThe Financial Conduct Authority (FCA) has officially confirmed that it will introduce a standardised, industry-wide compensation scheme for millions of motor finance customers. The decision follows extensive evidence of firms failing to comply with legal and regulatory standards regarding commission disclosures on car finance agreements.\n\nLenders will be required to proactively assess affected portfolios from 2007 to 2024 and provide standardised redress where consumers lost out. Payments are anticipated to commence before the end of 2026.\n\nThis confirmed scheme replaces case-by-case complaints handling with a rigid, standardised set of redress rules, aiming to balance consumer protection with market stability. TCC Group CEO Joe Norburn warns that with implementation timelines active, firms must move immediately from legal debate to operational execution.\n\nFirms must validate historical portfolios, clean data, and deploy robust calculation technologies to manage the scheme's massive scale under intense regulatory and public scrutiny.", "wordCount": 167, "keywords": [ "Complaints & Claims Handling", "Redress & Remediation", "Regulatory Change & Transformation", "Lending & Consumer Credit", "Motor Finance" ], "about": [ { "@type": "Thing", "name": "Complaints & Claims Handling", "url": "https://tcc.group/blog/solution/complaints-claims-handling/" }, { "@type": "Thing", "name": "Redress & Remediation", "url": "https://tcc.group/blog/solution/redress-and-remediation/" }, { "@type": "Thing", "name": "Regulatory Change & Transformation", "url": "https://tcc.group/blog/solution/regulatory-change-transformation/" }, { "@type": "Thing", "name": "Lending & Consumer Credit", "url": "https://tcc.group/blog/sector/lending-consumer-credit/" }, { "@type": "Thing", "name": "Motor Finance", "url": "https://tcc.group/blog/sector/motor-finance/" }, { "@type": "Thing", "name": "Confirmed Redress Scheme" } ], "articleSection": [ "Complaints & Claims Handling", "Redress & Remediation", "Regulatory Change & Transformation" ], "audience": [ { "@type": "Audience", "audienceType": "Lending & Consumer Credit" }, { "@type": "Audience", "audienceType": "Motor Finance" }, { "@type": "Audience", "audienceType": "CEOs, compliance heads, and operations managers at automotive lenders and credit brokers." } ], "citation": [ { "@type": "CreativeWork", "name": "FCA announced Motor Finance consumer redress scheme", "url": "https://tcc.group/blog/2026/03/30/fca-announced-motor-finance-consumer-redress-scheme/", "datePublished": "2026-03-30" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/regulatory-horizon/fca-motor-redress-announced/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/fca-motor-redress-announced/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What is the confirmed motor finance redress scheme?", "acceptedAnswer": { "@type": "Answer", "text": "It is an industry-wide compensation scheme requiring lenders to proactively assess car finance sales from 2007 to 2024 and compensate consumers affected by undisclosed commission rules." } }, { "@type": "Question", "name": "When will compensation payments begin under the scheme?", "acceptedAnswer": { "@type": "Answer", "text": "The FCA expects standardized compensation payments to consumers to begin before the end of 2026." } } ] } ] } ``` ### FCA drives informed, sustainable decisions - URL: https://tcc.group/insights/analysis-perspectives/fca-drives-informed-sustainable-decisions/ - Published: 2026-03-26 - Modified: 2026-09-02 **Topic:** Sustainable Financial Decisions TCC Group CEO Joe Norburn outlines the FCA's efforts to ensure consumers make informed and sustainable financial decisions through enhanced disclosure standards and transparency. #### What happened? TCC Group CEO Joe Norburn was featured in IT Supply Chain, discussing how the Financial Conduct Authority (FCA) is aligning its efforts to help consumers make more informed and sustainable financial decisions. The regulator is intensifying its focus on the quality and clarity of disclosures across all financial products. #### Why does it matter? As market demand grows for transparency around sustainability and environmental, social, and governance (ESG) factors, firms must deliver unambiguous, highly accessible product disclosures. Aligning product materials with Consumer Duty expectations ensures customers are not misled and can choose products that truly fit their preferences. #### Supporting sources - [FCA drives informed, sustainable decisions](https://tcc.group/blog/2026/03/27/fca-drives-informed-sustainable-decisions/) (2026-03-27) #### Are your product disclosures clear and compliant? Get in touch with our regulatory experts to verify your product transparency and ensure compliance with the latest FCA disclosure guidelines. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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TCC Group's CEO Joe Norburn was featured in Accountancy Daily to discuss the introduction of tighter rules for Buy Now, Pay Later (BNPL) loans and what they mean for firms and consumers. The article highlights how the FCA is bringing the previously unregulated BNPL market - valued at around £13bn - under its supervision, responding to growing concerns around consumer protection and rising usage of the product. #### Why does it matter? Buy Now Pay Later has grown into a £13bn market largely outside formal regulation, leaving gaps in how affordability is assessed and how clearly costs and risks are disclosed to consumers. Bringing BNPL within the FCA's remit signals that firms offering this form of credit will need to meet the same standards of transparency and responsible lending expected elsewhere in consumer credit. #### Supporting sources - [Tighter rules for buy now pay later loans](https://tcc.group/blog/2026/03/27/tighter-rules-for-buy-now-pay-later-loans/) (2026-03-27) #### Preparing for BNPL regulation? Talk to our team about getting your Buy Now Pay Later proposition ready for FCA supervision. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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deliver tangible outcomes. #### What happened? TCC Group's CEO Joe Norburn was featured in Compliance Week to discuss the FCA's evolving enforcement strategy and what it means for firms. The article highlights how the FCA is reducing the number of investigations it pursues, closing around 100 cases in recent years that were unlikely to lead to action, as part of a broader shift toward prioritising cases that deliver tangible outcomes. #### Why does it matter? A leaner caseload suggests the FCA is directing its resources toward higher-impact investigations, which could mean faster outcomes but also closer scrutiny for the cases that remain open. Firms under investigation, or at risk of one, should expect the regulator to move with greater focus on cases it judges likely to result in action. #### Supporting sources - [U.K. financial regulator cuts cases to focus on investigations](https://tcc.group/blog/2026/03/27/uk-financial-regulator-cuts-cases-to-focus-on-investigations/) (2026-03-27) #### Facing an FCA investigation? Speak to our team about navigating an FCA investigation or strengthening your enforcement readiness. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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resources on cases most likely to deliver real outcomes, and what this shift in enforcement strategy means for regulated firms.", "inLanguage": "en-GB", "articleBody": "The FCA is closing around 100 investigations that were unlikely to lead to action, as part of a broader shift toward prioritising cases that deliver tangible outcomes.\n\nTCC Group's CEO Joe Norburn was featured in Compliance Week to discuss the FCA's evolving enforcement strategy and what it means for firms.\n\nThe article highlights how the FCA is reducing the number of investigations it pursues, closing around 100 cases in recent years that were unlikely to lead to action, as part of a broader shift toward prioritising cases that deliver tangible outcomes.\n\nA leaner caseload suggests the FCA is directing its resources toward higher-impact investigations, which could mean faster outcomes but also closer scrutiny for the cases that remain open.\n\nFirms under investigation, or at risk of one, should expect the 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"@type": "Question", "name": "How many cases has the FCA closed?", "acceptedAnswer": { "@type": "Answer", "text": "The article reports that the FCA has closed around 100 cases in recent years that were unlikely to lead to action." } }, { "@type": "Question", "name": "Why is the FCA changing its enforcement approach?", "acceptedAnswer": { "@type": "Answer", "text": "The regulator is prioritising cases that deliver tangible outcomes rather than pursuing investigations less likely to result in action." } }, { "@type": "Question", "name": "What does this mean for firms under investigation?", "acceptedAnswer": { "@type": "Answer", "text": "Firms should expect the FCA to focus its resources more tightly on cases it judges likely to lead to enforcement action." } } ] } ] } ``` ### TCC Group: FCA Review Impact on Advice & Wealth Firms - URL: https://tcc.group/insights/analysis-perspectives/tcc-group-fca-review-impact-on-advice-wealth-firms/ - Published: 2026-03-26 - Modified: 2026-03-26 **Topic:** FCA Consolidation Review TCC Group CEO Joe Norburn discusses the FCA's consolidation review in an article for Wealth DFM, examining consolidation trends across the advice and wealth management sector. #### What happened? TCC Group CEO Joe Norburn has featured in *Wealth DFM* discussing the FCA's consolidation review and its implications for advice and wealth management firms. The article describes consolidation as a defining trend across the sector, bringing opportunities for growth alongside increased regulatory scrutiny of governance, financial resilience and client outcomes. It also explores the challenges firms face in managing acquisitions, including the need for due diligence and integration planning to maintain client outcomes as the market continues to evolve. #### Why does it matter? For firms considering an acquisition or merger, or reviewing their exposure to a consolidating market, the article highlights that regulatory attention is likely to focus on how well governance, financial resilience and client outcomes are maintained through the process, not simply on the commercial rationale for a deal. #### Supporting sources - [TCC Group: FCA Review Impact on Advice & Wealth Firms](https://tcc.group/blog/2026/03/27/tcc-group-fca-review-impact-on-advice-wealth-firms/) (2026-03-27) #### Considering a merger or acquisition? Speak to our team about managing due diligence, integration and client outcomes through consolidation. 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The FCA has released guidance highlighting a shift in its expectations around non-financial misconduct. As firms work to align their culture and governance with these standards, understanding what the regulator expects is central to fostering a compliant, ethical workplace. #### Why does it matter? The FCA has set out several actions firms are expected to take to manage the risks associated with non-financial misconduct, spanning policy, culture, training, monitoring, stakeholder engagement and independent validation. Firms that cannot evidence progress against these areas risk being seen as non-compliant with the regulator's revised expectations. #### Who is affected? Firms across financial services sectors, and in particular HR, risk and compliance functions responsible for policy, culture, training and governance of conduct. #### Key risks - Policies that do not clearly define unacceptable behaviours or a framework for reporting and responding to incidents. - A culture where employees do not feel safe to speak up about misconduct. - Training that is inconsistent or fails to reinforce the firm's values and expectations. - Senior management accountability under the Senior Managers and Certification Regime (SM&CR) that is not clearly documented. #### Actions to take 1. Establish clear policies and procedures that define unacceptable behaviours and set out a framework for reporting and responding to incidents. 2. Cultivate a supportive culture in which leadership models appropriate behaviour and employees feel safe to speak up. 3. Implement effective, regular training that reinforces the firm's values and equips staff to identify and address issues. 4. Monitor and review practices continuously, using metrics to assess the effectiveness of initiatives and adjust based on feedback and incidents. 5. Engage transparently with stakeholders, including customers and the regulator, and use feedback to enhance policies and practices. 6. Seek independent validation to design frameworks that bring structure and consistency to decision-making across HR, risk and compliance. #### Wider implications A key focus for firms is governance: clarifying senior management accountability under SM&CR, strengthening oversight and ensuring decisions are documented and escalated where applicable. There is also increasing demand for better insight into culture and conduct risk, with management information that moves beyond individual cases to show patterns, trends and outcomes. #### Recommendations The objective is not simply to meet regulatory expectations but to embed approaches that are sustainable and can be applied consistently, so that they stand up to scrutiny over time. TCC's experts work with firms to support the design of frameworks that align approaches across HR, risk and compliance. #### Supporting sources - [Five priorities for managing non-financial misconduct risk](https://tcc.group/blog/2026/03/26/non-financial-misconduct-risk/) (2026-03-26) #### Reviewing your approach to misconduct risk? TCC helps firms design consistent, well-governed frameworks for assessing and managing non-financial misconduct. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/insights/regulatory-horizon/non-financial-misconduct-risk/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Insights", "item": "https://tcc.group/insights/" }, { "@type": "ListItem", "position": 3, "name": "Five priorities for managing non-financial misconduct risk", "item": "https://tcc.group/insights/regulatory-horizon/non-financial-misconduct-risk/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/regulatory-horizon/non-financial-misconduct-risk/#webpage", "url": "https://tcc.group/insights/regulatory-horizon/non-financial-misconduct-risk/", "name": "Five priorities for managing non-financial misconduct risk", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-03-26T00:00:00+01:00", "dateModified": "2026-09-02T03:47:58+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/regulatory-horizon/non-financial-misconduct-risk/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "NewsArticle", "@id": "https://tcc.group/insights/regulatory-horizon/non-financial-misconduct-risk/#article", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/non-financial-misconduct-risk/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "Five priorities for managing non-financial misconduct risk", "datePublished": "2026-03-26T00:00:00+01:00", "dateModified": "2026-09-02T03:47:58+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/regulatory-horizon/non-financial-misconduct-risk/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/96b9653491224829a56bebadf6f195cf/thumbnail-1024-4251ca8f730f047f4f981be10015b4cb336f8649e3b3d3c14e8b6601ff19e3d7.jpg", "description": "The FCA's focus on non-financial misconduct is reshaping regulatory expectations. This sets out five practical priorities, from policy and culture to independent validation, that firms should address now.", "inLanguage": "en-GB", "articleBody": "The FCA's recent focus on non-financial misconduct signals a shift in regulatory expectations, and firms need clear policies, cultural change and independent validation to manage the risk and demonstrate compliance.\n\nThe FCA has released guidance highlighting a shift in its expectations around non-financial misconduct. As firms work to align their culture and governance with these standards, understanding what the regulator expects is central to fostering a compliant, ethical workplace.\n\nThe FCA has set out several actions firms are expected to take to manage the risks associated with non-financial misconduct, spanning policy, culture, training, monitoring, stakeholder engagement and independent validation. Firms that cannot evidence progress against these areas risk being seen as non-compliant with the regulator's revised expectations.\n\nFirms across financial services sectors, and in particular HR, risk and compliance functions responsible for policy, culture, training and governance of conduct.\n\n\u2022 Policies that do not clearly define unacceptable behaviours or a framework for reporting and responding to incidents.\n\u2022 A culture where employees do not feel safe to speak up about misconduct.\n\u2022 Training that is inconsistent or fails to reinforce the firm's values and expectations.\n\u2022 Senior management accountability under the Senior Managers and Certification Regime (SM&CR) that is not clearly documented.\n\n1. Establish clear policies and procedures that define unacceptable behaviours and set out a framework for reporting and responding to incidents.\n2. Cultivate a supportive culture in which leadership models appropriate behaviour and employees feel safe to speak up.\n3. Implement effective, regular training that reinforces the firm's values and equips staff to identify and address issues.\n4. Monitor and review practices continuously, using metrics to assess the effectiveness of initiatives and adjust based on feedback and incidents.\n5. Engage transparently with stakeholders, including customers and the regulator, and use feedback to enhance policies and practices.\n6. Seek independent validation to design frameworks that bring structure and consistency to decision-making across HR, risk and compliance.\n\nA key focus for firms is governance: clarifying senior management accountability under SM&CR, strengthening oversight and ensuring decisions are documented and escalated where applicable. There is also increasing demand for better insight into culture and conduct risk, with management information that moves beyond individual cases to show patterns, trends and outcomes.\n\nThe objective is not simply to meet regulatory expectations but to embed approaches that are sustainable and can be applied consistently, so that they stand up to scrutiny over time. 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Following its inaugural Regulatory Priorities report for Consumer Investments, the FCA has published its much-anticipated consultation on simplifying pensions and investment advice rules, with a Policy Statement expected in Q4 2026. The consultation sets out three main proposals. First, replacing COBS 9 and COBS 9A with a single new chapter, COBS 9C, covering basic, simplified, comprehensive and ongoing advice (targeted support rules remain in COBS 9B). Second, replacing the requirement to obtain "necessary" information with an expectation to take account of "sufficient" information, so firms gather only what is genuinely needed to demonstrate suitability rather than defaulting to a comprehensive fact-find regardless of scope. Third, removing the mandatory annual assessment rule for ongoing advice, giving firms flexibility over how frequently periodic reviews take place, alongside lower charges for less frequent reviews. #### Why does it matter? The proposals will have a material impact on the business models of all wealth management firms. Firms advising across different product types currently maintain parallel processes to comply with different rule sets, and consolidating them into COBS 9C means existing policies and procedures will need to be mapped across before the new rules take effect. The consultation also gives further detail on the FCA's expectations for client disengagement processes, placing significant onus on firms to design these consistently with the Consumer Duty rather than relying on new prescriptive rules. #### Who is affected? All wealth management firms providing advice on investments and pensions, particularly those operating ongoing advice or service propositions with periodic review charges. #### Key risks - Policies and procedures not being mapped from COBS 9 and 9A to the new COBS 9C structure before it comes into force. - Defaulting to comprehensive fact-finds rather than proportionate, "sufficient" information gathering. - Fair value assessments and disengagement processes not being ready ahead of the FCA's multi-firm work on ongoing advice. #### Actions to take 1. Read the consultation and map existing COBS 9 and 9A policies and procedures to the proposed COBS 9C structure. 2. Design differentiated advice processes based on client complexity, collecting only "sufficient" know-your-customer information. 3. Review periodic review frequency and client disengagement processes for consistency with the Consumer Duty. 4. Check current fair value assessments are compliant ahead of the FCA's multi-firm work on ongoing advice. #### Wider implications The changes reflect a wider FCA move towards a less prescriptive rulebook, placing more onus on firms to design their own compliant processes consistent with the Consumer Duty rather than following new detailed rules. #### Recommendations TCC's regulatory experts can talk firms through the CP26/10 proposals and give practical steps to take before the new rules come into force and go live. #### Supporting sources - [Key takeaways from CP26/10: Simplifying pensions and investment](https://tcc.group/blog/2026/03/25/the-key-takeaways-from-cp26-10-simplifying-the-pensions-and-investment-advice-rules/) (2026-03-25) #### Need help preparing for CP26/10? Get in touch with TCC's regulatory experts to discuss what CP26/10 means for your firm's business model. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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"description": "Get a concise breakdown of the FCA's CP26/10 proposals to consolidate COBS 9 and 9A, simplify client information requirements and give firms more flexibility over ongoing suitability reviews.", "inLanguage": "en-GB", "articleBody": "The FCA has published CP26/10, a consultation proposing to consolidate COBS 9 and 9A, replace the 'necessary' information test with a 'sufficient' information standard, and remove the mandatory annual review requirement for ongoing advice.\n\nFollowing its inaugural Regulatory Priorities report for Consumer Investments, the FCA has published its much-anticipated consultation on simplifying pensions and investment advice rules, with a Policy Statement expected in Q4 2026.\n\nThe consultation sets out three main proposals. First, replacing COBS 9 and COBS 9A with a single new chapter, COBS 9C, covering basic, simplified, comprehensive and ongoing advice (targeted support rules remain in COBS 9B).\n\nSecond, replacing the requirement to obtain \"necessary\" information with an expectation to take account of \"sufficient\" information, so firms gather only what is genuinely needed to demonstrate suitability rather than defaulting to a comprehensive fact-find regardless of scope.\n\nThird, removing the mandatory annual assessment rule for ongoing advice, giving firms flexibility over how frequently periodic reviews take place, alongside lower charges for less frequent reviews.\n\nThe proposals will have a material impact on the business models of all wealth management firms. Firms advising across different product types currently maintain parallel processes to comply with different rule sets, and consolidating them into COBS 9C means existing policies and procedures will need to be mapped across before the new rules take effect.\n\nThe consultation also gives further detail on the FCA's expectations for client disengagement processes, placing significant onus on firms to design these consistently with the Consumer Duty rather than relying on new prescriptive rules.\n\nAll wealth management firms providing advice on investments and pensions, particularly those operating ongoing advice or service propositions with periodic review charges.\n\n\u2022 Policies and procedures not being mapped from COBS 9 and 9A to the new COBS 9C structure before it comes into force.\n\u2022 Defaulting to comprehensive fact-finds rather than proportionate, \"sufficient\" information gathering.\n\u2022 Fair value assessments and disengagement processes not being ready ahead of the FCA's multi-firm work on ongoing advice.\n\n1. Read the consultation and map existing COBS 9 and 9A policies and procedures to the proposed COBS 9C structure.\n2. Design differentiated advice processes based on client complexity, collecting only \"sufficient\" know-your-customer information.\n3. Review periodic review frequency and client disengagement processes for consistency with the Consumer Duty.\n4. 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The proposals would remove the mandatory annual assessment rule, giving firms flexibility to set review frequency based on client needs and value for money." } }, { "@type": "Question", "name": "What should firms do now, ahead of the rules coming into force?", "acceptedAnswer": { "@type": "Answer", "text": "Firms should review current fair value assessments and disengagement processes for compliance, and start mapping existing policies to the proposed COBS 9C structure." } } ] } ] } ``` ### FCA motor finance redress scheme announcement coming next Monday (30th March) - URL: https://tcc.group/insights/regulatory-horizon/motor-redress-pending/ - Published: 2026-03-23 - Modified: 2026-09-02 **Topic:** Motor Finance Redress Announcement The FCA is set to publish the final details of its motor finance redress scheme shortly after markets close on Monday 30 March 2026, a critical moment for lenders after months of anticipation since the October 2025 consultation. #### What happened? The FCA has announced that it will publish the final details of its motor finance redress scheme shortly after markets close on Monday 30 March 2026. This marks a critical moment for the sector, bringing clarity to a programme that has been closely watched since the initial consultation in October 2025. #### Why does it matter? While the announcement will provide the framework for compensation, the operational and evidential challenges for lenders remain significant. With millions of historic agreements in scope, firms will need to act quickly to deliver fair outcomes efficiently and in line with regulatory expectations. Early preparation, particularly around data integrity, governance and complaint handling, is likely to be the key differentiator between firms that can respond quickly and those that cannot. #### Who is affected? Motor finance lenders with historic agreements in scope of the scheme, and the teams responsible for complaint handling, data and remediation delivery. #### Key risks - Firms that have not assessed their affected customer base may struggle to respond at the pace the scheme requires. - Weak governance or fragmented operational frameworks could slow delivery of redress at scale. - Manual, non-automated processes may not cope with the expected volume of cases. #### Actions to take 1. Assess the affected customer base and review historical data for completeness and accuracy. 2. Strengthen governance and operational frameworks so that redress can be delivered at scale. 3. Implement technology-enabled solutions to automate calculations, trace customers and manage communications. #### Wider implications Firms that act swiftly and in a structured way will not only reduce their own risk but will also be better placed to deliver fair outcomes and demonstrate compliance with the FCA's expectations for timeliness and transparency. #### Recommendations TCC recommends that firms prioritise structured planning and data-driven approaches now, ahead of the announcement, rather than waiting for the final scheme details before starting preparation. #### Supporting sources - [FCA motor finance redress scheme announcement coming next Monday (30th March)](https://tcc.group/blog/2026/03/24/motor-redress-pending/) (2026-03-24) #### Ready for the redress scheme announcement? TCC helps lenders navigate large-scale redress with practical, bespoke support for efficient, data-driven remediation. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/insights/regulatory-horizon/motor-redress-pending/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Insights", "item": "https://tcc.group/insights/" }, { "@type": "ListItem", "position": 3, "name": "FCA motor finance redress scheme announcement coming next Monday (30th March)", "item": "https://tcc.group/insights/regulatory-horizon/motor-redress-pending/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/regulatory-horizon/motor-redress-pending/#webpage", "url": "https://tcc.group/insights/regulatory-horizon/motor-redress-pending/", "name": "FCA motor finance redress scheme announcement coming next Monday (30th March)", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-03-24T00:00:00+01:00", "dateModified": "2026-09-02T03:47:58+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/regulatory-horizon/motor-redress-pending/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "NewsArticle", "@id": "https://tcc.group/insights/regulatory-horizon/motor-redress-pending/#article", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/motor-redress-pending/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "FCA motor finance redress scheme announcement coming next Monday (30th March)", "datePublished": "2026-03-24T00:00:00+01:00", "dateModified": "2026-09-02T03:47:58+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/regulatory-horizon/motor-redress-pending/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/b86f4296786b447e822e30050427f882/thumbnail-1024-868dd370f0483ca0fa931711b6c3ad2ec43506ba0f9ada94af811c562874dd6d.jpg", "description": "The FCA will publish the final details of its motor finance redress scheme on 30 March 2026. This sets out what lenders should have ready before the announcement lands.", "inLanguage": "en-GB", "articleBody": "The FCA is set to publish the final details of its motor finance redress scheme shortly after markets close on Monday 30 March 2026, a critical moment for lenders after months of anticipation since the October 2025 consultation.\n\nThe FCA has announced that it will publish the final details of its motor finance redress scheme shortly after markets close on Monday 30 March 2026. This marks a critical moment for the sector, bringing clarity to a programme that has been closely watched since the initial consultation in October 2025.\n\nWhile the announcement will provide the framework for compensation, the operational and evidential challenges for lenders remain significant. With millions of historic agreements in scope, firms will need to act quickly to deliver fair outcomes efficiently and in line with regulatory expectations.\n\nEarly preparation, particularly around data integrity, governance and complaint handling, is likely to be the key differentiator between firms that can respond quickly and those that cannot.\n\nMotor finance lenders with historic agreements in scope of the scheme, and the teams responsible for complaint handling, data and remediation delivery.\n\n\u2022 Firms that have not assessed their affected customer base may struggle to respond at the pace the scheme requires.\n\u2022 Weak governance or fragmented operational frameworks could slow delivery of redress at scale.\n\u2022 Manual, non-automated processes may not cope with the expected volume of cases.\n\n1. Assess the affected customer base and review historical data for completeness and accuracy.\n2. 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Implement technology-enabled solutions to automate calculations, trace customers and manage communications.\n\nFirms that act swiftly and in a structured way will not only reduce their own risk but will also be better placed to deliver fair outcomes and demonstrate compliance with the FCA's expectations for timeliness and transparency.\n\nTCC recommends that firms prioritise structured planning and data-driven approaches now, ahead of the announcement, rather than waiting for the final scheme details before starting preparation.", "wordCount": 330, "keywords": [ "Complaints & Claims Handling", "Redress & Remediation", "Regulatory Change & Transformation", "Lending & Consumer Credit", "Motor Finance" ], "about": [ { "@type": "Thing", "name": "Complaints & Claims Handling", "url": "https://tcc.group/blog/solution/complaints-claims-handling/" }, { "@type": "Thing", "name": "Redress & Remediation", "url": "https://tcc.group/blog/solution/redress-and-remediation/" }, { "@type": "Thing", "name": "Regulatory Change & Transformation", "url": "https://tcc.group/blog/solution/regulatory-change-transformation/" }, { "@type": "Thing", "name": "Lending & Consumer Credit", "url": "https://tcc.group/blog/sector/lending-consumer-credit/" }, { "@type": "Thing", "name": "Motor Finance", "url": "https://tcc.group/blog/sector/motor-finance/" }, { "@type": "Thing", "name": "Motor Finance Redress Announcement" } ], "articleSection": [ "Complaints & Claims Handling", "Redress & Remediation", "Regulatory Change & Transformation" ], "audience": [ { "@type": "Audience", "audienceType": "Lending & Consumer Credit" }, { "@type": "Audience", "audienceType": "Motor Finance" }, { "@type": "Audience", "audienceType": "Motor finance lenders preparing operational and data readiness for a confirmed redress scheme." } ], "citation": [ { "@type": "CreativeWork", "name": "FCA motor finance redress scheme announcement coming next Monday (30th March)", "url": "https://tcc.group/blog/2026/03/24/motor-redress-pending/", "datePublished": "2026-03-24" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/regulatory-horizon/motor-redress-pending/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/motor-redress-pending/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "When will the FCA publish the motor finance redress scheme details?", "acceptedAnswer": { "@type": "Answer", "text": "The FCA has said it will publish the final details shortly after markets close on Monday 30 March 2026." } }, { "@type": "Question", "name": "Why does the timing of the announcement matter to lenders?", "acceptedAnswer": { "@type": "Answer", "text": "Publishing after markets close is intended to give the sector, including listed lenders, time to absorb the details in an orderly way." } }, { "@type": "Question", "name": "What should lenders have ready before the announcement?", "acceptedAnswer": { "@type": "Answer", "text": "Lenders should have assessed their affected customer base, reviewed historical data and strengthened governance so they can respond quickly once the scheme is confirmed." } }, { "@type": "Question", "name": "How can firms manage a large volume of redress cases?", "acceptedAnswer": { "@type": "Answer", "text": "TCC recommends technology-enabled solutions that automate calculations, trace customers and manage communications, alongside experienced resource to handle complex cases." } } ] } ] } ``` ### Insurance claims rewired: The rise of agentic AI - URL: https://tcc.group/insights/analysis-perspectives/insurance-claims-rewired-the-rise-of-agentic-ai/ - Published: 2026-03-19 - Modified: 2026-09-02 **Topic:** Agentic AI in Claims TCC Group CTO Kit Ruparel outlines in IT Briefing how agentic AI is moving from passive analysis to active, autonomous decision-making in insurance claims handling. #### What happened? In an article published in IT Briefing, TCC Group CTO Kit Ruparel explores the rise of 'agentic AI' in insurance claims handling. Unlike older, passive AI models that simply flag risks or analyze static data, agentic AI can actively assist in decision-making and execute complex workflows. These advanced tools can progress claims, manage communications, and support real-time decisions, representing a major technological leap for insurance automation. #### Why does it matter? The transition to agentic AI promises massive operational efficiencies and faster claim resolution. However, as machines take on active execution and decision-making roles, firms must establish robust governance frameworks to maintain meaningful human oversight, manage algorithmic bias, and ensure fair outcomes under the Consumer Duty. #### Supporting sources - [Insurance claims rewired: The rise of agentic AI](https://tcc.group/blog/2026/03/20/insurance-claims-rewired-the-rise-of-agentic-ai/) (2026-03-20) #### Ready to integrate agentic AI in your claims processes? Speak to our specialists to explore how our compliance AI advisory and resourcing can help you implement automated claims technology safely and compliantly. 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TCC Group (TCC, Momenta and Recordsure) chief executive Joe Norburn was featured in European Business Magazine to discuss how acquisitive firms can drive growth through consolidation. He set out the key challenges facing organisations going through a merger or acquisition: maintaining strong governance, carrying out disciplined due diligence, and ensuring effective integration throughout the process. #### Why does it matter? Issues that are overlooked early in a deal often re-emerge later, and at a significantly higher cost to fix. The regulator expects firms to manage risk proactively across the entire deal lifecycle, not just at the point of signing. Sustainable growth depends on the ability to scale with control and maintain clear oversight, not on consolidation alone. #### Who is affected? Wealth management and financial advice firms that are acquiring, merging with, or being acquired by another business, along with the boards and deal teams responsible for those transactions. #### Key risks - Governance weaknesses that are not addressed before completion - Due diligence gaps that leave liabilities undiscovered until after the deal closes - Poor integration that lets early problems resurface at a higher cost later #### Actions to take 1. Maintain strong governance throughout the consolidation process, not only at the outset 2. Carry out disciplined due diligence before committing to a deal 3. Plan for effective integration from the start, rather than treating it as an afterthought #### Wider implications As consolidation becomes a structural feature of the UK wealth market, driven by succession planning, regulatory pressure and cost, firms that cannot scale with control risk falling behind those that can. #### Recommendations Firms considering acquisitive growth should treat scaling with control as a strategic priority alongside deal volume, rather than allowing consolidation targets to outpace their oversight capacity. #### Supporting sources - [UK Wealth Mergers Aren't the Risk - Bad Execution Is](https://tcc.group/blog/2026/03/20/the-uk-wealth-management-merger-wave-isnt-the-risk-bad-execution-is/) (2026-03-20) #### Planning a wealth management acquisition? Talk to our team about building due diligence and integration processes that keep pace with your growth. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/insights/analysis-perspectives/the-uk-wealth-management-merger-wave-isnt-the-risk-bad-execution-is/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Insights", "item": "https://tcc.group/insights/" }, { "@type": "ListItem", "position": 3, "name": "UK Wealth Mergers Aren’t the Risk – Bad Execution Is", "item": "https://tcc.group/insights/analysis-perspectives/the-uk-wealth-management-merger-wave-isnt-the-risk-bad-execution-is/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/analysis-perspectives/the-uk-wealth-management-merger-wave-isnt-the-risk-bad-execution-is/#webpage", "url": "https://tcc.group/insights/analysis-perspectives/the-uk-wealth-management-merger-wave-isnt-the-risk-bad-execution-is/", "name": "UK Wealth Mergers Aren’t the Risk – Bad Execution Is", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-03-20T00:00:00+01:00", "dateModified": "2026-09-02T03:49:07+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/analysis-perspectives/the-uk-wealth-management-merger-wave-isnt-the-risk-bad-execution-is/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "AnalysisNewsArticle", "@id": "https://tcc.group/insights/analysis-perspectives/the-uk-wealth-management-merger-wave-isnt-the-risk-bad-execution-is/#article", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/the-uk-wealth-management-merger-wave-isnt-the-risk-bad-execution-is/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "UK Wealth Mergers Aren’t the Risk – Bad Execution Is", "datePublished": "2026-03-20T00:00:00+01:00", "dateModified": "2026-09-02T03:49:07+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/analysis-perspectives/the-uk-wealth-management-merger-wave-isnt-the-risk-bad-execution-is/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/a2b62bc16ac44755b8e3b8f4ab1eea46/thumbnail-1024-9613c3edbab67e75b228208cf1fe2f621599ee81b434ec881b19e8fbc9779a44.jpg", "description": "Learn why disciplined governance, due diligence and integration - 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completion." } } ] } ] } ``` ### Modernising consumer redress: What FCA CP26/9 means for firms - URL: https://tcc.group/insights/regulatory-horizon/modernising-the-redress-system-what-fca-cp26-9-means-for-firms/ - Published: 2026-03-19 - Modified: 2026-09-02 ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", 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TCC Group's CEO, Joe Norburn, featured in Professional Adviser to discuss how the FCA's Pure Protection Market Study is set to reshape the regulatory landscape for the sector, with increasing scrutiny of fair value, commission structures and customer outcomes. The article explores how distribution models, digital access and transparency are coming under closer review, alongside the challenges firms face in demonstrating good customer outcomes, particularly for vulnerable customers. #### Why does it matter? Joe Norburn's central message is that the Market Study should not be underestimated: it has the potential to reshape how pure protection products are distributed and how firms are expected to evidence fair value and good customer outcomes going forward. #### Supporting sources - [Pure protection in focus: FCA market study raises regulatory expectations for 2026](https://tcc.group/blog/2026/03/20/pure-protection-fca-study-raises-2026-expectations/) (2026-03-20) #### Want to understand the Market Study's impact? Speak to our team about what the FCA's Pure Protection Market Study could mean for your distribution model. 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Recordsure." } }, { "@type": "Question", "name": "What did Joe Norburn discuss in Professional Adviser?", "acceptedAnswer": { "@type": "Answer", "text": "He discussed how the FCA's Pure Protection Market Study is set to reshape the regulatory landscape, with increasing scrutiny of fair value, commission structures and customer outcomes." } } ] } ] } ``` ### FCA Consumer Finance Regulatory Priorities 2026: What it means for compliance leaders - URL: https://tcc.group/insights/regulatory-horizon/fca-consumer-finance-regulatory-priorities-2026-what-it-means-for-compliance-leaders/ - Published: 2026-03-18 - Modified: 2026-09-02 **Topic:** Consumer Finance Priorities The FCA has published its 2026 Consumer Finance Regulatory Priorities report, establishing core supervision expectations around credit accessibility, debt forbearance, and robust motor finance redress. #### What happened? The Financial Conduct Authority (FCA) released its Consumer Finance Regulatory Priorities report on 17 March 2026. This publication is part of a series of retail and wholesale supervision priority reports, and defines the regulator's specific expectations for consumer credit firms, brokers, hire firms, and debt collectors. The report highlights three primary focus areas: ensuring responsible access to credit, improving the quality of forbearance and debt support, and enforcing effective complaint and redress procedures. #### Why does it matter? With 79% of UK adults holding a credit agreement and over 3 million seeing applications declined, the FCA expects lenders to use alternative data like open banking to expand responsible access. For those struggling with debt, the FCA warns that forbearance and debt advice quality are not consistently meeting outcomes. Furthermore, the stakes are elevated for motor finance lenders due to the imminent lift of the Personal Contract Purchase (PCP) and Hire Purchase (HP) commission complaint pause on 31 May 2026 and the finalisation of CP25/27. #### Who is affected? Lenders, hire purchase firms, credit brokers, debt collectors, and claims management companies operating under FCA consumer credit permissions are directly affected. #### Key risks Firms that fail to address these regulatory priorities face major operational and compliance risks: - Critical backlogs and process failures when the motor finance commission complaint pause lifts. - FCA intervention and supervisory action for inadequate debt forbearance or complex, high-barrier customer journeys. - Incomplete regulatory returns under the new CCR009 return, inviting deep data-driven supervision and audit. #### Actions to take Compliance leaders should execute several strategic actions immediately: 1. Conduct a gap analysis of current affordability frameworks against the FCA priorities baseline. 2. Audit consumer debt support and forbearance processes to ensure barriers are eliminated. 3. Prepare complaints-handling and capital structures for the final motor finance redress scheme rules. #### Wider implications The FCA is transitioning to highly data-driven and outcomes-based supervision. Firms that can evidence robust, compliant consumer outcomes will experience a lighter-touch regulatory approach, while outliers will face intensified supervisory scrutiny. #### Recommendations We recommend implementing specialized complaints remediation technology and robust data governance to capture consumer outcome metrics and satisfy the new CCR009 returns. #### Supporting sources - [FCA Consumer Finance Regulatory Priorities 2026: What it means for compliance leaders](https://tcc.group/blog/2026/03/19/fca-consumer-finance-regulatory-priorities-2026-what-it-means-for-compliance-leaders/) (2026-03-19) #### Are you prepared for the lifting of the PCP pause? Speak to our motor finance and consumer credit compliance specialists to audit your readiness and prepare a robust redress framework. 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TCC Group Chief Technology Officer Kit Ruparel recently discussed the operational risks of Agentic AI in Ecommerce & Payments Briefing. He warned that autonomous AI tools operating across multiple platforms create novel vulnerabilities, including data leaks, compliance gaps, and security risks, particularly when deployed without strict oversight. #### Why does it matter? With the rapid rise of 'shadow AI' alongside specific risks like prompt injection and unintended actions, software errors can scale instantly. Ruparel emphasizes that agentic AI must be managed as high-risk infrastructure with robust governance, permissions, and security-first deployment rather than treated as simple chat tools. #### Supporting sources - [Ecommerce & Payments Briefing: The hidden risks inside Agentic AI systems](https://tcc.group/blog/2026/03/16/ecommerce-payments-briefing-the-hidden-risks-inside-agentic-ai-systems/) (2026-03-16) #### Are you governing your AI infrastructure securely? Get in touch with our fintech and regulatory technology experts to discuss robust governance frameworks for your autonomous systems. 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It comes as the regulator highlights that nearly 15 million people are not saving enough for retirement. #### What happened? The FCA has published its Pensions Regulatory Priorities report, the third in its 2026 series following Insurance and Consumer Investments, with six further sector reports due across the year. The report sets out the FCA’s supervision priorities, how it intends to enable innovation, and a ‘what we expect firms to do’ section that firms can use for gap analyses and monitoring plans. Speaking at the TISA Inclusive Investing Conference, the FCA’s Lucy Castledine highlighted that nearly 15 million people are not saving enough for retirement. #### Why does it matter? The report continues work on value for money, with proposals to tackle poorly performing workplace schemes to be followed by a wider review of value for money in pensions and savings products that allow investment in unit-linked funds. Firms may be required to transfer customers to better solutions if value for money is not delivered, which carries real operational and commercial impact for advisers and providers. The FCA is also moving to a ‘show me, don’t tell me’ supervisory approach, with the Enforcement Watch report showing 23 enforcement operations opened since 3 June 2025, six relating to potential Consumer Duty breaches. #### Who is affected? Pensions providers and advisers, particularly those operating workplace schemes or products allowing investment in unit-linked funds, sit at the centre of the value-for-money work. Firms supporting ‘gone-away’ customers or those with vulnerabilities face particular attention, since the FCA is concerned these groups risk poor retirement outcomes due to older or less innovative products. #### Key risks - Workplace schemes or unit-linked products that do not deliver adequate value for money. - Poor product governance, complex charging structures and lack of transparency for consumers. - Weak oversight of appointed representatives. - Consumers of older or less innovative products facing reduced choice, flexibility and higher costs. #### Actions to take 1. Use the ‘what we expect firms to do’ section as a gap analysis and monitoring tool. 2. Prepare for potential customer transfers if value for money is not being delivered. 3. Review product governance, charging structures and transparency, particularly for older or legacy products. 4. Strengthen oversight of appointed representatives and evidence of good consumer outcomes. #### Wider implications The Regulatory Initiatives Grid links this report to a wider Pension Reform Steering Committee Group agenda, bringing together the FCA, the Department for Work and Pensions, HM Treasury and The Pensions Regulator. That coordination, alongside measures in the Pension Schemes Bill and initiatives such as pensions dashboards, suggests the direction of travel on value for money and consumer support is unlikely to slow. #### Recommendations Test control frameworks against the FCA’s expectations now, rather than waiting for the next sector report or supervisory request. Focus particularly on evidencing good outcomes with reliable data, since the Consumer Duty’s emphasis on value for money, communication quality and consumer decision-making runs through this report. #### Supporting sources - [What the FCA’s Pensions Regulatory Priorities report means for pensions providers](https://tcc.group/blog/2026/03/12/what-the-fcas-pensions-regulatory-priorities-report-means-for-pensions-providers/) (2026-03-12) #### Ready to evidence good pension outcomes? Contact our regulatory experts to explore how we can support your Consumer Duty adherence. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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pensions providers", "item": "https://tcc.group/insights/regulatory-horizon/what-the-fcas-pensions-regulatory-priorities-report-means-for-pensions-providers/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/regulatory-horizon/what-the-fcas-pensions-regulatory-priorities-report-means-for-pensions-providers/#webpage", "url": "https://tcc.group/insights/regulatory-horizon/what-the-fcas-pensions-regulatory-priorities-report-means-for-pensions-providers/", "name": "What the FCA\u2019s Pensions Regulatory Priorities report means for pensions providers", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-03-12T00:00:00+01:00", "dateModified": "2026-09-02T03:49:11+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/regulatory-horizon/what-the-fcas-pensions-regulatory-priorities-report-means-for-pensions-providers/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "NewsArticle", "@id": "https://tcc.group/insights/regulatory-horizon/what-the-fcas-pensions-regulatory-priorities-report-means-for-pensions-providers/#article", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/what-the-fcas-pensions-regulatory-priorities-report-means-for-pensions-providers/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "What the FCA\u2019s Pensions Regulatory Priorities report means for pensions providers", "datePublished": "2026-03-12T00:00:00+01:00", "dateModified": "2026-09-02T03:49:11+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/regulatory-horizon/what-the-fcas-pensions-regulatory-priorities-report-means-for-pensions-providers/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/1501cf8e1e7a47c3820579b82f071c70/thumbnail-1024-1d8718c2218c88f7a5f13c427afcce0aa64df6d5d5c30538dac4031a76e11e6c.jpg", "description": "Discover the key priorities in the FCA's Pensions Regulatory Priorities report, from value-for-money reforms to modernising legacy products, and see what pensions providers need to do now to evidence good outcomes for the 15 million people not saving enough.", "inLanguage": "en-GB", "articleBody": "The FCA's Pensions Regulatory Priorities report, the third in its 2026 series, sets out expectations on value for money, consumer support and modernising older products. It comes as the regulator highlights that nearly 15 million people are not saving enough for retirement.\n\nThe FCA has published its Pensions Regulatory Priorities report, the third in its 2026 series following Insurance and Consumer Investments, with six further sector reports due across the year.\n\nThe report sets out the FCA\u2019s supervision priorities, how it intends to enable innovation, and a \u2018what we expect firms to do\u2019 section that firms can use for gap analyses and monitoring plans.\n\nSpeaking at the TISA Inclusive Investing Conference, the FCA\u2019s Lucy Castledine highlighted that nearly 15 million people are not saving enough for retirement.\n\nThe report continues work on value for money, with proposals to tackle poorly performing workplace schemes to be followed by a wider review of value for money in pensions and savings products that allow investment in unit-linked funds.\n\nFirms may be required to transfer customers to better solutions if value for money is not delivered, which carries real operational and commercial impact for advisers and providers.\n\nThe FCA is also moving to a \u2018show me, don\u2019t tell me\u2019 supervisory approach, with the Enforcement Watch report showing 23 enforcement operations opened since 3 June 2025, six relating to potential Consumer Duty breaches.\n\nPensions providers and advisers, particularly those operating workplace schemes or products allowing investment in unit-linked funds, sit at the centre of the value-for-money work.\n\nFirms supporting \u2018gone-away\u2019 customers or those with vulnerabilities face particular attention, since the FCA is concerned these groups risk poor retirement outcomes due to older or less innovative products.\n\n\u2022 Workplace schemes or unit-linked products that do not deliver adequate value for money.\n\u2022 Poor product governance, complex charging structures and lack of transparency for consumers.\n\u2022 Weak oversight of appointed representatives.\n\u2022 Consumers of older or less innovative products facing reduced choice, flexibility and higher costs.\n\n1. Use the \u2018what we expect firms to do\u2019 section as a gap analysis and monitoring tool.\n2. Prepare for potential customer transfers if value for money is not being delivered.\n3. Review product governance, charging structures and transparency, particularly for older or legacy products.\n4. Strengthen oversight of appointed representatives and evidence of good consumer outcomes.\n\nThe Regulatory Initiatives Grid links this report to a wider Pension Reform Steering Committee Group agenda, bringing together the FCA, the Department for Work and Pensions, HM Treasury and The Pensions Regulator.\n\nThat coordination, alongside measures in the Pension Schemes Bill and initiatives such as pensions dashboards, suggests the direction of travel on value for money and consumer support is unlikely to slow.\n\nTest control frameworks against the FCA\u2019s expectations now, rather than waiting for the next sector report or supervisory request.\n\nFocus particularly on evidencing good outcomes with reliable data, since the Consumer Duty\u2019s emphasis on value for money, communication quality and consumer decision-making runs through this report.", "wordCount": 495, "keywords": [ "Consumer Duty", "Regulatory Change & Transformation", "Pensions & Retirement Income", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Consumer Duty", "url": "https://tcc.group/blog/solution/consumer-duty/" }, { "@type": "Thing", "name": "Regulatory Change & Transformation", "url": "https://tcc.group/blog/solution/regulatory-change-transformation/" }, { "@type": "Thing", "name": "Pensions & Retirement Income", "url": "https://tcc.group/blog/sector/pensions-retirement-income/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Pensions Regulatory Priorities" } ], "articleSection": [ "Consumer Duty", "Regulatory Change & Transformation" ], "audience": [ { "@type": "Audience", "audienceType": "Pensions & Retirement Income" }, { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Pensions providers, advisers and their governance, product and compliance teams." } ], "citation": [ { "@type": "CreativeWork", "name": "What the FCA\u2019s Pensions Regulatory Priorities report means for pensions providers", "url": "https://tcc.group/blog/2026/03/12/what-the-fcas-pensions-regulatory-priorities-report-means-for-pensions-providers/", "datePublished": "2026-03-12" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/regulatory-horizon/what-the-fcas-pensions-regulatory-priorities-report-means-for-pensions-providers/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/what-the-fcas-pensions-regulatory-priorities-report-means-for-pensions-providers/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "Which report is this in the FCA's 2026 series?", "acceptedAnswer": { "@type": "Answer", "text": "It is the third report, following Insurance (24 February) and Consumer Investments (4 March)." } }, { "@type": "Question", "name": "How many people does the FCA say are not saving enough for retirement?", "acceptedAnswer": { "@type": "Answer", "text": "Nearly 15 million, according to the FCA's Lucy Castledine speaking at the TISA Inclusive Investing Conference." } }, { "@type": "Question", "name": "What could happen if a scheme does not deliver value for money?", "acceptedAnswer": { "@type": "Answer", "text": "Firms may be required to take action to transfer customers to better solutions." } }, { "@type": "Question", "name": "How many enforcement operations has the FCA opened recently?", "acceptedAnswer": { "@type": "Answer", "text": "The Enforcement Watch report shows 23 enforcement operations opened since 3 June 2025, six relating to potential Consumer Duty breaches." } } ] } ] } ``` ### Insurance Edge: Pure protection FCA study raises expectations - URL: https://tcc.group/insights/analysis-perspectives/insurance-edge-pure-protection-in-focus-fca-market-study-raises-regulatory-expectations-for-2026/ - Published: 2026-03-10 - Modified: 2026-09-02 **Topic:** Pure Protection Expectations TCC Group CEO Joe Norburn outlines in Insurance Edge how firms should prepare for rising regulatory standards ahead of the FCA's pure protection market study. #### What happened? In an article published in Insurance Edge, TCC Group CEO Joe Norburn explores the FCA's pure protection distribution market study. The regulator is thoroughly investigating fair value, broker commission structures, competition, and consumer access to protection products. With the study's final report due in Q3 2026, firms are advised to proactively audit their policies and strengthen their evidence trail. #### Why does it matter? Firms cannot afford to wait until the final report is published. Remuneration models and distribution channels must be reviewed to ensure they do not cause consumer harm or create conflicts of interest, allowing firms to demonstrate clear alignment with Consumer Duty standards. #### Supporting sources - [Insurance Edge: Pure protection FCA study raises expectations](https://tcc.group/blog/2026/03/11/insurance-edge-pure-protection-in-focus-fca-market-study-raises-regulatory-expectations-for-2026/) (2026-03-11) #### Need to review your pure protection compliance? Speak to our compliance specialists to audit your remuneration transparency, strengthen your governance, and prepare for the 2026 regulatory changes. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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expectations", "item": "https://tcc.group/insights/analysis-perspectives/insurance-edge-pure-protection-in-focus-fca-market-study-raises-regulatory-expectations-for-2026/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/analysis-perspectives/insurance-edge-pure-protection-in-focus-fca-market-study-raises-regulatory-expectations-for-2026/#webpage", "url": "https://tcc.group/insights/analysis-perspectives/insurance-edge-pure-protection-in-focus-fca-market-study-raises-regulatory-expectations-for-2026/", "name": "Insurance Edge: Pure protection FCA study raises expectations", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-03-11T00:00:00+01:00", "dateModified": "2026-09-02T03:47:53+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/analysis-perspectives/insurance-edge-pure-protection-in-focus-fca-market-study-raises-regulatory-expectations-for-2026/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", 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The FCA published its first Regulatory Priorities report in February, covering the insurance sector, followed by a report on consumer investments on 4 March. The consumer investments report sets out four strategic priorities: building a stronger investment culture, strengthening trust, securing good consumer outcomes and strengthening financial crime controls. Lucy Castledine, the FCA’s Director of Consumer Investments, reinforced the report’s importance during a keynote speech at the TISA Inclusive Investing Conference, confirming it should act as a guide for firms’ boards and chief executives. Across the four priorities, the FCA sets out 11 specific expectations for firms, with two areas standing out as particularly significant: fair value assessment and product design. #### Why does it matter? The nine Regulatory Priorities reports are intended to become the FCA’s central annual communication to sectors, so firms should treat the report relevant to them as a key regulatory publication rather than routine correspondence. The sections outlining “what we expect firms to do” require close scrutiny. Firms are expected to objectively assess whether current practices meet the FCA’s standards and act where gaps exist. #### Who is affected? Consumer investment firms, and in particular the boards and chief executives who are expected to use the report as a guide for governance and strategic priorities. #### Key risks - Ongoing FCA investigations into potential breaches of fair value requirements. - Product design or distribution that is not clearly aligned to defined target markets. - Vulnerability considerations that are not evidenced in product design and monitoring. - Outcomes monitoring and management information that does not demonstrate intended results. - Ongoing advice services that have not been reviewed against the FCA’s February 2025 findings. #### Actions to take 1. Review fair value assessments to ensure they are comprehensive, well-documented and regularly reviewed. 2. Check that product design and distribution processes remain aligned with defined target markets, including vulnerable customers. 3. Build meaningful outcomes-monitoring management information that shows whether products deliver intended results. 4. Review ongoing advice services against the FCA’s February 2025 findings if this has not already been done. 5. Where gaps exist, develop a structured action plan approved at an appropriate governance level, with clear timelines and accountable owners. #### Wider implications The consumer investments report signals the FCA’s wider shift towards sector-by-sector annual communications. Firms in other sectors should expect similarly detailed priorities reports and treat them as a recurring feature of supervisory engagement. #### Recommendations At TCC Group, we support firms with regulatory gap analysis, Consumer Duty adherence and outcomes-monitoring frameworks, helping firms assess where they stand against the FCA’s expectations and develop practical next steps. #### Supporting sources - [What the FCA’s Regulatory Priorities report means for consumer investment firms](https://tcc.group/blog/2026/03/10/what-the-fcas-regulatory-priorities-report-means-for-consumer-investment-firms/) (2026-03-10) #### Need help meeting the FCA’s priorities? Speak to our regulatory experts about a structured gap analysis against the FCA’s Regulatory Priorities report, covering fair value, product design and outcomes monitoring. [Speak to our experts](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", 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"url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/insights/regulatory-horizon/what-the-fcas-regulatory-priorities-report-means-for-consumer-investment-firms/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Insights", "item": "https://tcc.group/insights/" }, { "@type": "ListItem", "position": 3, "name": "What the FCA\u2019s Regulatory Priorities report means for consumer 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".wp-block-excerpt" ] } }, { "@type": "NewsArticle", "@id": "https://tcc.group/insights/regulatory-horizon/what-the-fcas-regulatory-priorities-report-means-for-consumer-investment-firms/#article", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/what-the-fcas-regulatory-priorities-report-means-for-consumer-investment-firms/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "What the FCA\u2019s Regulatory Priorities report means for consumer investment firms", "datePublished": "2026-03-10T00:00:00+01:00", "dateModified": "2026-09-02T03:49:12+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/regulatory-horizon/what-the-fcas-regulatory-priorities-report-means-for-consumer-investment-firms/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/6d050b1a329a4a94b3ba3723fd5ecbe6/thumbnail-1600-2f4aad4e2ea09f661ec0a51d5ac4835923101e778c0c259c159344bc8df68a3d.jpg", "description": "Understand the FCA\u2019s first Regulatory Priorities report for consumer investments, its four strategic priorities, and the concrete governance, fair value and outcomes-monitoring actions your firm should take before supervisory attention intensifies.", "inLanguage": "en-GB", "articleBody": "The FCA\u2019s first Regulatory Priorities report sets out four strategic priorities for consumer investment firms, with fair value and product design singled out for close scrutiny.\n\nThe FCA published its first Regulatory Priorities report in February, covering the insurance sector, followed by a report on consumer investments on 4 March. The consumer investments report sets out four strategic priorities: building a stronger investment culture, strengthening trust, securing good consumer outcomes and strengthening financial crime controls.\n\nLucy Castledine, the FCA\u2019s Director of Consumer Investments, reinforced the report\u2019s importance during a keynote speech at the TISA Inclusive Investing Conference, confirming it should act as a guide for firms\u2019 boards and chief executives.\n\nAcross the four priorities, the FCA sets out 11 specific expectations for firms, with two areas standing out as particularly significant: fair value assessment and product design.\n\nThe nine Regulatory Priorities reports are intended to become the FCA\u2019s central annual communication to sectors, so firms should treat the report relevant to them as a key regulatory publication rather than routine correspondence.\n\nThe sections outlining \u201cwhat we expect firms to do\u201d require close scrutiny. Firms are expected to objectively assess whether current practices meet the FCA\u2019s standards and act where gaps exist.\n\nConsumer investment firms, and in particular the boards and chief executives who are expected to use the report as a guide for governance and strategic priorities.\n\n\u2022 Ongoing FCA investigations into potential breaches of fair value requirements.\n\u2022 Product design or distribution that is not clearly aligned to defined target markets.\n\u2022 Vulnerability considerations that are not evidenced in product design and monitoring.\n\u2022 Outcomes monitoring and management information that does not demonstrate intended results.\n\u2022 Ongoing advice services that have not been reviewed against the FCA\u2019s February 2025 findings.\n\n1. Review fair value assessments to ensure they are comprehensive, well-documented and regularly reviewed.\n2. Check that product design and distribution processes remain aligned with defined target markets, including vulnerable customers.\n3. Build meaningful outcomes-monitoring management information that shows whether products deliver intended results.\n4. Review ongoing advice services against the FCA\u2019s February 2025 findings if this has not already been done.\n5. Where gaps exist, develop a structured action plan approved at an appropriate governance level, with clear timelines and accountable owners.\n\nThe consumer investments report signals the FCA\u2019s wider shift towards sector-by-sector annual communications. Firms in other sectors should expect similarly detailed priorities reports and treat them as a recurring feature of supervisory engagement.\n\nAt TCC Group, we support firms with regulatory gap analysis, Consumer Duty adherence and outcomes-monitoring frameworks, helping firms assess where they stand against the FCA\u2019s expectations and develop practical next steps.", "wordCount": 438, "keywords": [ "Regulatory Change & Transformation", "Pensions & Retirement Income", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Regulatory Change & Transformation", "url": "https://tcc.group/blog/solution/regulatory-change-transformation/" }, { "@type": "Thing", "name": "Pensions & Retirement Income", "url": "https://tcc.group/blog/sector/pensions-retirement-income/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "FCA Regulatory Priorities" } ], "articleSection": [ "Regulatory Change & Transformation" ], "audience": [ { "@type": "Audience", "audienceType": "Pensions & Retirement Income" }, { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Compliance, product and governance leads at consumer investment firms preparing for the FCA\u2019s new sector-by-sector supervisory communications." } ], "citation": [ { "@type": "CreativeWork", "name": "What the FCA\u2019s Regulatory Priorities report means for consumer investment firms", "url": "https://tcc.group/blog/2026/03/10/what-the-fcas-regulatory-priorities-report-means-for-consumer-investment-firms/", "datePublished": "2026-03-10" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/regulatory-horizon/what-the-fcas-regulatory-priorities-report-means-for-consumer-investment-firms/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/what-the-fcas-regulatory-priorities-report-means-for-consumer-investment-firms/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What are the FCA\u2019s four strategic priorities for consumer investment firms?", "acceptedAnswer": { "@type": "Answer", "text": "Building a stronger investment culture, strengthening trust, securing good consumer outcomes and strengthening financial crime controls." } }, { "@type": "Question", "name": "Why does the Regulatory Priorities report matter for boards?", "acceptedAnswer": { "@type": "Answer", "text": "Lucy Castledine described it as a guide for firms\u2019 boards and chief executives, since it sets out the FCA\u2019s supervisory focus for the year ahead." } }, { "@type": "Question", "name": "What should firms do if they identify gaps against the FCA\u2019s expectations?", "acceptedAnswer": { "@type": "Answer", "text": "They should build a structured action plan, approved at an appropriate governance level, with clear timelines, deliverables and accountable owners." } }, { "@type": "Question", "name": "Is fair value a new area of FCA focus?", "acceptedAnswer": { "@type": "Answer", "text": "No, but the regulator has confirmed it is investigating firms for potential breaches, so existing fair value assessments need fresh review." } } ] } ] } ``` ### Always Finance News: Consolidation isn’t the risk. Getting it wrong is - URL: https://tcc.group/insights/analysis-perspectives/always-finance-news-consolidation-isnt-the-risk-getting-it-wrong-is/ - Published: 2026-03-08 - Modified: 2026-09-02 **Topic:** Consolidation and governance risk TCC Group's CEO Joe Norburn examines the FCA's review of consolidation in the advice and wealth management market, which finds that the risk lies not in consolidation itself but in weak governance around it. #### What happened? As featured in Always Finance News, TCC Group's CEO Joe Norburn discussed the FCA's latest review of consolidation in the UK advice and wealth management market, now seen as a structural shift rather than a temporary trend, driven by succession challenges, regulatory pressures and rising operational costs. The review finds that the key issue is not consolidation itself but whether firms can govern growth effectively. The FCA is placing particular emphasis on financial resilience, stressing that how acquisitions are financed, how debt is structured, and how risks are stress-tested can directly affect customer outcomes. #### Why does it matter? The FCA warns that as firms scale through acquisitions, strong governance, culture and due diligence are essential. Weak oversight, poor management information and unmanaged conflicts of interest can undermine the Consumer Duty if growth outpaces controls. On this analysis, consolidation itself is not the risk; failing to match expansion with effective governance, financial discipline and data-led oversight is what could expose firms to regulatory scrutiny and customer harm. #### Who is affected? The findings are directed at wealth management and financial advice firms that are acquiring other businesses, being acquired, or otherwise scaling through consolidation. #### Key risks - How acquisitions are financed and how debt is structured - Inadequate stress-testing of risks associated with growth - Weak oversight and poor management information as firms scale - Unmanaged conflicts of interest - Growth outpacing governance controls, undermining the Consumer Duty #### Actions to take 1. Review how planned or completed acquisitions are financed and how any related debt is structured. 2. Stress-test the risks associated with growth before and after consolidation. 3. Strengthen management information and governance to keep pace with the scale of the business. 4. Identify and manage conflicts of interest arising from consolidation activity. #### Wider implications The FCA's focus signals that consolidation activity in advice and wealth management will be judged on the strength of governance and financial discipline behind it, not simply on the fact that it is taking place. #### Recommendations Firms considering or undergoing consolidation should match the pace of expansion with effective governance, financial discipline and data-led oversight to protect customer outcomes. #### Supporting sources - [Always Finance News: Consolidation isn’t the risk. Getting it wrong is](https://tcc.group/blog/2026/03/09/always-finance-news-consolidation-isnt-the-risk-getting-it-wrong-is/) (2026-03-09) #### Consolidating? Let’s discuss governance risk Get in touch to discuss how we help firms govern growth through consolidation with confidence. 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The FCA is placing particular emphasis on financial resilience, stressing that how acquisitions are financed, how debt is structured, and how risks are stress-tested can directly affect customer outcomes.\n\nThe FCA warns that as firms scale through acquisitions, strong governance, culture and due diligence are essential. 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regulation signals end of ‘Wild West’ fintech loans system - URL: https://tcc.group/insights/analysis-perspectives/compliance-week-u-k-buy-now-pay-later-regulation-signals-end-of-wild-west-fintech-loans-system/ - Published: 2026-02-26 - Modified: 2026-09-02 **Topic:** BNPL regulatory oversight TCC Group's CEO Joe Norburn discusses in Compliance Week why stronger oversight of buy now, pay later lending was inevitable, and why it should help address risks for less financially resilient customers. #### What happened? From 15 July, buy now, pay later providers fall fully within the UK regulatory perimeter, bringing affordability checks, clearer disclosures and Consumer Duty obligations into focus. In Ruth Prickett's piece for Compliance Week, TCC Group CEO Joe Norburn explains why this shift was always likely, given the rapid growth of frictionless borrowing outside full regulation. #### Why does it matter? Joe Norburn argues that stronger oversight should help address the risks created by frictionless borrowing, particularly for customers with lower financial resilience who may be more exposed to unaffordable borrowing. The change signals that BNPL can no longer be treated as a lightly supervised alternative to mainstream credit, and firms should expect the same scrutiny applied to other regulated lending. #### Supporting sources - [Compliance Week: U.K. ‘buy now pay later’ regulation signals end of ‘Wild West’ fintech loans system](https://tcc.group/blog/2026/02/27/compliance-week-u-k-buy-now-pay-later-regulation-signals-end-of-wild-west-fintech-loans-system/) (2026-02-27) #### Preparing for BNPL regulatory oversight? TCC helps consumer credit and payments firms prepare for stronger BNPL oversight, from affordability checks to Consumer Duty evidence. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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Following a consultation by HM Treasury, the government has confirmed that the FCA will become the single anti-money laundering and counter-terrorist financing (AML/CTF) supervisor for professional services, taking on oversight of law firms, accountancy firms and trust company service providers. This replaces the current fragmented system of professional body and public authority supervisors. Alongside this, the FCA's Annual Work Programme 2025/26 names financial crime as one of its four strategic priorities, with the regulator moving from periodic checks to continuous, intelligence-driven oversight and a new data-led detection capability. #### Why does it matter? Full implementation of the new supervisory arrangements requires primary legislation and a phased transition, but firms cannot afford to wait to ensure their controls are in order. The pressing question for firms is not what the FCA will do, but whether their customer due diligence (CDD) and enhanced due diligence (EDD) frameworks can withstand closer regulatory scrutiny. Some firms may find that their controls have evolved reactively, with layered processes, manual workarounds or inconsistent escalation thresholds that no longer reflect the pace of financial crime risk in a real-time digital environment. #### Who is affected? Firms across professional and financial services, including those newly brought within FCA AML/CTF supervision, and compliance, risk and financial crime teams responsible for CDD and EDD frameworks. #### Key risks - Risk assessments that are procedural rather than genuinely risk-based. - An inability to evidence how and why due diligence decisions were made. - Inconsistent application of enhanced due diligence between similar high-risk cases. - Automated systems influencing risk ratings without a clear audit trail or human oversight. #### Actions to take 1. Revisit risk segmentation so that triggers for escalation to enhanced due diligence are clearly defined and consistently applied. 2. Map decision journeys end-to-end so that each judgment has an evidential trail that can be produced on request. 3. Clarify escalation triggers, strengthen documentation standards and embed quality assurance that tests whether checks were completed and applied effectively. 4. Review management information so it gives a clear view of volumes, risk segmentation, escalations, turnaround times and quality assurance outcomes. #### Wider implications As the FCA moves towards data-led, intelligence-driven supervision, firms will increasingly be expected to demonstrate how customer risk ratings are informed by live data, rather than fixed at onboarding and revisited only on a set timetable. Where technology, such as workflow tools, screening platforms and AI-supported reviews, is used to support CDD and EDD, it must strengthen governance rather than dilute it, with clear audit trails explaining how automated outputs influence decisions. #### Recommendations Firms should treat this as an opportunity to step back and ask whether their risk assessments are genuinely risk-based, whether decisions are evidenced, and whether the framework can scale under regulatory pressure without compromising quality. **TCC and Momenta** can provide specialist interim leaders, including experienced Chief Risk Officers and Chief Compliance Officers, alongside skilled resource and managed services, to help firms run CDD and EDD programmes consistently and in line with regulatory expectations. #### Supporting sources - [Navigating financial crime compliance in a changing landscape](https://tcc.group/blog/2026/02/26/navigating-financial-crime-compliance-in-a-changing-regulatory-landscape/) (2026-02-26) #### Ready to strengthen your financial crime controls? TCC and Momenta help firms scale resources, maintain control and demonstrate effective financial crime governance with confidence. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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"https://tcc.group/insights/regulatory-horizon/navigating-financial-crime-compliance-in-a-changing-regulatory-landscape/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/regulatory-horizon/navigating-financial-crime-compliance-in-a-changing-regulatory-landscape/#webpage", "url": "https://tcc.group/insights/regulatory-horizon/navigating-financial-crime-compliance-in-a-changing-regulatory-landscape/", "name": "Navigating financial crime compliance in a changing landscape", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-02-26T00:00:00+01:00", "dateModified": "2026-09-02T03:47:58+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/regulatory-horizon/navigating-financial-crime-compliance-in-a-changing-regulatory-landscape/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "NewsArticle", "@id": "https://tcc.group/insights/regulatory-horizon/navigating-financial-crime-compliance-in-a-changing-regulatory-landscape/#article", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/navigating-financial-crime-compliance-in-a-changing-regulatory-landscape/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "Navigating financial crime compliance in a changing landscape", "datePublished": "2026-02-26T00:00:00+01:00", "dateModified": "2026-09-02T03:47:58+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/regulatory-horizon/navigating-financial-crime-compliance-in-a-changing-regulatory-landscape/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/07db93da6e374a578b1efc3273d988f3/thumbnail-1600-b0b79dfb0ce7263d600e23887a049c9945e62b385cfbec09427cb991376155f0.jpg", "description": "The FCA is becoming the single AML/CTF supervisor for professional services and moving to continuous, data-led oversight. This looks at what that means for customer due diligence frameworks.", "inLanguage": "en-GB", "articleBody": "The FCA is set to become the single AML/CTF supervisor for professional services, and its 2025/26 work programme signals a move to continuous, data-led supervision of financial crime, meaning firms need to reassess their due diligence frameworks now.\n\nFollowing a consultation by HM Treasury, the government has confirmed that the FCA will become the single anti-money laundering and counter-terrorist financing (AML/CTF) supervisor for professional services, taking on oversight of law firms, accountancy firms and trust company service providers. This replaces the current fragmented system of professional body and public authority supervisors.\n\nAlongside this, the FCA's Annual Work Programme 2025/26 names financial crime as one of its four strategic priorities, with the regulator moving from periodic checks to continuous, intelligence-driven oversight and a new data-led detection capability.\n\nFull implementation of the new supervisory arrangements requires primary legislation and a phased transition, but firms cannot afford to wait to ensure their controls are in order. The pressing question for firms is not what the FCA will do, but whether their customer due diligence (CDD) and enhanced due diligence (EDD) frameworks can withstand closer regulatory scrutiny.\n\nSome firms may find that their controls have evolved reactively, with layered processes, manual workarounds or inconsistent escalation thresholds that no longer reflect the pace of financial crime risk in a real-time digital environment.\n\nFirms across professional and financial services, including those newly brought within FCA AML/CTF supervision, and compliance, risk and financial crime teams responsible for CDD and EDD frameworks.\n\n\u2022 Risk assessments that are procedural rather than genuinely risk-based.\n\u2022 An inability to evidence how and why due diligence decisions were made.\n\u2022 Inconsistent application of enhanced due diligence between similar high-risk cases.\n\u2022 Automated systems influencing risk ratings without a clear audit trail or human oversight.\n\n1. Revisit risk segmentation so that triggers for escalation to enhanced due diligence are clearly defined and consistently applied.\n2. Map decision journeys end-to-end so that each judgment has an evidential trail that can be produced on request.\n3. Clarify escalation triggers, strengthen documentation standards and embed quality assurance that tests whether checks were completed and applied effectively.\n4. Review management information so it gives a clear view of volumes, risk segmentation, escalations, turnaround times and quality assurance outcomes.\n\nAs the FCA moves towards data-led, intelligence-driven supervision, firms will increasingly be expected to demonstrate how customer risk ratings are informed by live data, rather than fixed at onboarding and revisited only on a set timetable.\n\nWhere technology, such as workflow tools, screening platforms and AI-supported reviews, is used to support CDD and EDD, it must strengthen governance rather than dilute it, with clear audit trails explaining how automated outputs influence decisions.\n\nFirms should treat this as an opportunity to step back and ask whether their risk assessments are genuinely risk-based, whether decisions are evidenced, and whether the framework can scale under regulatory pressure without compromising quality.\n\nTCC and Momenta can provide specialist interim leaders, including experienced Chief Risk Officers and Chief Compliance Officers, alongside skilled resource and managed services, to help firms run CDD and EDD programmes consistently and in line with regulatory expectations.", "wordCount": 516, "keywords": [ "Financial Crime Compliance", "Banking", "General Insurance & Protection", "Lending & Consumer Credit", "Motor Finance", "Payments & FinTech", "Pensions & Retirement Income", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Financial Crime Compliance", "url": "https://tcc.group/blog/solution/financial-crime-compliance/" }, { "@type": "Thing", "name": "Banking", "url": "https://tcc.group/blog/sector/banking/" }, { "@type": "Thing", "name": "General Insurance & Protection", "url": "https://tcc.group/blog/sector/general-insurance-protection/" }, { "@type": "Thing", "name": "Lending & Consumer Credit", "url": "https://tcc.group/blog/sector/lending-consumer-credit/" }, { "@type": "Thing", "name": "Motor Finance", "url": "https://tcc.group/blog/sector/motor-finance/" }, { "@type": "Thing", "name": "Payments & FinTech", "url": "https://tcc.group/blog/sector/payments-fintech/" }, { "@type": "Thing", "name": "Pensions & Retirement Income", "url": "https://tcc.group/blog/sector/pensions-retirement-income/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Financial Crime Compliance Reform" } ], "articleSection": [ "Financial Crime Compliance" ], "audience": [ { "@type": "Audience", "audienceType": "Banking" }, { "@type": "Audience", "audienceType": "General Insurance & Protection" }, { "@type": "Audience", "audienceType": "Lending & Consumer Credit" }, { "@type": "Audience", "audienceType": "Motor Finance" }, { "@type": "Audience", "audienceType": "Payments & FinTech" }, { "@type": "Audience", "audienceType": "Pensions & Retirement Income" }, { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Compliance leaders responsible for financial crime, customer due diligence and enhanced due diligence frameworks." } ], "citation": [ { "@type": "CreativeWork", "name": "Navigating financial crime compliance in a changing landscape", "url": "https://tcc.group/blog/2026/02/26/navigating-financial-crime-compliance-in-a-changing-regulatory-landscape/", "datePublished": "2026-02-26" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/regulatory-horizon/navigating-financial-crime-compliance-in-a-changing-regulatory-landscape/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/navigating-financial-crime-compliance-in-a-changing-regulatory-landscape/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What change is happening to AML/CTF supervision in the UK?", "acceptedAnswer": { "@type": "Answer", "text": "The FCA will become the single AML/CTF supervisor for professional services, taking on oversight of law firms, accountancy firms and trust company service providers, replacing the current fragmented system." } }, { "@type": "Question", "name": "When will the new supervisory arrangements take effect?", "acceptedAnswer": { "@type": "Answer", "text": "Full implementation requires primary legislation and a phased transition, though firms are advised not to wait before reviewing their controls." } }, { "@type": "Question", "name": "What is the difference between CDD and EDD?", "acceptedAnswer": { "@type": "Answer", "text": "Customer due diligence (CDD) is the standard process for establishing and monitoring customer risk, while enhanced due diligence (EDD) applies additional, more detailed checks where a customer presents a higher risk." } }, { "@type": "Question", "name": "How can firms demonstrate their financial crime controls work in practice?", "acceptedAnswer": { "@type": "Answer", "text": "Firms should maintain management information covering volumes, risk segmentation, escalations, turnaround times and quality assurance outcomes, aligned with risk appetite and board oversight." } } ] } ] } ``` ### Why traditional resourcing models are quietly undermining firms - URL: https://tcc.group/insights/regulatory-horizon/why-traditional-resourcing-models-are-quietly-undermining-financial-services-firms/ - Published: 2026-02-23 - Modified: 2026-09-02 **Topic:** Flexible Resourcing Models Financial services firms built around static, peak-capacity staffing struggle to flex with today's cycles of regulatory scrutiny and remediation. A deliberate core-and-flexible resourcing model can protect compliance and control without carrying excess permanent cost. #### What happened? Many financial services firms still structure their workforce around a peak-capacity staffing model: a permanent team large enough to absorb the busiest periods of regulatory change or remediation. That approach was designed for a level of certainty that no longer matches an environment defined by cycles of scrutiny, episodic remediation and shifting supervisory expectations. The consequence is a cost base that stays elevated long after programme intensity subsides, with specialist professionals recruited for peak pressure becoming underutilised between initiatives, while leadership teams are stretched thin during critical engagement or carrying excess capacity during quieter periods. #### Why does it matter? Resilience is now a regulatory expectation as much as a commercial one. Supervisors increasingly expect firms to demonstrate control, governance and delivery capability under pressure, while boards want transformation delivered at pace and shareholders expect disciplined cost management. Permanent recruitment cycles are rarely designed for speed or for highly specialised, short- to medium-term requirements, creating delay at precisely the moment decisiveness is needed. #### Who is affected? The issue applies across wealth management, pensions, payments, banking, lending, insurance and motor finance firms that rely on permanent headcount to absorb regulatory change, remediation or transformation demand. #### Key risks - A cost base that stays elevated once programme intensity subsides. - Specialist professionals underutilised between initiatives after being recruited for peak pressure. - Leadership teams stretched thin during critical regulatory engagement. - Delay at the point of greatest need because permanent recruitment cannot move quickly. #### Actions to take 1. Define a stable permanent core that sustains business-as-usual operations and continuity of control. 2. Identify which activities are genuinely business-as-usual and which are time-bound or specialist in nature. 3. Build routes to scale leadership and subject-matter expertise quickly without expanding fixed headcount. 4. Treat interim capability as a structured part of the operating model rather than reactive contingency. #### Wider implications When agile capability is embedded deliberately, it strengthens rather than dilutes regulatory credibility, enabling faster mobilisation during supervisory scrutiny and freeing internal teams to focus on sustaining control while specialist leaders concentrate on delivery. #### Recommendations Firms that reassess their resourcing model now, protecting a lean permanent core while retaining access to proven interim leadership and specialist capability, will be better placed for the next wave of regulatory change, transformation or heightened scrutiny. #### Supporting sources - [Why traditional resourcing models are quietly undermining financial services firms](https://tcc.group/blog/2026/02/24/why-traditional-resourcing-models-are-quietly-undermining-financial-services-firms/) (2026-02-24) #### Is your resourcing model built to flex? Talk to us about scaling leadership and specialist capability alongside your permanent core. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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"@type": "NewsArticle", "@id": "https://tcc.group/insights/regulatory-horizon/why-traditional-resourcing-models-are-quietly-undermining-financial-services-firms/#article", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/why-traditional-resourcing-models-are-quietly-undermining-financial-services-firms/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "Why traditional resourcing models are quietly undermining firms", "datePublished": "2026-02-24T00:00:00+01:00", "dateModified": "2026-09-02T03:49:14+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/regulatory-horizon/why-traditional-resourcing-models-are-quietly-undermining-financial-services-firms/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/88c7ff8c7b6c43d6868684ad52a57526/thumbnail-1600-718d6c8000d4b44a8b5a890921b4ce3a260a0bf67f1b84ce33a095438f7823f2.jpg", "description": "Understand why static, peak-capacity staffing models are straining financial services firms under today's regulatory pressure, and how a leaner permanent core paired with flexible specialist capacity keeps delivery and compliance on track.", "inLanguage": "en-GB", "articleBody": "Financial services firms built around static, peak-capacity staffing struggle to flex with today's cycles of regulatory scrutiny and remediation. A deliberate core-and-flexible resourcing model can protect compliance and control without carrying excess permanent cost.\n\nMany financial services firms still structure their workforce around a peak-capacity staffing model: a permanent team large enough to absorb the busiest periods of regulatory change or remediation. That approach was designed for a level of certainty that no longer matches an environment defined by cycles of scrutiny, episodic remediation and shifting supervisory expectations.\n\nThe consequence is a cost base that stays elevated long after programme intensity subsides, with specialist professionals recruited for peak pressure becoming underutilised between initiatives, while leadership teams are stretched thin during critical engagement or carrying excess capacity during quieter periods.\n\nResilience is now a regulatory expectation as much as a commercial one. Supervisors increasingly expect firms to demonstrate control, governance and delivery capability under pressure, while boards want transformation delivered at pace and shareholders expect disciplined cost management.\n\nPermanent recruitment cycles are rarely designed for speed or for highly specialised, short- to medium-term requirements, creating delay at precisely the moment decisiveness is needed.\n\nThe issue applies across wealth management, pensions, payments, banking, lending, insurance and motor finance firms that rely on permanent headcount to absorb regulatory change, remediation or transformation demand.\n\n\u2022 A cost base that stays elevated once programme intensity subsides.\n\u2022 Specialist professionals underutilised between initiatives after being recruited for peak pressure.\n\u2022 Leadership teams stretched thin during critical regulatory engagement.\n\u2022 Delay at the point of greatest need because permanent recruitment cannot move quickly.\n\n1. 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Treat interim capability as a structured part of the operating model rather than reactive contingency.\n\nWhen agile capability is embedded deliberately, it strengthens rather than dilutes regulatory credibility, enabling faster mobilisation during supervisory scrutiny and freeing internal teams to focus on sustaining control while specialist leaders concentrate on delivery.\n\nFirms that reassess their resourcing model now, protecting a lean permanent core while retaining access to proven interim leadership and specialist capability, will be better placed for the next wave of regulatory change, transformation or heightened scrutiny.", "wordCount": 396, "keywords": [ "Compliance AI & RegTech", "Regulatory Change & Transformation", "Banking", "General Insurance & Protection", "Lending & Consumer Credit", "Motor Finance", "Payments & FinTech", "Pensions & Retirement Income", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Regulatory Change & Transformation", "url": "https://tcc.group/blog/solution/regulatory-change-transformation/" }, { "@type": "Thing", "name": "Banking", "url": "https://tcc.group/blog/sector/banking/" }, { "@type": "Thing", "name": "General Insurance & Protection", "url": "https://tcc.group/blog/sector/general-insurance-protection/" }, { "@type": "Thing", "name": "Lending & Consumer Credit", "url": "https://tcc.group/blog/sector/lending-consumer-credit/" }, { "@type": "Thing", "name": "Motor Finance", "url": "https://tcc.group/blog/sector/motor-finance/" }, { "@type": "Thing", "name": "Payments & FinTech", "url": "https://tcc.group/blog/sector/payments-fintech/" }, { "@type": "Thing", "name": "Pensions & Retirement Income", "url": "https://tcc.group/blog/sector/pensions-retirement-income/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Flexible Resourcing Models" } ], "articleSection": [ "Compliance AI & RegTech", "Regulatory Change & Transformation" ], "audience": [ { "@type": "Audience", "audienceType": "Banking" }, { "@type": "Audience", "audienceType": "General Insurance & Protection" }, { "@type": "Audience", "audienceType": "Lending & Consumer Credit" }, { "@type": "Audience", "audienceType": "Motor Finance" }, { "@type": "Audience", "audienceType": "Payments & FinTech" }, { "@type": "Audience", "audienceType": "Pensions & Retirement Income" }, { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Leaders across wealth management, pensions, payments, banking, lending, insurance and motor finance firms reviewing their resourcing strategy." } ], "citation": [ { "@type": "CreativeWork", "name": "Why traditional resourcing models are quietly undermining financial services firms", "url": "https://tcc.group/blog/2026/02/24/why-traditional-resourcing-models-are-quietly-undermining-financial-services-firms/", "datePublished": "2026-02-24" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/regulatory-horizon/why-traditional-resourcing-models-are-quietly-undermining-financial-services-firms/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/why-traditional-resourcing-models-are-quietly-undermining-financial-services-firms/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What is a peak-capacity staffing model?", "acceptedAnswer": { "@type": "Answer", "text": "It is a workforce structured around a permanent team large enough to absorb the busiest periods of regulatory change or remediation." } }, { "@type": "Question", "name": "Why does this model create cost problems?", "acceptedAnswer": { "@type": "Answer", "text": "Because the elevated headcount remains in place even after programme intensity subsides, leaving specialist staff underutilised between initiatives." } }, { "@type": "Question", "name": "What is a core-and-flexible resourcing model?", "acceptedAnswer": { "@type": "Answer", "text": "It combines a lean, permanent core of experienced professionals with the ability to scale in specialist or interim capability quickly when regulatory intensity rises." } }, { "@type": "Question", "name": "How does flexible resourcing support regulatory credibility?", "acceptedAnswer": { "@type": "Answer", "text": "It enables faster mobilisation during supervisory scrutiny and stronger governance during complex change, rather than diluting control." } } ] } ] } ``` ### Forum Events and Media Group 2026: The Year the FCA Demands Proof - URL: https://tcc.group/insights/analysis-perspectives/forum-events-and-media-group-2026-the-year-the-fca-demands-proof-not-promises-2/ - Published: 2026-02-22 - Modified: 2026-09-02 **Topic:** Outcomes-Based Supervision TCC Group's Joe Norburn outlines how the FCA is shifting to targeted, data-led supervision in 2026, forcing firms to provide demonstrable evidence of positive consumer outcomes. #### What happened? In an article published by the Forum Events and Media Group, TCC Group (comprising TCC, Momenta, and Recordsure) leader Joe Norburn reflects on the FCA's core supervisory strategy for 2026. The regulator is executing a decisive transition away from prescriptive rulebook checklists and towards rigorous, outcomes-based supervision. While the FCA adopts a pro-growth stance and reduces reporting burdens for compliant businesses, it is simultaneously increasing targeted, data-led audits for firms that fail to demonstrate active operational control. #### Why does it matter? Under this supervisory model, verbal commitments and policy statements are no longer sufficient. Under the Consumer Duty, firms must provide robust, auditable data to prove they deliver fair value, clear communications, and positive customer outcomes. As firms expand their reliance on third-party integrations and artificial intelligence, they must maintain absolute transparency, accountability, and strong data governance to preserve market trust. #### Who is affected? This media feature is highly relevant for wealth managers, compliance heads, and senior executives navigating UK financial services regulation. #### Supporting sources - [Forum Events and Media Group 2026 the year FCA demands proof](https://tcc.group/blog/2026/02/23/forum-events-and-media-group-2026-the-year-the-fca-demands-proof-not-promises-2/) (2026-02-23) #### Does your compliance framework provide proof of outcomes? Deploy robust monitoring systems, secure reliable audit trails, and prepare your business for data-led supervision with our regulatory experts. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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The Financial Conduct Authority (FCA) and the Solicitors Regulation Authority (SRA) have issued a joint message addressing multiple representation in motor finance commission claims. The regulators highlighted instances where up to four representatives were instructed on a single claim. To support lenders, the FCA has released a Dear CEO letter detailing required administrative and communication steps to resolve these duplicate claims and prevent consumer confusion. #### Why does it matter? Multiple representation delays claims processing, increases costs, and can result in unexpected customer termination fees. As firms prepare for the lifting of the motor finance complaint pause on 31 May 2026 and the finalisation of the Consumer Redress Scheme, managing these duplicates is critical. Lenders are expected to perform robust due diligence to identify multiple representations and constructively engage with all parties to determine a single, authorized representative. #### Supporting sources - [FCA guidance on multiple representation in motor finance complaints](https://tcc.group/blog/2026/02/19/fca-guidance-on-multiple-representation-in-motor-finance-complaints/) (2026-02-19) #### Are your complaint systems ready to spot duplicates? Speak to our complaints and managed services experts to integrate robust due diligence processes and scale your claims operations safely. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/insights/regulatory-horizon/fca-guidance-on-multiple-representation-in-motor-finance-complaints/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Insights", "item": "https://tcc.group/insights/" }, { "@type": "ListItem", "position": 3, "name": "FCA guidance on multiple representation in motor finance complaints", "item": "https://tcc.group/insights/regulatory-horizon/fca-guidance-on-multiple-representation-in-motor-finance-complaints/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/regulatory-horizon/fca-guidance-on-multiple-representation-in-motor-finance-complaints/#webpage", "url": "https://tcc.group/insights/regulatory-horizon/fca-guidance-on-multiple-representation-in-motor-finance-complaints/", "name": "FCA guidance on multiple representation in motor finance complaints", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-02-19T00:00:00+01:00", "dateModified": "2026-09-02T03:47:42+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/regulatory-horizon/fca-guidance-on-multiple-representation-in-motor-finance-complaints/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "NewsArticle", "@id": "https://tcc.group/insights/regulatory-horizon/fca-guidance-on-multiple-representation-in-motor-finance-complaints/#article", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/fca-guidance-on-multiple-representation-in-motor-finance-complaints/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "FCA guidance on multiple representation in motor finance complaints", "datePublished": "2026-02-19T00:00:00+01:00", "dateModified": "2026-09-02T03:47:42+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/regulatory-horizon/fca-guidance-on-multiple-representation-in-motor-finance-complaints/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": null, "description": "The FCA and SRA have issued joint guidance on multiple representation in motor finance claims. Discover the critical steps lenders must take to resolve duplicate complaints and avoid delays.", "inLanguage": "en-GB", "articleBody": "The FCA and SRA have issued joint instructions on managing multiple representatives representing a single motor finance complainant, requiring lenders to execute strict due diligence.\n\nThe Financial Conduct Authority (FCA) and the Solicitors Regulation Authority (SRA) have issued a joint message addressing multiple representation in motor finance commission claims. The regulators highlighted instances where up to four representatives were instructed on a single claim.\n\nTo support lenders, the FCA has released a Dear CEO letter detailing required administrative and communication steps to resolve these duplicate claims and prevent consumer confusion.\n\nMultiple representation delays claims processing, increases costs, and can result in unexpected customer termination fees. 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As featured in Always Finance News, TCC Group's analysis sets out how 2026 will see the Financial Conduct Authority place greater emphasis on evidence over intent, moving to more targeted, data-led supervision while maintaining a pro-growth stance. Firms that can clearly demonstrate strong governance, fair customer outcomes and effective risk controls may benefit from lighter reporting, but scrutiny overall will be sharper and more outcome-focused, particularly under Consumer Duty requirements. #### Why does it matter? Alongside Consumer Duty, regulators are prioritising responsible AI use, operational resilience, motor finance preparedness, and integrated cyber and data protection. Firms that invest in transparent systems, reliable data and customer-centred practices stand to reduce regulatory risk and build competitive trust. Success in 2026, on this analysis, will depend on firms proving their capability rather than promising compliance. #### Who is affected? The shift affects firms across banking, wealth management and financial advice, general insurance and protection, and lending and consumer credit, wherever Consumer Duty, AI use or operational resilience obligations apply. #### Key risks - Sharper, more outcome-focused scrutiny under Consumer Duty - Increasing regulatory focus on responsible AI use - Operational resilience expectations - Motor finance preparedness - Integrated cyber and data protection requirements #### Actions to take 1. Review governance and management information so that fair customer outcomes can be evidenced, not just asserted. 2. Strengthen data quality and traceability to support more targeted, data-led supervision. 3. Check preparedness across responsible AI use, operational resilience, motor finance and cyber and data protection. #### Recommendations Firms that can evidence strong governance, fair outcomes and effective risk controls now will be better positioned as FCA supervision becomes more targeted and data-led. #### Supporting sources - [Always Finance News: 2026 the year the FCA demands proof, not promises](https://tcc.group/blog/2026/02/19/always-finance-news-2026-the-year-the-fca-demands-proof-not-promises/) (2026-02-19) #### Ready to evidence FCA compliance in 2026? Get in touch to discuss how we help firms evidence strong governance and fair customer outcomes ahead of sharper FCA scrutiny. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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"https://tcc.group/insights/analysis-perspectives/always-finance-news-2026-the-year-the-fca-demands-proof-not-promises/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/analysis-perspectives/always-finance-news-2026-the-year-the-fca-demands-proof-not-promises/#webpage", "url": "https://tcc.group/insights/analysis-perspectives/always-finance-news-2026-the-year-the-fca-demands-proof-not-promises/", "name": "Always Finance News: 2026 the year the FCA demands proof, not promises", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-02-19T00:00:00+01:00", "dateModified": "2026-09-02T03:47:31+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/analysis-perspectives/always-finance-news-2026-the-year-the-fca-demands-proof-not-promises/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "AnalysisNewsArticle", "@id": 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principles to evidence, rewarding firms that can prove strong governance and fair outcomes while sharpening scrutiny of Consumer Duty compliance.", "inLanguage": "en-GB", "articleBody": "TCC Group's analysis sets out why 2026 will see the FCA shift towards more targeted, data-led supervision, rewarding firms that can evidence strong governance and fair customer outcomes.\n\nAs featured in Always Finance News, TCC Group's analysis sets out how 2026 will see the Financial Conduct Authority place greater emphasis on evidence over intent, moving to more targeted, data-led supervision while maintaining a pro-growth stance.\n\nFirms that can clearly demonstrate strong governance, fair customer outcomes and effective risk controls may benefit from lighter reporting, but scrutiny overall will be sharper and more outcome-focused, particularly under Consumer Duty requirements.\n\nAlongside Consumer Duty, regulators are prioritising responsible AI use, operational resilience, motor finance preparedness, and integrated cyber and data protection. Firms that invest in transparent systems, reliable data and customer-centred practices stand to reduce regulatory risk and build competitive trust.\n\nSuccess in 2026, on this analysis, will depend on firms proving their capability rather than promising compliance.\n\nThe shift affects firms across banking, wealth management and financial advice, general insurance and protection, and lending and consumer credit, wherever Consumer Duty, AI use or operational resilience obligations apply.\n\n\u2022 Sharper, more outcome-focused scrutiny under Consumer Duty\n\u2022 Increasing regulatory focus on responsible AI use\n\u2022 Operational resilience expectations\n\u2022 Motor finance preparedness\n\u2022 Integrated cyber and data protection requirements\n\n1. Review governance and management information so that fair customer outcomes can be evidenced, not just asserted.\n2. Strengthen data quality and traceability to support more targeted, data-led supervision.\n3. 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TCC Group was recently featured in European Business Magazine, discussing the structural reality of consolidation in the UK wealth management and financial advice sector. Driven by succession pressures, regulatory costs, and scale requirements, acquisitions are surging. However, an FCA review highlights that the primary concern is not the mergers themselves, but whether firms maintain appropriate governance during growth. #### Why does it matter? Firms are scaling rapidly, but poor execution of integrations can compromise client outcomes. The FCA expects boards to evidence robust financial resilience, disciplined integration, and strong cultural governance. Boards must actively control conflicts of interest and maintain service standards as they expand, using continuous, data-driven monitoring of customer outcomes. #### Supporting sources - [European Business Magazine UK wealth management merger risks](https://tcc.group/blog/2026/02/18/european-business-magazine-uk-wealth-management-merger-risks/) (2026-02-18) #### Navigating wealth sector acquisitions? Contact our acquisition and regulatory due diligence experts to ensure your post-merger integration meets the highest regulatory standards. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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risks", "item": "https://tcc.group/insights/analysis-perspectives/european-business-magazine-the-uk-wealth-management-merger-wave-isnt-the-risk-bad-execution-is-2/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/analysis-perspectives/european-business-magazine-the-uk-wealth-management-merger-wave-isnt-the-risk-bad-execution-is-2/#webpage", "url": "https://tcc.group/insights/analysis-perspectives/european-business-magazine-the-uk-wealth-management-merger-wave-isnt-the-risk-bad-execution-is-2/", "name": "European Business Magazine UK wealth management merger risks", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-02-18T00:00:00+01:00", "dateModified": "2026-09-02T03:47:40+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/analysis-perspectives/european-business-magazine-the-uk-wealth-management-merger-wave-isnt-the-risk-bad-execution-is-2/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "AnalysisNewsArticle", "@id": "https://tcc.group/insights/analysis-perspectives/european-business-magazine-the-uk-wealth-management-merger-wave-isnt-the-risk-bad-execution-is-2/#article", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/european-business-magazine-the-uk-wealth-management-merger-wave-isnt-the-risk-bad-execution-is-2/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "European Business Magazine UK wealth management merger risks", "datePublished": "2026-02-18T00:00:00+01:00", "dateModified": "2026-09-02T03:47:40+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/analysis-perspectives/european-business-magazine-the-uk-wealth-management-merger-wave-isnt-the-risk-bad-execution-is-2/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": 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Integration is the most complex and underestimated phase of any acquisition. Value is created or lost at the point governance frameworks come under pressure, cultural alignment is tested, technology and controls must scale, and the client and adviser experience can be strengthened or destabilised. The FCA’s recent multi-firm review of consolidation in the financial advice and wealth management sector reinforces this, placing renewed emphasis on post-acquisition governance, control environments and the ability to evidence effective oversight across growing groups. #### Why does it matter? Too often, integration is treated as beginning only after contracts are signed. Without early planning during due diligence, integration becomes reactive: timelines slip, controls weaken and teams are stretched at the moment risk is highest. Underestimating cultural differences between the acquiring and acquired firm can lead to resistance, disengagement and slower progress towards a unified operating model. #### Who is affected? Executive teams and boards at acquiring firms, advisers and staff at newly acquired businesses, and their clients. #### Key risks - Integration treated as starting only after contracts are signed, making it reactive. - Cultural misalignment between acquirer and acquired firm causing resistance and disengagement. - Governance and committees failing to evolve with scale, weakening challenge and decision-making. - Disparate local compliance arrangements making it hard to maintain consistent standards or a clear view of risk. - Insufficient investment in people and capacity to support rapid adviser growth. #### Actions to take 1. Begin integration planning during regulatory due diligence, defining how systems, processes and cultures will be absorbed. 2. Assess cultural alignment early and address differences in values or operating models before they surface post-acquisition. 3. Evolve board and committee skills and experience as the group scales. 4. Move towards centralised compliance and control frameworks supported by shared technology. 5. Invest in the people, time and infrastructure needed to support integration at scale. #### Wider implications The FCA expects consolidators to demonstrate they understand what they acquire, how they integrate it, and how they oversee the process on an ongoing basis. Integration excellence is becoming a core driver of regulatory confidence, organisational performance and sustainable growth, not simply an operational consideration. #### Recommendations At TCC, we help consolidators build integration models that stand up to regulatory scrutiny, covering cultural assessment, regulatory due diligence, governance frameworks, integration planning and AI-enabled compliance oversight, alongside agile interim resourcing to strengthen operational resilience. #### Supporting sources - [Why most consolidation strategies succeed or fail at integration](https://tcc.group/blog/2026/02/18/why-most-consolidation-strategies-succeed-or-fail-at-integration/) (2026-02-18) #### Planning your next integration? Contact us to explore how cultural assessment, governance frameworks and agile interim resourcing can strengthen your next integration. 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consolidation strategies succeed, and what early planning, cultural alignment, governance evolution and investment in people and capacity require of consolidators.", "inLanguage": "en-GB", "articleBody": "TCC argues that integration, not the acquisition itself, is where consolidation strategies in wealth management and advice are truly tested and value is won or lost.\n\nIntegration is the most complex and underestimated phase of any acquisition. Value is created or lost at the point governance frameworks come under pressure, cultural alignment is tested, technology and controls must scale, and the client and adviser experience can be strengthened or destabilised.\n\nThe FCA\u2019s recent multi-firm review of consolidation in the financial advice and wealth management sector reinforces this, placing renewed emphasis on post-acquisition governance, control environments and the ability to evidence effective oversight across growing groups.\n\nToo often, integration is treated as beginning only after contracts are signed. Without early planning during due diligence, integration becomes reactive: timelines slip, controls weaken and teams are stretched at the moment risk is highest.\n\nUnderestimating cultural differences between the acquiring and acquired firm can lead to resistance, disengagement and slower progress towards a unified operating model.\n\nExecutive teams and boards at acquiring firms, advisers and staff at newly acquired businesses, and their clients.\n\n\u2022 Integration treated as starting only after contracts are signed, making it reactive.\n\u2022 Cultural misalignment between acquirer and acquired firm causing resistance and disengagement.\n\u2022 Governance and committees failing to evolve with scale, weakening challenge and decision-making.\n\u2022 Disparate local compliance arrangements making it hard to maintain consistent standards or a clear view of risk.\n\u2022 Insufficient investment in people and capacity to support rapid adviser growth.\n\n1. Begin integration planning during regulatory due diligence, defining how systems, processes and cultures will be absorbed.\n2. Assess cultural alignment early and address differences in values or operating models before they surface post-acquisition.\n3. Evolve board and committee skills and experience as the group scales.\n4. Move towards centralised compliance and control frameworks supported by shared technology.\n5. Invest in the people, time and infrastructure needed to support integration at scale.\n\nThe FCA expects consolidators to demonstrate they understand what they acquire, how they integrate it, and how they oversee the process on an ongoing basis. Integration excellence is becoming a core driver of regulatory confidence, organisational performance and sustainable growth, not simply an operational consideration.\n\nAt TCC, we help consolidators build integration models that stand up to regulatory scrutiny, covering cultural assessment, regulatory due diligence, governance frameworks, integration planning and AI-enabled compliance oversight, alongside agile interim resourcing to strengthen operational resilience.", "wordCount": 400, "keywords": [ "Compliance AI & RegTech", "Consolidation, Acquisition & Regulatory Due Diligence", "Regulatory Change & Transformation", "Pensions & Retirement Income", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Consolidation, Acquisition & Regulatory Due Diligence", "url": "https://tcc.group/blog/solution/consolidation-acquisition-regulatory-due-diligence/" }, { "@type": "Thing", "name": "Regulatory Change & Transformation", "url": "https://tcc.group/blog/solution/regulatory-change-transformation/" }, { "@type": "Thing", "name": "Pensions & Retirement Income", "url": "https://tcc.group/blog/sector/pensions-retirement-income/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Consolidation Integration Strategy" } ], "articleSection": [ "Compliance AI & RegTech", "Consolidation, Acquisition & Regulatory Due Diligence", "Regulatory Change & Transformation" ], "audience": [ { "@type": "Audience", "audienceType": "Pensions & Retirement Income" }, { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Executive teams and boards at wealth management and advice consolidators managing post-acquisition integration." } ], "citation": [ { "@type": "CreativeWork", "name": "Why most consolidation strategies succeed or fail at integration", "url": "https://tcc.group/blog/2026/02/18/why-most-consolidation-strategies-succeed-or-fail-at-integration/", "datePublished": "2026-02-18" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/analysis-perspectives/why-most-consolidation-strategies-succeed-or-fail-at-integration/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/why-most-consolidation-strategies-succeed-or-fail-at-integration/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "When should integration planning start?", "acceptedAnswer": { "@type": "Answer", "text": "During the regulatory due diligence stage, well before contracts are signed, so systems, processes and cultures can be absorbed in a planned rather than reactive way." } }, { "@type": "Question", "name": "Why does cultural alignment matter in consolidation?", "acceptedAnswer": { "@type": "Answer", "text": "Because underestimating differences in values, behaviours or operating models can lead to resistance, disengagement and slower progress towards a unified operating model." } }, { "@type": "Question", "name": "How should governance change as a group scales?", "acceptedAnswer": { "@type": "Answer", "text": "Boards and committees need a broader mix of skills and experience, particularly as firms expand into areas such as investment management or client money." } }, { "@type": "Question", "name": "What role does technology play in integration?", "acceptedAnswer": { "@type": "Answer", "text": "Centrally funded and implemented technology platforms help firms standardise processes, capture meaningful management information and evidence oversight consistently across the group." } } ] } ] } ``` ### Contact Centre Briefing: Pure protection in focus - URL: https://tcc.group/insights/analysis-perspectives/contact-centre-briefing-pure-protection-in-focus/ - Published: 2026-02-17 - Modified: 2026-09-02 **Topic:** Pure protection market study TCC Group's CEO Joe Norburn discussed the FCA's Market Study into pure protection in Contact Centre Briefing, highlighting rising regulatory expectations on fair value, commission transparency and customer access ahead of the final report due in Q3 2026. #### What happened? TCC Group featured in Contact Centre Briefing, where Group CEO Joe Norburn discussed the implications of the FCA's Market Study into pure protection, launched in 2024. Early findings from the review point to improved claims outcomes alongside ongoing concerns, including protection gaps and limited accessibility for vulnerable customers. The FCA is now examining whether remuneration and distribution models influence product suitability, affordability and long-term outcomes, and is encouraging firms to strengthen governance, data and customer communications ahead of its final report, due in the third quarter of 2026. #### Why does it matter? The study signals increasing regulatory focus on fair value, the transparency of commission structures and how customers access protection products. It sits alongside the FCA's broader outcomes-based approach to consumer protection across financial services. Firms that can evidence transparent pricing, appropriate incentives and strong customer outcomes will be best placed as expectations continue to rise in the run-up to the final report. #### Supporting sources - [Contact Centre Briefing: Pure protection in focus](https://tcc.group/blog/2026/02/18/contact-centre-briefing-pure-protection-in-focus/) (2026-02-18) #### Ready for the FCA's pure protection findings? TCC's regulatory experts can help you assess governance, data and communications ahead of the FCA's final market study report. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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Following a prolonged period of research and government consultation, the Financial Conduct Authority (FCA) has confirmed that the Buy Now Pay Later (BNPL) sector will officially fall under its regulatory supervision on 15 July 2026. This landmark decision brings stronger protections for millions of UK consumer credit borrowers. Firms operating in the BNPL space are urged to register for the Temporary Permissions Regime between 1 May and 1 July 2026, after which they will have a six-month window to apply for full registration. Merchant-own credit models remain exempt under the government's 2024 exclusion rules. #### Why does it matter? BNPL services have seen unprecedented growth, expanding from £0.06bn in 2017 to £13bn in 2024, with high adoption among consumers showing low financial resilience. While some claim this regulation could restrict access to credit, frictionless customer journeys have enabled rapid accumulation of unmanageable debt. By bringing BNPL under the outcomes-based Consumer Duty framework, the regulator aims to ensure borrowers receive clear information, proportionate affordability checks, and appropriate support if they fall into financial difficulty. #### Who is affected? All UK-based BNPL providers, fintech credit platforms, and merchants utilizing deferred payment solutions are affected by this regulatory expansion, alongside compliance leaders and risk managers. #### Key risks Unregulated or poorly prepared firms face several critical compliance risks: - Severe enforcement actions and financial penalties for failing to register within the designated May-to-July window. - Inadequate checkout disclosure and affordability checks failing to meet Consumer Duty standards. - Inability to handle consumer complaints through the Financial Ombudsman Service. #### Actions to take BNPL providers must take proactive steps now to prepare for the July 2026 deadline: 1. Submit applications for the Temporary Permissions Regime between 1 May and 1 July 2026. 2. Review checkout and payment journeys to embed transparency, clear disclosures, and balanced contract terms. 3. Upgrade credit assessment frameworks to include open banking and robust affordability checks. #### Wider implications The integration of BNPL into the FCA's scope reflects a broader trend of regulatory intervention in digital finance and frictionless checkout journeys, ensuring that vulnerable consumers are protected across all credit formats. #### Recommendations Firms should utilize specialist compliance consulting and interim resourcing to audit and upgrade their internal credit policies and complaints frameworks ahead of full authorization. #### Supporting sources - [FCA brings Buy Now Pay Later under its regulation from July 2026](https://tcc.group/blog/2026/02/12/fca-brings-buy-now-pay-later-under-its-regulation-from-july-2026/) (2026-02-12) #### Are your BNPL checkout journeys ready for regulation? Speak to our consumer credit experts to secure your temporary permissions and ensure full compliance with the Consumer Duty. 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"https://tcc.group/insights/regulatory-horizon/fca-brings-buy-now-pay-later-under-its-regulation-from-july-2026/#article", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/fca-brings-buy-now-pay-later-under-its-regulation-from-july-2026/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "FCA brings Buy Now Pay Later under its regulation from July 2026", "datePublished": "2026-02-12T00:00:00+01:00", "dateModified": "2026-09-02T03:47:41+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/regulatory-horizon/fca-brings-buy-now-pay-later-under-its-regulation-from-july-2026/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/e4c25b2adba94ea6ab2117b41436a589/thumbnail-1600-dfd1541fcb4595e24afb0d79dd3267b3516596d4d1c904aa31d663518095a092.jpg", "description": "The FCA has confirmed that the Buy Now Pay Later (BNPL) sector will come under its regulation starting 15 July 2026, introducing strict requirements for Consumer Duty compliance and robust affordability checks.", "inLanguage": "en-GB", "articleBody": "The FCA has confirmed that Buy Now Pay Later providers will fall under its full regulatory scope beginning in July 2026, requiring compliance with the Consumer Duty.\n\nFollowing a prolonged period of research and government consultation, the Financial Conduct Authority (FCA) has confirmed that the Buy Now Pay Later (BNPL) sector will officially fall under its regulatory supervision on 15 July 2026. This landmark decision brings stronger protections for millions of UK consumer credit borrowers.\n\nFirms operating in the BNPL space are urged to register for the Temporary Permissions Regime between 1 May and 1 July 2026, after which they will have a six-month window to apply for full registration. Merchant-own credit models remain exempt under the government's 2024 exclusion rules.\n\nBNPL services have seen unprecedented growth, expanding from \u00a30.06bn in 2017 to \u00a313bn in 2024, with high adoption among consumers showing low financial resilience. While some claim this regulation could restrict access to credit, frictionless customer journeys have enabled rapid accumulation of unmanageable debt.\n\nBy bringing BNPL under the outcomes-based Consumer Duty framework, the regulator aims to ensure borrowers receive clear information, proportionate affordability checks, and appropriate support if they fall into financial difficulty.\n\nAll UK-based BNPL providers, fintech credit platforms, and merchants utilizing deferred payment solutions are affected by this regulatory expansion, alongside compliance leaders and risk managers.\n\nUnregulated or poorly prepared firms face several critical compliance risks:\n\n\u2022 Severe enforcement actions and financial penalties for failing to register within the designated May-to-July window.\n\u2022 Inadequate checkout disclosure and affordability checks failing to meet Consumer Duty standards.\n\u2022 Inability to handle consumer complaints through the Financial Ombudsman Service.\n\nBNPL providers must take proactive steps now to prepare for the July 2026 deadline:\n\n1. Submit applications for the Temporary Permissions Regime between 1 May and 1 July 2026.\n2. Review checkout and payment journeys to embed transparency, clear disclosures, and balanced contract terms.\n3. Upgrade credit assessment frameworks to include open banking and robust affordability checks.\n\nThe integration of BNPL into the FCA's scope reflects a broader trend of regulatory intervention in digital finance and frictionless checkout journeys, ensuring that vulnerable consumers are protected across all credit formats.\n\nFirms should utilize specialist compliance consulting and interim resourcing to audit and upgrade their internal credit policies and complaints frameworks ahead of full authorization.", "wordCount": 383, "keywords": [ "Consumer Duty", "Regulatory Change & Transformation", "Lending & Consumer Credit", "Payments & FinTech" ], "about": [ { "@type": "Thing", "name": "Consumer Duty", "url": "https://tcc.group/blog/solution/consumer-duty/" }, { "@type": "Thing", "name": "Regulatory Change & Transformation", "url": "https://tcc.group/blog/solution/regulatory-change-transformation/" }, { "@type": "Thing", "name": "Lending & Consumer Credit", "url": "https://tcc.group/blog/sector/lending-consumer-credit/" }, { "@type": "Thing", "name": "Payments & FinTech", "url": "https://tcc.group/blog/sector/payments-fintech/" }, { "@type": "Thing", "name": "BNPL Regulation" } ], "articleSection": [ "Consumer Duty", "Regulatory Change & Transformation" ], "audience": [ { "@type": "Audience", "audienceType": "Lending & Consumer Credit" }, { "@type": "Audience", "audienceType": "Payments & FinTech" }, { "@type": "Audience", "audienceType": "Lenders, fintech companies, payments providers, and retail credit compliance directors." } ], "citation": [ { "@type": "CreativeWork", "name": "FCA brings Buy Now Pay Later under its regulation from July 2026", "url": "https://tcc.group/blog/2026/02/12/fca-brings-buy-now-pay-later-under-its-regulation-from-july-2026/", "datePublished": "2026-02-12" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/regulatory-horizon/fca-brings-buy-now-pay-later-under-its-regulation-from-july-2026/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/fca-brings-buy-now-pay-later-under-its-regulation-from-july-2026/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "When does BNPL regulation start in the UK?", "acceptedAnswer": { "@type": "Answer", "text": "The new regulatory regime officially begins on 15 July 2026, with the Temporary Permissions Regime open from 1 May to 1 July 2026." } }, { "@type": "Question", "name": "What does Consumer Duty mean for BNPL firms?", "acceptedAnswer": { "@type": "Answer", "text": "Firms must deliver clear payment agreements, conduct robust affordability checks, offer support for consumers in financial difficulty, and enable complaints to the Financial Ombudsman Service." } } ] } ] } ``` ### The FCA welcomes consolidation but raises the accountability bar - URL: https://tcc.group/insights/regulatory-horizon/the-fca-welcomes-consolidation-but-raises-the-accountability-bar/ - Published: 2026-02-10 - Modified: 2026-09-02 **Topic:** Consolidation and acquisition oversight The FCA's multi-firm review of wealth management consolidation confirms there are no new rules, but demands stronger evidence of governance, oversight and control from acquiring firms. Centralised compliance frameworks are becoming a condition of successful, scalable growth. #### What happened? The FCA's recent multi-firm review of consolidation in wealth management sends a clear message to leadership teams: growth is welcome, but only when it is supported by strong governance, effective oversight and clear evidence of control. For acquiring firms, this is a shift in emphasis rather than a new rulebook. The regulator is reinforcing expectations that have long existed, while significantly increasing scrutiny of how well firms demonstrate that they meet them in practice. The FCA has been positive about consolidation's role in improving customer outcomes and supporting sustainable growth, particularly given government initiatives to increase UK participation in investment markets and the structural shift to drawdown in retirement. #### Why does it matter? The FCA is placing particular focus on whether firms truly understand what they are acquiring and how effectively they oversee acquired businesses once transactions complete. Regulatory due diligence is no longer treated as a procedural step in the deal process. It must provide genuine insight into advice quality, cultural alignment and historical risk, and firms are expected to act decisively on what they uncover. Being able to evidence this end-to-end journey – from acquisition rationale through to integration and ongoing supervision – is fast becoming the currency of regulation. #### Who is affected? Consolidators and acquiring firms across wealth management and financial advice, particularly those integrating multiple acquired businesses under a single group structure. #### Key risks - Fragmented compliance and oversight across a group as it scales, reducing visibility and increasing risk. - Treating regulatory due diligence as a procedural step rather than a genuine assessment of advice quality and cultural fit. - Being unable to evidence the full acquisition-to-supervision journey when challenged by the regulator. - Slower growth, increased supervisory attention and operational friction for firms that cannot demonstrate control. #### Actions to take 1. Strengthen pre-acquisition regulatory due diligence so it genuinely tests advice quality, cultural alignment and historical risk. 2. Invest in group-wide governance standards and shared technology platforms as the business scales. 3. Adopt consistent suitability processes across acquired businesses to support meaningful management information. 4. Document the acquisition, integration and ongoing supervision journey so it can be evidenced to the regulator. #### Wider implications Centralisation is not simply about regulatory comfort – it creates operational leverage. When compliance, technology and reporting are aligned across a group, leadership teams gain clearer insight into adviser performance, client outcomes and risk trends. Firms that demonstrate evolved governance and disciplined integration are better placed to execute transactions with confidence and engage constructively with the regulator, turning scrutiny into a competitive differentiator. #### Recommendations TCC supports acquiring firms throughout the full acquisition lifecycle, from pre-acquisition regulatory due diligence to integration, governance design and ongoing compliance oversight, supported by Recordsure's AI-enabled technology. #### Supporting sources - [The FCA welcomes consolidation but raises the accountability bar](https://tcc.group/blog/2026/02/11/the-fca-welcomes-consolidation-but-raises-the-accountability-bar/) (2026-02-11) #### Ready to strengthen your acquisition governance? Talk to TCC about building an acquisition and integration strategy that stands up to FCA scrutiny. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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Centralised compliance frameworks are becoming a condition of successful, scalable growth.\n\nThe FCA's recent multi-firm review of consolidation in wealth management sends a clear message to leadership teams: growth is welcome, but only when it is supported by strong governance, effective oversight and clear evidence of control.\n\nFor acquiring firms, this is a shift in emphasis rather than a new rulebook. The regulator is reinforcing expectations that have long existed, while significantly increasing scrutiny of how well firms demonstrate that they meet them in practice.\n\nThe FCA has been positive about consolidation's role in improving customer outcomes and supporting sustainable growth, particularly given government initiatives to increase UK participation in investment markets and the structural shift to drawdown in retirement.\n\nThe FCA is placing particular focus on whether firms truly understand what they are acquiring and how effectively they oversee acquired businesses once transactions complete.\n\nRegulatory due diligence is no longer treated as a procedural step in the deal process. It must provide genuine insight into advice quality, cultural alignment and historical risk, and firms are expected to act decisively on what they uncover.\n\nBeing able to evidence this end-to-end journey \u2013 from acquisition rationale through to integration and ongoing supervision \u2013 is fast becoming the currency of regulation.\n\nConsolidators and acquiring firms across wealth management and financial advice, particularly those integrating multiple acquired businesses under a single group structure.\n\n\u2022 Fragmented compliance and oversight across a group as it scales, reducing visibility and increasing risk.\n\u2022 Treating regulatory due diligence as a procedural step rather than a genuine assessment of advice quality and cultural fit.\n\u2022 Being unable to evidence the full acquisition-to-supervision journey when challenged by the regulator.\n\u2022 Slower growth, increased supervisory attention and operational friction for firms that cannot demonstrate control.\n\n1. Strengthen pre-acquisition regulatory due diligence so it genuinely tests advice quality, cultural alignment and historical risk.\n2. Invest in group-wide governance standards and shared technology platforms as the business scales.\n3. Adopt consistent suitability processes across acquired businesses to support meaningful management information.\n4. Document the acquisition, integration and ongoing supervision journey so it can be evidenced to the regulator.\n\nCentralisation is not simply about regulatory comfort \u2013 it creates operational leverage. When compliance, technology and reporting are aligned across a group, leadership teams gain clearer insight into adviser performance, client outcomes and risk trends.\n\nFirms that demonstrate evolved governance and disciplined integration are better placed to execute transactions with confidence and engage constructively with the regulator, turning scrutiny into a competitive differentiator.\n\nTCC supports acquiring firms throughout the full acquisition lifecycle, from pre-acquisition regulatory due diligence to integration, governance design and ongoing compliance oversight, supported by Recordsure's AI-enabled technology.", "wordCount": 472, "keywords": [ "Compliance AI & RegTech", "Consolidation, Acquisition & Regulatory Due Diligence", "Regulatory Change & Transformation", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Consolidation, Acquisition & Regulatory Due Diligence", "url": "https://tcc.group/blog/solution/consolidation-acquisition-regulatory-due-diligence/" }, { "@type": "Thing", "name": "Regulatory Change & Transformation", "url": "https://tcc.group/blog/solution/regulatory-change-transformation/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Consolidation and acquisition oversight" } ], "articleSection": [ "Compliance AI & RegTech", "Consolidation, Acquisition & Regulatory Due Diligence", "Regulatory Change & Transformation" ], "audience": [ { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Leadership teams at wealth management and financial advice firms pursuing acquisitions or consolidation strategies." } ], "citation": [ { "@type": "CreativeWork", "name": "The FCA welcomes consolidation but raises the accountability bar", "url": "https://tcc.group/blog/2026/02/11/the-fca-welcomes-consolidation-but-raises-the-accountability-bar/", "datePublished": "2026-02-11" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/regulatory-horizon/the-fca-welcomes-consolidation-but-raises-the-accountability-bar/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/the-fca-welcomes-consolidation-but-raises-the-accountability-bar/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "Does the FCA's review introduce new rules for consolidators?", "acceptedAnswer": { "@type": "Answer", "text": "No. The review reinforces existing expectations around governance and oversight rather than creating new rules, while increasing scrutiny of how firms evidence compliance." } }, { "@type": "Question", "name": "Why does regulatory due diligence matter more now?", "acceptedAnswer": { "@type": "Answer", "text": "The FCA expects it to provide genuine insight into advice quality, cultural alignment and historical risk, rather than acting as a procedural step in the deal." } }, { "@type": "Question", "name": "What role does centralised governance play?", "acceptedAnswer": { "@type": "Answer", "text": "Firms with group-wide standards, shared technology and consistent suitability processes are better placed to demonstrate control and respond quickly to emerging issues." } }, { "@type": "Question", "name": "How can TCC help?", "acceptedAnswer": { "@type": "Answer", "text": "TCC supports firms across the acquisition lifecycle, from pre-acquisition due diligence to integration, governance design and ongoing compliance oversight." } } ] } ] } ``` ### Insurance Edge: Pure Protection in Focus - URL: https://tcc.group/insights/analysis-perspectives/insurance-edge-pure-protection-in-focus/ - Published: 2026-02-05 - Modified: 2026-09-02 **Topic:** Pure Protection Market Study TCC Group highlights the rising regulatory expectations from the FCA's Pure Protection Market Study regarding commission transparency and distribution models. #### What happened? The FCA's Pure Protection Market Study signals tougher regulatory expectations around fair value, commission transparency, and consumer outcomes. While pure protection products have seen improvements in claims and coverage, the regulator remains concerned about protection gaps and commission-driven incentives. With the final report expected in Q3 2026, firms must act now to review their distribution models and vulnerable customer safeguards. #### Why does it matter? The study highlights the FCA's scrutiny of commission structures and potential conflicts of interest that could lead to poor customer value. Firms in the pure protection space must establish robust data metrics to prove that their distribution structures deliver fair value and do not exploit vulnerable customers. #### Supporting sources - [Insurance Edge: Pure Protection in Focus](https://tcc.group/blog/2026/02/06/insurance-edge-pure-protection-in-focus/) (2026-02-06) #### Is your pure protection model ready for FCA scrutiny? Speak to our advisory specialists to evaluate your commission structures, distribution channels, and product governance before the FCA's final study report. 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"https://tcc.group/insights/analysis-perspectives/insurance-edge-pure-protection-in-focus/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "Insurance Edge: Pure Protection in Focus", "datePublished": "2026-02-06T00:00:00+01:00", "dateModified": "2026-09-02T03:47:53+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/analysis-perspectives/insurance-edge-pure-protection-in-focus/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/e7eedc60ce7d498783f2958517884d7f/thumbnail-1024-65152fde6f6bfbd9eb4543cdd53efce7bb3c443fab76cb2af1ede820115860ff.jpg", "description": "Understand the regulatory implications of the FCA's Pure Protection Market Study on commission transparency, fair value, and vulnerable customers in the protection insurance sector.", "inLanguage": "en-GB", "articleBody": "TCC Group highlights the rising regulatory expectations from the FCA's Pure Protection Market Study regarding commission transparency and distribution models.\n\nThe FCA's Pure Protection Market Study signals tougher regulatory expectations around fair value, commission transparency, and consumer outcomes. While pure protection products have seen improvements in claims and coverage, the regulator remains concerned about protection gaps and commission-driven incentives.\n\nWith the final report expected in Q3 2026, firms must act now to review their distribution models and vulnerable customer safeguards.\n\nThe study highlights the FCA's scrutiny of commission structures and potential conflicts of interest that could lead to poor customer value. 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The FCA has completed a multi-firm review of consolidation in the financial advice and wealth management sector, examining how acquiring firms govern, integrate and oversee their growing groups. In a Q&A session, TCC Group's Chief Product and Commercial Officer, Garry Evans, and Technical Director, David Boyhan, unpacked the review's findings. The headline message is that there are no new regulatory requirements, but the FCA is reinforcing long-standing expectations around control, oversight and governance. The regulator also highlighted good practice across the market and confirmed its commitment to supporting consolidators in delivering strong customer outcomes and sustainable growth. #### Why does it matter? The broader environment remains favourable for consolidation, supported by government and regulatory initiatives to increase UK participation in investment markets and structural trends such as the shift towards drawdown in retirement. Historically significant redress liabilities, particularly for defined benefit transfers, have also materially declined as interest rates have risen, adding to a positive picture for continued consolidation. Even so, the FCA expects consolidators to demonstrate that they understand exactly what they are buying, that systems and controls scale appropriately, and that group-wide risk management genuinely covers every acquired entity. #### Who is affected? Consolidators and acquiring firms in wealth management and financial advice, along with the target firms they acquire, are directly affected by the review's findings. #### Key risks - Group risk management frameworks that do not properly capture every entity within the group. - Systems and controls that fail to scale in line with growth. - Board effectiveness gaps as organisations expand without matching skills, experience or challenge. - Due diligence that stops at a tick-box exercise rather than truly understanding advice quality, culture and potential liabilities. #### Actions to take 1. Be explicit about risk appetite, the types of firms to acquire and the strategic rationale for each transaction. 2. Assess cultural alignment alongside technical strength before completing an acquisition. 3. Carry out high-quality regulatory due diligence that identifies issues, understands their implications and acts on findings. 4. Evolve boards and committees as the group grows, whether through training or recruiting specialist expertise. 5. Plan integration well before completion, covering onboarding, technology migration, training and resourcing. #### Wider implications Technology is playing an increasingly important role in evidencing compliance across distributed adviser populations, with centralised investment in systems supporting consistency and regulatory confidence more effectively than fragmented local decisions. Firms that treat governance and integration as central to their acquisition strategy, rather than an afterthought, are best placed to meet the FCA's expectations while continuing to grow. #### Recommendations TCC has supported consolidators for over 20 years across acquisition, due diligence, integration, governance and remediation, and combines this with Recordsure's AI-enabled compliance technology to help firms build scalable, regulator-ready consolidation models. Firms should seek independent input on how the FCA's findings apply to their specific business and how to manage regulatory and operational risk throughout the consolidation process. #### Supporting sources - [Consolidation: Balancing ambition with regulatory discipline](https://tcc.group/blog/2026/02/04/consolidation-balancing-commercial-ambition-with-regulatory-discipline/) (2026-02-04) #### Ready to strengthen your consolidation model? Book a time with our consolidation specialists to understand how the FCA's findings apply to your business and how we can help manage risk throughout the process. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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must now evidence stronger governance, group-wide risk oversight and due diligence as acquisitions continue across wealth management and financial advice.", "inLanguage": "en-GB", "articleBody": "The FCA's multi-firm review found no new rules for consolidators, but raised expectations on governance, oversight and due diligence as acquisitions continue across wealth management and financial advice.\n\nThe FCA has completed a multi-firm review of consolidation in the financial advice and wealth management sector, examining how acquiring firms govern, integrate and oversee their growing groups.\n\nIn a Q&A session, TCC Group's Chief Product and Commercial Officer, Garry Evans, and Technical Director, David Boyhan, unpacked the review's findings. The headline message is that there are no new regulatory requirements, but the FCA is reinforcing long-standing expectations around control, oversight and governance.\n\nThe regulator also highlighted good practice across the market and confirmed its commitment to supporting consolidators in delivering strong customer outcomes and sustainable growth.\n\nThe broader environment remains favourable for consolidation, supported by government and regulatory initiatives to increase UK participation in investment markets and structural trends such as the shift towards drawdown in retirement.\n\nHistorically significant redress liabilities, particularly for defined benefit transfers, have also materially declined as interest rates have risen, adding to a positive picture for continued consolidation.\n\nEven so, the FCA expects consolidators to demonstrate that they understand exactly what they are buying, that systems and controls scale appropriately, and that group-wide risk management genuinely covers every acquired entity.\n\nConsolidators and acquiring firms in wealth management and financial advice, along with the target firms they acquire, are directly affected by the review's findings.\n\n\u2022 Group risk management frameworks that do not properly capture every entity within the group.\n\u2022 Systems and controls that fail to scale in line with growth.\n\u2022 Board effectiveness gaps as organisations expand without matching skills, experience or challenge.\n\u2022 Due diligence that stops at a tick-box exercise rather than truly understanding advice quality, culture and potential liabilities.\n\n1. 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The Financial Conduct Authority (FCA) has issued its Interim Report on the Pure Protection Market Study, following data requests from 30 major insurers and intermediaries. The study focuses on fair value, commission structures, panel agreements, and digital accessibility across the pure protection distribution chain. While the review noted positive progress in claims payout rates, it raised serious concerns over wide protection gaps, limited accessibility for vulnerable consumers, and opaque panel and commission arrangements. #### Why does it matter? Pure protection has historically escaped the strict commission disclosures mandatory in other sectors, but this study signals a major shift. With indemnity commission models, clawback terms, and restricted panels under scrutiny, the regulator is evaluating whether these commercial structures distort advice suitability and premium pricing. Importantly, while the study is forward-looking and not an enforcement review, its final recommendations in Q3 2026 are highly likely to introduce rigid new rules around commission transparency and panel disclosures. #### Who is affected? Protection insurers, life assurance companies, non-workplace pension distributors, price comparison websites, and protection intermediaries are directly affected. #### Key risks Firms face key compliance and business model risks if they fail to adapt: - Severe disruption to commercial distribution models if indemnity commissions are restricted or capped. - Regulatory action for failing to show that panel selections and recommendations serve the customer's best interests. - Failing to provide accessible, plain-English information to customers, particularly those with vulnerable characteristics. #### Actions to take Protection providers and intermediaries should act during this interim feedback window: 1. Conduct a thorough review of existing commission structures and panel models against the FCA's fair value outcome. 2. Assess and enhance digital advice journeys and customer portals to guarantee accessibility for vulnerable consumers. 3. Prepare for increased commission transparency by modeling the impact of disclosure on customer journeys. #### Wider implications The pure protection market is the latest area to feel the impact of the outcomes-based Consumer Duty. The regulator's focus on information asymmetry suggests that the entire retail protection distribution chain will face structural reform to eliminate hidden incentives. #### Recommendations We recommend conducting a proactive audit of your distribution partners' sales practices and establishing robust, evidence-backed fair value assessments for all protection products. #### Supporting sources - [Pure Protection: Regulatory expectations intensify in 2026 | TCC](https://tcc.group/blog/2026/01/30/fca-market-study-on-pure-protection-regulatory-expectations-intensify-in-2026/) (2026-01-30) #### Is your pure protection commission model compliant? Speak to our insurance compliance specialists today to review your panels, commissions, and Consumer Duty evidence ahead of the final report. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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"@id": "https://tcc.group/insights/regulatory-horizon/fca-market-study-on-pure-protection-regulatory-expectations-intensify-in-2026/#article", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/fca-market-study-on-pure-protection-regulatory-expectations-intensify-in-2026/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "Pure Protection: Regulatory expectations intensify in 2026 | TCC", "datePublished": "2026-01-30T00:00:00+01:00", "dateModified": "2026-09-02T03:47:42+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/regulatory-horizon/fca-market-study-on-pure-protection-regulatory-expectations-intensify-in-2026/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/c5d7ea8832e54d629343721639f52535/thumbnail-1024-79293417693d773ceb31acf27182bf8df6ac3a46f606038af13ade5c86923289.jpg", "description": "As the FCA's Pure Protection Market Study intensifies, firms face unprecedented scrutiny over commissions, panel structures, and vulnerable customer support. Discover the interim findings and key steps to ensure compliance.", "inLanguage": "en-GB", "articleBody": "The FCA's Interim Report on the Pure Protection Market Study signals a tightening regulatory environment around insurance commissions, panel models, and vulnerable consumer access.\n\nThe Financial Conduct Authority (FCA) has issued its Interim Report on the Pure Protection Market Study, following data requests from 30 major insurers and intermediaries. The study focuses on fair value, commission structures, panel agreements, and digital accessibility across the pure protection distribution chain.\n\nWhile the review noted positive progress in claims payout rates, it raised serious concerns over wide protection gaps, limited accessibility for vulnerable consumers, and opaque panel and commission arrangements.\n\nPure protection has historically escaped the strict commission disclosures mandatory in other sectors, but this study signals a major shift. With indemnity commission models, clawback terms, and restricted panels under scrutiny, the regulator is evaluating whether these commercial structures distort advice suitability and premium pricing.\n\nImportantly, while the study is forward-looking and not an enforcement review, its final recommendations in Q3 2026 are highly likely to introduce rigid new rules around commission transparency and panel disclosures.\n\nProtection insurers, life assurance companies, non-workplace pension distributors, price comparison websites, and protection intermediaries are directly affected.\n\nFirms face key compliance and business model risks if they fail to adapt:\n\n\u2022 Severe disruption to commercial distribution models if indemnity commissions are restricted or capped.\n\u2022 Regulatory action for failing to show that panel selections and recommendations serve the customer's best interests.\n\u2022 Failing to provide accessible, plain-English information to customers, particularly those with vulnerable characteristics.\n\nProtection providers and intermediaries should act during this interim feedback window:\n\n1. Conduct a thorough review of existing commission structures and panel models against the FCA's fair value outcome.\n2. Assess and enhance digital advice journeys and customer portals to guarantee accessibility for vulnerable consumers.\n3. Prepare for increased commission transparency by modeling the impact of disclosure on customer journeys.\n\nThe pure protection market is the latest area to feel the impact of the outcomes-based Consumer Duty. The regulator's focus on information asymmetry suggests that the entire retail protection distribution chain will face structural reform to eliminate hidden incentives.\n\nWe recommend conducting a proactive audit of your distribution partners' sales practices and establishing robust, evidence-backed fair value assessments for all protection products.", "wordCount": 370, "keywords": [ "Consumer Duty", "Regulatory Change & Transformation", "General Insurance & Protection" ], "about": [ { "@type": "Thing", "name": "Consumer Duty", "url": "https://tcc.group/blog/solution/consumer-duty/" }, { "@type": "Thing", "name": "Regulatory Change & Transformation", "url": "https://tcc.group/blog/solution/regulatory-change-transformation/" }, { "@type": "Thing", "name": "General Insurance & Protection", "url": "https://tcc.group/blog/sector/general-insurance-protection/" }, { "@type": "Thing", "name": "Pure Protection Market Study" } ], "articleSection": [ "Consumer Duty", "Regulatory Change & Transformation" ], "audience": [ { "@type": "Audience", "audienceType": "General Insurance & Protection" }, { "@type": "Audience", "audienceType": "Insurers, distributors, independent brokers, and compliance heads within the life and protection insurance sectors." } ], "citation": [ { "@type": "CreativeWork", "name": "Pure Protection: Regulatory expectations intensify in 2026 | TCC", "url": "https://tcc.group/blog/2026/01/30/fca-market-study-on-pure-protection-regulatory-expectations-intensify-in-2026/", "datePublished": "2026-01-30" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/regulatory-horizon/fca-market-study-on-pure-protection-regulatory-expectations-intensify-in-2026/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/fca-market-study-on-pure-protection-regulatory-expectations-intensify-in-2026/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What is the purpose of the FCA Pure Protection Market Study?", "acceptedAnswer": { "@type": "Answer", "text": "The study aims to evaluate whether commission structures, panel arrangements, and distribution models work in the best interest of customers and promote healthy market competition." } }, { "@type": "Question", "name": "When is the final Pure Protection report expected?", "acceptedAnswer": { "@type": "Answer", "text": "The FCA is scheduled to publish its final report and targeted regulatory proposals in Q3 2026." } } ] } ] } ``` ### Why no loss doesn’t mean no risk in today’s redress market - URL: https://tcc.group/insights/regulatory-horizon/why-no-loss-doesnt-mean-no-risk-in-todays-redress-market/ - Published: 2026-01-28 - Modified: 2026-09-02 **Topic:** Redress Risk Management TCC explains why rising gilt yields producing ‘no loss’ redress outcomes don’t remove risk, and how firms are reprioritising DB transfer review and due diligence as a result. #### What happened? Today’s gilt environment has produced a growing number of ‘no loss’ outcomes on historic defined benefit transfer cases. Redress has shifted from being driven mainly by DB transfer complaints escalated through claims management companies or the Financial Ombudsman Service, towards becoming a critical component of M&A due diligence. Firms are no longer just asking “what is the loss today?” but increasingly “what could this look like under different market conditions?” Many are now reversing the traditional process, running redress calculations on higher-risk samples first to quickly establish whether losses exist before committing to full suitability reviews. #### Why does it matter? A ‘no loss’ result reflects conditions at a specific point in time, not a permanent state. If gilt yields were to fall materially, cases that look benign today could quickly become loss-making, and regulatory methodology may also evolve. An effective redress strategy now requires forward-looking scenario testing, not just retrospective calculation. #### Who is affected? Wealth managers and consolidators holding legacy DB transfer risk, and firms assessing books of business for acquisition. #### Key risks - Treating today’s ‘no loss’ position as permanent rather than point-in-time. - Overlooking higher-risk cohorts, such as larger transfer values, older cases from 2016–2017, and advice given to younger clients. - Failing to scenario-test exposure against falling gilt yields or evolving FCA methodology. - Applying an inconsistent approach to individual FOS-upheld cases versus book-level M&A due diligence. #### Actions to take 1. Prioritise review of higher-risk cases first: larger transfers, older cases, younger clients and higher-risk investment choices. 2. Run redress calculations ahead of full suitability reviews to quickly establish whether losses exist. 3. Build scenario testing that models outcomes under different yield environments. 4. Tailor methodology to the firm’s objectives, using detailed calculations for individual FOS cases and point-of-sale or market-index approaches for book-level M&A reviews. #### Wider implications Redress is becoming embedded in wider governance and acquisition strategy rather than treated as a standalone complaints process. Consolidators willing to acquire DB transfer books previously avoided need robust forward-looking analysis to price that risk appropriately. #### Recommendations At TCC, our team combines deep technical redress expertise with independence, helping firms quantify, manage and resolve redress obligations, from a single calculation to a strategic view across hundreds of historic cases. #### Supporting sources - [Why no loss doesn’t mean no risk in today’s redress market](https://tcc.group/blog/2026/01/29/why-no-loss-doesnt-mean-no-risk-in-todays-redress-market/) (2026-01-29) #### Managing legacy DB transfer risk? Get in touch to discuss how we can help quantify, manage and resolve redress obligations across your DB transfer book. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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"https://tcc.group/insights/regulatory-horizon/why-no-loss-doesnt-mean-no-risk-in-todays-redress-market/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/regulatory-horizon/why-no-loss-doesnt-mean-no-risk-in-todays-redress-market/#webpage", "url": "https://tcc.group/insights/regulatory-horizon/why-no-loss-doesnt-mean-no-risk-in-todays-redress-market/", "name": "Why no loss doesn\u2019t mean no risk in today\u2019s redress market", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-01-29T00:00:00+01:00", "dateModified": "2026-09-02T03:49:13+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/regulatory-horizon/why-no-loss-doesnt-mean-no-risk-in-todays-redress-market/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "NewsArticle", "@id": "https://tcc.group/insights/regulatory-horizon/why-no-loss-doesnt-mean-no-risk-in-todays-redress-market/#article", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/why-no-loss-doesnt-mean-no-risk-in-todays-redress-market/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "Why no loss doesn\u2019t mean no risk in today\u2019s redress market", "datePublished": "2026-01-29T00:00:00+01:00", "dateModified": "2026-09-02T03:49:13+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/regulatory-horizon/why-no-loss-doesnt-mean-no-risk-in-todays-redress-market/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/9a19806221ab425a94b40367f0afbf2b/thumbnail-1024-df2e9c90f059c649bffaa8279de13bbf6f3983135048873d3ee6a3b641010ae0.jpg", "description": "Discover why \u2018no loss\u2019 redress outcomes don\u2019t remove risk, and how firms are using scenario testing and prioritised due diligence to manage DB transfer exposure through market cycles.", "inLanguage": "en-GB", "articleBody": "TCC explains why rising gilt yields producing \u2018no loss\u2019 redress outcomes don\u2019t remove risk, and how firms are reprioritising DB transfer review and due diligence as a result.\n\nToday\u2019s gilt environment has produced a growing number of \u2018no loss\u2019 outcomes on historic defined benefit transfer cases. Redress has shifted from being driven mainly by DB transfer complaints escalated through claims management companies or the Financial Ombudsman Service, towards becoming a critical component of M&A due diligence.\n\nFirms are no longer just asking \u201cwhat is the loss today?\u201d but increasingly \u201cwhat could this look like under different market conditions?\u201d Many are now reversing the traditional process, running redress calculations on higher-risk samples first to quickly establish whether losses exist before committing to full suitability reviews.\n\nA \u2018no loss\u2019 result reflects conditions at a specific point in time, not a permanent state. If gilt yields were to fall materially, cases that look benign today could quickly become loss-making, and regulatory methodology may also evolve.\n\nAn effective redress strategy now requires forward-looking scenario testing, not just retrospective calculation.\n\nWealth managers and consolidators holding legacy DB transfer risk, and firms assessing books of business for acquisition.\n\n\u2022 Treating today\u2019s \u2018no loss\u2019 position as permanent rather than point-in-time.\n\u2022 Overlooking higher-risk cohorts, such as larger transfer values, older cases from 2016\u20132017, and advice given to younger clients.\n\u2022 Failing to scenario-test exposure against falling gilt yields or evolving FCA methodology.\n\u2022 Applying an inconsistent approach to individual FOS-upheld cases versus book-level M&A due diligence.\n\n1. Prioritise review of higher-risk cases first: larger transfers, older cases, younger clients and higher-risk investment choices.\n2. Run redress calculations ahead of full suitability reviews to quickly establish whether losses exist.\n3. Build scenario testing that models outcomes under different yield environments.\n4. Tailor methodology to the firm\u2019s objectives, using detailed calculations for individual FOS cases and point-of-sale or market-index approaches for book-level M&A reviews.\n\nRedress is becoming embedded in wider governance and acquisition strategy rather than treated as a standalone complaints process. Consolidators willing to acquire DB transfer books previously avoided need robust forward-looking analysis to price that risk appropriately.\n\nAt TCC, our team combines deep technical redress expertise with independence, helping firms quantify, manage and resolve redress obligations, from a single calculation to a strategic view across hundreds of historic cases.", "wordCount": 383, "keywords": [ "Complaints & Claims Handling", "Redress & Remediation", "Section 166, Skilled Person Reviews & FCA Intervention", "Pensions & Retirement Income", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Complaints & Claims Handling", "url": "https://tcc.group/blog/solution/complaints-claims-handling/" }, { "@type": "Thing", "name": "Redress & Remediation", "url": "https://tcc.group/blog/solution/redress-and-remediation/" }, { "@type": "Thing", "name": "Section 166, Skilled Person Reviews & FCA Intervention", "url": "https://tcc.group/blog/solution/section-166-skilled-person-reviews-fca-intervention/" }, { "@type": "Thing", "name": "Pensions & Retirement Income", "url": "https://tcc.group/blog/sector/pensions-retirement-income/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Redress Risk Management" } ], "articleSection": [ "Complaints & Claims Handling", "Redress & Remediation", "Section 166, Skilled Person Reviews & FCA Intervention" ], "audience": [ { "@type": "Audience", "audienceType": "Pensions & Retirement Income" }, { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Risk, complaints and M&A due diligence teams at wealth managers and consolidators managing legacy DB transfer exposure." } ], "citation": [ { "@type": "CreativeWork", "name": "Why no loss doesn\u2019t mean no risk in today\u2019s redress market", "url": "https://tcc.group/blog/2026/01/29/why-no-loss-doesnt-mean-no-risk-in-todays-redress-market/", "datePublished": "2026-01-29" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/regulatory-horizon/why-no-loss-doesnt-mean-no-risk-in-todays-redress-market/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/why-no-loss-doesnt-mean-no-risk-in-todays-redress-market/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "Why doesn\u2019t a \u2018no loss\u2019 outcome remove redress risk?", "acceptedAnswer": { "@type": "Answer", "text": "Because it reflects market conditions at a specific point in time; if gilt yields fall, cases that look benign today could become loss-making." } }, { "@type": "Question", "name": "How has redress become linked to M&A due diligence?", "acceptedAnswer": { "@type": "Answer", "text": "Falling losses on historic DB transfers have made some consolidators willing to acquire books of business they previously avoided, making forward-looking redress risk a key due diligence question." } }, { "@type": "Question", "name": "Which cases carry the greatest potential exposure?", "acceptedAnswer": { "@type": "Answer", "text": "Larger transfer values, older cases (particularly 2016\u20132017), advice given to younger clients, and cases where funds sat in cash or moved into higher-risk investments." } }, { "@type": "Question", "name": "What is scenario testing used for in redress?", "acceptedAnswer": { "@type": "Answer", "text": "To model outcomes under different yield environments, helping risk teams move beyond point-in-time assessments to understand potential long-term liabilities." } } ] } ] } ``` ### AI in financial services: a turning point for regulators and firms - URL: https://tcc.group/insights/press-releases/ai-in-financial-services-a-turning-point-for-regulators-and-firms/ - Published: 2026-01-28 - Modified: 2026-09-02 **Topic:** AI governance and accountability A UK Parliament Treasury Committee report finds that more than three-quarters of financial services firms are now using AI, but regulatory oversight has not kept pace with the risks. TCC Group's CEO Joe Norburn sets out what the findings mean for governance and accountability. #### What happened? The UK Parliament's Treasury Committee has published its report on Artificial Intelligence in Financial Services, finding that more than three-quarters of firms are now using AI, particularly in insurance claims processing and credit assessments. Commenting on the report, Joe Norburn, CEO of TCC Group, said it delivers “a stark warning to regulators and firms”. The Committee concluded that a “wait-and-see” regulatory stance is no longer sufficient. It recommends that the Bank of England and the Financial Conduct Authority provide practical guidance on how existing rules apply to AI by the end of 2026, strengthen accountability under the Senior Managers and Certification Regime, and introduce AI-specific stress testing. It also urges HM Treasury to bring major AI and cloud providers into the Critical Third Parties regime. Evidence submitted to MPs pointed to a lack of transparency in AI-driven decisions, the risk of excluding vulnerable customers, rising fraud, and unregulated advice from AI chatbots as areas of particular concern. #### Why does it matter? Norburn said the report exposes “a growing tension inside firms”: AI is evolving quickly and is often embedded deep within operational processes, while regulatory expectations remain fragmented and, in places, ambiguous. Without decisive action, the Committee warns that AI-driven decision-making risks amplifying bias, weakening consumer protection and creating new sources of systemic shock. Where accountability for AI outcomes is unclear, responsibility can fall through the gaps between teams and functions. The Committee's recommendations mark a shift from AI being treated primarily as an innovation opportunity to being treated as a conduct and operational resilience issue in its own right. #### Who is affected? The findings are relevant to firms across banking, lending and consumer credit, wealth management and financial advice, pensions and retirement income, payments and fintech, general insurance and protection, and motor finance, wherever AI is used in credit decisions, insurance claims, customer service or advice-related processes. Senior managers with responsibility for AI systems under the Senior Managers and Certification Regime are directly affected by the Committee's call for clearer accountability. #### Key risks - Opaque, hard-to-explain AI decision-making in credit, insurance and customer service - Potential exclusion of vulnerable consumers from products or fair treatment - Increased fraud enabled by AI tools - Unregulated advice or guidance generated by AI chatbots - Concentration risk from reliance on a small number of AI and cloud providers #### Actions to take 1. Review current AI use across credit, insurance, customer service and advice processes against existing regulatory expectations. 2. Clarify and document accountability for AI-related outcomes under the Senior Managers and Certification Regime. 3. Strengthen governance frameworks so that transparency and consumer protection are built in before AI systems are deployed, not added afterwards. 4. Assess exposure to AI and cloud providers ahead of possible inclusion in the Critical Third Parties regime. #### Wider implications The Committee's recommendations point towards firmer, more specific regulatory guidance from the Bank of England and the FCA by the end of 2026, rather than continued reliance on existing, more general rules. Bringing major AI and cloud providers within the Critical Third Parties regime would extend direct regulatory scrutiny beyond regulated firms themselves to the infrastructure many of them depend on. #### Recommendations Firms that strengthen governance frameworks, clarify accountability for AI outcomes, and align with emerging regulatory expectations now will be better placed as the Committee's recommendations take effect. Thoughtful implementation, supported by clear oversight, allows firms to pursue the efficiency benefits of AI while protecting consumers and market integrity. #### Supporting sources - [AI in financial services: a turning point for regulators and firms](https://tcc.group/blog/2026/01/29/ai-in-financial-services-a-turning-point-for-regulators-and-firms/) (2026-01-29) #### Need help governing AI responsibly? Get in touch to learn how we support financial services firms in adopting AI with confidence in regulated environments. 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"https://tcc.group/insights/press-releases/ai-in-financial-services-a-turning-point-for-regulators-and-firms/#article", "isPartOf": { "@id": "https://tcc.group/insights/press-releases/ai-in-financial-services-a-turning-point-for-regulators-and-firms/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "AI in financial services: a turning point for regulators and firms", "datePublished": "2026-01-29T00:00:00+01:00", "dateModified": "2026-09-02T03:47:31+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/press-releases/ai-in-financial-services-a-turning-point-for-regulators-and-firms/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/5afcd22d295a45e3b14af58d6ce600ff/thumbnail-1024-cfb3d55852c800d115cb34d2dfa7cc94f7a52ea8fd98230b7e38b409d731cd7a.jpg", "description": "TCC Group's CEO responds to a Treasury Committee report exposing gaps in AI oversight across financial services, explaining what firms need to do now to strengthen governance, accountability and consumer protection.", "inLanguage": "en-GB", "articleBody": "A UK Parliament Treasury Committee report finds that more than three-quarters of financial services firms are now using AI, but regulatory oversight has not kept pace with the risks. TCC Group's CEO Joe Norburn sets out what the findings mean for governance and accountability.\n\nThe UK Parliament's Treasury Committee has published its report on Artificial Intelligence in Financial Services, finding that more than three-quarters of firms are now using AI, particularly in insurance claims processing and credit assessments. Commenting on the report, Joe Norburn, CEO of TCC Group, said it delivers \u201ca stark warning to regulators and firms\u201d.\n\nThe Committee concluded that a \u201cwait-and-see\u201d regulatory stance is no longer sufficient. It recommends that the Bank of England and the Financial Conduct Authority provide practical guidance on how existing rules apply to AI by the end of 2026, strengthen accountability under the Senior Managers and Certification Regime, and introduce AI-specific stress testing. It also urges HM Treasury to bring major AI and cloud providers into the Critical Third Parties regime.\n\nEvidence submitted to MPs pointed to a lack of transparency in AI-driven decisions, the risk of excluding vulnerable customers, rising fraud, and unregulated advice from AI chatbots as areas of particular concern.\n\nNorburn said the report exposes \u201ca growing tension inside firms\u201d: AI is evolving quickly and is often embedded deep within operational processes, while regulatory expectations remain fragmented and, in places, ambiguous.\n\nWithout decisive action, the Committee warns that AI-driven decision-making risks amplifying bias, weakening consumer protection and creating new sources of systemic shock. Where accountability for AI outcomes is unclear, responsibility can fall through the gaps between teams and functions.\n\nThe Committee's recommendations mark a shift from AI being treated primarily as an innovation opportunity to being treated as a conduct and operational resilience issue in its own right.\n\nThe findings are relevant to firms across banking, lending and consumer credit, wealth management and financial advice, pensions and retirement income, payments and fintech, general insurance and protection, and motor finance, wherever AI is used in credit decisions, insurance claims, customer service or advice-related processes.\n\nSenior managers with responsibility for AI systems under the Senior Managers and Certification Regime are directly affected by the Committee's call for clearer accountability.\n\n\u2022 Opaque, hard-to-explain AI decision-making in credit, insurance and customer service\n\u2022 Potential exclusion of vulnerable consumers from products or fair treatment\n\u2022 Increased fraud enabled by AI tools\n\u2022 Unregulated advice or guidance generated by AI chatbots\n\u2022 Concentration risk from reliance on a small number of AI and cloud providers\n\n1. Review current AI use across credit, insurance, customer service and advice processes against existing regulatory expectations.\n2. Clarify and document accountability for AI-related outcomes under the Senior Managers and Certification Regime.\n3. Strengthen governance frameworks so that transparency and consumer protection are built in before AI systems are deployed, not added afterwards.\n4. Assess exposure to AI and cloud providers ahead of possible inclusion in the Critical Third Parties regime.\n\nThe Committee's recommendations point towards firmer, more specific regulatory guidance from the Bank of England and the FCA by the end of 2026, rather than continued reliance on existing, more general rules.\n\nBringing major AI and cloud providers within the Critical Third Parties regime would extend direct regulatory scrutiny beyond regulated firms themselves to the infrastructure many of them depend on.\n\nFirms that strengthen governance frameworks, clarify accountability for AI outcomes, and align with emerging regulatory expectations now will be better placed as the Committee's recommendations take effect.\n\nThoughtful implementation, supported by clear oversight, allows firms to pursue the efficiency benefits of AI while protecting consumers and market integrity.", "wordCount": 601, "keywords": [ "Compliance AI & RegTech", "Regulatory Change & Transformation", 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prepare for more detailed regulatory guidance and stress testing." } } ] } ] } ``` ### AB Accounting: AML heat to rise - URL: https://tcc.group/insights/analysis-perspectives/ab-accounting-aml-heat-to-rise/ - Published: 2026-01-26 - Modified: 2026-09-02 **Topic:** AML supervision for accountants TCC Group CEO Joe Norburn warns in AB Accounting that accountancy firms face tougher, data-led anti-money laundering supervision as the FCA takes over from 23 professional body supervisors. #### What happened? Accountancy firms should prepare for tougher anti-money laundering and counter-terrorism financing supervision, as the FCA is set to take over supervision from 23 professional body supervisors. The change brings stricter enforcement, greater scrutiny and heavier compliance demands, with a data-led, risk-based approach expected to increase the depth and frequency of checks. Writing for AB.accounting, TCC Group CEO Joe Norburn describes the change as transformational, pushing firms into a far more structured regulatory environment with a strong focus on governance, documentation and senior management accountability. #### Why does it matter? Norburn warns that broad statements of compliance will no longer be sufficient. The FCA will expect clear evidence, audit trails and active senior leadership engagement in managing AML and CTF risk, rather than generalised assurances. #### Supporting sources - [AB Accounting: AML heat to rise](https://tcc.group/blog/2026/01/27/ab-accounting-aml-heat-to-rise/) (2026-01-27) #### Preparing your firm for FCA AML supervision? Talk to us about strengthening your governance, documentation and evidence ahead of the FCA taking on AML supervision. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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TCC Group's CEO explains what a single regulator will expect to see. #### What happened? The FCA is preparing to take over anti-money laundering (AML) and counter-terrorist financing supervision of the legal and accounting sectors from 23 professional body supervisors. Joe Norburn, CEO of TCC Group, described the move as "transformational" in comments to AB Accounting, warning that firms will no longer be able to rely on broad statements of compliance. Instead, he said, firms will need to "provide clearer evidence for risk assessment, control testing and governance", moving beyond tick-box exercises towards a culture of demonstrable compliance. #### Why does it matter? A single regulator taking over from a patchwork of professional body supervisors points to deeper reviews, evidence-based assessments and less tolerance for informal or undocumented AML controls. > Practices will likely need to adopt a more structured approach to governance, with proper reporting, clear escalation routes and senior leaders engaging with AML risk on a regular basis. As Norburn puts it, accountability has to sit at the top table: AML can no longer be treated as a side task for one individual to manage in isolation. #### Who is affected? Accountancy firms currently supervised by one of the 23 professional body supervisors for AML purposes are directly affected, along with their MLROs and senior leadership teams who will carry greater personal accountability for governance and evidence. #### Key risks - Greater scrutiny, with deeper reviews of AML frameworks and a shift towards evidence-based assessment. - Governance gaps, where reporting lines, escalation routes and board-level engagement are informal or undocumented. - Weak data and monitoring, leaving firms unable to demonstrate how AML controls actually operate day to day. - Regulatory and reputational exposure for firms that are unprepared when the FCA takes over supervision. #### Actions to take 1. Review current AML risk assessments and evidence trails against what a single, more rigorous regulator is likely to expect. 2. Establish clear reporting lines and escalation routes for AML risk, rather than leaving this to one individual. 3. Ensure senior leaders engage with AML risk regularly, with outcomes recorded and actioned. 4. Put in place systems that can monitor, document and evidence AML controls on an ongoing basis. #### Wider implications Moving AML supervision for accountancy firms to the FCA signals a shift towards higher, more consistently applied standards and stronger enforcement than a fragmented system of professional body supervisors has delivered. Firms that treat this as an opportunity rather than a burden, building genuinely demonstrable compliance now, can turn it into a point of difference with clients and stakeholders concerned about financial crime risk. #### Recommendations Accountancy firms should start building the evidence base a single regulator will expect well before supervision transfers, rather than waiting for the change to take effect. That means structured governance, clear escalation routes, regular senior engagement with AML risk, and systems that can show how controls are tested and monitored in practice. #### Supporting sources - [Anti-money laundering (AML) under FCA: are accountancy firms ready for the new compliance era?](https://tcc.group/blog/2026/01/26/anti-money-laundering-aml-under-fca-are-accountancy-firms-ready-for-the-new-compliance-era/) (2026-01-26) #### Ready for the FCA's tougher AML regime? Talk to us about building and evidencing an AML framework that will stand up to FCA supervision. 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ready for the new compliance era?", "item": "https://tcc.group/insights/regulatory-horizon/anti-money-laundering-aml-under-fca-are-accountancy-firms-ready-for-the-new-compliance-era/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/regulatory-horizon/anti-money-laundering-aml-under-fca-are-accountancy-firms-ready-for-the-new-compliance-era/#webpage", "url": "https://tcc.group/insights/regulatory-horizon/anti-money-laundering-aml-under-fca-are-accountancy-firms-ready-for-the-new-compliance-era/", "name": "Anti-money laundering (AML) under FCA: are accountancy firms ready for the new compliance era?", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-01-26T00:00:00+01:00", "dateModified": "2026-09-02T03:47:32+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/regulatory-horizon/anti-money-laundering-aml-under-fca-are-accountancy-firms-ready-for-the-new-compliance-era/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "NewsArticle", "@id": "https://tcc.group/insights/regulatory-horizon/anti-money-laundering-aml-under-fca-are-accountancy-firms-ready-for-the-new-compliance-era/#article", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/anti-money-laundering-aml-under-fca-are-accountancy-firms-ready-for-the-new-compliance-era/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "Anti-money laundering (AML) under FCA: are accountancy firms ready for the new compliance era?", "datePublished": "2026-01-26T00:00:00+01:00", "dateModified": "2026-09-02T03:47:32+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/regulatory-horizon/anti-money-laundering-aml-under-fca-are-accountancy-firms-ready-for-the-new-compliance-era/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/50e934ff62ad4aaa8cf8dd1c9b428dad/thumbnail-1024-e021a6f224f2572c68f606bcf985daa82f1566a2e5e5313588dd7312a60431cf.jpg", "description": "Understand how the FCA's takeover of AML supervision from professional body supervisors will change compliance expectations for accountancy firms, and what governance, evidence and reporting changes to put in place now.", "inLanguage": "en-GB", "articleBody": "The FCA is set to take over anti-money laundering supervision of accountancy firms from 23 professional body supervisors, ending the era of broad compliance statements. TCC Group's CEO explains what a single regulator will expect to see.\n\nThe FCA is preparing to take over anti-money laundering (AML) and counter-terrorist financing supervision of the legal and accounting sectors from 23 professional body supervisors. Joe Norburn, CEO of TCC Group, described the move as \"transformational\" in comments to AB Accounting, warning that firms will no longer be able to rely on broad statements of compliance.\n\nInstead, he said, firms will need to \"provide clearer evidence for risk assessment, control testing and governance\", moving beyond tick-box exercises towards a culture of demonstrable compliance.\n\nA single regulator taking over from a patchwork of professional body supervisors points to deeper reviews, evidence-based assessments and less tolerance for informal or undocumented AML controls.\n\nPractices will likely need to adopt a more structured approach to governance, with proper reporting, clear escalation routes and senior leaders engaging with AML risk on a regular basis.\n\nAs Norburn puts it, accountability has to sit at the top table: AML can no longer be treated as a side task for one individual to manage in isolation.\n\nAccountancy firms currently supervised by one of the 23 professional body supervisors for AML purposes are directly affected, along with their MLROs and senior leadership teams who will carry greater personal accountability for governance and evidence.\n\n\u2022 Greater scrutiny, with deeper reviews of AML frameworks and a shift towards evidence-based assessment.\n\u2022 Governance gaps, where reporting lines, escalation routes and board-level engagement are informal or undocumented.\n\u2022 Weak data and monitoring, leaving firms unable to demonstrate how AML controls actually operate day to day.\n\u2022 Regulatory and reputational exposure for firms that are unprepared when the FCA takes over supervision.\n\n1. Review current AML risk assessments and evidence trails against what a single, more rigorous regulator is likely to expect.\n2. Establish clear reporting lines and escalation routes for AML risk, rather than leaving this to one individual.\n3. Ensure senior leaders engage with AML risk regularly, with outcomes recorded and actioned.\n4. Put in place systems that can monitor, document and evidence AML controls on an ongoing basis.\n\nMoving AML supervision for accountancy firms to the FCA signals a shift towards higher, more consistently applied standards and stronger enforcement than a fragmented system of professional body supervisors has delivered.\n\nFirms that treat this as an opportunity rather than a burden, building genuinely demonstrable compliance now, can turn it into a point of difference with clients and stakeholders concerned about financial crime risk.\n\nAccountancy firms should start building the evidence base a single regulator will expect well before supervision transfers, rather than waiting for the change to take effect.\n\nThat means structured governance, clear escalation routes, regular senior engagement with AML risk, and systems that can show how controls are tested and monitored in practice.", "wordCount": 490, "keywords": [ "Financial Crime Compliance", "Regulatory Change & Transformation" ], "about": [ { "@type": "Thing", "name": "Financial Crime Compliance", "url": "https://tcc.group/blog/solution/financial-crime-compliance/" }, { "@type": "Thing", "name": "Regulatory Change & Transformation", "url": "https://tcc.group/blog/solution/regulatory-change-transformation/" }, { "@type": "Thing", "name": "AML Supervision Reform" } ], "articleSection": [ "Financial Crime Compliance", "Regulatory Change & Transformation" ], "audience": [ { "@type": "Audience", "audienceType": "MLROs, compliance officers and senior partners at accountancy firms currently supervised by a professional body." } ], "citation": [ { "@type": "CreativeWork", "name": "Anti-money laundering (AML) under FCA: are accountancy firms ready for the new compliance era?", "url": "https://tcc.group/blog/2026/01/26/anti-money-laundering-aml-under-fca-are-accountancy-firms-ready-for-the-new-compliance-era/", "datePublished": "2026-01-26" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/regulatory-horizon/anti-money-laundering-aml-under-fca-are-accountancy-firms-ready-for-the-new-compliance-era/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/anti-money-laundering-aml-under-fca-are-accountancy-firms-ready-for-the-new-compliance-era/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "Why is AML supervision for accountancy firms moving to the FCA?", "acceptedAnswer": { "@type": "Answer", "text": "The FCA is taking over anti-money laundering and counter-terrorist financing supervision of the legal and accounting sectors from 23 professional body supervisors, replacing a fragmented system with a single regulator." } }, { "@type": "Question", "name": "What will accountancy firms need to show under the new regime?", "acceptedAnswer": { "@type": "Answer", "text": "Clearer evidence for risk assessment, control testing and governance, rather than broad statements of compliance, with structured reporting and escalation routes and regular senior engagement with AML risk." } }, { "@type": "Question", "name": "What should firms do to prepare?", "acceptedAnswer": { "@type": "Answer", "text": "Review AML governance and evidence now, put in place clear escalation routes and board-level oversight, and ensure systems can document and demonstrate controls before FCA supervision begins." } } ] } ] } ``` ### Why growth without rigour is the biggest risk in advice consolidation - URL: https://tcc.group/insights/regulatory-horizon/why-growth-without-rigour-is-the-biggest-risk-in-advice-consolidation/ - Published: 2026-01-21 - Modified: 2026-09-02 **Topic:** Advice Consolidation Risk As consolidation in the advice sector matures, TCC argues that due diligence, integration and governance quality, not scale, now determine which consolidators succeed. #### What happened? Consolidation has become the default growth strategy across the advice sector, but the market has matured, regulation has sharpened, and the cost of getting it wrong has risen sharply. Risk rarely sits in the headline numbers; it hides in the detail of how advice is delivered and evidenced, the quality of historic files and the robustness of governance structures. Due diligence has moved from a transactional hurdle to a commercial tool, with buyers asking harder questions, probing deeper, and using the insight gained to shape deal structures, negotiate price or walk away entirely. The FCA’s latest multi-firm review of consolidation in the financial advice and wealth management sector found that financial fragility does not remain confined to the balance sheet; it surfaces in service quality, adviser conduct and long-term sustainability. #### Why does it matter? Poor advice practices, weak oversight or unresolved conduct risks acquired in a deal do not disappear after completion. They sit inside the group, quietly compounding, until they surface as remediation, regulatory attention or reputational damage. Integration, not the deal itself, is where most acquisitions succeed or fail, and it is consistently underestimated. #### Who is affected? Consolidators, the advice and wealth management firms they acquire, their advisers and clients, and the boards and senior management overseeing group-wide governance. #### Key risks - Hidden liabilities and unresolved conduct risks surfacing after completion. - Integration being underestimated, leading to fragmented client experience and adviser strain. - Governance failing to keep pace as groups scale, weakening independent challenge. - Highly leveraged growth putting pressure on systems, resourcing and, ultimately, client outcomes. #### Actions to take 1. Use due diligence as a commercial tool: ask harder questions and use the insight gained to shape deal structure or price. 2. Treat integration as a strategic function: resource it properly, plan it carefully and monitor it closely. 3. Strengthen governance structures, skills and information as the group scales. 4. Stress-test growth models now, rather than explaining problems to the regulator later. #### Wider implications The FCA’s multi-firm review signals that financial fragility in consolidation groups surfaces in service quality and adviser conduct, not just the balance sheet. In a market where everyone is chasing scale, quality and discipline will become the real differentiator between consolidators. #### Recommendations TCC partners with consolidators across acquisition and integration, providing regulatory due diligence against FCA expectations and Consumer Duty standards, post-acquisition integration of culture, governance and controls, and strategic interim resource support to strengthen delivery and oversight as firms scale. #### Supporting sources - [Why growth without rigour is the biggest risk in advice consolidation](https://tcc.group/blog/2026/01/22/why-growth-without-rigour-is-the-biggest-risk-in-advice-consolidation/) (2026-01-22) #### Considering your next acquisition? Talk to us in confidence about regulatory due diligence, integration planning and interim resourcing for your next consolidation deal. [Talk to us](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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"https://tcc.group/insights/regulatory-horizon/why-growth-without-rigour-is-the-biggest-risk-in-advice-consolidation/#article", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/why-growth-without-rigour-is-the-biggest-risk-in-advice-consolidation/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "Why growth without rigour is the biggest risk in advice consolidation", "datePublished": "2026-01-22T00:00:00+01:00", "dateModified": "2026-09-02T03:49:13+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/regulatory-horizon/why-growth-without-rigour-is-the-biggest-risk-in-advice-consolidation/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/fadac066452b41999cb91572f89ef410/thumbnail-1024-b897e6273f925d98b5f80c56d44801439417395f1fbbdc28ceac7c9dcb8f36ad.jpg", "description": "Learn why scale alone no longer impresses in advice consolidation, and how rigorous due diligence, integration planning and governance protect value as the FCA sharpens scrutiny of growing groups.", "inLanguage": "en-GB", "articleBody": "As consolidation in the advice sector matures, TCC argues that due diligence, integration and governance quality, not scale, now determine which consolidators succeed.\n\nConsolidation has become the default growth strategy across the advice sector, but the market has matured, regulation has sharpened, and the cost of getting it wrong has risen sharply. Risk rarely sits in the headline numbers; it hides in the detail of how advice is delivered and evidenced, the quality of historic files and the robustness of governance structures.\n\nDue diligence has moved from a transactional hurdle to a commercial tool, with buyers asking harder questions, probing deeper, and using the insight gained to shape deal structures, negotiate price or walk away entirely.\n\nThe FCA\u2019s latest multi-firm review of consolidation in the financial advice and wealth management sector found that financial fragility does not remain confined to the balance sheet; it surfaces in service quality, adviser conduct and long-term sustainability.\n\nPoor advice practices, weak oversight or unresolved conduct risks acquired in a deal do not disappear after completion. They sit inside the group, quietly compounding, until they surface as remediation, regulatory attention or reputational damage.\n\nIntegration, not the deal itself, is where most acquisitions succeed or fail, and it is consistently underestimated.\n\nConsolidators, the advice and wealth management firms they acquire, their advisers and clients, and the boards and senior management overseeing group-wide governance.\n\n\u2022 Hidden liabilities and unresolved conduct risks surfacing after completion.\n\u2022 Integration being underestimated, leading to fragmented client experience and adviser strain.\n\u2022 Governance failing to keep pace as groups scale, weakening independent challenge.\n\u2022 Highly leveraged growth putting pressure on systems, resourcing and, ultimately, client outcomes.\n\n1. Use due diligence as a commercial tool: ask harder questions and use the insight gained to shape deal structure or price.\n2. Treat integration as a strategic function: resource it properly, plan it carefully and monitor it closely.\n3. Strengthen governance structures, skills and information as the group scales.\n4. Stress-test growth models now, rather than explaining problems to the regulator later.\n\nThe FCA\u2019s multi-firm review signals that financial fragility in consolidation groups surfaces in service quality and adviser conduct, not just the balance sheet. In a market where everyone is chasing scale, quality and discipline will become the real differentiator between consolidators.\n\nTCC partners with consolidators across acquisition and integration, providing regulatory due diligence against FCA expectations and Consumer Duty standards, post-acquisition integration of culture, governance and controls, and strategic interim resource support to strengthen delivery and oversight as firms scale.", "wordCount": 417, "keywords": [ "Compliance AI & RegTech", "Consolidation, Acquisition & Regulatory Due Diligence", "Regulatory Change & Transformation", "Pensions & Retirement Income", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Consolidation, Acquisition & Regulatory Due Diligence", "url": "https://tcc.group/blog/solution/consolidation-acquisition-regulatory-due-diligence/" }, { "@type": "Thing", "name": "Regulatory Change & Transformation", "url": "https://tcc.group/blog/solution/regulatory-change-transformation/" }, { "@type": "Thing", "name": "Pensions & Retirement Income", "url": "https://tcc.group/blog/sector/pensions-retirement-income/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Advice Consolidation Risk" } ], "articleSection": [ "Compliance AI & RegTech", "Consolidation, Acquisition & Regulatory Due Diligence", "Regulatory Change & Transformation" ], "audience": [ { "@type": "Audience", "audienceType": "Pensions & Retirement Income" }, { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Boards, M&A and integration leads at advice and wealth management consolidators and their acquisition targets." } ], "citation": [ { "@type": "CreativeWork", "name": "Why growth without rigour is the biggest risk in advice consolidation", "url": "https://tcc.group/blog/2026/01/22/why-growth-without-rigour-is-the-biggest-risk-in-advice-consolidation/", "datePublished": "2026-01-22" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/regulatory-horizon/why-growth-without-rigour-is-the-biggest-risk-in-advice-consolidation/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/why-growth-without-rigour-is-the-biggest-risk-in-advice-consolidation/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "Why is due diligence now a commercial tool, not just a compliance step?", "acceptedAnswer": { "@type": "Answer", "text": "Because buyers use the insight it provides to shape deal structures, negotiate price, or decide to walk away from firms with unresolved conduct risks." } }, { "@type": "Question", "name": "What did the FCA\u2019s multi-firm review of consolidation find?", "acceptedAnswer": { "@type": "Answer", "text": "That financial fragility does not stay confined to the balance sheet; it surfaces in service quality, adviser conduct and long-term sustainability." } }, { "@type": "Question", "name": "Why does integration matter more than the acquisition itself?", "acceptedAnswer": { "@type": "Answer", "text": "Integration is where most acquisitions succeed or fail, testing systems, processes, people, culture and consistency of client experience." } }, { "@type": "Question", "name": "What should firms do if governance hasn\u2019t kept pace with growth?", "acceptedAnswer": { "@type": "Answer", "text": "Invest in the structures, skills and information needed to support independent challenge and strategic decision-making as the group scales." } } ] } ] } ``` ### Watch on-demand: Sessions with our compliance experts - URL: https://tcc.group/insights/analysis-perspectives/watch-on-demand-sessions-with-our-compliance-experts/ - Published: 2026-01-20 - Modified: 2026-09-02 **Topic:** On-demand compliance sessions TCC has published a library of on-demand sessions in which its experts discuss current regulatory themes, from governance and redress to Consumer Duty and vulnerable customer support. #### What happened? TCC has brought together its recorded expert sessions in a single on-demand library, giving firms an easy way to catch up on topics they may have missed live. Recent additions include sessions on the FCA’s multi-firm review of governance and integration amid rapid consolidation, on how redress has evolved into a strategic tool for wealth managers, and on the ‘show me, don’t tell me’ approach to evidencing Consumer Duty compliance. Earlier sessions cover the FCA’s proposed motor finance redress scheme, adopting AI tools without introducing unnecessary risk, right-first-time suitability reviews, and the practical challenges of supporting vulnerable customers. #### Why does it matter? Regulatory expectations are moving quickly across multiple fronts at once, and it is difficult for compliance teams to attend every live session as it happens. Having these discussions available on demand means firms can return to the detail when it is directly relevant, for example when preparing for a board update or refreshing an implementation plan. Because the sessions span sectors and topics, they also give firms a quick way to see how issues such as governance, redress and vulnerable customer support connect to their own priorities. #### Who is affected? The sessions are aimed at wealth management, pensions, banking, lending, insurance and motor finance firms, and speak most directly to compliance, risk and senior management functions. Firms going through consolidation, preparing for redress schemes, or reviewing suitability and advice processes are likely to find the most immediately relevant content. #### Key risks - Governance and integration gaps emerging from rapid consolidation activity. - Difficulty evidencing Consumer Duty compliance under outcomes-based supervision. - Uneven identification and support of vulnerable customers. - Suitability reviews that default to tick-box compliance rather than genuine assessment. #### Actions to take 1. Filter the on-demand library for sessions most relevant to your firm’s current priorities. 2. Share relevant recordings with the teams responsible for governance, redress or advice quality. 3. Use the session themes as prompts to check your own frameworks against the FCA’s expectations. #### Wider implications The breadth of subjects covered reflects how compliance risk now sits across many parts of a firm at once, from consolidation governance to redress delivery and ongoing advice. Firms that treat these sessions as a standing resource, rather than a one-off watch, are better placed to keep pace as the regulatory picture continues to shift. #### Recommendations Build a short routine for checking the library when new sessions are added, and route the most relevant recordings to the people accountable for that area of the business. Where a session raises a question about your own arrangements, treat it as a trigger for a focused internal review rather than letting the point go untested. #### Supporting sources - [Watch on-demand: Sessions with our compliance experts](https://tcc.group/blog/2026/01/21/watch-on-demand-sessions-with-our-compliance-experts/) (2026-01-21) #### Want expert input on your own priorities? Speak to our team about the regulatory themes most relevant to your firm. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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"https://tcc.group/insights/analysis-perspectives/watch-on-demand-sessions-with-our-compliance-experts/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/analysis-perspectives/watch-on-demand-sessions-with-our-compliance-experts/#webpage", "url": "https://tcc.group/insights/analysis-perspectives/watch-on-demand-sessions-with-our-compliance-experts/", "name": "Watch on-demand: Sessions with our compliance experts", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-01-21T00:00:00+01:00", "dateModified": "2026-09-02T03:49:10+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/analysis-perspectives/watch-on-demand-sessions-with-our-compliance-experts/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "AnalysisNewsArticle", "@id": "https://tcc.group/insights/analysis-perspectives/watch-on-demand-sessions-with-our-compliance-experts/#article", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/watch-on-demand-sessions-with-our-compliance-experts/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "Watch on-demand: Sessions with our compliance experts", "datePublished": "2026-01-21T00:00:00+01:00", "dateModified": "2026-09-02T03:49:10+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/analysis-perspectives/watch-on-demand-sessions-with-our-compliance-experts/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/6d9b9e251ffb480692cba1778a670617/thumbnail-1024-55b73cbe2145c3f3803847ecf4f54ab58887932c9262c227b45aa133ddc876cc.jpg", "description": "Browse TCC's on-demand session library covering governance, redress, Consumer Duty, vulnerable customers and suitability, and use these expert recaps to benchmark your firm's practices without waiting for a live webinar slot.", "inLanguage": "en-GB", "articleBody": "TCC has published a library of on-demand sessions in which its experts discuss current regulatory themes, from governance and redress to Consumer Duty and vulnerable customer support.\n\nTCC has brought together its recorded expert sessions in a single on-demand library, giving firms an easy way to catch up on topics they may have missed live.\n\nRecent additions include sessions on the FCA\u2019s multi-firm review of governance and integration amid rapid consolidation, on how redress has evolved into a strategic tool for wealth managers, and on the \u2018show me, don\u2019t tell me\u2019 approach to evidencing Consumer Duty compliance.\n\nEarlier sessions cover the FCA\u2019s proposed motor finance redress scheme, adopting AI tools without introducing unnecessary risk, right-first-time suitability reviews, and the practical challenges of supporting vulnerable customers.\n\nRegulatory expectations are moving quickly across multiple fronts at once, and it is difficult for compliance teams to attend every live session as it happens.\n\nHaving these discussions available on demand means firms can return to the detail when it is directly relevant, for example when preparing for a board update or refreshing an implementation plan.\n\nBecause the sessions span sectors and topics, they also give firms a quick way to see how issues such as governance, redress and vulnerable customer support connect to their own priorities.\n\nThe sessions are aimed at wealth management, pensions, banking, lending, insurance and motor finance firms, and speak most directly to compliance, risk and senior management functions.\n\nFirms going through consolidation, preparing for redress schemes, or reviewing suitability and advice processes are likely to find the most immediately relevant content.\n\n\u2022 Governance and integration gaps emerging 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Filter the on-demand library for sessions most relevant to your firm\u2019s current priorities.\n2. Share relevant recordings with the teams responsible for governance, redress or advice quality.\n3. Use the session themes as prompts to check your own frameworks against the FCA\u2019s expectations.\n\nThe breadth of subjects covered reflects how compliance risk now sits across many parts of a firm at once, from consolidation governance to redress delivery and ongoing advice.\n\nFirms that treat these sessions as a standing resource, rather than a one-off watch, are better placed to keep pace as the regulatory picture continues to shift.\n\nBuild a short routine for checking the library when new sessions are added, and route the most relevant recordings to the people accountable for that area of the business.\n\nWhere a session raises a question about your own arrangements, treat it as a trigger for a focused internal review rather than letting the point go untested.", "wordCount": 455, "keywords": [ "Compliance AI & RegTech", "Consumer Duty", "Regulatory Change & Transformation", "Banking", "General Insurance & Protection", "Lending & Consumer Credit", "Motor Finance", "Payments & FinTech", "Pensions & Retirement Income", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Consumer Duty", "url": "https://tcc.group/blog/solution/consumer-duty/" }, { "@type": "Thing", "name": "Regulatory Change & Transformation", "url": "https://tcc.group/blog/solution/regulatory-change-transformation/" }, { "@type": "Thing", "name": "Banking", "url": "https://tcc.group/blog/sector/banking/" }, { "@type": "Thing", "name": "General Insurance & Protection", "url": "https://tcc.group/blog/sector/general-insurance-protection/" }, { "@type": "Thing", "name": "Lending & Consumer Credit", "url": "https://tcc.group/blog/sector/lending-consumer-credit/" }, { "@type": "Thing", "name": "Motor Finance", "url": "https://tcc.group/blog/sector/motor-finance/" }, { "@type": "Thing", "name": "Payments & FinTech", "url": "https://tcc.group/blog/sector/payments-fintech/" }, { "@type": "Thing", "name": "Pensions & Retirement Income", "url": "https://tcc.group/blog/sector/pensions-retirement-income/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "On-demand compliance sessions" } ], "articleSection": [ "Compliance AI & RegTech", "Consumer Duty", "Regulatory Change & Transformation" ], "audience": [ { "@type": "Audience", "audienceType": "Banking" }, { "@type": "Audience", "audienceType": "General Insurance & Protection" }, { "@type": "Audience", "audienceType": "Lending & Consumer Credit" }, { "@type": "Audience", "audienceType": "Motor Finance" }, { "@type": "Audience", "audienceType": "Payments & FinTech" }, { "@type": "Audience", "audienceType": "Pensions & Retirement Income" }, { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Compliance, risk and senior management teams in wealth management, pensions, banking, lending, insurance and motor finance firms." } ], "citation": [ { "@type": "CreativeWork", "name": "Watch on-demand: Sessions with our compliance experts", "url": "https://tcc.group/blog/2026/01/21/watch-on-demand-sessions-with-our-compliance-experts/", "datePublished": "2026-01-21" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/analysis-perspectives/watch-on-demand-sessions-with-our-compliance-experts/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/watch-on-demand-sessions-with-our-compliance-experts/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What topics does the on-demand library cover?", "acceptedAnswer": { "@type": "Answer", "text": "The sessions span consolidation and governance, redress, Consumer Duty, vulnerable customers, suitability reviews and the FCA's motor finance and ongoing advice work." } }, { "@type": "Question", "name": "Who should watch these sessions?", "acceptedAnswer": { "@type": "Answer", "text": "They are designed for compliance, risk and senior management teams across wealth management, pensions, banking, lending, insurance and motor finance firms." } }, { "@type": "Question", "name": "How often is the library updated?", "acceptedAnswer": { "@type": "Answer", "text": "New sessions are added as TCC's experts cover emerging regulatory developments, with recordings dated from March 2025 through to January 2026." } }, { "@type": "Question", "name": "Can I revisit a session after watching it live?", "acceptedAnswer": { "@type": "Answer", "text": "Yes, each session remains available on demand so you can return to the detail whenever it becomes relevant." } } ] } ] } ``` ### FCA's Value for Money Framework Gathers Pace - URL: https://tcc.group/insights/regulatory-horizon/fcas-value-for-money-framework-for-defined-contribution-pensions-gathers-pace/ - Published: 2026-01-20 - Modified: 2026-09-02 **Topic:** Value for Money Consultation Paper CP26/1 outlines plans for a standardized Value for Money framework for DC pension schemes, introducing standardized metrics and RAGG ratings. #### What happened? The Financial Conduct Authority has published Consultation Paper CP26/1, representing the next phase of the proposed Value for Money (VFM) Framework for defined contribution (DC) pensions. Developed in partnership with the Department for Work and Pensions (DWP) and The Pensions Regulator (TPR), the consultation responses are due by 8th March 2026. CP26/1 proposes a standardized approach to assessing value, shifting the regulatory focus away from narrow, short-term cost-cutting and towards a holistic, long-term assessment of value generation, investment performance, and service quality. #### Why does it matter? This framework introduces a significant change in retirement outcomes oversight. Pension schemes will receive public, standardized RAGG (Red, Amber, Green, Dark Green) ratings. Where schemes are rated amber or red, providers must take swift corrective action or ultimately transfer members into better-performing arrangements. For DC savers, who carry all investment risk themselves, small variances in long-term performance have a massive impact. This framework aligns directly with Consumer Duty, aiming to protect vulnerable or disengaged consumers who feel unprepared for retirement. #### Who is affected? This framework directly impacts Independent Governance Committees (IGCs), pension scheme trustees, asset managers, and providers of contract-based and trust-based DC schemes. #### Key risks - **Public Red/Amber RAGG Ratings:** Underperforming schemes facing reputational damage and the risk of being forced to transfer members. - **Accountability Pressures:** Increased liability for trustees and IGCs as they are forced to exercise complex qualitative judgements on value. - **Regulatory Non-Compliance:** Failing to establish comparable, standardised metrics across service quality and investment performance ahead of the legislative deadlines. #### Actions to take 1. **Engage with CP26/1:** Review and respond to the consultation proposals before the 8th March 2026 deadline, participating in industry roundtables. 2. **Audit Current Performance:** Assess existing DC scheme charges, service standards, and long-term investment performance against the proposed standardised metrics. 3. **Embed Consumer Duty:** Integrate Consumer Duty outcomes and vulnerable customer metrics into existing pension governance frameworks. 4. **Establish Governance Paths:** Equip trustees and IGCs with the robust data infrastructure required to execute and document complex value judgements. #### Wider implications The framework marks a decisive legislative shift. While contract-based schemes are directly affected under final rules, trust-based schemes will be aligned through the Pensions Schemes Bill currently progressing through Parliament. #### Recommendations Providers should act now to build robust, auditable frameworks for monitoring customer outcomes. Seeking independent regulatory assurance will ensure schemes are positioned to secure dark green ratings and maintain trust. #### Supporting sources - [FCA's Value for Money framework gathers pace](https://tcc.group/blog/2026/01/21/fcas-value-for-money-framework-for-defined-contribution-pensions-gathers-pace/) (2026-01-21) #### Is your pension scheme prepared for the VFM regime? Decode the value for money proposals and build a robust, auditable framework for monitoring outcomes with our pension specialists. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/insights/regulatory-horizon/fcas-value-for-money-framework-for-defined-contribution-pensions-gathers-pace/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Insights", "item": "https://tcc.group/insights/" }, { "@type": "ListItem", "position": 3, "name": "FCA’s Value for Money Framework Gathers Pace", "item": "https://tcc.group/insights/regulatory-horizon/fcas-value-for-money-framework-for-defined-contribution-pensions-gathers-pace/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/regulatory-horizon/fcas-value-for-money-framework-for-defined-contribution-pensions-gathers-pace/#webpage", "url": "https://tcc.group/insights/regulatory-horizon/fcas-value-for-money-framework-for-defined-contribution-pensions-gathers-pace/", "name": "FCA’s Value for Money Framework Gathers Pace", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2026-01-21T00:00:00+01:00", "dateModified": "2026-09-02T03:47:45+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/regulatory-horizon/fcas-value-for-money-framework-for-defined-contribution-pensions-gathers-pace/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "NewsArticle", "@id": "https://tcc.group/insights/regulatory-horizon/fcas-value-for-money-framework-for-defined-contribution-pensions-gathers-pace/#article", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/fcas-value-for-money-framework-for-defined-contribution-pensions-gathers-pace/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "FCA’s Value for Money Framework Gathers Pace", "datePublished": "2026-01-21T00:00:00+01:00", "dateModified": "2026-09-02T03:47:45+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/regulatory-horizon/fcas-value-for-money-framework-for-defined-contribution-pensions-gathers-pace/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/38f1b138e22f456d9b3235a3465ef19f/thumbnail-1024-cd2d595bafd52561c60a81e0d90263a498a1bf5c24c1a96df4ede10149d3ab37.jpg", "description": "The next phase of the FCA's Value for Money (VFM) framework consultation is underway. We analyze the shift towards holistic, long-term value in DC pensions and how trust-based schemes face increased transparency expectations.", "inLanguage": "en-GB", "articleBody": "Consultation Paper CP26/1 outlines plans for a standardized Value for Money framework for DC pension schemes, introducing standardized metrics and RAGG ratings.\n\nThe Financial Conduct Authority has published Consultation Paper CP26/1, representing the next phase of the proposed Value for Money (VFM) Framework for defined contribution (DC) pensions. Developed in partnership with the Department for Work and Pensions (DWP) and The Pensions Regulator (TPR), the consultation responses are due by 8th March 2026.\n\nCP26/1 proposes a standardized approach to assessing value, shifting the regulatory focus away from narrow, short-term cost-cutting and towards a holistic, long-term assessment of value generation, investment performance, and service quality.\n\nThis framework introduces a significant change in retirement outcomes oversight. Pension schemes will receive public, standardized RAGG (Red, Amber, Green, Dark Green) ratings. Where schemes are rated amber or red, providers must take swift corrective action or ultimately transfer members into better-performing arrangements.\n\nFor DC savers, who carry all investment risk themselves, small variances in long-term performance have a massive impact. This framework aligns directly with Consumer Duty, aiming to protect vulnerable or disengaged consumers who feel unprepared for retirement.\n\nThis framework directly impacts Independent Governance Committees (IGCs), pension scheme trustees, asset managers, and providers of contract-based and trust-based DC schemes.\n\n\u2022 Public Red/Amber RAGG Ratings: Underperforming schemes facing reputational damage and the risk of being forced to transfer members.\n\u2022 Accountability Pressures: Increased liability for trustees and IGCs as they are forced to exercise complex qualitative judgements on value.\n\u2022 Regulatory Non-Compliance: Failing to establish comparable, standardised metrics across service quality and investment performance ahead of the legislative deadlines.\n\n1. Engage with CP26/1: Review and respond to the consultation proposals before the 8th March 2026 deadline, participating in industry roundtables.\n2. Audit Current Performance: Assess existing DC scheme charges, service standards, and long-term investment performance against the proposed standardised metrics.\n3. Embed Consumer Duty: Integrate Consumer Duty outcomes and vulnerable customer metrics into existing pension governance frameworks.\n4. Establish Governance Paths: Equip trustees and IGCs with the robust data infrastructure required to execute and document complex value judgements.\n\nThe framework marks a decisive legislative shift. While contract-based schemes are directly affected under final rules, trust-based schemes will be aligned through the Pensions Schemes Bill currently progressing through Parliament.\n\nProviders should act now to build robust, auditable frameworks for monitoring customer outcomes. 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If performance cannot be raised, providers will be expected to transfer savers to better schemes." } }, { "@type": "Question", "name": "Are any pension arrangements exempt from the VFM framework?", "acceptedAnswer": { "@type": "Answer", "text": "Based on current consultation parameters, specialized arrangements like Executive Pension Plans (EPPs) and Small Self-Administered Schemes (SSAS) are expected to sit outside the scope." } } ] } ] } ``` ### Rethinking ongoing advice to deliver client value - URL: https://tcc.group/insights/analysis-perspectives/rethinking-ongoing-advice/ - Published: 2026-01-12 - Modified: 2026-09-02 **Topic:** 2026 Evidence Readiness TCC Group CEO Joe Norburn sets out, in an article featured by IT Supply Chain, why firms need always-on, data-led evidencing of ongoing advice delivery to meet the FCA's rising expectations in 2026. #### What happened? As the FCA raises the bar on how compliance must be demonstrated, Joe Norburn, CEO of TCC Group (TCC, Momenta and Recordsure), sets out what firms need to do to be ready for 2026. His view, featured by IT Supply Chain, is that firms need to move beyond good intentions towards always-on, data-led evidencing. He points to increasingly focused regulatory data requests, tougher evidential thresholds and far less tolerance for gaps in audit trails or reliance on manual, sample-based reviews. #### Why does it matter? Firms still operating periodic assessments or relying mainly on human-led controls are likely to struggle as scrutiny intensifies. The message is that documentation created after the fact, or evidence covering only a sample of clients, will increasingly fall short of what the regulator expects. #### Who is affected? Firms delivering an ongoing advice service, particularly those relying on periodic or sample-based reviews rather than continuous evidence of client outcomes. #### Key risks - Reliance on periodic assessments that cannot keep pace with increasingly focused regulatory data requests. - Gaps in audit trails that leave firms unable to evidence individual client outcomes. - Sample-based reviews that do not provide full-population visibility of ongoing advice delivery. #### Actions to take 1. Assess whether current evidence of ongoing advice delivery is generated continuously, or only produced periodically or on request. 2. Identify where audit trails have gaps and consider how these can be closed as part of everyday processes. 3. Consider how AI-driven analysis alongside human judgement could provide full-population visibility rather than relying on sampling. #### Wider implications The direction set out here reflects a wider pattern across ongoing advice servicing: the FCA's expectations are moving from firms being able to describe a process to firms being able to prove, for each client, that it worked. #### Recommendations Firms should begin building evidence readiness into everyday processes now, rather than treating it as a periodic exercise, combining automated analysis with human judgement to produce defensible audit trails and clear proof of positive customer outcomes. #### Supporting sources - [Rethinking ongoing advice to deliver client value](https://tcc.group/blog/2026/01/13/rethinking-ongoing-advice/) (2026-01-13) #### Ready for 2026's evidence expectations? Get in touch to discuss how we can help you build always-on, data-led evidencing into your ongoing advice service. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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"author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "Rethinking ongoing advice to deliver client value", "datePublished": "2026-01-13T00:00:00+01:00", "dateModified": "2026-09-02T03:48:02+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/analysis-perspectives/rethinking-ongoing-advice/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/b16558e3e365403588d79fdf7f78283d/thumbnail-1024-5b77a3694ec4993508e02e9cfa7e2550263017d7920d0513df3d2449274ec959.jpg", "description": "TCC Group CEO Joe Norburn explains why firms need always-on, data-led evidencing of ongoing advice delivery to meet the FCA's rising expectations in 2026, rather than relying on periodic, sample-based reviews.", "inLanguage": "en-GB", "articleBody": "TCC Group CEO Joe Norburn sets out, in an article featured by IT Supply Chain, why firms need always-on, data-led evidencing of ongoing advice delivery to meet the FCA's rising expectations in 2026.\n\nAs the FCA raises the bar on how compliance must be demonstrated, Joe Norburn, CEO of TCC Group (TCC, Momenta and Recordsure), sets out what firms need to do to be ready for 2026. His view, featured by IT Supply Chain, is that firms need to move beyond good intentions towards always-on, data-led evidencing.\n\nHe points to increasingly focused regulatory data requests, tougher evidential thresholds and far less tolerance for gaps in audit trails or reliance on manual, sample-based reviews.\n\nFirms still operating periodic assessments or relying mainly on human-led controls are likely to struggle as scrutiny intensifies. The message is that documentation created after the fact, or evidence covering only a sample of clients, will increasingly fall short of what the regulator expects.\n\nFirms delivering an ongoing advice service, particularly those relying on periodic or sample-based reviews rather than continuous evidence of client outcomes.\n\n\u2022 Reliance on periodic assessments that cannot keep pace with increasingly focused regulatory data requests.\n\u2022 Gaps in audit trails that leave firms unable to evidence individual client outcomes.\n\u2022 Sample-based reviews that do not provide full-population visibility of ongoing advice delivery.\n\n1. Assess whether current evidence of ongoing advice delivery is generated continuously, or only produced periodically or on request.\n2. Identify where audit trails have gaps and consider how these can be closed as part of everyday processes.\n3. 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delivery continuously, as part of everyday processes, rather than periodically or only when requested." } }, { "@type": "Question", "name": "Why are sample-based reviews a risk?", "acceptedAnswer": { "@type": "Answer", "text": "Because they do not give firms full-population visibility of ongoing advice delivery, which the FCA increasingly expects firms to demonstrate." } }, { "@type": "Question", "name": "Who set out this view?", "acceptedAnswer": { "@type": "Answer", "text": "Joe Norburn, CEO of TCC Group, in an article featured by IT Supply Chain." } } ] } ] } ``` ### Proving compliance in 2026: A data-led world - URL: https://tcc.group/insights/analysis-perspectives/it-supply-chain-2026-predictions-evidencing-compliance-in-a-data-led-regulatory-world/ - Published: 2026-01-06 - Modified: 2026-09-02 ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium 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must adapt their compliance models in 2026 to meet targeted regulatory evidence demands. #### What happened? In an article published in IFA Magazine, TCC Group CEO Joe Norburn explains that advice firms must adapt their compliance processes in 2026. As the FCA transitions from initial guidance to assertive enforcement, it will demand objective proof of Consumer Duty compliance. Despite political rhetoric suggesting a reduction in regulatory red tape, firms must prepare for targeted evidence requests, deeper thematic reviews, and zero tolerance for unsubstantiated compliance claims. #### Why does it matter? Evidence readiness will become a defining capability in 2026. Firms can no longer rely on manual file sampling or subjective, untested assumptions. Instead, they must deploy robust, systematic oversight to demonstrate customer comprehension, fair value, and compliant outcomes across their entire business. #### Supporting sources - [Advice firms need to adapt compliance requirements in 2026 - TCC](https://tcc.group/blog/2026/01/05/ifa-will-advice-firms-need-to-adapt-compliance-requirements-in-2026-practical-insights-from-tcc-group/) (2026-01-05) #### Is your firm evidence-ready for 2026? Speak to our senior consultants to audit your compliance models, streamline your file reviews, and establish robust evidence of compliant customer outcomes. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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"https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/5d15175dc1194585bae55567ee991aa3/thumbnail-1024-d11e500326199fae48f4eec5db6d13ff2447e37c326bfc9157699abb0b8e74f3.jpg", "description": "Understand why financial advice firms must adapt their compliance strategies in 2026 to prepare for targeted FCA evidence requests and stricter standards of outcome proof.", "inLanguage": "en-GB", "articleBody": "TCC Group CEO Joe Norburn outlines in IFA Magazine how advice firms must adapt their compliance models in 2026 to meet targeted regulatory evidence demands.\n\nIn an article published in IFA Magazine, TCC Group CEO Joe Norburn explains that advice firms must adapt their compliance processes in 2026. As the FCA transitions from initial guidance to assertive enforcement, it will demand objective proof of Consumer Duty compliance.\n\nDespite political rhetoric suggesting a reduction in regulatory red tape, firms must prepare for targeted evidence requests, deeper thematic reviews, and zero tolerance for unsubstantiated compliance claims.\n\nEvidence readiness will become a defining capability in 2026. Firms can no longer rely on manual file sampling or subjective, untested assumptions. Instead, they must deploy robust, systematic oversight to demonstrate customer comprehension, fair value, and compliant outcomes across their entire business.", "wordCount": 136, "keywords": [ "Regulatory Change & Transformation", "Banking", "General Insurance & Protection", "Lending & Consumer Credit", "Motor Finance", "Payments & FinTech", "Pensions & Retirement Income", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Regulatory Change & Transformation", "url": "https://tcc.group/blog/solution/regulatory-change-transformation/" }, { "@type": "Thing", "name": "Banking", "url": "https://tcc.group/blog/sector/banking/" }, { "@type": "Thing", "name": "General Insurance & Protection", "url": "https://tcc.group/blog/sector/general-insurance-protection/" }, { "@type": "Thing", "name": "Lending & Consumer Credit", "url": "https://tcc.group/blog/sector/lending-consumer-credit/" }, { "@type": "Thing", "name": "Motor Finance", "url": "https://tcc.group/blog/sector/motor-finance/" }, { "@type": "Thing", "name": "Payments & FinTech", "url": "https://tcc.group/blog/sector/payments-fintech/" }, { "@type": "Thing", "name": "Pensions & Retirement Income", "url": "https://tcc.group/blog/sector/pensions-retirement-income/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Compliance Adaptation 2026" } ], "articleSection": [ "Regulatory Change & Transformation" ], "audience": [ { "@type": "Audience", "audienceType": "Banking" }, { "@type": "Audience", "audienceType": "General Insurance & Protection" }, { "@type": "Audience", "audienceType": "Lending & Consumer Credit" }, { "@type": "Audience", "audienceType": "Motor Finance" }, { "@type": "Audience", "audienceType": "Payments & FinTech" }, { "@type": "Audience", "audienceType": "Pensions & Retirement Income" }, { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Wealth management directors, compliance managers, and advisers preparing for 2026 regulatory shifts." } ], "citation": [ { "@type": "CreativeWork", "name": "Advice firms need to adapt compliance requirements in 2026 - TCC", "url": "https://tcc.group/blog/2026/01/05/ifa-will-advice-firms-need-to-adapt-compliance-requirements-in-2026-practical-insights-from-tcc-group/", "datePublished": "2026-01-05" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/analysis-perspectives/ifa-will-advice-firms-need-to-adapt-compliance-requirements-in-2026-practical-insights-from-tcc-group/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/ifa-will-advice-firms-need-to-adapt-compliance-requirements-in-2026-practical-insights-from-tcc-group/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "Why will compliance expectations increase in 2026?", "acceptedAnswer": { "@type": "Answer", "text": "The FCA is shifting from explaining rules to actively demanding proof, meaning firms will face targeted evidence requests and less tolerance for unverified assumptions about consumer outcomes." } }, { "@type": "Question", "name": "What is 'evidence readiness' under the Consumer Duty?", "acceptedAnswer": { "@type": "Answer", "text": "Evidence readiness is the capability of a firm to quickly and systematically provide clear, data-backed proof of positive client outcomes and customer comprehension when requested by the regulator." } } ] } ] } ``` ### Top ten regulatory priorities for financial services firms in 2026 - URL: https://tcc.group/insights/regulatory-horizon/2026-regulatory-priorities/ - Published: 2025-12-17 - Modified: 2026-09-02 **Topic:** 2026 regulatory priorities TCC identifies ten regulatory priorities for 2026 under the FCA's 2025-2030 strategy, spanning Consumer Duty embedding, technology and AI oversight, motor finance redress and the new targeted support regime. #### What happened? The FCA's five-year strategy, published in March 2025, is built around four aims: becoming a smarter and more efficient regulator, supporting growth and innovation, helping customers navigate their financial lives, and combating financial crime. Firms that seek to do the right thing can expect streamlined reporting, simplified authorisation and fewer data requests, with 36,000 firms already benefiting from lighter reporting obligations. TCC groups its top ten priorities for 2026 into four themes: current themes, emerging opportunities, ongoing issues and areas to watch. The current themes include embedding and monitoring the Consumer Duty, technology, data and AI innovation, and the motor finance redress scheme, while targeted support is highlighted as an emerging opportunity. On the Consumer Duty, the FCA's multi-firm reviews are expected to focus on outcome monitoring, product design, customer journey mapping and the treatment of vulnerable customers, including a market-wide review of model portfolio services. On technology, firms are expected to ensure AI and data-driven tools are explainable, unbiased and properly overseen as the FCA itself becomes more data-led. #### Why does it matter? Reduced formal enforcement activity does not mean reduced scrutiny: the FCA is placing greater reliance on information requests as a supervisory tool and expects firms to evidence how they deliver good outcomes, fight financial crime and demonstrate effective governance, even as reporting burdens ease. On motor finance, the FCA has paused handling certain complaints while the legal position on historical discretionary commission arrangements is clarified, but has made clear that operational readiness, data integrity and governance will be critical once an industry-wide redress scheme is introduced. On targeted support, firms will be able to apply for permissions from March 2026 ahead of the regime's planned start on 6 April 2026, subject to legislation. #### Who is affected? These priorities affect firms across wealth management, pensions, banking, lending, payments, insurance and motor finance, particularly those with consumer credit or motor finance books, product providers considering targeted support, and any firm embedding AI or data-driven tools into customer-facing processes. #### Key risks - Consumer Duty: inconsistent monitoring of outcomes, fragmented product governance and poor identification of vulnerable customers. - Technology and AI: data governance gaps and insufficiently explainable or overseen AI and data-driven tools. - Motor finance redress: fragmented historical data, inconsistent documentation of commission arrangements and weak governance ahead of a redress scheme. - Targeted support: firms new to the regime risk being unprepared for the permissions process opening from March 2026. #### Actions to take 1. Embed Consumer Duty principles into governance, culture and business model to create an auditable framework for monitoring outcomes. 2. Review AI and data-driven tools for explainability, bias and vendor oversight ahead of increased FCA scrutiny. 3. Retain and organise historical motor finance records and prepare complaints-handling capacity for a potential redress scheme. 4. Consider whether to apply for FCA permissions to deliver targeted support ahead of the regime's planned start in April 2026. #### Wider implications The FCA's own account of its priorities extends beyond the four themes covered here to further areas the regulator is watching, including simplification of insurance rules, governance and non-financial misconduct, financial crime and market integrity, data privacy and cyber risk, ESG compliance and ongoing advice services. Together, the ten priorities point to a regulator that is easing some reporting burdens while sharpening its focus on evidenced outcomes. Firms that treat 2026 planning as an opportunity to strengthen governance and evidencing, rather than simply reduce reporting effort, are likely to be better placed as supervisory data requests increase. #### Recommendations TCC and Recordsure combine advisory expertise with technology to help firms embed governance and operational frameworks for safe innovation, while Recordsure's AI captures and analyses client interactions at scale to help monitor outcomes and evidence compliance. On motor finance specifically, TCC Group works alongside its Momenta brand to help clients prepare, validate and execute redress plans efficiently and at pace. #### Supporting sources - [Top ten regulatory priorities for financial services firms in 2026](https://tcc.group/blog/2025/12/18/2026-regulatory-priorities/) (2025-12-18) #### Planning your 2026 regulatory priorities? Talk to our team about embedding Consumer Duty outcomes, AI governance and motor finance readiness ahead of 2026. [Speak to our team](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory 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"author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "Top ten regulatory priorities for financial services firms in 2026", "datePublished": "2025-12-18T00:00:00+01:00", "dateModified": "2026-09-02T03:47:29+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/regulatory-horizon/2026-regulatory-priorities/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/c1cb6c1f6284407ead4668fae7c1c000/thumbnail-1024-fd400bcb92ba5408df76608a4ed37d3be5bb65a659fdbd951bd70fe503705b3e.jpg", "description": "TCC sets out ten regulatory priorities for 2026 under the FCA's five-year strategy, covering Consumer Duty embedding, AI governance, motor finance redress and targeted support, so firms know where to focus first.", "inLanguage": "en-GB", "articleBody": "TCC identifies ten regulatory priorities for 2026 under the FCA's 2025-2030 strategy, spanning Consumer Duty embedding, technology and AI oversight, motor finance redress and the new targeted support regime.\n\nThe FCA's five-year strategy, published in March 2025, is built around four aims: becoming a smarter and more efficient regulator, supporting growth and innovation, helping customers navigate their financial lives, and combating financial crime. Firms that seek to do the right thing can expect streamlined reporting, simplified authorisation and fewer data requests, with 36,000 firms already benefiting from lighter reporting obligations.\n\nTCC groups its top ten priorities for 2026 into four themes: current themes, emerging opportunities, ongoing issues and areas to watch. The current themes include embedding and monitoring the Consumer Duty, technology, data and AI innovation, and the motor finance redress scheme, while targeted support is highlighted as an emerging opportunity.\n\nOn the Consumer Duty, the FCA's multi-firm reviews are expected to focus on outcome monitoring, product design, customer journey mapping and the treatment of vulnerable customers, including a market-wide review of model portfolio services. On technology, firms are expected to ensure AI and data-driven tools are explainable, unbiased and properly overseen as the FCA itself becomes more data-led.\n\nReduced formal enforcement activity does not mean reduced scrutiny: the FCA is placing greater reliance on information requests as a supervisory tool and expects firms to evidence how they deliver good outcomes, fight financial crime and demonstrate effective governance, even as reporting burdens ease.\n\nOn motor finance, the FCA has paused handling certain complaints while the legal position on historical discretionary commission arrangements is clarified, but has made clear that operational readiness, data integrity and governance will be critical once an industry-wide redress scheme is introduced. On targeted support, firms will be able to apply for permissions from March 2026 ahead of the regime's planned start on 6 April 2026, subject to legislation.\n\nThese priorities affect firms across wealth management, pensions, banking, lending, payments, insurance and motor finance, particularly those with consumer credit or motor finance books, product providers considering targeted support, and any firm embedding AI or data-driven tools into customer-facing processes.\n\n\u2022 Consumer Duty: inconsistent monitoring of outcomes, fragmented product governance and poor identification of vulnerable customers.\n\u2022 Technology and AI: data governance gaps and insufficiently explainable or overseen AI and data-driven tools.\n\u2022 Motor finance redress: fragmented historical data, inconsistent documentation of commission arrangements and weak governance ahead of a redress scheme.\n\u2022 Targeted support: firms new to the regime risk being unprepared for the permissions process opening from March 2026.\n\n1. Embed Consumer Duty principles into governance, culture and business model to create an auditable framework for monitoring outcomes.\n2. Review AI and data-driven tools for explainability, bias and vendor oversight ahead of increased FCA scrutiny.\n3. Retain and organise historical motor finance records and prepare complaints-handling capacity for a potential redress scheme.\n4. Consider whether to apply for FCA permissions to deliver targeted support ahead of the regime's planned start in April 2026.\n\nThe FCA's own account of its priorities extends beyond the four themes covered here to further areas the regulator is watching, including simplification of insurance rules, governance and non-financial misconduct, financial crime and market integrity, data privacy and cyber risk, ESG compliance and ongoing advice services. Together, the ten priorities point to a regulator that is easing some reporting burdens while sharpening its focus on evidenced outcomes.\n\nFirms that treat 2026 planning as an opportunity to strengthen governance and evidencing, rather than simply reduce reporting effort, are likely to be better placed as supervisory data requests increase.\n\nTCC and Recordsure combine advisory expertise with technology to help firms embed governance and operational frameworks for safe innovation, while Recordsure's AI captures and analyses client interactions at scale to help monitor outcomes and evidence compliance.\n\nOn motor finance specifically, TCC Group works alongside its Momenta brand to help clients prepare, validate and execute redress plans efficiently and at pace.", "wordCount": 654, "keywords": [ "Compliance AI & RegTech", "Financial Crime Compliance", "Banking", "General Insurance & Protection", "Lending & Consumer Credit", "Motor Finance", "Payments & FinTech", "Pensions & Retirement Income", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Financial Crime Compliance", "url": "https://tcc.group/blog/solution/financial-crime-compliance/" }, { "@type": "Thing", "name": "Banking", "url": "https://tcc.group/blog/sector/banking/" }, { "@type": "Thing", "name": "General Insurance & Protection", "url": "https://tcc.group/blog/sector/general-insurance-protection/" }, { "@type": "Thing", "name": "Lending & Consumer Credit", "url": "https://tcc.group/blog/sector/lending-consumer-credit/" }, { "@type": "Thing", "name": "Motor Finance", "url": "https://tcc.group/blog/sector/motor-finance/" }, { "@type": "Thing", "name": "Payments & FinTech", "url": "https://tcc.group/blog/sector/payments-fintech/" }, { "@type": "Thing", "name": "Pensions & Retirement Income", "url": "https://tcc.group/blog/sector/pensions-retirement-income/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "2026 regulatory priorities" } ], "articleSection": [ "Compliance AI & RegTech", "Financial Crime Compliance" ], "audience": [ { "@type": "Audience", "audienceType": "Banking" }, { "@type": "Audience", "audienceType": "General Insurance & Protection" }, { "@type": "Audience", "audienceType": "Lending & Consumer Credit" }, { "@type": "Audience", "audienceType": "Motor Finance" }, { "@type": "Audience", "audienceType": "Payments & FinTech" }, { "@type": "Audience", "audienceType": "Pensions & Retirement Income" }, { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Compliance, risk and senior management teams planning their regulatory priorities for 2026." } ], "citation": [ { "@type": "CreativeWork", "name": "Top ten regulatory priorities for financial services firms in 2026", "url": "https://tcc.group/blog/2025/12/18/2026-regulatory-priorities/", "datePublished": "2025-12-18" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/regulatory-horizon/2026-regulatory-priorities/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/2026-regulatory-priorities/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What are the FCA's four strategic aims for 2025-2030?", "acceptedAnswer": { "@type": "Answer", "text": "Becoming a smarter, more efficient regulator; supporting growth and innovation; helping customers navigate their financial lives; and combating financial crime." } }, { "@type": "Question", "name": "How many regulatory priorities does TCC identify for 2026?", "acceptedAnswer": { "@type": "Answer", "text": "Ten, grouped under current themes, emerging opportunities, ongoing issues and areas to watch." } }, { "@type": "Question", "name": "When does the new targeted support regime take effect?", "acceptedAnswer": { "@type": "Answer", "text": "Firms can apply for permissions from March 2026, ahead of a planned start on 6 April 2026, subject to legislation." } }, { "@type": "Question", "name": "Why has the FCA paused some motor finance complaints?", "acceptedAnswer": { "@type": "Answer", "text": "To clarify the regulatory and legal position on historical discretionary commission arrangements before an industry-wide redress scheme is introduced." } } ] } ] } ``` ### 2026 Predictions: Evidencing Compliance in a Data-Led Regulatory World - URL: https://tcc.group/insights/analysis-perspectives/fraud-prevention-summit-2026-predictions-evidencing-compliance-in-a-data-led-regulatory-world/ - Published: 2025-12-16 - Modified: 2026-09-02 **Topic:** Data-Led Compliance TCC Group CEO Joe Norburn outlines why firms must prepare for targeted data requests and less regulatory tolerance by embedding continuous 'evidence readiness' into daily operations. #### What happened? In an article featured by Forum Events & Media Group, TCC Group CEO Joe Norburn shares predictions on how the compliance landscape will evolve. The Financial Conduct Authority is steadily sharpening its expectations, demanding a shift from intent-led compliance to a state of continuous, data-driven 'evidence readiness.' Regulated firms must prepare for highly targeted, granular data requests, rigorous standards of proof, and minimal tolerance for incomplete audit trails or basic, manual, sample-led monitoring approaches. #### Why does it matter? Traditional periodic reviews and retrospective sampling are no longer sufficient to satisfy modern supervisory demands. To succeed, firms must embed robust evidence generation directly into their day-to-day operations. Deploying predictive AI in combination with human expertise enables firms to generate population-level oversight, secure unalterable audit trails, and demonstrate positive customer outcomes consistently and at scale. #### Who is affected? This media feature directly impacts compliance managers, executive directors, and operations leads across all FCA-regulated financial institutions. #### Supporting sources - [2026 predictions evidencing compliance](https://tcc.group/blog/2026/03/24/fraud-prevention-summit-2026-predictions-evidencing-compliance-in-a-data-led-regulatory-world/) (2026-03-24) #### Is your business prepared for data-driven evidence demands? Transition from manual sampling to continuous evidence readiness with our tailored regulatory advisory and advanced RegTech solutions. 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"https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/3bb4f04a81ae4ec2ae26f97edd277f94/thumbnail-1024-0212867ed253299c241c5754868a30dbe557a1bf683b2d7736e54a45d7871e08.jpg", "description": "In Forum Events & Media, TCC Group CEO Joe Norburn shares essential predictions for 2026 compliance. Discover why firms must transition from intent-led compliance to data-driven evidence readiness.", "inLanguage": "en-GB", "articleBody": "TCC Group CEO Joe Norburn outlines why firms must prepare for targeted data requests and less regulatory tolerance by embedding continuous 'evidence readiness' into daily operations.\n\nIn an article featured by Forum Events & Media Group, TCC Group CEO Joe Norburn shares predictions on how the compliance landscape will evolve. The Financial Conduct Authority is steadily sharpening its expectations, demanding a shift from intent-led compliance to a state of continuous, data-driven 'evidence readiness.'\n\nRegulated firms must prepare for highly targeted, granular data requests, rigorous standards of proof, and minimal tolerance for incomplete audit trails or basic, manual, sample-led monitoring approaches.\n\nTraditional periodic reviews and retrospective sampling are no longer sufficient to satisfy modern supervisory demands. To succeed, firms must embed robust evidence generation directly into their day-to-day operations.\n\nDeploying predictive AI in combination with human expertise enables firms to generate population-level oversight, secure unalterable audit trails, and demonstrate positive customer outcomes consistently and at scale.\n\nThis media feature directly impacts compliance managers, executive directors, and operations leads across all FCA-regulated financial institutions.", "wordCount": 172, "keywords": [ "Compliance AI & RegTech", "Banking", "General Insurance & Protection", "Lending & Consumer Credit", "Motor Finance", "Payments & FinTech", "Pensions & Retirement Income", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Banking", "url": "https://tcc.group/blog/sector/banking/" }, { "@type": "Thing", "name": "General Insurance & Protection", "url": "https://tcc.group/blog/sector/general-insurance-protection/" }, { "@type": "Thing", "name": "Lending & Consumer Credit", "url": "https://tcc.group/blog/sector/lending-consumer-credit/" }, { "@type": "Thing", "name": "Motor Finance", "url": "https://tcc.group/blog/sector/motor-finance/" }, { "@type": "Thing", "name": "Payments & FinTech", "url": "https://tcc.group/blog/sector/payments-fintech/" }, { "@type": "Thing", "name": "Pensions & Retirement Income", "url": "https://tcc.group/blog/sector/pensions-retirement-income/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Data-Led Compliance" } ], "articleSection": [ "Compliance AI & RegTech" ], "audience": [ { "@type": "Audience", "audienceType": "Banking" }, { "@type": "Audience", "audienceType": "General Insurance & Protection" }, { "@type": "Audience", "audienceType": "Lending & Consumer Credit" }, { "@type": "Audience", "audienceType": "Motor Finance" }, { "@type": "Audience", "audienceType": "Payments & FinTech" }, { "@type": "Audience", "audienceType": "Pensions & Retirement Income" }, { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Compliance directors, operations leaders, and wealth managers planning for 2026 audits." } ], "citation": [ { "@type": "CreativeWork", "name": "2026 predictions evidencing compliance", "url": "https://tcc.group/blog/2026/03/24/fraud-prevention-summit-2026-predictions-evidencing-compliance-in-a-data-led-regulatory-world/", "datePublished": "2026-03-24" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/analysis-perspectives/fraud-prevention-summit-2026-predictions-evidencing-compliance-in-a-data-led-regulatory-world/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/fraud-prevention-summit-2026-predictions-evidencing-compliance-in-a-data-led-regulatory-world/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What does 'evidence readiness' mean for firms in 2026?", "acceptedAnswer": { "@type": "Answer", "text": "It means maintaining a continuous state of operational readiness to supply granular, data-backed proof of positive customer outcomes, rather than treating compliance as a periodic exercise." } }, { "@type": "Question", "name": "Why are manual, sample-led approaches becoming obsolete?", "acceptedAnswer": { "@type": "Answer", "text": "Manual sampling creates blind spots and fails to satisfy rising regulatory standards of proof, which require complete, population-level assurance and unalterable audit trails." } } ] } ] } ``` ### From Principles to Proof: Data-Led Compliance Evidencing in 2026 - URL: https://tcc.group/insights/regulatory-horizon/from-principles-to-proof-data-led-compliance-evidencing-in-2026/ - Published: 2025-12-15 - Modified: 2026-09-02 **Topic:** Compliance Evidencing TCC Group's CEO Joe Norburn outlines why 'evidence readiness' must become a continuous operational state in 2026, driven by granular regulatory scrutiny and predictive RegTech. #### What happened? TCC Group CEO Joe Norburn outlines strategic predictions for compliance in 2026, marking a decisive shift from interpreting the FCA's Consumer Duty to proving its execution in practice. Despite ongoing political conversations regarding 'reducing burdens' to stimulate economic growth, the practical supervisory reality is moving in the opposite direction. The FCA is operating an outcome-focused supervision model built on data. Firms face highly targeted evidence requests, granular audit trail reviews, and zero tolerance for well-meaning intentions without concrete, accessible proof. #### Why does it matter? Firms that treat compliance evidencing as a periodic, quarterly task will find themselves on the backfoot. Traditional manual-first compliance models that rely on low-volume file sampling are no longer sufficient to satisfy data-led audits. A weak evidence chain, missing audit trails, or unrecorded client conversations turn good business practices into significant regulatory risks. Furthermore, while 82% of firms feel confident they treat vulnerable customers appropriately, many lack the comprehensive, retrievable data needed to prove it. Moving to population-level oversight is the only reliable way to validate customer comprehension and prevent systemic detriment. #### Who is affected? This analysis is highly critical for compliance leaders, board directors, and operations managers at wealth advisors, insurers, banks, and payment providers. #### Key risks - **Unproven Customer Comprehension:** Relying on policy templates rather than active, documented testing to prove customers understand products and fees. - **Fragmented Audit Trails:** Unrecorded customer conversations or missing documentation that prevents the timely supply of evidence under S165 requests. - **Dated Manual Sampling:** Continuing to rely on low-volume manual file reviews which fail to detect unevenly distributed operational risk. #### Actions to take 1. **Establish Continuous Readiness:** Integrate evidence-readiness protocols directly into daily operations, ensuring all customer-facing files and logs are easily retrievable. 2. **Upgrade Customer Testing:** Implement post-interaction client surveys and structured comprehension tests to actively validate consumer support. 3. **Automate Conversation Logging:** Move away from selective call recording to ensure 100% of customer interactions are logged and auditable. 4. **Deploy Predictive AI:** Integrate predictive AI systems to analyze full conversation populations, triaging high-risk files for expert human review. #### Wider implications By late 2026, manual compliance models will be viewed as obsolete. Technology, specifically predictive AI with humans firmly in the loop, is transitioning from an innovative choice to critical compliance infrastructure. #### Recommendations Firms should audit their existing data quality and conversation recording capabilities, mapping out a clear roadmap to deploy automated evidence frameworks. #### Supporting sources - [From principles to proof: Data-led compliance evidencing in 2026](https://tcc.group/blog/2026/02/12/from-principles-to-proof-data-led-compliance-evidencing-in-2026/) (2026-02-12) #### Is your compliance team ready for data-led supervision? Transition from passive, manual sampling to continuous, AI-powered evidence readiness with our expert advisory and RegTech solutions. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/insights/regulatory-horizon/from-principles-to-proof-data-led-compliance-evidencing-in-2026/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Insights", "item": "https://tcc.group/insights/" }, { "@type": "ListItem", "position": 3, "name": "From Principles to Proof: Data-Led Compliance Evidencing in 2026", "item": "https://tcc.group/insights/regulatory-horizon/from-principles-to-proof-data-led-compliance-evidencing-in-2026/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/regulatory-horizon/from-principles-to-proof-data-led-compliance-evidencing-in-2026/#webpage", "url": "https://tcc.group/insights/regulatory-horizon/from-principles-to-proof-data-led-compliance-evidencing-in-2026/", "name": "From Principles to Proof: Data-Led Compliance Evidencing in 2026", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2025-12-16T00:00:00+01:00", "dateModified": "2026-09-02T03:47:48+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/regulatory-horizon/from-principles-to-proof-data-led-compliance-evidencing-in-2026/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "NewsArticle", "@id": "https://tcc.group/insights/regulatory-horizon/from-principles-to-proof-data-led-compliance-evidencing-in-2026/#article", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/from-principles-to-proof-data-led-compliance-evidencing-in-2026/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "From Principles to Proof: Data-Led Compliance Evidencing in 2026", "datePublished": "2025-12-16T00:00:00+01:00", "dateModified": "2026-09-02T03:47:48+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/regulatory-horizon/from-principles-to-proof-data-led-compliance-evidencing-in-2026/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/815671ad66f94811a3d3333292fe50b4/thumbnail-1600-af6818c01c5a56731ce573b424add15f83fa66be0be0fdb79493b15fa6c08af3.jpg", "description": "In 2026, the regulatory focus shifts from interpreting principles to demonstrating proof. Explore Joe Norburn's predictions on evidence readiness, predictive AI, and the inevitable decline of manual compliance sampling.", "inLanguage": "en-GB", "articleBody": "TCC Group's CEO Joe Norburn outlines why 'evidence readiness' must become a continuous operational state in 2026, driven by granular regulatory scrutiny and predictive RegTech.\n\nTCC Group CEO Joe Norburn outlines strategic predictions for compliance in 2026, marking a decisive shift from interpreting the FCA's Consumer Duty to proving its execution in practice. Despite ongoing political conversations regarding 'reducing burdens' to stimulate economic growth, the practical supervisory reality is moving in the opposite direction.\n\nThe FCA is operating an outcome-focused supervision model built on data. Firms face highly targeted evidence requests, granular audit trail reviews, and zero tolerance for well-meaning intentions without concrete, accessible proof.\n\nFirms that treat compliance evidencing as a periodic, quarterly task will find themselves on the backfoot. Traditional manual-first compliance models that rely on low-volume file sampling are no longer sufficient to satisfy data-led audits. A weak evidence chain, missing audit trails, or unrecorded client conversations turn good business practices into significant regulatory risks.\n\nFurthermore, while 82% of firms feel confident they treat vulnerable customers appropriately, many lack the comprehensive, retrievable data needed to prove it. Moving to population-level oversight is the only reliable way to validate customer comprehension and prevent systemic detriment.\n\nThis analysis is highly critical for compliance leaders, board directors, and operations managers at wealth advisors, insurers, banks, and payment providers.\n\n\u2022 Unproven Customer Comprehension: Relying on policy templates rather than active, documented testing to prove customers understand products and fees.\n\u2022 Fragmented Audit Trails: Unrecorded customer conversations or missing documentation that prevents the timely supply of evidence under S165 requests.\n\u2022 Dated Manual Sampling: Continuing to rely on low-volume manual file reviews which fail to detect unevenly distributed operational risk.\n\n1. Establish Continuous Readiness: Integrate evidence-readiness protocols directly into daily operations, ensuring all customer-facing files and logs are easily retrievable.\n2. Upgrade Customer Testing: Implement post-interaction client surveys and structured comprehension tests to actively validate consumer support.\n3. Automate Conversation Logging: Move away from selective call recording to ensure 100% of customer interactions are logged and auditable.\n4. Deploy Predictive AI: Integrate predictive AI systems to analyze full conversation populations, triaging high-risk files for expert human review.\n\nBy late 2026, manual compliance models will be viewed as obsolete. Technology, specifically predictive AI with humans firmly in the loop, is transitioning from an innovative choice to critical compliance infrastructure.\n\nFirms should audit their existing data quality and conversation recording capabilities, mapping out a clear roadmap to deploy automated evidence frameworks.", "wordCount": 407, "keywords": [ "Compliance AI & RegTech", "Banking", "General Insurance & Protection", "Lending & Consumer Credit", "Motor Finance", "Payments & FinTech", "Pensions & Retirement Income", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Banking", "url": "https://tcc.group/blog/sector/banking/" }, { "@type": "Thing", "name": "General Insurance & Protection", "url": "https://tcc.group/blog/sector/general-insurance-protection/" }, { "@type": "Thing", "name": "Lending & Consumer Credit", "url": 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"https://tcc.group/blog/sector/pensions-retirement-income/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" } ], "articleSection": [ "Compliance AI & RegTech" ], "audience": [ { "@type": "Audience", "audienceType": "Banking" }, { "@type": "Audience", "audienceType": "General Insurance & Protection" }, { "@type": "Audience", "audienceType": "Lending & Consumer Credit" }, { "@type": "Audience", "audienceType": "Motor Finance" }, { "@type": "Audience", "audienceType": "Payments & FinTech" }, { "@type": "Audience", "audienceType": "Pensions & Retirement Income" }, { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" } ] } ] } ``` ### Always Finance News: Leveraging predictive AI to drive value from financial compliance - URL: https://tcc.group/insights/analysis-perspectives/always-finance-news-leveraging-predictive-ai-to-drive-value-from-financial-compliance/ - Published: 2025-12-11 - Modified: 2026-09-02 **Topic:** Predictive AI and compliance value Following the FCA's renewed emphasis on Consumer Duty, TCC Group's CEO Joe Norburn examines how combining predictive AI with generative AI can help firms close compliance gaps and evidence fair customer outcomes. #### What happened? As featured in Always Finance News, TCC Group's CEO Joe Norburn examined how firms can meet the FCA's renewed emphasis on Consumer Duty by combining predictive AI with generative AI to close compliance gaps and deliver evidential customer outcomes. #### Why does it matter? By deploying AI that supports compliance teams rather than working against them, firms can meet regulatory expectations, safeguard their reputation, and build a foundation for incremental business value. #### Who is affected? The analysis is relevant to compliance teams in banking, wealth management and financial advice, and payments and fintech firms working to evidence Consumer Duty outcomes. #### Supporting sources - [Always Finance News: Leveraging predictive AI to drive value from financial compliance](https://tcc.group/blog/2025/12/12/always-finance-news-leveraging-predictive-ai-to-drive-value-from-financial-compliance/) (2025-12-12) #### Curious about predictive AI for compliance? Get in touch to discuss how predictive and generative AI can support your Consumer Duty compliance. 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Preparing for the FCA targeted support regime - URL: https://tcc.group/insights/analysis-perspectives/targeted-support/ - Published: 2025-12-11 - Modified: 2026-09-02 **Topic:** FCA Targeted Support Regime The FCA has published its policy statement for a new targeted support regime for pensions and retail investments, and firms will need permission to offer it once the regime takes effect. #### What happened? Following a joint review with the government on the boundary between financial advice and guidance, and two consultation papers, the FCA has published its policy statement for the new targeted support regime. The framework is designed to provide tailored support for pension and retail investment customers, and the regulator cites figures suggesting around 7 million UK adults with cash savings of £10,000 or more may be missing out on investment opportunities. The FCA has published near-final rules, and firms will be able to apply for permission to provide targeted support from March 2026, ahead of the regime's expected implementation on 6 April 2026, subject to legislation. Some firms have already engaged with the FCA's new Pre-application support service. #### Why does it matter? Targeted support will be a distinct regulated activity, meaning firms must obtain permission before offering it once the authorisation gateway opens. This marks a departure from the traditional divide between generic guidance and personalised advice, allowing firms to offer ready-made suggestions to customer segments without a full individual assessment. #### Who is affected? Firms operating in pensions and retail investments that want to offer targeted support, and the compliance, product and governance functions that will need to design and monitor it. #### Key risks - Offering targeted support without the required permission once the authorisation gateway opens in April. - Customer segments that are too broad to justify the support given, or so narrow that they cross into individualised advice. - Weak monitoring and governance arrangements that cannot demonstrate the support is delivering the intended benefit. - Customer communications that do not meet FCA and ICO expectations on marketing and data protection. #### Actions to take 1. Assess whether the firm needs to apply for permission to offer targeted support from March 2026. 2. Define customer segments that are granular enough to justify the support without becoming individualised advice. 3. Review product governance against the FCA's PROD rules for the segments to be served. 4. Check customer communications against the joint FCA/ICO guidance on marketing and data protection. #### Wider implications The underlying principles of the Consumer Duty continue to apply, so firms must be able to show that targeted support genuinely helps consumers pursue their financial objectives and avoid foreseeable harm, rather than treating it as a lighter-touch alternative to advice. #### Recommendations TCC recommends that firms invest early in governance, data foundations and customer-centric design so they can evidence good outcomes and maintain a clear boundary between targeted support and regulated advice ahead of the April 2026 deadline. #### Supporting sources - [Preparing for the FCA targeted support regime](https://tcc.group/blog/2025/12/12/targeted-support/) (2025-12-12) #### Getting ready for targeted support in 2026? Talk to TCC about preparing your firm's strategy, governance and communications for the FCA's targeted support regime. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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FCA has published its policy statement for the new targeted support regime. The framework is designed to provide tailored support for pension and retail investment customers, and the regulator cites figures suggesting around 7 million UK adults with cash savings of \u00a310,000 or more may be missing out on investment opportunities.\n\nThe FCA has published near-final rules, and firms will be able to apply for permission to provide targeted support from March 2026, ahead of the regime's expected implementation on 6 April 2026, subject to legislation. Some firms have already engaged with the FCA's new Pre-application support service.\n\nTargeted support will be a distinct regulated activity, meaning firms must obtain permission before offering it once the authorisation gateway opens. 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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 1. Review historic ongoing advice delivery, not only cases that have generated complaints. 2. Assess obligations under the Consumer Duty and DISP to identify and put right foreseeable harm. 3. 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 - [Always Finance News: Why reviewing the past must be a strategic focus for financial advice firms](https://tcc.group/blog/2025/12/10/always-finance-news-why-reviewing-the-past-must-be-a-strategic-focus-for-financial-advice-firms/) (2025-12-10) #### Reviewing historic advice delivery? Get in touch to discuss how we help firms review historic advice and remediate foreseeable harm. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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"https://tcc.group/insights/analysis-perspectives/always-finance-news-why-reviewing-the-past-must-be-a-strategic-focus-for-financial-advice-firms/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "AnalysisNewsArticle", "@id": "https://tcc.group/insights/analysis-perspectives/always-finance-news-why-reviewing-the-past-must-be-a-strategic-focus-for-financial-advice-firms/#article", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/always-finance-news-why-reviewing-the-past-must-be-a-strategic-focus-for-financial-advice-firms/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "Always Finance News: Why reviewing the past must be a strategic focus for financial advice firms", "datePublished": "2025-12-10T00:00:00+01:00", "dateModified": "2026-09-02T03:47:32+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/analysis-perspectives/always-finance-news-why-reviewing-the-past-must-be-a-strategic-focus-for-financial-advice-firms/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/fe42b88847304568b69f0d1075535adf/thumbnail-1024-378b6cd880591e5bdbc4e99cfda338a53cd35bc64650bfa6c8bd1f9394eac428.jpg", "description": "TCC Group's Jason Wintie explains why the FCA's softer tone on ongoing advice reviews doesn't lessen firms' obligations to identify and remedy historic harm, even for advice given as far back as 2018.", "inLanguage": "en-GB", "articleBody": "TCC Group's Strategic Regulatory Director, Jason Wintie, examines the FCA's latest feedback on ongoing advice and what it means for firms' obligations to review historic advice delivery.\n\nAs 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.\n\nThe 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.\n\nThat 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.\n\nThe 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.\n\n\u2022 Mistaking the FCA's softer tone for reduced obligations\n\u2022 Failing to identify foreseeable harm beyond client complaints\n\u2022 Overlooking advice delivered as far back as 2018\n\n1. Review historic ongoing advice delivery, not only cases that have generated complaints.\n2. Assess obligations under the Consumer Duty and DISP to identify and put right foreseeable harm.\n3. Extend the review period back to 2018 where advice of this type was delivered.\n\nFirms should treat the FCA's feedback as confirmation that historic advice review remains a live obligation, not a closed chapter.", "wordCount": 239, "keywords": [ "Compliance AI & RegTech", "Consumer Duty", "Redress & Remediation", "Suitability, Advice Quality & File Reviews", "Pensions & Retirement Income", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Consumer Duty", "url": "https://tcc.group/blog/solution/consumer-duty/" }, { "@type": "Thing", "name": "Redress & Remediation", "url": "https://tcc.group/blog/solution/redress-and-remediation/" }, { "@type": "Thing", "name": "Suitability, Advice Quality & File Reviews", "url": "https://tcc.group/blog/solution/outsourced-suitability-reviews/" }, { "@type": "Thing", "name": "Pensions & Retirement Income", "url": "https://tcc.group/blog/sector/pensions-retirement-income/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Historic advice remediation" } ], "articleSection": [ "Compliance AI & RegTech", "Consumer Duty", "Redress & Remediation", "Suitability, Advice Quality & File Reviews" ], "audience": [ { "@type": "Audience", "audienceType": "Pensions & Retirement Income" }, { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Compliance and advice leaders responsible for identifying and remediating historic harm in financial advice firms." } ], "citation": [ { "@type": "CreativeWork", "name": "Always Finance News: Why reviewing the past must be a strategic focus for financial advice firms", "url": "https://tcc.group/blog/2025/12/10/always-finance-news-why-reviewing-the-past-must-be-a-strategic-focus-for-financial-advice-firms/", "datePublished": "2025-12-10" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/analysis-perspectives/always-finance-news-why-reviewing-the-past-must-be-a-strategic-focus-for-financial-advice-firms/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/always-finance-news-why-reviewing-the-past-must-be-a-strategic-focus-for-financial-advice-firms/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "Does the FCA's softer tone mean lower expectations for firms?", "acceptedAnswer": { "@type": "Answer", "text": "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." } }, { "@type": "Question", "name": "How far back can this obligation extend?", "acceptedAnswer": { "@type": "Answer", "text": "The obligation can extend to advice delivered as far back as 2018." } }, { "@type": "Question", "name": "Is this obligation limited to responding to complaints?", "acceptedAnswer": { "@type": "Answer", "text": "No. Firms must identify and remedy foreseeable harm wherever it may have occurred, not only in response to complaints." } } ] } ] } ``` ### Preparing for the motor finance redress scheme is critical - URL: https://tcc.group/insights/analysis-perspectives/fca-preparing-for-the-motor-finance-redress-scheme-is-critical/ - Published: 2025-12-09 - Modified: 2026-09-02 **Topic:** FLA Convention Insights TCC's CCO Garry Evans reports from the FLA Annual Motor Finance Convention, warning lenders that waiting for final FCA guidelines before preparing for redress is a critical mistake. #### What happened? At the recent Finance & Leasing Association (FLA) Annual Motor Finance Convention, the forthcoming FCA-led redress scheme was the defining topic, consuming 40% of the event's agenda. Key speakers represented HM Treasury, automotive lenders, legal advisors, consumer groups, and compliance consultancies. While some providers hoped the FCA might delay or scale back the scheme, the regulator promptly dispelled this, reiterating that the scheme must be delivered swiftly with very little scope for deferrals. #### Why does it matter? Waiting for the FCA's final rules before preparing is a high-risk approach that will leave firms under-resourced and unable to comply. HM Treasury is aiming for a simple scheme, but legal advisors warn that scope remains broad and costly. Compliance experts stress that firms must act now to collate necessary customer records and documentation. Furthermore, an acute resourcing crunch is imminent. Once the scheme is launched, everyone will compete for the same compliance, analytical, and complaints-handling resources, driving up prices and causing severe operational delays. #### Who is affected? Motor finance providers, banking lenders, car dealership networks, and compliance directors across the automotive credit sector are affected. #### Key risks Firms delaying their operational prep face serious compliance and commercial risks: - Severe resourcing shortages and escalating costs for specialist complaints personnel once the scheme launches. - Incomplete historical data files causing delays, calculation errors, and negative customer outcomes. - Regulatory sanctions for failing to demonstrate swift, organized progress to the FCA. #### Actions to take Lenders must execute immediate preparatory actions to protect their operations: 1. Begin extracting and organising all historical customer files, finance contracts, and commission logs in scope. 2. Secure experienced external partner resources and complaints handling capacity ahead of the industry-wide rush. 3. Invest in scalable technology to automate redress processing and maintain data security. #### Wider implications The regulator's refusal to delay the scheme shows a zero-tolerance policy for administrative hesitation. The motor finance industry is facing a structural remediation surge, and success depends on proactive data readiness and resourcing strategies. #### Recommendations We recommend securing strategic partnerships with tech-enabled compliance advisors and managed service providers to lock in resourcing and build robust calculation workflows early. #### Supporting sources - [Preparing for the motor finance redress scheme is critical](https://tcc.group/blog/2025/12/10/preparing-for-the-motor-finance-redress-scheme-is-critical/) (2025-12-10) #### Are you waiting for the final FCA rules? Don't. Secure your compliance and complaints-handling resources today before the industry-wide resourcing crunch begins. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/insights/analysis-perspectives/fca-preparing-for-the-motor-finance-redress-scheme-is-critical/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Insights", "item": "https://tcc.group/insights/" }, { "@type": "ListItem", "position": 3, "name": "Preparing for the motor finance redress scheme is critical", "item": "https://tcc.group/insights/analysis-perspectives/fca-preparing-for-the-motor-finance-redress-scheme-is-critical/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/analysis-perspectives/fca-preparing-for-the-motor-finance-redress-scheme-is-critical/#webpage", "url": "https://tcc.group/insights/analysis-perspectives/fca-preparing-for-the-motor-finance-redress-scheme-is-critical/", "name": "Preparing for the motor finance redress scheme is critical", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2025-12-10T00:00:00+01:00", "dateModified": "2026-09-02T03:47:44+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/analysis-perspectives/fca-preparing-for-the-motor-finance-redress-scheme-is-critical/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "AnalysisNewsArticle", "@id": "https://tcc.group/insights/analysis-perspectives/fca-preparing-for-the-motor-finance-redress-scheme-is-critical/#article", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/fca-preparing-for-the-motor-finance-redress-scheme-is-critical/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "Preparing for the motor finance redress scheme is critical", "datePublished": "2025-12-10T00:00:00+01:00", "dateModified": "2026-09-02T03:47:44+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/analysis-perspectives/fca-preparing-for-the-motor-finance-redress-scheme-is-critical/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/36f5628752b443cbbf9ed191d3c224bd/thumbnail-1024-aa0b2da4bfc6403f10a143785629e1aad72b7ad542f0328675d8c2951abf6ef1.jpg", "description": "Waiting for the FCA's final motor finance redress scheme rules is a high-risk strategy. TCC's Chief Commercial Officer Garry Evans explores the key themes from the FLA Convention and why lenders must act now.", "inLanguage": "en-GB", "articleBody": "TCC's CCO Garry Evans reports from the FLA Annual Motor Finance Convention, warning lenders that waiting for final FCA guidelines before preparing for redress is a critical mistake.\n\nAt the recent Finance & Leasing Association (FLA) Annual Motor Finance Convention, the forthcoming FCA-led redress scheme was the defining topic, consuming 40% of the event's agenda. Key speakers represented HM Treasury, automotive lenders, legal advisors, consumer groups, and compliance consultancies.\n\nWhile some providers hoped the FCA might delay or scale back the scheme, the regulator promptly dispelled this, reiterating that the scheme must be delivered swiftly with very little scope for deferrals.\n\nWaiting for the FCA's final rules before preparing is a high-risk approach that will leave firms under-resourced and unable to comply. HM Treasury is aiming for a simple scheme, but legal advisors warn that scope remains broad and costly. Compliance experts stress that firms must act now to collate necessary customer records and documentation.\n\nFurthermore, an acute resourcing crunch is imminent. Once the scheme is launched, everyone will compete for the same compliance, analytical, and complaints-handling resources, driving up prices and causing severe operational delays.\n\nMotor finance providers, banking lenders, car dealership networks, and compliance directors across the automotive credit sector are affected.\n\nFirms delaying their operational prep face serious compliance and commercial risks:\n\n\u2022 Severe resourcing shortages and escalating costs for specialist complaints personnel once the scheme launches.\n\u2022 Incomplete historical data files causing delays, calculation errors, and negative customer outcomes.\n\u2022 Regulatory sanctions for failing to demonstrate swift, organized progress to the FCA.\n\nLenders must execute immediate preparatory actions to protect their operations:\n\n1. Begin extracting and organising all historical customer files, finance contracts, and commission logs in scope.\n2. Secure experienced external partner resources and complaints handling capacity ahead of the industry-wide rush.\n3. Invest in scalable technology to automate redress processing and maintain data security.\n\nThe regulator's refusal to delay the scheme shows a zero-tolerance policy for administrative hesitation. The motor finance industry is facing a structural remediation surge, and success depends on proactive data readiness and resourcing strategies.\n\nWe recommend securing strategic partnerships with tech-enabled compliance advisors and managed service providers to lock in resourcing and build robust calculation workflows early.", "wordCount": 367, "keywords": [ "Compliance AI & RegTech", "Suitability, Advice Quality & File Reviews", "Lending & Consumer Credit", "Motor Finance" ], "about": [ { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Suitability, Advice Quality & File Reviews", "url": "https://tcc.group/blog/solution/outsourced-suitability-reviews/" }, { "@type": "Thing", "name": "Lending & Consumer Credit", "url": "https://tcc.group/blog/sector/lending-consumer-credit/" }, { "@type": "Thing", "name": "Motor Finance", "url": "https://tcc.group/blog/sector/motor-finance/" }, { "@type": "Thing", "name": "FLA Convention Insights" } ], "articleSection": [ "Compliance AI & RegTech", "Suitability, Advice Quality & File Reviews" ], "audience": [ { "@type": "Audience", "audienceType": "Lending & Consumer Credit" }, { "@type": "Audience", "audienceType": "Motor Finance" }, { "@type": "Audience", "audienceType": "CEOs, risk directors, operations managers, and boards at motor finance lenders and automotive dealer groups." } ], "citation": [ { "@type": "CreativeWork", "name": "Preparing for the motor finance redress scheme is critical", "url": "https://tcc.group/blog/2025/12/10/preparing-for-the-motor-finance-redress-scheme-is-critical/", "datePublished": "2025-12-10" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/analysis-perspectives/fca-preparing-for-the-motor-finance-redress-scheme-is-critical/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/fca-preparing-for-the-motor-finance-redress-scheme-is-critical/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "Why is it risky to wait for final FCA motor finance guidance?", "acceptedAnswer": { "@type": "Answer", "text": "Firms that wait will face incomplete customer data logs and an acute shortage of compliance and complaints-handling resources, driving up costs and causing severe compliance delays." } }, { "@type": "Question", "name": "What should motor finance providers do immediately?", "acceptedAnswer": { "@type": "Answer", "text": "Providers must collocate all customer files, clean historical commission data, and secure specialized complaints resourcing and technology partners." } } ] } ] } ``` ### Attivo enhances advice compliance with TCC's AI solution - URL: https://tcc.group/insights/analysis-perspectives/attivo-enhances-advice-compliance-with-tcc-ai-solution/ - Published: 2025-12-02 - Modified: 2026-09-02 **Topic:** Scaling AI-Led Compliance Attivo's Chief Risk Officer describes how a phased rollout of Recordsure AI, backed by TCC's compliance expertise, cut file-checking costs by 40% within a year while increasing planner capacity and advice oversight. #### What happened? Attivo has partnered with TCC and Recordsure to roll out AI technology across its advice business, aiming to strengthen ongoing-advice compliance while reducing the cost of file reviews as the firm grows. Ian Plumton, Attivo's Chief Risk Officer, said the firm had explored AI options that lacked credibility or scalability before being introduced to Recordsure AI, backed by TCC's compliance expertise. With nearly 250 staff, cultural adoption was a real challenge, but clear communication and early evidence of reduced administrative work built support. Early pilots achieved accuracy in the high 90% range, and within a year Attivo cut file-checking costs by 40%, with no unsuitable cases identified and ongoing improvements in advice quality. #### Why does it matter? What began as a cost and compliance project grew into a wider operational one: high-accuracy voice capture and transcription gave Attivo a reliable foundation for automation, delivering meeting summaries and transcripts within 24 hours and reducing handover issues. Attivo is now on track to review 100% of planning meetings by early 2026, and continued rollout is delivering around 30% more planner capacity through accurate meeting capture and integration with intelliflo. #### Who is affected? Larger, multi-planner advice firms seeking to scale ongoing-advice review coverage without a proportionate increase in compliance headcount, and their compliance, risk and operations teams. #### Key risks - Choosing an AI provider without genuine scalability or compliance credibility can stall adoption. - Treating AI purely as a cost-cutting exercise risks missing its wider value for oversight and capacity. - Weak staff communication and buy-in can undermine rollout across a large planner base. #### Actions to take 1. Choose a partner that combines AI technology with demonstrable compliance expertise and governance. 2. Build a clear business case with defined, measurable use cases before rollout. 3. Communicate early wins, such as reduced administrative work, to build planner trust. 4. Track both compliance metrics and commercial outcomes, such as planner capacity and turnaround time. #### Wider implications Attivo's experience suggests that AI-led review, once mature, can extend beyond risk management into commercial performance: improved capacity, faster handovers and stronger evidence for Consumer Duty all followed from the same technology investment. Ian Plumton noted that choosing a partner with aligned commercial incentives was critical, so that both sides were working towards the same long-term goals rather than a narrower technology sale. #### Recommendations Firms planning a similar rollout should prioritise governance and a phased, human-centred approach over speed, building trust with planners through clear communication and visible early benefits. Success should be measured against both compliance outcomes, such as suitability and review coverage, and commercial outcomes, such as planner capacity and turnaround time. #### Supporting sources - [Attivo enhances advice compliance with TCC's AI solution](https://tcc.group/blog/2025/12/03/attivo-enhances-advice-compliance-with-tcc-ai-solution/) (2025-12-03) #### Considering AI for your advice compliance? Talk to our team about building a sound business case for AI-led compliance, backed by the governance that gives your planners and your board confidence. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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"https://tcc.group/insights/analysis-perspectives/attivo-enhances-advice-compliance-with-tcc-ai-solution/#article", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/attivo-enhances-advice-compliance-with-tcc-ai-solution/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "Attivo enhances advice compliance with TCC’s AI solution", "datePublished": "2025-12-03T00:00:00+01:00", "dateModified": "2026-09-02T03:47:33+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/analysis-perspectives/attivo-enhances-advice-compliance-with-tcc-ai-solution/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/b5500cb404eb40bd8b34b16b068f1154/thumbnail-1024-399109efdef8b4f354eb9f8ee7b14f63391a85f673e15472bfc0d347a6789dec.jpg", "description": "Discover how Attivo scaled AI-led advice compliance across its planner base, cutting file-checking costs by 40% while building the governance and trust to review every meeting.", "inLanguage": "en-GB", "articleBody": "Attivo's Chief Risk Officer describes how a phased rollout of Recordsure AI, backed by TCC's compliance expertise, cut file-checking costs by 40% within a year while increasing planner capacity and advice oversight.\n\nAttivo has partnered with TCC and Recordsure to roll out AI technology across its advice business, aiming to strengthen ongoing-advice compliance while reducing the cost of file reviews as the firm grows. Ian Plumton, Attivo's Chief Risk Officer, said the firm had explored AI options that lacked credibility or scalability before being introduced to Recordsure AI, backed by TCC's compliance expertise.\n\nWith nearly 250 staff, cultural adoption was a real challenge, but clear communication and early evidence of reduced administrative work built support. Early pilots achieved accuracy in the high 90% range, and within a year Attivo cut file-checking costs by 40%, with no unsuitable cases identified and ongoing improvements in advice quality.\n\nWhat began as a cost and compliance project grew into a wider operational one: high-accuracy voice capture and transcription gave Attivo a reliable foundation for automation, delivering meeting summaries and transcripts within 24 hours and reducing handover issues.\n\nAttivo is now on track to review 100% of planning meetings by early 2026, and continued rollout is delivering around 30% more planner capacity through accurate meeting capture and integration with intelliflo.\n\nLarger, multi-planner advice firms seeking to scale ongoing-advice review coverage without a proportionate increase in compliance headcount, and their compliance, risk and operations teams.\n\n\u2022 Choosing an AI provider without genuine scalability or compliance credibility can stall adoption.\n\u2022 Treating AI purely as a cost-cutting exercise risks missing its wider value for oversight and capacity.\n\u2022 Weak staff communication and buy-in can undermine rollout across a large planner base.\n\n1. Choose a partner that combines AI technology with demonstrable compliance expertise and governance.\n2. Build a clear business case with defined, measurable use cases before rollout.\n3. Communicate early wins, such as reduced administrative work, to build planner trust.\n4. Track both compliance metrics and commercial outcomes, such as planner capacity and turnaround time.\n\nAttivo's experience suggests that AI-led review, once mature, can extend beyond risk management into commercial performance: improved capacity, faster handovers and stronger evidence for Consumer Duty all followed from the same technology investment.\n\nIan Plumton noted that choosing a partner with aligned commercial incentives was critical, so that both sides were working towards the same long-term goals rather than a narrower technology sale.\n\nFirms planning a similar rollout should prioritise governance and a phased, human-centred approach over speed, building trust with planners through clear communication and visible early benefits.\n\nSuccess should be measured against both compliance outcomes, such as suitability and review coverage, and commercial outcomes, such as planner capacity and turnaround time.", "wordCount": 452, "keywords": [ "Compliance AI & RegTech", "Banking", 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"@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Scaling AI-Led Compliance" } ], "articleSection": [ "Compliance AI & RegTech" ], "audience": [ { "@type": "Audience", "audienceType": "Banking" }, { "@type": "Audience", "audienceType": "General Insurance & Protection" }, { "@type": "Audience", "audienceType": "Lending & Consumer Credit" }, { "@type": "Audience", "audienceType": "Motor Finance" }, { "@type": "Audience", "audienceType": "Payments & FinTech" }, { "@type": "Audience", "audienceType": "Pensions & Retirement Income" }, { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Compliance and risk leaders at growing advice firms considering a scaled rollout of AI-assisted file review." } ], "citation": [ { "@type": "CreativeWork", "name": "Attivo enhances advice compliance with TCC's AI solution", "url": "https://tcc.group/blog/2025/12/03/attivo-enhances-advice-compliance-with-tcc-ai-solution/", "datePublished": "2025-12-03" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/analysis-perspectives/attivo-enhances-advice-compliance-with-tcc-ai-solution/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/attivo-enhances-advice-compliance-with-tcc-ai-solution/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What results has Attivo achieved with Recordsure AI?", "acceptedAnswer": { "@type": "Answer", "text": "Within a year, Attivo cut file-checking costs by 40%, achieved no unsuitable cases, and is on track to review 100% of planning meetings by early 2026, alongside around 30% more planner capacity." } }, { "@type": "Question", "name": "How did Attivo manage staff adoption of AI across nearly 250 planners?", "acceptedAnswer": { "@type": "Answer", "text": "Through clear communication and early demonstrations of reduced administrative work, supported by a phased, human-centred rollout rather than an immediate firm-wide change." } }, { "@type": "Question", "name": "What role did TCC play alongside the Recordsure technology?", "acceptedAnswer": { "@type": "Answer", "text": "TCC provided the compliance expertise and governance structure behind the AI solution, helping Attivo build a business case and align the technology to its compliance practices." } } ] } ] } ``` ### FCA consolidation review: Lessons for wealth management - URL: https://tcc.group/insights/regulatory-horizon/lessons-from-fca-review-for-advice-and-wealth-management-consolidation/ - Published: 2025-12-01 - Modified: 2026-09-02 ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, 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**Topic:** Financial Wellbeing The FCA is urging financial firms to adopt tailored approaches to support financial wellbeing, encouraging consumers to move assets from cash to equities while delivering fair value. #### What happened? FCA Deputy Chief Executive Sarah Pritchard, in her address to the Investing and Saving Alliance (TISA) conference, outlined the regulator's vision for a more tailored approach to financial wellbeing. Emphasizing that consumer needs are increasingly complex, Pritchard urged the industry to move beyond 'one-size-fits-all' products and support consumers in fully understanding options for funding later life. This fits into a broader strategy to drive growth by encouraging consumers to transition from low-interest cash deposits to equity-based investments. The government supported this direction in the November 2025 Budget by announcing ISA system reforms to take effect from April 2027. #### Why does it matter? The regulator is challenging firms to actively re-educate consumers. Firms must move away from standard, passive disclaimers like 'capital at risk' and instead engage in proactive conversations about the benefits of investing. Under Consumer Duty, firms must demonstrate that they are actively helping clients meet their financial objectives and achieve good outcomes. This requires proving value through concrete criteria, such as tracking cash-to-asset ratios, providing holistic financial solutions (including borrowing and protection), and showing how interactions mitigate vulnerability. #### Who is affected? This guidance applies directly to financial advisers, wealth management firms, and consumer-facing financial services providers seeking to implement targeted support models. #### Key risks - **Unjustified Cash Holdings:** Failing to monitor or justify why high proportions of customer assets remain in cash under rising inflation. - **Failing vulnerable clients:** Inability to prove that communications are tailored to customer vulnerabilities, resulting in poor outcomes. - **Retrospective compliance:** Relying on passive, post-event checklists rather than active, data-led oversight. #### Actions to take 1. **Review Asset Allocations:** Identify the proportion of customer assets held in cash and establish clear, documented rationales for these positions. 2. **Reform Client Communications:** Upgrade suitability reports and promotions from passive warnings to active educational tools. 3. **Build Evidential Data:** Develop quantitative and qualitative measures to prove how clients are financially better off under your services. 4. **Leverage Compliance Tech:** Deploy speech analytics and interaction monitoring to identify vulnerabilities and surface risk at scale. #### Wider implications The regulatory expectation is clear: 'Show me, don't tell me.' As data-led oversight intensifies, firms must be capable of providing real-time evidence of the value and outcomes they deliver. #### Recommendations Firms should proactively audit their Consumer Duty MI matrix and deploy intelligent RegTech solutions to monitor client interactions and ensure tailored, compliant support. #### Supporting sources - [Financial wellbeing needs a tailored approach: The FCA’s vision for financial services](https://tcc.group/blog/2025/12/01/financial-wellbeing-needs-a-tailored-approach-the-fcas-vision-for-financial-services/) (2025-12-01) #### Are you ready to evidence positive customer outcomes? Benchmark your Consumer Duty metrics and deploy advanced interaction-monitoring technology with our specialist advisory team. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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We examine Deputy CEO Sarah Pritchard's address on tailored support, opportunity risk, and evidencing value in a data-led world.", "inLanguage": "en-GB", "articleBody": "The FCA is urging financial firms to adopt tailored approaches to support financial wellbeing, encouraging consumers to move assets from cash to equities while delivering fair value.\n\nFCA Deputy Chief Executive Sarah Pritchard, in her address to the Investing and Saving Alliance (TISA) conference, outlined the regulator's vision for a more tailored approach to financial wellbeing. Emphasizing that consumer needs are increasingly complex, Pritchard urged the industry to move beyond 'one-size-fits-all' products and support consumers in fully understanding options for funding later life.\n\nThis fits into a broader strategy to drive growth by encouraging consumers to transition from low-interest cash deposits to equity-based investments. The government supported this direction in the November 2025 Budget by announcing ISA system reforms to take effect from April 2027.\n\nThe regulator is challenging firms to actively re-educate consumers. Firms must move away from standard, passive disclaimers like 'capital at risk' and instead engage in proactive conversations about the benefits of investing. Under Consumer Duty, firms must demonstrate that they are actively helping clients meet their financial objectives and achieve good outcomes.\n\nThis requires proving value through concrete criteria, such as tracking cash-to-asset ratios, providing holistic financial solutions (including borrowing and protection), and showing how interactions mitigate vulnerability.\n\nThis guidance applies directly to financial advisers, wealth management firms, and consumer-facing financial services providers seeking to implement targeted support models.\n\n\u2022 Unjustified Cash Holdings: Failing to monitor or justify why high proportions of customer assets remain in cash under rising inflation.\n\u2022 Failing vulnerable clients: Inability to prove that communications are tailored to customer vulnerabilities, resulting in poor outcomes.\n\u2022 Retrospective compliance: Relying on passive, post-event checklists rather than active, data-led oversight.\n\n1. Review Asset Allocations: Identify the proportion of customer assets held in cash and establish clear, documented rationales for these positions.\n2. Reform Client Communications: Upgrade suitability reports and promotions from passive warnings to active educational tools.\n3. Build Evidential Data: Develop quantitative and qualitative measures to prove how clients are financially better off under your services.\n4. Leverage Compliance Tech: Deploy speech analytics and interaction monitoring to identify vulnerabilities and surface risk at scale.\n\nThe regulatory expectation is clear: 'Show me, don't tell me.' As data-led oversight intensifies, firms must be capable of providing real-time evidence of the value and outcomes they deliver.\n\nFirms should proactively audit their Consumer Duty MI matrix and deploy intelligent RegTech solutions to monitor client interactions and ensure tailored, compliant support.", "wordCount": 403, "keywords": [ "Consumer Duty", "Vulnerable Customers", "Banking", "General Insurance & Protection", "Lending & Consumer Credit", "Motor Finance", "Payments & FinTech", "Pensions & Retirement Income", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Consumer Duty", "url": "https://tcc.group/blog/solution/consumer-duty/" }, { "@type": "Thing", "name": "Vulnerable Customers", "url": "https://tcc.group/blog/solution/vulnerable-customers/" }, { "@type": "Thing", "name": "Banking", "url": "https://tcc.group/blog/sector/banking/" }, { "@type": "Thing", "name": "General Insurance & Protection", "url": "https://tcc.group/blog/sector/general-insurance-protection/" }, { "@type": "Thing", "name": "Lending & Consumer Credit", "url": "https://tcc.group/blog/sector/lending-consumer-credit/" }, { "@type": "Thing", "name": "Motor Finance", "url": "https://tcc.group/blog/sector/motor-finance/" }, { "@type": "Thing", "name": "Payments & FinTech", "url": "https://tcc.group/blog/sector/payments-fintech/" }, { "@type": "Thing", "name": "Pensions & Retirement Income", "url": "https://tcc.group/blog/sector/pensions-retirement-income/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Financial Wellbeing" } ], "articleSection": [ "Consumer Duty", "Vulnerable Customers" ], "audience": [ { "@type": "Audience", "audienceType": "Banking" }, { "@type": "Audience", "audienceType": "General Insurance & Protection" }, { "@type": "Audience", "audienceType": "Lending & Consumer Credit" }, { "@type": "Audience", "audienceType": "Motor Finance" }, { "@type": "Audience", "audienceType": "Payments & FinTech" }, { "@type": "Audience", "audienceType": "Pensions & Retirement Income" }, { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Advisers, wealth managers, and compliance leaders across financial services." } ], "citation": [ { "@type": "CreativeWork", "name": "Financial wellbeing needs a tailored approach: The FCA\u2019s vision for financial services", "url": "https://tcc.group/blog/2025/12/01/financial-wellbeing-needs-a-tailored-approach-the-fcas-vision-for-financial-services/", "datePublished": "2025-12-01" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/regulatory-horizon/financial-wellbeing-needs-a-tailored-approach-the-fcas-vision-for-financial-services/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/financial-wellbeing-needs-a-tailored-approach-the-fcas-vision-for-financial-services/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What is the FCA's core message on financial wellbeing?", "acceptedAnswer": { "@type": "Answer", "text": "The regulator demands that firms move beyond generic approaches, providing tailored support and active re-education to help consumers understand their options." } }, { "@type": "Question", "name": "How do ISA reforms from the November 2025 Budget affect this strategy?", "acceptedAnswer": { "@type": "Answer", "text": "Beginning April 2027, the ISA system will reserve \u00a38,000 of the \u00a320,000 allowance exclusively for investment, pushing advisers to help clients adapt quickly." } }, { "@type": "Question", "name": "How can firms demonstrate they are delivering fair value?", "acceptedAnswer": { "@type": "Answer", "text": "Firms should track clear criteria, such as the proportion of client assets in cash, the delivery of holistic services, and the quality of vulnerable customer outcomes." } } ] } ] } ``` ### Driving innovation and trust: TCC becomes a Finance & Leasing Association member - URL: https://tcc.group/insights/analysis-perspectives/driving-innovation-and-trust-tcc-mom-rs-becomes-a-finance-leasing-association-member/ - Published: 2025-11-16 - Modified: 2026-09-02 **Topic:** FLA Membership and Compliance TCC Group has joined the Finance & Leasing Association (FLA), enhancing its capability to support asset and consumer finance firms with compliance and remediation. #### What happened? TCC Group, incorporating TCC, Momenta, and Recordsure, has secured official membership in the Finance & Leasing Association (FLA). This milestone reflects our ongoing dedication to promoting excellence in governance and technological innovation across the regulated finance industry. As members, TCC Group gains access to the FLA's specialized research, industry insights, and professional training. This collaboration strengthens our capacity to guide firms through a rapidly changing regulatory landscape. #### Why does it matter? Membership in the UK's leading trade body for consumer and motor finance underscores TCC's standing as a trusted partner. It provides direct lines of communication with industry peers to identify emerging trends, and ensures our solutions remain aligned with the latest standards. For regulated firms, this ensures our managed services and advisory offerings are informed by the most current industry benchmarks, helping them maintain consumer trust and operational compliance. #### Who is affected? Regulated firms operating in the asset finance, consumer credit, and motor finance sectors are directly affected by these developments, as well as stakeholders responsible for risk management and compliance infrastructure. #### Key risks Firms face key risks from failing to keep pace with changing standards, which can lead to: - Inconsistent customer outcomes and regulatory non-compliance. - Backlogs in handling complex consumer complaints and motor finance redress cases. - Inadequate management information causing gaps in regulatory reporting. #### Actions to take Firms looking to enhance compliance and operational resilience should take these steps: 1. Assess current complaints and redress frameworks against updated FLA and FCA guidelines. 2. Utilise independent external advisory support to audit compliance policies. 3. Integrate intelligent technology to automate scope determination and reduce manual complaints handling. #### Wider implications The financial ecosystem is moving toward a more proactive, technology-driven approach to compliance. Trade associations like the FLA play a pivotal role in shaping robust frameworks that help firms adapt and remain resilient under heightened scrutiny. #### Recommendations We recommend that firms review their motor finance complaints handling processes to ensure they can scale. Implementing specialized resources and automation can protect customer trust and resolve issues efficiently. #### Supporting sources - [Driving innovation and trust: TCC becomes a Finance & Leasing Association member](https://tcc.group/blog/2025/11/17/driving-innovation-and-trust-tcc-mom-rs-becomes-a-finance-leasing-association-member/) (2025-11-17) #### Want to de-risk your motor finance complaints? Speak to our specialists about our fully managed complaints and remediation services powered by intelligent technology. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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This milestone reflects our ongoing dedication to promoting excellence in governance and technological innovation across the regulated finance industry.\n\nAs members, TCC Group gains access to the FLA's specialized research, industry insights, and professional training. This collaboration strengthens our capacity to guide firms through a rapidly changing regulatory landscape.\n\nMembership in the UK's leading trade body for consumer and motor finance underscores TCC's standing as a trusted partner. It provides direct lines of communication with industry peers to identify emerging trends, and ensures our solutions remain aligned with the latest standards.\n\nFor regulated firms, this ensures our managed services and advisory offerings are informed by the most current industry benchmarks, helping them maintain consumer trust and operational compliance.\n\nRegulated firms operating in the asset finance, consumer credit, and motor finance sectors are directly affected by these developments, as well as stakeholders responsible for risk management and compliance infrastructure.\n\nFirms face key risks from failing to keep pace with changing standards, which can lead to:\n\n\u2022 Inconsistent customer outcomes and regulatory non-compliance.\n\u2022 Backlogs in handling complex consumer complaints and motor finance redress cases.\n\u2022 Inadequate management information causing gaps in regulatory reporting.\n\nFirms looking to enhance compliance and operational resilience should take these steps:\n\n1. Assess current complaints and redress frameworks against updated FLA and FCA guidelines.\n2. Utilise independent external advisory support to audit compliance policies.\n3. Integrate intelligent technology to automate scope determination and reduce manual complaints handling.\n\nThe financial ecosystem is moving toward a more proactive, technology-driven approach to compliance. Trade associations like the FLA play a pivotal role in shaping robust frameworks that help firms adapt and remain resilient under heightened scrutiny.\n\nWe recommend that firms review their motor finance complaints handling processes to ensure they can scale. Implementing specialized resources and automation can protect customer trust and resolve issues efficiently.", "wordCount": 347, "keywords": [ "Complaints & Claims Handling", "Redress & Remediation", "Lending & Consumer Credit", "Motor Finance" ], "about": [ { "@type": "Thing", "name": "Complaints & Claims Handling", "url": "https://tcc.group/blog/solution/complaints-claims-handling/" }, { "@type": "Thing", "name": "Redress & Remediation", "url": "https://tcc.group/blog/solution/redress-and-remediation/" }, { "@type": "Thing", "name": "Lending & Consumer Credit", "url": "https://tcc.group/blog/sector/lending-consumer-credit/" }, { "@type": "Thing", "name": "Motor Finance", "url": "https://tcc.group/blog/sector/motor-finance/" }, { "@type": "Thing", "name": "FLA Membership and Compliance" } ], "articleSection": [ "Complaints & Claims Handling", "Redress & Remediation" ], "audience": [ { "@type": "Audience", "audienceType": "Lending & Consumer Credit" }, { "@type": "Audience", 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https://tcc.group/insights/analysis-perspectives/money-marketing-review-into-consolidation/ - Published: 2025-11-10 - Modified: 2026-09-02 ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", 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"url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Consolidation, Acquisition & Regulatory Due Diligence", "url": "https://tcc.group/blog/solution/consolidation-acquisition-regulatory-due-diligence/" }, { "@type": "Thing", "name": "Consumer Duty", "url": "https://tcc.group/blog/solution/consumer-duty/" }, { "@type": "Thing", "name": "Regulatory Change & Transformation", "url": "https://tcc.group/blog/solution/regulatory-change-transformation/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" } ], "articleSection": [ "Compliance AI & RegTech", "Consolidation, Acquisition & Regulatory Due Diligence", "Consumer Duty", "Regulatory Change & Transformation" ], "audience": [ { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" } ] } ] } ``` ### Evidencing compliance in a data-led regulatory world - URL: https://tcc.group/insights/analysis-perspectives/data-led-regulatory-world/ - Published: 2025-11-06 - Modified: 2026-09-02 **Topic:** Evidencing compliance with data TCC's webinar on evidencing compliance revealed a sector that feels directionally confident about demonstrating good Consumer Duty outcomes, but is still operationally stretched when it comes to recording, testing and evidencing them consistently. #### What happened? TCC ran a webinar on evidencing compliance, using three live polls to gauge industry sentiment. Asked how they felt about the evidence and reporting obligation, 42% of participants believed the regulatory environment was unlikely to change significantly in the near term, while a further 25% expected the Consumer Duty to keep increasing the burden, and 8% said they were uncertain what lies ahead. A second poll on customer conversation recording found that while 17% of firms now review more than ten per cent of interactions, a significantly higher proportion than the historic norm, 30% still do not record every conversation, and many assess only a small fraction of the conversations they do capture. A third poll on outcome testing found all respondents said they could verify vulnerability checks, and 82% felt confident demonstrating appropriate treatment and customer understanding. Yet only 53% reported that all their customer conversations were recorded, and only 41% could demonstrate the total absence of detriment across recent customer journeys. #### Why does it matter? The FCA's shift from prescription to what it terms “principles with proof” places the responsibility for demonstrating good outcomes squarely on firms, using tools such as section 165 information requests and targeted data requests to build a detailed picture of real-world practice. The poll results show a gap between the confidence firms have in their outcomes and the completeness of the evidence that would allow them to demonstrate this if asked. Record-keeping inconsistencies, missing audit trails and incomplete documentation continue to cause friction, particularly for standard activities such as annual reviews or vulnerability assessments. #### Who is affected? Compliance, risk and customer experience functions across wealth management, pensions, banking, lending, general insurance and protection, and motor finance are affected, particularly those relying on manual sampling to test customer outcomes. #### Key risks - Manual outcome testing that cannot review customer interactions at a statistically meaningful level. - Incomplete recording of customer conversations, leaving gaps in the evidence base for fair value, understanding and treatment. - Confidence in outcomes that is not backed by consistent, retrievable evidence across every customer journey. - Limited use of post-interaction surveys, despite these being among the most reliable tools for capturing genuine customer comprehension. #### Actions to take 1. Review how many customer conversations are currently recorded and assessed, and identify the gaps. 2. Use predictive AI to triage conversations and files at scale, so human reviewers can focus where they are genuinely needed. 3. Introduce post-interaction surveys where they are not already used, to capture genuine customer comprehension. 4. Build a consistent, retrievable evidence trail for vulnerability checks, fair value and customer understanding, rather than relying on periodic sampling. #### Wider implications Firms are entering a period where evidential readiness is a core operational capability, not just a regulatory expectation. Being able to demonstrate that the right conversations took place, that customers understood the information provided, and that good outcomes were achieved is becoming the standard the FCA expects, rather than simply avoiding harm. Predictive AI is becoming central to this shift because, unlike generative tools, it is designed to find patterns, detect missing steps and surface potential issues across entire populations of interactions, enabling population-level insight without a dramatic increase in headcount. #### Recommendations Firms should invest now in technology, data quality and intelligent sampling techniques to move from low-volume sampling towards true population-level insight, turning good intentions into robust, easily retrievable evidence. TCC's regulatory experts can assess a firm's current approach to evidencing outcomes, identify gaps and benchmark processes against best practice, while Recordsure's technology can help analyse every interaction and build a robust evidential framework. #### Supporting sources - [Evidencing compliance in a data-led regulatory world](https://tcc.group/blog/2025/11/07/data-led-regulatory-world/) (2025-11-07) #### Ready to strengthen your evidencing capability? TCC and Recordsure can help you assess your current approach to evidencing Consumer Duty outcomes and build a scalable evidential framework. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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"author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "Evidencing compliance in a data-led regulatory world", "datePublished": "2025-11-07T00:00:00+01:00", "dateModified": "2026-09-02T03:47:38+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/analysis-perspectives/data-led-regulatory-world/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/61a60f68e7384d9aa7b348dd334631bd/thumbnail-1024-13a1072d6405b69304ab2028a45f3b1d8cdcba3cba1df5d7e41a7c58d8d8b02a.jpg", "description": "Poll results from TCC's evidencing compliance webinar reveal a sector confident in its Consumer Duty outcomes but still struggling to record, test and evidence them consistently, and why predictive AI can help close the gap.", "inLanguage": "en-GB", "articleBody": "TCC's webinar on evidencing compliance revealed a sector that feels directionally confident about demonstrating good Consumer Duty outcomes, but is still operationally stretched when it comes to recording, testing and evidencing them consistently.\n\nTCC ran a webinar on evidencing compliance, using three live polls to gauge industry sentiment. Asked how they felt about the evidence and reporting obligation, 42% of participants believed the regulatory environment was unlikely to change significantly in the near term, while a further 25% expected the Consumer Duty to keep increasing the burden, and 8% said they were uncertain what lies ahead.\n\nA second poll on customer conversation recording found that while 17% of firms now review more than ten per cent of interactions, a significantly higher proportion than the historic norm, 30% still do not record every conversation, and many assess only a small fraction of the conversations they do capture.\n\nA third poll on outcome testing found all respondents said they could verify vulnerability checks, and 82% felt confident demonstrating appropriate treatment and customer understanding. Yet only 53% reported that all their customer conversations were recorded, and only 41% could demonstrate the total absence of detriment across recent customer journeys.\n\nThe FCA's shift from prescription to what it terms \u201cprinciples with proof\u201d places the responsibility for demonstrating good outcomes squarely on firms, using tools such as section 165 information requests and targeted data requests to build a detailed picture of real-world practice.\n\nThe poll results show a gap between the confidence firms have in their outcomes and the completeness of the evidence that would allow them to demonstrate this if asked. 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URL: https://tcc.group/insights/regulatory-horizon/why-simple-redress-schemes-require-strategic-planning/ - Published: 2025-10-26 - Modified: 2026-09-02 **Topic:** Motor Finance Redress Readiness TCC Group's webinar with Momenta and Recordsure explains why the proposed motor finance redress scheme is more complex than it first appears, and how firms can combine technology, governance and human judgement to execute it at scale. #### What happened? In a recent webinar, TCC Group's Garry Evans and Mike Morris examined the FCA's proposed motor finance redress scheme, exploring why early preparation is critical and how firms can approach remediation strategically across operational design, portfolio assessment, governance and internal capability. Redress schemes can look straightforward on paper: identify affected customers, calculate compensation and make payments. In practice, delivering fair and consistent outcomes for a scheme covering millions of customers and potentially millions in compensation requires significant operational, technological and human expertise. #### Why does it matter? Customer records can be inconsistent or incomplete, agreements span multiple product types and exceptions cannot be avoided. Without careful planning, these challenges translate into delays, costly errors and reputational risk. Automation can handle repetitive tasks such as calculations and customer communications, but it cannot replace human oversight for complex or disputed cases. Firms that combine technology with human expertise are better placed to manage scale, maintain accuracy and deliver consistent outcomes. #### Who is affected? The webinar is aimed at firms across wealth management, pensions, payments, banking, lending, insurance and motor finance that may be affected by the FCA's proposed motor finance redress scheme or comparable large-scale remediation exercises. #### Key risks - Inconsistent or incomplete customer records across agreements and product types. - Operational delays, costly errors and reputational damage from unplanned execution. - Over-reliance on automation for complex or disputed cases that need human judgement. - Weak capacity planning and reporting frameworks that cannot cope with high volumes. #### Actions to take 1. Validate the firm's proposed regulatory approach before the FCA finalises its scheme. 2. Review sales documentation and test redress calculations ahead of time. 3. Define scope determination, tracing and customer contact strategies in advance. 4. Model cost-effective resourcing scenarios and confirm capacity for peak volumes. #### Wider implications Firms that recognise the complexity of redress schemes and prepare accordingly are better placed to demonstrate operational maturity, customer focus and long-term resilience, turning a high-stakes regulatory challenge into a controlled, manageable process. #### Recommendations TCC Group's redress technology workflow, powered by iQcodex, has already processed over one million cases, helping firms analyse datasets, prepare documentation and position themselves to implement calculations and payments as soon as the FCA finalises its plans. A half-day redress strategy workshop is also available to pressure-test scope, sales documentation and resourcing before a scheme goes live. #### Supporting sources - [Why ‘simple’ redress schemes require strategic planning](https://tcc.group/blog/2025/10/27/why-simple-redress-schemes-require-strategic-planning/) (2025-10-27) #### Ready for the motor finance redress scheme? Get in touch to access our redress technology workflow or book a half-day redress strategy workshop. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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planning, data readiness and the right blend of technology and human oversight keep large-scale remediation under control.", "inLanguage": "en-GB", "articleBody": "TCC Group's webinar with Momenta and Recordsure explains why the proposed motor finance redress scheme is more complex than it first appears, and how firms can combine technology, governance and human judgement to execute it at scale.\n\nIn a recent webinar, TCC Group's Garry Evans and Mike Morris examined the FCA's proposed motor finance redress scheme, exploring why early preparation is critical and how firms can approach remediation strategically across operational design, portfolio assessment, governance and internal capability.\n\nRedress schemes can look straightforward on paper: identify affected customers, calculate compensation and make payments. In practice, delivering fair and consistent outcomes for a scheme covering millions of customers and potentially millions in compensation requires significant operational, technological and human expertise.\n\nCustomer records can be inconsistent or incomplete, agreements span multiple product types and exceptions cannot be avoided. Without careful planning, these challenges translate into delays, costly errors and reputational risk.\n\nAutomation can handle repetitive tasks such as calculations and customer communications, but it cannot replace human oversight for complex or disputed cases. Firms that combine technology with human expertise are better placed to manage scale, maintain accuracy and deliver consistent outcomes.\n\nThe webinar is aimed at firms across wealth management, pensions, payments, banking, lending, insurance and motor finance that may be affected by the FCA's proposed motor finance redress scheme or comparable large-scale remediation exercises.\n\n\u2022 Inconsistent or incomplete customer records across agreements and product types.\n\u2022 Operational delays, costly errors and reputational damage from unplanned execution.\n\u2022 Over-reliance on automation for complex or disputed cases that need human judgement.\n\u2022 Weak capacity planning and reporting frameworks that cannot cope with high volumes.\n\n1. Validate the firm's proposed regulatory approach before the FCA finalises its scheme.\n2. Review sales documentation and test redress calculations ahead of time.\n3. Define scope determination, tracing and customer contact strategies in advance.\n4. Model cost-effective resourcing scenarios and confirm capacity for peak volumes.\n\nFirms that recognise the complexity of redress schemes and prepare accordingly are better placed to demonstrate operational maturity, customer focus and long-term resilience, turning a high-stakes regulatory challenge into a controlled, manageable process.\n\nTCC Group's redress technology workflow, powered by iQcodex, has already processed over one million cases, helping firms analyse datasets, prepare documentation and position themselves to implement calculations and payments as soon as the FCA finalises its plans. A half-day redress strategy workshop is also available to pressure-test scope, sales documentation and resourcing before a scheme goes live.", "wordCount": 408, "keywords": [ "Regulatory Change & Transformation", "Banking", "General Insurance & Protection", "Lending & Consumer Credit", "Motor Finance", "Payments & FinTech", "Pensions & Retirement Income", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Regulatory Change & Transformation", "url": "https://tcc.group/blog/solution/regulatory-change-transformation/" }, { "@type": "Thing", "name": "Banking", "url": "https://tcc.group/blog/sector/banking/" }, { "@type": "Thing", "name": "General Insurance & Protection", "url": "https://tcc.group/blog/sector/general-insurance-protection/" }, { "@type": "Thing", "name": "Lending & Consumer Credit", "url": "https://tcc.group/blog/sector/lending-consumer-credit/" }, { "@type": "Thing", "name": "Motor Finance", "url": "https://tcc.group/blog/sector/motor-finance/" }, { "@type": "Thing", "name": "Payments & FinTech", "url": "https://tcc.group/blog/sector/payments-fintech/" }, { "@type": "Thing", "name": "Pensions & Retirement Income", "url": "https://tcc.group/blog/sector/pensions-retirement-income/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Motor Finance Redress Readiness" } ], "articleSection": [ "Regulatory Change & Transformation" ], "audience": [ { "@type": "Audience", "audienceType": "Banking" }, { "@type": "Audience", "audienceType": "General Insurance & Protection" }, { "@type": "Audience", "audienceType": "Lending & Consumer Credit" }, { "@type": "Audience", "audienceType": "Motor Finance" }, { "@type": "Audience", "audienceType": "Payments & FinTech" }, { "@type": "Audience", "audienceType": "Pensions & Retirement Income" }, { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Firms across wealth management, pensions, payments, banking, lending, insurance and motor finance preparing for large-scale redress." } ], "citation": [ { "@type": "CreativeWork", "name": "Why \u2018simple\u2019 redress schemes require strategic planning", "url": "https://tcc.group/blog/2025/10/27/why-simple-redress-schemes-require-strategic-planning/", "datePublished": "2025-10-27" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/regulatory-horizon/why-simple-redress-schemes-require-strategic-planning/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/why-simple-redress-schemes-require-strategic-planning/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "Why isn't the motor finance redress scheme as simple as it looks?", "acceptedAnswer": { "@type": "Answer", "text": "Because customer records, product variations and exceptions make calculation and payment far more complex to execute consistently at scale than a simple compensation exercise suggests." } }, { "@type": "Question", "name": "Can automation handle motor finance redress on its own?", "acceptedAnswer": { "@type": "Answer", "text": "No; automation supports repetitive tasks such as calculations and communications, but complex or disputed cases still need human oversight." } }, { "@type": "Question", "name": "What is TCC's redress technology workflow?", "acceptedAnswer": { "@type": "Answer", "text": "It is a purpose-built workflow powered by iQcodex that has already processed over one million redress cases for firms preparing for the FCA's scheme." } }, { "@type": "Question", "name": "What does the half-day redress strategy workshop cover?", "acceptedAnswer": { "@type": "Answer", "text": "It covers validating the firm's regulatory approach, reviewing sales documentation, testing calculations, resourcing options and scenario modelling." } } ] } ] } ``` ### “Show me, don’t tell me”: How AI is transforming compliance - URL: https://tcc.group/insights/analysis-perspectives/show-me-dont-tell-me-how-ai-is-transforming-compliance/ - Published: 2025-10-23 - Modified: 2026-09-02 **Topic:** AI-Led Compliance Assurance Regulators, boards and senior leaders increasingly expect firms to demonstrate that compliance controls work, not just that they exist, and TCC argues predictive AI can provide that continuous evidence. #### What happened? TCC's analysis describes a shift in regulatory expectations: firms are no longer able to rely on asserting that compliance policies exist. The FCA, boards and senior leaders now expect clear, data-backed evidence that those policies are working in practice. The piece sets out how AI tools can analyse large volumes of customer interactions and operational data to identify patterns, highlight risks and generate real-time evidence of conduct, in place of retrospective reviews or limited manual sampling. TCC and Recordsure hosted a related live webinar on 6 November 2025, exploring how predictive AI can improve monitoring, streamline assurance processes and build regulatory trust without increasing headcount. #### Why does it matter? Traditional oversight methods struggle to keep pace with rising volumes of customer interactions, data and regulatory expectations. Firms that rely solely on retrospective reviews or small manual samples risk gaps between what they report and what is actually happening in customer-facing conduct. Predictive AI is presented as a way to automate repetitive monitoring tasks, freeing compliance teams to focus on strategic oversight and to surface insights that would otherwise take weeks of manual analysis. #### Who is affected? Compliance, risk and assurance functions across financial services firms, particularly those under pressure to evidence oversight without expanding headcount. #### Key risks - Compliance assurance based on assertion rather than demonstrable, data-backed evidence. - Retrospective reviews and limited manual sampling that cannot keep pace with the volume of customer interactions. - Slow identification of emerging conduct risks when analysis depends on manual processes. #### Actions to take 1. Assess whether current monitoring can demonstrate, not just assert, that controls are working. 2. Identify where AI-based analysis could replace retrospective or sample-based reviews. 3. Register for TCC and Recordsure's live webinar on AI-led compliance assurance. #### Wider implications As “show me, don’t tell me” scrutiny becomes the norm, firms able to produce continuous, objective evidence of conduct are better placed to respond to regulator, board and stakeholder questions than those relying on periodic reporting alone. #### Recommendations Firms should review where compliance assurance still depends on manual sampling or retrospective checks, and consider where predictive AI, used alongside regulatory expertise, could provide continuous evidence of good conduct. #### Supporting sources - [“Show me, don’t tell me”: How AI Is transforming compliance](https://tcc.group/blog/2025/10/24/show-me-dont-tell-me-how-ai-is-transforming-compliance/) (2025-10-24) #### Ready to move to evidence-led compliance assurance? Speak to TCC about using AI to strengthen how your firm evidences compliance oversight. 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The FCA, boards and senior leaders now expect clear, data-backed evidence that those policies are working in practice.\n\nThe piece sets out how AI tools can analyse large volumes of customer interactions and operational data to identify patterns, highlight risks and generate real-time evidence of conduct, in place of retrospective reviews or limited manual sampling.\n\nTCC and Recordsure hosted a related live webinar on 6 November 2025, exploring how predictive AI can improve monitoring, streamline assurance processes and build regulatory trust without increasing headcount.\n\nTraditional oversight methods struggle to keep pace with rising volumes of customer interactions, data and regulatory expectations. 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Register for TCC and Recordsure's live webinar on AI-led compliance assurance.\n\nAs \u201cshow me, don\u2019t tell me\u201d scrutiny becomes the norm, firms able to produce continuous, objective evidence of conduct are better placed to respond to regulator, board and stakeholder questions than those relying on periodic reporting alone.\n\nFirms should review where compliance assurance still depends on manual sampling or retrospective checks, and consider where predictive AI, used alongside regulatory expertise, could provide continuous evidence of good conduct.", "wordCount": 372, "keywords": [ "Compliance AI & RegTech", "Suitability, Advice Quality & File Reviews", "Banking", "General Insurance & Protection", "Lending & Consumer Credit", "Motor Finance", "Payments & FinTech", "Pensions & Retirement Income", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Suitability, Advice Quality & File Reviews", "url": "https://tcc.group/blog/solution/outsourced-suitability-reviews/" }, { "@type": "Thing", "name": "Banking", "url": "https://tcc.group/blog/sector/banking/" }, { "@type": "Thing", "name": "General Insurance & Protection", "url": "https://tcc.group/blog/sector/general-insurance-protection/" }, { "@type": "Thing", "name": "Lending & Consumer Credit", "url": "https://tcc.group/blog/sector/lending-consumer-credit/" }, { "@type": "Thing", "name": "Motor Finance", "url": "https://tcc.group/blog/sector/motor-finance/" }, { "@type": "Thing", "name": "Payments & FinTech", "url": "https://tcc.group/blog/sector/payments-fintech/" }, { "@type": "Thing", "name": "Pensions & Retirement Income", "url": "https://tcc.group/blog/sector/pensions-retirement-income/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "AI-Led Compliance Assurance" } ], "articleSection": [ "Compliance AI & RegTech", "Suitability, Advice Quality & File Reviews" ], "audience": [ { "@type": "Audience", "audienceType": "Banking" }, { "@type": "Audience", "audienceType": "General Insurance & Protection" }, { "@type": "Audience", "audienceType": "Lending & Consumer Credit" }, { "@type": "Audience", "audienceType": "Motor Finance" }, { "@type": "Audience", "audienceType": "Payments & FinTech" }, { "@type": "Audience", "audienceType": "Pensions & Retirement Income" }, { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Compliance leaders across financial services firms responsible for demonstrating oversight and assurance to the FCA and their board." } ], "citation": [ { "@type": "CreativeWork", "name": "\u201cShow me, don\u2019t tell me\u201d: How AI Is transforming compliance", "url": "https://tcc.group/blog/2025/10/24/show-me-dont-tell-me-how-ai-is-transforming-compliance/", "datePublished": "2025-10-24" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/analysis-perspectives/show-me-dont-tell-me-how-ai-is-transforming-compliance/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/show-me-dont-tell-me-how-ai-is-transforming-compliance/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What does 'show me, don't tell me' compliance mean?", "acceptedAnswer": { "@type": "Answer", "text": "It means firms must provide data-backed evidence that compliance controls are working, rather than simply stating that policies are in place." } }, { "@type": "Question", "name": "How can AI help with compliance assurance?", "acceptedAnswer": { "@type": "Answer", "text": "AI can analyse large volumes of customer interactions and operational data to identify patterns, highlight risks and provide real-time evidence of conduct." } }, { "@type": "Question", "name": "When is TCC and Recordsure's related webinar?", "acceptedAnswer": { "@type": "Answer", "text": "The live webinar took place on 6 November 2025 at 12:30pm." } } ] } ] } ``` ### Turning motor finance compliance into an opportunity - URL: https://tcc.group/insights/analysis-perspectives/turning-motor-finance-compliance-into-an-opportunity/ - Published: 2025-10-22 - Modified: 2026-09-02 **Topic:** Motor finance redress preparation Garry Evans and Mike Morris explain why early preparation for the FCA's motor finance redress scheme reduces operational stress, and set out the governance, technology and capability firms need to build now. #### What happened? In the second excerpt from a recent webinar on the FCA's motor finance redress scheme, Garry Evans and Mike Morris set out what firms need to do now to prepare effectively. They focus on the case for early preparation, covering practical steps from portfolio assessment and governance through to operational design and building internal capability. #### Why does it matter? The FCA's consultation is a call to action: preparation is no longer optional. Firms that move early reduce operational stress while demonstrating a proactive approach to regulatory compliance. Waiting until the scheme launches tends to produce rushed processes, reactive decision-making and higher operational costs, whereas early preparation allows firms to plan, coordinate and deliver with precision. #### Who is affected? Motor finance lenders and brokers with historical commission arrangements in scope of the redress scheme, along with the compliance, operations, IT and customer service teams who need to work together on portfolio reviews. #### Key risks - Incomplete or unreliable historical customer records and agreement classifications. - Governance gaps that leave accountability and decision-making unclear during a large-scale redress exercise. - Over-reliance on automation for complex or exceptional cases that require human judgement. #### Actions to take 1. Review customer records, agreement classifications and historical data for completeness and accuracy. 2. Establish clear governance, accountability and decision-making structures across compliance, operations, IT and customer service. 3. Design workflows that combine automation for high-volume calculations with human review for complex or exceptional cases. 4. Train staff and build quality assurance mechanisms ahead of the scheme's launch. #### Wider implications Firms that prioritise preparedness are positioned not only to comply with FCA expectations but also to reinforce their reputation as capable, customer-focused organisations once the redress scheme takes effect. #### Recommendations TCC's motor finance redress workflow, powered by iQcodex, has already processed over one million cases, helping firms analyse datasets, prepare documents for review and define scope, tracing and contact strategies. A half-day redress strategy workshop is also available, covering regulatory approach validation, sales documentation review, calculation testing and resourcing options. #### Supporting sources - [Turning motor finance compliance into an opportunity](https://tcc.group/blog/2025/10/23/turning-motor-finance-compliance-into-an-opportunity/) (2025-10-23) #### Ready to prepare for motor finance redress? Speak to our team about our proven redress technology workflow or book a half-day redress strategy workshop. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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spanning portfolio assessment, governance and technology to build lasting compliance capability.", "inLanguage": "en-GB", "articleBody": "Garry Evans and Mike Morris explain why early preparation for the FCA's motor finance redress scheme reduces operational stress, and set out the governance, technology and capability firms need to build now.\n\nIn the second excerpt from a recent webinar on the FCA's motor finance redress scheme, Garry Evans and Mike Morris set out what firms need to do now to prepare effectively.\n\nThey focus on the case for early preparation, covering practical steps from portfolio assessment and governance through to operational design and building internal capability.\n\nThe FCA's consultation is a call to action: preparation is no longer optional. Firms that move early reduce operational stress while demonstrating a proactive approach to regulatory compliance.\n\nWaiting until the scheme launches tends to produce rushed processes, reactive decision-making and higher operational costs, whereas early preparation allows firms to plan, coordinate and deliver with precision.\n\nMotor finance lenders and brokers with historical commission arrangements in scope of the redress scheme, along with the compliance, operations, IT and customer service teams who need to work together on portfolio reviews.\n\n\u2022 Incomplete or unreliable historical customer records and agreement classifications.\n\u2022 Governance gaps that leave accountability and decision-making unclear during a large-scale redress exercise.\n\u2022 Over-reliance on automation for complex or exceptional cases that require human judgement.\n\n1. Review customer records, agreement classifications and historical data for completeness and accuracy.\n2. Establish clear governance, accountability and decision-making structures across compliance, operations, IT and customer service.\n3. Design workflows that combine automation for high-volume calculations with human review for complex or exceptional cases.\n4. 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The FCA's motor finance redress consultation sets out clear expectations on how firms should identify affected customers, calculate redress and manage remediation efficiently. TCC Group's Chief Product and Commercial Officer, Garry Evans, and Momenta's Head of Operations, Mike Morris, discussed what the consultation means for firms in a recent session. #### Why does it matter? The FCA has clarified which agreements are in scope, how redress should be calculated and the expected delivery timelines, with a stronger emphasis on governance and transparency alongside accurate calculations. Firms can no longer rely on broad, generic frameworks; many are also working with incomplete historical data, inconsistent workflows and gaps in cross-team collaboration that the consultation brings into focus. #### Who is affected? Motor finance lenders and brokers with regulated agreements potentially in scope of redress, and the compliance, operations and IT teams responsible for auditing records and delivering remediation. #### Key risks - Incomplete historical data and inconsistent workflows across teams. - Generic compliance frameworks that don't hold up against the consultation's specific requirements. - Weak governance and oversight undermining consistency and accuracy in redress calculations. #### Actions to take 1. Identify agreements in scope by reviewing all regulated motor finance agreements to determine which customers may be entitled to redress. 2. Design remediation processes that balance operational efficiency with accuracy in calculating and delivering redress. 3. Implement robust governance and oversight, with clear roles and responsibilities to maintain transparency throughout the process. #### Wider implications Firms that act early and understand the detail of the consultation can embed a culture of compliance while keeping customer outcomes at the forefront, strengthening their standing with the regulator. #### Recommendations Firms can either work with TCC's experts to guide compliance and remediation, or use its purpose-built technology, already processing over one million cases, to handle data analysis, document review, redress calculation and customer contact. #### Supporting sources - [Understanding the FCA changes impacting motor finance firms](https://tcc.group/blog/2025/10/20/understanding-the-fca-changes-impacting-motor-finance-firms/) (2025-10-20) #### Ready to get ahead of motor finance redress? Book a free demo to see how our experts and technology can support your redress preparation. [Book a demo](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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In a recent webinar, Kit Ruparel, TCC and Recordsure's Chief Technology Officer, joined Garry Evans, Chief Product and Commercial Officer, to set out a critical distinction: predictive AI is deterministic and produces the same output every time for the same inputs, making it suited to forecasting, modelling and structured data, with tunable confidence thresholds. Generative AI, by contrast, is probabilistic. Large language models were designed to be creative, producing varied outputs that can be confident and human-like but sometimes incorrect, a phenomenon Kit described as "confidently wrong". Predictive AI can reduce human effort dramatically, sometimes by up to 50%, when automating suitability checks and validating structured data. Generative AI is better suited to summarising information into digestible formats, such as portfolio reports or meeting summaries, rather than generating primary insights or critical decisions. #### Why does it matter? The FCA is increasingly expecting organisations to demonstrate strong governance and control, making oversight essential to any AI strategy. Generative AI's unpredictability means conversations on sensitive topics need guardrails, safety filters and monitoring by information security teams. Overreliance on generative AI for tasks such as suitability report generation introduces what the webinar called the "AI Verification Tax", where staff spend as much time checking AI outputs as they would performing the task manually. #### Who is affected? Wealth management firms using, or considering, AI for suitability assessments, advice processes, portfolio reporting and compliance evidence. #### Key risks - Generative AI producing confident but incorrect answers when used without oversight. - Overreliance on generative AI for primary insight or critical client decisions. - AI models "drifting" as business processes, customer needs and regulatory requirements change, requiring ongoing retesting. - Integrating AI without governance frameworks or information security oversight. #### Actions to take 1. Match the right AI type to each task: predictive AI for structured, repeatable work; generative AI for summarising and communicating. 2. Build governance frameworks with guardrails, safety filters and information security oversight. 3. Commit to ongoing testing and adaptation as AI models and regulatory expectations evolve. 4. Provide end-user training so staff understand how AI informs decisions. #### Wider implications The successful application of AI in financial services is as much about planning, oversight and understanding a tool's purpose as it is about the technology itself. Firms should continuously evaluate new AI tools and integrate them into a long-term compliance strategy rather than treating adoption as a one-off project. #### Recommendations TCC is offering a personalised consultation with its Chief Technology Officer to help firms validate their AI strategy and develop a practical, compliant framework. #### Supporting sources - [The role of generative and predictive AI in wealth management](https://tcc.group/blog/2025/10/17/the-role-of-generative-and-predictive-ai-in-wealth-management/) (2025-10-17) #### Want an expert review of your AI strategy? Book a personalised consultation with TCC to review how predictive and generative AI fit your compliance framework. [Book a consultation](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", 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"https://tcc.group/insights/analysis-perspectives/the-role-of-generative-and-predictive-ai-in-wealth-management/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/analysis-perspectives/the-role-of-generative-and-predictive-ai-in-wealth-management/#webpage", "url": "https://tcc.group/insights/analysis-perspectives/the-role-of-generative-and-predictive-ai-in-wealth-management/", "name": "The role of generative and predictive AI in wealth management", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2025-10-17T00:00:00+01:00", "dateModified": "2026-09-02T03:49:06+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/analysis-perspectives/the-role-of-generative-and-predictive-ai-in-wealth-management/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "AnalysisNewsArticle", "@id": "https://tcc.group/insights/analysis-perspectives/the-role-of-generative-and-predictive-ai-in-wealth-management/#article", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/the-role-of-generative-and-predictive-ai-in-wealth-management/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "The role of generative and predictive AI in wealth management", "datePublished": "2025-10-17T00:00:00+01:00", "dateModified": "2026-09-02T03:49:06+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/analysis-perspectives/the-role-of-generative-and-predictive-ai-in-wealth-management/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/918b4ae523bd4c68a98c0fd8ba05de3b/thumbnail-1600-6e0a9e53e95c8ccf463643afe093d5be4266a4da865ccfc387b85e836980a911.jpg", "description": "Learn the practical difference between predictive and generative AI, why combining both is essential for wealth management compliance, and how to avoid the risks of over-relying on either approach alone.", "inLanguage": "en-GB", "articleBody": "TCC and Recordsure's 'Building on solid foundations' webinar set out the practical differences between predictive and generative AI, and why wealth management firms need both, supported by governance, to adopt AI safely.\n\nIn a recent webinar, Kit Ruparel, TCC and Recordsure's Chief Technology Officer, joined Garry Evans, Chief Product and Commercial Officer, to set out a critical distinction: predictive AI is deterministic and produces the same output every time for the same inputs, making it suited to forecasting, modelling and structured data, with tunable confidence thresholds.\n\nGenerative AI, by contrast, is probabilistic. Large language models were designed to be creative, producing varied outputs that can be confident and human-like but sometimes incorrect, a phenomenon Kit described as \"confidently wrong\".\n\nPredictive AI can reduce human effort dramatically, sometimes by up to 50%, when automating suitability checks and validating structured data. Generative AI is better suited to summarising information into digestible formats, such as portfolio reports or meeting summaries, rather than generating primary insights or critical decisions.\n\nThe FCA is increasingly expecting organisations to demonstrate strong governance and control, making oversight essential to any AI strategy. Generative AI's unpredictability means conversations on sensitive topics need guardrails, safety filters and monitoring by information security teams.\n\nOverreliance on generative AI for tasks such as suitability report generation introduces what the webinar called the \"AI Verification Tax\", where staff spend as much time checking AI outputs as they would performing the task manually.\n\nWealth management firms using, or considering, AI for suitability assessments, advice processes, portfolio reporting and compliance evidence.\n\n\u2022 Generative AI producing confident but incorrect answers when used without oversight.\n\u2022 Overreliance on generative AI for primary insight or critical client decisions.\n\u2022 AI models \"drifting\" as business processes, customer needs and regulatory requirements change, requiring ongoing retesting.\n\u2022 Integrating AI without governance frameworks or information security oversight.\n\n1. Match the right AI type to each task: predictive AI for structured, repeatable work; generative AI for summarising and communicating.\n2. Build governance frameworks with guardrails, safety filters and information security oversight.\n3. Commit to ongoing testing and adaptation as AI models and regulatory expectations evolve.\n4. Provide end-user training so staff understand how AI informs decisions.\n\nThe successful application of AI in financial services is as much about planning, oversight and understanding a tool's purpose as it is about the technology itself. Firms should continuously evaluate new AI tools and integrate them into a long-term compliance strategy rather than treating adoption as a one-off project.\n\nTCC is offering a personalised consultation with its Chief Technology Officer to help firms validate their AI strategy and develop a practical, compliant framework.", "wordCount": 436, "keywords": [ "Compliance AI & RegTech", "Consumer Duty", "Suitability, Advice Quality & File Reviews", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Consumer Duty", "url": "https://tcc.group/blog/solution/consumer-duty/" }, { "@type": "Thing", "name": "Suitability, Advice Quality & File Reviews", "url": "https://tcc.group/blog/solution/outsourced-suitability-reviews/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Generative vs predictive AI" } ], "articleSection": [ "Compliance AI & RegTech", "Consumer Duty", "Suitability, Advice Quality & File Reviews" ], "audience": [ { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Compliance, technology and operations leaders assessing AI adoption in wealth management." } ], "citation": [ { "@type": "CreativeWork", "name": "The role of generative and predictive AI in wealth management", "url": "https://tcc.group/blog/2025/10/17/the-role-of-generative-and-predictive-ai-in-wealth-management/", "datePublished": "2025-10-17" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/analysis-perspectives/the-role-of-generative-and-predictive-ai-in-wealth-management/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/the-role-of-generative-and-predictive-ai-in-wealth-management/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What's the key difference between predictive and generative AI?", "acceptedAnswer": { "@type": "Answer", "text": "Predictive AI is deterministic and produces consistent, repeatable outputs ideal for forecasting and structured data, while generative AI is probabilistic and better suited to drafting, summarising and communicating information." } }, { "@type": "Question", "name": "Why can generative AI be risky for compliance tasks?", "acceptedAnswer": { "@type": "Answer", "text": "It can produce confident, human-like answers that are sometimes wrong, so it needs guardrails, safety filters and oversight before being used for anything customer-facing or evidential." } }, { "@type": "Question", "name": "What is the \"AI Verification Tax\"?", "acceptedAnswer": { "@type": "Answer", "text": "It's the extra time and effort spent checking generative AI outputs for accuracy, which can end up costing as much as doing the task manually." } }, { "@type": "Question", "name": "How much manual effort can predictive AI save?", "acceptedAnswer": { "@type": "Answer", "text": "In tasks like automating suitability checks and validating structured data, predictive AI can reduce human effort by up to 50%." } } ] } ] } ``` ### Turning no change reviews into insightful compliance opportunities - URL: https://tcc.group/insights/analysis-perspectives/turning-no-change-reviews-into-insightful-compliance-opportunities/ - Published: 2025-10-15 - Modified: 2026-09-02 **Topic:** No change suitability reviews David Boyhan and Neil Dethick explain why annual no change suitability reviews are often the highest-risk files, and how AI-assisted review can turn them into a source of compliance insight. #### What happened? In a recent webinar, TCC polled attendees on how often they formally assess suitability at a client's annual review, even when the outcome is no change. Just 20% of firms said more than 10% of their annual reviews are subject to a suitability check, while 80% said only 0 to 10% are checked. #### Why does it matter? David Boyhan, TCC's Technical Director, says no change reviews should never be ignored: these files can be high risk, particularly when a client's circumstances haven't changed for several years. The absence of a new product recommendation is often why they get overlooked, yet ongoing suitability still needs to be verified, and the FCA's 'show me, don't tell me' approach means firms must evidence good outcomes rather than assume them. #### Who is affected? Wealth management firms where no-change review clients often represent a larger share of the client bank than new business clients, and the compliance teams responsible for sampling and evidencing their reviews. #### Key risks - No change reviews being treated as low priority because there is no new product recommendation to check. - Higher-risk products such as drawdown accounts not receiving more frequent scrutiny than lower-risk holdings like ISAs. - Clients who haven't engaged for over 12 months continuing to pay fees without evidence they are still benefiting. - Inability to evidence a reasonable sampling process, increasing the risk of FCA censure. #### Actions to take 1. Confirm that a meaningful annual review has taken place for every client, including no-change cases. 2. Check that client objectives, needs, attitude to risk and capacity for loss remain aligned with the advice given. 3. Vary review frequency by product risk, giving closer scrutiny to higher-risk holdings such as drawdown. 4. Use AI to flag cases needing attention and RAG-rate files on timeliness, documentation and outcomes, while keeping human judgement for the final decision. #### Wider implications Treating no-change reviews as a genuine compliance checkpoint, rather than paperwork, helps firms build a defensible evidence base under the Consumer Duty's 'show me, don't tell me' expectations. #### Recommendations TCC is offering a free consultancy review for ongoing services cases, with the first five firms to respond receiving a sample assessment of 100 client files to benchmark current standards. #### Supporting sources - [Turning no change reviews into insightful compliance opportunities](https://tcc.group/blog/2025/10/16/turning-no-change-reviews-into-insightful-compliance-opportunities/) (2025-10-16) #### Want a free review of your files? Request a free sample assessment of 100 client files to see how your no-change reviews measure up. [Find out more](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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how AI can speed up file checking, and what practical steps turn a routine compliance task into a strategic advantage.", "inLanguage": "en-GB", "articleBody": "David Boyhan and Neil Dethick explain why annual no change suitability reviews are often the highest-risk files, and how AI-assisted review can turn them into a source of compliance insight.\n\nIn a recent webinar, TCC polled attendees on how often they formally assess suitability at a client's annual review, even when the outcome is no change.\n\nJust 20% of firms said more than 10% of their annual reviews are subject to a suitability check, while 80% said only 0 to 10% are checked.\n\nDavid Boyhan, TCC's Technical Director, says no change reviews should never be ignored: these files can be high risk, particularly when a client's circumstances haven't changed for several years.\n\nThe absence of a new product recommendation is often why they get overlooked, yet ongoing suitability still needs to be verified, and the FCA's 'show me, don't tell me' approach means firms must evidence good outcomes rather than assume them.\n\nWealth management firms where no-change review clients often represent a larger share of the client bank than new business clients, and the compliance teams responsible for sampling and evidencing their reviews.\n\n\u2022 No change reviews being treated as low priority because there is no new product recommendation to check.\n\u2022 Higher-risk products such as drawdown accounts not receiving more frequent scrutiny than lower-risk holdings like ISAs.\n\u2022 Clients who haven't engaged for over 12 months continuing to pay fees without evidence they are still benefiting.\n\u2022 Inability to evidence a reasonable sampling process, increasing the risk of FCA censure.\n\n1. Confirm that a meaningful annual review has taken place for every client, including no-change cases.\n2. Check that client objectives, needs, attitude to risk and capacity for loss remain aligned with the advice given.\n3. Vary review frequency by product risk, giving closer scrutiny to higher-risk holdings such as drawdown.\n4. Use AI to flag cases needing attention and RAG-rate files on timeliness, documentation and outcomes, while keeping human judgement for the final decision.\n\nTreating no-change reviews as a genuine compliance checkpoint, rather than paperwork, helps firms build a defensible evidence base under the Consumer Duty's 'show me, don't tell me' expectations.\n\nTCC is offering a free consultancy review for ongoing services cases, with the first five firms to respond receiving a sample assessment of 100 client files to benchmark current standards.", "wordCount": 384, "keywords": [ "Compliance AI & RegTech", "Suitability, Advice Quality & File Reviews", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Suitability, Advice Quality & File Reviews", "url": "https://tcc.group/blog/solution/outsourced-suitability-reviews/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "No change suitability reviews" } ], "articleSection": [ "Compliance AI & RegTech", "Suitability, Advice Quality & File Reviews" ], "audience": [ { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Compliance and advice quality teams at wealth management and financial advice firms." } ], "citation": [ { "@type": "CreativeWork", "name": "Turning no change reviews into insightful compliance opportunities", "url": "https://tcc.group/blog/2025/10/16/turning-no-change-reviews-into-insightful-compliance-opportunities/", "datePublished": "2025-10-16" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/analysis-perspectives/turning-no-change-reviews-into-insightful-compliance-opportunities/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/turning-no-change-reviews-into-insightful-compliance-opportunities/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What is a 'no change' suitability review?", "acceptedAnswer": { "@type": "Answer", "text": "It is the annual review of a client's advice where the conclusion is that no changes are needed, rather than a new product recommendation." } }, { "@type": "Question", "name": "Why are no change reviews considered high risk?", "acceptedAnswer": { "@type": "Answer", "text": "Because there is no new recommendation to prompt scrutiny, firms can overlook whether a client's circumstances, risk profile and objectives are still aligned with the advice given." } }, { "@type": "Question", "name": "How can AI help with no change reviews?", "acceptedAnswer": { "@type": "Answer", "text": "AI can flag cases needing attention, check for evidence of a meaningful review and help RAG-rate files, while leaving final judgement to the reviewer." } } ] } ] } ``` ### Tech insights: Secrets of AI Agents - URL: https://tcc.group/insights/analysis-perspectives/the-secrets-of-ai-agents/ - Published: 2025-10-14 - Modified: 2026-09-02 **Topic:** History of AI agents Recordsure's CTO Kit Ruparel traces AI agents back to the 1950s and explains the client, parser, reasoner and orchestrator roles that make up today's agentic frameworks, cautioning firms not to overlook what is really happening underneath the 'agentic' label. #### What happened? AI agents are not new. Software agents, autonomous units of software that respond to requests from users or other programs, were first conceptualised in the 1950s and became mainstream in the 1980s through patterns such as distributed systems and microservice architectures. Familiar examples followed, from Microsoft's Clippy in 1996 to Amazon's Alexa Skills Kit in 2015. Today's generative AI community has co-opted the "agentic" term to mean an end-to-end application ecosystem built on large language models, which has caused confusion about what is actually running underneath the label. An agentic framework can be broken down into a small number of roles: a Client that makes a request; a Parser, Reasoner and Orchestrator that interpret it, decide how to respond, and route sub-tasks; and one or more Servers, the "agents" themselves, that register what they can do and respond to requests. #### Why does it matter? The ease of entry into agentic AI is pushing companies to adopt it without looking closely enough at the AI, or other methods, being used underneath the agentic covers. Before large language models, communications between software components relied on formal, fragmented standards such as SOAP, CORBA and OAS. Anthropic's open-sourced MCP now provides a shared way for agents to register skills and communicate using natural language, and Google's emerging A2A protocol looks set to standardise how agentic servers talk to one another. #### Who is affected? Wealth management and compliance teams evaluating or procuring agentic AI tools, and vendors building agentic products, who need a shared understanding of what is genuinely AI-driven inside these systems. #### Key risks - Assuming an "agentic" label automatically means embedded AI, when the underlying logic may be predefined, rule-based software. - Not understanding which components, the parser, reasoner or orchestrator, are AI-driven versus rule-based. - Confusion caused by inconsistent industry use of the terms "agent" and "agentic". #### Actions to take 1. When evaluating an agentic AI tool, ask which components are genuinely AI-driven versus rule-based. 2. Check whether the tool follows an interoperability standard such as MCP, or the emerging A2A protocol. 3. Look past marketing language to understand the actual communications contract and skills each agent registers. #### Wider implications As large language models increasingly act as the shared communications protocol between software components, and standards such as MCP and A2A begin to formalise how agents register skills and talk to each other, understanding these roles will matter more for firms building on or procuring agentic tools. #### Supporting sources - [Tech insights: Secrets of AI Agents](https://tcc.group/blog/2025/10/15/the-secrets-of-ai-agents/) (2025-10-15) #### Want help evaluating your AI agent strategy? Speak to TCC and Recordsure about what is really running inside your AI agent tools, and how to deploy them safely. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/insights/analysis-perspectives/the-secrets-of-ai-agents/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Insights", "item": "https://tcc.group/insights/" }, { "@type": "ListItem", "position": 3, "name": "Tech insights: Secrets of AI Agents", "item": "https://tcc.group/insights/analysis-perspectives/the-secrets-of-ai-agents/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/analysis-perspectives/the-secrets-of-ai-agents/#webpage", "url": "https://tcc.group/insights/analysis-perspectives/the-secrets-of-ai-agents/", "name": "Tech insights: Secrets of AI Agents", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2025-10-15T00:00:00+01:00", "dateModified": "2026-09-02T03:49:07+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/analysis-perspectives/the-secrets-of-ai-agents/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "AnalysisNewsArticle", "@id": "https://tcc.group/insights/analysis-perspectives/the-secrets-of-ai-agents/#article", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/the-secrets-of-ai-agents/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "Tech insights: Secrets of AI Agents", "datePublished": "2025-10-15T00:00:00+01:00", "dateModified": "2026-09-02T03:49:07+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/analysis-perspectives/the-secrets-of-ai-agents/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": null, "description": "Discover why AI agents aren't new, how software agents evolved from 1950s concepts into today's agentic frameworks, and what genuinely matters when choosing the right AI for each task.", "inLanguage": "en-GB", "articleBody": "Recordsure's CTO Kit Ruparel traces AI agents back to the 1950s and explains the client, parser, reasoner and orchestrator roles that make up today's agentic frameworks, cautioning firms not to overlook what is really happening underneath the 'agentic' label.\n\nAI agents are not new. Software agents, autonomous units of software that respond to requests from users or other programs, were first conceptualised in the 1950s and became mainstream in the 1980s through patterns such as distributed systems and microservice architectures. Familiar examples followed, from Microsoft's Clippy in 1996 to Amazon's Alexa Skills Kit in 2015.\n\nToday's generative AI community has co-opted the \"agentic\" term to mean an end-to-end application ecosystem built on large language models, which has caused confusion about what is actually running underneath the label.\n\nAn agentic framework can be broken down into a small number of roles: a Client that makes a request; a Parser, Reasoner and Orchestrator that interpret it, decide how to respond, and route sub-tasks; and one or more Servers, the \"agents\" themselves, that register what they can do and respond to requests.\n\nThe ease of entry into agentic AI is pushing companies to adopt it without looking closely enough at the AI, or other methods, being used underneath the agentic covers.\n\nBefore large language models, communications between software components relied on formal, fragmented standards such as SOAP, CORBA and OAS. Anthropic's open-sourced MCP now provides a shared way for agents to register skills and communicate using natural language, and Google's emerging A2A protocol looks set to standardise how agentic servers talk to one another.\n\nWealth management and compliance teams evaluating or procuring agentic AI tools, and vendors building agentic products, who need a shared understanding of what is genuinely AI-driven inside these systems.\n\n\u2022 Assuming an \"agentic\" label automatically means embedded AI, when the underlying logic may be predefined, rule-based software.\n\u2022 Not understanding which components, the parser, reasoner or orchestrator, are AI-driven versus rule-based.\n\u2022 Confusion caused by inconsistent industry use of the terms \"agent\" and \"agentic\".\n\n1. When evaluating an agentic AI tool, ask which components are genuinely AI-driven versus rule-based.\n2. Check whether the tool follows an interoperability standard such as MCP, or the emerging A2A protocol.\n3. Look past marketing language to understand the actual communications contract and skills each agent registers.\n\nAs large language models increasingly act as the shared communications protocol between software components, and standards such as MCP and A2A begin to formalise how agents register skills and talk to each other, understanding these roles will matter more for firms building on or procuring agentic tools.", "wordCount": 430, "keywords": [ "Compliance AI & RegTech", "Consumer Duty", "Suitability, Advice Quality & File Reviews", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Consumer Duty", "url": "https://tcc.group/blog/solution/consumer-duty/" }, { "@type": "Thing", "name": "Suitability, Advice Quality & File Reviews", "url": "https://tcc.group/blog/solution/outsourced-suitability-reviews/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "History of AI agents" } ], "articleSection": [ "Compliance AI & RegTech", "Consumer Duty", "Suitability, Advice Quality & File Reviews" ], "audience": [ { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Technology and compliance leaders evaluating agentic AI tools before deployment." } ], "citation": [ { "@type": "CreativeWork", "name": "Tech insights: Secrets of AI Agents", "url": "https://tcc.group/blog/2025/10/15/the-secrets-of-ai-agents/", "datePublished": "2025-10-15" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/analysis-perspectives/the-secrets-of-ai-agents/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/the-secrets-of-ai-agents/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "Are AI agents a genuinely new technology?", "acceptedAnswer": { "@type": "Answer", "text": "No. Software agents were first conceptualised in the 1950s, with early consumer examples including Microsoft's Clippy in 1996 and Amazon's Alexa Skills Kit in 2015." } }, { "@type": "Question", "name": "What are the key roles in an agentic framework?", "acceptedAnswer": { "@type": "Answer", "text": "The Client, Parser, Reasoner and Orchestrator interpret and route a request, while the Agentic Server, the agent itself, responds to it." } }, { "@type": "Question", "name": "What is MCP?", "acceptedAnswer": { "@type": "Answer", "text": "The Model Context Protocol, open-sourced by Anthropic, gives agentic systems a shared way to register skills and communicate requests and responses in natural language." } }, { "@type": "Question", "name": "What's the risk of the current AI agent hype?", "acceptedAnswer": { "@type": "Answer", "text": "Firms may adopt agentic tools without examining what is genuinely happening underneath, whether that's AI or simple predefined rules, which can obscure how reliable or explainable the tool really is." } } ] } ] } ``` ### Harnessing AI to Transform Suitability Reviews into Actionable Insight - URL: https://tcc.group/insights/analysis-perspectives/harnessing-ai-to-transform-suitability-reviews-into-actionable-insight/ - Published: 2025-10-12 - Modified: 2026-09-02 **Topic:** Suitability File Reviews TCC's Neil Dethick discusses how embedding specialized AI into advice file reviews delivers robust evidence packs, reduces handling times by 40%, and generates actionable management intelligence. #### What happened? During our 'AI in Compliance' webinar, TCC Operations Director Neil Dethick highlighted a major challenge for wealth managers: extracting meaningful Management Information (MI) from suitability reviews. Survey data from attendees revealed that while a small fraction felt extremely confident in their current file review insights, the vast majority were only somewhat confident or had little faith in their ability to support root cause analysis. This snapshot underscores that firms frequently struggle to transform labor-intensive file audits into the actionable intelligence required to drive actual compliance improvements. #### Why does it matter? Delivering high-quality, 'Marks and Spencer' level suitability reviews has traditionally been limited by high operational costs and slow manual processes. However, embedding specialized AI at both the front and back ends of file reviews transforms this dynamic. At the front end, AI automates the sorting, prioritizing, and retrieval of critical client facts—such as KYC information, product performance, and risk appetites. Human reviewers can then focus exclusively on applying complex judgment regarding advice suitability. At the back end, AI builds comprehensive evidence packs, identifying trends, generating real-time dashboards, and reducing average handling times by over 40%. #### Who is affected? This technological advancement is highly relevant for operations directors, compliance review teams, and financial advice networks looking to optimize their QA processes. #### Key risks - **Uninformative MI:** Generating file review data that tracks superficial metrics (like call-handshake times) but fails to isolate root-cause compliance issues. - **Unmanageable QA Costs:** Facing skyrocketing operational costs and slow review cycles when trying to manually scale suitability testing volumes. - **Over-Reliance on Technology:** Attempting to fully automate suitability reviews, ignoring the essential, irreplaceable role of experienced human judgment. #### Actions to take 1. **Evaluate QA Faith:** Assess your current file review processes to determine if your compliance dashboards accurately support root cause analysis. 2. **Deploy Document AI:** Integrate front-end AI tools to instantly filter and prioritize client documents, surfacing risk and KYC facts for reviewers. 3. **Automate Evidence Support:** Build structured evidence support packs that signpost advisors to the specific documents underpinning each advice aspect. 4. **Combine Man and Machine:** Establish a blended review model that utilizes AI to handle administrative heavy lifting while retaining human experts for suitability judgments. #### Wider implications By blending technology with human expertise, compliance leaders can transition suitability reviews from a reactive cost-center into a proactive strategic lever that continuously elevates advice quality. #### Recommendations Firms should take advantage of TCC's complimentary business-as-usual analysis to review up to 100 client files from 2025 and receive a comprehensive board playback report. #### Supporting sources - [Harnessing AI to transform suitability reviews into actionable insight](https://tcc.group/blog/2025/10/13/harnessing-ai-to-transform-suitability-reviews-into-actionable-insight/) (2025-10-13) #### Ready to cut file review handling times by 40%? Secure a complimentary compliance analysis of up to 100 client files and receive a comprehensive, board-ready root-cause report from our team. [Book your review](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory 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"@id": "https://tcc.group/insights/analysis-perspectives/harnessing-ai-to-transform-suitability-reviews-into-actionable-insight/#article", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/harnessing-ai-to-transform-suitability-reviews-into-actionable-insight/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "Harnessing AI to Transform Suitability Reviews into Actionable Insight", "datePublished": "2025-10-13T00:00:00+01:00", "dateModified": "2026-09-02T03:47:48+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/analysis-perspectives/harnessing-ai-to-transform-suitability-reviews-into-actionable-insight/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/8352933e709047c08b1cd09e243178ca/thumbnail-1024-65012bfe895d528dc5760f19cd62db94b6a1f3b4c5a4dbe278e87fbb364cbce5.jpg", "description": "How can wealth managers transform suitability reviews from a cost-center into a strategic asset? Discover how blending predictive AI with human judgment can cut file review times by 40% and produce superior MI.", "inLanguage": "en-GB", "articleBody": "TCC's Neil Dethick discusses how embedding specialized AI into advice file reviews delivers robust evidence packs, reduces handling times by 40%, and generates actionable management intelligence.\n\nDuring our 'AI in Compliance' webinar, TCC Operations Director Neil Dethick highlighted a major challenge for wealth managers: extracting meaningful Management Information (MI) from suitability reviews. Survey data from attendees revealed that while a small fraction felt extremely confident in their current file review insights, the vast majority were only somewhat confident or had little faith in their ability to support root cause analysis.\n\nThis snapshot underscores that firms frequently struggle to transform labor-intensive file audits into the actionable intelligence required to drive actual compliance improvements.\n\nDelivering high-quality, 'Marks and Spencer' level suitability reviews has traditionally been limited by high operational costs and slow manual processes. However, embedding specialized AI at both the front and back ends of file reviews transforms this dynamic.\n\nAt the front end, AI automates the sorting, prioritizing, and retrieval of critical client facts\u2014such as KYC information, product performance, and risk appetites. Human reviewers can then focus exclusively on applying complex judgment regarding advice suitability. At the back end, AI builds comprehensive evidence packs, identifying trends, generating real-time dashboards, and reducing average handling times by over 40%.\n\nThis technological advancement is highly relevant for operations directors, compliance review teams, and financial advice networks looking to optimize their QA processes.\n\n\u2022 Uninformative MI: Generating file review data that tracks superficial metrics (like call-handshake times) but fails to isolate root-cause compliance issues.\n\u2022 Unmanageable QA Costs: Facing skyrocketing operational costs and slow review cycles when trying to manually scale suitability testing volumes.\n\u2022 Over-Reliance on Technology: Attempting to fully automate suitability reviews, ignoring the essential, irreplaceable role of experienced human judgment.\n\n1. Evaluate QA Faith: Assess your current file review processes to determine if your compliance dashboards accurately support root cause analysis.\n2. Deploy Document AI: Integrate front-end AI tools to instantly filter and prioritize client documents, surfacing risk and KYC facts for reviewers.\n3. Automate Evidence Support: Build structured evidence support packs that signpost advisors to the specific documents underpinning each advice aspect.\n4. Combine Man and Machine: Establish a blended review model that utilizes AI to handle administrative heavy lifting while retaining human experts for suitability judgments.\n\nBy blending technology with human expertise, compliance leaders can transition suitability reviews from a reactive cost-center into a proactive strategic lever that continuously elevates advice quality.\n\nFirms should take advantage of TCC's complimentary business-as-usual analysis to review up to 100 client files from 2025 and receive a comprehensive board playback report.", "wordCount": 428, "keywords": [ "Compliance AI & RegTech", "Suitability, Advice Quality & File Reviews", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Suitability, Advice Quality & File Reviews", "url": "https://tcc.group/blog/solution/outsourced-suitability-reviews/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Suitability File Reviews" } ], "articleSection": [ "Compliance AI & RegTech", "Suitability, Advice Quality & File Reviews" ], "audience": [ { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Operations directors, compliance managers, and wealth advisory leaders." } ], "citation": [ { "@type": "CreativeWork", "name": "Harnessing AI to transform suitability reviews into actionable insight", "url": "https://tcc.group/blog/2025/10/13/harnessing-ai-to-transform-suitability-reviews-into-actionable-insight/", "datePublished": "2025-10-13" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/analysis-perspectives/harnessing-ai-to-transform-suitability-reviews-into-actionable-insight/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/harnessing-ai-to-transform-suitability-reviews-into-actionable-insight/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "Why do traditional suitability reviews fail to deliver actionable MI?", "acceptedAnswer": { "@type": "Answer", "text": "They rely on fragmented, manual reviews that record flat compliance scores rather than analyzing underlying trends, findings, and systemic root causes." } }, { "@type": "Question", "name": "How does front-end AI assist human file reviewers?", "acceptedAnswer": { "@type": "Answer", "text": "It automatically documents, structures, and highlights essential facts like risk tolerance and KYC details, allowing humans to focus solely on suitability judgment." } }, { "@type": "Question", "name": "Can AI completely replace human suitability reviewers?", "acceptedAnswer": { "@type": "Answer", "text": "No. Human judgement is irreplaceable for evaluating complex financial advice. AI serves as a powerful enabler to streamline workflows, not a substitute." } } ] } ] } ``` ### What the FCA’s new motor finance redress scheme means for you - URL: https://tcc.group/insights/analysis-perspectives/what-the-fcas-new-motor-finance-redress-scheme-means-for-you/ - Published: 2025-10-09 - Modified: 2026-09-02 **Topic:** Motor finance redress readiness TCC's webinar with Momenta and Recordsure unpacked the FCA's motor finance redress consultation, including live poll data on industry sentiment and readiness. The panel set out the scope, timelines and preparation firms need before the scheme launches in early 2026. #### What happened? The FCA’s consultation on the motor finance redress scheme, published on 7 October, set out the scope, methodology and expectations that will shape the industry’s response. TCC hosted a webinar with Momenta and Recordsure, featuring Chief Product and Commercial Officer Garry Evans and Momenta UK’s Head of Operations Mike Morris, to examine the consultation, the operational realities firms face and how to prepare. A live poll found 57% of attendees felt the consultation landed as expected, 29% found it worse than anticipated and 14% thought it was better. #### Why does it matter? The scheme will cover all discretionary commission arrangements and other high-commission models, applying to agreements dating back as far as 2007, with firms expected to locate, verify and analyse data that may be nearly two decades old. The FCA’s own estimates put operational costs at £2.8 billion, excluding redress payments themselves, equating to roughly £240 per agreement across the 11.7 million customers thought likely to opt in. Strict timelines mean firms must contact existing complainants within three months of launch, reach all other affected customers within six months, and close the complaint window after twelve months. #### Who is affected? Motor finance lenders and brokers with discretionary commission arrangements or exclusive dealer relationships are directly in scope, along with any firm holding agreements dating back to 2007. Operational, data and complaints teams face the most immediate pressure, since manual intervention will still be needed for legacy data retrieval, tracing customers and handling deceased estates. #### Key risks - Only half of firms polled had reviewed and verified their data availability, and a third had begun identifying in-scope customers. - Just 17% had developed a tracing and contact strategy, and none reported systems ready to apply redress calculations automatically. - Half of respondents had not yet started any preparation, despite the FCA intending to launch the scheme in early 2026. #### Actions to take 1. Assess the completeness, accessibility and quality of data going back to 2007. 2. Design tracing and communication processes that can reach affected customers within the required timeframes. 3. Balance automation with manual review, supported by quality assurance and oversight. 4. Model potential exposure under the FCA’s proposed redress calculation to plan financial and operational response. #### Wider implications The FCA has positioned the scheme as straightforward and automatable, but the scale of the data challenge, agreements up to two decades old and 11.7 million potential customers, tells a more complex story. A parallel national advertising campaign is expected to generate significant enquiry volumes before the scheme formally begins, adding further pressure on firms that have not yet prepared. #### Recommendations Firms that invest in early preparation will be in a far stronger position once the final rules are confirmed, starting with understanding what data they hold and where the gaps are. Ensure contact centres and back-office teams are equipped for higher complaint volumes ahead of the scheme’s launch, rather than scaling up once it is already live. #### Supporting sources - [What the FCA’s new motor finance redress scheme means for you](https://tcc.group/blog/2025/10/10/what-the-fcas-new-motor-finance-redress-scheme-means-for-you/) (2025-10-10) #### Is your firm ready for motor finance redress? Get in touch to discuss your data readiness, remediation approach and complaint-handling capacity. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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"https://tcc.group/insights/analysis-perspectives/what-the-fcas-new-motor-finance-redress-scheme-means-for-you/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/analysis-perspectives/what-the-fcas-new-motor-finance-redress-scheme-means-for-you/#webpage", "url": "https://tcc.group/insights/analysis-perspectives/what-the-fcas-new-motor-finance-redress-scheme-means-for-you/", "name": "What the FCA\u2019s new motor finance redress scheme means for you", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2025-10-10T00:00:00+01:00", "dateModified": "2026-09-02T03:49:11+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/analysis-perspectives/what-the-fcas-new-motor-finance-redress-scheme-means-for-you/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "AnalysisNewsArticle", "@id": "https://tcc.group/insights/analysis-perspectives/what-the-fcas-new-motor-finance-redress-scheme-means-for-you/#article", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/what-the-fcas-new-motor-finance-redress-scheme-means-for-you/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "What the FCA\u2019s new motor finance redress scheme means for you", "datePublished": "2025-10-10T00:00:00+01:00", "dateModified": "2026-09-02T03:49:11+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/analysis-perspectives/what-the-fcas-new-motor-finance-redress-scheme-means-for-you/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/9085f7185b6b4ddd98f321d7950be22f/thumbnail-1024-a47f08ca2f83ebe3cc6df717c1fd05372d0401be61e480a09b71549e11d25056.jpg", "description": "Get the key findings from TCC's motor finance redress webinar with Momenta and Recordsure, including live poll results, the FCA's \u00a32.8 billion cost estimate, and why early preparation of data and processes will determine how ready your firm is.", "inLanguage": "en-GB", "articleBody": "TCC's webinar with Momenta and Recordsure unpacked the FCA's motor finance redress consultation, including live poll data on industry sentiment and readiness. The panel set out the scope, timelines and preparation firms need before the scheme launches in early 2026.\n\nThe FCA\u2019s consultation on the motor finance redress scheme, published on 7 October, set out the scope, methodology and expectations that will shape the industry\u2019s response.\n\nTCC hosted a webinar with Momenta and Recordsure, featuring Chief Product and Commercial Officer Garry Evans and Momenta UK\u2019s Head of Operations Mike Morris, to examine the consultation, the operational realities firms face and how to prepare.\n\nA live poll found 57% of attendees felt the consultation landed as expected, 29% found it worse than anticipated and 14% thought it was better.\n\nThe scheme will cover all discretionary commission arrangements and other high-commission models, applying to agreements dating back as far as 2007, with firms expected to locate, verify and analyse data that may be nearly two decades old.\n\nThe FCA\u2019s own estimates put operational costs at \u00a32.8 billion, excluding redress payments themselves, equating to roughly \u00a3240 per agreement across the 11.7 million customers thought likely to opt in.\n\nStrict timelines mean firms must contact existing complainants within three months of launch, reach all other affected customers within six months, and close the complaint window after twelve months.\n\nMotor finance lenders and brokers with discretionary commission arrangements or exclusive dealer relationships are directly in scope, along with any firm holding agreements dating back to 2007.\n\nOperational, data and complaints teams face the most immediate pressure, since manual intervention will still be needed for legacy data retrieval, tracing customers and handling deceased estates.\n\n\u2022 Only half of firms polled had reviewed and verified their data availability, and a third had begun identifying in-scope customers.\n\u2022 Just 17% had developed a tracing and contact strategy, and none reported systems ready to apply redress calculations automatically.\n\u2022 Half of respondents had not yet started any preparation, despite the FCA intending to launch the scheme in early 2026.\n\n1. Assess the completeness, accessibility and quality of data going back to 2007.\n2. Design tracing and communication processes that can reach affected customers within the required timeframes.\n3. Balance automation with manual review, supported by quality assurance and oversight.\n4. Model potential exposure under the FCA\u2019s proposed redress calculation to plan financial and operational response.\n\nThe FCA has positioned the scheme as straightforward and automatable, but the scale of the data challenge, agreements up to two decades old and 11.7 million potential customers, tells a more complex story.\n\nA parallel national advertising campaign is expected to generate significant enquiry volumes before the scheme formally begins, adding further pressure on firms that have not yet prepared.\n\nFirms that invest in early preparation will be in a far stronger position once the final rules are confirmed, starting with understanding what data they hold and where the gaps are.\n\nEnsure contact centres and back-office teams are equipped for higher complaint volumes ahead of the scheme\u2019s launch, rather than scaling up once it is already live.", "wordCount": 513, "keywords": [ "Complaints & Claims Handling", "Redress & Remediation", "Regulatory Change & Transformation", "Lending & Consumer Credit", "Motor Finance" ], "about": [ { "@type": "Thing", "name": "Complaints & Claims Handling", "url": "https://tcc.group/blog/solution/complaints-claims-handling/" }, { "@type": "Thing", "name": "Redress & Remediation", "url": "https://tcc.group/blog/solution/redress-and-remediation/" }, { "@type": "Thing", "name": "Regulatory Change & Transformation", "url": "https://tcc.group/blog/solution/regulatory-change-transformation/" }, { "@type": "Thing", "name": "Lending & Consumer Credit", "url": "https://tcc.group/blog/sector/lending-consumer-credit/" }, { "@type": "Thing", "name": "Motor Finance", "url": "https://tcc.group/blog/sector/motor-finance/" }, { "@type": "Thing", "name": "Motor finance redress readiness" } ], "articleSection": [ "Complaints & Claims Handling", "Redress & Remediation", "Regulatory Change & Transformation" ], "audience": [ { "@type": "Audience", "audienceType": "Lending & Consumer Credit" }, { "@type": "Audience", "audienceType": "Motor Finance" }, { "@type": "Audience", "audienceType": "Motor finance lenders, brokers and their operations, data and complaints teams." } ], "citation": [ { "@type": "CreativeWork", "name": "What the FCA\u2019s new motor finance redress scheme means for you", "url": "https://tcc.group/blog/2025/10/10/what-the-fcas-new-motor-finance-redress-scheme-means-for-you/", "datePublished": "2025-10-10" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/analysis-perspectives/what-the-fcas-new-motor-finance-redress-scheme-means-for-you/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/what-the-fcas-new-motor-finance-redress-scheme-means-for-you/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "How far back do agreements in scope go?", "acceptedAnswer": { "@type": "Answer", "text": "The scheme applies to agreements dating back as far as 2007." } }, { "@type": "Question", "name": "How much does the FCA estimate the scheme will cost to operate?", "acceptedAnswer": { "@type": "Answer", "text": "The FCA's own estimates suggest operational costs of \u00a32.8 billion, excluding redress payments, or roughly \u00a3240 per agreement across 11.7 million customers thought likely to opt in." } }, { "@type": "Question", "name": "How prepared were firms at the time of the webinar?", "acceptedAnswer": { "@type": "Answer", "text": "Preparedness varied widely; half of poll participants had verified their data availability, but half had not yet started any preparation and none had automated redress calculations ready." } }, { "@type": "Question", "name": "What are the key timelines firms need to meet?", "acceptedAnswer": { "@type": "Answer", "text": "Firms must contact existing complainants within three months of launch, reach all other affected customers within six months, and the complaint window closes after twelve months." } } ] } ] } ``` ### Attivo deploys Recordsure AI technology to evidence compliance - URL: https://tcc.group/insights/press-releases/attivo-deploys-recordsures-ai-technology-to-evidence-its-ongoing-advice-compliance-and-cut-file-review-costs/ - Published: 2025-10-08 - Modified: 2026-09-02 **Topic:** AI-Led File Review Advice firm Attivo has implemented Recordsure's predictive AI technology to review ongoing-advice files, cutting cost per case review by 40% within six months while improving suitability outcomes. #### What happened? Attivo, an independent financial advice firm, has implemented Recordsure's predictive AI technology to enhance its ongoing-advice compliance, support consistent service delivery and reduce the cost of file reviews. The technology analyses Attivo's data and flags potentially non-compliant cases for human review, freeing skilled staff to concentrate on assessing suitability for higher-risk cases rather than reviewing every document in full. Recordsure combines AI technology with the regulatory expertise of its sister company, TCC, whose compliance practitioners worked with Attivo to align the solution to its practices. Within the first six months, Attivo reduced first-time unclear suitability ratings to less than 10%, cut cost per case review by 40% on average, and completed over 1,000 file reviews with an average turnaround of two days. #### Why does it matter? The results show that AI-assisted review can support Consumer Duty ongoing-advice obligations without simply adding cost or headcount, provided it is paired with genuine compliance expertise rather than treated as a standalone tool. Jo French, CEO at Attivo, said the firm now has confidence that 100% of its files have been checked, giving assurance on both quality of outcome and compliance. #### Who is affected? Financial advice firms carrying out ongoing-advice reviews at scale, particularly those balancing the cost of file checking against the need for consistent, evidenced suitability outcomes. #### Key risks - Manual, document-by-document file review does not scale as ongoing-advice volumes grow. - Unclear suitability ratings weaken the evidence base firms need for Consumer Duty. - Rising review costs can squeeze the resource available for genuinely high-risk cases. #### Actions to take 1. Assess whether AI-led triage could focus skilled reviewer time on higher-risk cases. 2. Pair any AI tool with compliance expertise to align it to your firm's suitability standards. 3. Track outcome measures such as unclear-rating rates, turnaround time and cost per case. #### Wider implications Joe Norburn, CEO of TCC and Recordsure, said the collaboration demonstrates the real value AI can bring to financial advice firms when it is combined with compliance expertise, rather than deployed as a technology exercise on its own. #### Recommendations Firms considering AI-assisted file review should look for a solution that combines predictive technology with practitioner-led compliance expertise, and measure results against clear metrics such as unclear-rating rates, turnaround time and cost per case. #### Supporting sources - [Attivo deploys Recordsure AI technology to evidence compliance](https://tcc.group/blog/2025/10/09/attivo-deploys-recordsures-ai-technology-to-evidence-its-ongoing-advice-compliance-and-cut-file-review-costs/) (2025-10-09) #### Want AI-led compliance results like Attivo's? Talk to TCC and Recordsure about how AI-led file review could reduce your review costs while strengthening ongoing-advice compliance. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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"https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/d3dce8f82d054d0195f5e9ed7e185854/thumbnail-1024-486e38dce2eda820f7b4148a957dab9f3fb5eb37d363d7711b8cf41fc97239ba.jpg", "description": "See how one advice firm cut ongoing-advice file review costs by 40% and lifted quality using Recordsure's AI, paired with TCC's compliance expertise, within six months.", "inLanguage": "en-GB", "articleBody": "Advice firm Attivo has implemented Recordsure's predictive AI technology to review ongoing-advice files, cutting cost per case review by 40% within six months while improving suitability outcomes.\n\nAttivo, an independent financial advice firm, has implemented Recordsure's predictive AI technology to enhance its ongoing-advice compliance, support consistent service delivery and reduce the cost of file reviews. The technology analyses Attivo's data and flags potentially non-compliant cases for human review, freeing skilled staff to concentrate on assessing suitability for higher-risk cases rather than reviewing every document in full.\n\nRecordsure combines AI technology with the regulatory expertise of its sister company, TCC, whose compliance practitioners worked with Attivo to align the solution to its practices. Within the first six months, Attivo reduced first-time unclear suitability ratings to less than 10%, cut cost per case review by 40% on average, and completed over 1,000 file reviews with an average turnaround of two days.\n\nThe results show that AI-assisted review can support Consumer Duty ongoing-advice obligations without simply adding cost or headcount, provided it is paired with genuine compliance expertise rather than treated as a standalone tool.\n\nJo French, CEO at Attivo, said the firm now has confidence that 100% of its files have been checked, giving assurance on both quality of outcome and compliance.\n\nFinancial advice firms carrying out ongoing-advice reviews at scale, particularly those balancing the cost of file checking against the need for consistent, evidenced suitability outcomes.\n\n\u2022 Manual, document-by-document file review does not scale as ongoing-advice volumes grow.\n\u2022 Unclear suitability ratings weaken the evidence base firms need for Consumer Duty.\n\u2022 Rising review costs can squeeze the resource available for genuinely high-risk cases.\n\n1. Assess whether AI-led triage could focus skilled reviewer time on higher-risk cases.\n2. Pair any AI tool with compliance expertise to align it to your firm's suitability standards.\n3. Track outcome measures such as unclear-rating rates, turnaround time and cost per case.\n\nJoe Norburn, CEO of TCC and Recordsure, said the collaboration demonstrates the real value AI can bring to financial advice firms when it is combined with compliance expertise, rather than deployed as a technology exercise on its own.\n\nFirms considering AI-assisted file review should look for a solution that combines predictive technology with practitioner-led compliance expertise, and measure results against clear metrics such as unclear-rating rates, turnaround time and cost per case.", "wordCount": 388, "keywords": [ "Compliance AI & RegTech", "Suitability, Advice Quality & File Reviews", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Suitability, Advice Quality & File Reviews", "url": "https://tcc.group/blog/solution/outsourced-suitability-reviews/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "AI-Led File Review" } ], "articleSection": [ "Compliance AI & RegTech", "Suitability, Advice Quality & File Reviews" ], "audience": [ { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Financial advice firms looking to control the cost and consistency of ongoing-advice file reviews." } ], "citation": [ { "@type": "CreativeWork", "name": "Attivo deploys Recordsure AI technology to evidence compliance", "url": "https://tcc.group/blog/2025/10/09/attivo-deploys-recordsures-ai-technology-to-evidence-its-ongoing-advice-compliance-and-cut-file-review-costs/", "datePublished": "2025-10-09" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/press-releases/attivo-deploys-recordsures-ai-technology-to-evidence-its-ongoing-advice-compliance-and-cut-file-review-costs/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/press-releases/attivo-deploys-recordsures-ai-technology-to-evidence-its-ongoing-advice-compliance-and-cut-file-review-costs/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What results did Attivo achieve with Recordsure AI?", "acceptedAnswer": { "@type": "Answer", "text": "Within six months, Attivo reduced first-time unclear suitability ratings to less than 10%, cut cost per case review by 40% on average, and completed over 1,000 file reviews with an average turnaround of two days." } }, { "@type": "Question", "name": "How does Recordsure AI work alongside human reviewers?", "acceptedAnswer": { "@type": "Answer", "text": "It analyses advice data and flags potentially non-compliant cases for human review, allowing skilled staff to focus on assessing suitability for higher-risk cases rather than reviewing every file in full." } }, { "@type": "Question", "name": "Who is behind the Recordsure AI solution?", "acceptedAnswer": { "@type": "Answer", "text": "Recordsure combines AI technology with the regulatory expertise of its sister company, TCC, whose compliance practitioners worked with Attivo to align the solution to its practices." } } ] } ] } ``` ### Turning suitability reviews into a strategic advantage - URL: https://tcc.group/insights/analysis-perspectives/turning-suitability-reviews-into-a-strategic-advantage/ - Published: 2025-10-07 - Modified: 2026-09-02 **Topic:** Suitability review benchmarks A TCC and Recordsure webinar poll found many firms rework a significant share of advice files after suitability review, and sets out the FCA's expectations on risk-based sampling. #### What happened? TCC and Recordsure launched an 'AI for compliance' webinar series with a session on suitability reviews. A live poll found that 42% of firms needed to rework between 10% and 20% of advice files after a suitability review, 29% reworked 20 to 30%, and 29% reworked fewer than 10%. David Boyhan, TCC's Technical Director, set out the FCA's risk-based approach to sampling, referencing comments from Lucy Castledine, the FCA's Director of Consumer Investments, at the PIMFA conference. #### Why does it matter? Even where checks and balances exist, many cases initially carry an unclear rating, pulling advisers away from client work and delaying evidence that advice was suitable. The FCA expects firms to sample around 10% of files, with higher volumes for higher-risk areas such as new advisers or complex products like drawdown and VCTs, and for both new and ongoing advice to be reviewed. #### Who is affected? Compliance and paraplanning teams responsible for file review, and advisers whose files are rated unclear or unsuitable and need a route back to suitability. #### Key risks - Persistently high rework rates, with some firms historically seeing over 30% of cases need revisiting. - Sampling models that focus only on new advice and overlook ongoing advice reviews. - Feedback that is reported but not acted on, so it fails to change adviser behaviour. #### Actions to take 1. Apply a risk-based sampling model, reviewing around 10% of files with higher volumes for higher-risk areas. 2. Review both new business and ongoing advice files for suitability, not just new recommendations. 3. Give advisers a clear, actionable pathway back to suitability for every file rated unclear or unsuitable. 4. Use case clinics, workshops and training to turn review findings into behavioural change. #### Wider implications Firms working with TCC on this approach have seen their right-first-time rates improve from the low 60s to nearly 90% over ten months, showing that structured feedback can drive lasting change when advisers act on it. #### Recommendations Combine risk-based sampling with a collaborative review process: case clinics, best-practice workshops and commentary on Consumer Duty outcomes give advisers and paraplanners the context they need to improve, not just a rating. #### Supporting sources - [Turning suitability reviews into a strategic advantage](https://tcc.group/blog/2025/10/08/turning-suitability-reviews-into-a-strategic-advantage/) (2025-10-08) #### Want to cut your rework rate? Talk to us about building a suitability review process that reduces rework and improves client outcomes. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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risk-based sampling, and how one firm lifted its right-first-time rate to nearly 90%.", "inLanguage": "en-GB", "articleBody": "A TCC and Recordsure webinar poll found many firms rework a significant share of advice files after suitability review, and sets out the FCA's expectations on risk-based sampling.\n\nTCC and Recordsure launched an 'AI for compliance' webinar series with a session on suitability reviews. A live poll found that 42% of firms needed to rework between 10% and 20% of advice files after a suitability review, 29% reworked 20 to 30%, and 29% reworked fewer than 10%.\n\nDavid Boyhan, TCC's Technical Director, set out the FCA's risk-based approach to sampling, referencing comments from Lucy Castledine, the FCA's Director of Consumer Investments, at the PIMFA conference.\n\nEven where checks and balances exist, many cases initially carry an unclear rating, pulling advisers away from client work and delaying evidence that advice was suitable.\n\nThe FCA expects firms to sample around 10% of files, with higher volumes for higher-risk areas such as new advisers or complex products like drawdown and VCTs, and for both new and ongoing advice to be reviewed.\n\nCompliance and paraplanning teams responsible for file review, and advisers whose files are rated unclear or unsuitable and need a route back to suitability.\n\n\u2022 Persistently high rework rates, with some firms historically seeing over 30% of cases need revisiting.\n\u2022 Sampling models that focus only on new advice and overlook ongoing advice reviews.\n\u2022 Feedback that is reported but not acted on, so it fails to change adviser behaviour.\n\n1. Apply a risk-based sampling model, reviewing around 10% of files with higher volumes for higher-risk areas.\n2. Review both new business and ongoing advice files for suitability, not just new recommendations.\n3. Give advisers a clear, actionable pathway back to suitability for every file rated unclear or unsuitable.\n4. Use case clinics, workshops and training to turn review findings into behavioural change.\n\nFirms working with TCC on this approach have seen their right-first-time rates improve from the low 60s to nearly 90% over ten months, showing that structured feedback can drive lasting change when advisers act on it.\n\nCombine risk-based sampling with a collaborative review process: case clinics, best-practice workshops and commentary on Consumer Duty outcomes give advisers and paraplanners the context they need to improve, not just a rating.", "wordCount": 369, "keywords": [ "Compliance AI & RegTech", "Consumer Duty", "Suitability, Advice Quality & File Reviews", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Consumer Duty", "url": "https://tcc.group/blog/solution/consumer-duty/" }, { "@type": "Thing", "name": "Suitability, Advice Quality & File Reviews", "url": "https://tcc.group/blog/solution/outsourced-suitability-reviews/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Suitability review benchmarks" } ], "articleSection": [ "Compliance AI & RegTech", "Consumer Duty", "Suitability, Advice Quality & File Reviews" ], "audience": [ { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Compliance, advice quality and paraplanning teams at wealth management and financial advice firms." } ], "citation": [ { "@type": "CreativeWork", "name": "Turning suitability reviews into a strategic advantage", "url": "https://tcc.group/blog/2025/10/08/turning-suitability-reviews-into-a-strategic-advantage/", "datePublished": "2025-10-08" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/analysis-perspectives/turning-suitability-reviews-into-a-strategic-advantage/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/turning-suitability-reviews-into-a-strategic-advantage/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "How many advice files typically need rework after a suitability review?", "acceptedAnswer": { "@type": "Answer", "text": "In TCC and Recordsure's poll, 42% of firms reworked between 10% and 20% of files, 29% reworked 20 to 30%, and 29% reworked fewer than 10%." } }, { "@type": "Question", "name": "What does the FCA expect on risk-based sampling?", "acceptedAnswer": { "@type": "Answer", "text": "The FCA expects firms to focus monitoring on higher-risk interactions, with a general benchmark of around 10% of files sampled and higher volumes for higher-risk areas such as new advisers or complex products." } }, { "@type": "Question", "name": "What results has TCC's review process delivered?", "acceptedAnswer": { "@type": "Answer", "text": "Firms working with TCC over the past ten months have seen their right-first-time rates improve from the low 60s to nearly 90%." } } ] } ] } ``` ### 14m unfair motor loans due compensation under proposed scheme - URL: https://tcc.group/insights/analysis-perspectives/fca-motor-finance-redress-scheme/ - Published: 2025-10-06 - Modified: 2026-09-02 **Topic:** Proposed Motor Finance Redress The FCA is consulting on a massive, industry-wide compensation scheme for up to 14.2 million motor finance agreements, carrying an estimated £8.2 billion redress liability. #### What happened? The Financial Conduct Authority (FCA) has issued an update on its proposed motor finance consumer redress scheme. The regulator wants to establish an industry-wide compensation framework to reimburse motor finance customers who were treated unfairly between April 2007 and November 2024. The scheme targets cases where lenders paid commissions to brokers or car dealers without adequate disclosure to customers. The proposals estimate that 14.2 million motor finance agreements could be eligible, carrying an estimated redress liability of £8.2bn, potentially rising to £9.7bn with full consumer participation. #### Why does it matter? With average compensation estimated at £700 per agreement, this redress exercise represents one of the largest retail lending liabilities since PPI. The scheme will focus on discretionary commission arrangements (DCAs), high commission structures, or exclusive dealer ties. Crucially, the FCA is consulting on extending the deadline for firms to issue final responses to motor finance complaints to 31 July 2026, with final rules and the official scheme launch expected in early 2026. #### Who is affected? Motor finance providers, banking lenders with automotive portfolios, and car finance brokers are directly affected. #### Key risks Firms face severe risks if they delay their operational preparation: - Massive financial and liquidity strain from unmapped redress liabilities and interest payments. - Inability to manage the expected wave of complaints once the regulatory pause is lifted. - Breaches of complaints-handling timelines leading to further FCA penalties. #### Actions to take Firms must initiate proactive steps immediately during the consultation period: 1. Conduct portfolio modeling to identify and isolate historical agreements containing DCAs or undisclosed commission structures. 2. Cleanse and validate historical credit agreement data to ensure readiness for redress calculations. 3. Join our specialized webinars to understand the legal parameters and structure a defensible operational response. #### Wider implications The scale of this proposed scheme shows a highly interventionist regulator willing to apply sweeping, retrospective redress across retail credit markets. It highlights the absolute necessity of transparent commission disclosure under the Consumer Duty. #### Recommendations We recommend engaging expert advisory support and deploying scalable, tech-enabled complaints-handling systems to manage the impending volume spikes efficiently. #### Supporting sources - [The FCA indicates 14m unfair motor loans due compensation under FCA-proposed scheme](https://tcc.group/blog/2025/10/07/the-fca-indicates-14m-unfair-motor-loans-due-compensation-under-fca-proposed-scheme/) (2025-10-07) #### Are you prepared for the £8.2bn motor finance redress? Contact our motor finance compliance and redress specialists today to model your exposure and prepare a compliant operational framework. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/insights/analysis-perspectives/fca-motor-finance-redress-scheme/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Insights", "item": "https://tcc.group/insights/" }, { "@type": "ListItem", "position": 3, "name": "14m unfair motor loans due compensation under proposed scheme", "item": "https://tcc.group/insights/analysis-perspectives/fca-motor-finance-redress-scheme/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/analysis-perspectives/fca-motor-finance-redress-scheme/#webpage", "url": "https://tcc.group/insights/analysis-perspectives/fca-motor-finance-redress-scheme/", "name": "14m unfair motor loans due compensation under proposed scheme", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2025-10-07T00:00:00+01:00", "dateModified": "2026-09-02T03:47:43+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/analysis-perspectives/fca-motor-finance-redress-scheme/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "AnalysisNewsArticle", "@id": "https://tcc.group/insights/analysis-perspectives/fca-motor-finance-redress-scheme/#article", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/fca-motor-finance-redress-scheme/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "14m unfair motor loans due compensation under proposed scheme", "datePublished": "2025-10-07T00:00:00+01:00", "dateModified": "2026-09-02T03:47:43+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/analysis-perspectives/fca-motor-finance-redress-scheme/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/a1c09a0a1b94442c9f1a7da6cf9514a1/thumbnail-1024-957bdc38222c7cb8205bc6a5ef161c1284864e1f5edc9f828ae22b7eec7e0600.jpg", "description": "The FCA's proposed motor finance redress scheme could impact 14.2 million agreements, with estimated liabilities reaching \u00a38.2 billion. Learn about the key dates, rules, and implications for lenders.", "inLanguage": "en-GB", "articleBody": "The FCA is consulting on a massive, industry-wide compensation scheme for up to 14.2 million motor finance agreements, carrying an estimated \u00a38.2 billion redress liability.\n\nThe Financial Conduct Authority (FCA) has issued an update on its proposed motor finance consumer redress scheme. The regulator wants to establish an industry-wide compensation framework to reimburse motor finance customers who were treated unfairly between April 2007 and November 2024.\n\nThe scheme targets cases where lenders paid commissions to brokers or car dealers without adequate disclosure to customers. 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The scheme will focus on discretionary commission arrangements (DCAs), high commission structures, or exclusive dealer ties.\n\nCrucially, the FCA is consulting on extending the deadline for firms to issue final responses to motor finance complaints to 31 July 2026, with final rules and the official scheme launch expected in early 2026.\n\nMotor finance providers, banking lenders with automotive portfolios, and car finance brokers are directly affected.\n\nFirms face severe risks if they delay their operational preparation:\n\n\u2022 Massive financial and liquidity strain from unmapped redress liabilities and interest payments.\n\u2022 Inability to manage the expected wave of complaints once the regulatory pause is lifted.\n\u2022 Breaches of complaints-handling timelines leading to further FCA penalties.\n\nFirms must initiate proactive steps immediately during the consultation period:\n\n1. Conduct portfolio modeling to identify and isolate historical agreements containing DCAs or undisclosed commission structures.\n2. Cleanse and validate historical credit agreement data to ensure readiness for redress calculations.\n3. Join our specialized webinars to understand the legal parameters and structure a defensible operational response.\n\nThe scale of this proposed scheme shows a highly interventionist regulator willing to apply sweeping, retrospective redress across retail credit markets. It highlights the absolute necessity of transparent commission disclosure under the Consumer Duty.\n\nWe recommend engaging expert advisory support and deploying scalable, tech-enabled complaints-handling systems to manage the impending volume spikes efficiently.", "wordCount": 355, "keywords": [ "Complaints & Claims Handling", "Redress & Remediation", "Regulatory Change & Transformation", "Lending & Consumer Credit", "Motor Finance" ], "about": [ { "@type": "Thing", "name": "Complaints & Claims Handling", "url": "https://tcc.group/blog/solution/complaints-claims-handling/" }, { "@type": "Thing", "name": "Redress & Remediation", "url": "https://tcc.group/blog/solution/redress-and-remediation/" }, { "@type": "Thing", "name": "Regulatory Change & Transformation", "url": "https://tcc.group/blog/solution/regulatory-change-transformation/" }, { "@type": "Thing", "name": "Lending & Consumer Credit", "url": "https://tcc.group/blog/sector/lending-consumer-credit/" }, { "@type": "Thing", "name": "Motor Finance", "url": "https://tcc.group/blog/sector/motor-finance/" }, { "@type": "Thing", "name": "Proposed Motor Finance Redress" } ], "articleSection": [ "Complaints & Claims Handling", "Redress & Remediation", "Regulatory Change & Transformation" ], "audience": [ { "@type": "Audience", "audienceType": "Lending & Consumer Credit" }, { "@type": "Audience", "audienceType": "Motor Finance" }, { "@type": "Audience", "audienceType": "Compliance leads, risk officers, and finance directors in motor finance lenders and automotive brokers." } ], "citation": [ { "@type": "CreativeWork", "name": "The FCA indicates 14m unfair motor loans due compensation under FCA-proposed scheme", "url": "https://tcc.group/blog/2025/10/07/the-fca-indicates-14m-unfair-motor-loans-due-compensation-under-fca-proposed-scheme/", "datePublished": "2025-10-07" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/analysis-perspectives/fca-motor-finance-redress-scheme/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/fca-motor-finance-redress-scheme/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What is the estimated scope and cost of the proposed redress scheme?", "acceptedAnswer": { "@type": "Answer", "text": "The scheme could cover 14.2 million agreements, with an estimated industry redress liability of \u00a38.2 billion and an average compensation of \u00a3700 per case." } }, { "@type": "Question", "name": "Which motor finance agreements are targeted?", "acceptedAnswer": { "@type": "Answer", "text": "Agreements sold between 6 April 2007 and 1 November 2024 involving discretionary commission arrangements (DCAs) or undisclosed high commissions." } } ] } ] } ``` ### Suitability reviews with AI: compliance burden to asset - URL: https://tcc.group/insights/analysis-perspectives/suitability-reviews-with-ai-turning-a-compliance-burden-into-a-business-asset/ - Published: 2025-10-05 - Modified: 2026-09-02 **Topic:** AI-Led Suitability Reviews A TCC and Recordsure webinar found that most unclear suitability ratings stem from insufficient rationale rather than fact-finding gaps, and argued that AI-driven feedback can turn reviews into a source of adviser development. #### What happened? TCC and Recordsure opened their AI for compliance webinar series with a session on suitability reviews, hosted by Recordsure's Chief Product and Commercial Officer, Garry Evans, and joined by TCC's Technical Director, David Boyhan, and Operations Director, Neil Dethick. A live poll asked attendees where they saw the root cause of unclear suitability ratings: 38% pointed to insufficient or contradictory fact-finding and attitude-to-risk determination, while 62% pointed to insufficient rationale for the recommendation given. Neil Dethick said this matched his team's day-to-day experience, with files often falling short because advisers had not fully explained their reasoning, discounted alternatives or covered points such as taxation. The panel discussed how suitability checks are often treated as an administrative, tick-box exercise, with advisers receiving unclear ratings but little constructive feedback, which can create friction between advisers and compliance colleagues. #### Why does it matter? When files are repeatedly returned as unclear without constructive guidance, advisers spend unprofitable time on rework instead of serving clients, while the underlying issue often goes unresolved and recurs in future cases. A narrow focus on individual cases or products can also mean firms miss recurring, systemic weaknesses, and risk-based sampling that is too small or too narrow tends to produce results that offer little support for genuine root cause analysis. #### Who is affected? Compliance and quality assurance teams responsible for rating suitability files, and the advisers whose recommendations are reviewed. #### Key risks - Suitability ratings applied without detailed feedback, leaving advisers unclear why a file was marked unclear or unsuitable. - A narrow, case-by-case review focus that misses recurring, thematic weaknesses. - Risk-based sampling that is too small or too narrowly scoped to support meaningful root cause analysis. - Adviser rework on remediated files, which adds unprofitable time without addressing the underlying cause. #### Actions to take 1. Review whether unclear suitability ratings come with enough detail for advisers to understand and correct the issue. 2. Widen review sampling and thematic analysis to capture recurring, systemic weaknesses. 3. Use thematic analysis of review data to identify whether gaps sit mainly in fact-finding or in the rationale provided for recommendations. #### Wider implications TCC argues that combining AI-driven insights with expert oversight can turn suitability reviews from a source of friction into a source of learning, giving advisers clear, actionable feedback on what went wrong and why. #### Recommendations Firms should treat suitability review outcomes as a tool for improving adviser performance and customer outcomes, rather than only as a compliance gatekeeping exercise, and should use thematic analysis to target training and process changes at the root cause. #### Supporting sources - [Suitability reviews with AI: compliance burden to asset | TCC](https://tcc.group/blog/2025/10/06/suitability-reviews-with-ai-turning-a-compliance-burden-into-a-business-asset/) (2025-10-06) #### Want more right-first-time suitability outcomes? Talk to TCC and Recordsure about turning suitability reviews into a source of adviser development. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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"https://tcc.group/insights/analysis-perspectives/suitability-reviews-with-ai-turning-a-compliance-burden-into-a-business-asset/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/analysis-perspectives/suitability-reviews-with-ai-turning-a-compliance-burden-into-a-business-asset/#webpage", "url": "https://tcc.group/insights/analysis-perspectives/suitability-reviews-with-ai-turning-a-compliance-burden-into-a-business-asset/", "name": "Suitability reviews with AI: compliance burden to asset", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2025-10-06T00:00:00+01:00", "dateModified": "2026-09-02T03:48:03+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/analysis-perspectives/suitability-reviews-with-ai-turning-a-compliance-burden-into-a-business-asset/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "AnalysisNewsArticle", "@id": "https://tcc.group/insights/analysis-perspectives/suitability-reviews-with-ai-turning-a-compliance-burden-into-a-business-asset/#article", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/suitability-reviews-with-ai-turning-a-compliance-burden-into-a-business-asset/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "Suitability reviews with AI: compliance burden to asset", "datePublished": "2025-10-06T00:00:00+01:00", "dateModified": "2026-09-02T03:48:03+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/analysis-perspectives/suitability-reviews-with-ai-turning-a-compliance-burden-into-a-business-asset/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/7895729736c149c9b4aa6ea4f1c5b1c9/thumbnail-1024-7fcf3eda2393af1d60e1e7a180f560542f5954a57d32e89b5cf525ff93b9d8d9.jpg", "description": "TCC and Recordsure's webinar poll found most suitability files are rated unclear due to insufficient rationale, and set out how AI-driven feedback can turn reviews into a source of improvement.", "inLanguage": "en-GB", "articleBody": "A TCC and Recordsure webinar found that most unclear suitability ratings stem from insufficient rationale rather than fact-finding gaps, and argued that AI-driven feedback can turn reviews into a source of adviser development.\n\nTCC and Recordsure opened their AI for compliance webinar series with a session on suitability reviews, hosted by Recordsure's Chief Product and Commercial Officer, Garry Evans, and joined by TCC's Technical Director, David Boyhan, and Operations Director, Neil Dethick.\n\nA live poll asked attendees where they saw the root cause of unclear suitability ratings: 38% pointed to insufficient or contradictory fact-finding and attitude-to-risk determination, while 62% pointed to insufficient rationale for the recommendation given. Neil Dethick said this matched his team's day-to-day experience, with files often falling short because advisers had not fully explained their reasoning, discounted alternatives or covered points such as taxation.\n\nThe panel discussed how suitability checks are often treated as an administrative, tick-box exercise, with advisers receiving unclear ratings but little constructive feedback, which can create friction between advisers and compliance colleagues.\n\nWhen files are repeatedly returned as unclear without constructive guidance, advisers spend unprofitable time on rework instead of serving clients, while the underlying issue often goes unresolved and recurs in future cases.\n\nA narrow focus on individual cases or products can also mean firms miss recurring, systemic weaknesses, and risk-based sampling that is too small or too narrow tends to produce results that offer little support for genuine root cause analysis.\n\nCompliance and quality assurance teams responsible for rating suitability files, and the advisers whose recommendations are reviewed.\n\n\u2022 Suitability ratings applied without detailed feedback, leaving advisers unclear why a file was marked unclear or unsuitable.\n\u2022 A narrow, case-by-case review focus that misses recurring, thematic weaknesses.\n\u2022 Risk-based sampling that is too small or too narrowly scoped to support meaningful root cause analysis.\n\u2022 Adviser rework on remediated files, which adds unprofitable time without addressing the underlying cause.\n\n1. Review whether unclear suitability ratings come with enough detail for advisers to understand and correct the issue.\n2. Widen review sampling and thematic analysis to capture recurring, systemic weaknesses.\n3. Use thematic analysis of review data to identify whether gaps sit mainly in fact-finding or in the rationale provided for recommendations.\n\nTCC argues that combining AI-driven insights with expert oversight can turn suitability reviews from a source of friction into a source of learning, giving advisers clear, actionable feedback on what went wrong and why.\n\nFirms should treat suitability review outcomes as a tool for improving adviser performance and customer outcomes, rather than only as a compliance gatekeeping exercise, and should use thematic analysis to target training and process changes at the root cause.", "wordCount": 443, "keywords": [ "Compliance AI & RegTech", "Suitability, Advice Quality & File Reviews", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Suitability, Advice Quality & File Reviews", "url": "https://tcc.group/blog/solution/outsourced-suitability-reviews/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "AI-Led Suitability Reviews" } ], "articleSection": [ "Compliance AI & RegTech", "Suitability, Advice Quality & File Reviews" ], "audience": [ { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Compliance, quality assurance and advice leaders responsible for suitability review processes." } ], "citation": [ { "@type": "CreativeWork", "name": "Suitability reviews with AI: compliance burden to asset | TCC", "url": "https://tcc.group/blog/2025/10/06/suitability-reviews-with-ai-turning-a-compliance-burden-into-a-business-asset/", "datePublished": "2025-10-06" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/analysis-perspectives/suitability-reviews-with-ai-turning-a-compliance-burden-into-a-business-asset/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/suitability-reviews-with-ai-turning-a-compliance-burden-into-a-business-asset/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What did the webinar poll find about unclear suitability ratings?", "acceptedAnswer": { "@type": "Answer", "text": "38% of attendees cited fact-finding and risk-assessment issues, while 62% cited insufficient rationale for the recommendation as the main cause." } }, { "@type": "Question", "name": "Who spoke at the webinar?", "acceptedAnswer": { "@type": "Answer", "text": "Garry Evans of Recordsure hosted the session, joined by TCC's David Boyhan and Neil Dethick." } }, { "@type": "Question", "name": "How can firms reduce adviser rework on suitability files?", "acceptedAnswer": { "@type": "Answer", "text": "By giving advisers detailed, constructive feedback when a file is rated unclear, rather than returning it without explanation." } }, { "@type": "Question", "name": "What role does AI play in suitability reviews, according to TCC?", "acceptedAnswer": { "@type": "Answer", "text": "AI-driven insights combined with expert oversight can help firms give clearer feedback and identify systemic issues through thematic analysis." } } ] } ] } ``` ### Five takeaways for wealth managers from AI in Compliance - URL: https://tcc.group/insights/white-papers-guides/five-takeaways-ai-in-compliance-ongoing-advice-event-for-wealth-managers/ - Published: 2025-10-01 - Modified: 2026-09-02 **Topic:** AI in Compliance TCC summarizes critical insights from our 'AI to supercharge your ongoing advice' event in London, focusing on compliant ongoing advice, AI integration, and adoption. #### What happened? TCC recently hosted the 'AI to supercharge your ongoing advice' conference at the Bloomsbury in London, sparking vital discussions on advice, compliance, and technology. The event focused on the real-world operational challenges wealth managers face when maintaining compliance in ongoing service delivery. We have compiled these discussions into an extensive, practical Q&A document covering more than thirty of the most pressing questions raised by attendees on the day. #### Why does it matter? Firms are facing increased pressure under Consumer Duty to justify and document their ongoing advice services, particularly in complex scenarios like 'free' advice where no fees are charged. AI offers powerful tools to streamline these processes, but leaders must navigate the distinct roles of generative and predictive technologies. While generative AI assists with drafting and content, predictive AI excels at identifying risk, spotting file gaps, and strengthening quality assurance. Utilizing these tools requires absolute transparency with clients regarding data handling and ethical AI boundaries. #### Who is affected? This update and the accompanying Q&A guide are essential reading for wealth management professionals, compliance reviewers, and advisory business leaders. #### Key risks - **Undocumented Ongoing Advice:** Failing to record 'reasonable steps' and client contact, leading to compliance vulnerability. - **Unmanaged 'Free' Advice:** Providing advice without clear fee structures or documented value, breaching Consumer Duty standards. - **Unethical Data Exposure:** Introducing AI solutions without transparent customer communications regarding how personal data is processed. #### Actions to take 1. **Download the Q&A Guide:** Access the comprehensive Q&A follow-up to review practical advice and compliance strategies from industry peers. 2. **Differentiate AI Tools:** Align AI initiatives to use predictive models for risk-spotting and generative models for administrative drafting. 3. **Clarify Client Terms:** Update customer-facing terms of business to explain clearly and ethically how AI and customer data are integrated. 4. **Run Pilot Programs:** Address team change resistance by initiating small-scale pilot programs with clear, measurable early wins. #### Wider implications Compliance is rapidly evolving into a technology-driven function. Firms that integrate AI responsibly and maintain human oversight will achieve a significant competitive and operational advantage. #### Recommendations Review the comprehensive Q&A recap with your compliance and advisory teams to guide your technology and training roadmaps for the upcoming year. #### Supporting sources - [Five takeaways for wealth managers from AI in Compliance](https://tcc.group/blog/2025/10/02/five-takeaways-ai-in-compliance-ongoing-advice-event-for-wealth-managers/) (2025-10-02) #### Ready to supercharge your ongoing advice compliance? Download our exclusive AI in Compliance Q&A guide to explore practical, peer-tested compliance strategies for wealth managers. [Download now](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/insights/white-papers-guides/five-takeaways-ai-in-compliance-ongoing-advice-event-for-wealth-managers/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Insights", "item": "https://tcc.group/insights/" }, { "@type": "ListItem", "position": 3, "name": "Five takeaways for wealth managers from AI in Compliance", "item": "https://tcc.group/insights/white-papers-guides/five-takeaways-ai-in-compliance-ongoing-advice-event-for-wealth-managers/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/white-papers-guides/five-takeaways-ai-in-compliance-ongoing-advice-event-for-wealth-managers/#webpage", "url": "https://tcc.group/insights/white-papers-guides/five-takeaways-ai-in-compliance-ongoing-advice-event-for-wealth-managers/", "name": "Five takeaways for wealth managers from AI in Compliance", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2025-10-02T00:00:00+01:00", "dateModified": "2026-09-02T03:47:46+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/white-papers-guides/five-takeaways-ai-in-compliance-ongoing-advice-event-for-wealth-managers/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "Report", "@id": "https://tcc.group/insights/white-papers-guides/five-takeaways-ai-in-compliance-ongoing-advice-event-for-wealth-managers/#article", "isPartOf": { "@id": "https://tcc.group/insights/white-papers-guides/five-takeaways-ai-in-compliance-ongoing-advice-event-for-wealth-managers/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "Five takeaways for wealth managers from AI in Compliance", "datePublished": "2025-10-02T00:00:00+01:00", "dateModified": "2026-09-02T03:47:46+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/white-papers-guides/five-takeaways-ai-in-compliance-ongoing-advice-event-for-wealth-managers/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/67a9e022f5fa4cd6b9b343adcb5a7e55/thumbnail-1024-55b73cbe2145c3f3803847ecf4f54ab58887932c9262c227b45aa133ddc876cc.jpg", "description": "Discover five key takeaways for wealth managers from our AI in Compliance event in London. We explore 'reasonable steps' in ongoing advice, generative versus predictive AI, and client data ethics.", "inLanguage": "en-GB", "articleBody": "TCC summarizes critical insights from our 'AI to supercharge your ongoing advice' event in London, focusing on compliant ongoing advice, AI integration, and adoption.\n\nTCC recently hosted the 'AI to supercharge your ongoing advice' conference at the Bloomsbury in London, sparking vital discussions on advice, compliance, and technology. The event focused on the real-world operational challenges wealth managers face when maintaining compliance in ongoing service delivery.\n\nWe have compiled these discussions into an extensive, practical Q&A document covering more than thirty of the most pressing questions raised by attendees on the day.\n\nFirms are facing increased pressure under Consumer Duty to justify and document their ongoing advice services, particularly in complex scenarios like 'free' advice where no fees are charged. AI offers powerful tools to streamline these processes, but leaders must navigate the distinct roles of generative and predictive technologies.\n\nWhile generative AI assists with drafting and content, predictive AI excels at identifying risk, spotting file gaps, and strengthening quality assurance. Utilizing these tools requires absolute transparency with clients regarding data handling and ethical AI boundaries.\n\nThis update and the accompanying Q&A guide are essential reading for wealth management professionals, compliance reviewers, and advisory business leaders.\n\n\u2022 Undocumented Ongoing Advice: Failing to record 'reasonable steps' and client contact, leading to compliance vulnerability.\n\u2022 Unmanaged 'Free' Advice: Providing advice without clear fee structures or documented value, breaching Consumer Duty standards.\n\u2022 Unethical Data Exposure: Introducing AI solutions without transparent customer communications regarding how personal data is processed.\n\n1. Download the Q&A Guide: Access the comprehensive Q&A follow-up to review practical advice and compliance strategies from industry peers.\n2. Differentiate AI Tools: Align AI initiatives to use predictive models for risk-spotting and generative models for administrative drafting.\n3. Clarify Client Terms: Update customer-facing terms of business to explain clearly and ethically how AI and customer data are integrated.\n4. Run Pilot Programs: Address team change resistance by initiating small-scale pilot programs with clear, measurable early wins.\n\nCompliance is rapidly evolving into a technology-driven function. Firms that integrate AI responsibly and maintain human oversight will achieve a significant competitive and operational advantage.\n\nReview the comprehensive Q&A recap with your compliance and advisory teams to guide your technology and training roadmaps for the upcoming year.", "wordCount": 371, "keywords": [ "Compliance AI & RegTech", "Suitability, Advice Quality & File Reviews", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Suitability, Advice Quality & File Reviews", "url": "https://tcc.group/blog/solution/outsourced-suitability-reviews/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "AI in Compliance" } ], "articleSection": [ "Compliance AI & RegTech", "Suitability, Advice Quality & File Reviews" ], "audience": [ { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Wealth managers, compliance directors, and financial advice firm leaders." } ], "citation": [ { "@type": "CreativeWork", "name": "Five takeaways for wealth managers from AI in Compliance", "url": "https://tcc.group/blog/2025/10/02/five-takeaways-ai-in-compliance-ongoing-advice-event-for-wealth-managers/", "datePublished": "2025-10-02" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/white-papers-guides/five-takeaways-ai-in-compliance-ongoing-advice-event-for-wealth-managers/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/white-papers-guides/five-takeaways-ai-in-compliance-ongoing-advice-event-for-wealth-managers/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What does 'reasonable steps' mean in ongoing advice?", "acceptedAnswer": { "@type": "Answer", "text": "It involves active client contact and, crucially, documenting every action and attempt to demonstrate that compliance oversight is fully maintained." } }, { "@type": "Question", "name": "How does the framework address 'free' advice scenarios?", "acceptedAnswer": { "@type": "Answer", "text": "Firms must demonstrate that 'free' advice structures still deliver fair value, satisfy Consumer Duty guidelines, and protect vulnerable clients." } }, { "@type": "Question", "name": "What is the difference between generative and predictive AI in compliance?", "acceptedAnswer": { "@type": "Answer", "text": "Generative AI helps draft reports, while predictive AI analyzes files, identifies risks, and automates high-volume quality assurance tasks." } } ] } ] } ``` ### FCA softens tone on ongoing advice but keeps focus on value - URL: https://tcc.group/insights/analysis-perspectives/money-marketing-ongoing-advice-tone/ - Published: 2025-09-24 - Modified: 2026-09-02 ```json { "@context": "https://schema.org", "@graph": [ { 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"Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" } ], "articleSection": [ "Compliance AI & RegTech", "Suitability, Advice Quality & File Reviews" ], "audience": [ { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" } ] } ] } ``` ### The future of AI in compliance - URL: https://tcc.group/insights/analysis-perspectives/the-future-of-ai-in-compliance/ - Published: 2025-09-11 - Modified: 2026-09-02 **Topic:** AI in compliance webinars TCC and Recordsure are co-hosting a two-part October webinar series on using AI in compliance, covering right-first-time suitability and the foundations needed for responsible generative AI adoption. #### What happened? TCC Group is co-hosting a two-part webinar series with Recordsure, 'AI in compliance', running throughout October. The series focuses on two challenges clients raise every day. The first session, on right-first-time suitability, runs on 2 October at 12.30pm and explores how combining AI with practitioner expertise can improve consistency, cut routine rework and ensure evidence is strong enough to withstand regulatory scrutiny. The second session, on building on solid foundations, runs on 14 October at 12.30pm and looks at combining generative and predictive AI to build evidence frameworks that last, rather than deploying generative AI in isolation. #### Why does it matter? The FCA is increasingly expecting more than summaries: it wants auditable, reliable records. Building this quickly, without the right guardrails, can introduce real risks, including misunderstanding, rework and even regulatory penalties. TCC believes compliance should be forward-looking, anticipating what the regulator will expect rather than simply reacting to rules already in place. #### Who is affected? Firms with high suitability caseloads that are stretched thin and prone to rework, and compliance teams responsible for producing evidence that can withstand regulatory questions. #### Key risks - Rushing generative AI adoption without the right guardrails, risking misunderstanding and rework. - Producing suitability evidence that does not stand up to regulatory scrutiny. - Treating AI as a bolt-on rather than part of a broader, responsible evidence framework. #### Actions to take 1. Register for the 2 October session on right-first-time suitability. 2. Register for the 14 October session on building AI foundations. 3. Assess how a combination of generative and predictive AI could reduce routine work while keeping evidence auditable. #### Wider implications Compliance isn't just about avoiding fines – it's about doing business the right way. Gaining oversight that frees compliance teams from routine tasks means the necessary evidence is already there when regulatory questions come. #### Recommendations Firms exploring AI adoption should treat it as part of a broader, responsible foundation rather than a quick fix, combining generative and predictive AI under TCC and Recordsure's guidance. #### Supporting sources - [The future of AI in compliance](https://tcc.group/blog/2025/09/12/the-future-of-ai-in-compliance/) (2025-09-12) #### Want to join the AI in compliance webinars? Get in touch with TCC to register your interest in the 'AI in compliance' webinar series with Recordsure. [Register your interest](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", 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series on using AI in compliance, covering right-first-time suitability and the foundations needed for responsible generative AI adoption.\n\nTCC Group is co-hosting a two-part webinar series with Recordsure, 'AI in compliance', running throughout October. The series focuses on two challenges clients raise every day.\n\nThe first session, on right-first-time suitability, runs on 2 October at 12.30pm and explores how combining AI with practitioner expertise can improve consistency, cut routine rework and ensure evidence is strong enough to withstand regulatory scrutiny.\n\nThe second session, on building on solid foundations, runs on 14 October at 12.30pm and looks at combining generative and predictive AI to build evidence frameworks that last, rather than deploying generative AI in isolation.\n\nThe FCA is increasingly expecting more than summaries: it wants auditable, reliable records. 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Assess how a combination of generative and predictive AI could reduce routine work while keeping evidence auditable.\n\nCompliance isn't just about avoiding fines \u2013 it's about doing business the right way. 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TCC sets out why day rate alone is the wrong measure of value. #### What happened? Financial services firms are facing expanding regulatory obligations, heightened scrutiny and substantial penalties for failures, driving a surge in demand for interim specialists. Rising consumer debt and inflation have left more customers financially vulnerable, while complaints to the Financial Ombudsman have grown by 70%, stretching firms' capacity for trained case handlers and vulnerability specialists. Consumer Duty requirements, ongoing-advice reviews, the pending motor finance redress ruling and enhanced anti-money-laundering and fraud detection requirements are adding to the need for file checkers, compliance officers, remediation teams and financial crime specialists, at a time when the market for level 4 and 6 file checkers, redress analysts and senior compliance leaders is particularly tight. #### Why does it matter? Misjudging interim resourcing needs carries costs well beyond day rates. Regulatory fines now routinely run into the hundreds of millions, and poorly executed remediation programmes often lead to re-remediation, doubling the expense. There are hidden costs too: stalled product launches, lost management time, attrition problems, and reputational damage that can erode investor confidence, deter talent and undermine customer trust. What looks like a short-term saving on interim resourcing can become a much larger cost later. #### Who is affected? Financial services firms across sectors that are recruiting file checkers, redress analysts, compliance officers or senior compliance leaders into a market where proven interim talent is in short supply, and senior managers whose personal accountability under the SMCR depends on the quality of support around them. #### Key risks - A tight talent market for level 4 and 6 file checkers, redress analysts and senior compliance leaders. - Poorly executed remediation leading to re-remediation and doubled costs. - Hidden costs such as stalled launches, lost management time and attrition. - Personal accountability under the SMCR without access to genuinely specialist support. #### Actions to take 1. Judge interim resource against project KPIs, attrition rates, long-term value and stakeholder satisfaction, not day rate alone. 2. Test candidates on practical compliance expertise through technical evaluation, not just CV credentials. 3. Assess cultural fit alongside technical skill to reduce attrition and support faster integration. 4. Ensure rigorous vetting, including background checks, sanctions verification and right-to-work validation. #### Wider implications TCC reports a typical attrition rate of just 5% among its placements, against an industry average of 15-20%, attributing this to consultative discovery, technical evaluation, cultural fit assessment and rigorous vetting before placement, plus interim managers who up-skill permanent staff rather than simply filling a gap. > TCC delivered us a team of brilliant people. The tools and processes they created and the rapport they built with the internal team have been fantastic. We couldn't have delivered this programme without them. #### Recommendations Firms should treat interim resourcing decisions as strategic rather than tactical, selecting providers on the basis of technical evaluation, cultural fit and vetting rigour, and measuring success through project KPIs, attrition and long-term value rather than day rate alone. #### Supporting sources - [Beyond Day Rates: How specialist interim resourcing gives financial](https://tcc.group/blog/2025/09/08/beyond-day-rates-specialist-interim-resourcing-financial-services-competitive-edge/) (2025-09-08) #### Need specialist interim compliance resource? Contact us to discuss interim compliance specialists matched precisely to your firm's regulatory and resourcing challenges. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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TCC sets out why day rate alone is the wrong measure of value.\n\nFinancial services firms are facing expanding regulatory obligations, heightened scrutiny and substantial penalties for failures, driving a surge in demand for interim specialists. Rising consumer debt and inflation have left more customers financially vulnerable, while complaints to the Financial Ombudsman have grown by 70%, stretching firms' capacity for trained case handlers and vulnerability specialists.\n\nConsumer Duty requirements, ongoing-advice reviews, the pending motor finance redress ruling and enhanced anti-money-laundering and fraud detection requirements are adding to the need for file checkers, compliance officers, remediation teams and financial crime specialists, at a time when the market for level 4 and 6 file checkers, redress analysts and senior compliance leaders is particularly tight.\n\nMisjudging interim resourcing needs carries costs well beyond day rates. Regulatory fines now routinely run into the hundreds of millions, and poorly executed remediation programmes often lead to re-remediation, doubling the expense.\n\nThere are hidden costs too: stalled product launches, lost management time, attrition problems, and reputational damage that can erode investor confidence, deter talent and undermine customer trust. What looks like a short-term saving on interim resourcing can become a much larger cost later.\n\nFinancial services firms across sectors that are recruiting file checkers, redress analysts, compliance officers or senior compliance leaders into a market where proven interim talent is in short supply, and senior managers whose personal accountability under the SMCR depends on the quality of support around them.\n\n\u2022 A tight talent market for level 4 and 6 file checkers, redress analysts and senior compliance leaders.\n\u2022 Poorly executed remediation leading to re-remediation and doubled costs.\n\u2022 Hidden costs such as stalled launches, lost management time and attrition.\n\u2022 Personal accountability under the SMCR without access to genuinely specialist support.\n\n1. Judge interim resource against project KPIs, attrition rates, long-term value and stakeholder satisfaction, not day rate alone.\n2. Test candidates on practical compliance expertise through technical evaluation, not just CV credentials.\n3. Assess cultural fit alongside technical skill to reduce attrition and support faster integration.\n4. Ensure rigorous vetting, including background checks, sanctions verification and right-to-work validation.\n\nTCC reports a typical attrition rate of just 5% among its placements, against an industry average of 15-20%, attributing this to consultative discovery, technical evaluation, cultural fit assessment and rigorous vetting before placement, plus interim managers who up-skill permanent staff rather than simply filling a gap.\n\nTCC delivered us a team of brilliant people. The tools and processes they created and the rapport they built with the internal team have been fantastic. We couldn't have delivered this programme without them.\n\nFirms should treat interim resourcing decisions as strategic rather than tactical, selecting providers on the basis of technical evaluation, cultural fit and vetting rigour, and measuring success through project KPIs, attrition and long-term value rather than day rate alone.", "wordCount": 495, "keywords": [ "Consolidation, Acquisition & Regulatory Due Diligence", "Consumer Duty", "Financial Crime Compliance", "Regulatory Change & Transformation", "Section 166, Skilled Person Reviews & FCA Intervention", "Banking", "General Insurance & Protection", "Lending & Consumer Credit", "Motor Finance", "Payments & FinTech", "Pensions & Retirement Income", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Consolidation, Acquisition & Regulatory Due Diligence", "url": "https://tcc.group/blog/solution/consolidation-acquisition-regulatory-due-diligence/" }, { "@type": "Thing", "name": "Consumer Duty", "url": "https://tcc.group/blog/solution/consumer-duty/" }, { "@type": "Thing", "name": "Financial Crime Compliance", "url": "https://tcc.group/blog/solution/financial-crime-compliance/" }, { "@type": "Thing", "name": "Regulatory Change & Transformation", "url": "https://tcc.group/blog/solution/regulatory-change-transformation/" }, { "@type": "Thing", "name": "Section 166, Skilled Person Reviews & FCA Intervention", "url": "https://tcc.group/blog/solution/section-166-skilled-person-reviews-fca-intervention/" }, { "@type": "Thing", "name": "Banking", "url": "https://tcc.group/blog/sector/banking/" }, { "@type": "Thing", "name": "General Insurance & Protection", "url": "https://tcc.group/blog/sector/general-insurance-protection/" }, { "@type": "Thing", "name": "Lending & Consumer Credit", "url": "https://tcc.group/blog/sector/lending-consumer-credit/" }, { "@type": "Thing", "name": "Motor Finance", "url": "https://tcc.group/blog/sector/motor-finance/" }, { "@type": "Thing", "name": "Payments & FinTech", "url": "https://tcc.group/blog/sector/payments-fintech/" }, { "@type": "Thing", "name": "Pensions & Retirement Income", "url": "https://tcc.group/blog/sector/pensions-retirement-income/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Specialist Interim Resourcing" } ], "articleSection": [ "Consolidation, Acquisition & Regulatory Due Diligence", "Consumer Duty", "Financial Crime Compliance", "Regulatory Change & Transformation", "Section 166, Skilled Person Reviews & FCA Intervention" ], "audience": [ { "@type": "Audience", "audienceType": "Banking" }, { "@type": "Audience", "audienceType": "General Insurance & Protection" }, { "@type": "Audience", "audienceType": "Lending & Consumer Credit" }, { "@type": "Audience", "audienceType": "Motor Finance" }, { "@type": "Audience", "audienceType": "Payments & FinTech" }, { "@type": "Audience", "audienceType": "Pensions & Retirement Income" }, { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Leaders responsible for resourcing decisions across compliance, risk and change functions in financial services firms." } ], "citation": [ { "@type": "CreativeWork", "name": "Beyond Day Rates: How specialist interim resourcing gives financial", "url": "https://tcc.group/blog/2025/09/08/beyond-day-rates-specialist-interim-resourcing-financial-services-competitive-edge/", "datePublished": "2025-09-08" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/white-papers-guides/beyond-day-rates-specialist-interim-resourcing-financial-services-competitive-edge/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/white-papers-guides/beyond-day-rates-specialist-interim-resourcing-financial-services-competitive-edge/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "Why has demand for interim compliance specialists increased?", "acceptedAnswer": { "@type": "Answer", "text": "Growing customer vulnerability, a 70% rise in Financial Ombudsman complaints, Consumer Duty and motor finance reviews, and stronger financial crime prevention requirements have all increased firms' need for specialist support." } }, { "@type": "Question", "name": "What does it cost firms when they get interim resourcing wrong?", "acceptedAnswer": { "@type": "Answer", "text": "Regulatory fines that can run into the hundreds of millions, costly re-remediation, stalled projects, staff attrition and reputational damage that can erode customer and investor trust." } }, { "@type": "Question", "name": "How should firms judge the value of interim resource?", "acceptedAnswer": { "@type": "Answer", "text": "By looking beyond day rates to project KPIs, attrition rates, long-term value such as fewer compliance incidents, and stakeholder satisfaction, rather than cost alone." } }, { "@type": "Question", "name": "What attrition rate does TCC achieve among its interim placements?", "acceptedAnswer": { "@type": "Answer", "text": "TCC reports a typical attrition rate of just 5% among its placements, compared with an industry average of 15-20%." } } ] } ] } ``` ### Plan for the worst, act early: winning the remediation race - URL: https://tcc.group/insights/analysis-perspectives/plan-for-the-worst-act-early-winning-the-remediation-race/ - Published: 2025-08-25 - Modified: 2026-09-02 **Topic:** Motor Finance Redress Preparation In the closing session of a webinar on FCA redress and the future of motor finance, TCC, Momenta and Recordsure set out the practical steps firms should take while the scope of any redress scheme remains unclear. #### What happened? This is the concluding part of a TCC, Momenta and Recordsure webinar on FCA redress and the future of motor finance. With the final scope of any redress scheme still awaited from the FCA, the panel focused on what firms can do now rather than wait for certainty. The panel recommended that firms verify the integrity of their historical data, particularly where records may need to go back to 2007. Suggested areas of focus included cases involving discretionary commission, cases with high commission levels, and how disclosure of commission was handled at the point of sale. The panel also discussed the potential for claims management companies to widen the scope of activity, including raising vulnerability and affordability issues within complaints that sit outside the current pause, and encouraged firms to triage any complaints already waiting. #### Why does it matter? The panel was clear that uncertainty over the final scope of the scheme is not a reason for inaction. Firms that prepare early, particularly on data, are better placed to secure scarce resources such as specialist reviewers once a scheme is confirmed. The discussion also raised the possibility of wider implications beyond motor finance, noting that the same commission-related questions could extend into other parts of consumer credit, although the panel was cautious about how far the FCA is likely to take this. #### Who is affected? Motor finance creditors and their compliance, remediation and operations functions are the primary audience, alongside firms operating in the wider consumer credit market that use commission-based distribution arrangements. #### Key risks - Historical data going back to 2007 that may be incomplete, inconsistent or difficult to verify. - Claims management companies raising affordability and responsible lending issues within complaints that sit outside the current pause. - A shortage of specialist resource once the scope of any redress scheme is confirmed. - Uncertainty over how disclosure of commission and distribution arrangements will be assessed. #### Actions to take 1. Begin data mining historical files now, focusing on cases involving discretionary commission and high commission levels. 2. Review how commission was disclosed at the point of sale, and what firms held regarding distribution arrangements with dealers. 3. Triage any complaints already on hold, including those where affordability or responsible lending concerns may be present. 4. Assess current resourcing plans and consider early procurement of specialist support ahead of any confirmed scheme. 5. Review policies on vulnerable customers so they can respond appropriately to claims that raise vulnerability. #### Wider implications The panel noted that questions about commission-based distribution are not necessarily confined to motor finance, and that other parts of consumer credit could face similar scrutiny. The panel's own view was that the FCA does not currently appear motivated to broaden its focus, though this could change if claims management companies pursue that angle. #### Recommendations Firms should treat the current lack of clarity as a planning window rather than a reason to pause. Verifying data integrity, segmenting cases and reviewing dealer and distribution arrangements now will put firms in a stronger position once the scheme's scope is confirmed. Given the scale of the resourcing challenge the panel anticipates, firms may benefit from combining internal preparation with specialist and technology-led support to review cases at pace. #### Supporting sources - [Plan for the worst, act early: winning the remediation race](https://tcc.group/blog/2025/08/26/plan-for-the-worst-act-early-winning-the-remediation-race/) (2025-08-26) #### Ready to prepare for motor finance redress? TCC, Momenta and Recordsure can help you plan, scale and deliver a motor finance remediation programme, from data review through to specialist resourcing. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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next steps for firms: verifying data integrity, segmenting historical cases and preparing for a likely resourcing squeeze.", "inLanguage": "en-GB", "articleBody": "In the closing session of a webinar on FCA redress and the future of motor finance, TCC, Momenta and Recordsure set out the practical steps firms should take while the scope of any redress scheme remains unclear.\n\nThis is the concluding part of a TCC, Momenta and Recordsure webinar on FCA redress and the future of motor finance. With the final scope of any redress scheme still awaited from the FCA, the panel focused on what firms can do now rather than wait for certainty.\n\nThe panel recommended that firms verify the integrity of their historical data, particularly where records may need to go back to 2007. Suggested areas of focus included cases involving discretionary commission, cases with high commission levels, and how disclosure of commission was handled at the point of sale.\n\nThe panel also discussed the potential for claims management companies to widen the scope of activity, including raising vulnerability and affordability issues within complaints that sit outside the current pause, and encouraged firms to triage any complaints already waiting.\n\nThe panel was clear that uncertainty over the final scope of the scheme is not a reason for inaction. Firms that prepare early, particularly on data, are better placed to secure scarce resources such as specialist reviewers once a scheme is confirmed.\n\nThe discussion also raised the possibility of wider implications beyond motor finance, noting that the same commission-related questions could extend into other parts of consumer credit, although the panel was cautious about how far the FCA is likely to take this.\n\nMotor finance creditors and their compliance, remediation and operations functions are the primary audience, alongside firms operating in the wider consumer credit market that use commission-based distribution arrangements.\n\n\u2022 Historical data going back to 2007 that may be incomplete, inconsistent or difficult to verify.\n\u2022 Claims management companies raising affordability and responsible lending issues within complaints that sit outside the current pause.\n\u2022 A shortage of specialist resource once the scope of any redress scheme is confirmed.\n\u2022 Uncertainty over how disclosure of commission and distribution arrangements will be assessed.\n\n1. Begin data mining historical files now, focusing on cases involving discretionary commission and high commission levels.\n2. Review how commission was disclosed at the point of sale, and what firms held regarding distribution arrangements with dealers.\n3. Triage any complaints already on hold, including those where affordability or responsible lending concerns may be present.\n4. Assess current resourcing plans and consider early procurement of specialist support ahead of any confirmed scheme.\n5. Review policies on vulnerable customers so they can respond appropriately to claims that raise vulnerability.\n\nThe panel noted that questions about commission-based distribution are not necessarily confined to motor finance, and that other parts of consumer credit could face similar scrutiny. The panel's own view was that the FCA does not currently appear motivated to broaden its focus, though this could change if claims management companies pursue that angle.\n\nFirms should treat the current lack of clarity as a planning window rather than a reason to pause. 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In a recent webinar, Mike Morris, Head of Operations at Momenta, and Garry Evans, Chief Product and Commercial Officer for TCC Group, discussed how the Supreme Court ruling has shifted the balance from high-volume automated redress towards more complex, bespoke complaint handling. Before the ruling, firms expected a large proportion of cases, potentially 75–80% or more, to move through an automated workflow from tracing through to redress. Since the ruling, the volume of cases eligible for automated redress is lower, but the volume of complex cases sitting outside that population, and requiring more tailored, human review, is higher. Claims management company involvement is expected to add further complexity, identifying additional complaint points that need to be triaged and assessed through a more nuanced decision-making process. #### Why does it matter? All motor finance firms with a back book of relevant agreements will be affected, with a large number of remediation projects expected to run over the next 18 months. Demand for experienced case handlers, able to assess unfair practices and customer circumstances, is likely to outstrip supply in that period. A number of motor finance creditors have already begun procurement exercises ahead of full clarity on scope and process from the FCA, raising the risk that firms end up competing for the same pool of specialist resource. While redress payments to individual customers may be lower than first anticipated, the overall processing cost of remediation is likely to be higher, given the added complexity of the cases now in scope. #### Who is affected? Motor finance creditors with back-book agreements in scope for remediation, and the wider delivery market, including professional services firms and business process outsourcers, competing for the same specialist resource. #### Key risks - A shortage of experienced case handlers able to assess unfair practices and customer circumstances over the next 18 months. - Rising cost of resource as multiple firms compete for the same specialist talent pool. - Delivery delays for firms that wait for full clarity on scope before starting procurement. - Additional complexity introduced by claims management company activity on existing cases. #### Actions to take 1. Review policies and procedures now, ahead of confirmed scheme detail, to bring compliance practices up to date. 2. Consider offshore delivery options to access experienced resource at a reduced cost. 3. Start procurement and resourcing plans early rather than waiting for full clarity on scope. 4. Strengthen underlying processes so less experienced resources can be supported and scaled quickly. #### Wider implications Firms that start preparing now, by reviewing policies, tightening procedures and considering alternative delivery models such as offshore teams, will be better positioned to respond at scale once the FCA's redress scheme is finalised. #### Recommendations TCC, Recordsure and Momenta can help firms secure the right skills, design efficient processes and minimise operational risk ahead of the redress scheme. #### Supporting sources - [The resourcing crunch: preparing for a remediation surge](https://tcc.group/blog/2025/08/22/the-resourcing-crunch-preparing-for-a-remediation-surge/) (2025-08-22) #### Ready to plan your remediation resourcing? Talk to TCC about preparing your resourcing and processes ahead of the motor finance redress scheme. 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"https://tcc.group/insights/analysis-perspectives/the-resourcing-crunch-preparing-for-a-remediation-surge/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/analysis-perspectives/the-resourcing-crunch-preparing-for-a-remediation-surge/#webpage", "url": "https://tcc.group/insights/analysis-perspectives/the-resourcing-crunch-preparing-for-a-remediation-surge/", "name": "The resourcing crunch: preparing for a remediation surge", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2025-08-22T00:00:00+01:00", "dateModified": "2026-09-02T03:49:06+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/analysis-perspectives/the-resourcing-crunch-preparing-for-a-remediation-surge/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "AnalysisNewsArticle", "@id": "https://tcc.group/insights/analysis-perspectives/the-resourcing-crunch-preparing-for-a-remediation-surge/#article", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/the-resourcing-crunch-preparing-for-a-remediation-surge/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "The resourcing crunch: preparing for a remediation surge", "datePublished": "2025-08-22T00:00:00+01:00", "dateModified": "2026-09-02T03:49:06+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/analysis-perspectives/the-resourcing-crunch-preparing-for-a-remediation-surge/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/312b145a6c3b4ff994af4794f52593cf/thumbnail-1024-24789b67a88c9c6a86c7531e9984322a0dafa4ad5432750f7e1193f313838e27.jpg", "description": "Understand why the motor finance remediation programme will strain resourcing, what the Supreme Court ruling changes about complaint complexity, and how firms can secure the skilled case handlers they'll need.", "inLanguage": "en-GB", "articleBody": "Following the Supreme Court's motor finance ruling, resourcing is set to become one of the biggest challenges in delivering redress, as the balance shifts from high-volume automated processing towards more complex, bespoke complaint handling.\n\nIn a recent webinar, Mike Morris, Head of Operations at Momenta, and Garry Evans, Chief Product and Commercial Officer for TCC Group, discussed how the Supreme Court ruling has shifted the balance from high-volume automated redress towards more complex, bespoke complaint handling.\n\nBefore the ruling, firms expected a large proportion of cases, potentially 75\u201380% or more, to move through an automated workflow from tracing through to redress. Since the ruling, the volume of cases eligible for automated redress is lower, but the volume of complex cases sitting outside that population, and requiring more tailored, human review, is higher.\n\nClaims management company involvement is expected to add further complexity, identifying additional complaint points that need to be triaged and assessed through a more nuanced decision-making process.\n\nAll motor finance firms with a back book of relevant agreements will be affected, with a large number of remediation projects expected to run over the next 18 months. Demand for experienced case handlers, able to assess unfair practices and customer circumstances, is likely to outstrip supply in that period.\n\nA number of motor finance creditors have already begun procurement exercises ahead of full clarity on scope and process from the FCA, raising the risk that firms end up competing for the same pool of specialist resource.\n\nWhile redress payments to individual customers may be lower than first anticipated, the overall processing cost of remediation is likely to be higher, given the added complexity of the cases now in scope.\n\nMotor finance creditors with back-book agreements in scope for remediation, and the wider delivery market, including professional services firms and business process outsourcers, competing for the same specialist resource.\n\n\u2022 A shortage of experienced case handlers able to assess unfair practices and customer circumstances over the next 18 months.\n\u2022 Rising cost of resource as multiple firms compete for the same specialist talent pool.\n\u2022 Delivery delays for firms that wait for full clarity on scope before starting procurement.\n\u2022 Additional complexity introduced by claims management company activity on existing cases.\n\n1. Review policies and procedures now, ahead of confirmed scheme detail, to bring compliance practices up to date.\n2. Consider offshore delivery options to access experienced resource at a reduced cost.\n3. Start procurement and resourcing plans early rather than waiting for full clarity on scope.\n4. Strengthen underlying processes so less experienced resources can be supported and scaled quickly.\n\nFirms that start preparing now, by reviewing policies, tightening procedures and considering alternative delivery models such as offshore teams, will be better positioned to respond at scale once the FCA's redress scheme is finalised.\n\nTCC, Recordsure and Momenta can help firms secure the right skills, design efficient processes and minimise operational risk ahead of the redress scheme.", "wordCount": 487, "keywords": [ "Complaints & Claims Handling", "Redress & Remediation", "Lending & Consumer Credit", "Motor Finance" ], "about": [ { "@type": "Thing", "name": "Complaints & Claims Handling", "url": "https://tcc.group/blog/solution/complaints-claims-handling/" }, { "@type": "Thing", "name": "Redress & Remediation", "url": "https://tcc.group/blog/solution/redress-and-remediation/" }, { "@type": "Thing", "name": "Lending & Consumer Credit", "url": "https://tcc.group/blog/sector/lending-consumer-credit/" }, { "@type": "Thing", "name": "Motor Finance", "url": "https://tcc.group/blog/sector/motor-finance/" }, { "@type": "Thing", "name": "Motor finance remediation resourcing" } ], "articleSection": [ "Complaints & Claims Handling", "Redress & Remediation" ], "audience": [ { "@type": "Audience", "audienceType": "Lending & Consumer Credit" }, { "@type": "Audience", "audienceType": "Motor Finance" }, { "@type": "Audience", "audienceType": "Operations and compliance leaders at motor finance and consumer credit firms planning for redress." } ], "citation": [ { "@type": "CreativeWork", "name": "The resourcing crunch: preparing for a remediation surge", "url": "https://tcc.group/blog/2025/08/22/the-resourcing-crunch-preparing-for-a-remediation-surge/", "datePublished": "2025-08-22" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/analysis-perspectives/the-resourcing-crunch-preparing-for-a-remediation-surge/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/the-resourcing-crunch-preparing-for-a-remediation-surge/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "Why is resourcing expected to be a major challenge in motor finance remediation?", "acceptedAnswer": { "@type": "Answer", "text": "The Supreme Court ruling has shifted cases away from simple automated processing towards more complex, bespoke handling, increasing demand for experienced case handlers." } }, { "@type": "Question", "name": "What proportion of cases might be handled automatically?", "acceptedAnswer": { "@type": "Answer", "text": "Firms had been expecting a majority of cases, potentially 75-80%, to go through automated workflows, but the ruling has reduced that population and increased the complex caseload." } }, { "@type": "Question", "name": "What can firms do to mitigate the resourcing shortage?", "acceptedAnswer": { "@type": "Answer", "text": "Options include reviewing policies and procedures early, considering offshore delivery, and starting procurement before the full scope of the FCA scheme is confirmed." } }, { "@type": "Question", "name": "Will remediation cost less overall?", "acceptedAnswer": { "@type": "Answer", "text": "Per-customer redress payments may be lower, but the overall processing cost of remediation is likely to be higher due to the complexity of cases requiring review." } } ] } ] } ``` ### How to stay ahead of FCA demands and unlock AI's potential for wealth management compliance - URL: https://tcc.group/insights/regulatory-horizon/stay-ahead-of-fca-demands-with-ai-for-wealth-management/ - Published: 2025-08-21 - Modified: 2026-09-02 **Topic:** AI For Wealth Management Compliance TCC held an in-person event in London in September 2025 on evidencing ongoing advice under the Consumer Duty and using AI to respond to FCA information requests. #### What happened? TCC reported that the FCA has been actively emphasising the need for thorough evidencing of ongoing servicing under the Consumer Duty, even without high-profile public statements on the issue. In response, TCC hosted an exclusive in-person event on 16 September 2025 in London, bringing together wealth managers, legal experts and technology partners. The event addressed the FCA's expectations for substantive, evidenced annual reviews, documented client meetings and up-to-date fact finds and suitability letters, together with the ability to respond rapidly to section 165 information requests under the Financial Services and Markets Act 2000. Speakers included representatives from Attivo, DACBeachcroft, TCC and Recordsure, sharing perspectives on data-led supervision strategies and the use of AI in ongoing advice reviews. #### Why does it matter? Firms without modern technology or significant manual resource may struggle to meet the FCA's expectations for substantive, evidenced reviews. Inconsistent processes or weak records leave firms exposed to resource-heavy FCA investigations and more serious consequences if failings are identified. #### Who is affected? Wealth management firms providing ongoing advice services under the Consumer Duty, and the compliance and supervision teams responsible for responding to FCA information requests. #### Key risks - Ongoing advice reviews that amount to box-ticking rather than substantive, evidenced assessment. - Client meetings, fact finds and suitability letters that are not kept up to date. - An inability to respond rapidly to FCA section 165 information requests. #### Actions to take 1. Review whether annual ongoing advice reviews are substantive and properly evidenced. 2. Check that client fact finds and suitability letters are current and complete. 3. Test how quickly the firm could respond to an FCA section 165 request. #### Wider implications TCC's event materials described firms exploring data-led supervision strategies alongside AI, with the invitation referencing outcomes such as freeing up adviser time, reducing file review costs and completing suitability checks more quickly. These are the event's stated aims rather than independently verified results, but they point to where firms may look for efficiency as scrutiny increases. #### Recommendations Firms should sharpen data-led supervision of ongoing advice now, rather than waiting for a formal FCA information request to expose gaps in evidencing and record-keeping. #### Supporting sources - [How to stay ahead of FCA demands and unlock AI's potential for wealth management compliance](https://tcc.group/blog/2025/08/22/stay-ahead-of-fca-demands-with-ai-for-wealth-management/) (2025-08-22) #### Want to strengthen your ongoing advice evidencing? Talk to TCC about preparing your firm for FCA scrutiny of ongoing advice services. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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under the Consumer Duty and using AI to strengthen suitability and file review processes.", "inLanguage": "en-GB", "articleBody": "TCC held an in-person event in London in September 2025 on evidencing ongoing advice under the Consumer Duty and using AI to respond to FCA information requests.\n\nTCC reported that the FCA has been actively emphasising the need for thorough evidencing of ongoing servicing under the Consumer Duty, even without high-profile public statements on the issue. In response, TCC hosted an exclusive in-person event on 16 September 2025 in London, bringing together wealth managers, legal experts and technology partners.\n\nThe event addressed the FCA's expectations for substantive, evidenced annual reviews, documented client meetings and up-to-date fact finds and suitability letters, together with the ability to respond rapidly to section 165 information requests under the Financial Services and Markets Act 2000.\n\nSpeakers included representatives from Attivo, DACBeachcroft, TCC and Recordsure, sharing perspectives on data-led supervision strategies and the use of AI in ongoing advice reviews.\n\nFirms without modern technology or significant manual resource may struggle to meet the FCA's expectations for substantive, evidenced reviews. 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Test how quickly the firm could respond to an FCA section 165 request.\n\nTCC's event materials described firms exploring data-led supervision strategies alongside AI, with the invitation referencing outcomes such as freeing up adviser time, reducing file review costs and completing suitability checks more quickly. 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In part three of TCC Group's motor finance webinar, 'Driving Change,' compliance experts Gary Maude and Garry Evans analyze the Supreme Court's landmark ruling in the Johnson case. While the Court confirmed that commission payments are legally permissible, it established that the fairness of each contract depends on individual circumstances. Key factors such as the size of the commission (which was 55% in the Johnson case), the degree of disclosure transparency, and the sophistication of the consumer are critical in determining whether an 'unfair relationship' exists under the Consumer Credit Act (CCA). #### Why does it matter? This landmark case has created immense operational challenges for lenders and brokers. The FCA is preparing a formal consultation which will define the scope and mechanisms of eventual customer redress, including potential opt-in or opt-out structures. Even if total redress provision values decrease, the complexity of reviewing historic agreements case-by-case is significantly higher. Firms face massive complaint backlogs, rising Claims Management Company (CMC) activity, and the urgent need to upskill or source qualified complaint handling resources. #### Who is affected? This regulatory transition directly affects creditors, auto dealers, finance brokers, and legal teams managing historic discretionary or non-discretionary commission arrangements. #### Key risks - **Unquantified Backlogs:** Struggling to measure exposure or predict the operational cost of conducting bespoke case-by-case reviews. - **CMC Disturbance:** Managing highly time-consuming data subject access requests (DSARs) and disputed outcomes driven by active Claims Management Companies. - **Diluted Fair Value:** Failing to re-evaluate business-to-business and distributor relationships under the heightened lens of the Consumer Duty. #### Actions to take 1. **Watch the Webinar:** Access the full 'Driving Change' webinar to understand expert perspectives on the Supreme Court's deliberation factors. 2. **Audit Commission Portfolios:** Identify and categorize historic commission cases, analyzing variables like transparency and disclosure placement. 3. **Scale Complaint Resource:** Build or secure flexible, high-capacity complaint handling teams capable of managing bespoke review backlogs. 4. **Test Client Outcomes:** Conduct customer comprehension testing as part of product handover and fair value assessment reviews. #### Wider implications The boundary between lawful and unfair commission has become highly nuanced. Lenders and brokers must prepare for resource-intensive, customized dispute resolutions that demand strong, evidence-based governance. #### Recommendations Firms should proactively establish robust, scalable remediation frameworks and secure specialist interim handlers to address complaint backlogs before regulatory consultation rules are finalized. #### Supporting sources - [From legal definitions to operational realities: who feels the impact?](https://tcc.group/blog/2025/08/21/from-legal-definitions-to-operational-realities-who-feels-the-impact/) (2025-08-21) #### Are your motor finance teams prepared for bespoke reviews? Interpret complex rulings, assess your portfolio exposure, and deploy scalable complaint handling resources with our motor finance specialists. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/insights/analysis-perspectives/from-legal-definitions-to-operational-realities-who-feels-the-impact/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Insights", "item": "https://tcc.group/insights/" }, { "@type": "ListItem", "position": 3, "name": "From Legal Definitions to Operational Realities: Who Feels the Impact?", "item": "https://tcc.group/insights/analysis-perspectives/from-legal-definitions-to-operational-realities-who-feels-the-impact/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/analysis-perspectives/from-legal-definitions-to-operational-realities-who-feels-the-impact/#webpage", "url": "https://tcc.group/insights/analysis-perspectives/from-legal-definitions-to-operational-realities-who-feels-the-impact/", "name": "From Legal Definitions to Operational Realities: Who Feels the Impact?", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2025-08-21T00:00:00+01:00", "dateModified": "2026-09-02T03:47:48+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/analysis-perspectives/from-legal-definitions-to-operational-realities-who-feels-the-impact/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "AnalysisNewsArticle", "@id": "https://tcc.group/insights/analysis-perspectives/from-legal-definitions-to-operational-realities-who-feels-the-impact/#article", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/from-legal-definitions-to-operational-realities-who-feels-the-impact/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "From Legal Definitions to Operational Realities: Who Feels the Impact?", "datePublished": "2025-08-21T00:00:00+01:00", "dateModified": "2026-09-02T03:47:48+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/analysis-perspectives/from-legal-definitions-to-operational-realities-who-feels-the-impact/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/c7e7237459a04c64a80adf9ae7879936/thumbnail-1024-f9ea09343bdfa485c25ca4323c8f18fd6b42c7b919ef9fdc21c09c0dd4859df2.jpg", "description": "Unpack the Supreme Court's complex stance on motor finance commissions. We explore the operational realities of the Johnson ruling, opt-in versus opt-out redress, and the role of Claims Management Companies.", "inLanguage": "en-GB", "articleBody": "TCC Group's Gary Maude and Garry Evans analyze the Supreme Court's Johnson ruling, detailing its profound operational impact on motor finance creditors, brokers, and complaint handlers.\n\nIn part three of TCC Group's motor finance webinar, 'Driving Change,' compliance experts Gary Maude and Garry Evans analyze the Supreme Court's landmark ruling in the Johnson case. While the Court confirmed that commission payments are legally permissible, it established that the fairness of each contract depends on individual circumstances.\n\nKey factors such as the size of the commission (which was 55% in the Johnson case), the degree of disclosure transparency, and the sophistication of the consumer are critical in determining whether an 'unfair relationship' exists under the Consumer Credit Act (CCA).\n\nThis landmark case has created immense operational challenges for lenders and brokers. The FCA is preparing a formal consultation which will define the scope and mechanisms of eventual customer redress, including potential opt-in or opt-out structures.\n\nEven if total redress provision values decrease, the complexity of reviewing historic agreements case-by-case is significantly higher. Firms face massive complaint backlogs, rising Claims Management Company (CMC) activity, and the urgent need to upskill or source qualified complaint handling resources.\n\nThis regulatory transition directly affects creditors, auto dealers, finance brokers, and legal teams managing historic discretionary or non-discretionary commission arrangements.\n\n\u2022 Unquantified Backlogs: Struggling to measure exposure or predict the operational cost of conducting bespoke case-by-case reviews.\n\u2022 CMC Disturbance: Managing highly time-consuming data subject access requests (DSARs) and disputed outcomes driven by active Claims Management Companies.\n\u2022 Diluted Fair Value: Failing to re-evaluate business-to-business and distributor relationships under the heightened lens of the Consumer Duty.\n\n1. Watch the Webinar: Access the full 'Driving Change' webinar to understand expert perspectives on the Supreme Court's deliberation factors.\n2. Audit Commission Portfolios: Identify and categorize historic commission cases, analyzing variables like transparency and disclosure placement.\n3. Scale Complaint Resource: Build or secure flexible, high-capacity complaint handling teams capable of managing bespoke review backlogs.\n4. Test Client Outcomes: Conduct customer comprehension testing as part of product handover and fair value assessment reviews.\n\nThe boundary between lawful and unfair commission has become highly nuanced. Lenders and brokers must prepare for resource-intensive, customized dispute resolutions that demand strong, evidence-based governance.\n\nFirms should proactively establish robust, scalable remediation frameworks and secure specialist interim handlers to address complaint backlogs before regulatory consultation rules are finalized.", "wordCount": 392, "keywords": [ "Complaints & Claims Handling", "Redress & Remediation", "Regulatory Change & Transformation", "Lending & Consumer Credit", "Motor Finance" ], "about": [ { "@type": "Thing", "name": "Complaints & Claims Handling", "url": "https://tcc.group/blog/solution/complaints-claims-handling/" }, { "@type": "Thing", "name": "Redress & Remediation", "url": "https://tcc.group/blog/solution/redress-and-remediation/" }, { "@type": "Thing", "name": "Regulatory Change & Transformation", "url": "https://tcc.group/blog/solution/regulatory-change-transformation/" }, { "@type": "Thing", "name": "Lending & Consumer Credit", "url": "https://tcc.group/blog/sector/lending-consumer-credit/" }, { "@type": "Thing", "name": "Motor Finance", "url": "https://tcc.group/blog/sector/motor-finance/" }, { "@type": "Thing", "name": "Motor Finance Redress" } ], "articleSection": [ "Complaints & Claims Handling", "Redress & Remediation", "Regulatory Change & Transformation" ], "audience": [ { "@type": "Audience", "audienceType": "Lending & Consumer Credit" }, { "@type": "Audience", "audienceType": "Motor Finance" }, { "@type": "Audience", "audienceType": "Lenders, auto brokers, dealers, and compliance teams in the motor finance market." } ], "citation": [ { "@type": "CreativeWork", "name": "From legal definitions to operational realities: who feels the impact?", "url": "https://tcc.group/blog/2025/08/21/from-legal-definitions-to-operational-realities-who-feels-the-impact/", "datePublished": "2025-08-21" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/analysis-perspectives/from-legal-definitions-to-operational-realities-who-feels-the-impact/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/from-legal-definitions-to-operational-realities-who-feels-the-impact/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What makes a motor finance commission 'unfair' under the Johnson ruling?", "acceptedAnswer": { "@type": "Answer", "text": "The Court indicated that fairness is a case-by-case assessment depending on commission size, the clarity and transparency of its disclosure, and consumer characteristics." } }, { "@type": "Question", "name": "What is the expected timeline for FCA consultation on motor finance redress?", "acceptedAnswer": { "@type": "Answer", "text": "The FCA is committed to launching its formal consultation in October 2025, with scheme rules finalized in time for compensation payments in the following year." } }, { "@type": "Question", "name": "How are Claims Management Companies (CMCs) impacting the sector?", "acceptedAnswer": { "@type": "Answer", "text": "CMCs are actively targeting motor finance portfolios, inundating firms with complex, time-consuming DSAR requests and disputing previous remediation outcomes." } } ] } ] } ``` ### Breaking down the ruling: what the Johnson case means for redress - URL: https://tcc.group/insights/analysis-perspectives/breaking-down-the-ruling-what-the-johnson-case-means-for-redress/ - Published: 2025-08-19 - Modified: 2026-09-02 **Topic:** Motor finance redress The Supreme Court's ruling narrowed successful claims to the Johnson case alone, but the FCA is still consulting on a compensation scheme for unfair motor finance commission arrangements. #### What happened? The Supreme Court overturned two of the three motor finance commission cases before it, but in the Johnson case it found that the commission arrangement created an unfair relationship between consumer and lender under the Consumer Credit Act, making the commission unlawful. Days after the ruling, the FCA confirmed it intends to consult on a compensation scheme for consumers treated unfairly through discretionary commission arrangements (DCAs), with a consultation paper expected by early October 2025. The FCA anticipates the scheme will be finalised in time for complainants to begin seeking compensation the following year, giving firms a clearer, though not yet final, timetable for handling the backlog of complaints. #### Why does it matter? Narrowing the ruling to discretionary commission arrangements is likely to reduce the overall value of redress compared with the wider concerns raised before judgment, offering some relief to boards on liability. That relief is offset by added operational complexity: firms must now triage discretionary commission complaints separately from other motor finance complaints while the FCA's scheme design is still unresolved. Understanding both the letter and the spirit of the ruling will matter as much as the final scheme rules, since firms are already managing significant complaint volumes ahead of the October consultation. #### Who is affected? Motor finance lenders and intermediaries that used discretionary commission arrangements, and any firm currently handling a rising volume of related complaints, are directly affected. Wider consumer credit providers should also take note, given the Supreme Court's findings on unfair relationships under the Consumer Credit Act have implications beyond motor finance alone. #### Key risks - Under-provisioning for redress before the FCA's compensation scheme design and scope are confirmed. - Failing to separate discretionary commission complaints from other motor finance complaints during triage. - Misreading the narrowed ruling as removing complexity, when operational and complaint-handling challenges remain. - Delay in preparing for the October consultation and the scheme's anticipated implementation the following year. #### Actions to take 1. Review current complaint volumes and exposure specifically relating to discretionary commission arrangements. 2. Establish a triage process that separates DCA complaints from other motor finance complaints. 3. Prepare provisioning estimates that can flex as the FCA's consultation paper clarifies scheme design. 4. Monitor the FCA's October consultation closely and respond to any opt-in or opt-out proposals. #### Wider implications The ruling and the FCA's response reinforce that unfair relationship findings under the Consumer Credit Act can reshape redress expectations well beyond the specific case considered. Firms across consumer credit should expect continued regulatory and judicial attention to commission structures and the fairness of arrangements between lenders, intermediaries and consumers. #### Recommendations Firms should use the period before the FCA's consultation paper to strengthen their evidence base: complaint data, commission arrangements and root-cause analysis specific to discretionary commission cases. Independent support in interpreting the ruling and assessing complaint exposure can help firms prepare a defensible position ahead of the compensation scheme's finalisation. #### Supporting sources - [Breaking down the ruling: what the Johnson case means for redress](https://tcc.group/blog/2025/08/20/breaking-down-the-ruling-what-the-johnson-case-means-for-redress/) (2025-08-20) #### Need help preparing for the DCA scheme? TCC, Recordsure and Momenta can provide regulatory insight, operational support and technology to help you navigate motor finance redress with confidence. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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commission arrangements in motor finance, but firms still face a pending FCA compensation scheme and the operational challenge of triaging a growing volume of complaints.", "inLanguage": "en-GB", "articleBody": "The Supreme Court's ruling narrowed successful claims to the Johnson case alone, but the FCA is still consulting on a compensation scheme for unfair motor finance commission arrangements.\n\nThe Supreme Court overturned two of the three motor finance commission cases before it, but in the Johnson case it found that the commission arrangement created an unfair relationship between consumer and lender under the Consumer Credit Act, making the commission unlawful.\n\nDays after the ruling, the FCA confirmed it intends to consult on a compensation scheme for consumers treated unfairly through discretionary commission arrangements (DCAs), with a consultation paper expected by early October 2025.\n\nThe FCA anticipates the scheme will be finalised in time for complainants to begin seeking compensation the following year, giving firms a clearer, though not yet final, timetable for handling the backlog of complaints.\n\nNarrowing the ruling to discretionary commission arrangements is likely to reduce the overall value of redress compared with the wider concerns raised before judgment, offering some relief to boards on liability.\n\nThat relief is offset by added operational complexity: firms must now triage discretionary commission complaints separately from other motor finance complaints while the FCA's scheme design is still unresolved.\n\nUnderstanding both the letter and the spirit of the ruling will matter as much as the final scheme rules, since firms are already managing significant complaint volumes ahead of the October consultation.\n\nMotor finance lenders and intermediaries that used discretionary commission arrangements, and any firm currently handling a rising volume of related complaints, are directly affected.\n\nWider consumer credit providers 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In a webinar led by experts from TCC, Recordsure and Momenta, Garry Evans, Chief Product Officer and Chief Commercial Officer for TCC Group, was joined by Gary Maude, who heads TCC's advisory function, and Mike Morris, Head of Operations at Momenta, to discuss the Supreme Court ruling on motor finance commission arrangements and the FCA's subsequent proposed redress scheme. The panel noted that the FCA's proposed approach has sparked concern across the sector, with many fearing the bar for “unfairness” is set too low, potentially widening the scope of complaints and increasing liability. A narrower focus, such as limiting cases to discretionary commission arrangements or shortening the lookback period, might ease the burden while increasing the need for robust, case-by-case handling. #### Why does it matter? The FCA's approach could trigger a wave of claims management company-led complaints, creating significant resourcing and reputational challenges for lenders on top of the operational task of large-scale remediation. Mike Morris has been preparing for the DCA remediation and redress programme for more than eighteen months, reflecting the scale of the task facing firms. How firms act now, ahead of the FCA's expected update in October, will shape their risk, resilience and regulatory relationships for years to come. #### Who is affected? Motor finance lenders and creditors are directly affected, particularly those with historical discretionary commission arrangements, along with their complaints handling, remediation and operations teams. #### Key risks - A wave of claims management company-led complaints if the FCA sets a low bar for “unfairness”. - Resourcing large-scale remediation programmes without sufficient operational capacity or planning. - Reputational damage from how firms are seen to handle complaints and remediation under scrutiny. - Inconsistent case-by-case handling if a narrower scope, such as DCAs only, is adopted without robust processes. #### Actions to take 1. Assess your firm's exposure to the proposed redress scheme, including historical discretionary commission arrangements. 2. Prepare for multiple scenarios, given the FCA has not yet confirmed the final scope or lookback period. 3. Strengthen governance and customer engagement ahead of the FCA's expected update in October. 4. Explore how technology, including AI, can help scale your complaint handling and remediation response. #### Wider implications The FCA's final position on scope and the lookback period will materially affect the size and shape of remediation and redress programmes across the sector, with knock-on effects for operational teams and customers alike. #### Recommendations Firms should use the period before the FCA's October update to strengthen governance, assess exposure across multiple possible scenarios, and consider how AI-enabled complaint handling can support a consistent, case-by-case response at scale. #### Supporting sources - [Driving change: The Supreme Court ruling sparks industry debate](https://tcc.group/blog/2025/08/19/driving-change-the-supreme-court-ruling-sparks-industry-debate/) (2025-08-19) #### Preparing for the motor finance redress scheme? TCC, Recordsure and Momenta can help you assess exposure, plan for multiple scenarios and scale your complaint handling response. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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"https://tcc.group/insights/analysis-perspectives/driving-change-the-supreme-court-ruling-sparks-industry-debate/#article", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/driving-change-the-supreme-court-ruling-sparks-industry-debate/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "Driving change: The Supreme Court ruling sparks industry debate", "datePublished": "2025-08-19T00:00:00+01:00", "dateModified": "2026-09-02T03:47:39+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/analysis-perspectives/driving-change-the-supreme-court-ruling-sparks-industry-debate/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/7004a9b5ebe442dca18f43b7421cf3bb/thumbnail-1024-4e4c4c990506e06a8940866c503776aeafaf97f0ffc3ed620628689d3e95b3a8.jpg", "description": "A TCC, Recordsure and Momenta webinar examines the FCA's proposed motor finance redress scheme after the Supreme Court ruling, and what lenders should do now to prepare for possible large-scale remediation.", "inLanguage": "en-GB", "articleBody": "TCC, Momenta and Recordsure examined the FCA's proposed motor finance redress scheme following the Supreme Court ruling on commission arrangements, warning that a low bar for \u2018unfairness\u2019 could widen complaint scope and increase liability.\n\nIn a webinar led by experts from TCC, Recordsure and Momenta, Garry Evans, Chief Product Officer and Chief Commercial Officer for TCC Group, was joined by Gary Maude, who heads TCC's advisory function, and Mike Morris, Head of Operations at Momenta, to discuss the Supreme Court ruling on motor finance commission arrangements and the FCA's subsequent proposed redress scheme.\n\nThe panel noted that the FCA's proposed approach has sparked concern across the sector, with many fearing the bar for \u201cunfairness\u201d is set too low, potentially widening the scope of complaints and increasing liability. A narrower focus, such as limiting cases to discretionary commission arrangements or shortening the lookback period, might ease the burden while increasing the need for robust, case-by-case handling.\n\nThe FCA's approach could trigger a wave of claims management company-led complaints, creating significant resourcing and reputational challenges for lenders on top of the operational task of large-scale remediation. 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Assess your firm's exposure to the proposed redress scheme, including historical discretionary commission arrangements.\n2. Prepare for multiple scenarios, given the FCA has not yet confirmed the final scope or lookback period.\n3. Strengthen governance and customer engagement ahead of the FCA's expected update in October.\n4. Explore how technology, including AI, can help scale your complaint handling and remediation response.\n\nThe FCA's final position on scope and the lookback period will materially affect the size and shape of remediation and redress programmes across the sector, with knock-on effects for operational teams and customers alike.\n\nFirms should use the period before the FCA's October update to strengthen governance, assess exposure across multiple possible scenarios, and consider how AI-enabled complaint handling can support a consistent, case-by-case response at scale.", "wordCount": 446, "keywords": [ "Complaints & Claims Handling", "Redress & Remediation", "Regulatory Change & Transformation", "Lending & Consumer Credit", "Motor Finance" ], "about": [ { "@type": "Thing", "name": "Complaints & Claims Handling", "url": "https://tcc.group/blog/solution/complaints-claims-handling/" }, { "@type": "Thing", "name": "Redress & Remediation", "url": "https://tcc.group/blog/solution/redress-and-remediation/" }, { "@type": "Thing", "name": "Regulatory Change & Transformation", "url": "https://tcc.group/blog/solution/regulatory-change-transformation/" }, { "@type": "Thing", "name": "Lending & Consumer Credit", "url": "https://tcc.group/blog/sector/lending-consumer-credit/" }, { "@type": "Thing", "name": "Motor Finance", "url": "https://tcc.group/blog/sector/motor-finance/" }, { "@type": "Thing", "name": "Motor finance redress scheme" } ], "articleSection": [ "Complaints & Claims Handling", "Redress & Remediation", "Regulatory Change & Transformation" ], "audience": [ { "@type": "Audience", "audienceType": "Lending & Consumer Credit" }, { "@type": "Audience", "audienceType": "Motor Finance" }, { "@type": "Audience", "audienceType": "Motor finance lenders and their complaints, remediation and operations teams preparing for the FCA's proposed redress scheme." } ], "citation": [ { "@type": "CreativeWork", "name": "Driving change: The Supreme Court ruling sparks industry debate", "url": "https://tcc.group/blog/2025/08/19/driving-change-the-supreme-court-ruling-sparks-industry-debate/", "datePublished": "2025-08-19" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/analysis-perspectives/driving-change-the-supreme-court-ruling-sparks-industry-debate/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/driving-change-the-supreme-court-ruling-sparks-industry-debate/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What is the FCA's proposed motor finance redress scheme about?", "acceptedAnswer": { "@type": "Answer", "text": "It relates to discretionary commission arrangements in motor finance, following the Supreme Court ruling on commission arrangements, and is intended to address potential customer unfairness." } }, { "@type": "Question", "name": "Why are firms concerned about the FCA's approach?", "acceptedAnswer": { "@type": "Answer", "text": "Many fear the bar for \u2018unfairness\u2019 is set too low, which could widen the scope of complaints and increase liability across the sector." } }, { "@type": "Question", "name": "Could the scope of the scheme be narrowed?", "acceptedAnswer": { "@type": "Answer", "text": "A narrower focus, such as limiting cases to discretionary commission arrangements or shortening the lookback period, could ease the burden while increasing the need for robust case-by-case handling." } }, { "@type": "Question", "name": "What should firms do before the FCA's October update?", "acceptedAnswer": { "@type": "Answer", "text": "Assess their exposure, prepare for multiple scenarios, strengthen governance and customer engagement, and explore how technology can help scale their response." } } ] } ] } ``` ### Preparing the motor finance industry for the surge in complaints - URL: https://tcc.group/insights/analysis-perspectives/fca-redress-consultation-explained-key-impacts-on-motor-finance/ - Published: 2025-08-17 - Modified: 2026-09-02 **Topic:** PCP Redress and Resourcing TCC experts review the operational impacts of the Supreme Court's Johnson ruling and the FCA's redress proposals, offering five key resourcing and tech-enabled steps for motor finance firms. #### What happened? TCC and Recordsure recently hosted an industry webinar: 'Driving change – FCA redress and the future of motor finance', featuring CCO Garry Evans, Advisory Director Gary Maude, and Momenta Head of Operations Mike Morris. The panel explored the massive operational challenge created by the Supreme Court's Johnson ruling and the FCA's proposed redress scheme. The discussion highlighted critical challenges, including handling CMC-driven complaints, resourcing massive remediation spikes, and deploying advanced technology to scale calculation and communication workflows. #### Why does it matter? The Supreme Court's Johnson ruling has narrowed the legal definition of commission fairness while complicating its operational application. While commission size, disclosure transparency, and consumer vulnerability dictate fairness, firms must assess cases individually rather than applying blanket rules. This individual assessment, coupled with a surge in claims management company (CMC) complaints, creates a major resourcing crisis. Lenders face a severe shortage of skilled complaints-handling personnel, making automated, tech-led workflows critical to process claims on time. #### Supporting sources - [Preparing the motor finance industry for the surge in complaints](https://tcc.group/blog/2025/08/18/preparing-the-motor-finance-industry-for-the-surge-in-complaints/) (2025-08-18) #### Is your motor finance team ready for the surge? Contact our automotive compliance and resourcing experts today to secure skilled complaints-handling personnel and deploy automated redress calculators. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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On Sunday 3 August 2025, the FCA confirmed it would consult on a compensation scheme intended to provide redress to consumers who were treated unfairly when taking out motor finance. This followed the Supreme Court's ruling on three cases in which the Court of Appeal had previously found that commission payments to car dealers were unlawful. The Supreme Court overturned two of the three cases, but in the third, it ruled that the commission arrangements had resulted in an unfair relationship between the consumer and the lender under section 140A of the Consumer Credit Act, making the commission unlawful. The FCA has committed to publishing a consultation paper by early October 2025 setting out its proposals, and anticipates the scheme being finalised in time for complainants to start receiving compensation the following year. #### Why does it matter? The FCA has stated that the scheme should cover discretionary commission arrangements (DCAs), where a broker could adjust the interest rate offered to a customer. Following the Supreme Court's ruling, it is also considering whether some non-discretionary commission arrangements should be included, on the basis that they may have been unfair under the Consumer Credit Act. The regulator has proposed that the scheme cover motor finance agreements dating back to 2007, to remain consistent with the period the Financial Ombudsman Service can consider. This scope, together with the criteria for unfairness, is likely to be challenged by the industry during the consultation process. #### Who is affected? Motor finance lenders and the dealers and brokers that arranged agreements with discretionary commission, particularly those with agreements dating back to 2007. Consumers who took out motor finance with a DCA, and potentially those with certain non-discretionary arrangements, may be eligible for redress. #### Key risks - Firms may not hold complete records for older agreements, particularly those dating back to 2007. - A rise in affordability complaints and data subject access requests is already apparent across the sector. - Uncertainty remains over whether the scheme will operate on an opt-in or opt-out basis. - The FCA's proposed criteria for unfairness may be challenged by the industry as too broad. #### Actions to take 1. Define the affected customer base: identify which customers held discretionary commission agreements and assess the quality and completeness of the underlying data. 2. Review policies and procedures to confirm they are designed, compliant and suitable for handling a redress scheme at scale, including dealer disclosure practices and distribution arrangements. 3. Plan operational resource, including experienced and qualified staff, to manage an expected rise in complaint and DSAR volumes without disrupting business-as-usual service levels. 4. Consider automation and workflow tools that can support accurate, auditable remediation of large customer populations. #### Wider implications The FCA may not expect redress payments before the end of the year, but boards need to understand their exposure and begin preparation immediately. Firms that plan in a structured way, with clear data governance, are better placed to manage redress at scale than those that wait for the final scheme details. #### Recommendations Early preparation, particularly around data integrity, governance and complaint handling, is the key differentiator between a reactive and a proactive response to a redress scheme of this size. #### Supporting sources - [Preparing the motor finance industry for the surge in complaints](https://tcc.group/blog/2025/08/04/motor-finance-redress-scheme-what-do-we-know-now/) (2025-08-04) #### Ready to prepare for the redress scheme? TCC supports motor finance firms with data-driven remediation planning, governance and complaint handling ahead of the FCA's redress scheme. [Talk to our experts](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/insights/regulatory-horizon/motor-finance-redress-scheme-what-do-we-know-now/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Insights", "item": "https://tcc.group/insights/" }, { "@type": "ListItem", "position": 3, "name": "Preparing the motor finance industry for the surge in complaints", "item": "https://tcc.group/insights/regulatory-horizon/motor-finance-redress-scheme-what-do-we-know-now/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/regulatory-horizon/motor-finance-redress-scheme-what-do-we-know-now/#webpage", "url": "https://tcc.group/insights/regulatory-horizon/motor-finance-redress-scheme-what-do-we-know-now/", "name": "Preparing the motor finance industry for the surge in complaints", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2025-08-04T00:00:00+01:00", "dateModified": "2026-09-02T03:47:58+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/regulatory-horizon/motor-finance-redress-scheme-what-do-we-know-now/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "NewsArticle", "@id": "https://tcc.group/insights/regulatory-horizon/motor-finance-redress-scheme-what-do-we-know-now/#article", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/motor-finance-redress-scheme-what-do-we-know-now/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "Preparing the motor finance industry for the surge in complaints", "datePublished": "2025-08-04T00:00:00+01:00", "dateModified": "2026-09-02T03:47:58+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/regulatory-horizon/motor-finance-redress-scheme-what-do-we-know-now/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/c82488b1f399450d980c33de903c3c15/thumbnail-1600-a1c04a9f851a644ef7aa0939b5da38d173c78180c0cbef597b671c105a1318dc.jpg", "description": "The Supreme Court's ruling on motor finance commission has prompted the FCA to consult on a compensation scheme. This explains what is known so far and the practical steps lenders should take now.", "inLanguage": "en-GB", "articleBody": "Following the Supreme Court's ruling on discretionary commission arrangements, the FCA has confirmed it will consult on a motor finance compensation scheme, and firms need to prepare now for a significant rise in complaints.\n\nOn Sunday 3 August 2025, the FCA confirmed it would consult on a compensation scheme intended to provide redress to consumers who were treated unfairly when taking out motor finance. This followed the Supreme Court's ruling on three cases in which the Court of Appeal had previously found that commission payments to car dealers were unlawful.\n\nThe Supreme Court overturned two of the three cases, but in the third, it ruled that the commission arrangements had resulted in an unfair relationship between the consumer and the lender under section 140A of the Consumer Credit Act, making the commission unlawful.\n\nThe FCA has committed to publishing a consultation paper by early October 2025 setting out its proposals, and anticipates the scheme being finalised in time for complainants to start receiving compensation the following year.\n\nThe FCA has stated that the scheme should cover discretionary commission arrangements (DCAs), where a broker could adjust the interest rate offered to a customer. Following the Supreme Court's ruling, it is also considering whether some non-discretionary commission arrangements should be included, on the basis that they may have been unfair under the Consumer Credit Act.\n\nThe regulator has proposed that the scheme cover motor finance agreements dating back to 2007, to remain consistent with the period the Financial Ombudsman Service can consider. This scope, together with the criteria for unfairness, is likely to be challenged by the industry during the consultation process.\n\nMotor finance lenders and the dealers and brokers that arranged agreements with discretionary commission, particularly those with agreements dating back to 2007. Consumers who took out motor finance with a DCA, and potentially those with certain non-discretionary arrangements, may be eligible for redress.\n\n\u2022 Firms may not hold complete records for older agreements, particularly those dating back to 2007.\n\u2022 A rise in affordability complaints and data subject access requests is already apparent across the sector.\n\u2022 Uncertainty remains over whether the scheme will operate on an opt-in or opt-out basis.\n\u2022 The FCA's proposed criteria for unfairness may be challenged by the industry as too broad.\n\n1. Define the affected customer base: identify which customers held discretionary commission agreements and assess the quality and completeness of the underlying data.\n2. Review policies and procedures to confirm they are designed, compliant and suitable for handling a redress scheme at scale, including dealer disclosure practices and distribution arrangements.\n3. Plan operational resource, including experienced and qualified staff, to manage an expected rise in complaint and DSAR volumes without disrupting business-as-usual service levels.\n4. Consider automation and workflow tools that can support accurate, auditable remediation of large customer populations.\n\nThe FCA may not expect redress payments before the end of the year, but boards need to understand their exposure and begin preparation immediately. Firms that plan in a structured way, with clear data governance, are better placed to manage redress at scale than those that wait for the final scheme details.\n\nEarly preparation, particularly around data integrity, governance and complaint handling, is the key differentiator between a reactive and a proactive response to a redress scheme of this size.", "wordCount": 547, "keywords": [ "Compliance AI & RegTech", "Suitability, Advice Quality & File Reviews", "Lending & Consumer Credit", "Motor Finance" ], "about": [ { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Suitability, Advice Quality & File Reviews", "url": "https://tcc.group/blog/solution/outsourced-suitability-reviews/" }, { "@type": "Thing", "name": "Lending & Consumer Credit", "url": "https://tcc.group/blog/sector/lending-consumer-credit/" }, { "@type": "Thing", "name": "Motor Finance", "url": "https://tcc.group/blog/sector/motor-finance/" }, { "@type": "Thing", "name": "Motor Finance DCA Redress" } ], "articleSection": [ "Compliance AI & RegTech", "Suitability, Advice Quality & File Reviews" ], "audience": [ { "@type": "Audience", "audienceType": "Lending & Consumer Credit" }, { "@type": "Audience", "audienceType": "Motor Finance" }, { "@type": "Audience", "audienceType": "Motor finance lenders and brokers preparing for a redress scheme and rising complaint volumes." } ], "citation": [ { "@type": "CreativeWork", "name": "Preparing the motor finance industry for the surge in complaints", "url": "https://tcc.group/blog/2025/08/04/motor-finance-redress-scheme-what-do-we-know-now/", "datePublished": "2025-08-04" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/regulatory-horizon/motor-finance-redress-scheme-what-do-we-know-now/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/motor-finance-redress-scheme-what-do-we-know-now/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What did the Supreme Court decide in the motor finance cases?", "acceptedAnswer": { "@type": "Answer", "text": "It overturned two of the three cases but found that, in the Johnson case, undisclosed commission had created an unfair relationship under the Consumer Credit Act, making the commission unlawful." } }, { "@type": "Question", "name": "What is a discretionary commission arrangement (DCA)?", "acceptedAnswer": { "@type": "Answer", "text": "A DCA is an arrangement where a broker or dealer could adjust the interest rate offered to a customer, which in turn affected the commission they received." } }, { "@type": "Question", "name": "How far back could the redress scheme reach?", "acceptedAnswer": { "@type": "Answer", "text": "The FCA has proposed that the scheme cover motor finance agreements dating back to 2007, in line with the period the Financial Ombudsman Service can consider." } }, { "@type": "Question", "name": "What should motor finance firms do now?", "acceptedAnswer": { "@type": "Answer", "text": "Firms should define their affected customer base, review policies and procedures, plan operational resource and consider automation to manage an expected rise in complaints." } } ] } ] } ``` ### Preparing the motor finance industry for the surge in commission complaints - URL: https://tcc.group/insights/white-papers-guides/surge-motor-finance/ - Published: 2025-07-21 - Modified: 2026-09-02 **Topic:** Motor Finance Commission Redress Following the Court of Appeal's ruling on undisclosed motor finance commissions, TCC sets out how the FCA's expected redress scheme could work and what firms should do to prepare. #### What happened? In October 2024, the Court of Appeal ruled that it was unlawful for brokers to receive commissions from lenders without disclosing them to customers and obtaining informed consent. The FCA has extended the complaint response window for affected cases to December 2025 while the industry awaits the Supreme Court's final judgment, and is preparing a formal redress scheme likely to be mandatory for relevant firms. The expected scheme could extend beyond discretionary commission arrangements to non-DCA commission models, and is likely to include firm-wide obligations on complaint handling, centralised guidance and standards for assessing harm and compensation. A new consumer-facing complaints portal may also be introduced, reducing reliance on claims management companies. #### Why does it matter? For motor finance providers, brokers and lenders, this is a test of operational readiness, not just a regulatory inconvenience. Firms will need to identify which customers were affected by historical commission arrangements and review how those disclosures were handled. Data quality, legal record accuracy and GDPR compliance will all affect a firm's ability to determine who is entitled to redress and to respond within the FCA's timelines. #### Who is affected? Motor finance brokers, lenders and providers involved in discretionary and non-discretionary commission arrangements, along with their complaints, compliance and data governance teams. #### Key risks - Historical commission disclosures that cannot be evidenced for affected customers. - Data quality or record-keeping gaps that make it difficult to identify who is entitled to redress. - Complaint-handling processes that cannot scale to a significant rise in volumes. - Wider exposure beyond discretionary commission arrangements if non-DCA models are brought into scope. #### Actions to take 1. Identify which customers were affected by historical commission disclosure practices. 2. Review data quality and legal record accuracy ahead of any redress scheme. 3. Build or refine internal processes for complaint triage and affordability review. 4. Prepare communication plans for consistent messaging across digital and non-digital channels. #### Wider implications Firms that act early, by strengthening internal governance, investing in scalable technology and training their teams, will be better placed to manage the scale of the expected redress scheme than those that wait for the Supreme Court's final ruling. #### Recommendations TCC recommends that firms treat automation, workflow tools and reporting as part of their redress readiness, and consider advisory support, interim resource or managed remediation where internal capacity is limited. #### Supporting sources - [Preparing the motor finance industry for the surge in commission complaints](https://tcc.group/blog/2025/07/22/surge-motor-finance/) (2025-07-22) #### Ready to prepare for motor finance redress? Talk to TCC about reviewing your motor finance commission complaints and redress readiness. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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"name": "Kit Ruparel" }, "headline": "Preparing the motor finance industry for the surge in commission complaints", "datePublished": "2025-07-22T00:00:00+01:00", "dateModified": "2026-09-02T03:48:04+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/white-papers-guides/surge-motor-finance/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/3f1986cdd13a434a9273c15a2a9f173b/thumbnail-1024-7902481934bec4a7c930fa9bd23b794096df8b17f0629e96187a2247c1da9a3f.jpg", "description": "TCC examines the Court of Appeal's motor finance commission ruling and the FCA's expected redress scheme, setting out what brokers and lenders should do to prepare operationally.", "inLanguage": "en-GB", "articleBody": "Following the Court of Appeal's ruling on undisclosed motor finance commissions, TCC sets out how the FCA's expected redress scheme could work and what firms should do to prepare.\n\nIn October 2024, the Court of Appeal ruled that it was unlawful for brokers to receive commissions from lenders without disclosing them to customers and obtaining informed consent. The FCA has extended the complaint response window for affected cases to December 2025 while the industry awaits the Supreme Court's final judgment, and is preparing a formal redress scheme likely to be mandatory for relevant firms.\n\nThe expected scheme could extend beyond discretionary commission arrangements to non-DCA commission models, and is likely to include firm-wide obligations on complaint handling, centralised guidance and standards for assessing harm and compensation. A new consumer-facing complaints portal may also be introduced, reducing reliance on claims management companies.\n\nFor motor finance providers, brokers and lenders, this is a test of operational readiness, not just a regulatory inconvenience. Firms will need to identify which customers were affected by historical commission arrangements and review how those disclosures were handled.\n\nData quality, legal record accuracy and GDPR compliance will all affect a firm's ability to determine who is entitled to redress and to respond within the FCA's timelines.\n\nMotor finance brokers, lenders and providers involved in discretionary and non-discretionary commission arrangements, along with their complaints, compliance and data governance teams.\n\n\u2022 Historical commission disclosures that cannot be evidenced for affected customers.\n\u2022 Data quality or record-keeping gaps that make it difficult to identify who is entitled to redress.\n\u2022 Complaint-handling processes that cannot scale to a significant rise in volumes.\n\u2022 Wider exposure beyond discretionary commission arrangements if non-DCA models are brought into scope.\n\n1. Identify which customers were affected by historical commission disclosure practices.\n2. Review data quality and legal record accuracy ahead of any redress scheme.\n3. Build or refine internal processes for complaint triage and affordability review.\n4. Prepare communication plans for consistent messaging across digital and non-digital channels.\n\nFirms that act early, by strengthening internal governance, investing in scalable technology and training their teams, will be better placed to manage the scale of the expected redress scheme than those that wait for the Supreme Court's final ruling.\n\nTCC recommends that firms treat automation, workflow tools and reporting as part of their redress readiness, and consider advisory support, interim resource or managed remediation where internal capacity is limited.", "wordCount": 401, "keywords": [ "Compliance AI & RegTech", "Suitability, Advice Quality & File Reviews", "Lending & Consumer Credit", "Motor Finance" ], "about": [ { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Suitability, Advice Quality & File Reviews", "url": "https://tcc.group/blog/solution/outsourced-suitability-reviews/" }, { "@type": "Thing", "name": "Lending & Consumer Credit", "url": "https://tcc.group/blog/sector/lending-consumer-credit/" }, { "@type": "Thing", "name": "Motor Finance", "url": "https://tcc.group/blog/sector/motor-finance/" }, { "@type": "Thing", "name": "Motor Finance Commission Redress" } ], "articleSection": [ "Compliance AI & RegTech", "Suitability, Advice Quality & File Reviews" ], "audience": [ { "@type": "Audience", "audienceType": "Lending & Consumer Credit" }, { "@type": "Audience", "audienceType": "Motor Finance" }, { "@type": "Audience", "audienceType": "Compliance, complaints and operations leaders at motor finance brokers, lenders and providers." } ], "citation": [ { "@type": "CreativeWork", "name": "Preparing the motor finance industry for the surge in commission complaints", "url": "https://tcc.group/blog/2025/07/22/surge-motor-finance/", "datePublished": "2025-07-22" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/white-papers-guides/surge-motor-finance/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/white-papers-guides/surge-motor-finance/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What triggered the motor finance commission complaints issue?", "acceptedAnswer": { "@type": "Answer", "text": "An October 2024 Court of Appeal ruling found it unlawful for brokers to receive commissions from lenders without disclosing them and obtaining informed consent." } }, { "@type": "Question", "name": "Until when has the FCA extended the complaint response window?", "acceptedAnswer": { "@type": "Answer", "text": "The FCA has extended the response window for affected cases to December 2025." } }, { "@type": "Question", "name": "Will non-discretionary commission models be affected?", "acceptedAnswer": { "@type": "Answer", "text": "TCC notes that non-DCA commission models could also come under scrutiny, not just discretionary commission arrangements." } }, { "@type": "Question", "name": "What should firms do now?", "acceptedAnswer": { "@type": "Answer", "text": "Identify affected customers, review data quality and legal records, and build complaint-handling and communication processes ready for a formal redress scheme." } } ] } ] } ``` ### Reflections on two years of Consumer Duty - URL: https://tcc.group/insights/analysis-perspectives/money-marketing-consumer-duty-turns-two/ - Published: 2025-07-14 - Modified: 2026-09-02 ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", 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https://tcc.group/insights/white-papers-guides/interim-resourcing/ - Published: 2025-07-10 - Modified: 2026-09-02 ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", 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TCC and its technology partner Recordsure took part in a large remediation programme in Australia, delivered with KPMG as part of the Royal Commission into financial services. The programme required consistent oversight of servicing records at a scale beyond what manual review could achieve. Recordsure's AI-powered technology was used to automate case assessment and surface insights from a large volume of client data. TCC's Chief Product and Commercial Officer, Garry Evans, discussed the outcome on stage at intelliflo's Innovate 2025 event. #### Why does it matter? The programme achieved an 85% efficiency gain: a project originally projected to span six years was completed in under one, at less than half the original cost. This shows that servicing records can be assessed at scale without relying solely on manual review. The "no-service" remediation issue addressed in Australia is similar to the ongoing advice servicing questions currently facing UK firms, where the ability to validate and reconstruct historic servicing activity has become both an operational need and a regulatory expectation. #### Who is affected? Firms that need to validate historic ongoing advice servicing, particularly where records date back to 2018 or earlier and align with the FCA's recent guidance on ongoing advice reviews. #### Key risks - Manual review processes that cannot cope with the volume of historic servicing records requiring assessment. - Limited visibility of gaps or risks in historic ongoing advice delivery. - Difficulty evidencing regulatory adherence where documentation is incomplete or inconsistent. #### Actions to take 1. Establish how far back historic servicing records need to be reviewed, taking account of FCA guidance. 2. Consider whether AI-assisted case assessment could reduce the time and cost of reviewing a large volume of records. 3. Combine automated analysis with specialist review to interpret findings, validate quality and provide regulatory assurance. 4. Build a clear view of historical ongoing advice delivery, including any gaps or risks that require remediation. #### Wider implications The Australian programme shows that combining automation with compliance expertise can materially change the pace and cost of a large-scale servicing review. For UK firms facing similar questions about historic ongoing advice, this points to an alternative to purely manual assessment. Where full documentation exists, this approach can also go beyond basic checks to assess the quality of advice communications, not just their presence. #### Recommendations Firms considering a review of historic ongoing advice servicing should assess whether the scale of the exercise justifies a technology-assisted approach, and should ensure any automated findings are reviewed by specialists who can provide compliance context. Firms should also build a dashboard, or equivalent view, that gives ongoing visibility of servicing delivery rather than treating the review as a one-off exercise. #### Supporting sources - [Redefining ongoing advice servicing oversight](https://tcc.group/blog/2025/07/08/redefining-ongoing-advice-oversight/) (2025-07-08) #### Want to review your ongoing advice servicing? Get in touch to find out how we can help you review historic servicing records and strengthen oversight of your ongoing advice process. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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historic ongoing advice servicing records in a remediation programme, with parallels to the servicing issues facing UK wealth management firms.\n\nTCC and its technology partner Recordsure took part in a large remediation programme in Australia, delivered with KPMG as part of the Royal Commission into financial services. The programme required consistent oversight of servicing records at a scale beyond what manual review could achieve.\n\nRecordsure's AI-powered technology was used to automate case assessment and surface insights from a large volume of client data. TCC's Chief Product and Commercial Officer, Garry Evans, discussed the outcome on stage at intelliflo's Innovate 2025 event.\n\nThe programme achieved an 85% efficiency gain: a project originally projected to span six years was completed in under one, at less than half the original cost. 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technology can analyse servicing records dating back to 2018 and beyond, aligned with the FCA's recent guidance." } } ] } ] } ``` ### Mastering regulatory due diligence in acquisitions - URL: https://tcc.group/insights/white-papers-guides/mastering-regulatory-due-diligence/ - Published: 2025-06-25 - Modified: 2026-09-02 ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" 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FCA’s findings mean for your firm - URL: https://tcc.group/insights/analysis-perspectives/consumer-duty-one-year-on-what-the-fcas-findings-mean-for-your-firm/ - Published: 2025-06-16 - Modified: 2026-08-04 **Topic:** Consumer Duty outcome monitoring A practical review of the FCA’s Consumer Duty findings and the evidence firms should strengthen across governance, products, communications and customer support. #### What happened? Consumer Duty moved the regulatory conversation from policy design to demonstrable customer outcomes. The FCA’s early findings make one point clear: having a framework is not enough. Firms need reliable evidence that products, communications, support and pricing work as intended for real customers, including those with characteristics of vulnerability. #### Why does it matter? Boards should be able to follow a clear line from the outcomes the firm wants to deliver to the measures used to monitor them. That means combining management information with customer journeys, complaints, quality assurance, behavioural data and remediation activity. A dashboard of green indicators is weak evidence if thresholds are poorly defined or if it hides material differences between customer groups. The annual assessment should therefore explain why each measure matters, what action was taken when performance moved outside tolerance, and whether that intervention improved the outcome. Challenge from independent risk and compliance teams should be visible in the record rather than implied. #### Who is affected? Boards, product owners, distributors, operations, risk and compliance teams all need to evidence how products and customer journeys perform, including for customers with characteristics of vulnerability. #### Key risks Product reviews are strongest when they examine foreseeable harm across the full lifecycle. Firms should revisit target markets, distribution assumptions, fair value evidence and the experience of customers who cancel, complain or need additional support. Communications testing should assess understanding, not simply confirm that required words are present. #### Actions to take Where distributors or outsourced providers influence the journey, firms need timely information and clear escalation routes. Gaps in data should trigger proportionate investigation rather than become a standing explanation for limited assurance. #### Wider implications A practical next step is to select a small number of high-risk journeys and test them end to end. Include customer files, call or message records, operational data and the decisions made by frontline teams. Compare the intended outcome with what actually happened, then document ownership and deadlines for improvement. #### Recommendations Consumer Duty should increasingly look like normal business governance: specific outcomes, credible measures, active challenge and prompt correction. Firms that can show this chain of evidence will be better prepared for supervisory questions and better placed to identify harm before it becomes systemic. #### Supporting sources - [FCA Consumer Duty publications and resources](https://www.fca.org.uk/firms/consumer-duty/publications-resources) - Reviewed by: TCC Group regulatory specialists, Regulatory compliance specialists #### Need stronger evidence from your controls? TCC Group can help you test higher-risk journeys, establish practical priorities and deliver controlled improvement. [Talk to our team](https://tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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In a session presented by TCC's Strategic Regulatory Director, Jason Wintle, alongside TCC and Recordsure's Chief Product and Commercial Officer, Garry Evans, and Claire Bell, Head of Regulatory Risk at Attivo, speakers set out the risks and opportunities facing advice firms on ongoing advice. The FCA's concerns are not new: for years it has warned against clients paying for services they might not receive. In February 2024, it issued a data request to the 22 largest firms, asking for the number of clients due a suitability review, the number that received one, and the number of cases where fees were refunded because the review did not take place. A second request in October 2024 probed the quality of reviews, including whether attitudes to risk and personal circumstances were reassessed. The FCA published its findings in February 2025, noting that suitability reviews were delivered in around 83% of cases and that the issues identified were not systemic. #### Why does it matter? While some in the industry read the February 2025 findings as reassuring, the underlying message is that firms need to be able to evidence the delivery of ongoing advice as part of business as usual, going back to 2018. A review cannot simply happen; it must be documented, measured and meet clear standards. Several firms have already been subject to section 166 reviews, and remediation work is ongoing across the sector. The FCA is expected to broaden its supervision beyond the original 22 firms and has signalled its intention to review the ongoing advice services rules in 2025, meaning further change is likely. Claims management companies are also paying close attention to this area. #### Who is affected? Wealth management and financial advice firms that charge for ongoing advice services, and the compliance and advice teams responsible for suitability reviews and client evidence. #### Key risks - Insufficient evidence on file to demonstrate that a suitability review took place and what it covered. - Client risk profiles and capacity for loss that are not regularly reassessed. - Ongoing advice services that continue after they have stopped adding value to the client. - Claims management company interest in firms that cannot evidence delivery of ongoing advice. #### Actions to take 1. Put in place a documented, repeatable process that ensures reviews are completed on time and client information is current. 2. Reassess clients' risk profiles and capacity for loss and record tailored, relevant recommendations at each review. 3. Monitor ongoing advice in real time and incorporate it into governance and board-level reporting, rather than treating it as an afterthought. 4. Stop the service and refund fees where appropriate if a client cannot be contacted or ongoing advice is no longer adding value. #### Wider implications The FCA's growing interest in ongoing advice is not only a regulatory challenge; it is a chance for firms to strengthen client relationships and modernise their operations. Predictive tools, such as Recordsure AI, can flag where reviews are overdue or incomplete, adding a layer of oversight that supports, rather than replaces, human judgment. #### Recommendations Firms should combine a backwards-looking review of past practice with a forward-looking, sustainable process for ongoing advice, supported by clear evidence and, where helpful, predictive tools that highlight overdue or incomplete reviews. #### Supporting sources - [Why it's time to rethink your approach to ongoing advice services](https://tcc.group/blog/2025/06/12/ongoing-advice-approach/) (2025-06-12) #### Time to review your ongoing advice approach? TCC can help you strengthen your processes, improve your evidence trail and explore how AI can support smarter, more efficient reviews. [Contact us](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/insights/analysis-perspectives/ongoing-advice-approach/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Insights", "item": "https://tcc.group/insights/" }, { "@type": "ListItem", "position": 3, "name": "Why it’s time to rethink your approach to ongoing advice services", "item": "https://tcc.group/insights/analysis-perspectives/ongoing-advice-approach/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/analysis-perspectives/ongoing-advice-approach/#webpage", "url": "https://tcc.group/insights/analysis-perspectives/ongoing-advice-approach/", "name": "Why it’s time to rethink your approach to ongoing advice services", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2025-06-12T00:00:00+01:00", "dateModified": "2026-09-02T03:47:59+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/analysis-perspectives/ongoing-advice-approach/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "AnalysisNewsArticle", "@id": "https://tcc.group/insights/analysis-perspectives/ongoing-advice-approach/#article", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/ongoing-advice-approach/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "Why it’s time to rethink your approach to ongoing advice services", "datePublished": "2025-06-12T00:00:00+01:00", "dateModified": "2026-09-02T03:47:59+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/analysis-perspectives/ongoing-advice-approach/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/c34e15ebb79848f197028528e3b494a9/thumbnail-1024-32fb2c7059a087f14bb9f50cb95a6d9b7f941f7570cb3bb03ad9cc14f208c674.jpg", "description": "Ongoing advice is no longer something firms can manage quietly. This sets out what the FCA's reviews have found so far and how firms can evidence delivery and prepare for closer scrutiny.", "inLanguage": "en-GB", "articleBody": "A TCC and Recordsure webinar set out why ongoing advice can no longer be managed in the background, covering the FCA's evolving expectations on suitability reviews and how predictive AI can support evidence and oversight.\n\nIn a session presented by TCC's Strategic Regulatory Director, Jason Wintle, alongside TCC and Recordsure's Chief Product and Commercial Officer, Garry Evans, and Claire Bell, Head of Regulatory Risk at Attivo, speakers set out the risks and opportunities facing advice firms on ongoing advice.\n\nThe FCA's concerns are not new: for years it has warned against clients paying for services they might not receive. In February 2024, it issued a data request to the 22 largest firms, asking for the number of clients due a suitability review, the number that received one, and the number of cases where fees were refunded because the review did not take place. A second request in October 2024 probed the quality of reviews, including whether attitudes to risk and personal circumstances were reassessed.\n\nThe FCA published its findings in February 2025, noting that suitability reviews were delivered in around 83% of cases and that the issues identified were not systemic.\n\nWhile some in the industry read the February 2025 findings as reassuring, the underlying message is that firms need to be able to evidence the delivery of ongoing advice as part of business as usual, going back to 2018. A review cannot simply happen; it must be documented, measured and meet clear standards.\n\nSeveral firms have already been subject to section 166 reviews, and remediation work is ongoing across the sector. The FCA is expected to broaden its supervision beyond the original 22 firms and has signalled its intention to review the ongoing advice services rules in 2025, meaning further change is likely. Claims management companies are also paying close attention to this area.\n\nWealth management and financial advice firms that charge for ongoing advice services, and the compliance and advice teams responsible for suitability reviews and client evidence.\n\n\u2022 Insufficient evidence on file to demonstrate that a suitability review took place and what it covered.\n\u2022 Client risk profiles and capacity for loss that are not regularly reassessed.\n\u2022 Ongoing advice services that continue after they have stopped adding value to the client.\n\u2022 Claims management company interest in firms that cannot evidence delivery of ongoing advice.\n\n1. Put in place a documented, repeatable process that ensures reviews are completed on time and client information is current.\n2. Reassess clients' risk profiles and capacity for loss and record tailored, relevant recommendations at each review.\n3. Monitor ongoing advice in real time and incorporate it into governance and board-level reporting, rather than treating it as an afterthought.\n4. Stop the service and refund fees where appropriate if a client cannot be contacted or ongoing advice is no longer adding value.\n\nThe FCA's growing interest in ongoing advice is not only a regulatory challenge; it is a chance for firms to strengthen client relationships and modernise their operations. Predictive tools, such as Recordsure AI, can flag where reviews are overdue or incomplete, adding a layer of oversight that supports, rather than replaces, human judgment.\n\nFirms should combine a backwards-looking review of past practice with a forward-looking, sustainable process for ongoing advice, supported by clear evidence and, where helpful, predictive tools that highlight overdue or incomplete reviews.", "wordCount": 556, "keywords": [ "Consumer Duty", "Suitability, Advice Quality & File Reviews", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Consumer Duty", "url": "https://tcc.group/blog/solution/consumer-duty/" }, { "@type": "Thing", "name": "Suitability, Advice Quality & File Reviews", "url": "https://tcc.group/blog/solution/outsourced-suitability-reviews/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": 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2025, the FCA reported that suitability reviews were delivered in around 83% of cases and that the issues identified were not systemic, though firms still need to evidence delivery." } }, { "@type": "Question", "name": "How far back should firms be able to evidence ongoing advice?", "acceptedAnswer": { "@type": "Answer", "text": "Firms should be able to provide evidence of ongoing advice delivery going back to 2018, as part of their business-as-usual approach." } }, { "@type": "Question", "name": "What should firms do if a client cannot be contacted?", "acceptedAnswer": { "@type": "Answer", "text": "Firms should be proactive, stopping the service and refunding fees where appropriate if a client cannot be contacted or the advice is no longer adding value." } }, { "@type": "Question", "name": "How can predictive AI help with ongoing advice reviews?", "acceptedAnswer": { "@type": "Answer", "text": "Predictive AI tools, such as Recordsure AI, can flag where reviews are overdue or incomplete, supporting human judgment rather than replacing it." } } ] } ] } ``` ### Ongoing advice remains high on the regulator's radar - URL: https://tcc.group/insights/analysis-perspectives/money-marketing-ongoing-advice-still-on-the-regulator-radar/ - Published: 2025-06-11 - Modified: 2026-09-02 ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 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Published: 2025-05-29 - Modified: 2025-05-29 **Topic:** Vulnerable Customer Strategy The final part of TCC's vulnerability webinar series outlines our house view on aligning corporate culture, product design, processes, data, and outcomes with FCA expectations. #### What happened? In the final installment of our vulnerable customers webinar series, we summarize TCC’s house view across five key operational areas: alignment, adaptation, identification, treatment, and outcomes. Firms are expected to embed vulnerability into their core strategy and culture, ensuring senior leaders have direct oversight and that policies translate into consistent frontline practices. #### Why does it matter? The FCA's supervisory focus has shifted to 'show me,' meaning that high-level policy papers on the wall are no longer sufficient. Firms must prove that their treatment plans are implemented and tracked through to completion. Crucially, vulnerability characteristics can be transient or compound. Systems must be dynamic enough to capture and adapt treatment plans as customer circumstances change. #### Who is affected? Firms across wealth management, pensions, payments, banking, lending, consumer credit, general insurance, and motor finance. #### Key risks - Treating vulnerability policies as a checklist exercise without aligning corporate culture and strategy. - Using rigid systems that fail to adapt when a vulnerable customer’s circumstances change. - Inability to produce clear management information (MI) showing positive client outcomes. #### Actions to take 1. Align culture and strategy so they are mutually reinforcing and fully evidenceable. 2. Review products and services regularly to ensure they are designed with vulnerability in mind. 3. Ensure systems collect granular, high-quality data to direct appropriate customer support. 4. Develop an MI portfolio to review customer satisfaction and lifecycle outcomes regularly. #### Wider implications A successful vulnerable customer strategy requires demonstrable links to key controls and committees. Senior management must actively review MI to identify and remediate areas of concern. #### Recommendations Firms should evaluate their current approach to vulnerability and partner with TCC to assess gaps, design training, and build evidence frameworks that withstand regulatory challenge. #### Supporting sources - [Part 4: Aligning strategy & practice to support vulnerable customers](https://tcc.group/blog/2025/05/30/tcc-webinar-part-four-embed-vulnerable-customer-strategy/) (2025-05-30) #### Is your vulnerability strategy truly embedded? Speak to TCC today about building a robust evidence framework to prove positive vulnerable customer outcomes. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/insights/analysis-perspectives/tcc-webinar-part-four-embed-vulnerable-customer-strategy/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Insights", "item": "https://tcc.group/insights/" }, { "@type": "ListItem", "position": 3, "name": "Part 4: Aligning strategy & practice to support vulnerable customers", "item": "https://tcc.group/insights/analysis-perspectives/tcc-webinar-part-four-embed-vulnerable-customer-strategy/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/analysis-perspectives/tcc-webinar-part-four-embed-vulnerable-customer-strategy/#webpage", "url": "https://tcc.group/insights/analysis-perspectives/tcc-webinar-part-four-embed-vulnerable-customer-strategy/", "name": "Part 4: Aligning strategy & practice to support vulnerable customers", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2025-05-30T00:00:00+01:00", "dateModified": "2025-05-30T00:00:00+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/analysis-perspectives/tcc-webinar-part-four-embed-vulnerable-customer-strategy/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "AnalysisNewsArticle", "@id": "https://tcc.group/insights/analysis-perspectives/tcc-webinar-part-four-embed-vulnerable-customer-strategy/#article", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/tcc-webinar-part-four-embed-vulnerable-customer-strategy/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "Part 4: Aligning strategy & practice to support vulnerable customers", "datePublished": "2025-05-30T00:00:00+01:00", "dateModified": "2025-05-30T00:00:00+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/analysis-perspectives/tcc-webinar-part-four-embed-vulnerable-customer-strategy/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/9074ec00f86b4f8d8199e091827c30ba/thumbnail-1024-b36a505040bff41573699136304a080d0a5dd60bbb14a524997f2d457944e890.jpg", "description": "Discover how to align culture, product design, and data to support vulnerable customers. Learn TCC's house view on meeting the FCA's five key areas of focus.", "inLanguage": "en-GB", "articleBody": "The final part of TCC's vulnerability webinar series outlines our house view on aligning corporate culture, product design, processes, data, and outcomes with FCA expectations.\n\nIn the final installment of our vulnerable customers webinar series, we summarize TCC\u2019s house view across five key operational areas: alignment, adaptation, identification, treatment, and outcomes.\n\nFirms are expected to embed vulnerability into their core strategy and culture, ensuring senior leaders have direct oversight and that policies translate into consistent frontline practices.\n\nThe FCA's supervisory focus has shifted to 'show me,' meaning that high-level policy papers on the wall are no longer sufficient. Firms must prove that their treatment plans are implemented and tracked through to completion.\n\nCrucially, vulnerability characteristics can be transient or compound. Systems must be dynamic enough to capture and adapt treatment plans as customer circumstances change.\n\nFirms across wealth management, pensions, payments, banking, lending, consumer credit, general insurance, and motor finance.\n\n\u2022 Treating vulnerability policies as a checklist exercise without aligning corporate culture and strategy.\n\u2022 Using rigid systems that fail to adapt when a vulnerable customer\u2019s circumstances change.\n\u2022 Inability to produce clear management information (MI) showing positive client outcomes.\n\n1. Align culture and strategy so they are mutually reinforcing and fully evidenceable.\n2. Review products and services regularly to ensure they are designed with vulnerability in mind.\n3. Ensure systems collect granular, high-quality data to direct appropriate customer support.\n4. Develop an MI portfolio to review customer satisfaction and lifecycle outcomes regularly.\n\nA successful vulnerable customer strategy requires demonstrable links to key controls and committees. 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In part three of TCC’s vulnerability webinar series, Garry Evans is joined by Juana Diaz-Landinez and Gary Maude to explore how firms can build 'safe environments' to support vulnerable customers. Many customers hesitate to disclose their vulnerability due to fear, embarrassment, or concern about how their data might be used. Firms must move away from expecting customers to self-identify and instead reduce barriers to trust. #### Why does it matter? Supervisors complain that firms are unable to identify or monitor outcomes for vulnerable customers due to poor data and unengaged senior leadership. Evidencing is the key benchmark for compliance. Furthermore, internal conflict can arise where advisors face sales pressures to fast-track transactions, making it vital to establish friction and robust controls in the customer journey. #### Who is affected? Quality assurance and frontline advisory teams across banking, insurance, lending, wealth management, and consumer credit. #### Key risks - Relying on client self-identification as the sole method of screening for vulnerability. - Subjecting vulnerable customers to burdensome processes to prove their circumstances, causing distress. - Failing to identify transient or multiple vulnerabilities during ongoing customer touchpoints. #### Actions to take 1. Build a positive disclosure environment that actively promotes the benefits of sharing information. 2. Train staff to treat every client touchpoint as an opportunity to detect changes in circumstances. 3. Review quality assurance frameworks to ensure they capture both static and thematic monitoring. 4. Incorporate contraindicators like arrears, litigation, and declined claims into your MI. #### Wider implications Meaningful monitoring requires a holistic view of vulnerability across all three lines of defense. Senior leadership must be actively engaged, ensuring committees review relevant MI and agree on clear remediation actions. #### Recommendations TCC recommends firms evaluate their QA metrics, remove non-material weighting, and design disclosure environments that protect and empower vulnerable customers. #### Supporting sources - [Part 3: Creating safe environments & evidencing support](https://tcc.group/blog/2025/05/29/tcc-webinar-part-three-safe-environments-vulnerable-customers/) (2025-05-29) #### Is your disclosure environment truly safe? Talk to our consultants about building an empathetic customer journey and robust monitoring frameworks. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/insights/analysis-perspectives/tcc-webinar-part-three-safe-environments-vulnerable-customers/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Insights", "item": "https://tcc.group/insights/" }, { "@type": "ListItem", "position": 3, "name": "Part 3: Creating safe environments & evidencing support", "item": "https://tcc.group/insights/analysis-perspectives/tcc-webinar-part-three-safe-environments-vulnerable-customers/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/analysis-perspectives/tcc-webinar-part-three-safe-environments-vulnerable-customers/#webpage", "url": "https://tcc.group/insights/analysis-perspectives/tcc-webinar-part-three-safe-environments-vulnerable-customers/", "name": "Part 3: Creating safe environments & evidencing support", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2025-05-29T00:00:00+01:00", "dateModified": "2025-05-29T00:00:00+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/analysis-perspectives/tcc-webinar-part-three-safe-environments-vulnerable-customers/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "AnalysisNewsArticle", "@id": "https://tcc.group/insights/analysis-perspectives/tcc-webinar-part-three-safe-environments-vulnerable-customers/#article", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/tcc-webinar-part-three-safe-environments-vulnerable-customers/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "Part 3: Creating safe environments & evidencing support", "datePublished": "2025-05-29T00:00:00+01:00", "dateModified": "2025-05-29T00:00:00+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/analysis-perspectives/tcc-webinar-part-three-safe-environments-vulnerable-customers/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/7331a565b35f4ffa8fac1de4832c5f2f/thumbnail-1024-a47805a377e78e8b9677bc36bd7bedec3e700c784fa4c971af618c52c4f4d125.jpg", "description": "Discover how to build a safe disclosure environment for vulnerable customers. Learn how to overcome barriers to disclosure and implement meaningful compliance monitoring.", "inLanguage": "en-GB", "articleBody": "Part three of TCC's vulnerable customers webinar series examines the importance of building 'safe environments' that encourage client transparency and discusses how to establish effective monitoring.\n\nIn part three of TCC\u2019s vulnerability webinar series, Garry Evans is joined by Juana Diaz-Landinez and Gary Maude to explore how firms can build 'safe environments' to support vulnerable customers.\n\nMany customers hesitate to disclose their vulnerability due to fear, embarrassment, or concern about how their data might be used. Firms must move away from expecting customers to self-identify and instead reduce barriers to trust.\n\nSupervisors complain that firms are unable to identify or monitor outcomes for vulnerable customers due to poor data and unengaged senior leadership. Evidencing is the key benchmark for compliance.\n\nFurthermore, internal conflict can arise where advisors face sales pressures to fast-track transactions, making it vital to establish friction and robust controls in the customer journey.\n\nQuality assurance and frontline advisory teams across banking, insurance, lending, wealth management, and consumer credit.\n\n\u2022 Relying on client self-identification as the sole method of screening for vulnerability.\n\u2022 Subjecting vulnerable customers to burdensome processes to prove their circumstances, causing distress.\n\u2022 Failing to identify transient or multiple vulnerabilities during ongoing customer touchpoints.\n\n1. Build a positive disclosure environment that actively promotes the benefits of sharing information.\n2. Train staff to treat every client touchpoint as an opportunity to detect changes in circumstances.\n3. Review quality assurance frameworks to ensure they capture both static and thematic monitoring.\n4. 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In the second part of TCC’s vulnerability webinar series, Gary Maude and Garry Evans focus on how firms can align strategy, culture, and operational controls to deliver positive outcomes. A successful approach requires senior management to actively drive a clear risk appetite down through the business, rather than allowing individual business areas to create their own siloed cultures. #### Why does it matter? Firms often struggle with the 'empowerment conundrum'—allowing frontline staff flexibility to help vulnerable clients while maintaining regulatory consistency. Without structured parameters and detailed process granularity, decisions become highly subjective, leading to inconsistent treatment and the dilution of strategic controls. #### Who is affected? Operational leaders and compliance teams across banking, consumer credit, wealth management, insurance, and motor finance. #### Key risks - Allowing business areas to drive up operational culture, causing fragmented compliance standards. - Frontline processes that are too open to subjective interpretation, leading to inconsistent outcomes. - Confusing 'nice' treatment with 'fair' treatment, which can inadvertently harm clients' long-term credit or financial interests. #### Actions to take 1. Establish a clear, firm-wide vulnerability risk appetite statement owned by senior management. 2. Incorporate vulnerability considerations directly into your product governance cycle from design to launch. 3. Define structured parameters for frontline staff to balance flexibility with process consistency. 4. Ensure staff competency training is highly challenging and goes beyond a simple annual checklist. #### Wider implications Service designs must be reviewed to eliminate counterintuitive targets, such as pressuring call center staff to resolve calls quickly regardless of the client's vulnerability. Robust controls must monitor the end-to-end customer journey. #### Recommendations Firms should review their operational processes to ensure they provide sufficient granularity for staff to handle multiple and transient vulnerabilities consistently. #### Supporting sources - [Part 2: How to embed and evidence your vulnerability strategy](https://tcc.group/blog/2025/05/28/tcc-webinar-part-two-embed-vulnerability-strategy/) (2025-05-28) #### Are your vulnerability controls robust enough? Speak to TCC about reviewing your risk appetite, training your staff, and embedding a cohesive vulnerability strategy. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/insights/analysis-perspectives/tcc-webinar-part-two-embed-vulnerability-strategy/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Insights", "item": "https://tcc.group/insights/" }, { "@type": "ListItem", "position": 3, "name": "Part 2: How to embed and evidence your vulnerability strategy", "item": "https://tcc.group/insights/analysis-perspectives/tcc-webinar-part-two-embed-vulnerability-strategy/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/analysis-perspectives/tcc-webinar-part-two-embed-vulnerability-strategy/#webpage", "url": "https://tcc.group/insights/analysis-perspectives/tcc-webinar-part-two-embed-vulnerability-strategy/", "name": "Part 2: How to embed and evidence your vulnerability strategy", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2025-05-28T00:00:00+01:00", "dateModified": "2025-05-28T00:00:00+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/analysis-perspectives/tcc-webinar-part-two-embed-vulnerability-strategy/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "AnalysisNewsArticle", "@id": "https://tcc.group/insights/analysis-perspectives/tcc-webinar-part-two-embed-vulnerability-strategy/#article", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/tcc-webinar-part-two-embed-vulnerability-strategy/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "Part 2: How to embed and evidence your vulnerability strategy", "datePublished": "2025-05-28T00:00:00+01:00", "dateModified": "2025-05-28T00:00:00+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/analysis-perspectives/tcc-webinar-part-two-embed-vulnerability-strategy/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/dcdbdc002f1d4d5bad57c9ab8c775401/thumbnail-1024-5feaa4a7f81a075cdb77378d92dbf9b6eedff7d61fb04ca7142a8d4e05bf5390.jpg", "description": "Learn how to align corporate culture, strategy, and controls to support vulnerable customers. Discover how to balance staff empowerment with process consistency.", "inLanguage": "en-GB", "articleBody": "Part two of TCC's vulnerability webinar series explores how firms can drive strategy and risk appetite down into operations to ensure consistent, compliant treatment of vulnerable customers.\n\nIn the second part of TCC\u2019s vulnerability webinar series, Gary Maude and Garry Evans focus on how firms can align strategy, culture, and operational controls to deliver positive outcomes.\n\nA successful approach requires senior management to actively drive a clear risk appetite down through the business, rather than allowing individual business areas to create their own siloed cultures.\n\nFirms often struggle with the 'empowerment conundrum'\u2014allowing frontline staff flexibility to help vulnerable clients while maintaining regulatory consistency.\n\nWithout structured parameters and detailed process granularity, decisions become highly subjective, leading to inconsistent treatment and the dilution of strategic controls.\n\nOperational leaders and compliance teams across banking, consumer credit, wealth management, insurance, and motor finance.\n\n\u2022 Allowing business areas to drive up operational culture, causing fragmented compliance standards.\n\u2022 Frontline processes that are too open to subjective interpretation, leading to inconsistent outcomes.\n\u2022 Confusing 'nice' treatment with 'fair' treatment, which can inadvertently harm clients' long-term credit or financial interests.\n\n1. 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In part one of TCC's vulnerability webinar series, regulatory experts Garry Evans and Gary Maude discuss why vulnerable customers continue to receive worse outcomes in the financial services sector. While the FCA’s guidelines on vulnerability remain unchanged, recent supervisory reviews highlight a significant gap in how firms apply these rules, resulting in inconsistent execution across customer journeys. #### Why does it matter? Statistics show that only 40% of vulnerable customers disclose their needs to their financial providers. Of those who do, a staggering number report negative experiences compared to non-vulnerable customers. Furthermore, the FCA has recently issued substantial fines ranging from £5.4 million to £10.9 million to major firms for failing to treat vulnerable customers in arrears fairly, underscoring the severe cost of non-compliance. #### Who is affected? All regulated financial sectors, including wealth management, pensions, banking, lending, consumer credit, general insurance, and motor finance. #### Key risks - Failure to identify vulnerable customers, with 60% of vulnerable clients choosing not to disclose their circumstances. - Corporate and senior management exposure under SMCR for allowing systematic customer detriment. - Severe financial costs from fines, Section 166 reviews, and past business reviews (PBR). #### Actions to take 1. Develop a proactive identification strategy instead of expecting clients to self-identify. 2. Review the cultural drivers within your business to ensure customer outcomes are prioritized over sales pressures. 3. Assess your compliance controls against recent FCA multi-sector and retail banking reviews. #### Wider implications Supervisors are looking closely at corporate governance. A firm’s inability to protect vulnerable customers is increasingly viewed as a failure of senior leadership and cultural design, rather than just a process error. #### Recommendations Firms should watch the full webinar series and evaluate how effectively their corporate culture translates into positive customer outcomes. #### Supporting sources - [Part 1: Understanding poorer outcomes for vulnerable customers](https://tcc.group/blog/2025/05/27/tcc-webinar-part-one-poorer-outxomes-vulnerable/) (2025-05-27) #### Are you confident in your vulnerability controls? Contact TCC today to learn how our experts can help you audit your vulnerability processes and protect customer outcomes. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/insights/analysis-perspectives/tcc-webinar-part-one-poorer-outxomes-vulnerable/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Insights", "item": "https://tcc.group/insights/" }, { "@type": "ListItem", "position": 3, "name": "Part 1: Understanding poorer outcomes for vulnerable customers", "item": "https://tcc.group/insights/analysis-perspectives/tcc-webinar-part-one-poorer-outxomes-vulnerable/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/analysis-perspectives/tcc-webinar-part-one-poorer-outxomes-vulnerable/#webpage", "url": "https://tcc.group/insights/analysis-perspectives/tcc-webinar-part-one-poorer-outxomes-vulnerable/", "name": "Part 1: Understanding poorer outcomes for vulnerable customers", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2025-05-27T00:00:00+01:00", "dateModified": "2025-05-27T00:00:00+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/analysis-perspectives/tcc-webinar-part-one-poorer-outxomes-vulnerable/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "AnalysisNewsArticle", "@id": "https://tcc.group/insights/analysis-perspectives/tcc-webinar-part-one-poorer-outxomes-vulnerable/#article", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/tcc-webinar-part-one-poorer-outxomes-vulnerable/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "Part 1: Understanding poorer outcomes for vulnerable customers", "datePublished": "2025-05-27T00:00:00+01:00", "dateModified": "2025-05-27T00:00:00+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/analysis-perspectives/tcc-webinar-part-one-poorer-outxomes-vulnerable/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/214911216b1045c6a79b94fea5890d9e/thumbnail-1024-f3141190c99680ae94314566330c196cb646f324f2fe5feca99196c8e0662d08.jpg", "description": "Understand the FCA's concerns regarding vulnerable customers. Learn why inconsistent execution causes worse outcomes and how to address barriers to customer disclosure.", "inLanguage": "en-GB", "articleBody": "The first part of TCC's vulnerability webinar series explores why vulnerable customers continue to receive poorer outcomes and discusses how firms must bridge the gap between policy and practice.\n\nIn part one of TCC's vulnerability webinar series, regulatory experts Garry Evans and Gary Maude discuss why vulnerable customers continue to receive worse outcomes in the financial services sector.\n\nWhile the FCA\u2019s guidelines on vulnerability remain unchanged, recent supervisory reviews highlight a significant gap in how firms apply these rules, resulting in inconsistent execution across customer journeys.\n\nStatistics show that only 40% of vulnerable customers disclose their needs to their financial providers. Of those who do, a staggering number report negative experiences compared to non-vulnerable customers.\n\nFurthermore, the FCA has recently issued substantial fines ranging from \u00a35.4 million to \u00a310.9 million to major firms for failing to treat vulnerable customers in arrears fairly, underscoring the severe cost of non-compliance.\n\nAll regulated financial sectors, including wealth management, pensions, banking, lending, consumer credit, general insurance, and motor finance.\n\n\u2022 Failure to identify vulnerable customers, with 60% of vulnerable clients choosing not to disclose their circumstances.\n\u2022 Corporate and senior management exposure under SMCR for allowing systematic customer detriment.\n\u2022 Severe financial costs from fines, Section 166 reviews, and past business reviews (PBR).\n\n1. Develop a proactive identification strategy instead of expecting clients to self-identify.\n2. Review the cultural drivers within your business to ensure customer outcomes are prioritized over sales pressures.\n3. Assess your compliance controls against recent FCA multi-sector and retail banking reviews.\n\nSupervisors are looking closely at corporate governance. 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In a recent TCC webinar, panellists Garry Evans, Gary Maude and Juana Diaz-Landinez explored how firms are applying the FCA's existing vulnerable customer guidance in practice. Polling found that only 18% of firms are highly confident their processes and controls meet FCA standards for identifying and managing vulnerable customers, with 68% moderately confident and 14% uncertain. Recent FCA reviews of multi-sector and retail banking firms found no new standards were needed, but did highlight significant gaps in application, with fines of £6 to £10 million issued where poor outcomes and weak oversight were found. #### Why does it matter? Redress amounts reported alongside these reviews are substantial: up to £185 million to HSBC customers, £105 million from TSB following a £10.9 million fine, and over £21.5 million from Volkswagen Financial Services to around 110,000 customers following a £5.4 million fine. The FCA's rules on vulnerability haven't changed significantly; the regulator's concern is that firms aren't consistently embedding them into day-to-day practice, and only 4 in 10 vulnerable customers say they have disclosed their needs. #### Who is affected? Firms across wealth management, pensions, payments, banking, lending, insurance and motor finance whose frontline staff, culture and processes shape how vulnerable customers are identified and supported. #### Key risks - Relying on self-disclosure, when the FCA reports only 40% of vulnerable customers come forward. - A cultural mismatch where frontline staff are incentivised to push sales over service. - Treating vulnerability as static, rather than dynamic and shaped by life events, health issues or economic shocks. - Lacking structured, evidenced monitoring of vulnerable customer outcomes, leaving firms unable to answer the FCA's 'show me, don't tell me' expectation. #### Actions to take 1. Align culture and strategy around vulnerability, and drive these values into processes, training and risk management. 2. Build proactive processes to identify indicators of vulnerability, rather than relying solely on customers to disclose. 3. Design personalised, proportionate treatment plans with ongoing monitoring and adaptation. 4. Capture structured data and metrics on vulnerable customer outcomes, including honest feedback from customers who received poor outcomes. #### Wider implications TCC's house view groups the FCA's priorities into five areas: alignment of strategy and culture, adaptation of products and processes, proactive identification, personalised treatment, and evidence that outcomes are fair. #### Recommendations Firms should move beyond 'being nice' to demonstrating fair outcomes, ensuring flexibility in how staff support customers is guided by clear frameworks rather than unstructured discretion. #### Supporting sources - [Firms express low confidence in current vulnerability support](https://tcc.group/blog/2025/05/23/vulnerability-financial-services-support/) (2025-05-23) #### How confident are you in vulnerability support? Book a no-obligation call with our regulatory specialists to review your firm's approach to supporting vulnerable customers. [Book a call](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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"https://tcc.group/insights/analysis-perspectives/vulnerability-financial-services-support/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/analysis-perspectives/vulnerability-financial-services-support/#webpage", "url": "https://tcc.group/insights/analysis-perspectives/vulnerability-financial-services-support/", "name": "Firms express low confidence in current vulnerability support", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2025-05-23T00:00:00+01:00", "dateModified": "2026-09-02T03:49:10+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/analysis-perspectives/vulnerability-financial-services-support/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "AnalysisNewsArticle", "@id": "https://tcc.group/insights/analysis-perspectives/vulnerability-financial-services-support/#article", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/vulnerability-financial-services-support/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "Firms express low confidence in current vulnerability support", "datePublished": "2025-05-23T00:00:00+01:00", "dateModified": "2026-09-02T03:49:10+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/analysis-perspectives/vulnerability-financial-services-support/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/449c318580364b18b6a373201f1de233/thumbnail-1024-73b0f98e2cbceb0e47770eb4b84788d679593697f3b83389c776e748c5a4aec5.jpg", "description": "Discover why only 18% of firms feel highly confident in supporting vulnerable customers, what recent FCA fines reveal about the gaps, and the five priority areas TCC recommends firms address now.", "inLanguage": "en-GB", "articleBody": "TCC's webinar panel found that just 18% of firms are highly confident their processes meet FCA standards for vulnerable customers, against a backdrop of significant fines and redress for poor outcomes.\n\nIn a recent TCC webinar, panellists Garry Evans, Gary Maude and Juana Diaz-Landinez explored how firms are applying the FCA's existing vulnerable customer guidance in practice.\n\nPolling found that only 18% of firms are highly confident their processes and controls meet FCA standards for identifying and managing vulnerable customers, with 68% moderately confident and 14% uncertain.\n\nRecent FCA reviews of multi-sector and retail banking firms found no new standards were needed, but did highlight significant gaps in application, with fines of \u00a36 to \u00a310 million issued where poor outcomes and weak oversight were found.\n\nRedress amounts reported alongside these reviews are substantial: up to \u00a3185 million to HSBC customers, \u00a3105 million from TSB following a \u00a310.9 million fine, and over \u00a321.5 million from Volkswagen Financial Services to around 110,000 customers following a \u00a35.4 million fine.\n\nThe FCA's rules on vulnerability haven't changed significantly; the regulator's concern is that firms aren't consistently embedding them into day-to-day practice, and only 4 in 10 vulnerable customers say they have disclosed their needs.\n\nFirms across wealth management, pensions, payments, banking, lending, insurance and motor finance whose frontline staff, culture and processes shape how vulnerable customers are identified and supported.\n\n\u2022 Relying on self-disclosure, when the FCA reports only 40% of vulnerable customers come forward.\n\u2022 A cultural mismatch where frontline staff are incentivised to push sales over service.\n\u2022 Treating vulnerability as static, rather than dynamic and shaped by life events, health issues or economic shocks.\n\u2022 Lacking structured, evidenced monitoring of vulnerable customer outcomes, leaving firms unable to answer the FCA's 'show me, don't tell me' expectation.\n\n1. Align culture and strategy around vulnerability, and drive these values into processes, training and risk management.\n2. Build proactive processes to identify indicators of vulnerability, rather than relying solely on customers to disclose.\n3. Design personalised, proportionate treatment plans with ongoing monitoring and adaptation.\n4. Capture structured data and metrics on vulnerable customer outcomes, including honest feedback from customers who received poor outcomes.\n\nTCC's house view groups the FCA's priorities into five areas: alignment of strategy and culture, adaptation of products and processes, proactive identification, personalised treatment, and evidence that outcomes are fair.\n\nFirms should move beyond 'being nice' to demonstrating fair outcomes, ensuring flexibility in how staff support customers is guided by clear frameworks rather than unstructured discretion.", "wordCount": 415, "keywords": [ "Consumer Duty", "Vulnerable Customers", "Banking", "General Insurance & Protection", "Lending & Consumer Credit", "Motor Finance", "Payments & FinTech", "Pensions & Retirement Income", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Consumer Duty", "url": "https://tcc.group/blog/solution/consumer-duty/" }, { "@type": "Thing", "name": "Vulnerable Customers", "url": "https://tcc.group/blog/solution/vulnerable-customers/" }, { "@type": "Thing", "name": "Banking", "url": "https://tcc.group/blog/sector/banking/" }, { "@type": "Thing", "name": "General Insurance & Protection", "url": "https://tcc.group/blog/sector/general-insurance-protection/" }, { "@type": "Thing", "name": "Lending & Consumer Credit", "url": "https://tcc.group/blog/sector/lending-consumer-credit/" }, { "@type": "Thing", "name": "Motor Finance", "url": "https://tcc.group/blog/sector/motor-finance/" }, { "@type": "Thing", "name": "Payments & FinTech", "url": "https://tcc.group/blog/sector/payments-fintech/" }, { "@type": "Thing", "name": "Pensions & Retirement Income", "url": "https://tcc.group/blog/sector/pensions-retirement-income/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Vulnerable customer support" } ], "articleSection": [ "Consumer Duty", "Vulnerable Customers" ], "audience": [ { "@type": "Audience", "audienceType": "Banking" }, { "@type": "Audience", "audienceType": "General Insurance & Protection" }, { "@type": "Audience", "audienceType": "Lending & Consumer Credit" }, { "@type": "Audience", "audienceType": "Motor Finance" }, { "@type": "Audience", "audienceType": "Payments & FinTech" }, { "@type": "Audience", "audienceType": "Pensions & Retirement Income" }, { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Compliance, advisory and customer outcomes teams across regulated financial services." } ], "citation": [ { "@type": "CreativeWork", "name": "Firms express low confidence in current vulnerability support", "url": "https://tcc.group/blog/2025/05/23/vulnerability-financial-services-support/", "datePublished": "2025-05-23" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/analysis-perspectives/vulnerability-financial-services-support/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/vulnerability-financial-services-support/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "How confident are firms in their vulnerable customer support?", "acceptedAnswer": { "@type": "Answer", "text": "TCC's webinar poll found only 18% of firms are highly confident their processes meet FCA standards, with 68% moderately confident and 14% uncertain." } }, { "@type": "Question", "name": "Has the FCA's guidance on vulnerable customers changed?", "acceptedAnswer": { "@type": "Answer", "text": "No major updates have been made; the FCA's concern is that firms aren't consistently applying existing rules in practice." } }, { "@type": "Question", "name": "What fines and redress have resulted from poor vulnerability outcomes?", "acceptedAnswer": { "@type": "Answer", "text": "Recent cases include fines of \u00a36 to \u00a310 million for poor outcomes, plus reported redress including up to \u00a3185 million from HSBC and \u00a3105 million from TSB." } }, { "@type": "Question", "name": "What are TCC's five priority areas for vulnerability?", "acceptedAnswer": { "@type": "Answer", "text": "Alignment of strategy and culture, adaptation of products and processes, proactive identification, personalised treatment, and evidence that outcomes are fair." } } ] } ] } ``` ### FCA's review flags gaps in support for vulnerable consumers - URL: https://tcc.group/insights/regulatory-horizon/the-fcas-multi-firm-review-flags-gaps-in-support-for-vulnerable-customers/ - Published: 2025-04-30 - Modified: 2026-09-02 **Topic:** Vulnerable customer outcomes The FCA's review of firms' treatment of vulnerable customers found that existing guidance and the Consumer Duty remain appropriate, but that outcomes for vulnerable customers still lag behind, particularly in wealth and asset management. Three firms have already been fined for related failures. #### What happened? The FCA has published the findings of its extensive review into how financial services firms support customers in vulnerable circumstances, and whether existing guidance remains appropriate. The regulator confirmed that current guidance, alongside the Consumer Duty, remains appropriate, but found sizeable gaps that need addressing. The wealth and asset management sector continues to fall behind others, with a small number of firms still claiming to have very few or no identified vulnerable customers. The FCA found that vulnerable customers receive worse outcomes than non-vulnerable customers, struggle to find products and services that meet their needs, and that firms are failing to adequately monitor these outcomes and take action where needed. #### Why does it matter? The FCA has already fined three firms for failures in the treatment of vulnerable customers: Volkswagen Finance (£5.4 million, for repossessing vehicles without adequately considering customers' circumstances), HSBC (£6.2 million, for not adequately considering customers' circumstances when they missed repayments) and TSB (£10.9 million, for failing to treat customers in arrears fairly). The FCA has confirmed it will continue to take vulnerable customer outcomes into account as part of its ongoing Consumer Duty work, signalling sustained supervisory focus in this area. #### Who is affected? Firms across wealth management and financial advice, pensions and retirement income, payments and fintech, banking, lending and consumer credit, general insurance and protection, and motor finance all need to evidence how they identify and support vulnerable customers. #### Key risks - Under-identifying vulnerable customers, particularly in wealth and asset management. - Failing to adequately monitor outcomes for vulnerable customers and act where needed. - Barriers to disclosure: FCA research found only four in ten customers with characteristics of vulnerability disclose it, often fearing poorer service. - Enforcement action, as seen with the fines imposed on Volkswagen Finance, HSBC and TSB. #### Actions to take 1. Define what signs of vulnerability your customer base may show, and what a good outcome looks like for those with additional or diverse needs. 2. Revisit how good outcomes for vulnerable customers are measured, and whether the current metrics give enough insight. 3. Review the quality of the data used to measure customer outcomes and ensure it provides actionable insight. 4. Examine barriers to disclosure and how clearly you communicate its benefits to customers. 5. Incorporate vulnerability data and insight into product design and review processes, training relevant staff. 6. Ensure senior leaders are engaged, including through a formal governance body with a vulnerable customer remit. #### Wider implications The FCA is folding vulnerable customer outcomes into its wider Consumer Duty supervision, meaning firms cannot treat this as a standalone policy exercise. Consistent monitoring and evidenced action are becoming baseline expectations across the sector. #### Recommendations TCC's regulatory experts can help firms review their vulnerable customer processes and client journey, deliver 'how to treat vulnerable customers' training, and review how embedded Consumer Duty changes have become. #### Supporting sources - [FCA's review flags gaps in support for vulnerable consumers](https://tcc.group/blog/2025/05/01/the-fcas-multi-firm-review-flags-gaps-in-support-for-vulnerable-customers/) (2025-05-01) #### Ready to review your vulnerable customer support? Speak to TCC's regulatory specialists about strengthening how your firm identifies and supports vulnerable customers. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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"https://tcc.group/insights/regulatory-horizon/the-fcas-multi-firm-review-flags-gaps-in-support-for-vulnerable-customers/#article", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/the-fcas-multi-firm-review-flags-gaps-in-support-for-vulnerable-customers/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "FCA’s review flags gaps in support for vulnerable consumers", "datePublished": "2025-05-01T00:00:00+01:00", "dateModified": "2026-09-02T03:49:06+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/regulatory-horizon/the-fcas-multi-firm-review-flags-gaps-in-support-for-vulnerable-customers/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/57919a1327d74213a1b40ebdfc50549c/thumbnail-1024-4f04943840bcb80b22f0830a32d200751c62ecae772b49ebfe38e550c9eb626b.png", "description": "Discover the FCA's key findings on vulnerable customer outcomes, the fines already issued to major firms, and ten practical steps to strengthen how your firm identifies, monitors and supports customers in vulnerable circumstances.", "inLanguage": "en-GB", "articleBody": "The FCA's review of firms' treatment of vulnerable customers found that existing guidance and the Consumer Duty remain appropriate, but that outcomes for vulnerable customers still lag behind, particularly in wealth and asset management. Three firms have already been fined for related failures.\n\nThe FCA has published the findings of its extensive review into how financial services firms support customers in vulnerable circumstances, and whether existing guidance remains appropriate.\n\nThe regulator confirmed that current guidance, alongside the Consumer Duty, remains appropriate, but found sizeable gaps that need addressing. The wealth and asset management sector continues to fall behind others, with a small number of firms still claiming to have very few or no identified vulnerable customers.\n\nThe FCA found that vulnerable customers receive worse outcomes than non-vulnerable customers, struggle to find products and services that meet their needs, and that firms are failing to adequately monitor these outcomes and take action where needed.\n\nThe FCA has already fined three firms for failures in the treatment of vulnerable customers: Volkswagen Finance (\u00a35.4 million, for repossessing vehicles without adequately considering customers' circumstances), HSBC (\u00a36.2 million, for not adequately considering customers' circumstances when they missed repayments) and TSB (\u00a310.9 million, for failing to treat customers in arrears fairly).\n\nThe FCA has confirmed it will continue to take vulnerable customer outcomes into account as part of its ongoing Consumer Duty work, signalling sustained supervisory focus in this area.\n\nFirms across wealth management and financial advice, pensions and retirement income, payments and fintech, banking, lending and consumer credit, general insurance and protection, and motor finance all need to evidence how they identify and support vulnerable customers.\n\n\u2022 Under-identifying vulnerable customers, particularly in wealth and asset management.\n\u2022 Failing to adequately monitor outcomes for vulnerable customers and act where needed.\n\u2022 Barriers to disclosure: FCA research found only four in ten customers with characteristics of vulnerability disclose it, often fearing poorer service.\n\u2022 Enforcement action, as seen with the fines imposed on Volkswagen Finance, HSBC and TSB.\n\n1. Define what signs of vulnerability your customer base may show, and what a good outcome looks like for those with additional or diverse needs.\n2. Revisit how good outcomes for vulnerable customers are measured, and whether the current metrics give enough insight.\n3. Review the quality of the data used to measure customer outcomes and ensure it provides actionable insight.\n4. Examine barriers to disclosure and how clearly you communicate its benefits to customers.\n5. Incorporate vulnerability data and insight into product design and review processes, training relevant staff.\n6. Ensure senior leaders are engaged, including through a formal governance body with a vulnerable customer remit.\n\nThe FCA is folding vulnerable customer outcomes into its wider Consumer Duty supervision, meaning firms cannot treat this as a standalone policy exercise. Consistent monitoring and evidenced action are becoming baseline expectations across the sector.\n\nTCC's regulatory experts can help firms review their vulnerable customer processes and client journey, deliver 'how to treat vulnerable customers' training, and review how embedded Consumer Duty changes have become.", "wordCount": 503, "keywords": [ "Consolidation, Acquisition & Regulatory Due Diligence", "Regulatory Change & Transformation", "Banking", "General Insurance & Protection", "Lending & Consumer Credit", "Motor Finance", "Payments & FinTech", "Pensions & Retirement Income", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Consolidation, Acquisition & Regulatory Due Diligence", "url": "https://tcc.group/blog/solution/consolidation-acquisition-regulatory-due-diligence/" }, { "@type": "Thing", "name": "Regulatory Change & Transformation", "url": "https://tcc.group/blog/solution/regulatory-change-transformation/" }, { "@type": "Thing", "name": "Banking", "url": "https://tcc.group/blog/sector/banking/" }, { "@type": "Thing", "name": "General Insurance & Protection", "url": "https://tcc.group/blog/sector/general-insurance-protection/" }, { "@type": "Thing", "name": "Lending & Consumer Credit", "url": "https://tcc.group/blog/sector/lending-consumer-credit/" }, { "@type": "Thing", "name": "Motor Finance", "url": "https://tcc.group/blog/sector/motor-finance/" }, { "@type": "Thing", "name": "Payments & FinTech", "url": "https://tcc.group/blog/sector/payments-fintech/" }, { "@type": "Thing", "name": "Pensions & Retirement Income", "url": "https://tcc.group/blog/sector/pensions-retirement-income/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Vulnerable customer outcomes" } ], "articleSection": [ "Consolidation, Acquisition & Regulatory Due Diligence", "Regulatory Change & Transformation" ], "audience": [ { "@type": "Audience", "audienceType": "Banking" }, { "@type": "Audience", "audienceType": "General Insurance & Protection" }, { "@type": "Audience", "audienceType": "Lending & Consumer Credit" }, { "@type": "Audience", "audienceType": "Motor Finance" }, { "@type": "Audience", "audienceType": "Payments & FinTech" }, { "@type": "Audience", "audienceType": "Pensions & Retirement Income" }, { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Compliance and customer outcomes teams across financial services, particularly wealth and asset management." } ], "citation": [ { "@type": "CreativeWork", "name": "FCA's review flags gaps in support for vulnerable consumers", "url": "https://tcc.group/blog/2025/05/01/the-fcas-multi-firm-review-flags-gaps-in-support-for-vulnerable-customers/", "datePublished": "2025-05-01" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/regulatory-horizon/the-fcas-multi-firm-review-flags-gaps-in-support-for-vulnerable-customers/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/the-fcas-multi-firm-review-flags-gaps-in-support-for-vulnerable-customers/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "Did the FCA introduce new rules for vulnerable customers?", "acceptedAnswer": { "@type": "Answer", "text": "No. The FCA confirmed existing guidance and the Consumer Duty remain appropriate, but firms need to close gaps in how outcomes are monitored and acted upon." } }, { "@type": "Question", "name": "Which firms have been fined over vulnerable customer treatment?", "acceptedAnswer": { "@type": "Answer", "text": "Volkswagen Finance, HSBC and TSB were fined a combined total of over \u00a322 million for failing to treat vulnerable customers fairly." } }, { "@type": "Question", "name": "Why do wealth and asset management firms need to pay particular attention?", "acceptedAnswer": { "@type": "Answer", "text": "The FCA specifically flagged this sector as lagging behind others, with some firms claiming to have very few or no identified vulnerable customers." } }, { "@type": "Question", "name": "How can firms encourage more customers to disclose vulnerability?", "acceptedAnswer": { "@type": "Answer", "text": "By addressing barriers to disclosure and clearly communicating its benefits, since FCA research found only four in ten customers with characteristics of vulnerability disclose it." } } ] } ] } ``` ### TCC Group acquires Momenta Group - URL: https://tcc.group/insights/press-releases/tcc-group-acquires-momenta-group-to-expand-compliance-and-resourcing-solutions-for-regulated-industries/ - Published: 2025-04-27 - Modified: 2025-04-27 **Topic:** Momenta Group Acquisition TCC Group has acquired the UK and Australian business of Momenta Group, a resourcing and client services provider for regulated industries, expanding TCC's compliance and specialist resourcing capacity. #### What happened? TCC Group, headed by The Consulting Consortium Holdings, has announced the acquisition of the assets and business of Momenta Group in the UK and Australia. Momenta supplies strategic client services and resourcing solutions to regulated industries. Joanne Smith, Founder and Executive Chair of TCC Group, said the acquisition brings together “proven, strategic solutions and innovation in environments where compliance, governance, and operational quality are non-negotiable”. Joe Norburn, CEO of TCC Group, said the deal reinforces a “combined network of over 30,000 highly-skilled, credible associates”. Momenta's UK Chief Delivery Officer, Kim McKeown, and Australia Operations Director, Simon Rippon, both commented on the acquisition, describing it as an opportunity to extend Momenta's services and resourcing capability to a wider client base through TCC Group. #### Why does it matter? The acquisition combines TCC Group's compliance advisory and technology capability, delivered alongside its Recordsure business, with Momenta's resourcing and implementation services. For clients of either organisation, this widens the combined pool of interim resource and specialist expertise available to support regulatory and compliance projects. For firms in regulated sectors, the expanded resourcing network may be relevant when planning projects that require additional short-term specialist capacity, such as remediation exercises, file reviews or regulatory change programmes. #### Who is affected? The acquisition is most relevant to compliance, risk and procurement functions at regulated financial services, utilities and government organisations that use interim or specialist resourcing to support compliance and regulatory projects, including existing clients of TCC Group and Momenta. #### Wider implications The acquisition reflects continued consolidation among providers offering compliance advisory, technology and specialist resourcing services to regulated industries, bringing these capabilities together under a single organisation rather than firms sourcing them separately. #### Recommendations Firms that use interim resourcing or client services support for compliance projects may wish to review how the combined TCC Group and Momenta offering could apply to upcoming regulatory change or remediation work, and to raise any questions about continuity of service with their existing contacts at either organisation. #### Supporting sources - [TCC Group acquires Momenta Group](https://tcc.group/blog/2025/04/28/tcc-group-acquires-momenta-group-to-expand-compliance-and-resourcing-solutions-for-regulated-industries/) (2025-04-28) #### Want to discuss your resourcing needs? Get in touch to find out how our combined compliance and specialist resourcing capability can support your organisation. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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".wp-block-excerpt" ] } }, { "@type": "NewsArticle", "@id": "https://tcc.group/insights/press-releases/tcc-group-acquires-momenta-group-to-expand-compliance-and-resourcing-solutions-for-regulated-industries/#article", "isPartOf": { "@id": "https://tcc.group/insights/press-releases/tcc-group-acquires-momenta-group-to-expand-compliance-and-resourcing-solutions-for-regulated-industries/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "TCC Group acquires Momenta Group", "datePublished": "2025-04-28T00:00:00+01:00", "dateModified": "2025-04-28T00:00:00+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/press-releases/tcc-group-acquires-momenta-group-to-expand-compliance-and-resourcing-solutions-for-regulated-industries/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/b0f81fe44fc14eeca8c719ea500d6436/thumbnail-1024-9a5bf08fbe598965c46e2e43b901128b22b0a9fc0ccdd5026d6d4e961fffcf02.png", "description": "TCC Group has acquired the UK and Australian business of Momenta Group, a resourcing and client services provider, extending TCC's compliance and specialist resourcing offering for regulated industries.", "inLanguage": "en-GB", "articleBody": "TCC Group has acquired the UK and Australian business of Momenta Group, a resourcing and client services provider for regulated industries, expanding TCC's compliance and specialist resourcing capacity.\n\nTCC Group, headed by The Consulting Consortium Holdings, has announced the acquisition of the assets and business of Momenta Group in the UK and Australia. Momenta supplies strategic client services and resourcing solutions to regulated industries.\n\nJoanne Smith, Founder and Executive Chair of TCC Group, said the acquisition brings together \u201cproven, strategic solutions and innovation in environments where compliance, governance, and operational quality are non-negotiable\u201d. Joe Norburn, CEO of TCC Group, said the deal reinforces a \u201ccombined network of over 30,000 highly-skilled, credible associates\u201d.\n\nMomenta's UK Chief Delivery Officer, Kim McKeown, and Australia Operations Director, Simon Rippon, both commented on the acquisition, describing it as an opportunity to extend Momenta's services and resourcing capability to a wider client base through TCC Group.\n\nThe acquisition combines TCC Group's compliance advisory and technology capability, delivered alongside its Recordsure business, with Momenta's resourcing and implementation services. For clients of either organisation, this widens the combined pool of interim resource and specialist expertise available to support regulatory and compliance projects.\n\nFor firms in regulated sectors, the expanded resourcing network may be relevant when planning projects that require additional short-term specialist capacity, such as remediation exercises, file reviews or regulatory change programmes.\n\nThe acquisition is most relevant to compliance, risk and procurement functions at regulated financial services, utilities and government organisations that use interim or specialist resourcing to support compliance and regulatory projects, including existing clients of TCC Group and Momenta.\n\nThe acquisition reflects continued consolidation among providers offering compliance advisory, technology and specialist resourcing services to regulated industries, bringing these capabilities together under a single organisation rather than firms sourcing them separately.\n\nFirms that use interim resourcing or client services support for compliance projects may wish to review how the combined TCC Group and Momenta offering could apply to upcoming regulatory change or remediation work, and to raise any questions about continuity of service with their existing contacts at either organisation.", "wordCount": 345, "about": [ { "@type": "Thing", "name": "Momenta Group Acquisition" } ], "audience": [ { "@type": "Audience", "audienceType": "Compliance, resourcing and procurement leaders at regulated financial services and government organisations." } ], "citation": [ { "@type": "CreativeWork", "name": "TCC Group acquires Momenta Group", "url": "https://tcc.group/blog/2025/04/28/tcc-group-acquires-momenta-group-to-expand-compliance-and-resourcing-solutions-for-regulated-industries/", "datePublished": "2025-04-28" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/press-releases/tcc-group-acquires-momenta-group-to-expand-compliance-and-resourcing-solutions-for-regulated-industries/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/press-releases/tcc-group-acquires-momenta-group-to-expand-compliance-and-resourcing-solutions-for-regulated-industries/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What has TCC Group acquired?", "acceptedAnswer": { "@type": "Answer", "text": "TCC Group has acquired the assets and business of Momenta Group, which trades in the UK and Australia and supplies strategic client services and resourcing solutions to regulated industries." } }, { "@type": "Question", "name": "Why did TCC Group acquire Momenta?", "acceptedAnswer": { "@type": "Answer", "text": "The acquisition combines TCC Group's compliance and regulatory expertise with Momenta's client services and resourcing capabilities, extending the resourcing network available to clients in regulated industries." } }, { "@type": "Question", "name": "Does this affect existing TCC Group or Momenta clients?", "acceptedAnswer": { "@type": "Answer", "text": "The announcement states that clients of both organisations will have access to TCC Group's regulatory expertise and Recordsure's RegTech, alongside Momenta's resourcing and implementation capabilities." } } ] } ] } ``` ### FCA's Review: Wealth Managers surprised by positive findings - URL: https://tcc.group/insights/analysis-perspectives/tcc-roundup-fca-ongoing-advice-key-findings-and-remaining-risks/ - Published: 2025-04-22 - Modified: 2025-04-22 **Topic:** FCA Ongoing Advice Review TCC's regulatory experts analyze the FCA's ongoing advice review findings, highlighting critical risks in self-reported data and outlining next steps for wealth management firms. #### What happened? A recent TCC poll revealed that 72% of wealth managers viewed the FCA’s ongoing advice services review findings as more positive than expected. However, experts caution against premature relief. The regulator's findings are heavily based on self-reported data and adviser attestations, rather than qualitative reviews of client files. There is significant variability in the quality and consistency of these responses across the industry. #### Why does it matter? The FCA is expected to revisit this area later in the year, and firms must be able to back up their claims with hard evidence. Relying purely on practice management system data as proof of a review is unlikely to satisfy supervisors. Firms need to show that reviews were substantive, including updated KYC, recent attitude-to-risk documentation, and suitability letters or contact logs for every service period dating back to 2018. #### Who is affected? Wealth management and financial advice firms providing ongoing services and charging annual advisory fees. #### Key risks - Relying on weak or incomplete records in practice management systems as evidence of advice. - Supervisory intervention if file samples fail to prove that a review took place. - Potential redress liabilities for clients charged ongoing fees where no substantive review was delivered. #### Actions to take 1. Audit a representative sample of client files to assess the quality of evidence supporting your ongoing reviews. 2. Verify that every client charged since 2018 can be mapped to one of the three FCA review buckets. 3. Update fair value assessments and disengagement processes to handle non-engaging clients. #### Wider implications The transition under Consumer Duty from 'tell me' to 'show me' means firms are fully responsible for evidencing compliance. Proportional and risk-based sampling of client files can help identify weaknesses before the regulator intervenes. #### Recommendations TCC recommends wealth managers conduct a backward-looking review to 2018 to evaluate files, identify gaps, and ensure a robust forward-looking compliance framework is in place. #### Supporting sources - [FCA's Review: Wealth Managers surprised by positive findings](https://tcc.group/blog/2025/04/23/tcc-roundup-fca-ongoing-advice-key-findings-and-remaining-risks/) (2025-04-23) #### Are you sure your ongoing reviews are evidenced? Talk to our experts about conducting a proportionate file review to ensure your evidence stands up to scrutiny. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/insights/analysis-perspectives/tcc-roundup-fca-ongoing-advice-key-findings-and-remaining-risks/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Insights", "item": "https://tcc.group/insights/" }, { "@type": "ListItem", "position": 3, "name": "FCA’s Review: Wealth Managers surprised by positive findings", "item": "https://tcc.group/insights/analysis-perspectives/tcc-roundup-fca-ongoing-advice-key-findings-and-remaining-risks/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/analysis-perspectives/tcc-roundup-fca-ongoing-advice-key-findings-and-remaining-risks/#webpage", "url": "https://tcc.group/insights/analysis-perspectives/tcc-roundup-fca-ongoing-advice-key-findings-and-remaining-risks/", "name": "FCA’s Review: Wealth Managers surprised by positive findings", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2025-04-23T00:00:00+01:00", "dateModified": "2025-04-23T00:00:00+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/analysis-perspectives/tcc-roundup-fca-ongoing-advice-key-findings-and-remaining-risks/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "Article", "@id": "https://tcc.group/insights/analysis-perspectives/tcc-roundup-fca-ongoing-advice-key-findings-and-remaining-risks/#article", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/tcc-roundup-fca-ongoing-advice-key-findings-and-remaining-risks/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "FCA’s Review: Wealth Managers surprised by positive findings", "datePublished": "2025-04-23T00:00:00+01:00", "dateModified": "2025-04-23T00:00:00+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/analysis-perspectives/tcc-roundup-fca-ongoing-advice-key-findings-and-remaining-risks/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/8d6531b987a84ab588bc67f9f77585b7/thumbnail-1024-6f7d0d309bd98a66eec203eae0e43590ccf9c232fd3b6bef0f7ddfc2face3d44.png", "description": "Explore expert insights on the FCA's ongoing advice review. Learn about remaining compliance risks, adviser attestation, and why relying on practice management data alone falls short.", "inLanguage": "en-GB", "articleBody": "TCC's regulatory experts analyze the FCA's ongoing advice review findings, highlighting critical risks in self-reported data and outlining next steps for wealth management firms.\n\nA recent TCC poll revealed that 72% of wealth managers viewed the FCA\u2019s ongoing advice services review findings as more positive than expected. However, experts caution against premature relief.\n\nThe regulator's findings are heavily based on self-reported data and adviser attestations, rather than qualitative reviews of client files. There is significant variability in the quality and consistency of these responses across the industry.\n\nThe FCA is expected to revisit this area later in the year, and firms must be able to back up their claims with hard evidence. Relying purely on practice management system data as proof of a review is unlikely to satisfy supervisors.\n\nFirms need to show that reviews were substantive, including updated KYC, recent attitude-to-risk documentation, and suitability letters or contact logs for every service period dating back to 2018.\n\nWealth management and financial advice firms providing ongoing services and charging annual advisory fees.\n\n\u2022 Relying on weak or incomplete records in practice management systems as evidence of advice.\n\u2022 Supervisory intervention if file samples fail to prove that a review took place.\n\u2022 Potential redress liabilities for clients charged ongoing fees where no substantive review was delivered.\n\n1. Audit a representative sample of client files to assess the quality of evidence supporting your ongoing reviews.\n2. Verify that every client charged since 2018 can be mapped to one of the three FCA review buckets.\n3. Update fair value assessments and disengagement processes to handle non-engaging clients.\n\nThe transition under Consumer Duty from 'tell me' to 'show me' means firms are fully responsible for evidencing compliance. Proportional and risk-based sampling of client files can help identify weaknesses before the regulator intervenes.\n\nTCC recommends wealth managers conduct a backward-looking review to 2018 to evaluate files, identify gaps, and ensure a robust forward-looking compliance framework is in place.", "wordCount": 323, "keywords": [ "Compliance AI & RegTech", "Suitability, Advice Quality & File Reviews", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Suitability, Advice Quality & File Reviews", "url": "https://tcc.group/blog/solution/outsourced-suitability-reviews/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "FCA Ongoing Advice Review" } ], "articleSection": [ "Compliance AI & RegTech", "Suitability, Advice Quality & File Reviews" ], "audience": [ { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Wealth managers, compliance officers, and operations directors at financial advisory firms." } ], "citation": [ { "@type": "CreativeWork", "name": "FCA's Review: Wealth Managers surprised by positive findings", "url": "https://tcc.group/blog/2025/04/23/tcc-roundup-fca-ongoing-advice-key-findings-and-remaining-risks/", "datePublished": "2025-04-23" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/analysis-perspectives/tcc-roundup-fca-ongoing-advice-key-findings-and-remaining-risks/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/tcc-roundup-fca-ongoing-advice-key-findings-and-remaining-risks/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "Why were the FCA's findings surprisingly positive?", "acceptedAnswer": { "@type": "Answer", "text": "Because they relied on self-reported survey data from firms, which can mask qualitative gaps in individual client files." } }, { "@type": "Question", "name": "What evidence does the FCA expect for an ongoing review?", "acceptedAnswer": { "@type": "Answer", "text": "The FCA expects to see updated KYC, an attitude-to-risk assessment, and a suitability report or clear proof of client contact." } }, { "@type": "Question", "name": "Does the review apply retrospectively?", "acceptedAnswer": { "@type": "Answer", "text": "Yes, wealth managers are expected to assess their reviews and client engagement history going back to January 2018." } } ] } ] } ``` ### A Growth Agenda is Good for the Consolidation Market - URL: https://tcc.group/insights/analysis-perspectives/growth-good-consolidation-market/ - Published: 2025-04-21 - Modified: 2026-09-02 **Topic:** Wealth Management Consolidation TCC's David Boyhan explores the growth opportunities in the UK wealth management consolidation market, emphasizing the role of robust data in satisfying regulatory standards. #### What happened? In his commentary published by Money Marketing, TCC's Technical Director David Boyhan analyzes the rapid growth and evolving opportunities within the UK wealth management consolidation market. As mergers, acquisitions, and consolidation gather pace, firms must ensure that integration strategies are supported by robust, clean, and high-quality data to navigate complex regulatory due diligence. #### Why does it matter? The FCA's rising standards of proof mean that consolidators cannot simply inherit historical compliance liabilities without comprehensive auditing. Enhanced data quality, thorough pre-acquisition review, and structured outcome monitoring are critical tools for satisfying FCA requirements and securing long-term integration success. Firms that prioritize rigorous regulatory due diligence and implement data-driven compliance during transitions will establish a significant competitive advantage. #### Who is affected? This media insight directly impacts wealth consolidators, financial advice networks, and transaction managers in the financial sector. #### Supporting sources - [A growth agenda is good for the consolidation market](https://tcc.group/blog/2025/04/22/growth-good-consolidation-market/) (2025-04-22) #### Are you planning a wealth management consolidation? Ensure successful integration, identify regulatory risks, and execute robust pre-acquisition due diligence with our specialist advisory team. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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wealth management consolidation market, emphasizing the role of robust data in satisfying regulatory standards.\n\nIn his commentary published by Money Marketing, TCC's Technical Director David Boyhan analyzes the rapid growth and evolving opportunities within the UK wealth management consolidation market.\n\nAs mergers, acquisitions, and consolidation gather pace, firms must ensure that integration strategies are supported by robust, clean, and high-quality data to navigate complex regulatory due diligence.\n\nThe FCA's rising standards of proof mean that consolidators cannot simply inherit historical compliance liabilities without comprehensive auditing. Enhanced data quality, thorough pre-acquisition review, and structured outcome monitoring are critical tools for satisfying FCA requirements and securing long-term integration success.\n\nFirms that prioritize rigorous regulatory due diligence and implement data-driven compliance during transitions will establish a significant competitive advantage.\n\nThis media insight directly impacts wealth consolidators, financial advice networks, and transaction managers in the financial sector.", "wordCount": 153, "keywords": [ "Compliance AI & RegTech", "Consolidation, Acquisition & Regulatory Due Diligence", "Regulatory Change & Transformation", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Consolidation, Acquisition & Regulatory Due Diligence", "url": "https://tcc.group/blog/solution/consolidation-acquisition-regulatory-due-diligence/" }, { "@type": "Thing", "name": "Regulatory Change & Transformation", "url": "https://tcc.group/blog/solution/regulatory-change-transformation/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Wealth Management Consolidation" } ], "articleSection": [ "Compliance AI & RegTech", "Consolidation, Acquisition & Regulatory Due Diligence", "Regulatory Change & Transformation" ], "audience": [ { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Wealth managers, consolidators, and advisory executives involved in mergers and acquisitions." } ], "citation": [ { "@type": "CreativeWork", "name": "A growth agenda is good for the consolidation market", "url": "https://tcc.group/blog/2025/04/22/growth-good-consolidation-market/", "datePublished": "2025-04-22" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/analysis-perspectives/growth-good-consolidation-market/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/growth-good-consolidation-market/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What is the primary challenge in wealth management consolidation?", "acceptedAnswer": { "@type": "Answer", "text": "Acquiring firms risk inheriting significant regulatory liabilities and historic file review issues if they fail to perform rigorous, data-driven pre-acquisition due diligence." } }, { "@type": "Question", "name": "How does enhanced data quality support consolidators?", "acceptedAnswer": { "@type": "Answer", "text": "It provides a clear, auditable trail of advice quality, helping firms demonstrate to the FCA that acquired books of business satisfy modern Consumer Duty expectations." } } ] } ] } ``` ### Preparing for change: FCA's review of protection product distribution and value - URL: https://tcc.group/insights/regulatory-horizon/preparing-for-change-fcas-review-of-protection-product-distribution-and-value/ - Published: 2025-04-13 - Modified: 2026-09-02 **Topic:** Protection Product Distribution Review The FCA's Market Study is examining how pure protection products are distributed, with a particular focus on commission arrangements, product value and outcomes for vulnerable customers. TCC sets out a six-step strategy for firms to prepare proactively. #### What happened? The FCA's Market Study into the distribution of pure protection products is focused on commission arrangements, and whether these affect a product's value, design or the way competition works in the market. Currently, there is no requirement to disclose the value of commission payments or how they affect the premium paid. The study is forward-looking: its objective is not to evaluate past conduct or determine whether redress is needed. The FCA has also acknowledged existing good outcomes in the market, including improved accessibility of cover and high claim payout ratios. The regulator is examining known risk areas, including unnecessary switching of products, commission models that may drive unsuitable sales, conflicts of interest within commission arrangements, and the complexity of the distribution chain. #### Why does it matter? Even where existing ICOBS disclosure rules are met, an imbalance of knowledge can remain between customers and insurers or intermediaries about protection needs, available options and reasonable cost. This is particularly significant given that consumers often buy pure protection products at a vulnerable point in their lives. The FCA is also reviewing indemnity-based distribution arrangements and insurer panels, noting that these can drive unsuitable sales or repeated re-broking, and that panel arrangements can limit market access for smaller insurers. #### Who is affected? Insurers and intermediaries involved in the distribution of pure protection products, including those using commission-based sales models, panel arrangements, lead generation or non-advised sales channels. #### Key risks - Commission structures that may drive unsuitable product sales or unnecessary switching. - Lead generation and marketing practices that route vulnerable customers towards the lowest-premium, non-advised options. - Insurer panel arrangements that limit competition or restrict access for smaller insurers. - Fair value assessments that do not adequately reflect the needs of vulnerable customers. #### Actions to take 1. Review product governance, design and distribution strategy to confirm customers can access products that meet their needs. 2. Evaluate incentive schemes to check they are not encouraging unnecessary switching or unsuitable sales. 3. Revisit fair value assessments, including whether they work well for vulnerable customers. 4. Review communication strategies to confirm customers receive the right information at the right time. 5. Assess management information to test for good outcomes across different customer cohorts and distribution channels. #### Wider implications The Market Study follows the pending motor finance commission Supreme Court decision, which has raised broader questions about commission-based distribution models across financial services. Firms in the protection market should expect continued scrutiny of commission structures and panel arrangements as a result. #### Recommendations Firms should treat the Market Study as an opportunity to review their distribution arrangements proactively, ahead of any formal findings, rather than waiting for the FCA to identify specific concerns. The six-step strategy set out above offers a practical starting point. #### Supporting sources - [Preparing for change: FCA's review of protection product distribution and value](https://tcc.group/blog/2025/04/14/preparing-for-change-fcas-review-of-protection-product-distribution-and-value/) (2025-04-14) #### Reviewing your protection product distribution? Our advisory team can support an independent review of your product governance, incentives and fair value assessments ahead of the FCA's findings. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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"The FCA's Market Study into pure protection product distribution focuses on commission arrangements, fair value and vulnerable customers. This article sets out a six-step strategy for insurers and intermediaries to prepare proactively for the outcome.", "inLanguage": "en-GB", "articleBody": "The FCA's Market Study is examining how pure protection products are distributed, with a particular focus on commission arrangements, product value and outcomes for vulnerable customers. TCC sets out a six-step strategy for firms to prepare proactively.\n\nThe FCA's Market Study into the distribution of pure protection products is focused on commission arrangements, and whether these affect a product's value, design or the way competition works in the market. Currently, there is no requirement to disclose the value of commission payments or how they affect the premium paid.\n\nThe study is forward-looking: its objective is not to evaluate past conduct or determine whether redress is needed. The FCA has also acknowledged existing good outcomes in the market, including improved accessibility of cover and high claim payout ratios.\n\nThe regulator is examining known risk areas, including unnecessary switching of products, commission models that may drive unsuitable sales, conflicts of interest within commission arrangements, and the complexity of the distribution chain.\n\nEven where existing ICOBS disclosure rules are met, an imbalance of knowledge can remain between customers and insurers or intermediaries about protection needs, available options and reasonable cost. This is particularly significant given that consumers often buy pure protection products at a vulnerable point in their lives.\n\nThe FCA is also reviewing indemnity-based distribution arrangements and insurer panels, noting that these can drive unsuitable sales or repeated re-broking, and that panel arrangements can limit market access for smaller insurers.\n\nInsurers and intermediaries involved in the distribution of pure protection products, including those using commission-based sales models, panel arrangements, lead generation or non-advised sales channels.\n\n\u2022 Commission structures that may drive unsuitable product sales or unnecessary switching.\n\u2022 Lead generation and marketing practices that route vulnerable customers towards the lowest-premium, non-advised options.\n\u2022 Insurer panel arrangements that limit competition or restrict access for smaller insurers.\n\u2022 Fair value assessments that do not adequately reflect the needs of vulnerable customers.\n\n1. Review product governance, design and distribution strategy to confirm customers can access products that meet their needs.\n2. Evaluate incentive schemes to check they are not encouraging unnecessary switching or unsuitable sales.\n3. Revisit fair value assessments, including whether they work well for vulnerable customers.\n4. Review communication strategies to confirm customers receive the right information at the right time.\n5. Assess management information to test for good outcomes across different customer cohorts and distribution channels.\n\nThe Market Study follows the pending motor finance commission Supreme Court decision, which has raised broader questions about commission-based distribution models across financial services. Firms in the protection market should expect continued scrutiny of commission structures and panel arrangements as a result.\n\nFirms should treat the Market Study as an opportunity to review their distribution arrangements proactively, ahead of any formal findings, rather than waiting for the FCA to identify specific concerns. The six-step strategy set out above offers a practical starting point.", "wordCount": 477, "keywords": [ "Consumer Duty", "Regulatory Change & Transformation", "General Insurance & Protection" ], "about": [ { "@type": "Thing", "name": "Consumer Duty", "url": "https://tcc.group/blog/solution/consumer-duty/" }, { "@type": "Thing", "name": "Regulatory Change & Transformation", "url": "https://tcc.group/blog/solution/regulatory-change-transformation/" }, { "@type": "Thing", "name": "General Insurance & Protection", "url": "https://tcc.group/blog/sector/general-insurance-protection/" }, { "@type": "Thing", "name": "Protection Product Distribution Review" } ], "articleSection": [ "Consumer Duty", "Regulatory Change & Transformation" ], "audience": [ { "@type": "Audience", "audienceType": "General Insurance & Protection" }, { "@type": "Audience", "audienceType": "Compliance and distribution teams at insurers and intermediaries operating in the pure protection market." } ], "citation": [ { "@type": "CreativeWork", "name": "Preparing for change: FCA's review of protection product distribution and value", "url": "https://tcc.group/blog/2025/04/14/preparing-for-change-fcas-review-of-protection-product-distribution-and-value/", "datePublished": "2025-04-14" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/regulatory-horizon/preparing-for-change-fcas-review-of-protection-product-distribution-and-value/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/preparing-for-change-fcas-review-of-protection-product-distribution-and-value/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What is the focus of the FCA's Market Study?", "acceptedAnswer": { "@type": "Answer", "text": "The Market Study focuses on commission arrangements in the distribution of pure protection products, and whether they affect product value, design or market competition." } }, { "@type": "Question", "name": "Is the Market Study looking at past conduct or redress?", "acceptedAnswer": { "@type": "Answer", "text": "No, the FCA has confirmed the study is forward-looking and its objective is not to evaluate past conduct or determine the need for redress." } }, { "@type": "Question", "name": "What good outcomes has the FCA already identified in the market?", "acceptedAnswer": { "@type": "Answer", "text": "The FCA has identified improved accessibility to cover, favourable pricing compared with other countries, and high ratios of claim payouts." } }, { "@type": "Question", "name": "What should firms do now?", "acceptedAnswer": { "@type": "Answer", "text": "TCC recommends a six-step strategy covering product governance, incentive schemes, fair value assessments, communications and management information." } } ] } ] } ``` ### Part 3: FCA's ongoing advice services review: long term compliance - URL: https://tcc.group/insights/analysis-perspectives/tcc-webinar-part-three-fca-ongoing-advice-services-review-long-term-compliance/ - Published: 2025-04-01 - Modified: 2025-04-01 **Topic:** Long-Term Ongoing Advice Compliance Part three of TCC's ongoing advice webinar focuses on achieving long-term compliance in wealth management, including the use of proportional sampling and the realities of client redress. #### What happened? In the final part of our ongoing advice webinar series, TCC experts Gary Maude and David Boyhan discuss proportional sampling, data mining challenges, and client redress models. While the FCA's survey results were surprisingly positive, firms are struggling to gather historical client records from disjointed, legacy practice systems, making complete compliance auditing a significant hurdle. #### Why does it matter? A major risk is adviser non-adherence to the firm's own processes, which carries severe professional indemnity (PI) and regulatory implications. Firms are currently evaluating redress models, with high-profile cases like St James' Place bringing widespread attention to how client contact, chronologies, and service delivery are documented and defended. #### Who is affected? Wealth management firms, financial advisory networks, and PI insurers managing exposure to ongoing advice fees. #### Key risks - Difficulty in extracting clean historical client data from legacy or paper-based systems. - Adviser non-compliance with internal protocols, increasing conduct risk. - Underestimating PI insurance implications when establishing past business reviews or calculating redress. #### Actions to take 1. Perform proportional file sampling to evaluate advice quality and identify systemic risks. 2. Document a clear chronology of client touchpoints and attempts to contact non-responsive clients. 3. Ensure disengagement processes are actively used for clients who no longer require or use services. 4. Engage senior leadership to review root cause analysis and underlying compliance trends. #### Wider implications Proportionality is a vital tool. Large-scale past business reviews can sometimes be avoided by executing robust, representative sampling to prove a lack of systemic client detriment, keeping PI insurers and regulators satisfied. #### Recommendations Wealth managers should establish a clear data-mining strategy and seek expert compliance support to design defensible, proportional file sampling methodologies. #### Supporting sources - [Part 3: FCA's ongoing advice services review: long term compliance](https://tcc.group/blog/2025/04/02/tcc-webinar-part-three-fca-ongoing-advice-services-review-long-term-compliance/) (2025-04-02) #### Need help designing a proportional file review? Contact TCC's advisory practice to discuss how we can help you navigate ongoing advice compliance and data extraction challenges. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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"description": "Learn about long-term compliance in wealth management. Explore proportional file sampling, data collection challenges, and the potential impact of client redress.", "inLanguage": "en-GB", "articleBody": "Part three of TCC's ongoing advice webinar focuses on achieving long-term compliance in wealth management, including the use of proportional sampling and the realities of client redress.\n\nIn the final part of our ongoing advice webinar series, TCC experts Gary Maude and David Boyhan discuss proportional sampling, data mining challenges, and client redress models.\n\nWhile the FCA's survey results were surprisingly positive, firms are struggling to gather historical client records from disjointed, legacy practice systems, making complete compliance auditing a significant hurdle.\n\nA major risk is adviser non-adherence to the firm's own processes, which carries severe professional indemnity (PI) and regulatory implications.\n\nFirms are currently evaluating redress models, with high-profile cases like St James' Place bringing widespread attention to how client contact, chronologies, and service delivery are documented and defended.\n\nWealth management firms, financial advisory networks, and PI insurers managing exposure to ongoing advice fees.\n\n\u2022 Difficulty in extracting clean historical client data from legacy or paper-based systems.\n\u2022 Adviser non-compliance with internal protocols, increasing conduct risk.\n\u2022 Underestimating PI insurance implications when establishing past business reviews or calculating redress.\n\n1. 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In part two of TCC’s ongoing advice webinar series, Garry Evans, Gary Maude, and David Boyhan unpack the critical next steps for wealth managers following the FCA’s review findings. The FCA requires a retrospective review of client records dating back to January 2018. Firms must categorize their clients into three distinct buckets: those who received a review, those who declined or did not engage, and those who were not offered a review. #### Why does it matter? The core compliance challenge is proving that a review took place. For completed reviews, the minimum evidence required on file is updated KYC and an ongoing suitability report letter. For clients who declined or did not engage, firms must produce chasers or invitations, as a lack of contact logs will place clients in the 'not offered' category, raising significant regulatory and redress risks. #### Who is affected? Wealth management groups, financial advisers, and compliance networks managing ongoing fee-charging advice services. #### Key risks - Insufficient evidence on file to prove that ongoing reviews occurred, risking regulatory action. - Relying on practice management system data rather than direct, qualitative evidence. - Fragmented record-keeping across older, paper-based, or legacy IT systems. #### Actions to take 1. Map your clients into the three FCA buckets for each annual service period back to 2018. 2. Verify that every completed review contains updated KYC and a suitability report letter. 3. Locate and document invitations or chasers sent to non-responsive or declining clients. 4. Incorporate ongoing advice data into senior management MI, conduct risk assessments, and Board challenges. #### Wider implications Firms are struggling to mine legacy data, meaning that some reviews cannot be easily verified. This has direct implications for professional indemnity (PI) insurance and potential redress liabilities if adviser non-compliance is uncovered. #### Recommendations Wealth management groups must design robust, defensible disengagement protocols and leverage expert compliance advisory to handle retrospective file reviews systematically. #### Supporting sources - [Part 2: FCA’s ongoing advice services review: next steps for wealth managers](https://tcc.group/blog/2025/04/01/tcc-webinar-part-two-fca-ongoing-advice-services-review-evidence-next-steps-for-wealth-managers/) (2025-04-01) #### Are your retrospective client records fully compliant? Contact TCC today to learn how our experts can support your backward-looking data reviews and disengagement strategies. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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Locate and document invitations or chasers sent to non-responsive or declining clients.\n4. Incorporate ongoing advice data into senior management MI, conduct risk assessments, and Board challenges.\n\nFirms are struggling to mine legacy data, meaning that some reviews cannot be easily verified. This has direct implications for professional indemnity (PI) insurance and potential redress liabilities if adviser non-compliance is uncovered.\n\nWealth management groups must design robust, defensible disengagement protocols and leverage expert compliance advisory to handle retrospective file reviews systematically.", "wordCount": 321, "keywords": [ "Compliance AI & RegTech", "Consumer Duty", "Suitability, Advice Quality & File Reviews", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Consumer Duty", "url": "https://tcc.group/blog/solution/consumer-duty/" }, { "@type": "Thing", "name": "Suitability, Advice Quality & File Reviews", "url": "https://tcc.group/blog/solution/outsourced-suitability-reviews/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "FCA Ongoing Advice Next Steps" } ], "articleSection": [ "Compliance AI & RegTech", "Consumer Duty", "Suitability, Advice Quality & File Reviews" ], "audience": [ { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Wealth managers, compliance officers, and operations directors responsible for client review processes." } ], "citation": [ { "@type": "CreativeWork", "name": "Part 2: FCA\u2019s ongoing advice services review: next steps for wealth managers", "url": "https://tcc.group/blog/2025/04/01/tcc-webinar-part-two-fca-ongoing-advice-services-review-evidence-next-steps-for-wealth-managers/", "datePublished": "2025-04-01" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/analysis-perspectives/tcc-webinar-part-two-fca-ongoing-advice-services-review-evidence-next-steps-for-wealth-managers/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/tcc-webinar-part-two-fca-ongoing-advice-services-review-evidence-next-steps-for-wealth-managers/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "Why is January 2018 the starting point for retrospective reviews?", "acceptedAnswer": { "@type": "Answer", "text": "This is when the MiFID II requirements came into play, introducing specific standards for ongoing advice services." } }, { "@type": "Question", "name": "What evidence is needed for a completed ongoing review?", "acceptedAnswer": { "@type": "Answer", "text": "Firms must have updated KYC records and a report letter confirming the client's ongoing suitability." } }, { "@type": "Question", "name": "What if a client declined a review?", "acceptedAnswer": { "@type": "Answer", "text": "Firms must have clear, documented evidence (such as emails or chaser logs) proving the client was invited to engage." } } ] } ] } ``` ### Wealth managers signal the FCA’s ongoing advice review presented better findings than they expected - URL: https://tcc.group/insights/regulatory-horizon/ongoing-advice-poll/ - Published: 2025-03-26 - Modified: 2026-09-02 **Topic:** Ongoing Advice Evidence Poll A TCC poll of wealth managers found that many firms have only partial evidence of ongoing advice reviews, and the FCA is expected to revisit its findings later in the year with a focus on the evidence firms hold. #### What happened? Although the FCA's initial review findings were viewed by some as a positive result for the sector, TCC cautions that they are based on self-reported information rather than a qualitative evaluation of individual client reviews. TCC's own work in this area has highlighted concerns about reliance on adviser attestation, since the quality and consistency of firms' responses varies markedly. TCC polled wealth managers on the evidence they hold: 38% said they have all the evidence needed to identify which clients received their review, 58% said they have only some of that evidence, and 4% said they have none at all. #### Why does it matter? The FCA has indicated it will revisit this topic later in the year, expecting firms to have evidence on file to substantiate the thoroughness of their suitability reviews. TCC's poll also found that 62% of wealth managers had the relevant fact-find and evidential report saved in their practice management system, 23% had only a checkmark to indicate a review was received, and 15% held evidence in a different format. The FCA's review categorises ongoing advice clients into three groups: those who received their review as anticipated, those who did not engage, and those who were not contacted at all, the last of whom are due redress. #### Who is affected? Wealth management firms providing ongoing advice services, and the compliance, risk and advice functions responsible for maintaining evidence of client reviews dating back to 2018. #### Key risks - Relying on adviser attestation without independently verifying the quality and consistency of reviews. - Holding evidence in inconsistent formats, such as a checkmark rather than a full fact-find or report. - Being unable to categorise clients correctly into the FCA's three review outcome groups. - Weak management information that does not allow senior managers to evidence oversight under SM&CR. #### Actions to take 1. For clients who received their review, keep up-to-date know-your-customer information and a report letter confirming ongoing suitability. 2. For clients who did not engage, keep documented evidence, such as an invitation email, that they were given the opportunity to take part. 3. Categorise client interactions dating back to 2018 into the three review outcome groups annually, and use this analysis to determine the right action for each client. 4. Review management information regularly, examine root causes of unusually favourable outcomes, and take action based on findings across advisers, branches and supervisors. #### Wider implications Senior managers are expected to demonstrate their compliance with the Senior Managers and Certification Regime alongside their board duties, providing sufficient evidence that these matters have been thoroughly considered. Firms will also need to closely examine fair value assessments and implement a thorough disengagement strategy for clients who meet the relevant criteria. #### Recommendations TCC recommends a twofold approach: a backwards-looking piece of work to establish the evidence firms already hold, and a forward-looking plan to ensure reviews are documented consistently going forward. Independent expertise can help firms demonstrate their commitment to conducting annual client reviews backed by thorough documentation. #### Supporting sources - [Wealth managers signal the FCA’s ongoing advice review presented better findings than they expected](https://tcc.group/blog/2025/03/27/ongoing-advice-poll/) (2025-03-27) #### How strong is your ongoing advice evidence? TCC's regulatory specialists help wealth management firms streamline compliance and confidently demonstrate reliable client reviews. [Contact us](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/insights/regulatory-horizon/ongoing-advice-poll/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Insights", "item": "https://tcc.group/insights/" }, { "@type": "ListItem", "position": 3, "name": "Wealth managers signal the FCA\u2019s ongoing advice review presented better findings than they expected", "item": "https://tcc.group/insights/regulatory-horizon/ongoing-advice-poll/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/regulatory-horizon/ongoing-advice-poll/#webpage", "url": "https://tcc.group/insights/regulatory-horizon/ongoing-advice-poll/", "name": "Wealth managers signal the FCA\u2019s ongoing advice review presented better findings than they expected", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2025-03-27T00:00:00+01:00", "dateModified": "2026-09-02T03:47:59+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/regulatory-horizon/ongoing-advice-poll/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "NewsArticle", "@id": "https://tcc.group/insights/regulatory-horizon/ongoing-advice-poll/#article", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/ongoing-advice-poll/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "Wealth managers signal the FCA\u2019s ongoing advice review presented better findings than they expected", "datePublished": "2025-03-27T00:00:00+01:00", "dateModified": "2026-09-02T03:47:59+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/regulatory-horizon/ongoing-advice-poll/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/4ef4e2b5d9154a4694be516a75f7d5cf/thumbnail-1024-f1b705c078dbe5b46a679f3b5e9cc14a4bc925e5c74bdfaa66c439060cf4ba0d.jpg", "description": "A TCC poll found many wealth managers hold only partial evidence of ongoing advice reviews. This looks at what the FCA expects firms to have on file before it revisits the topic.", "inLanguage": "en-GB", "articleBody": "A TCC poll of wealth managers found that many firms have only partial evidence of ongoing advice reviews, and the FCA is expected to revisit its findings later in the year with a focus on the evidence firms hold.\n\nAlthough the FCA's initial review findings were viewed by some as a positive result for the sector, TCC cautions that they are based on self-reported information rather than a qualitative evaluation of individual client reviews. TCC's own work in this area has highlighted concerns about reliance on adviser attestation, since the quality and consistency of firms' responses varies markedly.\n\nTCC polled wealth managers on the evidence they hold: 38% said they have all the evidence needed to identify which clients received their review, 58% said they have only some of that evidence, and 4% said they have none at all.\n\nThe FCA has indicated it will revisit this topic later in the year, expecting firms to have evidence on file to substantiate the thoroughness of their suitability reviews. TCC's poll also found that 62% of wealth managers had the relevant fact-find and evidential report saved in their practice management system, 23% had only a checkmark to indicate a review was received, and 15% held evidence in a different format.\n\nThe FCA's review categorises ongoing advice clients into three groups: those who received their review as anticipated, those who did not engage, and those who were not contacted at all, the last of whom are due redress.\n\nWealth management firms providing ongoing advice services, and the compliance, risk and advice functions responsible for maintaining evidence of client reviews dating back to 2018.\n\n\u2022 Relying on adviser attestation without independently verifying the quality and consistency of reviews.\n\u2022 Holding evidence in inconsistent formats, such as a checkmark rather than a full fact-find or report.\n\u2022 Being unable to categorise clients correctly into the FCA's three review outcome groups.\n\u2022 Weak management information that does not allow senior managers to evidence oversight under SM&CR.\n\n1. For clients who received their review, keep up-to-date know-your-customer information and a report letter confirming ongoing suitability.\n2. For clients who did not engage, keep documented evidence, such as an invitation email, that they were given the opportunity to take part.\n3. Categorise client interactions dating back to 2018 into the three review outcome groups annually, and use this analysis to determine the right action for each client.\n4. Review management information regularly, examine root causes of unusually favourable outcomes, and take action based on findings across advisers, branches and supervisors.\n\nSenior managers are expected to demonstrate their compliance with the Senior Managers and Certification Regime alongside their board duties, providing sufficient evidence that these matters have been thoroughly considered. Firms will also need to closely examine fair value assessments and implement a thorough disengagement strategy for clients who meet the relevant criteria.\n\nTCC recommends a twofold approach: a backwards-looking piece of work to establish the evidence firms already hold, and a forward-looking plan to ensure reviews are documented consistently going forward. Independent expertise can help firms demonstrate their commitment to conducting annual client reviews backed by thorough documentation.", "wordCount": 520, "keywords": [ "Consumer Duty", "Suitability, Advice Quality & File Reviews", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Consumer Duty", "url": "https://tcc.group/blog/solution/consumer-duty/" }, { "@type": "Thing", "name": "Suitability, Advice Quality & File Reviews", "url": "https://tcc.group/blog/solution/outsourced-suitability-reviews/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Ongoing Advice Evidence Poll" } ], "articleSection": [ "Consumer Duty", "Suitability, Advice Quality & File Reviews" ], "audience": [ { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Wealth management firms responsible for evidencing ongoing advice suitability reviews." } ], "citation": [ { "@type": "CreativeWork", "name": "Wealth managers signal the FCA\u2019s ongoing advice review presented better findings than they expected", "url": "https://tcc.group/blog/2025/03/27/ongoing-advice-poll/", "datePublished": "2025-03-27" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/regulatory-horizon/ongoing-advice-poll/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/ongoing-advice-poll/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What did TCC's poll find about ongoing advice evidence?", "acceptedAnswer": { "@type": "Answer", "text": "38% of wealth managers said they had all the evidence needed to identify which clients received their review, 58% said they had only some evidence, and 4% said they had none." } }, { "@type": "Question", "name": "Why should the FCA's positive findings be treated with caution?", "acceptedAnswer": { "@type": "Answer", "text": "The findings are based on self-reported information rather than an independent qualitative review of individual client files, so quality and consistency may vary between firms." } }, { "@type": "Question", "name": "How does the FCA categorise ongoing advice clients?", "acceptedAnswer": { "@type": "Answer", "text": "The FCA groups clients into those who received their review as anticipated, those who did not engage, and those who were not contacted at all and are due redress." } }, { "@type": "Question", "name": "How far back should firms review client interactions?", "acceptedAnswer": { "@type": "Answer", "text": "Firms should categorise client interactions dating back to 2018 into the three review outcome groups, and repeat this process annually." } } ] } ] } ``` ### What risks remain for firms following the FCA’s ongoing advice review findings? - URL: https://tcc.group/insights/analysis-perspectives/risks-remaining-following-fca-advice/ - Published: 2025-03-24 - Modified: 2026-09-02 **Topic:** Ongoing Advice Reviews TCC hosted a webinar in March 2025 in which regulatory experts examined the FCA's findings on ongoing advice reviews and the practical risks firms still need to manage. #### What happened? On 19 March 2025, TCC's Chief Commercial Officer and Chief Product Officer, Garry Evans, was joined by regulatory experts Gary Maude and David Boyhan for a webinar on the Financial Conduct Authority's ongoing advice review findings. The session covered how firms can deliver ongoing advice services with the appropriate evidence, the quality of ongoing advice reviews, the clarity of client chronology, and the importance of a backward-looking review alongside preparation for the future. Disengagement strategies and the wider ripple effect of poor ongoing servicing were also discussed. The webinar was split into three parts covering the scope of the FCA's review, next steps for wealth managers, and the long-term compliance implications for the sector. #### Why does it matter? Firms that cannot evidence the ongoing advice service a client has actually received are exposed when the FCA asks for proof, not assurance. The topics raised in the webinar point to specific gaps regulators are likely to probe, from unclear client chronology to weak disengagement processes. A poorly evidenced ongoing advice proposition can affect more than one client file: issues identified in a backward-looking review often point to systemic weaknesses with a wider ripple effect across a firm's client bank. #### Who is affected? Wealth managers and financial advice firms that charge for ongoing advice services, along with the compliance and advice quality teams responsible for reviewing and evidencing that service. #### Key risks - Ongoing advice reviews that lack clear, contemporaneous evidence of the service delivered. - An unclear chronology of client contact and reviews over time. - Disengagement processes that are not documented or consistently applied. #### Actions to take 1. Review how ongoing advice service delivery is currently evidenced against FCA expectations. 2. Check that client chronology and review history are clear and complete. 3. Confirm that disengagement processes are documented and applied consistently. #### Recommendations Firms unsure whether their ongoing advice evidencing would satisfy FCA scrutiny should treat this as a priority review area, drawing on independent regulatory expertise where in-house resource or experience is limited. #### Supporting sources - [What risks remain for firms following the FCA’s ongoing advice review findings?](https://tcc.group/blog/2025/03/25/risks-remaining-following-fca-advice/) (2025-03-25) #### Need help evidencing your ongoing advice service? Talk to TCC about strengthening how your firm evidences and delivers compliant ongoing advice reviews. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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"https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/insights/analysis-perspectives/risks-remaining-following-fca-advice/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Insights", "item": "https://tcc.group/insights/" }, { "@type": "ListItem", "position": 3, "name": "What risks remain for firms following the FCA\u2019s ongoing advice review findings?", "item": "https://tcc.group/insights/analysis-perspectives/risks-remaining-following-fca-advice/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/analysis-perspectives/risks-remaining-following-fca-advice/#webpage", "url": "https://tcc.group/insights/analysis-perspectives/risks-remaining-following-fca-advice/", "name": "What risks remain for firms following the FCA\u2019s ongoing advice review findings?", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2025-03-25T00:00:00+01:00", "dateModified": "2026-09-02T03:48:02+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/analysis-perspectives/risks-remaining-following-fca-advice/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "AnalysisNewsArticle", "@id": "https://tcc.group/insights/analysis-perspectives/risks-remaining-following-fca-advice/#article", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/risks-remaining-following-fca-advice/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "What risks remain for firms following the FCA\u2019s ongoing advice review findings?", "datePublished": "2025-03-25T00:00:00+01:00", "dateModified": "2026-09-02T03:48:02+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/analysis-perspectives/risks-remaining-following-fca-advice/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/ddf38609a94d44adbff4c3bb304043de/thumbnail-1024-576630feb999c24fdbdfb58b6197ba0e5d3a90ee537e9ecb0bf0954606484c6d.jpg", "description": "TCC's regulatory experts discussed the FCA's ongoing advice review findings in a dedicated webinar, covering evidencing standards, review quality, chronology and disengagement strategies that wealth management firms should address without delay.", "inLanguage": "en-GB", "articleBody": "TCC hosted a webinar in March 2025 in which regulatory experts examined the FCA's findings on ongoing advice reviews and the practical risks firms still need to manage.\n\nOn 19 March 2025, TCC's Chief Commercial Officer and Chief Product Officer, Garry Evans, was joined by regulatory experts Gary Maude and David Boyhan for a webinar on the Financial Conduct Authority's ongoing advice review findings.\n\nThe session covered how firms can deliver ongoing advice services with the appropriate evidence, the quality of ongoing advice reviews, the clarity of client chronology, and the importance of a backward-looking review alongside preparation for the future. Disengagement strategies and the wider ripple effect of poor ongoing servicing were also discussed.\n\nThe webinar was split into three parts covering the scope of the FCA's review, next steps for wealth managers, and the long-term compliance implications for the sector.\n\nFirms that cannot evidence the ongoing advice service a client has actually received are exposed when the FCA asks for proof, not assurance. The topics raised in the webinar point to specific gaps regulators are likely to probe, from unclear client chronology to weak disengagement processes.\n\nA poorly evidenced ongoing advice proposition can affect more than one client file: issues identified in a backward-looking review often point to systemic weaknesses with a wider ripple effect across a firm's client bank.\n\nWealth managers and financial advice firms that charge for ongoing advice services, along with the compliance and advice quality teams responsible for reviewing and evidencing that service.\n\n\u2022 Ongoing advice reviews that lack clear, contemporaneous evidence of the service delivered.\n\u2022 An unclear chronology of client contact and reviews over time.\n\u2022 Disengagement processes that are not documented or consistently applied.\n\n1. Review how ongoing advice service delivery is currently evidenced against FCA expectations.\n2. Check that client chronology and review history are clear and complete.\n3. Confirm that disengagement processes are documented and applied consistently.\n\nFirms unsure whether their ongoing advice evidencing would satisfy FCA scrutiny should treat this as a priority review area, drawing on independent regulatory expertise where in-house resource or experience is limited.", "wordCount": 349, "keywords": [ "Consumer Duty", "Suitability, Advice Quality & File Reviews", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Consumer Duty", "url": "https://tcc.group/blog/solution/consumer-duty/" }, { "@type": "Thing", "name": "Suitability, Advice Quality & File Reviews", "url": "https://tcc.group/blog/solution/outsourced-suitability-reviews/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Ongoing Advice Reviews" } ], "articleSection": [ "Consumer Duty", "Suitability, Advice Quality & File Reviews" ], "audience": [ { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Compliance and advice quality leaders in wealth management firms delivering ongoing advice services." } ], "citation": [ { "@type": "CreativeWork", "name": "What risks remain for firms following the FCA\u2019s ongoing advice review findings?", "url": "https://tcc.group/blog/2025/03/25/risks-remaining-following-fca-advice/", "datePublished": "2025-03-25" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/analysis-perspectives/risks-remaining-following-fca-advice/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/risks-remaining-following-fca-advice/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What did the TCC webinar on ongoing advice reviews cover?", "acceptedAnswer": { "@type": "Answer", "text": "It covered the FCA's ongoing advice review findings, including evidencing standards, review quality, client chronology, disengagement strategies and preparing for the future." } }, { "@type": "Question", "name": "Who hosted the webinar?", "acceptedAnswer": { "@type": "Answer", "text": "TCC's Garry Evans hosted the session with regulatory experts Gary Maude and David Boyhan." } }, { "@type": "Question", "name": "Which firms should pay attention to these findings?", "acceptedAnswer": { "@type": "Answer", "text": "Wealth management and financial advice firms that provide ongoing advice services, and their compliance teams." } } ] } ] } ``` ### How do the ongoing advice review findings relate to the Consumer Duty? - URL: https://tcc.group/insights/analysis-perspectives/how-do-fca-ongoing-advice-review-findings-relate-to-consumer-duty/ - Published: 2025-03-12 - Modified: 2026-09-02 **Topic:** Ongoing Advice Review TCC experts David and Garry discuss how the FCA's ongoing advice review findings integrate with Consumer Duty board reporting and data-led regulatory expectations. #### What happened? In this fourth Q&A instalment, Garry asks David how the Financial Conduct Authority (FCA) ongoing advice review findings relate to the broader framework of the Consumer Duty. David notes that ongoing advice services represent a high-priority area that directly feeds into a firm's annual Consumer Duty board report. The regulator plans to actively contact firms to inspect progress on ongoing advice services. Advice businesses must be prepared to supply detailed historical management information (MI) dating back to 2018, including evidence of redress and client outcomes. #### Why does it matter? The FCA is a data-led regulator. This means compliance cannot simply be declared; it must be backed by rigorous, auditable evidence. Ongoing advice records form a critical part of the MI needed to prove that clients receive fair value and that the services paid for are actually delivered. If the FCA reviews a firm, the firm must show robust processes for analyzing their ongoing advice back-book, identifying gaps, and managing client redress fairly where service delivery has fallen short. #### Who is affected? This regulatory focus affects all financial advice and wealth management firms, pension advisers, and compliance teams responsible for oversight of ongoing fee-based service agreements. #### Key risks - **Lack of Auditable Data:** Failing to maintain detailed and structured MI dating back to 2018 regarding ongoing service delivery and client outcomes. - **Deficient Board Reporting:** Missing critical ongoing advice metrics in the annual Consumer Duty board report. - **Unresolved Legacy Issues:** Failing to address or justify unpaid client redress for past service failures before regulatory contact. #### Actions to take 1. **Assemble Historical MI:** Gather and audit ongoing service delivery records dating back to 2018 to establish a robust data baseline. 2. **Review Redress Processes:** Assess and document any outstanding client redress actions with clear justifications. 3. **Update Board Reports:** Ensure the annual Consumer Duty board report explicitly addresses ongoing advice quality and value. #### Wider implications The FCA's focus on ongoing advice indicates a wider shift where regulators use data-led methods to spot industry-wide value discrepancies. Advice firms must transition from passive compliance to active, evidenced monitoring. #### Recommendations Firms should implement automated compliance tools to monitor ongoing advice delivery systematically, ensuring every client paying an ongoing fee receives their scheduled reviews. #### Supporting sources - [How do the review findings relate to the Consumer Duty?](https://tcc.group/blog/2025/03/13/how-do-fca-ongoing-advice-review-findings-relate-to-consumer-duty/) (2025-03-13) #### Are you prepared for an FCA ongoing advice audit? Talk to our wealth management experts today to help you structure your historical MI and strengthen your Consumer Duty evidence trail. [Contact our team](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory 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the Consumer Duty, and understand the critical management information required to evidence compliance in your annual board report.", "inLanguage": "en-GB", "articleBody": "TCC experts David and Garry discuss how the FCA's ongoing advice review findings integrate with Consumer Duty board reporting and data-led regulatory expectations.\n\nIn this fourth Q&A instalment, Garry asks David how the Financial Conduct Authority (FCA) ongoing advice review findings relate to the broader framework of the Consumer Duty. David notes that ongoing advice services represent a high-priority area that directly feeds into a firm's annual Consumer Duty board report.\n\nThe regulator plans to actively contact firms to inspect progress on ongoing advice services. Advice businesses must be prepared to supply detailed historical management information (MI) dating back to 2018, including evidence of redress and client outcomes.\n\nThe FCA is a data-led regulator. This means compliance cannot simply be declared; it must be backed by rigorous, auditable evidence. Ongoing advice records form a critical part of the MI needed to prove that clients receive fair value and that the services paid for are actually delivered.\n\nIf the FCA reviews a firm, the firm must show robust processes for analyzing their ongoing advice back-book, identifying gaps, and managing client redress fairly where service delivery has fallen short.\n\nThis regulatory focus affects all financial advice and wealth management firms, pension advisers, and compliance teams responsible for oversight of ongoing fee-based service agreements.\n\n\u2022 Lack of Auditable Data: Failing to maintain detailed and structured MI dating back to 2018 regarding ongoing service delivery and client outcomes.\n\u2022 Deficient Board Reporting: Missing critical ongoing advice metrics in the annual Consumer Duty board report.\n\u2022 Unresolved Legacy Issues: Failing to address or justify unpaid client redress for past service failures before regulatory contact.\n\n1. 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In the final part of this compliance Q&A, Garry and David address the actions financial advice firms must take following the FCA's thematic review of ongoing advice services. David highlights that with the regulator's findings now published, there are no excuses for non-compliance going forward. David outlines a dual approach: a forward-looking review of current policies and a backward-looking audit of historical service delivery dating back to 2018. #### Why does it matter? With approximately 90% of advice clients on ongoing service agreements, ensuring and demonstrating good customer outcomes is a regulatory necessity under Consumer Duty. Reviewing client agreements to match promised services against actual delivery is essential to pass fair value assessments. Equally critical is the backward-looking piece. Firms must identify clients who have paid fees but were not invited to reviews or chose not to engage, and take corrective action including potential fee redress and disengagement. #### Who is affected? This affects financial advisers, wealth management firms, and compliance teams managing ongoing advisory contracts and recurring fee structures. #### Key risks - **Service Delivery Gap:** Charging ongoing fees without delivering the promised annual reviews, violating Consumer Duty fair value rules. - **Unmanaged Disengaged Clients:** Allowing clients who do not engage to continue paying for ongoing services without formal disengagement. - **Historical Exposure:** Unaddressed legacy issues since 2018 where client service was not delivered, risking severe FCA enforcement. #### Actions to take 1. **Review Current Agreements:** Verify that forward-looking customer agreements, fair value assessments, and disengagement policies are fully compliant. 2. **Audit Historical Files:** Review client files back to 2018 to identify where promised reviews did not occur. 3. **Implement Redress or Disengagement:** Provide fee redress where services were not delivered, and formally disengage chronically unresponsive clients. #### Wider implications The thematic review indicates that the FCA expects advice firms to have high operational standards. Passive collection of ongoing fees without active verification of service delivery will be met with swift regulatory action. #### Recommendations Firms should integrate robust audit tools and client tracking systems to ensure no annual reviews are missed, and build automated disengagement triggers for uncooperative clients. #### Supporting sources - [How can firms keep their ongoing advice services compliant?](https://tcc.group/blog/2025/03/13/how-firms-can-keep-their-ongoing-advice-services-compliant/) (2025-03-13) #### Are your ongoing advice reviews fully compliant? Our experts deliver impartial compliance assessments, pragmatic outsourcing, and specialized file reviews to help you tackle ongoing advice hurdles. [Talk to our experts](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", 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advice services fully compliant under the FCA's latest thematic review standards.", "inLanguage": "en-GB", "articleBody": "TCC experts outline the forward-looking policy updates and historical data checks required to ensure wealth management firms remain compliant with FCA expectations.\n\nIn the final part of this compliance Q&A, Garry and David address the actions financial advice firms must take following the FCA's thematic review of ongoing advice services. David highlights that with the regulator's findings now published, there are no excuses for non-compliance going forward.\n\nDavid outlines a dual approach: a forward-looking review of current policies and a backward-looking audit of historical service delivery dating back to 2018.\n\nWith approximately 90% of advice clients on ongoing service agreements, ensuring and demonstrating good customer outcomes is a regulatory necessity under Consumer Duty. Reviewing client agreements to match promised services against actual delivery is essential to pass fair value assessments.\n\nEqually critical is the backward-looking piece. Firms must identify clients who have paid fees but were not invited to reviews or chose not to engage, and take corrective action including potential fee redress and disengagement.\n\nThis affects financial advisers, wealth management firms, and compliance teams managing ongoing advisory contracts and recurring fee structures.\n\n\u2022 Service Delivery Gap: Charging ongoing fees without delivering the promised annual reviews, violating Consumer Duty fair value rules.\n\u2022 Unmanaged Disengaged Clients: Allowing clients who do not engage to continue paying for ongoing services without formal disengagement.\n\u2022 Historical Exposure: Unaddressed legacy issues since 2018 where client service was not delivered, risking severe FCA enforcement.\n\n1. Review Current Agreements: Verify that forward-looking customer agreements, fair value assessments, and disengagement policies are fully compliant.\n2. Audit Historical Files: Review client files back to 2018 to identify where promised reviews did not occur.\n3. Implement Redress or Disengagement: Provide fee redress where services were not delivered, and formally disengage chronically unresponsive clients.\n\nThe thematic review indicates that the FCA expects advice firms to have high operational standards. Passive collection of ongoing fees without active verification of service delivery will be met with swift regulatory action.\n\nFirms should integrate robust audit tools and client tracking systems to ensure no annual reviews are missed, and build automated disengagement triggers for uncooperative clients.", "wordCount": 352, "keywords": [ "Compliance AI & RegTech", "Consumer Duty", "Suitability, Advice Quality & File Reviews", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Consumer Duty", "url": "https://tcc.group/blog/solution/consumer-duty/" }, { "@type": "Thing", "name": "Suitability, Advice Quality & File Reviews", "url": "https://tcc.group/blog/solution/outsourced-suitability-reviews/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Ongoing Advice Compliance" } ], "articleSection": [ "Compliance AI & RegTech", "Consumer Duty", "Suitability, Advice Quality & File Reviews" ], "audience": [ { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Wealth managers, financial planning firm directors, and compliance officers responsible for ongoing client review services." } ], "citation": [ { "@type": "CreativeWork", "name": "How can firms keep their ongoing advice services compliant?", "url": "https://tcc.group/blog/2025/03/13/how-firms-can-keep-their-ongoing-advice-services-compliant/", "datePublished": "2025-03-13" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/analysis-perspectives/how-firms-can-keep-their-ongoing-advice-services-compliant/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/how-firms-can-keep-their-ongoing-advice-services-compliant/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What is the go-forward compliance piece for ongoing advice?", "acceptedAnswer": { "@type": "Answer", "text": "Firms must review current client agreements, fair value assessments, and disengagement processes to ensure policies are geared towards delivering real, documented client outcomes." } }, { "@type": "Question", "name": "What must firms do regarding historical ongoing advice service failures?", "acceptedAnswer": { "@type": "Answer", "text": "Firms must audit files back to 2018, identify instances where reviews were missed or clients didn't engage, and provide appropriate redress or formally disengage those clients." } } ] } ] } ``` ### How should firms be considering quality and suitability of advice? - URL: https://tcc.group/insights/analysis-perspectives/how-to-consider-quality-and-suitability-of-advice/ - Published: 2025-03-11 - Modified: 2026-09-02 **Topic:** Advice Quality and Suitability TCC experts explore why advisory firms must assess the ongoing quality and suitability of advice, shifting from routine process checklists to risk-based outcomes. #### What happened? In the third part of this compliance series, Garry and David discuss how firms should evaluate the quality and suitability of their ongoing advice. Garry notes that the FCA's thematic review concentrated heavily on service delivery metrics (such as whether annual review meetings occurred), rather than the qualitative standard of the advice itself. David emphasizes that under the Consumer Duty, demonstrating the quality and suitability of ongoing advice remains a non-negotiable expectation for firms that have transitioned up to 90% of their client base into recurring fee structures. #### Why does it matter? The traditional compliance models historically prioritized suitability at the point of initial sale, but ongoing advice suitability is now equally vital. Firms must demonstrate that repeated annual reviews are delivering actual, documented benefits and remain suitable for each client's evolving circumstances. A critical area of risk is the 'no change' review, where everything is identical year-on-year. While superficially simple, these static reviews represent higher potential risk and require a robust, controlled oversight environment to justify ongoing fee collection. #### Who is affected? This regulatory focus affects financial planners, wealth management firms, and compliance leaders who oversee recurring service propositions and file review operations. #### Key risks - **Static Reviews:** Standardizing annual reviews with no portfolio or strategy changes, which represents higher suitability risk without rigorous justification. - **Checklist Complacency:** Focusing solely on process checklists (i.e. scheduling the meeting) while neglecting to monitor and evidence advice quality. - **Friction in Oversight:** Operating without a controlled environment to audit and monitor advice suitability at scale across different customer groups. #### Actions to take 1. **Adopt a Risk-Based Approach:** Implement deeper file reviews and audits for clients undergoing consecutive 'no change' annual reviews. 2. **Establish Quality Controls:** Build a controlled advice oversight framework that assesses the qualitative value of advice rather than just completion rates. 3. **Evidence Client Outcomes:** Document exactly why ongoing advisory strategies remain suitable for each client's specific circumstances. #### Wider implications The FCA's focus is evolving from basic operational tracking to checking the actual substance and value of ongoing advice. Advice firms must be prepared to defend the suitability of their recommendations during subsequent thematic probes. #### Recommendations Firms should employ external advice quality experts to conduct objective file reviews and build robust compliance monitoring frameworks that capture qualitative advice outcomes. #### Supporting sources - [How should firms be considering quality and suitability of advice?](https://tcc.group/blog/2025/03/13/how-to-consider-quality-and-suitability-of-advice/) (2025-03-12) #### Are you confident in your ongoing advice suitability? Speak to our file review and advisory specialists to establish a robust, risk-based advice quality framework that meets FCA expectations. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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evidencing the suitability and quality of ongoing advice under the Consumer Duty.", "inLanguage": "en-GB", "articleBody": "TCC experts explore why advisory firms must assess the ongoing quality and suitability of advice, shifting from routine process checklists to risk-based outcomes.\n\nIn the third part of this compliance series, Garry and David discuss how firms should evaluate the quality and suitability of their ongoing advice. Garry notes that the FCA's thematic review concentrated heavily on service delivery metrics (such as whether annual review meetings occurred), rather than the qualitative standard of the advice itself.\n\nDavid emphasizes that under the Consumer Duty, demonstrating the quality and suitability of ongoing advice remains a non-negotiable expectation for firms that have transitioned up to 90% of their client base into recurring fee structures.\n\nThe traditional compliance models historically prioritized suitability at the point of initial sale, but ongoing advice suitability is now equally vital. Firms must demonstrate that repeated annual reviews are delivering actual, documented benefits and remain suitable for each client's evolving circumstances.\n\nA critical area of risk is the 'no change' review, where everything is identical year-on-year. 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Establish Quality Controls: Build a controlled advice oversight framework that assesses the qualitative value of advice rather than just completion rates.\n3. Evidence Client Outcomes: Document exactly why ongoing advisory strategies remain suitable for each client's specific circumstances.\n\nThe FCA's focus is evolving from basic operational tracking to checking the actual substance and value of ongoing advice. 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In the second part of TCC's ongoing advice series, Garry and David discuss how firms should manage clients who do not engage with recurring review offers. David confirms that the FCA expects immediate, proactive redress for the 2% of clients who were never invited to annual reviews. For the roughly 15% of clients who did not respond or declined reviews, firms must conduct historical data audits going back to January 2018 to evaluate whether they paid for a service they did not receive. #### Why does it matter? Charging recurring fees to clients who are disengaged or uninvited violates Consumer Duty fair value rules. If reviews have been missed for multiple years, firms may need to initiate fee remediation or structured redress campaigns. Furthermore, setting up a compliant disengagement process is complex. Firms cannot simply cut off a client; they must consider client vulnerability and outline a documented chase sequence before terminating the advisory agreement. #### Who is affected? This regulatory focus affects financial advice networks, wealth managers, and operations directors handling client fee structures and annual review cycles. #### Key risks - **Unjustified Ongoing Fees:** Continuing to collect advisory fees from clients who have not engaged in reviews for several years without intervention. - **Unmanaged Redress Liabilities:** Failure to audit historical files back to 2018 and identify uninvited cohorts who are due fee refunds. - **Non-compliant Termination:** Disengaging unresponsive clients without appropriate safeguards for vulnerable consumers or documented chase attempts. #### Actions to take 1. **Audit Data Back to 2018:** Scan client files to identify individuals who paid for ongoing advice but did not receive a review. 2. **Draft a Disengagement Policy:** Create a structured policy outlining vulnerability assessments and a set number of client contact attempts before formal cutoff. 3. **Execute Fee Remediation:** Implement redress plans for uninvited client cohorts and chronic non-responders who received no value. #### Wider implications This highlights the FCA's strict 'no service, no fee' stance. Advice firms must establish robust tracking to demonstrate active client contact and ensure fee structures correspond to delivered value. #### Recommendations Firms should deploy compliant, automated tracking systems to record every client invitation, response, and disengagement step, protecting themselves from regulatory exposure. #### Supporting sources - [What should firms do about disengaged clients?](https://tcc.group/blog/2025/03/13/how-to-manage-disengaged-ongoing-advice-clients-q2/) (2025-03-11) #### Are your client disengagement processes compliant? Speak to our advisory team today to help you structure your historical file audits, disengagement policies, and vulnerable customer safeguards. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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policies, and redress steps required.", "inLanguage": "en-GB", "articleBody": "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.\n\nIn the second part of TCC's ongoing advice series, Garry and David discuss how firms should manage clients who do not engage with recurring review offers. 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This includes assessing client vulnerability, executing a documented chase sequence, and formally ending the contract if engagement is not achieved." } } ] } ] } ``` ### Key findings from FCA's ongoing advice review - URL: https://tcc.group/insights/analysis-perspectives/key-findings-ongoing-advice-q1/ - Published: 2025-03-09 - Modified: 2026-09-02 ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 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on the gaps for those who did not and be ready to evidence outcomes going forward. #### What happened? The Financial Conduct Authority (FCA) asked wealth management firms to provide data on how many clients were due an ongoing advice review, how many actually received one, and what happened when they did not. A year after collecting this information, the regulator has now published its findings. The findings show that the vast majority of clients received their review, but the FCA has identified remedial actions firms must take for clients who did not, along with a wider question about how firms should be liaising with clients who did not respond or declined a review. #### Why does it matter? The findings matter because they signal the FCA's continuing attention on ongoing advice servicing, an area already under scrutiny following the thematic review that first raised concerns about a wider remediation cycle across the wealth management sector. Firms that cannot evidence when reviews took place, or explain why some clients did not receive one, are exposed to the same regulatory attention that produced this review in the first place. #### Who is affected? Any firm providing an ongoing advice service is affected, particularly those with clients dating back to 2018 or earlier, as this is the period the FCA's communication points firms towards when checking their records. #### Key risks - Insufficient evidence on file to demonstrate that reviews took place, or that fair value assessments were properly carried out. - Client agreements that do not reflect what is actually delivered under the ongoing advice service. - No clear process for identifying disengaged clients, or for re-engaging those who declined a review. #### Actions to take 1. Review the back book of ongoing advice clients, focusing on records from 2018 onwards. 2. Check client agreements against what has actually been delivered, and revisit fair value assessments for the ongoing advice service. 3. Put in place a process to identify when a review is due, ensure it takes place, and record the outcome. 4. Develop a consistent approach for contacting clients who have not responded to, or have declined, a review invitation. #### Wider implications The review raises a broader question about disengaged clients: firms cannot simply record that a client did not respond and move on. The findings point towards an expectation that firms actively manage this population and can show what steps were taken. This sits alongside the Consumer Duty, which similarly expects firms to evidence that clients are receiving fair value and good outcomes from an ongoing service, not just that a service exists on paper. #### Recommendations Firms should treat this as an opportunity to review historic evidence before it is requested by the regulator, rather than waiting for a formal information request. Where gaps are identified, a clear remediation plan should be put in place and recorded. Going forward, the process for tracking review due dates and outcomes should not rely solely on manual checks. #### Supporting sources - [Q&A: The important insights from the FCA’s ongoing advice review findings](https://tcc.group/blog/2025/03/06/qa-ongoing-advice-findings/) (2025-03-06) #### Need help evidencing your ongoing advice reviews? Contact us to discuss how we can help you review your back book and put in place a compliant, evidenced approach to ongoing advice reviews. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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received their ongoing advice review, but firms must act on the gaps for those who did not and be ready to evidence outcomes going forward.\n\nThe Financial Conduct Authority (FCA) asked wealth management firms to provide data on how many clients were due an ongoing advice review, how many actually received one, and what happened when they did not. A year after collecting this information, the regulator has now published its findings.\n\nThe findings show that the vast majority of clients received their review, but the FCA has identified remedial actions firms must take for clients who did not, along with a wider question about how firms should be liaising with clients who did not respond or declined a review.\n\nThe findings matter because they signal the FCA's continuing attention on ongoing advice servicing, an area already under scrutiny following the thematic review that first raised concerns about a wider remediation cycle across the wealth management sector.\n\nFirms that cannot evidence when reviews took place, or explain why some clients did not receive one, are exposed to the same regulatory attention that produced this review in the first place.\n\nAny firm providing an ongoing advice service is affected, particularly those with clients dating back to 2018 or earlier, as this is the period the FCA's communication points firms towards when checking their records.\n\n\u2022 Insufficient evidence on file to demonstrate that reviews took place, or that fair value assessments were properly carried out.\n\u2022 Client agreements that do not reflect what is actually delivered under the ongoing advice service.\n\u2022 No clear process for identifying disengaged clients, or for re-engaging those who declined a review.\n\n1. Review the back book of ongoing advice clients, focusing on records from 2018 onwards.\n2. Check client agreements against what has actually been delivered, and revisit fair value assessments for the ongoing advice service.\n3. Put in place a process to identify when a review is due, ensure it takes place, and record the outcome.\n4. Develop a consistent approach for contacting clients who have not responded to, or have declined, a review invitation.\n\nThe review raises a broader question about disengaged clients: firms cannot simply record that a client did not respond and move on. The findings point towards an expectation that firms actively manage this population and can show what steps were taken.\n\nThis sits alongside the Consumer Duty, which similarly expects firms to evidence that clients are receiving fair value and good outcomes from an ongoing service, not just that a service exists on paper.\n\nFirms should treat this as an opportunity to review historic evidence before it is requested by the regulator, rather than waiting for a formal information request. Where gaps are identified, a clear remediation plan should be put in place and recorded.\n\nGoing forward, the process for tracking review due dates and outcomes should not rely solely on manual checks.", "wordCount": 491, "keywords": [ "Compliance AI & RegTech", "Consumer Duty", "Suitability, Advice Quality & File Reviews", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Consumer Duty", "url": "https://tcc.group/blog/solution/consumer-duty/" }, { "@type": "Thing", "name": "Suitability, Advice Quality & File Reviews", "url": "https://tcc.group/blog/solution/outsourced-suitability-reviews/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Ongoing Advice Review Findings" } ], "articleSection": [ "Compliance AI & RegTech", "Consumer Duty", "Suitability, Advice Quality & File Reviews" ], "audience": [ { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Wealth management and financial advice firms delivering an ongoing advice service, particularly those with long-standing back-book clients." } ], "citation": [ { "@type": "CreativeWork", "name": "Q&A: The important insights from the FCA\u2019s ongoing advice review findings", "url": "https://tcc.group/blog/2025/03/06/qa-ongoing-advice-findings/", "datePublished": "2025-03-06" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/analysis-perspectives/qa-ongoing-advice-findings/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/qa-ongoing-advice-findings/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What did the FCA's ongoing advice review find?", "acceptedAnswer": { "@type": "Answer", "text": "It found that the vast majority of clients due a review received one, but identified remedial actions firms must take for the clients who did not." } }, { "@type": "Question", "name": "How far back should firms check their records?", "acceptedAnswer": { "@type": "Answer", "text": "Based on the FCA's communication, firms are advised to review records back to 2018." } }, { "@type": "Question", "name": "What should firms do about disengaged clients?", "acceptedAnswer": { "@type": "Answer", "text": "Firms need a clear approach for contacting and re-engaging clients who did not respond to, or declined, an ongoing advice review." } } ] } ] } ``` ### Understanding & implementing the FCA's ongoing advice findings - URL: https://tcc.group/insights/regulatory-horizon/ongoing-review-findings/ - Published: 2025-02-24 - Modified: 2026-09-02 **Topic:** Ongoing Advice Service Reviews The FCA has published findings from its review of ongoing advice services, confirming that around 2% of clients paying for a review did not receive one. Firms are expected to assess their own records against these findings and consider redress where appropriate. #### What happened? The FCA has published the results of its review into ongoing advice services, several months after the work concluded. Simon Walls, interim Executive Director at the FCA, described ongoing advice and support as valuable to consumers, but the regulator also identified specific shortcomings that firms need to address. Around 2% of clients who were paying for a review service did not receive one. The FCA has indicated that redress is likely to be appropriate for these clients, and firms are expected to identify who they are and determine a suitable level of redress. The regulator has also said it will return to this area later in the year to assess how firms have responded, and will expect firms to produce management information covering clients who have not been offered a paid-for service and clients who are not engaging with it. #### Why does it matter? The delay between the FCA completing its work and publishing the findings suggests the regulator was not entirely satisfied with what it found. That, combined with the planned follow-up work, means this is not a subject firms can treat as closed. Firms need to be able to evidence, not simply assert, that ongoing advice services have been delivered as set out in client agreements. The FCA has also indicated that fair value assessments for ongoing advice should be revisited to confirm they still hold up. #### Who is affected? The findings apply to wealth management and financial advice firms that operate a paid-for ongoing advice or review service, and to the advisers and support staff responsible for delivering and recording those reviews. Clients who have been paying for a review service but have not received one, and clients who have stopped engaging with the service, are the two groups the FCA has specifically highlighted. #### Key risks - Clients being charged for a review service that was not delivered, creating a redress liability. - Management information that records a review as complete when the underlying contact would not meet the criteria for one. - No clear or consistently applied policy for disengaging clients who repeatedly decline reviews. - Fair value assessments for ongoing advice that have not been revisited since the Consumer Duty came into force. #### Actions to take 1. Identify clients, back to January 2018, who were paying for a review service but did not receive one, and assess the redress due. 2. Review management information to confirm it accurately reflects whether a review has taken place and meets a reasonable standard of client contact. 3. Set out, and apply consistently, a policy for disengaging clients who are not engaging with the ongoing service, including any charge refunds. 4. Revisit the fair value assessment for the ongoing advice service in light of the findings. 5. Prepare evidence of consistent annual client reviews since 2018, ready to share with the FCA if requested. #### Wider implications The FCA has said this review activity will feed into future work assessing how firms have responded, so the findings should be treated as a starting point rather than a one-off exercise. Firms should expect scrutiny of their response to continue through the year. The regulator has also confirmed that this analysis should be reflected in the firm's Consumer Duty board report, linking ongoing advice directly to the wider Consumer Duty governance firms already have in place. #### Recommendations Firms should treat the findings as a call to action rather than a closed matter. That means checking client agreements against what has actually been delivered, correcting management information practices, and being ready to demonstrate compliance with clear evidence. Given the scope of the analysis required, and the sensitivity of any redress decisions, independent input can help firms test their approach before the FCA returns to this area later in the year. #### Supporting sources - [Understanding & implementing the FCA's ongoing advice findings](https://tcc.group/blog/2025/02/25/ongoing-review-findings/) (2025-02-25) #### Need help reviewing your ongoing advice service? Our advisory and managed services teams can help you assess your ongoing advice reviews, management information and redress approach against the FCA's findings. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/insights/regulatory-horizon/ongoing-review-findings/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Insights", "item": "https://tcc.group/insights/" }, { "@type": "ListItem", "position": 3, "name": "Understanding & implementing the FCA’s ongoing advice findings", "item": "https://tcc.group/insights/regulatory-horizon/ongoing-review-findings/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/regulatory-horizon/ongoing-review-findings/#webpage", "url": "https://tcc.group/insights/regulatory-horizon/ongoing-review-findings/", "name": "Understanding & implementing the FCA’s ongoing advice findings", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2025-02-25T00:00:00+01:00", "dateModified": "2026-09-02T03:47:59+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/regulatory-horizon/ongoing-review-findings/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "NewsArticle", "@id": "https://tcc.group/insights/regulatory-horizon/ongoing-review-findings/#article", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/ongoing-review-findings/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "Understanding & implementing the FCA’s ongoing advice findings", "datePublished": "2025-02-25T00:00:00+01:00", "dateModified": "2026-09-02T03:47:59+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/regulatory-horizon/ongoing-review-findings/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/586f377c21ae442da5521102d0e6e785/thumbnail-1024-cd18cc649e57b669adc4e8e38e60e8a5ee7136765706b9152355706c14da0fcb.png", "description": "The FCA has published findings on ongoing advice services, identifying clients who did not receive paid-for reviews. This article sets out the practical steps wealth management firms should take now, from management information checks to redress decisions.", "inLanguage": "en-GB", "articleBody": "The FCA has published findings from its review of ongoing advice services, confirming that around 2% of clients paying for a review did not receive one. Firms are expected to assess their own records against these findings and consider redress where appropriate.\n\nThe FCA has published the results of its review into ongoing advice services, several months after the work concluded. Simon Walls, interim Executive Director at the FCA, described ongoing advice and support as valuable to consumers, but the regulator also identified specific shortcomings that firms need to address.\n\nAround 2% of clients who were paying for a review service did not receive one. The FCA has indicated that redress is likely to be appropriate for these clients, and firms are expected to identify who they are and determine a suitable level of redress.\n\nThe regulator has also said it will return to this area later in the year to assess how firms have responded, and will expect firms to produce management information covering clients who have not been offered a paid-for service and clients who are not engaging with it.\n\nThe delay between the FCA completing its work and publishing the findings suggests the regulator was not entirely satisfied with what it found. That, combined with the planned follow-up work, means this is not a subject firms can treat as closed.\n\nFirms need to be able to evidence, not simply assert, that ongoing advice services have been delivered as set out in client agreements. The FCA has also indicated that fair value assessments for ongoing advice should be revisited to confirm they still hold up.\n\nThe findings apply to wealth management and financial advice firms that operate a paid-for ongoing advice or review service, and to the advisers and support staff responsible for delivering and recording those reviews.\n\nClients who have been paying for a review service but have not received one, and clients who have stopped engaging with the service, are the two groups the FCA has specifically highlighted.\n\n\u2022 Clients being charged for a review service that was not delivered, creating a redress liability.\n\u2022 Management information that records a review as complete when the underlying contact would not meet the criteria for one.\n\u2022 No clear or consistently applied policy for disengaging clients who repeatedly decline reviews.\n\u2022 Fair value assessments for ongoing advice that have not been revisited since the Consumer Duty came into force.\n\n1. Identify clients, back to January 2018, who were paying for a review service but did not receive one, and assess the redress due.\n2. Review management information to confirm it accurately reflects whether a review has taken place and meets a reasonable standard of client contact.\n3. Set out, and apply consistently, a policy for disengaging clients who are not engaging with the ongoing service, including any charge refunds.\n4. Revisit the fair value assessment for the ongoing advice service in light of the findings.\n5. Prepare evidence of consistent annual client reviews since 2018, ready to share with the FCA if requested.\n\nThe FCA has said this review activity will feed into future work assessing how firms have responded, so the findings should be treated as a starting point rather than a one-off exercise. Firms should expect scrutiny of their response to continue through the year.\n\nThe regulator has also confirmed that this analysis should be reflected in the firm's Consumer Duty board report, linking ongoing advice directly to the wider Consumer Duty governance firms already have in place.\n\nFirms should treat the findings as a call to action rather than a closed matter. That means checking client agreements against what has actually been delivered, correcting management information practices, and being ready to demonstrate compliance with clear evidence.\n\nGiven the scope of the analysis required, and the sensitivity of any redress decisions, independent input can help firms test their approach before the FCA returns to this area later in the year.", "wordCount": 654, "keywords": [ "Compliance AI & RegTech", "Suitability, Advice Quality & File Reviews", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Suitability, Advice Quality & File Reviews", "url": "https://tcc.group/blog/solution/outsourced-suitability-reviews/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Ongoing Advice Service Reviews" } ], "articleSection": [ "Compliance AI & RegTech", "Suitability, Advice Quality & File Reviews" ], "audience": [ { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Compliance, advice and suitability teams at wealth management and financial advice firms that provide ongoing advice services." } ], "citation": [ { "@type": "CreativeWork", "name": "Understanding & implementing the FCA's ongoing advice findings", "url": "https://tcc.group/blog/2025/02/25/ongoing-review-findings/", "datePublished": "2025-02-25" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/regulatory-horizon/ongoing-review-findings/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/ongoing-review-findings/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What did the FCA find in its review of ongoing advice services?", "acceptedAnswer": { "@type": "Answer", "text": "The FCA found that around 2% of clients paying for a review service did not receive one, and it has indicated that redress is likely to be appropriate for those clients." } }, { "@type": "Question", "name": "How far back should firms look when assessing this issue?", "acceptedAnswer": { "@type": "Answer", "text": "TCC recommends that firms review their records back to January 2018 when identifying clients who may not have received a paid-for review." } }, { "@type": "Question", "name": "Does a client declining a review remove the need for redress?", "acceptedAnswer": { "@type": "Answer", "text": "The FCA has said redress is less likely where a client has consciously and repeatedly declined a review, but firms still need a clear disengagement policy for these clients." } }, { "@type": "Question", "name": "Will the FCA look at this area again?", "acceptedAnswer": { "@type": "Answer", "text": "Yes, the FCA has said it will carry out further work later in the year to assess how firms have responded to its findings." } } ] } ] } ``` ### Benefit your business by enhancing customer data - URL: https://tcc.group/insights/regulatory-horizon/customer-data-benefits/ - Published: 2025-02-17 - Modified: 2026-09-02 **Topic:** Enhancing customer data Better customer data can help firms meet FCA information requests more easily while also supporting deeper client insight, particularly around ongoing advice reviews and retirement income advice. #### 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 1. Review your business register or client management system against the FCA's ongoing advice review reporting requirements. 2. Capture review subscription status, meeting frequency, scheduled dates, actual dates and follow-up review dates for every client. 3. Record attitude to risk, capacity for loss and total assets, including primary residence, for retirement income clients. 4. Use the data gathered to prioritise client engagement ahead of the IHT changes taking effect in 2027. 5. 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 - [Benefit your business by enhancing customer data](https://tcc.group/blog/2025/02/18/customer-data-benefits/) (2025-02-18) #### Want to strengthen your client data? TCC's regulatory experts can help you review and enhance your business register to meet FCA expectations and support better client outcomes. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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"https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/insights/regulatory-horizon/customer-data-benefits/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Insights", "item": "https://tcc.group/insights/" }, { "@type": "ListItem", "position": 3, "name": "Benefit your business by enhancing customer data", "item": "https://tcc.group/insights/regulatory-horizon/customer-data-benefits/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/regulatory-horizon/customer-data-benefits/#webpage", "url": "https://tcc.group/insights/regulatory-horizon/customer-data-benefits/", "name": "Benefit your business by enhancing customer data", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2025-02-18T00:00:00+01:00", "dateModified": "2026-09-02T03:47:38+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/regulatory-horizon/customer-data-benefits/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "NewsArticle", "@id": "https://tcc.group/insights/regulatory-horizon/customer-data-benefits/#article", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/customer-data-benefits/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "Benefit your business by enhancing customer data", "datePublished": "2025-02-18T00:00:00+01:00", "dateModified": "2026-09-02T03:47:38+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/regulatory-horizon/customer-data-benefits/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/60228bbee05e442f92a5f777becbe0f1/thumbnail-1024-0e3d6a5c654815845c980501de8de2526b1fc4c65cf4508aeeec67b7d0e9f5bf.jpg", "description": "Practical steps for enhancing client data to meet FCA reporting requirements on ongoing advice reviews and retirement income, while identifying protection and inheritance tax opportunities within your existing client bank.", "inLanguage": "en-GB", "articleBody": "Better customer data can help firms meet FCA information requests more easily while also supporting deeper client insight, particularly around ongoing advice reviews and retirement income advice.\n\nThe 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.\n\nIn 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.\n\nFirms 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.\n\nFor 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.\n\nFinancial advice and wealth management firms managing ongoing advice services, and those advising clients on retirement income and decumulation, are most directly affected.\n\n\u2022 Inability to evidence the number of ongoing advice reviews conducted and missed when the FCA requests this information.\n\u2022 Client management systems that do not capture review frequency, scheduled dates, actual dates and follow-up reviews.\n\u2022 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.\n\n1. Review your business register or client management system against the FCA's ongoing advice review reporting requirements.\n2. Capture review subscription status, meeting frequency, scheduled dates, actual dates and follow-up review dates for every client.\n3. Record attitude to risk, capacity for loss and total assets, including primary residence, for retirement income clients.\n4. Use the data gathered to prioritise client engagement ahead of the IHT changes taking effect in 2027.\n5. 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TCC's regulatory experts have taken stock of the frequent questions and obstacles that firms face in meeting the Consumer Duty, working through each of the four outcomes: consumer understanding, consumer support, products and services, and price and value. On consumer understanding, common obstacles include customers relying on information or media rather than firm communications, documentation issued to protect the firm rather than the customer, and products recommended without customers being made aware of the risks involved. #### Why does it matter? Consumers can only be expected to take responsibility for their financial decisions when firms communicate effectively and ensure a clear understanding of products, including their features, risks and the consequences of decisions made. Where this does not happen, firms fall short of the Duty's requirements even if governance structures look complete on paper. On consumer support, recurring problems include vulnerability being identified but not reflected in client-facing documentation, reliance on customers to identify themselves as vulnerable, and barriers in the customer journey that prevent customers receiving the support they need. #### Who is affected? These obstacles are relevant across wealth management and financial advice, pensions and retirement income, payments and fintech, banking, consumer credit and lending, general insurance and protection, and motor finance. #### Key risks - Inadequate research into a product or service's target market - Fair value assessments completed with limited resulting changes to pricing, relying mainly on market benchmarking - Actual charges differing from those quoted in customer agreements - Charging for services the firm is not actually providing, such as ongoing advice - Difficulties for customers wanting to switch or exit a product or service #### Actions to take 1. Validate how you know customers understand your products, advice or service 2. Assess whether post-sale support is at least as effective as pre-sale support 3. Review how target markets are defined and documented for each product 4. Check whether your charging structure is regularly reviewed against the value delivered 5. Ensure board reports address ongoing work and necessary actions, not only positive outcomes #### Wider implications Firms should expect that the regulator can request the outcomes of monitoring activities and board reports at any time, and that this information will be used to assess compliance with the Duty and identify detrimental practices. Boards are expected to take necessary action, however uncomfortable, and to demonstrate this individually and collectively, including revisiting or questioning existing analysis where needed. Chairs are responsible for ensuring information is reviewed in a timely way with appropriate quorum and management information. #### Recommendations TCC's subject matter experts can assess a firm's Consumer Duty strategy, identifying compliance gaps and highlighting areas that require focus, whether additional expertise is needed to implement changes or independent assurance is sought that Consumer Duty integration is comprehensive. Technology can also support ongoing monitoring, review and documentation of outcomes. #### Supporting sources - [A Consumer Duty recap: frequent obstacles to achieving good customer outcomes](https://tcc.group/blog/2025/02/14/consumer-duty-recap/) (2025-02-14) #### Want an independent view of your Consumer Duty strategy? TCC's experts can assess your Consumer Duty arrangements and identify gaps that need attention. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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"https://tcc.group/insights/regulatory-horizon/consumer-duty-recap/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/regulatory-horizon/consumer-duty-recap/#webpage", "url": "https://tcc.group/insights/regulatory-horizon/consumer-duty-recap/", "name": "A Consumer Duty recap: frequent obstacles to achieving good customer outcomes", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2025-02-14T00:00:00+01:00", "dateModified": "2026-09-02T03:47:36+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/regulatory-horizon/consumer-duty-recap/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "NewsArticle", "@id": "https://tcc.group/insights/regulatory-horizon/consumer-duty-recap/#article", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/consumer-duty-recap/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "A Consumer Duty recap: frequent obstacles to achieving good customer outcomes", "datePublished": "2025-02-14T00:00:00+01:00", "dateModified": "2026-09-02T03:47:36+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/regulatory-horizon/consumer-duty-recap/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/046e5512e64e4da7a9770905dfc6aa40/thumbnail-1024-29113ee69ca3b64746ff5a0fb4c552154c8e47941600e3b56cbceac9a2d13e3b.jpg", "description": "A recap of the frequent obstacles firms face across the Consumer Duty's four outcomes, with the key questions boards should be asking to close gaps before the regulator asks them first.", "inLanguage": "en-GB", "articleBody": "TCC's regulatory experts take stock of the questions and obstacles firms commonly face across the Consumer Duty's four outcomes: consumer understanding, consumer support, products and services, and price and value.\n\nTCC's regulatory experts have taken stock of the frequent questions and obstacles that firms face in meeting the Consumer Duty, working through each of the four outcomes: consumer understanding, consumer support, products and services, and price and value.\n\nOn consumer understanding, common obstacles include customers relying on information or media rather than firm communications, documentation issued to protect the firm rather than the customer, and products recommended without customers being made aware of the risks involved.\n\nConsumers can only be expected to take responsibility for their financial decisions when firms communicate effectively and ensure a clear understanding of products, including their features, risks and the consequences of decisions made. Where this does not happen, firms fall short of the Duty's requirements even if governance structures look complete on paper.\n\nOn consumer support, recurring problems include vulnerability being identified but not reflected in client-facing documentation, reliance on customers to identify themselves as vulnerable, and barriers in the customer journey that prevent customers receiving the support they need.\n\nThese obstacles are relevant across wealth management and financial advice, pensions and retirement income, payments and fintech, banking, consumer credit and lending, general insurance and protection, and motor finance.\n\n\u2022 Inadequate research into a product or service's target market\n\u2022 Fair value assessments completed with limited resulting changes to pricing, relying mainly on market benchmarking\n\u2022 Actual charges differing from those quoted in customer agreements\n\u2022 Charging for services the firm is not actually providing, such as ongoing advice\n\u2022 Difficulties for customers wanting to switch or exit a product or service\n\n1. Validate how you know customers understand your products, advice or service\n2. Assess whether post-sale support is at least as effective as pre-sale support\n3. Review how target markets are defined and documented for each product\n4. Check whether your charging structure is regularly reviewed against the value delivered\n5. Ensure board reports address ongoing work and necessary actions, not only positive outcomes\n\nFirms should expect that the regulator can request the outcomes of monitoring activities and board reports at any time, and that this information will be used to assess compliance with the Duty and identify detrimental practices.\n\nBoards are expected to take necessary action, however uncomfortable, and to demonstrate this individually and collectively, including revisiting or questioning existing analysis where needed. Chairs are responsible for ensuring information is reviewed in a timely way with appropriate quorum and management information.\n\nTCC's subject matter experts can assess a firm's Consumer Duty strategy, identifying compliance gaps and highlighting areas that require focus, whether additional expertise is needed to implement changes or independent assurance is sought that Consumer Duty integration is comprehensive. Technology can also support ongoing monitoring, review and documentation of outcomes.", "wordCount": 480, "keywords": [ "Compliance AI & RegTech", "Consumer Duty", "Banking", "General Insurance & Protection", "Lending & Consumer Credit", "Motor Finance", "Payments & FinTech", "Pensions & Retirement Income", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Consumer Duty", "url": "https://tcc.group/blog/solution/consumer-duty/" }, { "@type": "Thing", "name": "Banking", "url": "https://tcc.group/blog/sector/banking/" }, { "@type": "Thing", "name": "General Insurance & Protection", "url": "https://tcc.group/blog/sector/general-insurance-protection/" }, { "@type": "Thing", "name": "Lending & Consumer Credit", "url": "https://tcc.group/blog/sector/lending-consumer-credit/" }, { "@type": "Thing", "name": "Motor Finance", "url": "https://tcc.group/blog/sector/motor-finance/" }, { "@type": "Thing", "name": "Payments & FinTech", "url": "https://tcc.group/blog/sector/payments-fintech/" }, { "@type": "Thing", "name": "Pensions & Retirement Income", "url": "https://tcc.group/blog/sector/pensions-retirement-income/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Consumer Duty common obstacles" } ], "articleSection": [ "Compliance AI & RegTech", "Consumer Duty" ], "audience": [ { "@type": "Audience", "audienceType": "Banking" }, { "@type": "Audience", "audienceType": "General Insurance & Protection" }, { "@type": "Audience", "audienceType": "Lending & Consumer Credit" }, { "@type": "Audience", "audienceType": "Motor Finance" }, { "@type": "Audience", "audienceType": "Payments & FinTech" }, { "@type": "Audience", "audienceType": "Pensions & Retirement Income" }, { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Boards and compliance teams reviewing their existing Consumer Duty arrangements for common gaps." } ], "citation": [ { "@type": "CreativeWork", "name": "A Consumer Duty recap: frequent obstacles to achieving good customer outcomes", "url": "https://tcc.group/blog/2025/02/14/consumer-duty-recap/", "datePublished": "2025-02-14" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/regulatory-horizon/consumer-duty-recap/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/consumer-duty-recap/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What are the four outcomes covered in this recap?", "acceptedAnswer": { "@type": "Answer", "text": "Consumer understanding, consumer support, products and services, and price and value." } }, { "@type": "Question", "name": "What is a common obstacle to good consumer support outcomes?", "acceptedAnswer": { "@type": "Answer", "text": "Firms relying on customers to identify themselves as vulnerable, rather than proactively identifying and recording vulnerability." } }, { "@type": "Question", "name": "Can the FCA request Consumer Duty monitoring data at any time?", "acceptedAnswer": { "@type": "Answer", "text": "Yes; firms should expect that the regulator can request the outcomes of monitoring activities and board reports at any time." } } ] } ] } ``` ### Seven key topics to ensure the success of your ongoing advisory reviews - URL: https://tcc.group/insights/white-papers-guides/seven-topics-ongoing-advice-services/ - Published: 2025-02-11 - Modified: 2026-09-02 **Topic:** Ongoing Advice Standards TCC has compiled seven regulatory standards firms should proactively address to deliver compliant, evidenced ongoing advice reviews, drawing on lessons from PPI, pension review and s166 cases. #### What happened? TCC has published an expert guide setting out seven critical topics firms should consider now to stay ahead of regulatory standards for ongoing advice reviews: a positive start to the customer journey, delivering ongoing advice proactively, the timing of ongoing advice, meeting the requirements of advice, meeting the customer's information needs, delivering fair value, and refund policy. The guide draws a parallel with previous large-scale remediation episodes, including PPI claims, pension reviews and s166 assessments, where shortcuts or profit-led decisions created problems that surfaced, and grew in cost, years later. #### Why does it matter? Both firms and individuals carry responsibility when ongoing service charges are mishandled, and the cost of correcting mistakes can exceed the original penalty, with individuals also facing personal liability. Addressing these seven topics now is a way to reduce that exposure before issues compound. #### Who is affected? Wealth management and financial advice firms that charge ongoing advice fees, and the compliance, risk and advice quality functions responsible for reviewing that service. #### Key risks - Ongoing service charges taken without a service that meets the requirements of advice. - Customer information needs not being met throughout the ongoing advice relationship. - Fair value and refund policies that are unclear or inconsistently applied. - Issues left unaddressed can resemble the pattern seen in PPI, pension review and s166 cases. #### Actions to take 1. Download and review the expert guide covering the seven ongoing advice topics. 2. Assess current ongoing advice processes against each of the seven topics. 3. Consider independent expertise to review, manage and evidence ongoing advice where in-house capacity is limited. #### Wider implications TCC and its sister company Recordsure combine regulatory consultancy expertise with AI-based technology, giving ongoing advice providers additional tools to review, manage and evidence their service beyond what manual processes alone can achieve. #### Recommendations Firms should treat the seven topics as a checklist for their next ongoing advice review cycle, and seek an unbiased external review where they are unsure whether current practice would satisfy the FCA's requirements of advice and fair value. #### Supporting sources - [Seven key topics to ensure the success of your ongoing advisory reviews](https://tcc.group/blog/2025/02/12/seven-topics-ongoing-advice-services/) (2025-02-12) #### Want help reviewing your ongoing advice service? Contact TCC to discuss an independent review of your ongoing advice reviews and evidencing. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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should proactively address to deliver compliant, evidenced ongoing advice reviews, drawing on lessons from PPI, pension review and s166 cases.\n\nTCC has published an expert guide setting out seven critical topics firms should consider now to stay ahead of regulatory standards for ongoing advice reviews: a positive start to the customer journey, delivering ongoing advice proactively, the timing of ongoing advice, meeting the requirements of advice, meeting the customer's information needs, delivering fair value, and refund policy.\n\nThe guide draws a parallel with previous large-scale remediation episodes, including PPI claims, pension reviews and s166 assessments, where shortcuts or profit-led decisions created problems that surfaced, and grew in cost, years later.\n\nBoth firms and individuals carry responsibility when ongoing service charges are mishandled, and the cost of correcting mistakes can exceed the original penalty, with individuals also facing personal liability. Addressing these seven topics now is a way to reduce that exposure before issues compound.\n\nWealth management and financial advice firms that charge ongoing advice fees, and the compliance, risk and advice quality functions responsible for reviewing that service.\n\n\u2022 Ongoing service charges taken without a service that meets the requirements of advice.\n\u2022 Customer information needs not being met throughout the ongoing advice relationship.\n\u2022 Fair value and refund policies that are unclear or inconsistently applied.\n\u2022 Issues left unaddressed can resemble the pattern seen in PPI, pension review and s166 cases.\n\n1. Download and review the expert guide covering the seven ongoing advice topics.\n2. Assess current ongoing advice processes against each of the seven topics.\n3. Consider independent expertise to review, manage and evidence ongoing advice where in-house capacity is limited.\n\nTCC and its sister company Recordsure combine regulatory consultancy expertise with AI-based technology, giving ongoing advice providers additional tools to review, manage and evidence their service beyond what manual processes alone can achieve.\n\nFirms should treat the seven topics as a checklist for their next ongoing advice review cycle, and seek an unbiased external review where they are unsure whether current practice would satisfy the FCA's requirements of advice and fair value.", "wordCount": 352, "keywords": [ "Compliance AI & RegTech", "Consumer Duty", "Suitability, Advice Quality & File Reviews", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Consumer Duty", "url": "https://tcc.group/blog/solution/consumer-duty/" }, { "@type": "Thing", "name": "Suitability, Advice Quality & File Reviews", "url": "https://tcc.group/blog/solution/outsourced-suitability-reviews/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Ongoing Advice Standards" } ], "articleSection": [ "Compliance AI & RegTech", "Consumer Duty", "Suitability, Advice Quality & File Reviews" ], "audience": [ { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Compliance, advice quality and senior leaders in wealth management firms delivering ongoing advice." } ], "citation": [ { "@type": "CreativeWork", "name": "Seven key topics to ensure the success of your ongoing advisory reviews", "url": "https://tcc.group/blog/2025/02/12/seven-topics-ongoing-advice-services/", "datePublished": "2025-02-12" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/white-papers-guides/seven-topics-ongoing-advice-services/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/white-papers-guides/seven-topics-ongoing-advice-services/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What are the seven topics in TCC's ongoing advice guide?", "acceptedAnswer": { "@type": "Answer", "text": "They cover the customer journey, proactive delivery of ongoing advice, timing, meeting the requirements of advice, customer information needs, fair value and refund policy." } }, { "@type": "Question", "name": "Why does TCC compare this to PPI and pension review cases?", "acceptedAnswer": { "@type": "Answer", "text": "Because past shortcuts in ongoing servicing created risks that stayed hidden for years before surfacing at a much higher cost, a pattern the guide warns firms to avoid repeating." } }, { "@type": "Question", "name": "Who can help firms address these topics?", "acceptedAnswer": { "@type": "Answer", "text": "TCC, working with its sister company Recordsure, offers advisory, managed services and AI-based tools to review, manage and evidence ongoing advice." } } ] } ] } ``` ### The benefits of enhancing data capture go beyond compliance – Money Marketing - URL: https://tcc.group/insights/analysis-perspectives/benefits-of-enhanced-data-go-beyond-compliance-money-marketing/ - Published: 2025-02-05 - Modified: 2026-09-02 **Topic:** Data and FCA Expectations In Money Marketing, TCC's Technical Director David Boyhan explains how better data capture helps firms meet FCA requirements and ensure regular client reviews happen when they should, particularly given regulatory focus on ongoing advice and motor finance. #### What happened? The FCA has said for some years that it wants to be a data-led regulator. With supervisory attention currently on ongoing-advice services and motor finance, TCC's Technical Director David Boyhan argues in Money Marketing that now is the time for firms to look closely at how they collate and use their data. #### Why does it matter? Boyhan's central point is that valuable data does more than help firms meet FCA requirements: it can also help businesses ensure that regular client reviews actually happen as and when they should, reducing the risk of missed or late reviews. #### Supporting sources - [The benefits of enhancing data capture go beyond compliance – Money Marketing](https://tcc.group/blog/2025/02/06/benefits-of-enhanced-data-go-beyond-compliance-money-marketing/) (2025-02-06) #### Is your client data working hard enough? Contact us to discuss how better data capture can strengthen your compliance evidence and client review processes. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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"https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/insights/analysis-perspectives/benefits-of-enhanced-data-go-beyond-compliance-money-marketing/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Insights", "item": "https://tcc.group/insights/" }, { "@type": "ListItem", "position": 3, "name": "The benefits of enhancing data capture go beyond compliance \u2013 Money Marketing", "item": "https://tcc.group/insights/analysis-perspectives/benefits-of-enhanced-data-go-beyond-compliance-money-marketing/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/analysis-perspectives/benefits-of-enhanced-data-go-beyond-compliance-money-marketing/#webpage", "url": "https://tcc.group/insights/analysis-perspectives/benefits-of-enhanced-data-go-beyond-compliance-money-marketing/", "name": "The benefits of enhancing data capture go beyond compliance \u2013 Money Marketing", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2025-02-06T00:00:00+01:00", "dateModified": "2026-09-02T03:47:33+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/analysis-perspectives/benefits-of-enhanced-data-go-beyond-compliance-money-marketing/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "AnalysisNewsArticle", "@id": "https://tcc.group/insights/analysis-perspectives/benefits-of-enhanced-data-go-beyond-compliance-money-marketing/#article", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/benefits-of-enhanced-data-go-beyond-compliance-money-marketing/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "The benefits of enhancing data capture go beyond compliance \u2013 Money Marketing", "datePublished": "2025-02-06T00:00:00+01:00", "dateModified": "2026-09-02T03:47:33+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/analysis-perspectives/benefits-of-enhanced-data-go-beyond-compliance-money-marketing/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/86360a98d9f54b39b9401e973ce45e87/thumbnail-1024-a9b0a3bb9f0acff76747916d787b5f7fa4e63e4c7589e46e97721dc136de4c6f.jpg", "description": "Find out why enhanced data capture helps advice firms meet FCA expectations and keep client reviews on schedule, according to TCC's Technical Director David Boyhan.", "inLanguage": "en-GB", "articleBody": "In Money Marketing, TCC's Technical Director David Boyhan explains how better data capture helps firms meet FCA requirements and ensure regular client reviews happen when they should, particularly given regulatory focus on ongoing advice and motor finance.\n\nThe FCA has said for some years that it wants to be a data-led regulator. With supervisory attention currently on ongoing-advice services and motor finance, TCC's Technical Director David Boyhan argues in Money Marketing that now is the time for firms to look closely at how they collate and use their data.\n\nBoyhan's central point is that valuable data does more than help firms meet FCA requirements: it can also help businesses ensure that regular client reviews actually happen as and when they should, reducing the risk of missed or late reviews.", "wordCount": 129, "keywords": [ "Compliance AI & RegTech", "Consumer Duty", "Regulatory Change & Transformation", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Consumer Duty", "url": "https://tcc.group/blog/solution/consumer-duty/" }, { "@type": "Thing", "name": "Regulatory Change & Transformation", "url": "https://tcc.group/blog/solution/regulatory-change-transformation/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Data and FCA Expectations" } ], "articleSection": [ "Compliance AI & RegTech", "Consumer Duty", "Regulatory Change & Transformation" ], "audience": [ { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Advice firms and compliance teams responsible for client review data and ongoing-advice obligations." } ], "citation": [ { "@type": "CreativeWork", "name": "The benefits of enhancing data capture go beyond compliance \u2013 Money Marketing", "url": "https://tcc.group/blog/2025/02/06/benefits-of-enhanced-data-go-beyond-compliance-money-marketing/", "datePublished": "2025-02-06" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/analysis-perspectives/benefits-of-enhanced-data-go-beyond-compliance-money-marketing/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/benefits-of-enhanced-data-go-beyond-compliance-money-marketing/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "Why does the FCA care about how firms use data?", "acceptedAnswer": { "@type": "Answer", "text": "The FCA has said it wants to be a data-led regulator, and its current supervisory focus on ongoing-advice services and motor finance makes firms' data practices more visible." } }, { "@type": "Question", "name": "What benefit does enhanced data capture offer beyond compliance?", "acceptedAnswer": { "@type": "Answer", "text": "It can help firms ensure that regular client reviews happen as and when they should, rather than simply satisfying a regulatory requirement after the fact." } } ] } ] } ``` ### Overview so far: the expected regulatory hot topics of 2025 - URL: https://tcc.group/insights/regulatory-horizon/2025-regulatory-topics/ - Published: 2025-01-27 - Modified: 2026-09-02 **Topic:** 2025 regulatory hot topics Drawing on TCC's 2024 compliance forums, this overview sets out the FCA's current concerns spanning financial resilience, vulnerable customers, Consumer Duty fair value and senior management accountability. #### What happened? TCC's regulatory specialists hosted a series of compliance forums throughout 2024, and this overview draws together the issues raised as the topics most likely to matter for financial services compliance in 2025. The FCA's concerns include the financial resilience of firms and the adequacy of their wind-down plans, alongside the continued reliance of UK consumers on short-term credit, which points to unresolved arrears and vulnerability issues. Fines issued during 2024 showed that firms are often preoccupied with business as usual at the expense of proper controls and control testing. Consumer Duty outcomes remain under scrutiny too, particularly product price and fair value in areas such as Discretionary Commission Arrangements, ongoing advice services and self-invested personal pensions, where the FCA has noted that fees and commissions are not always consistently aligned with the Duty. #### Why does it matter? The FCA is expected to challenge senior management and boards more directly to explain how they discharge their duties and why problems occurred on their watch. Training and competence, often treated as a tick-box exercise, is likely to come under similar pressure. Firms that leave known risk areas unaddressed face a cumulative effect: the longer a weakness persists, the more customers are likely to be affected by it, and the greater the risk of regulatory intrusion that is costly, stressful and disruptive to individual careers as well as the firm. #### Who is affected? These themes apply broadly across wealth management, pensions, banking, lending, insurance, motor finance and payments firms, particularly those managing short-term credit, ongoing advice services, self-invested personal pensions or products where commission arrangements affect customer outcomes. #### Key risks - Cumulative risk: unresolved weaknesses compound the longer they are left unaddressed. - Perception risk: the regulator increasingly questions how and why senior management allowed risks to materialise. - Culture risk: the actions a firm takes, and fails to take, reflect its culture, with dominant personalities or groupthink among the most damaging behaviours. - Systems and controls risk: controls should be proportionate to complexity rather than fitted around budgets. - Corporate governance risk: committees, the three lines of defence and conflicts of interest all need to be clearly defined and evidenced. #### Actions to take 1. Review systems and controls around known risk areas, including price, value, Discretionary Commission Arrangements and ongoing services. 2. Benchmark the firm against its peer group to identify strengths, comparative weaknesses and any outlier positions. 3. Assess evidence of cultural and conduct metrics against the firm's stated risk appetite. 4. Review monitoring and audit plans for key systems and controls to strengthen control effectiveness. 5. Evaluate corporate governance arrangements, including committee structures and SMCR accountability, against best practice. #### Wider implications > Be proactive. Don't wait for us to intervene, we expect our firms to lead from the front. That message from the FCA sets the tone for 2025: firms are expected to identify and address weaknesses themselves rather than wait for supervisory action. #### Recommendations TCC offers an unbiased review and strategic advice to help firms meet their compliance objectives, alongside outsourcing solutions and specialist resourcing that draws on a network of more than 5,000 pre-vetted subject matter experts. Where appropriate, TCC combines this expertise with technology from its sister company, Recordsure, to help firms drive operational efficiencies and evidence outcomes to the regulator's satisfaction. #### Supporting sources - [Overview so far: the expected regulatory hot topics of 2025](https://tcc.group/blog/2025/01/28/2025-regulatory-topics/) (2025-01-28) #### Want help preparing for 2025's priorities? Speak to our team about a review of your systems, controls and Consumer Duty evidence ahead of the year ahead. [Contact us](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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"name": "Kit Ruparel" }, "headline": "Overview so far: the expected regulatory hot topics of 2025", "datePublished": "2025-01-28T00:00:00+01:00", "dateModified": "2026-09-02T03:47:29+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/regulatory-horizon/2025-regulatory-topics/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/e686a68b4dec4fcba687af4e66873a28/thumbnail-1024-71386f58e0adbea8b53bc506fd9b1be2ede79eddbdeec1ee5a91e2d05a062736.jpg", "description": "TCC's compliance forums identify the FCA concerns most likely to shape 2025, from financial resilience and vulnerable customers to Consumer Duty fair value, helping firms target reviews before the regulator intervenes.", "inLanguage": "en-GB", "articleBody": "Drawing on TCC's 2024 compliance forums, this overview sets out the FCA's current concerns spanning financial resilience, vulnerable customers, Consumer Duty fair value and senior management accountability.\n\nTCC's regulatory specialists hosted a series of compliance forums throughout 2024, and this overview draws together the issues raised as the topics most likely to matter for financial services compliance in 2025.\n\nThe FCA's concerns include the financial resilience of firms and the adequacy of their wind-down plans, alongside the continued reliance of UK consumers on short-term credit, which points to unresolved arrears and vulnerability issues. Fines issued during 2024 showed that firms are often preoccupied with business as usual at the expense of proper controls and control testing.\n\nConsumer Duty outcomes remain under scrutiny too, particularly product price and fair value in areas such as Discretionary Commission Arrangements, ongoing advice services and self-invested personal pensions, where the FCA has noted that fees and commissions are not always consistently aligned with the Duty.\n\nThe FCA is expected to challenge senior management and boards more directly to explain how they discharge their duties and why problems occurred on their watch. Training and competence, often treated as a tick-box exercise, is likely to come under similar pressure.\n\nFirms that leave known risk areas unaddressed face a cumulative effect: the longer a weakness persists, the more customers are likely to be affected by it, and the greater the risk of regulatory intrusion that is costly, stressful and disruptive to individual careers as well as the firm.\n\nThese themes apply broadly across wealth management, pensions, banking, lending, insurance, motor finance and payments firms, particularly those managing short-term credit, ongoing advice services, self-invested personal pensions or products where commission arrangements affect customer outcomes.\n\n\u2022 Cumulative risk: unresolved weaknesses compound the longer they are left unaddressed.\n\u2022 Perception risk: the regulator increasingly questions how and why senior management allowed risks to materialise.\n\u2022 Culture risk: the actions a firm takes, and fails to take, reflect its culture, with dominant personalities or groupthink among the most damaging behaviours.\n\u2022 Systems and controls risk: controls should be proportionate to complexity rather than fitted around budgets.\n\u2022 Corporate governance risk: committees, the three lines of defence and conflicts of interest all need to be clearly defined and evidenced.\n\n1. 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"acceptedAnswer": { "@type": "Answer", "text": "Cumulative risk, perception risk, culture risk, systems and controls risk, and corporate governance risk." } }, { "@type": "Question", "name": "How can TCC help firms prepare?", "acceptedAnswer": { "@type": "Answer", "text": "Through an unbiased review and strategic advice, outsourcing solutions, specialist resourcing and, where suitable, Recordsure's technology to evidence outcomes." } } ] } ] } ``` ### Failing Consumer Duty with renewal barriers - URL: https://tcc.group/insights/regulatory-horizon/insurance-renewal-barriers/ - Published: 2025-01-08 - Modified: 2026-09-02 ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing 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Protection" } ] } ] } ``` ### What firms should take from the FCA’s latest portfolio strategy letter - URL: https://tcc.group/insights/analysis-perspectives/tcc-explores-fca-portfolio-strategy-letter-7-october-2024/ - Published: 2024-11-11 - Modified: 2024-11-11 **Topic:** FCA Portfolio Strategy Letter TCC's Technical Director David Boyhan examines the FCA's portfolio strategy letter for financial advisers and investment intermediaries, dated 7 October 2024, in an article for Money Marketing. #### What happened? TCC's Technical Director David Boyhan has written an article for *Money Marketing* examining the FCA's portfolio strategy letter for financial advisers and investment intermediaries, published on 7 October 2024. The letter has become an established part of the regulator's communications, sitting alongside its annual business plan. Unlike the business plan, the portfolio strategy letter provides sector-specific detail, setting out the FCA's priorities and expectations for advisory firms. #### Why does it matter? The article highlights that the regulator's update points to the importance of firms carrying out adequate due diligence of their back books. For advisory firms, this signals an area the FCA is likely to focus on when assessing supervisory priorities. #### Supporting sources - [What firms should take from the FCA’s latest portfolio strategy letter](https://tcc.group/blog/2024/11/12/tcc-explores-fca-portfolio-strategy-letter-7-october-2024/) (2024-11-12) #### Need help reviewing your back book? Contact our team to discuss how we can support your due diligence and portfolio strategy work. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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Financial advice firms now have numerous AI solutions to choose from, but it is often unclear which type of AI is being promoted, or whether it is suited to the firm's needs. There are two main types of AI on the market, and identifying which one is right for a given business is an important first step before adopting any tool. #### Why does it matter? Choosing the wrong type of AI can mean investing in a tool that does not match the firm's needs, so understanding the distinction between the two main types of AI is a necessary step before making that decision. #### Supporting sources - [How advice firms should navigate the AI journey](https://tcc.group/blog/2024/09/17/advice-firms-ai/) (2024-09-17) #### Not sure which AI is right for you? Speak to our team about choosing the right type of AI for your advice business. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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TCC recently hosted a Consumer Duty forum with leaders from medium to large financial services firms. The event highlighted that while many firms have established basic compliance frameworks, embedding the required cultural shift and maintaining robust corporate governance remains a significant challenge. Key discussions centered around active board involvement, the role of Consumer Duty Champions, and the integrity of Management Information (MI). Participants noted that some boards still expect solely positive reporting, which can mask critical areas of work-in-progress or required remediation. #### Why does it matter? The FCA's supervisory focus is shifting from initial implementation to long-term outcome testing. Proportionality under SYSC rules means that smaller firms are not exempt from rigorous evidence generation. To withstand scrutiny, firms must transition from passive complaints-tracking to active qualitative and quantitative monitoring. Firms are also navigating specific operational challenges, such as ongoing service charges and coordinating product oversight between manufacturers and distributors. Robust, data-led evidence is essential to avoid regulatory intervention. #### Who is affected? This update is highly relevant for non-executive directors, Customer Duty Champions, and Senior Management Function (SMF) holders across wealth management, insurance, banking, and lending firms. #### Key risks - **Superficial Board Reporting:** Presenting only positive progress to the board, leaving critical operational gaps unaddressed. - **Weak Outsource Monitoring:** Insufficient oversight of product governance and customer journeys across distributor-manufacturer boundaries. - **Distorted QA Metrics:** Relying on superficial scores, such as call-handling speed, rather than assessing material customer outcomes. #### Actions to take 1. **Record Board Scrutiny:** Document active board interrogation of Consumer Duty reports, including requests for deeper risk analysis. 2. **Upgrade MI Frameworks:** Transition from passive complaint counts to qualitative outcome indicators that drive clear business actions. 3. **Address Service Charges:** Establish clear operational protocols for ongoing service reviews, including monitoring behavior risks in system inputs. 4. **Deploy RegTech Solutions:** Invest in technology-driven quality assurance to increase testing volumes and reduce manual compliance burdens. #### Wider implications Supervisory expectations continue to rise across all sectors. Proving long-term compliance is becoming a key differentiator of firm reputation, customer trust, and market competitiveness. #### Recommendations Boards should proactively challenge their current Consumer Duty evidence frameworks and address any indifferent internal cultures before the next reporting cycle. #### Supporting sources - [Five key priorities for long-term Consumer Duty success](https://tcc.group/blog/2024/08/09/five-priorities-consumer-duty/) (2024-08-09) #### Ready to validate your long-term Consumer Duty framework? Evaluate your MI, test your customer outcomes, and secure independent regulatory reassurance with our expert compliance team. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/insights/regulatory-horizon/five-priorities-consumer-duty/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Insights", "item": "https://tcc.group/insights/" }, { "@type": "ListItem", "position": 3, "name": "Five key priorities for long-term Consumer Duty success", "item": "https://tcc.group/insights/regulatory-horizon/five-priorities-consumer-duty/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/regulatory-horizon/five-priorities-consumer-duty/#webpage", "url": "https://tcc.group/insights/regulatory-horizon/five-priorities-consumer-duty/", "name": "Five key priorities for long-term Consumer Duty success", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2024-08-09T00:00:00+01:00", "dateModified": "2026-09-02T03:47:45+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/regulatory-horizon/five-priorities-consumer-duty/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "NewsArticle", "@id": "https://tcc.group/insights/regulatory-horizon/five-priorities-consumer-duty/#article", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/five-priorities-consumer-duty/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "Five key priorities for long-term Consumer Duty success", "datePublished": "2024-08-09T00:00:00+01:00", "dateModified": "2026-09-02T03:47:45+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/regulatory-horizon/five-priorities-consumer-duty/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/8735a4dbb3d44c879d6f2ef75d0c71f3/thumbnail-1024-1b6989330724aeefc207c13847004ca858e833b112f695096dee357fe70b882f.jpg", "description": "Following our recent Consumer Duty forum, we outline five key priorities for long-term success. Discover insights on embedding governance, managing Board reporting, and the role of RegTech in outcome testing.", "inLanguage": "en-GB", "articleBody": "TCC summarizes the five discussion themes from our recent Consumer Duty forum, focusing on culture, Board challenge, proportionality, and evidence-led monitoring.\n\nTCC recently hosted a Consumer Duty forum with leaders from medium to large financial services firms. The event highlighted that while many firms have established basic compliance frameworks, embedding the required cultural shift and maintaining robust corporate governance remains a significant challenge.\n\nKey discussions centered around active board involvement, the role of Consumer Duty Champions, and the integrity of Management Information (MI). Participants noted that some boards still expect solely positive reporting, which can mask critical areas of work-in-progress or required remediation.\n\nThe FCA's supervisory focus is shifting from initial implementation to long-term outcome testing. Proportionality under SYSC rules means that smaller firms are not exempt from rigorous evidence generation. To withstand scrutiny, firms must transition from passive complaints-tracking to active qualitative and quantitative monitoring.\n\nFirms are also navigating specific operational challenges, such as ongoing service charges and coordinating product oversight between manufacturers and distributors. Robust, data-led evidence is essential to avoid regulatory intervention.\n\nThis update is highly relevant for non-executive directors, Customer Duty Champions, and Senior Management Function (SMF) holders across wealth management, insurance, banking, and lending firms.\n\n\u2022 Superficial Board Reporting: Presenting only positive progress to the board, leaving critical operational gaps unaddressed.\n\u2022 Weak Outsource Monitoring: Insufficient oversight of product governance and customer journeys across distributor-manufacturer boundaries.\n\u2022 Distorted QA Metrics: Relying on superficial scores, such as call-handling speed, rather than assessing material customer outcomes.\n\n1. Record Board Scrutiny: Document active board interrogation of Consumer Duty reports, including requests for deeper risk analysis.\n2. Upgrade MI Frameworks: Transition from passive complaint counts to qualitative outcome indicators that drive clear business actions.\n3. Address Service Charges: Establish clear operational protocols for ongoing service reviews, including monitoring behavior risks in system inputs.\n4. Deploy RegTech Solutions: Invest in technology-driven quality assurance to increase testing volumes and reduce manual compliance burdens.\n\nSupervisory expectations continue to rise across all sectors. 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Smaller and medium firms must still produce robust, auditable evidence of how they deliver and test appropriate outcomes." } }, { "@type": "Question", "name": "What is the recommended approach for Quality Assurance (QA)?", "acceptedAnswer": { "@type": "Answer", "text": "Firms should shift focus away from non-material administrative scores and instead use data and technology to monitor material customer outcomes." } } ] } ] } ``` ### Consumer Duty: What does the FCA expect from ongoing advice services? - URL: https://tcc.group/insights/analysis-perspectives/consumer-duty-what-does-the-fca-expect-from-ongoing-advice-services/ - Published: 2024-04-03 - Modified: 2026-09-02 **Topic:** Ongoing advice charges The FCA wrote to 20 major financial advice firms requesting information on their ongoing advice charges, signalling scrutiny of fair value and consumer understanding under the Consumer Duty. #### What happened? The FCA wrote to 20 major financial advice firms requesting information on their ongoing advice charges, signalling its intention to focus on how firms are revising their approach in line with the Consumer Duty's fair value and consumer understanding requirements. In Money Marketing, TCC's Technical Director David Boyhan outlined what firms can expect from the FCA's next steps. #### Why does it matter? Firms offering ongoing advice services need to be able to show that customers are actually receiving the ongoing service they are charged for, and that charges reflect fair value, since this is now an area of direct regulatory information requests rather than general guidance. #### Supporting sources - [Consumer Duty: What does the FCA expect from ongoing advice services?](https://tcc.group/blog/2024/04/04/consumer-duty-what-does-the-fca-expect-from-ongoing-advice-services/) (2024-04-04) #### Confident your ongoing advice charges hold up? TCC can help you prepare for regulatory scrutiny of ongoing advice services. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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about ongoing advice charges, with practical steps to prepare for scrutiny of fair value and consumer understanding.", "inLanguage": "en-GB", "articleBody": "The FCA wrote to 20 major financial advice firms requesting information on their ongoing advice charges, signalling scrutiny of fair value and consumer understanding under the Consumer Duty.\n\nThe FCA wrote to 20 major financial advice firms requesting information on their ongoing advice charges, signalling its intention to focus on how firms are revising their approach in line with the Consumer Duty's fair value and consumer understanding requirements. 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TCC's Gary Maude sets out firms' safeguarding obligations in the Consumer Duty era. #### What happened? A recent Financial Ombudsman Service decision has drawn attention to the risks of DIY SIPP arrangements, particularly for customers displaying signs of vulnerability such as gambling addiction. Writing in FT Adviser, TCC's Head of Advisory Practice, Gary Maude, set out firms' safeguarding obligations towards customers taking a DIY approach in the Consumer Duty era. #### Why does it matter? Consumer Duty does not treat a self-directed or execution-only proposition as a reason to step back from identifying and supporting vulnerable customers. The Ombudsman's decision is a reminder that firms retain safeguarding obligations even where customers are making their own choices. #### Supporting sources - [Assessing vulnerability: How can firms help mitigate risks of DIY SIPPs?](https://tcc.group/blog/2024/02/09/assessing-vulnerability-how-can-firms-help-mitigate-risks-of-diy-sipps/) (2024-02-09) #### Are your DIY SIPP safeguards Duty-ready? Talk to us about assessing and evidencing how your firm identifies and supports vulnerable customers in self-directed arrangements. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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"AnalysisNewsArticle", "@id": "https://tcc.group/insights/analysis-perspectives/assessing-vulnerability-how-can-firms-help-mitigate-risks-of-diy-sipps/#article", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/assessing-vulnerability-how-can-firms-help-mitigate-risks-of-diy-sipps/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "Assessing vulnerability: How can firms help mitigate risks of DIY SIPPs?", "datePublished": "2024-02-09T00:00:00+01:00", "dateModified": "2026-09-02T03:47:32+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/analysis-perspectives/assessing-vulnerability-how-can-firms-help-mitigate-risks-of-diy-sipps/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/945b36b177184adba6e1cad6947e81c3/thumbnail-1024-591f29d9dcebc47046e4c12003d243626918a51086c9f12884cc9505297f11c2.jpg", "description": "Learn what a Financial Ombudsman Service ruling on DIY SIPPs means for firms' safeguarding duties towards vulnerable customers, and how to evidence good outcomes under Consumer Duty.", "inLanguage": "en-GB", "articleBody": "A Financial Ombudsman Service decision has highlighted the risks of DIY SIPP arrangements for customers showing signs of vulnerability, such as gambling addiction. TCC's Gary Maude sets out firms' safeguarding obligations in the Consumer Duty era.\n\nA recent Financial Ombudsman Service decision has drawn attention to the risks of DIY SIPP arrangements, particularly for customers displaying signs of vulnerability such as gambling addiction. Writing in FT Adviser, TCC's Head of Advisory Practice, Gary Maude, set out firms' safeguarding obligations towards customers taking a DIY approach in the Consumer Duty era.\n\nConsumer Duty does not treat a self-directed or execution-only proposition as a reason to step back from identifying and supporting vulnerable customers. 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Consumer Duty applies regardless of whether a customer is advised or self-directed, and firms retain obligations to identify and support customers showing signs of vulnerability." } }, { "@type": "Question", "name": "What risk did the Financial Ombudsman Service decision highlight?", "acceptedAnswer": { "@type": "Answer", "text": "It highlighted the risks of DIY SIPP arrangements for customers displaying signs of vulnerability, such as gambling addiction, and firms' safeguarding obligations towards them." } } ] } ] } ``` ### Equity Release: Get your five-step guide to Consumer Duty compliance - URL: https://tcc.group/insights/white-papers-guides/equity-release-get-your-five-step-guide-to-consumer-duty-compliance/ - Published: 2024-02-01 - Modified: 2026-09-02 **Topic:** Consumer Duty in Equity Release The FCA's review of equity release highlighted standard failures in advice and promotions, prompting TCC to release a five-step compliance guide for firms. #### What happened? Later life mortgages and equity release have returned to the regulatory spotlight after a wide-ranging FCA review raised serious concerns. The regulator flagged issues around advice standards, misleading financial promotions, and potential risks being underreported to clients. These issues directly clash with the newly implemented Consumer Duty legislation. The regulator now expects all mortgage and equity release providers to review the findings and make immediate changes where they are falling short. #### Why does it matter? Equity release products are intrinsically complex and high-risk, making suitability and customer understanding critical, especially when dealing with vulnerable customers. Failing to meet Consumer Duty standards exposes firms to severe regulatory intervention and reputational damage. Furthermore, the FCA discovered instances where sales were incentivised over providing quality advice, which is a major breach of the 'customer first' ethos of the Consumer Duty. #### Who is affected? This affects all equity release providers, advisers, and later life mortgage intermediaries, as well as their compliance and training functions. #### Key risks Firms in this sector face significant risks if they fail to align with the regulator's priorities: - Severe FCA enforcement actions due to misleading advertising and unsuitable advice. - Incentive structures that promote sales volumes over client suitability, leading to poor customer outcomes. - Failure to properly identify and support customers showing vulnerable characteristics. #### Actions to take Firms should adopt our five-step roadmap to address the regulator's expectations: 1. Step up customer communications and vet financial promotions closely. 2. Enable effective, unpressured decision-making for customers and their families. 3. Focus on meaningful conversations that go beyond simple transaction checklists. 4. Set out clear best practice guidelines anchored in the Consumer Duty principles. 5. Spotlight internal processes, incentive structures, and governance frameworks. #### Wider implications The FCA is shifting toward a highly proactive, outcomes-focused supervision model. Mortgage lenders can no longer rely on traditional checklists; they must prove and document that their products and advice consistently serve the customer's best interests. #### Recommendations We recommend conducting a diagnostic review of historical sales files and financial promotions to identify potential gaps, as well as restructuring any commercial incentive models that could compromise advice suitability. #### Supporting sources - [Equity Release: Get your five-step guide to Consumer Duty compliance](https://tcc.group/blog/2024/02/02/equity-release-get-your-five-step-guide-to-consumer-duty-compliance/) (2024-02-02) #### Is your equity release advice strategy compliant? Contact our advisory team today for a swift compliance diagnostic check-in on your sales processes and financial promotions. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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With defined benefit (DB) transfers now treated as business as usual by the regulator, the FCA's focus for regulatory due diligence is shifting. Writing in Money Marketing, TCC's Technical Director David Boyhan explains the reasons behind this change in priorities and sets out three areas acquirers should not overlook when reviewing a target firm. #### Why does it matter? Acquirers who base their due diligence on the FCA's previous areas of focus risk overlooking the issues the regulator is now most concerned with, which could mean inheriting problems from a target firm after a deal completes. #### Supporting sources - [Regulatory due diligence: Examining firms’ priorities for 2024](https://tcc.group/blog/2024/01/10/regulatory-due-diligence-fca-priorities-for-2024/) (2024-01-10) #### Planning an acquisition in financial services? Get in touch to discuss how we can support your regulatory due diligence ahead of an acquisition. 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With defined benefit (DB) transfers now treated as business as usual by the regulator, the FCA's focus for regulatory due diligence is shifting.\n\nWriting in Money Marketing, TCC's Technical Director David Boyhan explains the reasons behind this change in priorities and sets out three areas acquirers should not overlook when reviewing a target firm.\n\nAcquirers who base their due diligence on the FCA's previous areas of focus risk overlooking the issues the regulator is now most concerned with, which could mean inheriting problems from a target firm after a deal completes.", "wordCount": 146, "keywords": [ "Compliance AI & RegTech", "Consolidation, Acquisition & Regulatory Due Diligence", "Regulatory Change & Transformation", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Consolidation, Acquisition & Regulatory Due Diligence", "url": "https://tcc.group/blog/solution/consolidation-acquisition-regulatory-due-diligence/" }, { "@type": "Thing", "name": "Regulatory Change & Transformation", "url": "https://tcc.group/blog/solution/regulatory-change-transformation/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Regulatory Due Diligence Priorities" } ], "articleSection": [ "Compliance AI & RegTech", "Consolidation, Acquisition & Regulatory Due Diligence", "Regulatory Change & Transformation" ], "audience": [ { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Firms undertaking or considering acquisitions in financial services, particularly those responsible for regulatory due diligence on a target firm." } ], "citation": [ { "@type": "CreativeWork", "name": "Regulatory due diligence: Examining firms\u2019 priorities for 2024", "url": "https://tcc.group/blog/2024/01/10/regulatory-due-diligence-fca-priorities-for-2024/", "datePublished": "2024-01-10" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/analysis-perspectives/regulatory-due-diligence-fca-priorities-for-2024/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/regulatory-due-diligence-fca-priorities-for-2024/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "Why is DB transfer due diligence changing?", "acceptedAnswer": { "@type": "Answer", "text": "Because the FCA now treats DB transfers as business as usual, which is shifting where the regulator expects acquirers to focus their due diligence." } }, { "@type": "Question", "name": "Who wrote this analysis?", "acceptedAnswer": { "@type": "Answer", "text": "TCC's Technical Director, David Boyhan, writing in Money Marketing." } } ] } ] } ``` ### Four steps to building an effective Retirement Income proposition - URL: https://tcc.group/insights/analysis-perspectives/four-steps-building-an-effective-centralised-retirement-income-proposition/ - Published: 2023-11-12 - Modified: 2026-09-02 **Topic:** Retirement Income Proposition TCC's Technical Director David Boyhan outlines key steps in Money Marketing to help wealth managers design and audit an effective Centralised Retirement Income Proposition. #### What happened? In an article published in Money Marketing, TCC's Technical Director David Boyhan addresses the FCA's heightened scrutiny of retirement income advice. Earlier, the regulator issued a major 87-question survey to more than 1,000 advisory firms, gathering data on their management processes, fee structures, incentives, and internal controls. Given the high risk of poor outcomes associated with decumulation and retirement planning, the regulator expects firms to actively and systematically review their advice models. #### Why does it matter? With further regulatory findings and communications expected, firms must take a proactive approach rather than waiting for formal intervention. Designing and auditing a dedicated Centralised Retirement Income Proposition (CRIP) is essential for proving compliance with the Consumer Duty. Firms must ensure that advisors are supported by robust tools, clear decumulation suitability standards, and aligned fee structures that put customer outcomes first. #### Who is affected? This media commentary is designed for advisory firm executives, pension trustees, and compliance managers in the pensions and wealth sector. #### Supporting sources - [Four steps to building an effective Retirement Income proposition](https://tcc.group/blog/2023/11/13/four-steps-building-an-effective-centralised-retirement-income-proposition/) (2023-11-13) #### Is your retirement income proposition regulatory-ready? Review your processes, audit your advice files, and secure a robust centralised retirement proposition with our pensions advisory team. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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"AnalysisNewsArticle", "@id": "https://tcc.group/insights/analysis-perspectives/four-steps-building-an-effective-centralised-retirement-income-proposition/#article", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/four-steps-building-an-effective-centralised-retirement-income-proposition/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "Four steps to building an effective Retirement Income proposition", "datePublished": "2023-11-13T00:00:00+01:00", "dateModified": "2026-09-02T03:47:47+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/analysis-perspectives/four-steps-building-an-effective-centralised-retirement-income-proposition/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/2ff172f6e03d4f869eed2d5e762f459d/thumbnail-1024-c40fa944850a6cccd182df0b9aab6a049b9248618bf71b7502af13f1bee345e5.jpg", "description": "With the FCA intensifying its focus on retirement income advice, firms must review their processes. TCC's David Boyhan outlines four essential steps in Money Marketing to deliver compliant outcomes.", "inLanguage": "en-GB", "articleBody": "TCC's Technical Director David Boyhan outlines key steps in Money Marketing to help wealth managers design and audit an effective Centralised Retirement Income Proposition.\n\nIn an article published in Money Marketing, TCC's Technical Director David Boyhan addresses the FCA's heightened scrutiny of retirement income advice. Earlier, the regulator issued a major 87-question survey to more than 1,000 advisory firms, gathering data on their management processes, fee structures, incentives, and internal controls.\n\nGiven the high risk of poor outcomes associated with decumulation and retirement planning, the regulator expects firms to actively and systematically review their advice models.\n\nWith further regulatory findings and communications expected, firms must take a proactive approach rather than waiting for formal intervention. 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A year on from firms first building and scrutinising their Consumer Duty implementation plans, the FCA's Director of Cross Cutting Policy and Strategy, Nisha Arora, reminded regulated businesses that the Duty is not a “once and done” exercise. Firms are being asked to check that the changes identified during planning are now well underway, and whether those changes go far enough to achieve good customer outcomes. Nisha Arora described the Consumer Duty as the “golden thread” that will run through all conversations firms have with the regulator, with the FCA testing how firms have implemented and embedded the Duty across their full business life cycle. From 31 July 2024, the Duty will also apply to closed products and services, meaning firms need to ensure their legacy book of business aligns with it too. #### Why does it matter? The Duty needs to be applied across the whole organisation, from board level through to front-line delivery, including product design, communications and customer support. Senior managers need to assess whether consumers are genuinely at the heart of the business, and whether the firm's long-term strategy is consistent with delivering good customer outcomes. The FCA's supervisory and enforcement approach will be “proportionate to the harm, or risk of harm, to consumers”, prioritising the most serious breaches and acting swiftly, driven in large part by the management information firms provide. #### Who is affected? All regulated firms across wealth management, pensions, banking, lending, general insurance and protection, and motor finance are affected, particularly those with closed products or legacy books of business that will come into scope from July 2024. #### Key risks - Treating Consumer Duty implementation as a one-off exercise rather than an ongoing programme of assessment, testing and evidencing. - Insufficient detective and preventative controls where risks to good outcomes have already been identified. - Data and monitoring that does not give the board comfort that good customer outcomes are being achieved for the annual assessment. - Legacy books of business that have not been reviewed ahead of closed products coming into scope on 31 July 2024. #### Actions to take 1. Confirm that changes identified during the planning phase are underway and assess whether they go far enough to achieve good customer outcomes. 2. Identify the data needed to measure and monitor the delivery of outcomes, and ensure it is in a format that informs the board. 3. Review your approach to customer outcomes monitoring, fair value assessments and customer communications testing. 4. Prepare your legacy book of business for closed products and services coming into scope from 31 July 2024. 5. Consider an independent review or post-implementation audit of your Consumer Duty approach ahead of your annual assessment. #### Wider implications With the Consumer Duty now described by the regulator as a “golden thread” running through every supervisory conversation, firms should expect their annual assessment to form part of the evidence the FCA considers when judging their overall level of compliance. #### Recommendations Firms that are not comfortable with elements of their Duty stance should take rapid action, including appointing independent regulatory expertise to review their approach to embedding the Duty across the business. #### Supporting sources - [Delivering better customer outcomes under the Consumer Duty](https://tcc.group/blog/2023/11/08/delivering-better-outcomes/) (2023-11-08) #### Confident in your Consumer Duty embedding? TCC's subject matter experts can review your Consumer Duty implementation and help you prepare for your annual assessment. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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"@type": "Person", "name": "Kit Ruparel" }, "headline": "Delivering better customer outcomes under the Consumer Duty", "datePublished": "2023-11-08T00:00:00+01:00", "dateModified": "2026-09-02T03:47:38+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/regulatory-horizon/delivering-better-outcomes/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/a76a081878d9468e85c8afd98ef3eb12/thumbnail-1024-6b6dbd19d591ee8468226f3e26f32457c71ddbdee6c8ddbb70fe3e9854ffbc0b.jpg", "description": "A reminder from the FCA that the Consumer Duty is an ongoing commitment, not a one-off project, with closed products coming into scope from July 2024 and annual assessments under growing scrutiny.", "inLanguage": "en-GB", "articleBody": "A year on from firms first implementing their Consumer Duty plans, the FCA's Nisha Arora reminded firms that the Duty is not a \u2018once and done\u2019 exercise, with closed products due to come into scope from 31 July 2024.\n\nA year on from firms first building and scrutinising their Consumer Duty implementation plans, the FCA's Director of Cross Cutting Policy and Strategy, Nisha Arora, reminded regulated businesses that the Duty is not a \u201conce and done\u201d exercise. Firms are being asked to check that the changes identified during planning are now well underway, and whether those changes go far enough to achieve good customer outcomes.\n\nNisha Arora described the Consumer Duty as the \u201cgolden thread\u201d that will run through all conversations firms have with the regulator, with the FCA testing how firms have implemented and embedded the Duty across their full business life cycle. From 31 July 2024, the Duty will also apply to closed products and services, meaning firms need to ensure their legacy book of business aligns with it too.\n\nThe Duty needs to be applied across the whole organisation, from board level through to front-line delivery, including product design, communications and customer support. Senior managers need to assess whether consumers are genuinely at the heart of the business, and whether the firm's long-term strategy is consistent with delivering good customer outcomes.\n\nThe FCA's supervisory and enforcement approach will be \u201cproportionate to the harm, or risk of harm, to consumers\u201d, prioritising the most serious breaches and acting swiftly, driven in large part by the management information firms provide.\n\nAll regulated firms across wealth management, pensions, banking, lending, general insurance and protection, and motor finance are affected, particularly those with closed products or legacy books of business that will come into scope from July 2024.\n\n\u2022 Treating Consumer Duty implementation as a one-off exercise rather than an ongoing programme of assessment, testing and evidencing.\n\u2022 Insufficient detective and preventative controls where risks to good outcomes have already been identified.\n\u2022 Data and monitoring that does not give the board comfort that good customer outcomes are being achieved for the annual assessment.\n\u2022 Legacy books of business that have not been reviewed ahead of closed products coming into scope on 31 July 2024.\n\n1. Confirm that changes identified during the planning phase are underway and assess whether they go far enough to achieve good customer outcomes.\n2. Identify the data needed to measure and monitor the delivery of outcomes, and ensure it is in a format that informs the board.\n3. Review your approach to customer outcomes monitoring, fair value assessments and customer communications testing.\n4. Prepare your legacy book of business for closed products and services coming into scope from 31 July 2024.\n5. Consider an independent review or post-implementation audit of your Consumer Duty approach ahead of your annual assessment.\n\nWith the Consumer Duty now described by the regulator as a \u201cgolden thread\u201d running through every supervisory conversation, firms should expect their annual assessment to form part of the evidence the FCA considers when judging their overall level of compliance.\n\nFirms that are not comfortable with elements of their Duty stance should take rapid action, including appointing independent regulatory expertise to review their approach to embedding the Duty across the business.", "wordCount": 543, "keywords": [ "Compliance AI & RegTech", "Consumer Duty", "Banking", "General Insurance & Protection", "Lending & Consumer Credit", "Motor Finance", "Payments & FinTech", "Pensions & Retirement Income", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Consumer Duty", "url": "https://tcc.group/blog/solution/consumer-duty/" }, { "@type": "Thing", "name": "Banking", "url": "https://tcc.group/blog/sector/banking/" }, { "@type": "Thing", "name": "General Insurance & Protection", "url": "https://tcc.group/blog/sector/general-insurance-protection/" }, { "@type": "Thing", "name": "Lending & Consumer Credit", "url": "https://tcc.group/blog/sector/lending-consumer-credit/" }, { "@type": "Thing", "name": "Motor Finance", "url": "https://tcc.group/blog/sector/motor-finance/" }, { "@type": "Thing", "name": "Payments & FinTech", "url": "https://tcc.group/blog/sector/payments-fintech/" }, { "@type": "Thing", "name": "Pensions & Retirement Income", "url": "https://tcc.group/blog/sector/pensions-retirement-income/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Embedding the Consumer Duty" } ], "articleSection": [ "Compliance AI & RegTech", "Consumer Duty" ], "audience": [ { "@type": "Audience", "audienceType": "Banking" }, { "@type": "Audience", "audienceType": "General Insurance & Protection" }, { "@type": "Audience", "audienceType": "Lending & Consumer Credit" }, { "@type": "Audience", "audienceType": "Motor Finance" }, { "@type": "Audience", "audienceType": "Payments & FinTech" }, { "@type": "Audience", "audienceType": "Pensions & Retirement Income" }, { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Senior managers and compliance teams responsible for embedding and evidencing the Consumer Duty across their firm." } ], "citation": [ { "@type": "CreativeWork", "name": "Delivering better customer outcomes under the Consumer Duty", "url": "https://tcc.group/blog/2023/11/08/delivering-better-outcomes/", "datePublished": "2023-11-08" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/regulatory-horizon/delivering-better-outcomes/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/delivering-better-outcomes/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "Is the Consumer Duty a one-off implementation exercise?", "acceptedAnswer": { "@type": "Answer", "text": "No. The FCA's Nisha Arora has been clear that firms must continue assessing, testing, understanding and evidencing Duty outcomes on an ongoing basis." } }, { "@type": "Question", "name": "When do closed products come into scope of the Consumer Duty?", "acceptedAnswer": { "@type": "Answer", "text": "From 31 July 2024, the Consumer Duty will also apply to closed products and services, so legacy books of business need to align with it." } }, { "@type": "Question", "name": "What has the FCA said about its supervisory approach?", "acceptedAnswer": { "@type": "Answer", "text": "The FCA has said its supervisory and enforcement approach will be proportionate to the harm or risk of harm to consumers, prioritising the most serious breaches." } }, { "@type": "Question", "name": "What should firms do if they are unsure about their Duty compliance?", "acceptedAnswer": { "@type": "Answer", "text": "Appointing independent regulatory expertise to review the firm's approach to embedding the Duty can be a useful first step." } } ] } ] } ``` ### Collaborating to implement best Consumer Duty practice - URL: https://tcc.group/insights/press-releases/consumer-duty-alliance/ - Published: 2023-11-06 - Modified: 2026-09-02 **Topic:** Consumer Duty Alliance membership TCC has become an affiliate member of the Consumer Duty Alliance, a not-for-profit community that helps regulated firms understand, meet and deliver the FCA's Consumer Duty requirements. #### What happened? TCC has become a proud affiliate member of the Consumer Duty Alliance, a not-for-profit community interest company established to help regulated firms understand, meet and deliver the FCA's Consumer Duty requirements. The Alliance works with practitioners and subject matter experts, including TCC, to support the sharing of good practice across the sector as firms continue to explore how the Duty's four outcomes are implemented. TCC's team of industry practitioners and ex-regulators has been providing expertise to organisations applying the new standards since the Duty was announced as the long-term vision for financial services regulation. #### Why does it matter? The Consumer Duty was introduced to increase public confidence in financial services by placing the onus on firms to demonstrate that they have customers' best interests at heart. Joe Norburn, CEO at TCC, said the Alliance aims to elevate public trust in the finance sector by creating a collaborative network that shares and develops best industry practice, which TCC's subject matter experts are well placed to support. With so much criteria to evidence, maintaining and evidencing compliance requires considerable time, resource and budget, making external validation and advisory review a practical way to check that an approach is watertight. #### Who is affected? Regulated firms across banking, lending, wealth management, pensions, insurance, payments and motor finance that need to evidence their Consumer Duty approach are affected. #### Actions to take 1. Seek independent, external validation of your Consumer Duty approach. 2. Draw on practitioner and ex-regulator expertise to check your approach is watertight. #### Wider implications The Alliance reflects a broader industry move towards shared, sector-wide practice on the Consumer Duty rather than firms working through implementation in isolation. #### Supporting sources - [Collaborating to implement best Consumer Duty practice](https://tcc.group/blog/2023/11/07/consumer-duty-alliance/) (2023-11-07) #### Want independent assurance on Consumer Duty? Get in touch with TCC's experts today to see how we can help validate and strengthen your Consumer Duty compliance. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/press-releases/consumer-duty-alliance/#webpage", "url": "https://tcc.group/insights/press-releases/consumer-duty-alliance/", "name": "Collaborating to implement best Consumer Duty practice", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2023-11-07T00:00:00+01:00", "dateModified": "2026-09-02T03:47:35+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/press-releases/consumer-duty-alliance/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "NewsArticle", "@id": "https://tcc.group/insights/press-releases/consumer-duty-alliance/#article", "isPartOf": { "@id": "https://tcc.group/insights/press-releases/consumer-duty-alliance/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "Collaborating to implement best Consumer Duty practice", "datePublished": "2023-11-07T00:00:00+01:00", "dateModified": "2026-09-02T03:47:35+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/press-releases/consumer-duty-alliance/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/7f057786448c4d199c211df32afb47c9/thumbnail-1024-5d166e51debc5087f69ad34003b1e6254d5ea11886a9fefae5340fce5b02bac2.jpg", "description": "TCC has joined the Consumer Duty Alliance as an affiliate member, bringing practitioner and ex-regulator expertise to help firms validate their approach and share good practice across the sector.", "inLanguage": "en-GB", "articleBody": "TCC has become an affiliate member of the Consumer Duty Alliance, a not-for-profit community that helps regulated firms understand, meet and deliver the FCA's Consumer Duty requirements.\n\nTCC has become a proud affiliate member of the Consumer Duty Alliance, a not-for-profit community interest company established to help regulated firms understand, meet and deliver the FCA's Consumer Duty requirements.\n\nThe Alliance works with practitioners and subject matter experts, including TCC, to support the sharing of good practice across the sector as firms continue to explore how the Duty's four outcomes are implemented.\n\nTCC's team of industry practitioners and ex-regulators has been providing expertise to organisations applying the new standards since the Duty was announced as the long-term vision for financial services regulation.\n\nThe Consumer Duty was introduced to increase public confidence in financial services by placing the onus on firms to demonstrate that they have customers' best interests at heart.\n\nJoe Norburn, CEO at TCC, said the Alliance aims to elevate public trust in the finance sector by creating a collaborative network that shares and develops best industry practice, which TCC's subject matter experts are well placed to support.\n\nWith so much criteria 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In an article for Money Marketing, TCC’s Senior Regulatory Consultant Andy Fouracres discusses whether firms are still relying on pre-Consumer Duty assumptions when assessing fair value. TCC’s benchmarking study found that half of firms surveyed had no plans to change their fee model, with those firms confident their existing structure already meets the FCA’s expectations. #### Why does it matter? In the run-up to the Consumer Duty, the regulator called on firms to re-examine their charging structures to ensure compliance with the Price and Value outcome, yet the research suggests many firms are avoiding the difficult questions that exercise requires. Firms that assume their existing fee model is compliant without fresh evidence risk falling short of the FCA’s fair value requirements. #### Who is affected? Compliance and pricing teams at regulated firms reassessing whether their charging structures meet the Consumer Duty’s fair value requirements. #### Supporting sources - [Why firms need to be challenging themselves on price and value](https://tcc.group/blog/2023/09/26/why-firms-need-to-be-challenging-themselves-on-price-and-value/) (2023-09-26) #### Reviewed your fees since Consumer Duty? Talk to our advisory team about benchmarking your charging structure against the FCA’s fair value expectations. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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"https://tcc.group/insights/analysis-perspectives/why-firms-need-to-be-challenging-themselves-on-price-and-value/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What did TCC\u2019s benchmarking study find?", "acceptedAnswer": { "@type": "Answer", "text": "That half of firms surveyed had no plans to change their fee model, believing their existing charging structure already meets the FCA\u2019s expectations." } }, { "@type": "Question", "name": "Who wrote this piece?", "acceptedAnswer": { "@type": "Answer", "text": "TCC\u2019s Senior Regulatory Consultant Andy Fouracres, writing for Money Marketing." } }, { "@type": "Question", "name": "What Consumer Duty outcome does this relate to?", "acceptedAnswer": { "@type": "Answer", "text": "The Price and Value outcome, which requires firms to assess whether their charges are proportionate to the benefits provided." } } ] } ] } ``` ### Business Systems, TCC and Recordsure collaborate on - URL: https://tcc.group/insights/press-releases/business-systems-tcc-and-recordsure-join-forces-to-provide-comprehensive-expertise-and-guidance-on-new-consumer-duty-regulations/ - Published: 2023-08-15 - Modified: 2026-09-02 **Topic:** Consumer Duty advisory partnership Business Systems, TCC and Recordsure have joined forces to offer advisory services and ongoing support to help regulated firms meet the Consumer Duty. #### What happened? Business Systems, TCC and Recordsure have announced a collaboration to provide advisory services and ongoing support for firms addressing the Consumer Duty, which came into force on 31 July 2023. The partnership brings together Business Systems' compliance and customer experience solutions, TCC's financial services consultancy expertise and Recordsure's AI RegTech capability to offer tailored consultancy services covering regulatory gap analysis, policy and procedures, monitoring and reporting, and remediation and implementation. Joe Norburn, CEO at TCC and Recordsure, and Adam Kantor, CEO at Business Systems, both welcomed the collaboration as a way to help clients embrace the Consumer Duty and strengthen customer trust. #### Why does it matter? The Consumer Duty places significant responsibility on financial institutions to act in customers' best interests and to evidence fair treatment and improved outcomes, which many firms are still working to embed. By combining compliance expertise with established technology, the partnership aims to help firms move from gap identification through to ongoing monitoring, reporting and remediation, rather than treating the Duty as a one-off compliance project. #### Who is affected? The collaboration is aimed at regulated firms across banking, lending, wealth management, pensions, insurance, payments and motor finance that need to demonstrate Consumer Duty compliance to the FCA. #### Actions to take 1. Carry out a regulatory gap analysis against the Consumer Duty's requirements. 2. Develop policies and procedures covering products and services, price and value, consumer understanding and consumer support. 3. Establish reporting systems and insight dashboards to track progress and evidence outcomes to the regulator. 4. Review and implement remediation to ensure long-term compliance with the new rules. #### Wider implications The partnership reflects a wider trend of specialist compliance and technology providers combining expertise to help firms meet outcome-focused regulation rather than relying on a single adviser or system. #### Recommendations Firms should treat Consumer Duty compliance as an ongoing programme, using gap analysis to prioritise action, and monitoring and reporting to evidence outcomes over time rather than as a one-off exercise. #### Supporting sources - [Business Systems, TCC and Recordsure collaborate on](https://tcc.group/blog/2023/08/16/business-systems-tcc-and-recordsure-join-forces-to-provide-comprehensive-expertise-and-guidance-on-new-consumer-duty-regulations/) (2023-08-16) #### Need support with Consumer Duty compliance? Learn more about how TCC, Business Systems and Recordsure can support your Consumer Duty needs, from gap analysis to ongoing remediation. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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Published in May 2023, the FCA's Consumer Duty price and value assessment review examined the frameworks of 14 predominantly large financial businesses. The review highlighted areas that successfully aligned with the regulator's vision for the future, alongside key areas where firms were falling short. In Money Marketing, TCC Regulatory Consultant Juana Diaz-Landinez read between the lines of the FCA's feedback to uncover the overarching lessons firms should take on board. #### Why does it matter? The findings give firms outside the reviewed sample a clear indication of what the FCA expects a mature fair value assessment framework to look like, and where other firms have fallen short. Applying these lessons can help firms build a Consumer Duty strategy that stands up to regulatory scrutiny, rather than waiting to be picked for a future review. #### Supporting sources - [Three key themes from the FCA's Fair Value assessment review](https://tcc.group/blog/2023/07/21/three-key-themes-from-the-fcas-fair-value-assessment-review/) (2023-07-21) #### Reviewing your fair value assessments? Speak to our team about strengthening your Consumer Duty price and value framework. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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"citation": [ { "@type": "CreativeWork", "name": "Three key themes from the FCA's Fair Value assessment review", "url": "https://tcc.group/blog/2023/07/21/three-key-themes-from-the-fcas-fair-value-assessment-review/", "datePublished": "2023-07-21" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/analysis-perspectives/three-key-themes-from-the-fcas-fair-value-assessment-review/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/three-key-themes-from-the-fcas-fair-value-assessment-review/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What did the FCA's Fair Value assessment review examine?", "acceptedAnswer": { "@type": "Answer", "text": "It examined the price and value assessment frameworks of 14, predominantly large, financial businesses, published in May 2023." } }, { "@type": "Question", "name": "What did the review find?", "acceptedAnswer": { "@type": "Answer", "text": "It found areas where firms' frameworks aligned well with the FCA's expectations, and other areas where firms fell short." } }, { "@type": "Question", "name": "Who wrote about the review's lessons for firms?", "acceptedAnswer": { "@type": "Answer", "text": "TCC's Regulatory Consultant Juana Diaz-Landinez, in an article for Money Marketing." } } ] } ] } ``` ### Home and motor insurers must do more to support struggling customers, FCA warns - URL: https://tcc.group/insights/analysis-perspectives/home-and-motor-insurers-must-do-more-to-support-struggling-customers-fca-warns/ - Published: 2023-07-09 - Modified: 2026-09-02 **Topic:** General Insurance Claims The FCA has warned home and motor insurers to improve their claims handling and support for vulnerable customers, particularly regarding vehicle write-offs and unfair settlement valuations. #### What happened? The Financial Conduct Authority (FCA) has issued a stern warning to home and motor insurers following a significant rise in complaints about claims handling quality. The regulator highlighted specific concerns around customers receiving unfair settlements below market value for written-off vehicles. Following an FCA investigation, Direct Line Group was ordered to review five years of total loss claims to identify and compensate affected policyholders. The regulator has made it clear that similar swift enforcement action will be taken against other firms failing to meet expected standards. #### Why does it matter? This warning highlights that the FCA is actively monitoring after-sales support under the Consumer Duty, demanding that post-sale customer experiences are as seamless as pre-sale interactions. Underestimating claims valuations or delaying settlements represents a direct breach of the duty's customer support and fair value outcomes. Firms are expected to demonstrate that their products perform as consumers reasonably expect. Failing to do so not only invites regulatory intervention but also indicates underlying deficiencies in product governance and target market design. #### Who is affected? This regulatory focus directly impacts UK home and motor insurers, claims management teams, and product manufacturers. Firms offering motor finance and ancillary insurance products must also review their total loss settlement processes and vulnerable customer safeguards. #### Key risks - **Undervalued Settlements:** Offering customers total loss payouts below the fair market value of their vehicles, leading to redress exercises and fines. - **Poor Vulnerability Identification:** Inadequate systems to predict or react to customers experiencing temporary or permanent financial vulnerability. - **Friction in After-Sales Support:** Maintaining claims processes that are slow or difficult to navigate, failing the Consumer Duty support standards. #### Actions to take 1. **Conduct a Claims Review:** Audit total loss settlements and write-off valuations from recent years to ensure they align with fair market value. 2. **Strengthen Vulnerability Controls:** Optimize management information and customer interaction oversight to identify and support customers facing financial difficulty. 3. **Map Customer Journeys:** Review after-sales support to verify it is as frictionless and responsive as pre-sales processes. #### Wider implications This intervention signals a broader shift towards data-led, proactive enforcement by the FCA during the cost-of-living crisis. The regulator is increasingly willing to order retroactive reviews and redress programs for systemic claims-handling failures. #### Recommendations Insurers must ensure their Key Risk Indicators (KRIs) are set up to detect if claimants fail to understand core policy terms. Product governance frameworks should also be refreshed to verify that product performance continually aligns with consumer expectations. #### Supporting sources - [Home and motor insurers must do more to support struggling customers, FCA warns](https://tcc.group/blog/2023/07/10/home-and-motor-insurers-must-do-more-to-support-struggling-customers-fca-warns/) (2023-07-10) #### Are your insurance claims processes Consumer Duty compliant? Speak to our general insurance specialists to review your claims handling controls, valuation methodologies, and customer support frameworks. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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FCA warns", "item": "https://tcc.group/insights/analysis-perspectives/home-and-motor-insurers-must-do-more-to-support-struggling-customers-fca-warns/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/analysis-perspectives/home-and-motor-insurers-must-do-more-to-support-struggling-customers-fca-warns/#webpage", "url": "https://tcc.group/insights/analysis-perspectives/home-and-motor-insurers-must-do-more-to-support-struggling-customers-fca-warns/", "name": "Home and motor insurers must do more to support struggling customers, FCA warns", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2023-07-10T00:00:00+01:00", "dateModified": "2026-09-02T03:47:49+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/analysis-perspectives/home-and-motor-insurers-must-do-more-to-support-struggling-customers-fca-warns/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", 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"https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/959c75df8a83472983a44bcb09857172/thumbnail-1024-acc3091f62726122d99958e7df845c0064037221f07a0f59e9d300e823bd9284.jpg", "description": "Understand how the FCA's latest warning on motor and home insurance claims handling affects your firm, and learn how to align product design, claims settlements, and vulnerable customer support with Consumer Duty expectations.", "inLanguage": "en-GB", "articleBody": "The FCA has warned home and motor insurers to improve their claims handling and support for vulnerable customers, particularly regarding vehicle write-offs and unfair settlement valuations.\n\nThe Financial Conduct Authority (FCA) has issued a stern warning to home and motor insurers following a significant rise in complaints about claims handling quality. The regulator highlighted specific concerns around customers receiving unfair settlements below market value for written-off vehicles.\n\nFollowing an FCA investigation, Direct Line Group was ordered to review five years of total loss claims to identify and compensate affected policyholders. The regulator has made it clear that similar swift enforcement action will be taken against other firms failing to meet expected standards.\n\nThis warning highlights that the FCA is actively monitoring after-sales support under the Consumer Duty, demanding that post-sale customer experiences are as seamless as pre-sale interactions. Underestimating claims valuations or delaying settlements represents a direct breach of the duty's customer support and fair value outcomes.\n\nFirms are expected to demonstrate that their products perform as consumers reasonably expect. Failing to do so not only invites regulatory intervention but also indicates underlying deficiencies in product governance and target market design.\n\nThis regulatory focus directly impacts UK home and motor insurers, claims management teams, and product manufacturers. Firms offering motor finance and ancillary insurance products must also review their total loss settlement processes and vulnerable customer safeguards.\n\n\u2022 Undervalued Settlements: Offering customers total loss payouts below the fair market value of their vehicles, leading to redress exercises and fines.\n\u2022 Poor Vulnerability Identification: Inadequate systems to predict or react to customers experiencing temporary or permanent financial vulnerability.\n\u2022 Friction in After-Sales Support: Maintaining claims processes that are slow or difficult to navigate, failing the Consumer Duty support standards.\n\n1. Conduct a Claims Review: Audit total loss settlements and write-off valuations from recent years to ensure they align with fair market value.\n2. Strengthen Vulnerability Controls: Optimize management information and customer interaction oversight to identify and support customers facing financial difficulty.\n3. Map Customer Journeys: Review after-sales support to verify it is as frictionless and responsive as pre-sales processes.\n\nThis intervention signals a broader shift towards data-led, proactive enforcement by the FCA during the cost-of-living crisis. The regulator is increasingly willing to order retroactive reviews and redress programs for systemic claims-handling failures.\n\nInsurers must ensure their Key Risk Indicators (KRIs) are set up to detect if claimants fail to understand core policy terms. 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Building on the priorities outlined in its Strategy 2022-2025, the FCA's latest Business Plan reiterated its commitment to improving customer outcomes, pledging a host of new, more stringent requirements for regulated firms over the coming financial year. In Money Marketing, TCC Senior Regulatory Consultant Andy Fouracres examined the top three areas these standard-raising initiatives are set to focus on. #### Why does it matter? Firms that understand where the FCA's attention is heading can take proactive steps to meet new obligations ahead of time, rather than reacting once requirements are already in force. #### Supporting sources - [Three need-to-know regulatory changes on the FCA's agenda](https://tcc.group/blog/2023/05/31/three-need-to-know-regulatory-changes-on-the-fcas-agenda/) (2023-05-31) #### Getting ahead of the FCA's agenda? Talk to our team about preparing for the FCA's incoming regulatory priorities. 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Business Plan, plus the proactive steps firms can take to meet the incoming obligations.", "inLanguage": "en-GB", "articleBody": "Building on its Strategy 2022-2025, the FCA's latest Business Plan set out more stringent requirements for regulated firms; TCC's Andy Fouracres examines the top three areas set to be targeted and how firms can prepare.\n\nBuilding on the priorities outlined in its Strategy 2022-2025, the FCA's latest Business Plan reiterated its commitment to improving customer outcomes, pledging a host of new, more stringent requirements for regulated firms over the coming financial year.\n\nIn Money Marketing, TCC Senior Regulatory Consultant Andy Fouracres examined the top three areas these standard-raising initiatives are set to focus on.\n\nFirms that understand where the FCA's attention is heading can take proactive steps to meet new obligations ahead of time, rather than reacting once requirements are already in force.", "wordCount": 123, "keywords": [ "Compliance AI & RegTech", "Consumer Duty", "Regulatory Change & Transformation", "Banking", "General Insurance & Protection", "Lending & Consumer Credit", "Payments & FinTech", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Consumer Duty", "url": "https://tcc.group/blog/solution/consumer-duty/" }, { "@type": "Thing", "name": "Regulatory Change & Transformation", "url": "https://tcc.group/blog/solution/regulatory-change-transformation/" }, { "@type": "Thing", "name": "Banking", "url": "https://tcc.group/blog/sector/banking/" }, { "@type": "Thing", "name": "General Insurance & Protection", "url": "https://tcc.group/blog/sector/general-insurance-protection/" }, { "@type": "Thing", "name": "Lending & Consumer Credit", "url": "https://tcc.group/blog/sector/lending-consumer-credit/" }, { "@type": "Thing", "name": "Payments & FinTech", "url": 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lending, wherever the FCA's standard-raising initiatives apply." } }, { "@type": "Question", "name": "How can firms prepare?", "acceptedAnswer": { "@type": "Answer", "text": "By identifying where the FCA's Business Plan priorities fall within their business and taking proactive steps ahead of the new requirements coming into force." } } ] } ] } ``` ### Consumer Duty: Four key lessons from the FCA's Fair Value - URL: https://tcc.group/insights/regulatory-horizon/consumer-duty-four-key-lessons-from-the-fcas-fair-value-frameworks-review/ - Published: 2023-05-23 - Modified: 2026-09-02 **Topic:** Fair Value assessments The FCA's thematic review of Fair Value assessments ahead of the Consumer Duty's 31 July launch found firms relying too heavily on assertions, benchmarking and average outcomes rather than firm evidence. #### What happened? The FCA published findings from a thematic review exploring how firms across retail banking, payments and consumer investments were approaching their Fair Value assessments ahead of the Consumer Duty's launch on 31 July. The review assessed whether firms' internal processes matched the regulator's vision for the new price and value requirements. The FCA found some frameworks relied on high-level assertions of fair value without evidence to support them, reflecting a 'show me, don't tell me' expectation that many firms had not yet grasped. It also flagged concerns about the use of generic templates that were not tailored to the specific product or service being assessed. #### Why does it matter? Fair value cannot be assessed against a single checklist: it depends on the nature of the product, its target market and the whole customer journey, not just price. The review found firms need to look beyond fees to non-financial elements such as customer support after the point of sale, since poor post-sale service can undermine value even where pricing looks competitive. The FCA also expects value assessments to consider differential outcomes for different customer segments rather than relying on averages, while confirming that its rules do not require firms to charge every customer the same amount or make the same profit from each one. #### Who is affected? The review's findings are relevant across wealth management and financial advice, pensions and retirement income, payments and fintech, banking, consumer credit and lending, general insurance and protection, and motor finance. #### Key risks - Fair value assessments built on assertion rather than evidence - Over-reliance on generic templates not tailored to the product being assessed - Assessing value on price alone, without considering the whole customer journey - Using average outcomes instead of assessing different customer segments - Gaps in the data and data-gathering methods needed to monitor fair value on an ongoing basis #### Actions to take 1. Check whether value assessments cover all the areas the FCA would expect 2. Assess all products and services, not just a sample, against fair value requirements 3. Identify concrete steps to address any areas found to be falling short 4. Build processes that consistently evidence that all clients are receiving value 5. Prioritise review effort on products and services with the greatest potential for customer harm #### Wider implications The review also found firms had not always considered the impact of cross-subsidies on fair value, and that data gaps around metrics such as profit margins, claims ratios and defaults were making it harder for some firms, particularly in markets like fund management, to evidence value consistently. With so many data points potentially relevant, firms need to decide in advance which data and tools they will use, rather than treating this as a one-off exercise for the implementation deadline. #### Recommendations Firms should be transparent about their reasoning, able to answer why they charge what they charge and how it provides value, and should embrace a collaborative approach with other firms in the distribution chain to gather the information needed to assess value. An impartial, expert second opinion can help identify gaps before the regulator does. #### Supporting sources - [Consumer Duty: Four key lessons from the FCA‚Äôs Fair Value](https://tcc.group/blog/2023/05/24/consumer-duty-four-key-lessons-from-the-fcas-fair-value-frameworks-review/) (2023-05-24) #### Need support with Price and Value requirements? TCC's experts can offer an honest, detailed review of your Consumer Duty strategy. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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assessments, covering evidencing standards, whole-package value, differential outcomes and the data firms need to support their charging decisions.", "inLanguage": "en-GB", "articleBody": "The FCA's thematic review of Fair Value assessments ahead of the Consumer Duty's 31 July launch found firms relying too heavily on assertions, benchmarking and average outcomes rather than firm evidence.\n\nThe FCA published findings from a thematic review exploring how firms across retail banking, payments and consumer investments were approaching their Fair Value assessments ahead of the Consumer Duty's launch on 31 July. The review assessed whether firms' internal processes matched the regulator's vision for the new price and value requirements.\n\nThe FCA found some frameworks relied on high-level assertions of fair value without evidence to support them, reflecting a 'show me, don't tell me' expectation that many firms had not yet grasped. It also flagged concerns about the use of generic templates that were not tailored to the specific product or service being assessed.\n\nFair value cannot be assessed against a single checklist: it depends on the nature of the product, its target market and the whole customer journey, not just price. The review found firms need to look beyond fees to non-financial elements such as customer support after the point of sale, since poor post-sale service can undermine value even where pricing looks competitive.\n\nThe FCA also expects value assessments to consider differential outcomes for different customer segments rather than relying on averages, while confirming that its rules do not require firms to charge every customer the same amount or make the same profit from each one.\n\nThe review's findings are relevant across wealth management and financial advice, pensions and retirement income, payments and fintech, banking, consumer credit and lending, general insurance and protection, and motor finance.\n\n\u2022 Fair value assessments built on assertion rather than evidence\n\u2022 Over-reliance on generic templates not tailored to the product being assessed\n\u2022 Assessing value on price alone, without considering the whole customer journey\n\u2022 Using average outcomes instead of assessing different customer segments\n\u2022 Gaps in the data and data-gathering methods needed to monitor fair value on an ongoing basis\n\n1. 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TCC has joined the SME Climate Hub community and signed the SME Climate Commitment, pledging to take action to lower its environmental impact, including halving its emissions by 2030 in line with the United Nations' Race to Zero campaign. The SME Climate Hub is a non-profit global organisation that supports small and medium-sized businesses in taking steps to reduce their environmental impact, manage resources more efficiently and work towards net zero. The initiative was originally developed through a collaboration between the We Mean Business Coalition, the Exponential Roadmap Initiative and the Race to Zero campaign, with support from Normative and the Net Zero team at Oxford University. TCC is also a member of the UK's Business Climate Leaders campaign. #### Why does it matter? The commitment sets a public benchmark, halving emissions by 2030, against which TCC's own environmental progress can be tracked. For clients and partners considering supplier due diligence that includes environmental criteria, this provides a reference point for TCC's stated sustainability commitments. #### Who is affected? The announcement is most relevant to clients, partners and prospective employees who factor environmental and sustainability commitments into their assessment of suppliers or employers. #### Actions to take 1. Continue working towards the 2030 target of halving emissions. 2. Share annual progress updates on environmental performance, as committed to under the initiative. #### Wider implications The commitment reflects a broader trend of professional and financial services firms adopting externally recognised climate frameworks, rather than making standalone environmental claims, providing a consistent basis for comparison across organisations. #### Recommendations Firms considering their own environmental commitments may wish to review established frameworks such as the SME Climate Hub, which provide a recognised structure for setting and reporting emissions targets rather than developing bespoke commitments in isolation. #### Supporting sources - [TCC Joins SME Climate Hub to Reduce Emissions](https://tcc.group/blog/2023/05/03/tcc-joins-sme-climate-hub-initiative/) (2023-05-03) #### Want to know more about our sustainability commitments? Contact our team to find out more about TCC's approach to sustainability. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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"https://tcc.group/insights/regulatory-horizon/tcc-joins-sme-climate-hub-initiative/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/regulatory-horizon/tcc-joins-sme-climate-hub-initiative/#webpage", "url": "https://tcc.group/insights/regulatory-horizon/tcc-joins-sme-climate-hub-initiative/", "name": "TCC Joins SME Climate Hub to Reduce Emissions", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2023-05-03T00:00:00+01:00", "dateModified": "2023-05-03T00:00:00+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/regulatory-horizon/tcc-joins-sme-climate-hub-initiative/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "NewsArticle", "@id": "https://tcc.group/insights/regulatory-horizon/tcc-joins-sme-climate-hub-initiative/#article", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/tcc-joins-sme-climate-hub-initiative/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "TCC Joins SME Climate Hub to Reduce Emissions", "datePublished": "2023-05-03T00:00:00+01:00", "dateModified": "2023-05-03T00:00:00+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/regulatory-horizon/tcc-joins-sme-climate-hub-initiative/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/6aaaba49e5ff435697ea22b23bf88787/thumbnail-1024-21004ffe8f8ba9a7faff34ad8e923eddb4dafa81d638f965f2266262662b0774.jpg", "description": "TCC has joined the SME Climate Hub and signed the SME Climate Commitment, pledging to halve its emissions by 2030 in line with the United Nations' Race to Zero campaign.", "inLanguage": "en-GB", "articleBody": "TCC has joined the SME Climate Hub and signed the SME Climate Commitment, pledging to halve its emissions by 2030 in line with the United Nations' Race to Zero campaign.\n\nTCC has joined the SME Climate Hub community and signed the SME Climate Commitment, pledging to take action to lower its environmental impact, including halving its emissions by 2030 in line with the United Nations' Race to Zero campaign.\n\nThe SME Climate Hub is a non-profit global organisation that supports small and medium-sized businesses in taking steps to reduce their environmental impact, manage resources more efficiently and work towards net zero. The initiative was originally developed through a collaboration between the We Mean Business Coalition, the Exponential Roadmap Initiative and the Race to Zero campaign, with support from Normative and the Net Zero team at Oxford University.\n\nTCC is also a member of the UK's Business Climate Leaders campaign.\n\nThe commitment sets a public benchmark, halving emissions by 2030, against which TCC's own environmental progress can be tracked. For clients and partners considering supplier due diligence that includes environmental criteria, this provides a reference point for TCC's stated sustainability commitments.\n\nThe announcement is most relevant to clients, partners and prospective employees who factor environmental and sustainability commitments into their assessment of suppliers or employers.\n\n1. Continue working towards the 2030 target of halving emissions.\n2. 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The British Steel Pensions Scheme (BSPS) redress scheme has commenced, giving affected advisory firms until February 2024 to review pension transfer advice, complete complex redress calculations, and issue compensation payments to clients. Writing in Money Marketing, TCC's Actuarial and Redress Director Harry Eastwood discusses the challenges firms face under this compressed timeline and shares a practical three-point plan to ensure compliance without compromising accuracy. #### Why does it matter? Resolving BSPS redress claims is highly sensitive and complex. Under the FCA's strict supervision, advisory firms must calculate redress with extreme precision to avoid further compliance breaches, while scaling their operational capacity to meet the statutory deadlines. #### Supporting sources - [How to Approach British Steel Pensions Scheme Redress](https://tcc.group/blog/2023/03/23/how-firms-should-approach-british-steel-pensions-redress/) (2023-03-23) #### Need support with British Steel pensions redress? Speak to our specialist resourcing and actuarial team to help you deliver accurate, timely, and compliant BSPS redress calculations and case reviews. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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TCC and its sister company Recordsure have jointly been presented with the RegTech Innovation award at the 2023 FinTech Breakthrough Awards. The award is one of five prizes given under the programme’s RegTech category and recognises businesses judged to have pushed the boundaries of regulatory technology through disruptive, tech-enabled solutions over the preceding year. The judging panel assessed entrants against criteria including degree of innovation, performance, ease of use, functionality, value and overall impact. TCC and Recordsure Group CEO Joe Norburn described the joint award as recognition of the “collaborative efforts of both companies” for a second year running. The win follows previous recognition for the group, including the Best RegTech Company award (jointly with Recordsure) in 2022 and as a standalone business in 2021, making this the third consecutive year TCC has been recognised at the ceremony. #### Why does it matter? The award reflects TCC’s *Intelligent Compliance* approach, which combines the hands-on compliance knowledge of its consultants, former regulators and industry practitioners with Recordsure’s ReviewAI RegTech suite. For firms evaluating compliance partners, third-party recognition of this kind offers an independent reference point when comparing providers that combine advisory expertise with technology. Consistent recognition over three years also signals a degree of continuity in the underlying approach, which regulated firms may find relevant when assessing the stability of a long-term compliance or RegTech relationship. #### Who is affected? The announcement is most relevant to compliance, risk and technology functions at regulated financial services firms that are reviewing how they combine human expertise with automated monitoring and analytics tools. #### Wider implications The FinTech Breakthrough Awards, established in 2016, have grown alongside the wider adoption of digital channels and RegTech across financial services, a trend the source material links to the acceleration of digital transformation following the pandemic. Recognition in this category reflects a broader industry shift towards combining consultancy expertise with AI-powered analytics rather than treating the two as separate disciplines. #### Recommendations Firms selecting or reviewing a RegTech partner may wish to consider how a provider combines subject-matter expertise with technology, rather than assessing either element in isolation, and to ask providers for independent evidence of innovation and outcomes rather than relying on marketing claims alone. #### Supporting sources - [TCC Wins RegTech Innovation Award at FinTech Breakthrough](https://tcc.group/blog/2023/03/23/tcc-and-recordsure-awarded-regtech-innovation-fintech-breakthrough-awards/) (2023-03-23) #### Reviewing your RegTech and compliance partnerships? Speak to our team about how combining consultancy expertise with RegTech can support your compliance objectives. 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"https://tcc.group/insights/regulatory-horizon/tcc-and-recordsure-awarded-regtech-innovation-fintech-breakthrough-awards/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/regulatory-horizon/tcc-and-recordsure-awarded-regtech-innovation-fintech-breakthrough-awards/#webpage", "url": "https://tcc.group/insights/regulatory-horizon/tcc-and-recordsure-awarded-regtech-innovation-fintech-breakthrough-awards/", "name": "TCC Wins RegTech Innovation Award at FinTech Breakthrough", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2023-03-23T00:00:00+01:00", "dateModified": "2023-03-23T00:00:00+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/regulatory-horizon/tcc-and-recordsure-awarded-regtech-innovation-fintech-breakthrough-awards/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "NewsArticle", "@id": "https://tcc.group/insights/regulatory-horizon/tcc-and-recordsure-awarded-regtech-innovation-fintech-breakthrough-awards/#article", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/tcc-and-recordsure-awarded-regtech-innovation-fintech-breakthrough-awards/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "TCC Wins RegTech Innovation Award at FinTech Breakthrough", "datePublished": "2023-03-23T00:00:00+01:00", "dateModified": "2023-03-23T00:00:00+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/regulatory-horizon/tcc-and-recordsure-awarded-regtech-innovation-fintech-breakthrough-awards/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/dba93aefa77945ce9805e6f088beb479/thumbnail-1024-6d276911adaed51dfd07f65e74873c2f733e3c2e7a691a5e821af12dccb31edb.jpg", "description": "TCC and sister company Recordsure have won the RegTech Innovation award at the 2023 FinTech Breakthrough Awards, the group's third consecutive year of recognition for combining compliance expertise with regulatory technology.", "inLanguage": "en-GB", "articleBody": "TCC and Recordsure have jointly won the RegTech Innovation award at the 2023 FinTech Breakthrough Awards, marking a third consecutive year of recognition for the group.\n\nTCC and its sister company Recordsure have jointly been presented with the RegTech Innovation award at the 2023 FinTech Breakthrough Awards. The award is one of five prizes given under the programme\u2019s RegTech category and recognises businesses judged to have pushed the boundaries of regulatory technology through disruptive, tech-enabled solutions over the preceding year.\n\nThe judging panel assessed entrants against criteria including degree of innovation, performance, ease of use, functionality, value and overall impact. TCC and Recordsure Group CEO Joe Norburn described the joint award as recognition of the \u201ccollaborative efforts of both companies\u201d for a second year running.\n\nThe win follows previous recognition for the group, including the Best RegTech Company award (jointly with Recordsure) in 2022 and as a standalone business in 2021, making this the third consecutive year TCC has been recognised at the ceremony.\n\nThe award reflects TCC\u2019s Intelligent Compliance approach, which combines the hands-on compliance knowledge of its consultants, former regulators and industry practitioners with Recordsure\u2019s ReviewAI RegTech suite. For firms evaluating compliance partners, third-party recognition of this kind offers an independent reference point when comparing providers that combine advisory expertise with technology.\n\nConsistent recognition over three years also signals a degree of continuity in the underlying approach, which regulated firms may find relevant when assessing the stability of a long-term compliance or RegTech relationship.\n\nThe announcement is most relevant to compliance, risk and technology functions at regulated financial services firms that are reviewing how they combine human expertise with automated monitoring and analytics tools.\n\nThe FinTech Breakthrough Awards, established in 2016, have grown alongside the wider adoption of digital channels and RegTech across financial services, a trend the source material links to the acceleration of digital transformation following the pandemic. Recognition in this category reflects a broader industry shift towards combining consultancy expertise with AI-powered analytics rather than treating the two as separate disciplines.\n\nFirms selecting or reviewing a RegTech partner may wish to consider how a provider combines subject-matter expertise with technology, rather than assessing either element in isolation, and to ask providers for independent evidence of innovation and outcomes rather than relying on marketing claims alone.", "wordCount": 380, "keywords": [ "Compliance AI & RegTech", "Payments & FinTech" ], "about": [ { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Payments & FinTech", "url": "https://tcc.group/blog/sector/payments-fintech/" }, { "@type": "Thing", "name": "RegTech Industry Recognition" } ], "articleSection": [ "Compliance AI & RegTech" ], "audience": [ { "@type": "Audience", "audienceType": "Payments & FinTech" }, { "@type": "Audience", "audienceType": "Compliance and technology leaders assessing RegTech providers and partnership models." } ], "citation": [ { "@type": "CreativeWork", "name": "TCC Wins RegTech Innovation Award at FinTech Breakthrough", "url": "https://tcc.group/blog/2023/03/23/tcc-and-recordsure-awarded-regtech-innovation-fintech-breakthrough-awards/", "datePublished": "2023-03-23" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/regulatory-horizon/tcc-and-recordsure-awarded-regtech-innovation-fintech-breakthrough-awards/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/tcc-and-recordsure-awarded-regtech-innovation-fintech-breakthrough-awards/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What award did TCC and Recordsure win?", "acceptedAnswer": { "@type": "Answer", "text": "TCC and Recordsure jointly won the RegTech Innovation award at the 2023 FinTech Breakthrough Awards." } }, { "@type": "Question", "name": "Is this the first time TCC has been recognised at the awards?", "acceptedAnswer": { "@type": "Answer", "text": "No. TCC previously won the Best RegTech Company award jointly with Recordsure in 2022, and as a standalone business in 2021, making 2023 its third consecutive year of recognition." } }, { "@type": "Question", "name": "What did the judging panel assess?", "acceptedAnswer": { "@type": "Answer", "text": "The panel assessed entrants on degree of innovation, performance, ease of use, functionality, value and overall impact." } } ] } ] } ``` ### How to prepare for the Consumer Duty's Price and Value outcome - URL: https://tcc.group/insights/regulatory-horizon/prepare-for-price-and-value-outcome/ - Published: 2023-03-12 - Modified: 2026-09-02 **Topic:** Consumer Duty Price and Value With the Consumer Duty coming into force in July 2023, this article sets out how firms should approach value assessments under the price and value outcome, including benchmarking charges and evidencing fair value for different client segments. #### What happened? With the Consumer Duty's implementation date of July 2023 approaching, this article sets out the FCA's expectations under the price and value outcome and what distribution firms need to do to prepare. A value assessment should start with calculating the cost of a service, from initial design through to ongoing reviews, and should include non-financial costs such as additional staff needed to service clients. Firms are also expected to benchmark their charges against peers, not to match them, but to understand how they compare. The FCA has taken a "show me, don't tell me" approach, meaning firms need to demonstrate a reasonable relationship between the price charged and profitability, and be ready to explain why they charge what they charge. #### Why does it matter? Higher charges do not automatically mean poor value, and lower charges do not automatically mean fair value. What matters is whether a firm can evidence the cost of its service and demonstrate the value it provides, including for percentage-based charging models where clients with larger portfolios may pay more. Firms with tiered service levels, such as gold, silver and bronze options, need to understand the cost of each tier and evidence that value is delivered at every level, linking this back to the value assessment. #### Who is affected? Distribution firms, including wealth management and financial advice firms, that set their own charges or operate within a wider distribution chain involving product manufacturers and platforms. #### Key risks - Being unable to evidence how the cost of a service was calculated, including non-financial costs. - Percentage-based charging models that are not justified by additional work or services provided. - Failing to assess the cumulative impact of charges across the distribution chain, including platform costs. - Value assessments that are not ready to submit to the FCA on request. #### Actions to take 1. Calculate the full cost of each service, including design, ongoing review and non-financial costs such as additional staffing. 2. Benchmark charges against peers to understand relative positioning, without assuming charges must match. 3. Evidence why any percentage-based or tiered charging structure delivers proportionate value at each level. 4. Assess the cumulative impact of charges across the distribution chain, including platforms and manufacturer products. 5. Prepare a value assessment for every service offered, ready to share with the FCA if requested. #### Wider implications Distribution firms are not required to carry out value assessments on manufacturers' products, but they do need to obtain enough information from manufacturers to understand the value those products provide, and factor this into their own assessment of the full distribution chain. #### Recommendations Firms should ask themselves whether their value assessments cover everything the FCA would expect, whether every service has been assessed, and how they can demonstrate that all clients receive value. Firms unsure of the answers should seek independent assurance ahead of implementation. #### Supporting sources - [How to prepare for the Consumer Duty's Price and Value outcome](https://tcc.group/blog/2023/03/13/prepare-for-price-and-value-outcome/) (2023-03-13) #### Need help with your value assessments? Speak to one of our experts about preparing your firm's price and value assessments ahead of the Consumer Duty. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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"https://tcc.group/insights/regulatory-horizon/prepare-for-price-and-value-outcome/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "How to prepare for the Consumer Duty’s Price and Value outcome", "datePublished": "2023-03-13T00:00:00+01:00", "dateModified": "2026-09-02T03:47:59+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/regulatory-horizon/prepare-for-price-and-value-outcome/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/cf4a6c044e2d452caf74811e8adb9a28/thumbnail-1024-568e59b2a2d93e98ac7dd612e82794e71e372d8b34cab46fd357de5a117528d9.jpg", "description": "As the Consumer Duty's July 2023 deadline approaches, this article explains how to conduct value assessments, benchmark charges and evidence fair value across different client segments and distribution arrangements.", "inLanguage": "en-GB", "articleBody": "With the Consumer Duty coming into force in July 2023, this article sets out how firms should approach value assessments under the price and value outcome, including benchmarking charges and evidencing fair value for different client segments.\n\nWith the Consumer Duty's implementation date of July 2023 approaching, this article sets out the FCA's expectations under the price and value outcome and what distribution firms need to do to prepare.\n\nA value assessment should start with calculating the cost of a service, from initial design through to ongoing reviews, and should include non-financial costs such as additional staff needed to service clients. Firms are also expected to benchmark their charges against peers, not to match them, but to understand how they compare.\n\nThe FCA has taken a \"show me, don't tell me\" approach, meaning firms need to demonstrate a reasonable relationship between the price charged and profitability, and be ready to explain why they charge what they charge.\n\nHigher charges do not automatically mean poor value, and lower charges do not automatically mean fair value. What matters is whether a firm can evidence the cost of its service and demonstrate the value it provides, including for percentage-based charging models where clients with larger portfolios may pay more.\n\nFirms with tiered service levels, such as gold, silver and bronze options, need to understand the cost of each tier and evidence that value is delivered at every level, linking this back to the value assessment.\n\nDistribution firms, including wealth management and financial advice firms, that set their own charges or operate within a wider distribution chain involving product manufacturers and platforms.\n\n\u2022 Being unable to evidence how the cost of a service was calculated, including non-financial costs.\n\u2022 Percentage-based charging models that are not justified by additional work or services provided.\n\u2022 Failing to assess the cumulative impact of charges across the distribution chain, including platform costs.\n\u2022 Value assessments that are not ready to submit to the FCA on request.\n\n1. Calculate the full cost of each service, including design, ongoing review and non-financial costs such as additional staffing.\n2. Benchmark charges against peers to understand relative positioning, without assuming charges must match.\n3. Evidence why any percentage-based or tiered charging structure delivers proportionate value at each level.\n4. Assess the cumulative impact of charges across the distribution chain, including platforms and manufacturer products.\n5. Prepare a value assessment for every service offered, ready to share with the FCA if requested.\n\nDistribution firms are not required to carry out value assessments on manufacturers' products, but they do need to obtain enough information from manufacturers to understand the value those products provide, and factor this into their own assessment of the full distribution chain.\n\nFirms should ask themselves whether their value assessments cover everything the FCA would expect, whether every service has been assessed, and how they can demonstrate that all clients receive value. Firms unsure of the answers should seek independent assurance ahead of implementation.", "wordCount": 493, "keywords": [ "Compliance AI & RegTech", "Consumer Duty", "Banking", "General Insurance & Protection", "Lending & Consumer Credit", "Motor Finance", "Payments & FinTech", "Pensions & Retirement Income", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Consumer Duty", "url": "https://tcc.group/blog/solution/consumer-duty/" }, { "@type": "Thing", "name": "Banking", "url": "https://tcc.group/blog/sector/banking/" }, { "@type": "Thing", "name": "General Insurance & Protection", "url": "https://tcc.group/blog/sector/general-insurance-protection/" }, { "@type": "Thing", "name": "Lending & Consumer Credit", "url": "https://tcc.group/blog/sector/lending-consumer-credit/" }, { "@type": "Thing", "name": "Motor Finance", "url": "https://tcc.group/blog/sector/motor-finance/" }, { "@type": "Thing", "name": "Payments & FinTech", "url": "https://tcc.group/blog/sector/payments-fintech/" }, { "@type": "Thing", "name": "Pensions & Retirement Income", "url": "https://tcc.group/blog/sector/pensions-retirement-income/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Consumer Duty Price and Value" } ], "articleSection": [ "Compliance AI & RegTech", "Consumer Duty" ], "audience": [ { "@type": "Audience", "audienceType": "Banking" }, { "@type": "Audience", "audienceType": "General Insurance & Protection" }, { "@type": "Audience", "audienceType": "Lending & Consumer Credit" }, { "@type": "Audience", "audienceType": "Motor Finance" }, { "@type": "Audience", "audienceType": "Payments & FinTech" }, { "@type": "Audience", "audienceType": "Pensions & Retirement Income" }, { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Compliance and distribution teams at financial services firms responsible for pricing, value assessments and the Consumer Duty implementation." } ], "citation": [ { "@type": "CreativeWork", "name": "How to prepare for the Consumer Duty's Price and Value outcome", "url": "https://tcc.group/blog/2023/03/13/prepare-for-price-and-value-outcome/", "datePublished": "2023-03-13" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/regulatory-horizon/prepare-for-price-and-value-outcome/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/prepare-for-price-and-value-outcome/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "Is there a set methodology for a value assessment?", "acceptedAnswer": { "@type": "Answer", "text": "No, there is no prescribed methodology, but firms should start by calculating the full cost of the service, including non-financial costs, before comparing this to the value received by clients." } }, { "@type": "Question", "name": "Do all clients need to pay the same charges?", "acceptedAnswer": { "@type": "Answer", "text": "No, charges do not need to be identical for every client, but firms must be able to demonstrate that all clients are receiving fair value for what they pay." } }, { "@type": "Question", "name": "Do distribution firms need to assess manufacturers' products?", "acceptedAnswer": { "@type": "Answer", "text": "Distribution firms do not need to carry out value assessments on manufacturers' products, but they should obtain enough information from manufacturers to understand the value those products provide." } }, { "@type": "Question", "name": "What questions should firms ask themselves before the deadline?", "acceptedAnswer": { "@type": "Answer", "text": "Firms should check whether their value assessments cover everything the FCA expects, whether every service has been assessed, and how they can evidence that all clients receive value." } } ] } ] } ``` ### Your four-point plan for successful British Steel pensions redress - URL: https://tcc.group/insights/regulatory-horizon/four-point-plan-british-steel-pension-redresssion/ - Published: 2023-03-01 - Modified: 2026-09-02 **Topic:** British Steel Redress TCC's Technical Director David Boyhan provides a strategic four-point plan for pension firms to navigate the strict 12-month BSPS redress timetable. #### What happened? The Financial Conduct Authority has launched its formal redress scheme for the British Steel Pension Scheme (BSPS), following research showing that 47% of advice given was unsuitable. This mis-selling affects approximately 1,100 consumers, with average payouts estimated at £45,000 per customer, representing a total sector liability of around £49 million. Implicated firms face a compressed 12-month timeline to contact affected customers, perform complete suitability reviews, calculate appropriate redress, and issue final payments. #### Why does it matter? The regulator is watching advice firms closely, leaving zero margin for error. DB Transfer cases are highly complex and specialized, requiring expert reviewers to determine suitability. Additionally, firms must handle complex data-gathering issues, such as tracking British Steel funds that have been merged with other plans or transferred across multiple schemes. Firms are also strictly forbidden from issuing unsolicited, unauthorized settlement offers to clients. Any attempts to resolve cases outside the sanctioned scheme rules will attract immediate regulatory intervention. #### Who is affected? This redress scheme directly impacts financial advice firms, compliance auditors, and specialized pension advisers with historic BSPS cases in their back books. #### Key risks - **Missing Tight Deadlines:** Failing to meet strict milestones for client contact, case reviews, and compensation calculations within the 12-month window. - **Inaccurate Suitability Reviews:** Using under-qualified staff to review complex DB Transfer cases, leading to incorrect redress assessments. - **Unsanctioned Settlements:** Attempting to settle claims directly with consumers, resulting in severe disciplinary action from the FCA. #### Actions to take 1. **Begin Back-Book Reviews:** Immediately start reviewing all historic BSPS cases in your back book; do not wait for the regulator to prompt you. 2. **Gather Data Early:** Retrieve and consolidate transfer data, including tracking funds that have been combined or moved to other providers. 3. **Cooperate with the Scheme:** Follow the official FCA calculator and guidance, ensuring FOS-escalated cases are managed in parallel. 4. **Enlist DB Specialists:** Secure experienced, independent DB transfer reviewers to ensure accuracy and meet tight deadlines. #### Wider implications The BSPS redress scheme underscores the FCA's long-term determination to protect savers and penalize systemic advice failures. It serves as a stark warning on suitability standards for the entire pensions industry. #### Recommendations Outsource your review project or augment your internal compliance teams with qualified contractors to ensure complete technical accuracy and timely delivery. #### Supporting sources - [Your four-point plan for successful British Steel pensions redress](https://tcc.group/blog/2023/03/02/four-point-plan-british-steel-pension-redresssion/) (2023-03-02) #### Do you need expert help with British Steel redress reviews? Secure highly skilled, independent DB transfer specialists to manage your BSPS reviews accurately and within regulatory deadlines. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/insights/regulatory-horizon/four-point-plan-british-steel-pension-redresssion/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Insights", "item": "https://tcc.group/insights/" }, { "@type": "ListItem", "position": 3, "name": "Your four-point plan for successful British Steel pensions redress", "item": "https://tcc.group/insights/regulatory-horizon/four-point-plan-british-steel-pension-redresssion/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/regulatory-horizon/four-point-plan-british-steel-pension-redresssion/#webpage", "url": "https://tcc.group/insights/regulatory-horizon/four-point-plan-british-steel-pension-redresssion/", "name": "Your four-point plan for successful British Steel pensions redress", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2023-03-02T00:00:00+01:00", "dateModified": "2026-09-02T03:47:46+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/regulatory-horizon/four-point-plan-british-steel-pension-redresssion/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "NewsArticle", "@id": "https://tcc.group/insights/regulatory-horizon/four-point-plan-british-steel-pension-redresssion/#article", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/four-point-plan-british-steel-pension-redresssion/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "Your four-point plan for successful British Steel pensions redress", "datePublished": "2023-03-02T00:00:00+01:00", "dateModified": "2026-09-02T03:47:46+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/regulatory-horizon/four-point-plan-british-steel-pension-redresssion/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/89c3d000f0ec4bd381ebda9b357c53c3/thumbnail-1024-dd17446a2791b8954d2ad783660d63af16d95206ed217f3f860b14088f27cc92.jpg", "description": "With the British Steel Pension Scheme (BSPS) redress programme underway, firms face strict deadlines and high financial stakes. Discover a crucial four-point plan to execute reviews, gather data, and manage FOS claims.", "inLanguage": "en-GB", "articleBody": "TCC's Technical Director David Boyhan provides a strategic four-point plan for pension firms to navigate the strict 12-month BSPS redress timetable.\n\nThe Financial Conduct Authority has launched its formal redress scheme for the British Steel Pension Scheme (BSPS), following research showing that 47% of advice given was unsuitable. This mis-selling affects approximately 1,100 consumers, with average payouts estimated at \u00a345,000 per customer, representing a total sector liability of around \u00a349 million.\n\nImplicated firms face a compressed 12-month timeline to contact affected customers, perform complete suitability reviews, calculate appropriate redress, and issue final payments.\n\nThe regulator is watching advice firms closely, leaving zero margin for error. DB Transfer cases are highly complex and specialized, requiring expert reviewers to determine suitability. Additionally, firms must handle complex data-gathering issues, such as tracking British Steel funds that have been merged with other plans or transferred across multiple schemes.\n\nFirms are also strictly forbidden from issuing unsolicited, unauthorized settlement offers to clients. Any attempts to resolve cases outside the sanctioned scheme rules will attract immediate regulatory intervention.\n\nThis redress scheme directly impacts financial advice firms, compliance auditors, and specialized pension advisers with historic BSPS cases in their back books.\n\n\u2022 Missing Tight Deadlines: Failing to meet strict milestones for client contact, case reviews, and compensation calculations within the 12-month window.\n\u2022 Inaccurate Suitability Reviews: Using under-qualified staff to review complex DB Transfer cases, leading to incorrect redress assessments.\n\u2022 Unsanctioned Settlements: Attempting to settle claims directly with consumers, resulting in severe disciplinary action from the FCA.\n\n1. Begin Back-Book Reviews: Immediately start reviewing all historic BSPS cases in your back book; do not wait for the regulator to prompt you.\n2. 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It serves as a stark warning on suitability standards for the entire pensions industry.\n\nOutsource your review project or augment your internal compliance teams with qualified contractors to ensure complete technical accuracy and timely delivery.", "wordCount": 384, "keywords": [ "Consumer Duty", "Banking", "General Insurance & Protection", "Lending & Consumer Credit", "Motor Finance", "Payments & FinTech", "Pensions & Retirement Income", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Consumer Duty", "url": "https://tcc.group/blog/solution/consumer-duty/" }, { "@type": "Thing", "name": "Banking", "url": "https://tcc.group/blog/sector/banking/" }, { "@type": "Thing", "name": "General Insurance & Protection", "url": "https://tcc.group/blog/sector/general-insurance-protection/" }, { "@type": "Thing", "name": "Lending & Consumer Credit", "url": "https://tcc.group/blog/sector/lending-consumer-credit/" }, { "@type": "Thing", "name": "Motor Finance", "url": "https://tcc.group/blog/sector/motor-finance/" }, { "@type": "Thing", "name": "Payments & FinTech", "url": "https://tcc.group/blog/sector/payments-fintech/" }, { "@type": "Thing", "name": "Pensions & Retirement Income", "url": "https://tcc.group/blog/sector/pensions-retirement-income/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "British Steel Redress" } ], "articleSection": [ "Consumer Duty" ], "audience": [ { "@type": "Audience", "audienceType": "Banking" }, { "@type": "Audience", "audienceType": "General Insurance & Protection" }, { "@type": "Audience", "audienceType": "Lending & Consumer Credit" }, { "@type": "Audience", "audienceType": "Motor Finance" }, { "@type": "Audience", "audienceType": "Payments & FinTech" }, { "@type": "Audience", "audienceType": "Pensions & Retirement Income" }, { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Pension advisers, compliance managers, and directors of wealth management firms." } ], "citation": [ { "@type": "CreativeWork", "name": "Your four-point plan for successful British Steel pensions redress", "url": "https://tcc.group/blog/2023/03/02/four-point-plan-british-steel-pension-redresssion/", "datePublished": "2023-03-02" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/regulatory-horizon/four-point-plan-british-steel-pension-redresssion/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/four-point-plan-british-steel-pension-redresssion/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What is the average payout under the BSPS redress scheme?", "acceptedAnswer": { "@type": "Answer", "text": "The average compensation payout is estimated at \u00a345,000 per affected customer, representing an industry-wide redress total of \u00a349 million." } }, { "@type": "Question", "name": "Can firms make independent settlement offers to affected clients?", "acceptedAnswer": { "@type": "Answer", "text": "No. The FCA has strictly reiterated that firms must not, under any circumstances, approach consumers with unsolicited, unsanctioned settlement offers." } }, { "@type": "Question", "name": "What are the key deadlines in the BSPS redress schedule?", "acceptedAnswer": { "@type": "Answer", "text": "Firms had from 28th February to 28th March 2023 to contact customers. Case reviews must be completed by 30th September 2023, and calculations must be submitted by 31st December 2023." } } ] } ] } ``` ### Retirement income in the regulator’s spotlight - URL: https://tcc.group/insights/analysis-perspectives/retirement-income-in-the-regulators-spotlight/ - Published: 2023-02-28 - Modified: 2026-09-02 **Topic:** Retirement Income Suitability TCC's David Boyhan explains, in Money Marketing, why the FCA views retirement income as a regulatory priority and what advisers can do to ensure clients receive suitable recommendations. #### What happened? The FCA views retirement income as a regulatory priority, warning that unsuitable recommendations can cause significant and irreversible harm to the financial wellbeing of retired individuals. Writing in Money Marketing, TCC's Technical Director David Boyhan explores what advisers can do to ensure clients receive the right level of care when making decisions about their retirement income. #### Why does it matter? Retirement income decisions are often irreversible, so firms that cannot demonstrate suitable advice in this area are exposed to both regulatory attention and the risk of lasting harm to clients. #### Supporting sources - [Retirement income in the regulator’s spotlight](https://tcc.group/blog/2023/03/01/retirement-income-in-the-regulators-spotlight/) (2023-03-01) #### Confident your retirement income advice is suitable? Get in touch to discuss how we can help you assess the suitability of your retirement income advice. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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"isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/retirement-income-in-the-regulators-spotlight/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "Retirement income in the regulator\u2019s spotlight", "datePublished": "2023-03-01T00:00:00+01:00", "dateModified": "2026-09-02T03:48:02+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/analysis-perspectives/retirement-income-in-the-regulators-spotlight/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": null, "description": "David Boyhan of TCC explains why the FCA treats retirement income as a regulatory priority, and sets out what advisers can do to ensure clients receive the right level of care.", "inLanguage": "en-GB", "articleBody": "TCC's David Boyhan explains, in Money Marketing, why the FCA views retirement income as a regulatory priority and what advisers can do to ensure clients receive suitable recommendations.\n\nThe FCA views 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"Question", "name": "Who wrote this analysis?", "acceptedAnswer": { "@type": "Answer", "text": "TCC's Technical Director, David Boyhan, writing in Money Marketing." } } ] } ] } ``` ### Rethinking vulnerability for the Consumer Duty era - URL: https://tcc.group/insights/analysis-perspectives/rethinking-vulnerability-for-the-consumer-duty-era/ - Published: 2022-12-04 - Modified: 2026-09-02 **Topic:** Vulnerability Under Consumer Duty TCC's Garry Evans explains, in Money Marketing, how the Consumer Duty raises the bar for identifying and managing customer vulnerability, and offers guidance for a more proactive safeguarding approach. #### What happened? The Consumer Duty raises the standard for customer protection across financial services, placing greater emphasis than before on firms' need to identify and manage vulnerability among their customers on an ongoing basis. Writing in Money Marketing, TCC Group's Chief Product Officer Garry Evans examines how this higher standard requires firms to take a more proactive approach to vulnerability, and offers guidance on building a safeguarding strategy that can adapt over time. #### Why does it matter? Firms that treat vulnerability as a one-off assessment, rather than an ongoing part of customer management, are unlikely to meet the standard the Consumer Duty sets, and may struggle to evidence that vulnerable customers are receiving good outcomes. #### Supporting sources - [Rethinking vulnerability for the Consumer Duty era](https://tcc.group/blog/2022/12/05/rethinking-vulnerability-for-the-consumer-duty-era/) (2022-12-05) #### Reviewing your approach to vulnerable customers? Contact us to discuss how we can help you build a safeguarding strategy that meets the standard set by the Consumer Duty. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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### Webinar Recap: Understanding the Consumer Duty’s outcomes - URL: https://tcc.group/insights/regulatory-horizon/webinar-consumer-duty-good-outcomes/ - Published: 2022-11-27 - Modified: 2026-09-02 **Topic:** Consumer Duty supervision TCC's webinar recap explains how the FCA will supervise the Consumer Duty through existing oversight activity rather than dedicated audits. It also sets out why firms should treat 31 July 2023 as a starting point rather than a deadline to simply survive. #### What happened? TCC hosted a webinar with Recordsure, featuring Ex-FCA supervisor Olivia Fahy alongside guest speakers, exploring why the Consumer Duty goes well beyond the existing Treating Customers Fairly (TCF) regime. The panel summarised the FCA’s expectations into three key preparations: aligning compliance activity with deliverability, understanding the regulator’s more interventionist supervisory style, and building a workable data strategy. The FCA confirmed it has already asked several firms to present their Implementation Plans for scrutiny, signalling that progress will be actively monitored in the run-up to the July 2023 deadline. #### Why does it matter? Firms often draw comparisons between the Consumer Duty and TCF, but the panel was clear these are fundamentally different regimes in both structure and enforcement. The Consumer Duty combines a consumer principle, cross-cutting rules and four outcomes, and the FCA has said non-compliance will carry stringent penalties, from interventionist powers and fines to Section 166 investigations. Rather than a single dedicated audit, compliance checks will be woven into the regulator’s existing supervision, meaning every touchpoint with the FCA now has the potential to inform Consumer Duty assessment. #### Who is affected? Larger ‘fixed’ firms should expect their named supervisors to gather outcomes information as part of routine oversight, while smaller firms are more likely to be picked up through issue-focused, multi-firm checks. Any firm authorised or seeking authorisation needs a workable data strategy, since the FCA expects data usage to be built into how compliance is evidenced from the outset. #### Key risks - Being unable to evidence outcomes when asked, given there is no single Consumer Duty test to prepare for. - Underestimating the reputational and financial impact of supervisory enforcement or Section 166 investigations. - Treating the 31 July 2023 deadline as an end point rather than an ongoing obligation. #### Actions to take 1. Make all colleagues aware of the process and policy changes required before July 2023. 2. Task working groups with detailing what, when and how changes will be implemented. 3. Build a data strategy that supports vulnerability monitoring, conduct risk and customer outcomes evidencing. #### Wider implications The panel suggested the Consumer Duty is partly a response to criticism that the FCA has not always been proactive enough, repositioning the regulator as more interventionist. That shift means firms should expect scrutiny to continue well beyond the initial deadline, with the regulator maintaining pressure through ordinary supervisory activity rather than a fixed audit cycle. #### Recommendations Treat 31 July 2023 as a starting point for cultural change rather than a compliance finish line, and keep working groups active on implementation detail beyond that date. Prioritise the data capabilities needed to monitor vulnerability, conduct risk and customer outcomes, since this underpins how the FCA expects firms to evidence the Duty. #### Supporting sources - [Webinar Recap: Understanding the Consumer Duty‚Äôs outcomes](https://tcc.group/blog/2022/11/28/webinar-consumer-duty-good-outcomes/) (2022-11-28) #### Ready to strengthen your Consumer Duty evidence? Talk to our team about building the data and oversight needed to evidence good outcomes. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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explains how the FCA will supervise the Consumer Duty through existing oversight activity rather than dedicated audits. It also sets out why firms should treat 31 July 2023 as a starting point rather than a deadline to simply survive.\n\nTCC hosted a webinar with Recordsure, featuring Ex-FCA supervisor Olivia Fahy alongside guest speakers, exploring why the Consumer Duty goes well beyond the existing Treating Customers Fairly (TCF) regime.\n\nThe panel summarised the FCA\u2019s expectations into three key preparations: aligning compliance activity with deliverability, understanding the regulator\u2019s more interventionist supervisory style, and building a workable data strategy.\n\nThe FCA confirmed it has already asked several firms to present their Implementation Plans for scrutiny, signalling that progress will be actively monitored in the run-up to the July 2023 deadline.\n\nFirms often draw comparisons between the Consumer Duty and TCF, but the panel was clear these are fundamentally different regimes in both structure and enforcement.\n\nThe Consumer Duty combines a consumer principle, cross-cutting rules and four outcomes, and the FCA has said non-compliance will carry stringent penalties, from interventionist powers and fines to Section 166 investigations.\n\nRather than a single dedicated audit, compliance checks will be woven into the regulator\u2019s existing supervision, meaning every touchpoint with the FCA now has the potential to inform Consumer Duty assessment.\n\nLarger \u2018fixed\u2019 firms should expect their named supervisors to gather outcomes information as part of routine oversight, while smaller firms are more likely to be picked up through issue-focused, multi-firm checks.\n\nAny firm authorised or seeking authorisation needs a workable data strategy, since the FCA expects data usage to be built into how compliance is evidenced from the outset.\n\n\u2022 Being unable to evidence outcomes when asked, given there is no single Consumer Duty test to prepare for.\n\u2022 Underestimating the reputational and financial impact of supervisory enforcement or Section 166 investigations.\n\u2022 Treating the 31 July 2023 deadline as an end point rather than an ongoing obligation.\n\n1. 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- URL: https://tcc.group/insights/analysis-perspectives/consumer-duty-compliance-how-should-firms-approach-the-four-outcomes/ - Published: 2022-10-18 - Modified: 2026-09-02 **Topic:** Consumer Duty Four Outcomes With the deadline for Consumer Duty Implementation Plans imminent, TCC's Neil Dethick examined what each of the Four Outcomes should achieve for customers in an article for Money Marketing. #### What happened? With the deadline for Consumer Duty Implementation Plans less than two weeks away, TCC's Associate Director Neil Dethick wrote in Money Marketing about what each of the Consumer Duty's Four Outcomes is meant to achieve for customers, and offered actionable tips for devising a compliance strategy that satisfies the regulator's requirements. #### Why does it matter? Firms should be stress-testing their approach to ensure they are putting customers' needs first across the entire business lifecycle, rather than treating the Four Outcomes as a checklist exercise. #### Supporting sources - [Consumer Duty compliance: how should firms approach the Four Outcomes?](https://tcc.group/blog/2022/10/19/consumer-duty-compliance-how-should-firms-approach-the-four-outcomes/) (2022-10-19) #### Reviewing your Consumer Duty approach? TCC can help you stress-test your strategy against the Four Outcomes. 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"https://tcc.group/insights/analysis-perspectives/consumer-duty-compliance-how-should-firms-approach-the-four-outcomes/#article", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/consumer-duty-compliance-how-should-firms-approach-the-four-outcomes/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "Consumer Duty compliance: how should firms approach the Four Outcomes?", "datePublished": "2022-10-19T00:00:00+01:00", "dateModified": "2026-09-02T03:47:35+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/analysis-perspectives/consumer-duty-compliance-how-should-firms-approach-the-four-outcomes/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/901793bf37d14937a6254d63e94dc870/thumbnail-1024-b9a2511471568b3eb55254f97e3309281d112f306694193cf4e7a2b73d2d6fbe.jpg", "description": "A concise steer on what each of the Consumer Duty's Four Outcomes is meant to achieve for customers, with practical pointers for building a compliance strategy the regulator will accept.", "inLanguage": "en-GB", "articleBody": "With the deadline for Consumer Duty Implementation Plans imminent, TCC's Neil Dethick examined what each of the Four Outcomes should achieve for customers in an article for Money Marketing.\n\nWith the deadline for Consumer Duty Implementation Plans less than two weeks away, TCC's Associate Director Neil Dethick wrote in Money Marketing about what each of the Consumer Duty's Four Outcomes is meant to achieve for customers, and offered actionable tips for devising a compliance strategy that satisfies the regulator's requirements.\n\nFirms should be stress-testing their approach to ensure they are putting customers' needs first across the entire business lifecycle, rather than treating the Four Outcomes as a checklist exercise.", "wordCount": 109, "keywords": [ "Compliance AI & RegTech", "Consumer Duty", "Regulatory 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"https://tcc.group/insights/analysis-perspectives/consumer-duty-compliance-how-should-firms-approach-the-four-outcomes/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/consumer-duty-compliance-how-should-firms-approach-the-four-outcomes/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What are the Consumer Duty's Four Outcomes?", "acceptedAnswer": { "@type": "Answer", "text": "They cover products and services, price and value, consumer understanding and consumer support." } }, { "@type": "Question", "name": "Who wrote the original Money Marketing article?", "acceptedAnswer": { "@type": "Answer", "text": "TCC's Associate Director, Neil Dethick." } } ] } ] } ``` ### Spotlight on the FCA's Consumer Support Outcome 4 - URL: https://tcc.group/insights/regulatory-horizon/consumer-support-duty-outcome-4/ - Published: 2022-10-18 - Modified: 2026-09-02 **Topic:** Consumer support outcome Following FCA comments on becoming a more outcome-based regulator, TCC Associate Director Neil Dethick considers the consumer support outcome to conclude an outcome-by-outcome insight series. #### What happened? Speaking at the CISI/Financial Planning Conference 2022, the FCA's Chief Operating Officer and Executive Director, Emily Sheppard, described the regulator as moving towards becoming a more innovative, assertive and adaptive organisation driven by outcomes. TCC Associate Director Neil Dethick used this as the starting point to consider the consumer support outcome, the fourth and final outcome in TCC's Consumer Duty deep-dive series. Support must be available throughout the customer journey, whether by phone, email, in-branch or webchat. The FCA does not prescribe which channels firms should use, but expects firms to demonstrate that they provide effective support for customers' needs. #### Why does it matter? Neil explains that firms need to consider two key points when deciding what support to offer: first, that the channels available meet the needs of the customer, and second, that where a product is designed for a specific market, firms are explicit about which support channels are available and whether they suit everyone. The FCA cites a poor practice example of a customer unable to read braille or large print who continued to receive paper communications despite requesting email. Customer needs can also change over time, for example following a change in financial circumstances that affects how a customer can access support. Where this happens, the FCA expects firms to adapt their support accordingly, including helping the customer exit the product if appropriate. #### Who is affected? This applies across wealth management and financial advice, pensions and retirement income, payments and fintech, banking, consumer credit and lending, general insurance and protection, and motor finance, wherever firms provide ongoing support to customers. #### Key risks - Support channels that do not meet the needs of customers with specific requirements - Failing to make reasonable adjustments for disabled customers under the Equality Act 2010 - Not adapting support when a customer's circumstances change, such as losing mobile access - Insufficient support for customers struggling with payments during the cost-of-living crisis #### Recommendations The FCA wrote to 3,500 lenders reminding them of the standards expected to support customers through the cost-of-living crisis, and indicated it will build on these standards under the Consumer Duty. Sheldon Mills, the FCA's Executive Director of Consumers and Competition, said the regulator expects all firms to get the basics right and provide good quality support, with early action for those struggling with debt. #### Supporting sources - [Spotlight on the FCA's Consumer Support Outcome 4](https://tcc.group/blog/2022/10/19/consumer-support-duty-outcome-4/) (2022-10-19) #### Reviewing your consumer support arrangements? TCC can help you assess whether your support offering meets FCA expectations under the Consumer Duty. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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regulator, TCC Associate Director Neil Dethick considers the consumer support outcome to conclude an outcome-by-outcome insight series.\n\nSpeaking at the CISI/Financial Planning Conference 2022, the FCA's Chief Operating Officer and Executive Director, Emily Sheppard, described the regulator as moving towards becoming a more innovative, assertive and adaptive organisation driven by outcomes. TCC Associate Director Neil Dethick used this as the starting point to consider the consumer support outcome, the fourth and final outcome in TCC's Consumer Duty deep-dive series.\n\nSupport must be available throughout the customer journey, whether by phone, email, in-branch or webchat. The FCA does not prescribe which channels firms should use, but expects firms to demonstrate that they provide effective support for customers' needs.\n\nNeil explains that firms need to consider two key points when deciding what support to offer: first, that the channels available meet the needs of the customer, and second, that where a product is designed for a specific market, firms are explicit about which support channels are available and whether they suit everyone. 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TCC's Associate Director Neil Dethick set out three practical considerations for firms addressing the Consumer Duty's consumer understanding outcome, following comments from the FCA's Nick McGruer, Head for Advisers, Wealth and Pensions, that independent financial advisers would shortly receive a “Dear CEO” letter on delivering good advice. The outcome requires firms to give retail customers the information they need, when they need it, in a format they can understand, whether communications are delivered verbally, online or in print. Neil highlighted that the FCA's own Duty rules cite research showing one in seven adults have literacy skills at or below those expected of a nine to eleven-year-old, a benchmark firms designing mass-market products need to keep in view. He also pointed to testing as the practical route to compliance: firms should review and continually refine communications, asking whether each one is genuinely relatable, and apply the same rigour to consumer-understanding testing as they do to testing designed to maximise sales. #### Why does it matter? Consumer understanding sits at the centre of the Consumer Duty's requirement that firms act to deliver good outcomes for retail customers. Communications that use complicated contractual language, or that are not tested against the audience they are aimed at, create an unnecessary barrier to customers making informed decisions. Neil Dethick noted that the FCA expects firms to apply the same standard of rigour to consumer-understanding testing as they already apply when testing communications designed to drive sales, closing a gap that has historically favoured commercial outcomes over customer comprehension. #### Who is affected? The outcome applies to every retail-facing firm across wealth management, pensions, banking, lending, general insurance and protection, and motor finance, wherever verbal, online or printed communications are used with retail customers. It is particularly relevant to firms serving mass-market audiences, where the FCA expects literacy levels to be taken into account, and to those supporting customers with characteristics of vulnerability, including older customers less comfortable with digital channels and more anxious customers who may prefer digital tools to phone conversations. #### Key risks - Communications that assume a level of literacy or financial understanding higher than a significant proportion of the target audience actually has. - Contractual or product language that is technically accurate but creates an unnecessary barrier to understanding. - Applying less rigorous testing to consumer-understanding communications than to sales and marketing communications. - Using a single communication channel that does not suit the vulnerability profile or preferences of the target market. #### Actions to take 1. Map the communication channels used across the customer journey and check they suit the target market's likely vulnerability characteristics. 2. Review printed, verbal and digital communications for language, format and length, considering the FCA's literacy benchmark. 3. Test communications with representative customers, asking directly whether the content is relatable and actionable. 4. Apply the same testing standard to consumer-understanding communications as to sales and revenue-focused communications. 5. Build ongoing review of communications into business-as-usual monitoring rather than treating testing as a one-off exercise. #### Wider implications The consumer understanding outcome cannot be evidenced through policy alone; the FCA has made clear it expects firms to test communications in practice and demonstrate the results. Firms that have historically prioritised testing for commercial effectiveness will need to extend that same discipline to customer-facing content. Vulnerability characteristics also change over time, so firms need a mechanism for keeping pace with a customer's circumstances rather than assessing vulnerability once at onboarding. #### Recommendations Firms should prioritise testing of communications used with mass-market products and with customers known to have characteristics of vulnerability, since these are the areas the FCA is most likely to scrutinise. Building a documented testing and review cycle, with clear ownership at board level, will help firms evidence that the consumer understanding outcome is being met on an ongoing basis rather than assumed. #### Supporting sources - [FCA Outcome 3: Consumer understanding](https://tcc.group/blog/2022/10/11/consumer-understanding-duty-outcome-3/) (2022-10-11) #### Need help testing your customer communications? TCC's regulatory experts can help you review, test and evidence your customer communications against the Consumer Duty's consumer understanding outcome. 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"https://tcc.group/insights/regulatory-horizon/consumer-understanding-duty-outcome-3/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "FCA Outcome 3: Consumer understanding", "datePublished": "2022-10-11T00:00:00+01:00", "dateModified": "2026-09-02T03:47:37+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/regulatory-horizon/consumer-understanding-duty-outcome-3/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/84c3541cc53e41619a8f3b58a79ba0e4/thumbnail-1024-182704351d0c53485e77a4ba50410f0145ec2862599422d6a75399e7ce94a06c.jpg", "description": "Practical guidance on the Consumer Duty's consumer understanding outcome, covering clear communication, testing and support for vulnerable customers, drawn from TCC's Associate Director Neil Dethick.", "inLanguage": "en-GB", "articleBody": "TCC's Associate Director Neil Dethick sets out three practical considerations for the Consumer Duty's consumer understanding outcome: clear communication, testing, and support for vulnerable customers.\n\nTCC's Associate Director Neil Dethick set out three practical considerations for firms addressing the Consumer Duty's consumer understanding outcome, following comments from the FCA's Nick McGruer, Head for Advisers, Wealth and Pensions, that independent financial advisers would shortly receive a \u201cDear CEO\u201d letter on delivering good advice.\n\nThe outcome requires firms to give retail customers the information they need, when they need it, in a format they can understand, whether communications are delivered verbally, online or in print. Neil highlighted that the FCA's own Duty rules cite research showing one in seven adults have literacy skills at or below those expected of a nine to eleven-year-old, a benchmark firms designing mass-market products need to keep in view.\n\nHe also pointed to testing as the practical route to compliance: firms should review and continually refine communications, asking whether each one is genuinely relatable, and apply the same rigour to consumer-understanding testing as they do to testing designed to maximise sales.\n\nConsumer understanding sits at the centre of the Consumer Duty's requirement that firms act to deliver good outcomes for retail customers. Communications that use complicated contractual language, or that are not tested against the audience they are aimed at, create an unnecessary barrier to customers making informed decisions.\n\nNeil Dethick noted that the FCA expects firms to apply the same standard of rigour to consumer-understanding testing as they already apply when testing communications designed to drive sales, closing a gap that has historically favoured commercial outcomes over customer comprehension.\n\nThe outcome applies to every retail-facing firm across wealth management, pensions, banking, lending, general insurance and protection, and motor finance, wherever verbal, online or printed communications are used with retail customers.\n\nIt is particularly relevant to firms serving mass-market audiences, where the FCA expects literacy levels to be taken into account, and to those supporting customers with characteristics of vulnerability, including older customers less comfortable with digital channels and more anxious customers who may prefer digital tools to phone conversations.\n\n\u2022 Communications that assume a level of literacy or financial understanding higher than a significant proportion of the target audience actually has.\n\u2022 Contractual or product language that is technically accurate but creates an unnecessary barrier to understanding.\n\u2022 Applying less rigorous testing to consumer-understanding communications than to sales and marketing communications.\n\u2022 Using a single communication channel that does not suit the vulnerability profile or preferences of the target market.\n\n1. Map the communication channels used across the customer journey and check they suit the target market's likely vulnerability characteristics.\n2. Review printed, verbal and digital communications for language, format and length, considering the FCA's literacy benchmark.\n3. Test communications with representative customers, asking directly whether the content is relatable and actionable.\n4. Apply the same testing standard to consumer-understanding communications as to sales and revenue-focused communications.\n5. Build ongoing review of communications into business-as-usual monitoring rather than treating testing as a one-off exercise.\n\nThe consumer understanding outcome cannot be evidenced through policy alone; the FCA has made clear it expects firms to test communications in practice and demonstrate the results. Firms that have historically prioritised testing for commercial effectiveness will need to extend that same discipline to customer-facing content.\n\nVulnerability characteristics also change over time, so firms need a mechanism for keeping pace with a customer's circumstances rather than assessing vulnerability once at onboarding.\n\nFirms should prioritise testing of communications used with mass-market products and with customers known to have characteristics of vulnerability, since these are the areas the FCA is most likely to scrutinise.\n\nBuilding a documented testing and review cycle, with clear ownership at board level, will help firms evidence that the consumer understanding outcome is being met on an ongoing basis rather than assumed.", "wordCount": 642, "keywords": [ "Compliance AI & RegTech", "Regulatory Change & Transformation", "Banking", "General Insurance & Protection", "Lending & Consumer Credit", "Motor Finance", "Payments & FinTech", "Pensions & Retirement Income", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Regulatory Change & Transformation", "url": "https://tcc.group/blog/solution/regulatory-change-transformation/" }, { "@type": "Thing", "name": "Banking", "url": "https://tcc.group/blog/sector/banking/" }, { "@type": "Thing", "name": "General Insurance & Protection", "url": "https://tcc.group/blog/sector/general-insurance-protection/" }, { "@type": "Thing", "name": "Lending & Consumer Credit", "url": "https://tcc.group/blog/sector/lending-consumer-credit/" }, { "@type": "Thing", "name": "Motor Finance", "url": "https://tcc.group/blog/sector/motor-finance/" }, { "@type": "Thing", "name": "Payments & FinTech", "url": "https://tcc.group/blog/sector/payments-fintech/" }, { "@type": "Thing", "name": "Pensions & Retirement Income", "url": "https://tcc.group/blog/sector/pensions-retirement-income/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Consumer Duty: consumer understanding" } ], "articleSection": [ "Compliance AI & RegTech", "Regulatory Change & Transformation" ], "audience": [ { "@type": "Audience", "audienceType": "Banking" }, { "@type": "Audience", "audienceType": "General Insurance & Protection" }, { "@type": "Audience", "audienceType": "Lending & Consumer Credit" }, { "@type": "Audience", "audienceType": "Motor Finance" }, { "@type": "Audience", "audienceType": "Payments & FinTech" }, { "@type": "Audience", "audienceType": "Pensions & Retirement Income" }, { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Compliance, marketing and customer communications teams responsible for retail communications across wealth, pensions, banking, lending, insurance and motor finance." } ], "citation": [ { "@type": "CreativeWork", "name": "FCA Outcome 3: Consumer understanding", "url": "https://tcc.group/blog/2022/10/11/consumer-understanding-duty-outcome-3/", "datePublished": "2022-10-11" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/regulatory-horizon/consumer-understanding-duty-outcome-3/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/consumer-understanding-duty-outcome-3/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What is the consumer understanding outcome under the Consumer Duty?", "acceptedAnswer": { "@type": "Answer", "text": "It requires firms to give retail customers the information they need, when they need it, in a format they can understand, across verbal, online and printed communications." } }, { "@type": "Question", "name": "Why does the FCA reference literacy levels in its Consumer Duty rules?", "acceptedAnswer": { "@type": "Answer", "text": "The FCA cites research showing one in seven adults have literacy skills at or below those expected of a nine to eleven-year-old, which firms designing mass-market communications need to take into account." } }, { "@type": "Question", "name": "How can firms evidence they meet the consumer understanding outcome?", "acceptedAnswer": { "@type": "Answer", "text": "By testing communications with representative customers, reviewing and refining them on an ongoing basis, and applying the same rigour to that testing as they apply to sales-focused communications." } }, { "@type": "Question", "name": "Does the consumer understanding outcome apply differently to vulnerable customers?", "acceptedAnswer": { "@type": "Answer", "text": "Yes, firms need to consider which communication channels suit their target market's vulnerability profile, for example older customers may prefer non-digital channels while anxious customers may prefer digital ones." } } ] } ] } ``` ### FCA Outcome 2: Price and value - URL: https://tcc.group/insights/regulatory-horizon/price-and-value-duty-outcome/ - Published: 2022-10-03 - Modified: 2026-09-02 **Topic:** Consumer Duty Price and Value As part of a series spotlighting the Consumer Duty's four outcomes, TCC's Neil Dethick sets out three key points firms should consider for the price and value outcome ahead of the implementation deadline. #### What happened? In this second article in a series spotlighting the Consumer Duty's four outcomes, Neil Dethick, Associate Director at TCC, focuses on price and value ahead of the Duty Implementation Plan deadline. Firms have long been expected to offer fair value, but under the Duty they must now explain and evidence how they determine a product or service's worth and that the associated charge represents fair value. The FCA has indicated it will spot check firms and may scrutinise evidence where it has concerns about a firm's level of compliance. The FCA's 2019 paper, "Fair pricing in Financial Services," confirmed there is no simple formula for determining whether a price is unfair, meaning firms need to apply judgement supported by evidence rather than a fixed calculation. #### Why does it matter? Neil Dethick notes that a product or service should not exploit a consumer's lack of knowledge to charge an unfair price. He also raises the question of whether a reduction in a product's benefits should be reflected in a corresponding reduction in price, suggesting that firms need to keep pricing and benefits aligned over time. A harmful outcome is one where a customer does not receive good value, is frustrated by unsuitable or unnecessary features, or experiences poor communication or support. The FCA does not intend to set prices or treat lower-priced products as automatically fair; instead, it will look at the overall relationship between price, features and benefits. #### Who is affected? Firms across financial services that design, price or distribute products and services within scope of the Consumer Duty's price and value outcome. #### Key risks - Being unable to explain or evidence how a product or service's worth was determined. - Pricing that has not been reviewed following a reduction in a product's features or benefits. - Assuming a lower price is automatically fair value without considering the wider relationship between price and benefits. - Ongoing value assessment processes that are not maintained beyond the initial design stage. #### Actions to take 1. Document how the worth of each product or service was determined and how this links to the price charged. 2. Maintain an ongoing value assessment process, with continuous reviews and updates beyond the initial design stage. 3. Review pricing where product features or benefits have changed, to confirm the price still reflects fair value. 4. Prepare evidence ready for FCA spot checks, particularly where compliance concerns might arise. #### Wider implications The absence of a simple formula for fair value means firms cannot rely on a single test or benchmark. Evidencing a reasonable relationship between price and profitability, supported by clear reasoning, will remain necessary as the FCA continues to check compliance with the Duty's four outcomes. #### Recommendations Firms should ensure their value assessment processes are genuinely ongoing rather than a one-off exercise at launch, and should be ready to demonstrate the reasoning behind their pricing if the FCA asks to see it. #### Supporting sources - [FCA Outcome 2: Price and value](https://tcc.group/blog/2022/10/04/price-and-value-duty-outcome/) (2022-10-04) #### Preparing evidence for the price and value outcome? Our Consumer Duty specialists can help you build and evidence your ongoing value assessment process. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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{ "@type": "WebPage", "@id": "https://tcc.group/insights/regulatory-horizon/price-and-value-duty-outcome/#webpage", "url": "https://tcc.group/insights/regulatory-horizon/price-and-value-duty-outcome/", "name": "FCA Outcome 2: Price and value", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2022-10-04T00:00:00+01:00", "dateModified": "2026-09-02T03:48:00+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/regulatory-horizon/price-and-value-duty-outcome/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "NewsArticle", "@id": "https://tcc.group/insights/regulatory-horizon/price-and-value-duty-outcome/#article", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/price-and-value-duty-outcome/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "FCA Outcome 2: Price and value", "datePublished": "2022-10-04T00:00:00+01:00", "dateModified": "2026-09-02T03:48:00+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/regulatory-horizon/price-and-value-duty-outcome/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/ac7ade7ef090403291d3cc3b7376b32d/thumbnail-1024-e10dde77a589325dca527d3ba6e6c9971e47dbc9ff019469f798455c73a8e3b6.jpg", "description": "Neil Dethick, Associate Director at TCC, explains three key points firms should consider for the Consumer Duty's price and value outcome: evidencing fair value, why there is no simple formula, and how to avoid harmful outcomes.", "inLanguage": "en-GB", "articleBody": "As part of a series spotlighting the Consumer Duty's four outcomes, TCC's Neil Dethick sets out three key points firms should consider for the price and value outcome ahead of the implementation deadline.\n\nIn this second article in a series spotlighting the Consumer Duty's four outcomes, Neil Dethick, Associate Director at TCC, focuses on price and value ahead of the Duty Implementation Plan deadline.\n\nFirms have long been expected to offer fair value, but under the Duty they must now explain and evidence how they determine a product or service's worth and that the associated charge represents fair value. The FCA has indicated it will spot check firms and may scrutinise evidence where it has concerns about a firm's level of compliance.\n\nThe FCA's 2019 paper, \"Fair pricing in Financial Services,\" confirmed there is no simple formula for determining whether a price is unfair, meaning firms need to apply judgement supported by evidence rather than a fixed calculation.\n\nNeil Dethick notes that a product or service should not exploit a consumer's lack of knowledge to charge an unfair price. He also raises the question of whether a reduction in a product's benefits should be reflected in a corresponding reduction in price, suggesting that firms need to keep pricing and benefits aligned over time.\n\nA harmful outcome is one where a customer does not receive good value, is frustrated by unsuitable or unnecessary features, or experiences poor communication or support. The FCA does not intend to set prices or treat lower-priced products as automatically fair; instead, it will look at the overall relationship between price, features and benefits.\n\nFirms across financial services that design, price or distribute products and services within scope of the Consumer Duty's price and value outcome.\n\n\u2022 Being unable to explain or evidence how a product or service's worth was determined.\n\u2022 Pricing that has not been reviewed following a reduction in a product's features or benefits.\n\u2022 Assuming a lower price is automatically fair value without considering the wider relationship between price and benefits.\n\u2022 Ongoing value assessment processes that are not maintained beyond the initial design stage.\n\n1. Document how the worth of each product or service was determined and how this links to the price charged.\n2. Maintain an ongoing value assessment process, with continuous reviews and updates beyond the initial design stage.\n3. Review pricing where product features or benefits have changed, to confirm the price still reflects fair value.\n4. Prepare evidence ready for FCA spot checks, particularly where compliance concerns might arise.\n\nThe absence of a simple formula for fair value means firms cannot rely on a single test or benchmark. Evidencing a reasonable relationship between price and profitability, supported by clear reasoning, will remain necessary as the FCA continues to check compliance with the Duty's four outcomes.\n\nFirms should ensure their value assessment processes are genuinely ongoing rather than a one-off exercise at launch, and should be ready to demonstrate the reasoning behind their pricing if the FCA asks to see it.", "wordCount": 502, "keywords": [ "Compliance AI & RegTech", "Consumer Duty", "Banking", "General Insurance & Protection", "Lending & Consumer Credit", "Motor Finance", "Payments & FinTech", "Pensions & Retirement Income", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Consumer Duty", "url": "https://tcc.group/blog/solution/consumer-duty/" }, { "@type": "Thing", "name": "Banking", "url": "https://tcc.group/blog/sector/banking/" }, { "@type": "Thing", "name": "General Insurance & Protection", "url": "https://tcc.group/blog/sector/general-insurance-protection/" }, { "@type": "Thing", "name": "Lending & Consumer Credit", "url": "https://tcc.group/blog/sector/lending-consumer-credit/" }, { "@type": "Thing", "name": "Motor Finance", "url": "https://tcc.group/blog/sector/motor-finance/" }, { "@type": "Thing", "name": "Payments & FinTech", "url": "https://tcc.group/blog/sector/payments-fintech/" }, { "@type": "Thing", "name": "Pensions & Retirement Income", "url": "https://tcc.group/blog/sector/pensions-retirement-income/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Consumer Duty Price and Value" } ], "articleSection": [ "Compliance AI & RegTech", "Consumer Duty" ], "audience": [ { "@type": "Audience", "audienceType": "Banking" }, { "@type": "Audience", "audienceType": "General Insurance & Protection" }, { "@type": "Audience", "audienceType": "Lending & Consumer Credit" }, { "@type": "Audience", "audienceType": "Motor Finance" }, { "@type": "Audience", "audienceType": "Payments & FinTech" }, { "@type": "Audience", "audienceType": "Pensions & Retirement Income" }, { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Compliance and product teams preparing evidence of compliance with the Consumer Duty's price and value outcome." } ], "citation": [ { "@type": "CreativeWork", "name": "FCA Outcome 2: Price and value", "url": "https://tcc.group/blog/2022/10/04/price-and-value-duty-outcome/", "datePublished": "2022-10-04" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/regulatory-horizon/price-and-value-duty-outcome/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/price-and-value-duty-outcome/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What must firms evidence under the price and value outcome?", "acceptedAnswer": { "@type": "Answer", "text": "Firms must explain and evidence how they determine a product or service's worth and that the associated charge represents fair value." } }, { "@type": "Question", "name": "Is there a fixed formula for assessing fair value?", "acceptedAnswer": { "@type": "Answer", "text": "No, the FCA has confirmed there is no simple formula for determining whether a price is unfair, so firms need to apply judgement supported by evidence." } }, { "@type": "Question", "name": "Does a lower price automatically mean fair value?", "acceptedAnswer": { "@type": "Answer", "text": "No, the FCA does not treat lower-priced products as automatically fair; it considers the overall relationship between price, features and benefits." } }, { "@type": "Question", "name": "What happens if a product's benefits reduce?", "acceptedAnswer": { "@type": "Answer", "text": "Neil Dethick suggests that a reduction in a product's benefits should be reflected in a proportionate decrease in price." } } ] } ] } ``` ### FCA Outcome 1: Products and services - URL: https://tcc.group/insights/regulatory-horizon/products-and-services-duty-outcome/ - Published: 2022-09-26 - Modified: 2026-09-02 **Topic:** Consumer Duty Products and Services In the first of a series spotlighting the Consumer Duty's four outcomes, TCC's Neil Dethick sets out three points firms should consider for the products and services outcome ahead of the 31 October 2022 deadline. #### What happened? This article is the first in a series spotlighting the Consumer Duty's four outcomes: products and services, price and value, consumer understanding and consumer support. Neil Dethick, Associate Director at TCC, considers three important areas of the products and services outcome ahead of the 31 October 2022 deadline. The first area is understanding the characteristics of the target customer throughout a product's full lifecycle, including design, approval, marketing and ongoing management, with particular attention to the needs of vulnerable customers. The second area is integrating consumer feedback into product development, and the third is measuring success through the FCA's expected use of management information, complaints data and its Financial Lives Survey. #### Why does it matter? Neil Dethick suggests firms test themselves against a simple question: if the FCA asked for a substantial sample of customer journeys to prove the customer's best interests were kept in mind throughout a product's life cycle, could the firm quickly and easily evidence this, both before and after sale? Firms are also expected to have a Consumer Duty champion at board or equivalent level, responsible for ensuring the outcomes are discussed in a meaningful way, and to demonstrate a clear process for gathering and acting on consumer feedback. #### Who is affected? Teams responsible for product design, marketing, target market research and board-level Consumer Duty governance across financial services firms. #### Key risks - Being unable to evidence that customer journeys were designed with the target market's best interests in mind. - No clear process for gathering and acting on consumer feedback during product development. - Absence of a board-level Consumer Duty champion responsible for meaningful discussion of the outcomes. - Management information that does not allow the firm to track consumer trust, confidence or understanding over time. #### Actions to take 1. Map the full lifecycle of each product or service and confirm governance and evidence exist at every stage. 2. Establish a demonstrable process for gathering and incorporating consumer feedback into product development. 3. Confirm a Consumer Duty champion is in place at board or equivalent level. 4. Build management information that tracks consumer trust, confidence and understanding, alongside complaints data. #### Wider implications The FCA has confirmed it will take a more assertive, data-led approach to monitoring products and services, drawing on management information, complaints data and its Financial Lives Survey. Firms should expect this data-led scrutiny to continue as the Duty embeds. #### Recommendations Firms should prepare now to answer the customer journey test that Neil Dethick sets out, and ensure a board-level Consumer Duty champion and a working feedback loop are in place ahead of the deadline. #### Supporting sources - [FCA Outcome 1: Products and services](https://tcc.group/blog/2022/09/27/products-and-services-duty-outcome/) (2022-09-27) #### Preparing your products and services outcome? Speak to our Consumer Duty specialists about evidencing good outcomes across your product lifecycle. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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"https://tcc.group/insights/regulatory-horizon/products-and-services-duty-outcome/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/regulatory-horizon/products-and-services-duty-outcome/#webpage", "url": "https://tcc.group/insights/regulatory-horizon/products-and-services-duty-outcome/", "name": "FCA Outcome 1: Products and services", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2022-09-27T00:00:00+01:00", "dateModified": "2026-09-02T03:48:00+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/regulatory-horizon/products-and-services-duty-outcome/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "NewsArticle", "@id": "https://tcc.group/insights/regulatory-horizon/products-and-services-duty-outcome/#article", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/products-and-services-duty-outcome/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "FCA Outcome 1: Products and services", "datePublished": "2022-09-27T00:00:00+01:00", "dateModified": "2026-09-02T03:48:00+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/regulatory-horizon/products-and-services-duty-outcome/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/a5d9a3bd99c742f9a1c2fbaeb14e7dda/thumbnail-1024-1c7f1600de5ad4e8469a360300a937d566d35157d266084b312e42870e9fa16e.jpg", "description": "Ahead of the Consumer Duty's implementation deadline, TCC's Neil Dethick sets out three points firms should consider for the products and services outcome: customer characteristics, integrating feedback and measuring success.", "inLanguage": "en-GB", "articleBody": "In the first of a series spotlighting the Consumer Duty's four outcomes, TCC's Neil Dethick sets out three points firms should consider for the products and services outcome ahead of the 31 October 2022 deadline.\n\nThis article is the first in a series spotlighting the Consumer Duty's four outcomes: products and services, price and value, consumer understanding and consumer support. Neil Dethick, Associate Director at TCC, considers three important areas of the products and services outcome ahead of the 31 October 2022 deadline.\n\nThe first area is understanding the characteristics of the target customer throughout a product's full lifecycle, including design, approval, marketing and ongoing management, with particular attention to the needs of vulnerable customers.\n\nThe second area is integrating consumer feedback into product development, and the third is measuring success through the FCA's expected use of management information, complaints data and its Financial Lives Survey.\n\nNeil Dethick suggests firms test themselves against a simple question: if the FCA asked for a substantial sample of customer journeys to prove the customer's best interests were kept in mind throughout a product's life cycle, could the firm quickly and easily evidence this, both before and after sale?\n\nFirms are also expected to have a Consumer Duty champion at board or equivalent level, responsible for ensuring the outcomes are discussed in a meaningful way, and to demonstrate a clear process for gathering and acting on consumer feedback.\n\nTeams responsible for product design, marketing, target market research and board-level Consumer Duty governance across financial services firms.\n\n\u2022 Being unable to evidence that customer journeys were designed with the target market's best interests in mind.\n\u2022 No clear process for gathering and acting on consumer feedback during product development.\n\u2022 Absence of a board-level Consumer Duty champion responsible for meaningful discussion of the outcomes.\n\u2022 Management information that does not allow the firm to track consumer trust, confidence or understanding over time.\n\n1. Map the full lifecycle of each product or service and confirm governance and evidence exist at every stage.\n2. Establish a demonstrable process for gathering and incorporating consumer feedback into product development.\n3. Confirm a Consumer Duty champion is in place at board or equivalent level.\n4. Build management information that tracks consumer trust, confidence and understanding, alongside complaints data.\n\nThe FCA has confirmed it will take a more assertive, data-led approach to monitoring products and services, drawing on management information, complaints data and its Financial Lives Survey. Firms should expect this data-led scrutiny to continue as the Duty embeds.\n\nFirms should prepare now to answer the customer journey test that Neil Dethick sets out, and ensure a board-level Consumer Duty champion and a working feedback loop are in place ahead of the deadline.", "wordCount": 452, "keywords": [ "Compliance AI & RegTech", "Consumer Duty", "Banking", "General Insurance & Protection", "Lending & Consumer Credit", "Motor Finance", "Payments & FinTech", "Pensions & Retirement Income", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Consumer Duty", "url": "https://tcc.group/blog/solution/consumer-duty/" }, { "@type": "Thing", "name": "Banking", "url": "https://tcc.group/blog/sector/banking/" }, { "@type": "Thing", "name": "General Insurance & Protection", "url": "https://tcc.group/blog/sector/general-insurance-protection/" }, { "@type": "Thing", "name": "Lending & Consumer Credit", "url": "https://tcc.group/blog/sector/lending-consumer-credit/" }, { "@type": "Thing", "name": "Motor Finance", "url": "https://tcc.group/blog/sector/motor-finance/" }, { "@type": "Thing", "name": "Payments & FinTech", "url": "https://tcc.group/blog/sector/payments-fintech/" }, { "@type": "Thing", "name": "Pensions & Retirement Income", "url": "https://tcc.group/blog/sector/pensions-retirement-income/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Consumer Duty Products and Services" } ], "articleSection": [ "Compliance AI & RegTech", "Consumer Duty" ], "audience": [ { "@type": "Audience", "audienceType": "Banking" }, { "@type": "Audience", "audienceType": "General Insurance & Protection" }, { "@type": "Audience", "audienceType": "Lending & Consumer Credit" }, { "@type": "Audience", "audienceType": "Motor Finance" }, { "@type": "Audience", "audienceType": "Payments & FinTech" }, { "@type": "Audience", "audienceType": "Pensions & Retirement Income" }, { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Product design, marketing and compliance teams responsible for the products and services outcome under the Consumer Duty." } ], "citation": [ { "@type": "CreativeWork", "name": "FCA Outcome 1: Products and services", "url": "https://tcc.group/blog/2022/09/27/products-and-services-duty-outcome/", "datePublished": "2022-09-27" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/regulatory-horizon/products-and-services-duty-outcome/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/regulatory-horizon/products-and-services-duty-outcome/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What is the products and services outcome under the Consumer Duty?", "acceptedAnswer": { "@type": "Answer", "text": "It is one of four Consumer Duty outcomes, requiring firms to evidence that products and services are designed, approved, marketed and managed with the target market's best interests in mind." } }, { "@type": "Question", "name": "What test does Neil Dethick suggest firms apply?", "acceptedAnswer": { "@type": "Answer", "text": "He suggests firms check whether they could quickly and easily provide a substantial sample of customer journeys proving the customer's best interests were kept in mind throughout the product's life cycle." } }, { "@type": "Question", "name": "Do firms need a board-level Consumer Duty champion?", "acceptedAnswer": { "@type": "Answer", "text": "Yes, firms are expected to have a Consumer Duty champion at board or equivalent level responsible for ensuring the outcomes are discussed meaningfully." } }, { "@type": "Question", "name": "How will the FCA measure success under this outcome?", "acceptedAnswer": { "@type": "Answer", "text": "The FCA will monitor products and services consumers use and measure consumer trust and confidence using management information, complaints data and its Financial Lives Survey." } } ] } ] } ``` ### How to prepare for FCA's new Consumer Duty - URL: https://tcc.group/insights/regulatory-horizon/how-to-prepare-for-fca-consumer-duty/ - Published: 2022-09-20 - Modified: 2026-09-02 **Topic:** Consumer Duty Preparation TCC Director Neil Dethick shares practical and preparatory steps, emphasizing board responsibility and working groups, for firms preparing their Consumer Duty Implementation Plans. #### What happened? The FCA's landmark Consumer Duty introduces a higher, clearer standard of consumer protection across the financial services sector. With the critical Implementation Plan deadline approaching on 31st October, regulated firms face a challenging period to align their operations with the new legislative principle. TCC Director Neil Dethick discusses how boards and executive teams must prioritize compliance by taking practical, demonstrable steps to establish robust transition plans and outcome monitoring frameworks. #### Why does it matter? The FCA is adopting an 'assertive supervision' model, utilizing proactive intervention rather than passive oversight. Under the 'show me, don't tell me' approach, firms must prove they are putting customer needs and well-being at the heart of their culture, particularly when supporting vulnerable customers. Boards are fully accountable for the Duty. They must ensure that the four key outcomes—products and services, price and value, consumer understanding, and consumer support—are consistently achieved and evidenced through robust management information (MI). #### Who is affected? This regulatory transition directly impacts all FCA-regulated financial services firms, their boards of directors, compliance officers, and customer journey designers. #### Key risks - **Poor Board Oversight:** Boards failing to actively supervise the design, implementation, and continuous measurement of Consumer Duty plans. - **Unvouched Outcomes:** Lack of structured, auditable MI to prove to the regulator that consumers are receiving good outcomes. - **Inadequate Gap Analysis:** Failing to perform a comprehensive gap analysis on product design, delivery, and customer lifecycles. #### Actions to take 1. **Appoint a Working Group:** Form an internal Consumer Duty working group to lead proactive implementation and coordinate efforts. 2. **Conduct a Gap Analysis:** Perform a detailed review of product design, customer lifecycles, and after-sales support systems. 3. **Upgrade Board MI:** Re-examine and optimize the management information delivered to the board to ensure it reliably monitors and evidences customer outcomes. #### Wider implications The Consumer Duty signals a permanent cultural reset in UK financial services. Proactive firms that embed outcome-focused measurements now will establish a robust foundation for long-term compliance and competitive advantage. #### Recommendations Firms should validate their transition plans and gap analyses through independent, third-party compliance assessments to ensure all regulatory blind spots are addressed. #### Supporting sources - [How to prepare for FCA's new Consumer Duty](https://tcc.group/blog/2022/09/21/how-to-prepare-for-fca-consumer-duty/) (2022-09-21) #### Is your Consumer Duty plan regulator-ready? Our senior consultants can assist your firm in conducting rigorous gap analyses, upgrading board MI, and validating your implementation strategies. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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responsibility and working groups, for firms preparing their Consumer Duty Implementation Plans.\n\nThe FCA's landmark Consumer Duty introduces a higher, clearer standard of consumer protection across the financial services sector. With the critical Implementation Plan deadline approaching on 31st October, regulated firms face a challenging period to align their operations with the new legislative principle.\n\nTCC Director Neil Dethick discusses how boards and executive teams must prioritize compliance by taking practical, demonstrable steps to establish robust transition plans and outcome monitoring frameworks.\n\nThe FCA is adopting an 'assertive supervision' model, utilizing proactive intervention rather than passive oversight. Under the 'show me, don't tell me' approach, firms must prove they are putting customer needs and well-being at the heart of their culture, particularly when supporting vulnerable customers.\n\nBoards are fully accountable for the Duty. They must ensure that the four key outcomes\u2014products and services, price and value, consumer understanding, and consumer support\u2014are consistently achieved and evidenced through robust management information (MI).\n\nThis regulatory transition directly impacts all FCA-regulated financial services firms, their boards of directors, compliance officers, and customer journey designers.\n\n\u2022 Poor Board Oversight: Boards failing to actively supervise the design, implementation, and continuous measurement of Consumer Duty plans.\n\u2022 Unvouched Outcomes: Lack of structured, auditable MI to prove to the regulator that consumers are receiving good outcomes.\n\u2022 Inadequate Gap Analysis: Failing to perform a comprehensive gap analysis on product design, delivery, and customer lifecycles.\n\n1. Appoint a Working Group: Form an internal Consumer Duty working group to lead proactive implementation and coordinate efforts.\n2. Conduct a Gap Analysis: Perform a detailed review of product design, customer lifecycles, and after-sales support systems.\n3. Upgrade Board MI: Re-examine and optimize the management information delivered to the board to ensure it reliably monitors and evidences customer outcomes.\n\nThe Consumer Duty signals a permanent cultural reset in UK financial services. 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With the FCA's deadline for implementation plans confirmed for 31 October 2022, firms needed to work out how to adjust their business framework to meet a significant step up in oversight requirements. In Money Marketing, TCC Associate Director Neil Dethick set out the three steps firms should work through to develop their Consumer Duty strategy, with tips on aligning with the FCA's "show me, don't tell me" approach to regulation. #### Why does it matter? With only weeks left to prepare, firms need to know where to focus their attention so that limited time is spent on the areas that matter most to the regulator. #### Supporting sources - [Three key steps to ensuring Consumer Duty readiness](https://tcc.group/blog/2022/08/24/three-key-steps-to-ensuring-consumer-duty-readiness/) (2022-08-24) #### Preparing your Consumer Duty plan? Talk to our team about building an implementation plan that meets the FCA's expectations. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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Neil Dethick, writing in Money Marketing." } } ] } ] } ``` ### Women in Governance, Risk and Compliance: meet TCC and Recordsure’s Joanne Smith - URL: https://tcc.group/insights/regulatory-horizon/women-in-grc-meet-joanne-smith/ - Published: 2022-07-25 - Modified: 2026-09-02 **Topic:** Women in GRC Awards Joanne Smith, founder of TCC Group and Recordsure, has been confirmed as a judge for the Women in GRC Awards 2022, recognising her three decades leading innovation in compliance and RegTech. #### What happened? After being named Innovator of the Year at the Women in Governance, Risk and Compliance (GRC) Awards 2021, TCC and Recordsure Founder and Executive Chair Joanne Smith has been confirmed as a judge for this year's event, ahead of the shortlist announcement in September. The awards recognise female leaders, mentors and advocates in the risk and compliance sector across 17 award categories. #### Why does it matter? Joanne Smith founded TCC Group in 2001 and RegTech business Recordsure in 2012, and her work has produced several industry firsts, including a face-to-face conversation recording solution built to meet the security needs of financial regulators, a speech recognition system for multi-party conversations, and an AI system that breaks financial conversations into component parts for compliance, training and customer insight reviews. #### Who is affected? The piece is of interest to compliance and RegTech professionals, and to those following industry recognition for women in governance, risk and compliance leadership. #### Wider implications Beyond her business milestones, Joanne Smith has supported women in technology and financial services, mentoring colleagues, investing in female-led technology businesses and chairing the CBI SME council. #### Supporting sources - [Women in Governance, Risk and Compliance: meet TCC and Recordsure's Joanne Smith](https://tcc.group/blog/2022/07/26/women-in-grc-meet-joanne-smith/) (2022-07-26) #### Want to learn more about TCC's leadership? Get in touch to find out more about TCC Group's people and our approach to compliance and RegTech. 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myth-busting: what do firms need to know? - URL: https://tcc.group/insights/analysis-perspectives/consumer-duty-myth-busting/ - Published: 2022-07-14 - Modified: 2026-09-02 **Topic:** Consumer Duty misconceptions A survey by Royal London found almost one in five advisers were still unfamiliar with the Consumer Duty just weeks before the final rules were announced, prompting TCC's Juana Diaz-Landinez to address common misconceptions in Money Marketing. #### What happened? A recent survey by Royal London found that almost one in five advisers were still unfamiliar with the Consumer Duty, despite only weeks remaining until the final rules were announced. In Money Marketing, TCC's Associate Director Juana Diaz-Landinez discussed four of the most prevalent misconceptions about the new rules. #### Why does it matter? The survey findings suggest many firms remain unaware of the significant step-up in regulatory obligations awaiting them, which makes it important to confirm that plans for implementation are based on an accurate understanding of what the Duty actually requires, rather than assumptions. #### Supporting sources - [Consumer Duty myth-busting: what do firms need to know?](https://tcc.group/blog/2022/07/15/consumer-duty-myth-busting/) (2022-07-15) #### Unsure if your Consumer Duty plans are on track? TCC can help you check your understanding of the Duty against the regulator's actual requirements. 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"https://tcc.group/insights/analysis-perspectives/consumer-duty-myth-busting/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "Consumer Duty myth-busting: what do firms need to know?", "datePublished": "2022-07-15T00:00:00+01:00", "dateModified": "2026-09-02T03:47:36+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/analysis-perspectives/consumer-duty-myth-busting/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/3e003cfe870a42e8bd63da6a5f98cdf7/thumbnail-1024-f3874bffaf0c369c84acefad7fc4d83044161b5a52615a34ca56322b12d5176f.jpg", "description": "Four common misconceptions about the Consumer Duty are challenged, helping firms check they are genuinely prepared for implementation rather than relying on assumptions about what the new rules actually require.", "inLanguage": "en-GB", "articleBody": "A survey by Royal London found almost one in five advisers 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In Money Marketing, TCC's Associate Director Juana Diaz-Landinez discussed four of the most prevalent misconceptions about the new rules.\n\nThe survey findings suggest many firms remain unaware of the significant step-up in regulatory obligations awaiting them, which makes it important to confirm that plans for implementation are based on an accurate understanding of what the Duty actually requires, rather than assumptions.", "wordCount": 128, "keywords": [ "Compliance AI & RegTech", "Consumer Duty", "Regulatory Change & Transformation", "Banking", "General Insurance & Protection", "Lending & Consumer Credit", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Consumer Duty", "url": "https://tcc.group/blog/solution/consumer-duty/" }, { "@type": "Thing", "name": "Regulatory Change & Transformation", "url": "https://tcc.group/blog/solution/regulatory-change-transformation/" }, { "@type": "Thing", "name": "Banking", "url": "https://tcc.group/blog/sector/banking/" }, { "@type": "Thing", "name": "General Insurance & Protection", "url": "https://tcc.group/blog/sector/general-insurance-protection/" }, { "@type": "Thing", "name": "Lending & Consumer Credit", "url": "https://tcc.group/blog/sector/lending-consumer-credit/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Consumer Duty misconceptions" } ], "articleSection": [ "Compliance AI & RegTech", "Consumer Duty", "Regulatory Change & Transformation" ], "audience": [ { "@type": "Audience", "audienceType": "Banking" }, { "@type": "Audience", "audienceType": "General Insurance & Protection" }, { "@type": "Audience", "audienceType": "Lending & Consumer Credit" }, { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Financial advice firms and advisers preparing for the Consumer Duty's implementation." } ], "citation": [ { "@type": "CreativeWork", "name": "Consumer Duty myth-busting: what do firms need to know?", "url": "https://tcc.group/blog/2022/07/15/consumer-duty-myth-busting/", "datePublished": "2022-07-15" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/analysis-perspectives/consumer-duty-myth-busting/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/consumer-duty-myth-busting/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "How many advisers were unfamiliar with the Consumer Duty, according to the survey?", "acceptedAnswer": { "@type": "Answer", "text": "A Royal London survey found almost one in five advisers were still unfamiliar with it." } }, { "@type": "Question", "name": "Who wrote the original Money Marketing article?", "acceptedAnswer": { "@type": "Answer", "text": "TCC's Associate Director, Juana Diaz-Landinez." } } ] } ] } ``` ### Three rules for turning complaints into valuable lessons - URL: https://tcc.group/insights/analysis-perspectives/three-rules-for-turning-complaints-into-valuable-lessons/ - Published: 2022-06-13 - Modified: 2026-09-02 **Topic:** Complaints handling In FT Adviser, TCC's Neil Dethick sets out a three-step process for handling customer complaints constructively and turning less-than-stellar outcomes into a learning experience for the team. #### What happened? In FT Adviser, TCC Associate Director Neil Dethick set out his three-step process for helping unsatisfied customers navigate a firm's complaints procedure. He explained how firms can transform less-than-stellar outcomes into a learning experience for their team, rather than treating each complaint as a closed case. #### Why does it matter? Approaching complaints constructively benefits both the customer and the firm, and gives teams a structured way to identify what needs to change to prevent similar issues recurring. #### Supporting sources - [Three rules for turning complaints into valuable lessons](https://tcc.group/blog/2022/06/14/three-rules-for-turning-complaints-into-valuable-lessons/) (2022-06-14) #### Want to improve your complaints process? Contact our team to discuss turning complaints into a genuine learning opportunity. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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Associate Director Neil Dethick." } } ] } ] } ``` ### Spotting the warning signs of a risky acquisition - URL: https://tcc.group/insights/analysis-perspectives/three-warning-signs-of-a-risky-acquisition/ - Published: 2022-05-24 - Modified: 2026-09-02 **Topic:** Acquisition due diligence With the financial sector experiencing a surge in acquisitions, TCC's David Boyhan sets out three major red flags to check for before moving ahead with a deal, so target firms don't end up saddling acquirers with hidden liabilities. #### What happened? The financial sector is experiencing a significant surge in acquisitions. Acquisitions can be an efficient way to expand distribution, but firms need to do their homework first to avoid a target firm saddling them with hidden liabilities. In Money Marketing, Technical Director David Boyhan suggested three major red flags to watch out for before moving ahead with any acquisition. #### Why does it matter? Spotting warning signs before completion gives acquirers the chance to price, renegotiate or walk away from a deal, rather than discovering a target firm's liabilities after the transaction has closed. #### Supporting sources - [Spotting the warning signs of a risky acquisition](https://tcc.group/blog/2022/05/25/three-warning-signs-of-a-risky-acquisition/) (2022-05-25) #### Considering an acquisition? Speak to our team about assessing a target firm's regulatory and compliance risk before you commit. 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The FCA's Consumer Duty introduces higher standards of care across the entire customer lifecycle, replacing the previous 'Treating Customers Fairly' (TCF) requirements. This transition poses complex operational and cultural shifts for regulated firms. Writing in FT Adviser, TCC Associate Director Neil Dethick identifies four critical operational complications that businesses should address to prevent implementation delays and ensure compliance. #### Why does it matter? Unlike previous regimes, the Consumer Duty requires proactive evidence of good outcomes across products, pricing, comprehension, and customer support. Moving beyond simple disclosure to active monitoring and vulnerability tracking presents significant system and data integration hurdles for traditional compliance operations. #### Supporting sources - [Implementing the Consumer Duty: what are the foreseeable challenges?](https://tcc.group/blog/2022/04/12/implementing-the-consumer-duty-what-are-the-foreseeable-challenges/) (2022-04-12) #### Are you struggling with Consumer Duty challenges? Speak to our advisory team today to help you conduct gap analyses, upgrade your customer journeys, and design compliant outcome-monitoring systems. [Talk to our experts](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", 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should anticipate as they prepare for the FCA's Consumer Duty implementation and outcome monitoring.", "inLanguage": "en-GB", "articleBody": "TCC Associate Director Neil Dethick discusses the operational challenges and new standards of care associated with the transition to the FCA's Consumer Duty in FT Adviser.\n\nThe FCA's Consumer Duty introduces higher standards of care across the entire customer lifecycle, replacing the previous 'Treating Customers Fairly' (TCF) requirements. 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Regulators around the world have signalled their intent to keep strengthening consumer protections and raising standards, including the incoming Consumer Duty, the expansion of the Appointed Representatives regime, and the FCA's Consumer Investments Strategy. Research from the Wealth and Asset Management 4.0 project found that one in three businesses polled expect risk management regulation to increase within the next two years. In this piece, TCC Group Chief Commercial Officer Mark Hover explains how digital transformation and RegTech are helping firms manage this growing compliance workload. #### Why does it matter? Staying on top of compliance manually is becoming unmanageable for even the most experienced teams as new rules accumulate. Private banks, retail asset managers and broker-dealers are already leading the shift, with more than half self-reporting mid- or advanced-stage digital development. Around 65% of these firms are investing in process automation, 52% in smart data and analytics, and 46% in tech-powered compliance platforms, showing that digital tools are becoming standard practice rather than an experiment. #### Who is affected? Banking, wealth management, pensions, payments, lending, insurance and motor finance firms that need to scale compliance activity, such as file reviews and SMCR administration, without a matching increase in headcount. #### Key risks - Manual compliance processes becoming unmanageable as new regulatory requirements accumulate - File reviews and quality assurance checks that are too labour-intensive to scale with demand - HR teams administering processes like SMCR Fitness & Propriety assessments without the regulatory knowledge to handle irregular cases #### Actions to take 1. Automate time-consuming file checking tasks to increase the number of checks carried out without adding headcount 2. Introduce workflow tools that guide teams through processes such as SMCR administration step by step 3. Use speech analytics to review client conversations and direct reviewer attention to higher-risk interactions 4. Build a management information trail that supports supervisory oversight and audit evidence #### Wider implications With around 30% of firms expecting more rules on conduct and individual accountability, RegTech that codifies best practice into workflows can help firms stay consistent as requirements continue to change. #### Recommendations Firms should look for RegTech solutions built with the regulator's expectations in mind, so that compliance processes hold up to scrutiny as headcount-neutral automation takes on a larger share of the workload. #### Supporting sources - [Three ways digital transformation is strengthening compliance](https://tcc.group/blog/2022/03/29/three-ways-digital-transformation-is-strengthening-compliance/) (2022-03-29) #### Ready to modernise your compliance processes? Contact us to discuss how RegTech can help your team manage a growing compliance workload. [Get started](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/insights/press-releases/three-ways-digital-transformation-is-strengthening-compliance/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Insights", "item": "https://tcc.group/insights/" }, { "@type": "ListItem", "position": 3, "name": "Three ways digital transformation is strengthening compliance", "item": "https://tcc.group/insights/press-releases/three-ways-digital-transformation-is-strengthening-compliance/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/press-releases/three-ways-digital-transformation-is-strengthening-compliance/#webpage", "url": "https://tcc.group/insights/press-releases/three-ways-digital-transformation-is-strengthening-compliance/", "name": "Three ways digital transformation is strengthening compliance", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2022-03-29T00:00:00+01:00", "dateModified": "2026-09-02T03:49:09+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/press-releases/three-ways-digital-transformation-is-strengthening-compliance/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "NewsArticle", "@id": "https://tcc.group/insights/press-releases/three-ways-digital-transformation-is-strengthening-compliance/#article", "isPartOf": { "@id": "https://tcc.group/insights/press-releases/three-ways-digital-transformation-is-strengthening-compliance/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "Three ways digital transformation is strengthening compliance", "datePublished": "2022-03-29T00:00:00+01:00", "dateModified": "2026-09-02T03:49:09+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/press-releases/three-ways-digital-transformation-is-strengthening-compliance/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/1d9c4acc949f48e898585a610a067f8e/thumbnail-1024-e00a9bade6721f8756a6888f2f1997a969231c3b05e65f79e4da2a3616575c2c.jpg", "description": "Discover how leading wealth, banking and insurance firms are using RegTech - from automated file reviews to AI speech analytics - to keep pace with rising compliance demands without expanding headcount.", "inLanguage": "en-GB", "articleBody": "As regulators raise the bar on consumer protection, TCC's Group Chief Commercial Officer Mark Hover explains how automation, workflow tools and AI-driven speech analytics are helping firms manage a growing compliance workload without increasing headcount.\n\nRegulators around the world have signalled their intent to keep strengthening consumer protections and raising standards, including the incoming Consumer Duty, the expansion of the Appointed Representatives regime, and the FCA's Consumer Investments Strategy.\n\nResearch from the Wealth and Asset Management 4.0 project found that one in three businesses polled expect risk management regulation to increase within the next two years.\n\nIn this piece, TCC Group Chief Commercial Officer Mark Hover explains how digital transformation and RegTech are helping firms manage this growing compliance workload.\n\nStaying on top of compliance manually is becoming unmanageable for even the most experienced teams as new rules accumulate. Private banks, retail asset managers and broker-dealers are already leading the shift, with more than half self-reporting mid- or advanced-stage digital development.\n\nAround 65% of these firms are investing in process automation, 52% in smart data and analytics, and 46% in tech-powered compliance platforms, showing that digital tools are becoming standard practice rather than an experiment.\n\nBanking, wealth management, pensions, payments, lending, insurance and motor finance firms that need to scale compliance activity, such as file reviews and SMCR administration, without a matching increase in headcount.\n\n\u2022 Manual compliance processes becoming unmanageable as new regulatory requirements accumulate\n\u2022 File reviews and quality assurance checks that are too labour-intensive to scale with demand\n\u2022 HR teams administering processes like SMCR Fitness & Propriety assessments without the regulatory knowledge to handle irregular cases\n\n1. 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- URL: https://tcc.group/insights/analysis-perspectives/how-prepared-are-you-for-the-consumer-duty/ - Published: 2022-03-24 - Modified: 2026-09-02 **Topic:** Consumer Duty Readiness TCC Associate Director Juana Diaz-Landinez discusses the four key components that regulated firms must address in Money Marketing to prepare for the FCA's Consumer Duty. #### What happened? The FCA's long-awaited Consumer Duty is set to enforce a whole new standard of customer care. With less than a year until the implementation deadline, firms are urged to act proactively to ensure a smooth transition and avoid compliance failures. Writing in Money Marketing, TCC Associate Director Juana Diaz-Landinez outlines the top four questions that firms should address immediately to structure their transition programmes and prepare for the new regulatory regime. #### Why does it matter? The Consumer Duty represents a fundamental cultural and operational shift, moving the regulatory focus from tick-box compliance to objective customer outcomes. Firms that delay their readiness reviews risk severe regulatory action, including fines and product restrictions once the Duty comes into force. #### Supporting sources - [How prepared are you for the Consumer Duty?](https://tcc.group/blog/2022/03/25/how-prepared-are-you-for-the-consumer-duty/) (2022-03-25) #### Is your firm fully prepared for the Consumer Duty? Speak to our regulatory change experts today to review your transition plans and ensure compliance with the FCA's new standards of customer care. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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TCC and Recordsure have been named joint winners of the “Best RegTech Company” title at the 2022 FinTech Breakthrough Awards, now in their sixth year. The award recognises companies, products and technologies judged to be pushing the boundaries of the global FinTech industry. The win marks a second consecutive year of recognition for TCC, having previously won the same award in 2021. FinTech Breakthrough Managing Director James Johnson said the two organisations “deliver on this challenge, driving innovation and delivering ‘breakthrough’ compliance solutions”. The group’s technology portfolio referenced in the announcement includes High-Performance Assurance, a file-reviewing platform combining Recordsure AI Docs’ automation with document viewing, bookmarking and gap-flagging tools, and Recordsure AI Voice, which analyses and segments client conversations and flags cases for further review. A further tool, SMCR PRO, was announced as due to launch in 2022 to support Senior Managers and Certification Regime obligations. #### Why does it matter? The award reflects the combination of regulatory compliance expertise and technology that TCC and Recordsure position as central to their offering. For regulated firms, tools such as AI Voice and High-Performance Assurance are presented as ways of reviewing a greater proportion of client interactions and files than manual review alone would allow. Recognition across two consecutive years suggests a degree of continuity in the approach, which may be relevant to firms assessing the durability of a compliance technology partner. #### Who is affected? The announcement is most relevant to compliance, quality assurance and file review functions at regulated firms considering how to combine automated analytics with existing review processes, and to firms preparing for Senior Managers and Certification Regime obligations. #### Wider implications The source material describes rising demand from financial services customers for more efficient, lower-cost ways of managing regulatory compliance and reducing conduct risk and remediation costs, while also expecting improved customer outcomes. Awards of this kind reflect a broader market trend of firms combining artificial intelligence, machine learning and automation with existing compliance functions rather than treating them as a replacement for expert judgement. #### Recommendations Firms reviewing their approach to file review or quality assurance may wish to consider tools that combine automated triage or flagging with expert review, and to assess how any new certification or resourcing tool will support forthcoming regulatory deadlines such as SM&CR obligations. #### Supporting sources - [TCC and Recordsure win joint ‘Best RegTech Company’](https://tcc.group/blog/2022/03/17/tcc-and-recordsure-win-joint-best-regtech-company-prize-at-fintech-breakthrough-awards-2022/) (2022-03-17) #### Comparing compliance technology providers? Talk to our team about how combining consultancy expertise with RegTech tools can support your compliance and quality assurance processes. 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The award recognises companies, products and technologies judged to be pushing the boundaries of the global FinTech industry.\n\nThe win marks a second consecutive year of recognition for TCC, having previously won the same award in 2021. FinTech Breakthrough Managing Director James Johnson said the two organisations \u201cdeliver on this challenge, driving innovation and delivering \u2018breakthrough\u2019 compliance solutions\u201d.\n\nThe group\u2019s technology portfolio referenced in the announcement includes High-Performance Assurance, a file-reviewing platform combining Recordsure AI Docs\u2019 automation with document viewing, bookmarking and gap-flagging tools, and Recordsure AI Voice, which analyses and segments client conversations and flags cases for further review. 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For regulated firms, tools such as AI Voice and High-Performance Assurance are presented as ways of reviewing a greater proportion of client interactions and files than manual review alone would allow.\n\nRecognition across two consecutive years suggests a degree of continuity in the approach, which may be relevant to firms assessing the durability of a compliance technology partner.\n\nThe announcement is most relevant to compliance, quality assurance and file review functions at regulated firms considering how to combine automated analytics with existing review processes, and to firms preparing for Senior Managers and Certification Regime obligations.\n\nThe source material describes rising demand from financial services customers for more efficient, lower-cost ways of managing regulatory compliance and reducing conduct risk and remediation costs, while also expecting improved customer outcomes. Awards of this kind reflect a broader market trend of firms combining artificial intelligence, machine learning and automation with existing compliance functions rather than treating them as a replacement for expert judgement.\n\nFirms reviewing their approach to file review or quality assurance may wish to consider tools that combine automated triage or flagging with expert review, and to assess how any new certification or resourcing tool will support forthcoming regulatory deadlines such as SM&CR obligations.", "wordCount": 398, "keywords": [ "Compliance AI & RegTech", "Payments & FinTech" ], "about": [ { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Payments & FinTech", "url": "https://tcc.group/blog/sector/payments-fintech/" }, { "@type": "Thing", "name": "RegTech Award Recognition" } ], "articleSection": [ "Compliance AI & RegTech" ], "audience": [ { "@type": "Audience", "audienceType": "Payments & FinTech" }, { "@type": "Audience", "audienceType": "Compliance and technology leaders comparing RegTech providers for financial services firms." } ], "citation": [ { "@type": "CreativeWork", "name": "TCC and Recordsure win joint \u2018Best RegTech Company\u2019", "url": "https://tcc.group/blog/2022/03/17/tcc-and-recordsure-win-joint-best-regtech-company-prize-at-fintech-breakthrough-awards-2022/", "datePublished": "2022-03-17" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/analysis-perspectives/tcc-and-recordsure-win-joint-best-regtech-company-prize-at-fintech-breakthrough-awards-2022/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/tcc-and-recordsure-win-joint-best-regtech-company-prize-at-fintech-breakthrough-awards-2022/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What award did TCC and Recordsure win in 2022?", "acceptedAnswer": { "@type": "Answer", "text": "TCC and Recordsure were named joint winners of the Best RegTech Company award at the 2022 FinTech Breakthrough Awards." } }, { "@type": "Question", "name": "Had TCC won this award before?", "acceptedAnswer": { "@type": "Answer", "text": "Yes. TCC previously won the same award in 2021, making 2022 its second consecutive win." } }, { "@type": "Question", "name": "What tools were mentioned as part of TCC and Recordsure's RegTech portfolio?", "acceptedAnswer": { "@type": "Answer", "text": "The announcement references High-Performance Assurance, Recordsure AI Voice, and an upcoming tool called SMCR PRO designed to support Senior Managers and Certification Regime obligations." } } ] } ] } ``` ### Joanne Smith named Innovator of the Year 2022 finalist - URL: https://tcc.group/insights/press-releases/joanne-smith-innovator-of-the-year-2022-award-finalist/ - Published: 2022-03-05 - Modified: 2026-09-02 ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, 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"urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/insights/press-releases/joanne-smith-innovator-of-the-year-2022-award-finalist/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Insights", "item": "https://tcc.group/insights/" }, { "@type": "ListItem", "position": 3, "name": "Joanne Smith named Innovator of the Year 2022 finalist", "item": "https://tcc.group/insights/press-releases/joanne-smith-innovator-of-the-year-2022-award-finalist/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/press-releases/joanne-smith-innovator-of-the-year-2022-award-finalist/#webpage", "url": "https://tcc.group/insights/press-releases/joanne-smith-innovator-of-the-year-2022-award-finalist/", "name": "Joanne Smith named Innovator of the Year 2022 finalist", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2022-03-06T00:00:00+01:00", "dateModified": "2026-09-02T03:47:54+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/press-releases/joanne-smith-innovator-of-the-year-2022-award-finalist/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "Article", "@id": "https://tcc.group/insights/press-releases/joanne-smith-innovator-of-the-year-2022-award-finalist/#article", "isPartOf": { "@id": "https://tcc.group/insights/press-releases/joanne-smith-innovator-of-the-year-2022-award-finalist/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "Joanne Smith named Innovator of the Year 2022 finalist", "datePublished": "2022-03-06T00:00:00+01:00", "dateModified": "2026-09-02T03:47:54+01:00", "mainEntityOfPage": { "@id": 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In this installment of TCC's Five-Minute Insights, digital strategist and FinTech expert Sabrina Del Prete discussed key findings from the Wealth and Asset Management 4.0 study. Sabrina, founder and CEO of Kore Labs, outlined how firms can use regulatory technology to bridge internal communication gaps, automate processes, and drive commercial efficiency. Rather than focusing exclusively on client-facing website menus, Sabrina urged firms to turn their digital transformation focus inwards to address root-cause operational inefficiencies that impact client experiences later in the journey. #### Why does it matter? Embedding compliance directly into internal workflows is a critical buffer against rising regulatory demands. By hard-wiring rules into active operating systems rather than performing manual checklists at the end of a transaction, firms can dramatically reduce human error. Furthermore, RegTech offers a dynamic, flexible framework. As regulations change, digital systems can be updated instantly, ensuring compliance frameworks remain resilient and future-proof across the entire organization. #### Who is affected? This update is highly relevant for digital transformation officers, compliance directors, and senior management within wealth and asset management firms. #### Key risks - **Superficial Digitisation:** Pouring resources into customer-facing platforms while leaving fragmented, inefficient, and manual back-office compliance processes untouched. - **Manual Checklists:** Relying on retrospective, post-transaction tick-box compliance that remains highly vulnerable to human error. - **Insular Compliance:** Facing changing global regulations in isolation rather than leveraging collaborative, crowd-sourced digital platforms and shared best practices. #### Actions to take 1. **Pivot Digital Focus:** Direct digital transformation budgets inwards to streamline and automate core back-office compliance processes. 2. **Hard-wire Compliance:** Integrate regulatory requirements directly into day-to-day transaction workflows instead of using retrospective reviews. 3. **Deploy Flexible Tech:** Partner with agile RegTech providers whose systems can be updated dynamically as regulatory expectations evolve. 4. **Collaborate Externally:** Leverage shared industry platforms to gather insights from peer firms and apply crowd-sourced compliance best practices. #### Wider implications Regulators globally are aligning on data-led, proactive expectations. Wealth managers must adapt by transitioning from passive compliance frameworks to active, technology-driven business models. #### Recommendations Firms should audit their operational workflows to identify where manual processes can be replaced with embedded compliance rules, maximizing efficiency and accuracy. #### Supporting sources - [Five-Minute Insights: Embedding Compliance with RegTech](https://tcc.group/blog/2022/02/21/five-minute-insights-embedding-compliance-with-regtech/) (2022-02-21) #### Ready to hard-wire compliance into your operations? Unlock operational efficiency and future-proof your compliance frameworks with our specialized RegTech advisory and delivery team. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due diligence", "financial crime controls" ], "brand": [ { "@type": "Brand", "name": "TCC", "url": "https://tcc.group/" }, { "@type": "Brand", "name": "Recordsure", "url": "https://recordsure.com/" }, { "@type": "Brand", "name": "Momenta", "url": "https://momentagroup.com/" } ], "subOrganization": [ { "@type": "Organization", "@id": "https://recordsure.com/#organization", "name": "Recordsure", "legalName": "Record Sure Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08279232" }, "url": "https://recordsure.com/" }, { "@type": "Organization", "@id": "https://momentagroup.com/#organization", "name": "Momenta Group", "legalName": "Momenta Interim Management Limited", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "08465864" }, "url": "https://momentagroup.com/" } ], "sameAs": [ "https://www.linkedin.com/company/tcc.group" ], "logo": { "@type": "ImageObject", "@id": "https://tcc.group/#logo", "url": "https://tcc.group/wp-content/uploads/2026/07/TCC_Master_Logo_RGB-.png" }, "@context": "https://schema.org" }, { "@type": "WebSite", "@id": "https://tcc.group/#website", "url": "https://tcc.group/", "name": "tcc.group", "description": "", "publisher": { "@id": "https://tcc.group/#organization" }, "potentialAction": { "@type": "SearchAction", "target": { "@type": "EntryPoint", "urlTemplate": "https://tcc.group/?s={search_term_string}" }, "query-input": "required name=search_term_string" } }, { "@type": "BreadcrumbList", "@id": "https://tcc.group/insights/press-releases/five-minute-insights-embedding-compliance-with-regtech/#breadcrumb", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://tcc.group/" }, { "@type": "ListItem", "position": 2, "name": "Insights", "item": "https://tcc.group/insights/" }, { "@type": "ListItem", "position": 3, "name": "Five-Minute Insights: Embedding Compliance with RegTech", "item": "https://tcc.group/insights/press-releases/five-minute-insights-embedding-compliance-with-regtech/" } ] }, { "@type": "WebPage", "@id": "https://tcc.group/insights/press-releases/five-minute-insights-embedding-compliance-with-regtech/#webpage", "url": "https://tcc.group/insights/press-releases/five-minute-insights-embedding-compliance-with-regtech/", "name": "Five-Minute Insights: Embedding Compliance with RegTech", "isPartOf": { "@id": "https://tcc.group/#website" }, "inLanguage": "en-GB", "datePublished": "2022-02-21T00:00:00+01:00", "dateModified": "2026-09-02T03:47:45+01:00", "breadcrumb": { "@id": "https://tcc.group/insights/press-releases/five-minute-insights-embedding-compliance-with-regtech/#breadcrumb" }, "speakable": { "@type": "SpeakableSpecification", "cssSelector": [ ".tcc-speakable", ".entry-summary", ".wp-block-excerpt" ] } }, { "@type": "NewsArticle", "@id": "https://tcc.group/insights/press-releases/five-minute-insights-embedding-compliance-with-regtech/#article", "isPartOf": { "@id": "https://tcc.group/insights/press-releases/five-minute-insights-embedding-compliance-with-regtech/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "Five-Minute Insights: Embedding Compliance with RegTech", "datePublished": "2022-02-21T00:00:00+01:00", "dateModified": "2026-09-02T03:47:45+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/press-releases/five-minute-insights-embedding-compliance-with-regtech/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/f90d5e8b4c3f43ed949b9cf15f9b6f3d/thumbnail-1024-1388ff10fec50a6631e2e187deeec6d767c248b843a97ae3fc9a5dc186be4098.jpg", "description": "How can wealth and asset managers streamline compliance and improve client journeys through technology? FinTech expert Sabrina Del Prete shares key strategies on internal digital transformation and collaborative RegTech platforms.", "inLanguage": "en-GB", "articleBody": "FinTech strategist Sabrina Del Prete explains how wealth and asset managers can embed compliance directly into internal systems using RegTech to streamline processes and reduce human error.\n\nIn this installment of TCC's Five-Minute Insights, digital strategist and FinTech expert Sabrina Del Prete discussed key findings from the Wealth and Asset Management 4.0 study. Sabrina, founder and CEO of Kore Labs, outlined how firms can use regulatory technology to bridge internal communication gaps, automate processes, and drive commercial efficiency.\n\nRather than focusing exclusively on client-facing website menus, Sabrina urged firms to turn their digital transformation focus inwards to address root-cause operational inefficiencies that impact client experiences later in the journey.\n\nEmbedding compliance directly into internal workflows is a critical buffer against rising regulatory demands. By hard-wiring rules into active operating systems rather than performing manual checklists at the end of a transaction, firms can dramatically reduce human error.\n\nFurthermore, RegTech offers a dynamic, flexible framework. As regulations change, digital systems can be updated instantly, ensuring compliance frameworks remain resilient and future-proof across the entire organization.\n\nThis update is highly relevant for digital transformation officers, compliance directors, and senior management within wealth and asset management firms.\n\n\u2022 Superficial Digitisation: Pouring resources into customer-facing platforms while leaving fragmented, inefficient, and manual back-office compliance processes untouched.\n\u2022 Manual Checklists: Relying on retrospective, post-transaction tick-box compliance that remains highly vulnerable to human error.\n\u2022 Insular Compliance: Facing changing global regulations in isolation rather than leveraging collaborative, crowd-sourced digital platforms and shared best practices.\n\n1. Pivot Digital Focus: Direct digital transformation budgets inwards to streamline and automate core back-office compliance processes.\n2. Hard-wire Compliance: Integrate regulatory requirements directly into day-to-day transaction workflows instead of using retrospective reviews.\n3. Deploy Flexible Tech: Partner with agile RegTech providers whose systems can be updated dynamically as regulatory expectations evolve.\n4. Collaborate Externally: Leverage shared industry platforms to gather insights from peer firms and apply crowd-sourced compliance best practices.\n\nRegulators globally are aligning on data-led, proactive expectations. Wealth managers must adapt by transitioning from passive compliance frameworks to active, technology-driven business models.\n\nFirms should audit their operational workflows to identify where manual processes can be replaced with embedded compliance rules, maximizing efficiency and accuracy.", "wordCount": 364, "keywords": [ "Compliance AI & RegTech", "Regulatory Change & Transformation", "Suitability, Advice Quality & File Reviews", "Banking", "General Insurance & Protection", "Lending & Consumer Credit", "Motor Finance", "Payments & FinTech", "Pensions & Retirement Income", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Regulatory Change & Transformation", "url": "https://tcc.group/blog/solution/regulatory-change-transformation/" }, { "@type": "Thing", "name": "Suitability, Advice Quality & File Reviews", "url": "https://tcc.group/blog/solution/outsourced-suitability-reviews/" }, { "@type": "Thing", "name": "Banking", "url": "https://tcc.group/blog/sector/banking/" }, { "@type": "Thing", "name": "General Insurance & Protection", "url": "https://tcc.group/blog/sector/general-insurance-protection/" }, { "@type": "Thing", "name": "Lending & Consumer Credit", "url": "https://tcc.group/blog/sector/lending-consumer-credit/" }, { "@type": "Thing", "name": "Motor Finance", "url": "https://tcc.group/blog/sector/motor-finance/" }, { "@type": "Thing", "name": "Payments & FinTech", "url": "https://tcc.group/blog/sector/payments-fintech/" }, { "@type": "Thing", "name": "Pensions & Retirement Income", "url": "https://tcc.group/blog/sector/pensions-retirement-income/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Compliance RegTech" } ], "articleSection": [ "Compliance AI & RegTech", "Regulatory Change & Transformation", "Suitability, Advice Quality & File Reviews" ], "audience": [ { "@type": "Audience", "audienceType": "Banking" }, { "@type": "Audience", "audienceType": "General Insurance & Protection" }, { "@type": "Audience", "audienceType": "Lending & Consumer Credit" }, { "@type": "Audience", "audienceType": "Motor Finance" }, { "@type": "Audience", "audienceType": "Payments & FinTech" }, { "@type": "Audience", "audienceType": "Pensions & Retirement Income" }, { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Operations leaders, digital transformation directors, and compliance teams in financial services." } ], "citation": [ { "@type": "CreativeWork", "name": "Five-Minute Insights: Embedding Compliance with RegTech", "url": "https://tcc.group/blog/2022/02/21/five-minute-insights-embedding-compliance-with-regtech/", "datePublished": "2022-02-21" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/press-releases/five-minute-insights-embedding-compliance-with-regtech/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/press-releases/five-minute-insights-embedding-compliance-with-regtech/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What is the primary risk of superficial digital transformation?", "acceptedAnswer": { "@type": "Answer", "text": "Firms risk having an attractive website front-end while deep internal inefficiencies and manual compliance processes continue to create errors and poor client outcomes." } }, { "@type": "Question", "name": "How does RegTech reduce human error in compliance?", "acceptedAnswer": { "@type": "Answer", "text": "RegTech hard-wires regulatory rules directly into the workflow, automating checks so compliance is achieved during the process rather than checked at the end." } }, { "@type": "Question", "name": "How can collaborative platforms help firms adapt to regulation?", "acceptedAnswer": { "@type": "Answer", "text": "Shared digital platforms allow firms to work collaboratively through adjustment phases, sharing best practices and benefiting from the 'wisdom of the crowd'." } } ] } ] } ``` ### How advisers can balance digital innovation and human relationships - URL: https://tcc.group/insights/analysis-perspectives/how-advisers-can-balance-digital-innovation-and-human-relationships/ - Published: 2022-02-09 - Modified: 2026-09-02 **Topic:** Digital and Human Advice TCC and Recordsure CEO Joe Norburn shares insights in Money Marketing on how financial advisers can balance digital communication tools with a personalized human touch. #### What happened? In an article published in Money Marketing, TCC and Recordsure Group CEO Joe Norburn examined how financial advice firms are navigating the shift to digital customer engagement, which has rapidly become the standard in financial services. #### Why does it matter? While digital platforms offer unparalleled convenience and efficiency, maintaining the 'human touch' remains critical for building trust, understanding complex client needs, and supporting vulnerable customers who may struggle with purely digital interfaces. #### Supporting sources - [How advisers can balance digital innovation and human relationships](https://tcc.group/blog/2022/02/10/how-advisers-can-balance-digital-innovation-and-human-relationships/) (2022-02-10) #### Need to balance digital innovation with compliant advice? Speak to our specialists to explore how our compliance advisory and RegTech solutions can help you integrate digital tools while preserving the vital human element. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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platforms with the essential 'human element' to maintain strong client relationships and meet regulatory customer support standards.", "inLanguage": "en-GB", "articleBody": "TCC and Recordsure CEO Joe Norburn shares insights in Money Marketing on how financial advisers can balance digital communication tools with a personalized human touch.\n\nIn an article published in Money Marketing, TCC and Recordsure Group CEO Joe Norburn examined how financial advice firms are navigating the shift to digital customer engagement, which has rapidly become the standard in financial services.\n\nWhile digital platforms offer unparalleled convenience and efficiency, maintaining the 'human touch' remains critical for building trust, understanding complex client needs, and supporting vulnerable customers who may struggle with purely digital interfaces.", "wordCount": 93, "keywords": [ "Compliance AI & RegTech", "Consumer Duty", "Vulnerable Customers", "Wealth Management & Financial Advice" ], "about": [ 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platforms for routine administrative tasks while reserving direct human interaction for complex advice, planning, and high-value customer support." } } ] } ] } ``` ### Why a holistic approach is the future for advisers and wealth managers - URL: https://tcc.group/insights/analysis-perspectives/why-a-holistic-approach-is-the-future-for-advisers-and-wealth-managers/ - Published: 2022-01-13 - Modified: 2026-09-02 **Topic:** Holistic Advice Approach New industry research shows clients want more digital access and choice, but the study argues advisers should respond with a holistic, stage-of-life approach rather than demographic segmentation. #### What happened? The Wealth and Asset Management 4.0 study found that firms now expect up to three-quarters of client interactions to be conducted digitally within two years, while 40% of investors view digital access as a priority. Around 39% of investors already look to their chosen firm for goal-based financial advice, with demand for retirement, next-generation succession and real-estate investment planning advice expected to rise by roughly 10% over the next two years. Over one-third of firms reported a high return on investment from digital channels, and 89% of investors singled out mobile apps as their preferred medium of interaction. #### Why does it matter? The research suggests success lies in advisers embracing a holistic approach to helping clients achieve their overall life goals, rather than relying on static demographic labels such as ‘mass-affluent’ or ‘UHNW’. Asking ‘where are they in their journey?’ rather than ‘who are they on paper?’ produces more nuanced, higher-quality advice, and encourages more robust fact-finding rather than advice built on demographic assumptions. #### Who is affected? Financial planning and wealth management firms adapting their client segmentation, digital channels and compliance processes to a changing market. #### Key risks - Relying on static demographic labels rather than life-stage needs, producing less nuanced advice. - Losing the strength of the client-adviser relationship as digital-first services expand. - Blurring the distinction between advised and non-advised transactions as digital models evolve. - Manual, administrative compliance processes failing to keep pace with rising client demand and squeezed budgets. #### Actions to take 1. Build a client-centric culture, with senior management visibly leading a people-focused, purpose-led business strategy. 2. Put in place a robust compliance framework that reflects the distinction between advised and non-advised transactions. 3. Automate manual, administrative compliance tasks, including case file reviews and SMCR obligations. 4. Widen the product and channel portfolio to match rising client demand for choice and digital access. #### Wider implications As digital delivery becomes the default across the industry, the real differentiator for advice firms will be the quality of the holistic, human layer built on top of digital capability, not digital investment alone. #### Recommendations TCC can help firms improve their organisational culture, navigate the regulatory distinction between advised and non-advised transactions, and use smart RegTech to make case file reviews and other compliance processes more efficient. #### Supporting sources - [Why a holistic approach is the future for advisers and wealth managers](https://tcc.group/blog/2022/01/14/why-a-holistic-approach-is-the-future-for-advisers-and-wealth-managers/) (2022-01-14) #### Ready to modernise your advice model? Speak to our advisory team about building a holistic, compliant advice model that balances digital efficiency with the human relationship clients still value. [Speak to our team](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory 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study points advisers toward a holistic, stage-of-life approach to advice, and what building client-centric culture, compliance and digital capability actually requires.", "inLanguage": "en-GB", "articleBody": "New industry research shows clients want more digital access and choice, but the study argues advisers should respond with a holistic, stage-of-life approach rather than demographic segmentation.\n\nThe Wealth and Asset Management 4.0 study found that firms now expect up to three-quarters of client interactions to be conducted digitally within two years, while 40% of investors view digital access as a priority.\n\nAround 39% of investors already look to their chosen firm for goal-based financial advice, with demand for retirement, next-generation succession and real-estate investment planning advice expected to rise by roughly 10% over the next two years. Over one-third of firms reported a high return on investment from digital channels, and 89% of investors singled out mobile apps as their preferred medium of interaction.\n\nThe research suggests success lies in advisers embracing a holistic approach to helping clients achieve their overall life goals, rather than relying on static demographic labels such as \u2018mass-affluent\u2019 or \u2018UHNW\u2019.\n\nAsking \u2018where are they in their journey?\u2019 rather than \u2018who are they on paper?\u2019 produces more nuanced, higher-quality advice, and encourages more robust fact-finding rather than advice built on demographic assumptions.\n\nFinancial planning and wealth management firms adapting their client segmentation, digital channels and compliance processes to a changing market.\n\n\u2022 Relying on static demographic labels rather than life-stage needs, producing less nuanced advice.\n\u2022 Losing the strength of the client-adviser relationship as digital-first services expand.\n\u2022 Blurring the distinction between advised and non-advised transactions as digital models evolve.\n\u2022 Manual, administrative compliance processes failing to keep pace with rising client demand and squeezed budgets.\n\n1. 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Widen the product and channel portfolio to match rising client demand for choice and digital access.\n\nAs digital delivery becomes the default across the industry, the real differentiator for advice firms will be the quality of the holistic, human layer built on top of digital capability, not digital investment alone.\n\nTCC can help firms improve their organisational culture, navigate the regulatory distinction between advised and non-advised transactions, and use smart RegTech to make case file reviews and other compliance processes more efficient.", "wordCount": 389, "keywords": [ "Compliance AI & RegTech", "Suitability, Advice Quality & File Reviews", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Suitability, Advice Quality & File Reviews", "url": "https://tcc.group/blog/solution/outsourced-suitability-reviews/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Holistic Advice Approach" } ], "articleSection": [ "Compliance AI & RegTech", "Suitability, Advice Quality & File Reviews" ], "audience": [ { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Advice and wealth management firms rethinking client segmentation, digital channels and compliance processes." } ], "citation": [ { "@type": "CreativeWork", "name": "Why a holistic approach is the future for advisers and wealth managers", "url": "https://tcc.group/blog/2022/01/14/why-a-holistic-approach-is-the-future-for-advisers-and-wealth-managers/", "datePublished": "2022-01-14" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/analysis-perspectives/why-a-holistic-approach-is-the-future-for-advisers-and-wealth-managers/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/why-a-holistic-approach-is-the-future-for-advisers-and-wealth-managers/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What does a \u201cholistic approach\u201d mean in this context?", "acceptedAnswer": { "@type": "Answer", "text": "Advising clients based on where they are in their life journey and goals, rather than static demographic categories like \u2018mass-affluent\u2019 or \u2018UHNW\u2019." } }, { "@type": "Question", "name": "Are clients moving away from wanting human advisers?", "acceptedAnswer": { "@type": "Answer", "text": "No; the research found hybrid human-digital models are growing, but the human relationship remains important even as digital access becomes a priority for many investors." } }, { "@type": "Question", "name": "What compliance challenge does a digital-first advice model create?", "acceptedAnswer": { "@type": "Answer", "text": "Firms need to understand the regulatory distinction between advised and non-advised transactions to protect clients and their own business." } }, { "@type": "Question", "name": "How can firms free up capacity to focus on holistic advice?", "acceptedAnswer": { "@type": "Answer", "text": "By automating manual, administrative compliance tasks such as case file reviews and streamlining SMCR obligations." } } ] } ] } ``` ### How RegTech is reshaping compliance for the digital era - URL: https://tcc.group/insights/analysis-perspectives/how-regtech-is-reshaping-compliance-for-the-digital-era/ - Published: 2021-12-07 - Modified: 2026-09-02 **Topic:** RegTech Compliance TCC and Recordsure CEO Joe Norburn discusses in Financier Worldwide how RegTech has transitioned into an essential daily tool for modern compliance teams. #### What happened? Amid intensifying regulatory scrutiny and the digitisation demands accelerated by the pandemic, RegTech has transitioned from a novel luxury into an essential tool for compliance departments across financial services. Speaking to Financier Worldwide, TCC and Recordsure Group CEO Joe Norburn highlights the daily role of RegTech and explores how proactive businesses can capitalise on digital compliance tools to drive operational efficiencies. #### Why does it matter? Modern regulators demand granular, data-driven evidence of compliant customer outcomes. Traditional manual sampling is no longer sufficient to monitor thousands of complex digital customer interactions. Deploying advanced RegTech tools allows firms to gain complete oversight of conduct risks while reducing compliance costs. #### Supporting sources - [How RegTech is reshaping compliance for the digital era](https://tcc.group/blog/2021/12/08/how-regtech-is-reshaping-compliance-for-the-digital-era/) (2021-12-08) #### Ready to modernise your compliance with RegTech? Speak to our specialists to find out how our compliance AI and advisory solutions can streamline your oversight and de-risk your digital channels. [Talk to our team](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory 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In Money Marketing, TCC's Technical Director David Boyhan discussed the recent surge in equity release activity. He focused on the critical importance of evaluating long-term suitability and customer circumstances before recommending cash release from a property. #### Why does it matter? Equity release is a major, often irreversible financial decision with significant long-term implications for consumers and their families. Assessing suitability requires deep customer knowledge, clear communication of potential risks, and careful consideration of alternative later life lending options to prevent potential customer harm. #### Supporting sources - [Suitability and Equity Release: How well do you know your client?](https://tcc.group/blog/2021/11/24/suitability-and-equity-release-how-well-do-you-know-your-client/) (2021-11-24) #### Are you confident in your equity release suitability? Speak to our suitability and file review experts to discover how our independent audits can strengthen your advice quality and compliance frameworks. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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The Wealth and Asset Management 4.0 study, led by ThoughtLab in collaboration with TCC, Recordsure and several other financial services firms, has published findings on how the COVID-19 pandemic has changed investor expectations. The research is based on a global survey of 2,325 investors and a separate survey of 500 investment advisory groups, private banks, trust companies, broker-dealers, robo-advisors, family offices and institutional and alternative asset management firms. The study identifies six shifts: a move to digital channels, with 40% of investors saying digital access has become a greater priority and nine in ten preferring mobile as their channel; growing demand for ESG and purpose-led investing, with 34% of investors expected to seek ESG advice over the next two years; and a democratisation of products previously reserved for wealthier clients, with 67% of investors wanting access to alternatives. The remaining shifts cover higher standards for firms acting in clients' best interests, demand for lower fees and greater transparency, with only 37% of investors satisfied with provider fees, and a willingness among investors to switch providers, with 44% planning to move a significant proportion of their funds over the next two years. #### Why does it matter? TCC Head of Culture Olivia Fahy said the findings show that wealth and asset management firms now face pressure from investors across generations to demonstrate a credible ESG offering, and that interest in ESG spans age groups and wealth levels rather than being limited to younger investors. The study suggests that fee transparency and demonstrating client-focused conduct are becoming as significant to investors as investment performance, which has implications for how firms structure their charges and communicate with clients. #### Who is affected? The findings are most relevant to wealth and asset management firms reviewing their digital capability, ESG proposition, fee structures and client segmentation, particularly firms whose client base spans multiple generations and wealth levels. #### Key risks - Investors switching providers: the study found that a third of investors moved 20% or more of their funds to another provider in the past year, with 44% planning to do so over the next two years. - Fee dissatisfaction: only 37% of investors reported being happy with their provider's fees, and 36% with fee structures. - Advisor-led attrition: 62% of investors said they were likely or very likely to leave a firm to follow their financial adviser. #### Actions to take 1. Review digital access and mobile channels against the finding that nine in ten investors prefer mobile as their primary channel. 2. Assess the firm's ESG and purpose-led investing proposition across client segments, given that ESG interest was reported across age groups rather than concentrated among younger investors. 3. Review fee structures and transparency of charges, given reported dissatisfaction levels among surveyed investors. 4. Consider client segmentation and product access, given rising demand from a wider range of investors for products such as alternatives and IPOs. #### Wider implications TCC and Recordsure Group CEO Joe Norburn described the pace of change in the sector as significant, noting that investors now have a wider range of channels through which to engage with their advisers. The study was also sponsored by Deloitte, eToro, FIS, Salesforce, Appway, HCL, LexisNexis Risk Solutions, Publicis Sapient and Refinitiv, indicating broad industry interest in the findings. The combination of digital adoption, ESG demand and fee scrutiny suggests firms may need to reconsider client segmentation and go-to-market strategy rather than treating these as separate, isolated trends. #### Recommendations The study suggests firms should take a more client-centric approach focused on individual circumstances rather than broad demographic assumptions, reflected in its finding that almost two-thirds of providers plan to offer alternatives over the next two years and more than half plan to offer goals-based planning. Firms that have invested in digital transformation reported average increases in productivity of 13.8%, assets under management of 8.1% and revenue of 7.7%, according to the study, which may be a relevant benchmark for firms planning their own digital investment. #### Supporting sources - [Global study, supported by TCC and Recordsure, reveals six](https://tcc.group/blog/2021/11/04/tcc-recordsure-global-wealth-asset-management-study-post-pandemic-changes/) (2021-11-04) #### Want to discuss the study's findings for your firm? Contact our team to talk through what these investor trends mean for your proposition and pricing. 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"@id": "https://tcc.group/insights/analysis-perspectives/tcc-recordsure-global-wealth-asset-management-study-post-pandemic-changes/#article", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/tcc-recordsure-global-wealth-asset-management-study-post-pandemic-changes/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "Global study, supported by TCC and Recordsure, reveals six", "datePublished": "2021-11-04T00:00:00+01:00", "dateModified": "2021-11-04T00:00:00+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/analysis-perspectives/tcc-recordsure-global-wealth-asset-management-study-post-pandemic-changes/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/6c1076127a404e42b165e890edf5f053/thumbnail-1024-0cce6f7a965804f1d6f49c0046e1508e661608bf044d4b4fd5005a5e6c4fdaaa.jpg", "description": "A global study backed by TCC and Recordsure identifies six shifts reshaping wealth and asset management after the pandemic, from rising demand for digital access to greater scrutiny of fees, transparency and ESG credentials.", "inLanguage": "en-GB", "articleBody": "A global study of wealth managers, supported by TCC and Recordsure, identifies six shifts in investor expectations following the COVID-19 pandemic, covering digital access, ESG, fees and transparency.\n\nThe Wealth and Asset Management 4.0 study, led by ThoughtLab in collaboration with TCC, Recordsure and several other financial services firms, has published findings on how the COVID-19 pandemic has changed investor expectations. The research is based on a global survey of 2,325 investors and a separate survey of 500 investment advisory groups, private banks, trust companies, broker-dealers, robo-advisors, family offices and institutional and alternative asset management firms.\n\nThe study identifies six shifts: a move to digital channels, with 40% of investors saying digital access has become a greater priority and nine in ten preferring mobile as their channel; growing demand for ESG and purpose-led investing, with 34% of investors expected to seek ESG advice over the next two years; and a democratisation of products previously reserved for wealthier clients, with 67% of investors wanting access to alternatives.\n\nThe remaining shifts cover higher standards for firms acting in clients' best interests, demand for lower fees and greater transparency, with only 37% of investors satisfied with provider fees, and a willingness among investors to switch providers, with 44% planning to move a significant proportion of their funds over the next two years.\n\nTCC Head of Culture Olivia Fahy said the findings show that wealth and asset management firms now face pressure from investors across generations to demonstrate a credible ESG offering, and that interest in ESG spans age groups and wealth levels rather than being limited to younger investors.\n\nThe study suggests that fee transparency and demonstrating client-focused conduct are becoming as significant to investors as investment performance, which has implications for how firms structure their charges and communicate with clients.\n\nThe findings are most relevant to wealth and asset management firms reviewing their digital capability, ESG proposition, fee structures and client segmentation, particularly firms whose client base spans multiple generations and wealth levels.\n\n\u2022 Investors switching providers: the study found that a third of investors moved 20% or more of their funds to another provider in the past year, with 44% planning to do so over the next two years.\n\u2022 Fee dissatisfaction: only 37% of investors reported being happy with their provider's fees, and 36% with fee structures.\n\u2022 Advisor-led attrition: 62% of investors said they were likely or very likely to leave a firm to follow their financial adviser.\n\n1. Review digital access and mobile channels against the finding that nine in ten investors prefer mobile as their primary channel.\n2. Assess the firm's ESG and purpose-led investing proposition across client segments, given that ESG interest was reported across age groups rather than concentrated among younger investors.\n3. Review fee structures and transparency of charges, given reported dissatisfaction levels among surveyed investors.\n4. Consider client segmentation and product access, given rising demand from a wider range of investors for products such as alternatives and IPOs.\n\nTCC and Recordsure Group CEO Joe Norburn described the pace of change in the sector as significant, noting that investors now have a wider range of channels through which to engage with their advisers. The study was also sponsored by Deloitte, eToro, FIS, Salesforce, Appway, HCL, LexisNexis Risk Solutions, Publicis Sapient and Refinitiv, indicating broad industry interest in the findings.\n\nThe combination of digital adoption, ESG demand and fee scrutiny suggests firms may need to reconsider client segmentation and go-to-market strategy rather than treating these as separate, isolated trends.\n\nThe study suggests firms should take a more client-centric approach focused on individual circumstances rather than broad demographic assumptions, reflected in its finding that almost two-thirds of providers plan to offer alternatives over the next two years and more than half plan to offer goals-based planning.\n\nFirms that have invested in digital transformation reported average increases in productivity of 13.8%, assets under management of 8.1% and revenue of 7.7%, according to the study, which may be a relevant benchmark for firms planning their own digital investment.", "wordCount": 670, "keywords": [ "Compliance AI & RegTech", "Regulatory Change & Transformation", "Wealth Management & Financial Advice" ], "about": [ { "@type": "Thing", "name": "Compliance AI & RegTech", "url": "https://tcc.group/blog/solution/compliance-ai-regtech/" }, { "@type": "Thing", "name": "Regulatory Change & Transformation", "url": "https://tcc.group/blog/solution/regulatory-change-transformation/" }, { "@type": "Thing", "name": "Wealth Management & Financial Advice", "url": "https://tcc.group/blog/sector/wealth-management-financial-advice/" }, { "@type": "Thing", "name": "Wealth Management Investor Trends" } ], "articleSection": [ "Compliance AI & RegTech", "Regulatory Change & Transformation" ], "audience": [ { "@type": "Audience", "audienceType": "Wealth Management & Financial Advice" }, { "@type": "Audience", "audienceType": "Leaders at wealth and asset management firms reviewing client proposition and pricing." } ], "citation": [ { "@type": "CreativeWork", "name": "Global study, supported by TCC and Recordsure, reveals six", "url": "https://tcc.group/blog/2021/11/04/tcc-recordsure-global-wealth-asset-management-study-post-pandemic-changes/", "datePublished": "2021-11-04" } ] }, { "@type": "FAQPage", "@id": "https://tcc.group/insights/analysis-perspectives/tcc-recordsure-global-wealth-asset-management-study-post-pandemic-changes/#faqpage", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/tcc-recordsure-global-wealth-asset-management-study-post-pandemic-changes/#webpage" }, "inLanguage": "en-GB", "mainEntity": [ { "@type": "Question", "name": "What is the Wealth and Asset Management 4.0 study?", "acceptedAnswer": { "@type": "Answer", "text": "It is a global study led by ThoughtLab, in collaboration with TCC, Recordsure and other financial services firms, examining how COVID-19 changed investor expectations in wealth and asset management." } }, { "@type": "Question", "name": "How many investors and firms were surveyed?", "acceptedAnswer": { "@type": "Answer", "text": "The study was based on a survey of 2,325 investors and a separate survey of 500 investment advisory groups, private banks, trust companies, broker-dealers, robo-advisors, family offices and institutional and alternative asset management firms." } }, { "@type": "Question", "name": "What are the six shifts identified by the study?", "acceptedAnswer": { "@type": "Answer", "text": "The study identifies a shift to digital channels, growing ESG and purpose-led investing, democratisation of products, higher standards for client outcomes, demand for lower fees and greater transparency, and investors' willingness to switch providers." } }, { "@type": "Question", "name": "Who sponsored the study?", "acceptedAnswer": { "@type": "Answer", "text": "In addition to TCC Group and Recordsure, the study was sponsored by Deloitte, eToro, FIS, Salesforce, Appway, HCL, LexisNexis Risk Solutions, Publicis Sapient and Refinitiv." } } ] } ] } ``` ### How has the contingent charging ban impacted the advice industry? - URL: https://tcc.group/insights/analysis-perspectives/how-has-the-contingent-charging-ban-impacted-the-advice-industry/ - Published: 2021-07-07 - Modified: 2026-09-02 **Topic:** Contingent Charging Ban TCC Technical Director David Boyhan comments in FT Adviser on the impact of the contingent charging ban and evolving suitability standards in the DB pension transfer market. #### What happened? David Boyhan, Technical Director at TCC, spoke with FT Adviser to discuss the effects of the FCA's contingent charging ban on the Defined Benefit (DB) pension transfer advisory market. David argues that while conversion rates from contingent-charging firms historically justified the regulator's intervention, the recent rise in advice suitability has been primarily driven by firms developing a deeper, more mature comprehension of the FCA's overall expectations. #### Why does it matter? While the market for DB pension transfers has contracted, David explains this is not solely due to the ban itself; many firms withdrew from the market earlier due to heightened regulatory scrutiny. The ban reinforces the transition toward fee structures that remove conflicts of interest, aligning advice with customer outcomes. #### Supporting sources - [How has the contingent charging ban impacted the advice industry?](https://tcc.group/blog/2021/07/08/how-has-the-contingent-charging-ban-impacted-the-advice-industry/) (2021-07-08) #### Are your DB pension transfer reviews fully compliant? Speak to our suitability specialists today to learn how our advice quality file reviews and compliance advisory can safeguard your pension propositions. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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contingent charging ban and a clearer understanding of regulatory expectations have reshaped the DB pension transfer advice market.", "inLanguage": "en-GB", "articleBody": "TCC Technical Director David Boyhan comments in FT Adviser on the impact of the contingent charging ban and evolving suitability standards in the DB pension transfer market.\n\nDavid Boyhan, Technical Director at TCC, spoke with FT Adviser to discuss the effects of the FCA's contingent charging ban on the Defined Benefit (DB) pension transfer advisory market.\n\nDavid argues that while conversion rates from contingent-charging firms historically justified the regulator's intervention, the recent rise in advice suitability has been primarily driven by firms developing a deeper, more mature comprehension of the FCA's overall expectations.\n\nWhile the market for DB pension transfers has contracted, David explains this is not solely due to the ban itself; many firms withdrew from the market earlier due to heightened 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https://tcc.group/insights/analysis-perspectives/lessons-from-the-fcas-db-transfer-guidance/ - Published: 2021-05-19 - Modified: 2026-09-02 ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", 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TCC Group's James Marshall featured in Money Marketing, discussing why firms should be aiming to beat the FCA's expectations on risk management rather than simply meeting them. #### Why does it matter? Aiming only to meet minimum regulatory expectations leaves firms with little margin when those expectations rise or when supervisory scrutiny increases. Setting a higher internal bar for risk management gives firms more confidence that they can withstand closer examination. #### Supporting sources - [Why you need supercharged risk management](https://tcc.group/blog/2021/04/26/why-you-need-supercharged-risk-management/) (2021-04-26) #### Want risk management that exceeds FCA expectations? Speak to our risk and compliance specialists about strengthening your risk management framework beyond baseline requirements. [Get in touch](https://staging.tcc.group/contact/) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "Organization", "@id": "https://tcc.group/#organization", "name": "TCC Group", "legalName": "The Consulting Consortium Ltd", "url": "https://tcc.group/", "description": "TCC Group is the collective strength of TCC, Recordsure and Momenta: intelligent compliance, AI-driven RegTech and strategic resourcing for FCA-regulated financial services firms.", "identifier": { "@type": "PropertyValue", "propertyID": "Companies House", "value": "04144405" }, "address": { "@type": "PostalAddress", "streetAddress": "10 Lower Thames Street", "addressLocality": "London", "postalCode": "EC3R 6EN", "addressCountry": "GB" }, "telephone": "+44 20 3772 7230", "email": "hello@tcc.group", "areaServed": "GB", "knowsAbout": [ "FCA compliance", "Consumer Duty assurance", "Section 166 skilled person reviews", "motor finance redress", "suitability reviews", "redress calculations", "regulatory due 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TCC was founded in 2001, when Joanne Smith left KPMG to set up a boutique compliance consultancy built on the belief that culture is central to good outcomes in financial services. The business grew quickly, opening a UK Operations Centre in Leeds within its first year to provide outsourced reviews, redress and complaint handling. A period of steady growth followed, including a rebrand, an acquisition and external investment. In 2015, TCC was named Compliance Consulting Firm of the Year at the Finance Monthly Global Awards, and by 2018 it had begun introducing RegTech into major client remediation projects. In 2020, TCC extended its reach beyond the UK with a launch in Australia, marking twenty years of continuous development in how the firm supports regulated firms. #### Why does it matter? TCC's history runs alongside two decades of regulatory change, from the formation of the FSA in response to concerns about self-regulation, through to the introduction of MiFID I and II and the Senior Managers and Certification Regime. Each shift required firms to make sense of larger and more complex rulebooks. Founding the business on the principle that culture underpins good conduct meant TCC's approach could adapt as expectations moved from rules-based compliance towards outcome-focused regulation, an emphasis that continues under today's regulatory agenda. #### Who is affected? The anniversary is relevant to financial services firms across wealth management, pensions, banking, lending, insurance, motor finance and payments who work with TCC's advisory, managed services, specialist resourcing or compliance AI and RegTech offerings, as well as firms considering a long-term compliance partner. #### Wider implications TCC frames its next phase around continued development of its RegTech capability, including High Performance Assurance and intelligent culture analytics, tools intended to help clients address past issues, strengthen present controls and protect future performance while extracting commercial value from compliance activity. Having become an international business in 2020, TCC's stated ambition is to keep introducing new technologies and services across the UK, Australia and further markets. #### Supporting sources - [20 years and counting: TCC's innovation journey](https://tcc.group/blog/2021/01/19/20-years-and-counting-tccs-innovation-journey/) (2021-01-19) #### Ready to talk about your compliance challenges? With two decades of regulatory experience behind us, get in touch to discuss how our advisory, managed services and RegTech capability could support your firm. 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URL: https://tcc.group/insights/analysis-perspectives/how-smart-firms-can-leverage-the-new-db-transfer-rules/ - Published: 2020-11-04 - Modified: 2026-09-02 **Topic:** DB Pension Transfers TCC's David Boyhan explains in Money Marketing how the FCA's revised Defined Benefit pension transfer rules represent a commercial and compliance opportunity for advisory firms. #### What happened? The FCA has introduced new, more stringent rules governing Defined Benefit (DB) pension transfers, aimed at protecting consumers from unsuitable advice. The changes include a ban on contingent charging structures for transfer advice, except in very narrow circumstances. Speaking to Money Marketing, TCC's David Boyhan argues that rather than being a purely restrictive measure, the new rules can benefit proactive firms as much as they benefit clients by setting a clearer standard for advice quality. #### Why does it matter? By removing the conflict of interest inherent in contingent charging, the new rules allow firms to evidence that their pension transfer recommendations are purely objective and in the client's best interests. This aligns perfectly with modern suitability requirements and can help firms rebuild regulatory confidence in this high-risk market sector. #### Supporting sources - [How smart firms can leverage the new DB transfer rules](https://tcc.group/blog/2020/11/05/how-smart-firms-can-leverage-the-new-db-transfer-rules/) (2020-11-05) #### Are your DB pension transfer reviews fully compliant? Speak to our suitability specialists today to learn how our advice quality file reviews and compliance advisory can safeguard your pension propositions. 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"https://tcc.group/insights/analysis-perspectives/how-smart-firms-can-leverage-the-new-db-transfer-rules/#article", "isPartOf": { "@id": "https://tcc.group/insights/analysis-perspectives/how-smart-firms-can-leverage-the-new-db-transfer-rules/#webpage" }, "author": { "@type": "Person", "name": "Kit Ruparel" }, "headline": "How smart firms can leverage the new DB transfer rules", "datePublished": "2020-11-05T00:00:00+01:00", "dateModified": "2026-09-02T03:47:51+01:00", "mainEntityOfPage": { "@id": "https://tcc.group/insights/analysis-perspectives/how-smart-firms-can-leverage-the-new-db-transfer-rules/#webpage" }, "publisher": { "@id": "https://tcc.group/#organization" }, "image": "https://assets.tcc.group/1c1c2f3a6e9a4a0a9b0f6ab6a1a1d8a1/bab604b54df044c28bba1e5a077af229/thumbnail-1024-c4bfc7223f018e09978e35d6904405ef8f0a084507b1acbd754a8b2e2a8d93f3.jpg", "description": "Discover how the FCA's new rules on Defined Benefit (DB) pension transfers can help proactive advice firms deliver higher-quality suitability and rebuild regulatory trust.", "inLanguage": "en-GB", "articleBody": "TCC's David Boyhan explains in Money Marketing how the FCA's revised Defined Benefit pension transfer rules represent a commercial and compliance opportunity for advisory firms.\n\nThe FCA has introduced new, more stringent rules governing Defined Benefit (DB) pension transfers, aimed at protecting consumers from unsuitable advice. The changes include a ban on contingent charging structures for transfer advice, except in very narrow circumstances.\n\nSpeaking to Money Marketing, TCC's David Boyhan argues that rather than being a purely restrictive measure, the new rules can benefit proactive firms as much as they benefit clients by setting a clearer standard for advice quality.\n\nBy removing the conflict of interest inherent in contingent charging, the new rules allow firms to evidence that their pension transfer recommendations are purely objective and in the client's best interests. 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A recognised leader within financial services, she continues to play a key role in shaping the Group's strategic direction and long-term vision. ```json { "@context": "https://schema.org", "@graph": [ { "@context": "https://schema.org", "@type": "Person", "@id": "https://profiles.tcc.group/4035f225e0bc472b8846485e699da163", "name": "Joanne Smith", "affiliation": [ "TCC Group" ], "sameAs": [ "https://www.linkedin.com/in/joanne-smith-7414947/", "https://www.grcworldforums.com/joanne-smith/5511.article", "https://axentia.co.uk/teammembers/joanne-smith/", "https://thefintechtimes.com/ai-queen-joanne-smith-ceo-recordsure/" ], "jobTitle": "Founder and Executive Chair", "worksFor": "TCC Group", "image": "https://profiles.tcc.group/media/e62c8472f9b14d0a953daad062b89719/thumbnail-320" } ] } ``` ### Joe Norburn - URL: https://tcc.group/meet-the-team/joe-norburn/ - Role: Group CEO, TCC and Recordsure Joe leads TCC Group and Recordsure, bringing extensive experience from senior leadership roles across financial services, banking and technology-enabled businesses. He is passionate about helping organisations respond to changing customer, regulatory and operational expectations. ```json { "@context": "https://schema.org", "@graph": [ { "@context": "https://schema.org", "@type": "Person", "@id": "https://profiles.tcc.group/df151edeae504e4fac4b7fb05c31ed2d", "name": "Joe Norburn", "affiliation": [ "TCC Group" ], "sameAs": [ "https://www.linkedin.com/in/joenorburn/" ], "jobTitle": "Group CEO, TCC and Recordsure", "worksFor": "TCC Group", "image": "https://profiles.tcc.group/media/50a4d62d858741fabd3c827d71a9cd88/thumbnail-320" } ] } ``` ### Garry Evans - URL: https://tcc.group/meet-the-team/garry-evans/ - Role: Chief Product & Commercial Officer Garry oversees commercial strategy, product innovation and business growth across the Group. With a strong background in fintech and technology-led businesses, he focuses on developing solutions that help clients solve complex regulatory and operational challenges. ```json { "@context": "https://schema.org", "@graph": [ { "@context": "https://schema.org", "@type": "Person", "@id": "https://profiles.tcc.group/1e65bada3c46483590bd2bb183a112e5", "name": "Garry Evans", "affiliation": [ "TCC Group" ], "sameAs": [ "https://www.linkedin.com/in/garryevans2020/" ], "jobTitle": "Chief Product & Commercial Officer", "worksFor": "TCC Group", "image": "https://profiles.tcc.group/media/954bd0c8691c46d2af225f565f6bb080/thumbnail-320" } ] } ``` ### Chris Matthews - URL: https://tcc.group/meet-the-team/chris-matthews/ - Role: Chief Information Officer (CIO) / Chief Information Security Officer (CISO) Chris leads technology operations, information security and digital transformation across the Group. His experience spans large-scale data, infrastructure and technology programmes in highly regulated environments. ```json { "@context": "https://schema.org", "@graph": [ { "@context": "https://schema.org", "@type": "Person", "@id": "https://profiles.tcc.group/b438ddaa234b45228e765bfbe93415c2", "name": "Chris Matthews", "affiliation": [ "TCC Group" ], "sameAs": [ "https://www.linkedin.com/in/cmatthewscio/" ], "jobTitle": "Chief Information Officer (CIO) / Chief Information Security Officer (CISO)", "worksFor": "TCC Group", "image": "https://profiles.tcc.group/media/1c2e51bd88444b4ba09f5ff52f5dddef/thumbnail-320" } ] } ``` ### Kit Ruparel - URL: https://tcc.group/meet-the-team/kit-ruparel/ - Role: Chief Technology Officer (CTO) Kit drives the development of TCC Group's technology strategy and engineering capability. He is responsible for ensuring our platforms and solutions remain secure, scalable and aligned to the evolving needs of our clients. ```json { "@context": "https://schema.org", "@graph": [ { "@context": "https://schema.org", "@type": "Person", "@id": "https://profiles.tcc.group/89a11a14de3e4eb0b278fd9c633413d9", "name": "Kit Ruparel", "affiliation": [ "TCC Group" ], "sameAs": [ "https://www.linkedin.com/in/kitruparel/" ], "jobTitle": "Chief Technology Officer (CTO)", "worksFor": "TCC Group", "image": "https://profiles.tcc.group/media/4a4d1f9c058441dc8f9ccea5d2ad0bf5/thumbnail-320" } ] } ``` ### Beverley Metcalfe - URL: https://tcc.group/meet-the-team/beverley-metcalfe/ - Role: Client Delivery Director Beverley leads strategic programme delivery across TCC, bringing extensive experience of large-scale remediation, transformation and operational initiatives within regulated businesses. ```json { "@context": "https://schema.org", "@graph": [ { "@context": "https://schema.org", "@type": "Person", "@id": "https://profiles.tcc.group/6ad36c403c54439d8561b319154f004c", "name": "Beverley Metcalfe", "affiliation": [ "TCC Group" ], "sameAs": [ "https://www.linkedin.com/in/bemetcalfe/" ], "jobTitle": "Client Delivery Director", "worksFor": "TCC Group", "image": "https://profiles.tcc.group/media/541f1ccc9ff349ee92e5dcec6c123ec8/thumbnail-320" } ] } ``` ### Anthony Harkess - URL: https://tcc.group/meet-the-team/anthony-harkess/ - Role: Client Account Director Anthony works closely with clients to identify and deliver specialist resource and project solutions. His experience spans resource strategy, account management and complex programme support. ```json { "@context": "https://schema.org", "@graph": [ { "@context": "https://schema.org", "@type": "Person", "@id": "https://profiles.tcc.group/c6e81941ca4248f8aa0e3c1d32fc6f18", "name": "Anthony Harkess", "affiliation": [ "TCC Group" ], "sameAs": [ "https://www.linkedin.com/in/anthonyharkess/" ], "jobTitle": "Client Account Director", "worksFor": "TCC Group", "image": "https://profiles.tcc.group/media/cb8a28dfcfb148bd9de1568b88bb21d9/thumbnail-320" } ] } ``` ### Jason Wintie - URL: https://tcc.group/meet-the-team/jason-wintie/ - Role: Head of Advisory Jason leads TCC's advisory practice, helping firms address regulatory obligations, governance requirements and conduct-related challenges across multiple sectors of financial services. ```json { "@context": "https://schema.org", "@graph": [ { "@context": "https://schema.org", "@type": "Person", "@id": "https://profiles.tcc.group/4d4e99ab0aca43aaa32a72253e4ae9a9", "name": "Jason Wintie", "affiliation": [ "TCC Group" ], "sameAs": [ "https://www.linkedin.com/in/jason-wintie/" ], "jobTitle": "Head of Advisory", "worksFor": "TCC Group", "image": "https://profiles.tcc.group/media/75506944ffeb41d8a5dfe9b0686f3cb0/thumbnail-320" } ] } ``` ### Judith Wright - URL: https://tcc.group/meet-the-team/judith-wright/ - Role: Technical Director Judith is a highly experienced compliance specialist whose expertise spans investments, pensions, mortgages, supervision and regulatory oversight. She provides technical leadership across a wide range of client engagements. ```json { "@context": "https://schema.org", "@graph": [ { "@context": "https://schema.org", "@type": "Person", "@id": "https://profiles.tcc.group/6260d665943f4c78a01517a8ee05d360", "name": "Judith Wright", "affiliation": [ "TCC Group" ], "sameAs": [ "https://www.linkedin.com/in/judith-wright/" ], "jobTitle": "Technical Director", "worksFor": "TCC Group", "image": "https://profiles.tcc.group/media/7136b026e3d34a0d919776b53696396c/thumbnail-320" } ] } ``` ### Neil Dethick - URL: https://tcc.group/meet-the-team/neil-dethick/ - Role: Associate Director Neil brings more than 25 years of financial services experience, specialising in remediation, redress, regulatory compliance and operational improvement programmes. ```json { "@context": "https://schema.org", "@graph": [ { "@context": "https://schema.org", "@type": "Person", "@id": "https://profiles.tcc.group/4ef1b999464d4837b4af04186c041be5", "name": "Neil Dethick", "affiliation": [ "TCC Group" ], "sameAs": [ "https://www.linkedin.com/in/neildethick/" ], "jobTitle": "Associate Director", "worksFor": "TCC Group", "image": "https://profiles.tcc.group/media/36ee7e9be0304e1cac38478644c14e13/thumbnail-320" } ] } ``` ### Harry Eastwood - URL: https://tcc.group/meet-the-team/harry-eastwood/ - Role: Actuarial & Redress Director A Fellow of the Institute and Faculty of Actuaries, Harry advises clients on actuarial matters, redress programmes and complex remediation projects, drawing on extensive experience across pensions and insurance. ```json { "@context": "https://schema.org", "@graph": [ { "@context": "https://schema.org", "@type": "Person", "@id": "https://profiles.tcc.group/5cdf77ef3a7349ccaae86250641a970e", "name": "Harry Eastwood", "affiliation": [ "TCC Group" ], "sameAs": [ "https://www.linkedin.com/in/heastwood/" ], "jobTitle": "Actuarial & Redress Director", "worksFor": "TCC Group", "image": "https://profiles.tcc.group/media/ed16e55cc9ea4d9f88c6993821d8f2bb/thumbnail-320" } ] } ``` ### Fida Dar - URL: https://tcc.group/meet-the-team/fida-dar/ - Role: Senior Technical Operations Manager Fida supports the delivery of client programmes and operational services, helping ensure projects are delivered efficiently, effectively and to the highest standards. ```json { "@context": "https://schema.org", "@graph": [ { "@context": "https://schema.org", "@type": "Person", "@id": "https://profiles.tcc.group/b84563be619d4b078797d5c32329b03f", "name": "Fida Dar", "affiliation": [ "TCC Group" ], "sameAs": [ "https://www.linkedin.com/in/fida-dar-741439185/" ], "jobTitle": "Senior Technical Operations Manager", "worksFor": "TCC Group", "image": "https://profiles.tcc.group/media/f93b370fa8334b6d956b42ad7d4a2649/thumbnail-320" } ] } ``` ### Sam Majumdar - URL: https://tcc.group/meet-the-team/sam-majumdar/ - Role: Senior Consultant Sam has extensive experience supporting remediation, conduct risk, regulatory review and transformation programmes across the financial services sector. ```json { "@context": "https://schema.org", "@graph": [ { "@context": "https://schema.org", "@type": "Person", "@id": "https://profiles.tcc.group/e8bad200c55d4677aa2327e6d497ab05", "name": "Sam Majumdar", "affiliation": [ "TCC Group" ], "sameAs": [ "https://www.linkedin.com/in/sam-majumdar-2981882/" ], "jobTitle": "Senior Consultant", "worksFor": "TCC Group", "image": "https://profiles.tcc.group/media/9ff315b709634667aa67200d98a32f0a/thumbnail-320" } ] } ``` ### Jana Robinson - URL: https://tcc.group/meet-the-team/jana-robinson/ - Role: Specialist Resourcing Jana helps clients access specialist regulatory and operational expertise by matching experienced professionals to complex programme and business requirements. ```json { "@context": "https://schema.org", "@graph": [ { "@context": "https://schema.org", "@type": "Person", "@id": "https://profiles.tcc.group/f606b387cb9844c29d25fee8f130e436", "name": "Jana Robinson", "affiliation": [ "TCC Group" ], "sameAs": [ "https://www.linkedin.com/in/jana-robinson-tcc/" ], "jobTitle": "Specialist Resourcing", "worksFor": "TCC Group", "image": "https://profiles.tcc.group/media/72b71013d26a4b6bad491cc1e2640b1e/thumbnail-320" } ] } ``` ### Victoria Mansbridge - URL: https://tcc.group/meet-the-team/victoria-mansbridge/ - Role: Head of Sales Operations Victoria leads sales operations and commercial support functions across the Group, helping ensure clients receive a seamless experience from initial engagement through to delivery. ```json { "@context": "https://schema.org", "@graph": [ { "@context": "https://schema.org", "@type": "Person", "@id": "https://profiles.tcc.group/50aa2b14d32e4444be0ca70b734db803", "name": "Victoria Mansbridge", "affiliation": [ "TCC Group" ], "sameAs": [ "https://www.linkedin.com/in/victoria-mansbridge-b5932716/" ], "jobTitle": "Head of Sales Operations", "worksFor": "TCC Group", "image": "https://profiles.tcc.group/media/642973d599f749ee9501b215e81dcc95/thumbnail-320" } ] } ``` ### Richard Lee - URL: https://tcc.group/meet-the-team/richard-lee/ - Role: Client Account Director Richard works with clients to identify how technology-enabled solutions can support compliance, governance and customer outcome objectives. ```json { "@context": "https://schema.org", "@graph": [ { "@context": "https://schema.org", "@type": "Person", "@id": "https://profiles.tcc.group/0b37ba1fb7be4866bd8b4f015de9a14d", "name": "Richard Lee", "affiliation": [ "TCC Group" ], "sameAs": [ "https://www.linkedin.com/in/richard-lee-saas-regtech/" ], "jobTitle": "Client Account Director", "worksFor": "TCC Group", "image": "https://profiles.tcc.group/media/2fc48316ac4f4212b621028cc8465ceb/thumbnail-320" } ] } ``` ### Hana Shackleton - URL: https://tcc.group/meet-the-team/hana-shackleton/ - Role: Group Marketing Director Hana leads the Group's marketing strategy, brand development, digital presence and thought leadership programmes across TCC, Recordsure and Momenta. ```json { "@context": "https://schema.org", "@graph": [ { "@context": "https://schema.org", "@type": "Person", "@id": "https://profiles.tcc.group/1b0abea806e44aaca86d09bd270fd479", "name": "Hana Shackleton", "affiliation": [ "TCC Group" ], "sameAs": [ "https://www.linkedin.com/in/hana-shackleton-8472016/" ], "jobTitle": "Group Marketing Director", "worksFor": "TCC Group", "image": "https://profiles.tcc.group/media/9ed359ac42b741efb2cc87dbbc96d085/thumbnail-320" } ] } ``` ### Rebecca Swiffen - URL: https://tcc.group/meet-the-team/rebecca-swiffen/ - Role: Head of People Rebecca leads the people strategy across the Group, helping attract, develop and retain talented individuals while supporting a positive and high-performing culture. ```json { "@context": "https://schema.org", "@graph": [ { "@context": "https://schema.org", "@type": "Person", "@id": "https://profiles.tcc.group/a2b8127724ec4f00889abfbe3bcffd2a", "name": "Rebecca Swiffen", "affiliation": [ "TCC Group" ], "sameAs": [ "https://www.linkedin.com/in/rebecca-swiffen/" ], "jobTitle": "Head of People", "worksFor": "TCC Group", "image": "https://profiles.tcc.group/media/f25174cc5bf7404d89c0e884ab5388cc/thumbnail-320" } ] } ``` ### Diane Turner - URL: https://tcc.group/meet-the-team/diane-turner/ - Role: Senior Campaign and Design Marketing Manager Diane Turner is Senior Campaign and Design Marketing Manager at TCC Group, contributing to the Group's thought leadership and editorial programme. ```json { "@context": "https://schema.org", "@graph": [ { "@context": "https://schema.org", "@type": "Person", "@id": "https://profiles.tcc.group/5a297546e4424f86a3992ff3afcd2e70", "name": "Diane Turner", "affiliation": [ "TCC Group" ], "sameAs": [], "jobTitle": "Senior Campaign and Design Marketing Manager", "worksFor": "TCC Group", "image": "https://profiles.tcc.group/media/1550df4c486e450db29eedf60b3b774c/thumbnail-320" } ] } ``` ### May York - URL: https://tcc.group/meet-the-team/may-york/ - Role: Marketing and Content Executive May York is Marketing and Content Executive at TCC Group, contributing to the Group's thought leadership and editorial programme. ```json { "@context": "https://schema.org", "@graph": [ { "@context": "https://schema.org", "@type": "Person", "@id": "https://profiles.tcc.group/7dc0d14aefda480984ddac4f8a71370c", "name": "May York", "affiliation": [ "TCC Group" ], "sameAs": [], "jobTitle": "Marketing and Content Executive", "worksFor": "TCC Group", "image": "https://profiles.tcc.group/media/9cec98fcc80848a180b86d85e56984eb/thumbnail-320" } ] } ```