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WHAT THIS MEANS IN PRACTICE FOR ADVISERS & SUPPORT TEAMS
- Expect more focus on judgement, not checklists - firms should be prepared to explain why their advice processes deliver good outcomes, rather than simply showing rule compliance.
- Fact finds should be proportionate to the advice being given - advisers will be empowered to gather sufficient information to demonstrate suitability - not automatically complete full fact finds where they add little value.Â
- Suitability reports should help clients understand decisions - focusing on what is relevant and useful for the client, with clearer explanations that they're likely to read.
- Clearer treatment of risk and loss - firms should ensure advice clearly distinguishes between a client’s willingness to take risk and their ability to absorb losses.
- Ongoing services must clearly deliver value - annual suitability reviews may be replaced with more flexible, periodic reviews, if appropriate. Firms will need to justify review frequency and demonstrate that ongoing advice continues to meet Consumer Duty expectations.
Even though CP26/10 is a consultation, this is further stimulus for firms to assess whether their advice processes, documentation and ongoing services are genuinely consumer focused, proportionate and outcome driven -Â an opportunity for proportionality to deliver effective outcomes!
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FCA CONSULTATION ON MODERNISING REDRESSÂ
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The FCA also published proposals with the Financial Ombudsman Service to modernise the redress system, reinforcing firms’ Consumer Duty obligations to identify, escalate and remediate harm earlier.
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This paper emphasises firm‑led redress, clearer reporting of emerging issues to the FCA, and more consistent Ombudsman outcomes to improve predictability for firms and outcomes for consumers. It also signals support for introducing a long‑stop on referring complaints to the Ombudsman, to provide greater certainty around very historic claims, subject to consultation and legislation.Â
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ON TOUR WITH THE FCA - HEAR AND INTERACT DIRECTLY WITH YOUR REGULATOR
Our programme of 2026 conferences is a unique opportunity to hear directly from the regulator and demand is such that we had to bring in more seating for our recent Gatwick event.
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Sara Woodroffe, Head of Consumer Investments at the FCA, led the day with an update on the regulator’s new supervisory approach and the introduction of its Regulatory Priorities reports. She also spoke on targeted support and simplified advice and if you weren’t able to join us, you may like to watch this FTAdviser interview from the day.
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Our Manchester conference on 22nd April will showcase the first insights from the 2025 Adviser Survey, in a keynote from Nick Hulme, Head of Department at Consumer Investments, so this is an event you don’t want to miss - book your ticket here.
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THE SUCCESSION ALLIANCE LAUNCHES - EVERYONE NEEDS A SUCCESSION PLAN
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March saw the launch of our latest UK-wide taskforce focused on improving education, consistency and standards around succession planning for financial advice firms.
Chaired by Ben Wright from Melo, the board brings together senior leaders from across the succession ecosystem, with the intention of ensuring that the Alliance’s work is informed by a broad range of practical experience from those directly involved in succession decisions and transactions. Follow their new LinkedIn page to keep up to date with the latest news.
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DATA STRATEGY GUIDE AND CHECKLIST - FREE TO DOWNLOAD
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Our Consumer Duty Data Forum published its first resources for firms this month; a Good Practice Guide to Managing Your Data and an accompanying Data Strategy Checklist.
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They're both designed for firms taking their first or next steps in developing a proportionate data strategy framework that firms can use within Consumer Duty planning and operational reviews.
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CYBERSECURITY OVERVIEW, CHECKLIST AND PAPER - DOWNLOAD FOR FREEÂ
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We’ve also launched new cybersecurity support, in recognition of cyber risk as one of the most significant foreseeable harms facing advice firms.
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The Cybersecurity Checklist & Overview 2026 provides a plain English starting point to assess current controls and identify gaps, while the Cybersecurity Paper 2026 explores emerging threats, regulatory expectations and practical controls firms can implement immediately.Â
Very best wishes,
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Keith Richards, CEO, Consumer Duty Alliance