When I started Money Wise UK and began helping IFA and financial planning firms, I did not expect the volume of papers, reviews, consultations and updates that would come out of the FCA.
At times, it can feel relentless.
Consumer Duty. Retirement income advice. Vulnerable clients. Client understanding. Advice Guidance Boundary Review. Targeted support. Sustainability. Non-financial misconduct. The list continues.
For some firms, the natural reaction is frustration. Another paper. Another process. Another checklist. Another thing to evidence.
I understand that. Running an advice business is hard enough. Advisers are trying to look after clients, manage teams, deal with platforms and providers, write reports, keep fees fair, grow the business and still have time to think strategically.
So when another FCA update lands, it can feel like regulation is getting in the way.
But I increasingly think that is the wrong way to look at it.
FCA Updates Are Not Just Regulation
Not every FCA paper creates a new rule. Not every good practice note means a firm has to immediately rebuild everything it does.
But FCA updates do tell us something important.
They show the direction of travel.
If you take the time to step back, read across the different papers and understand the common themes, you start to see what a good advice business should look like.
The themes are often consistent:
- Better evidence of client outcomes.
- Stronger governance.
- Clearer client communication.
- A deeper understanding of vulnerability.
- More robust retirement income advice.
- Better use of data.
- More focus on whether clients understand and value the service they receive.
That is not just compliance. That is business strategy.
Data Is King
One of the most important lessons I learnt during my time at LWM was that data is king.
I helped build the business. I built much of the data, the reporting and the insight that sat behind it. The business was eventually sold without my involvement. People can read into that whatever they want, but my own reflection is simple: the owners understood the value of the data that had been created.
Data told the story of the business.
It showed where the clients were. It showed where the assets were. It showed what income was recurring. It showed what the business was worth. It showed the risks, the opportunities and the direction of travel.
That lesson has stayed with me.
When I look at Consumer Duty, I do not see it simply as a compliance requirement. I see it as an opportunity for financial planning firms to better understand their clients and their business.
The FCA expects firms to assess, test, understand and evidence the outcomes their customers are receiving. That can sound regulatory, but in practice it asks a very simple question:
Do we really know what our clients are experiencing?
Consumer Duty Should Improve the Business
Good Consumer Duty work is not about producing a board report once a year and putting it in a folder.
It should help a firm answer important questions.
Are clients receiving the service they were promised?
Do they understand the advice they have received?
Are vulnerable clients being identified and supported properly?
Are certain groups of clients disengaging?
Are clients receiving fair value?
Are communications clear enough?
Are review meetings happening when they should?
Are clients happy with the service, or are we assuming they are?
This is where the data becomes powerful.
Some of the work I have been doing with clients recently has focused on understanding what clients feel, what they value and whether they are receiving the service they expect.
That information is incredibly rich.
It can confirm what a firm is doing well. It can highlight where the client experience is strong. But it can also reveal small gaps that the business can improve.
That should not be seen as a threat.
It should be seen as a gift.
Because if a business knows where clients are confused, disappointed, disengaged or underserved, it has an opportunity to act before the issue becomes bigger.
Retirement Income Advice Is a Good Example
Retirement is another area where FCA updates should not simply be seen as a burden.
The FCA’s work on retirement income advice has been clear in its direction of travel. Drawing a line between accumulation and decumulation is vital.
Helping clients build wealth is not the same as helping them draw an income from that wealth.
In accumulation, the focus is often on contributions, growth, tax allowances and long-term investment returns. In decumulation, the focus changes. The client may now be dependent on the portfolio. They may worry about running out of money. They may be more sensitive to market falls. They may need income flexibility, cashflow modelling, tax planning, emotional support and clearer conversations about trade-offs.
That is why retirement income advice needs its own framework.
It is not enough to simply take the accumulation investment process and apply it to retirement clients.
The questions change.
How much income is sustainable?
What happens if markets fall early in retirement?
How much cash should be held?
What level of withdrawal is realistic?
How should guaranteed income, pensions, ISAs and taxable assets be blended?
What happens if care costs arise?
How often should the plan be reviewed?
What are the warning signs that the strategy needs to change?
The FCA Retirement Income Advice Thematic Review may not be legislation in itself, but the good practice examples clearly show where firms should be paying attention.
For me, that creates an opportunity.
A well-designed Centralised Retirement Proposition is not just there to keep the regulator happy. It helps advisers deliver a more consistent, thoughtful and robust client experience.
Compliance Is a Form of Marketing
One thing I often come back to is a story from the early days of Hargreaves Lansdown.
The compliance and marketing teams were placed in the same room.
I think there is something powerful in that.
Compliance should not be seen as the business prevention department.
Good compliance protects clients. It protects the business. But it also helps a firm explain what it does, why it does it and how it delivers value.
In that sense, compliance is a form of marketing.
A firm that can clearly evidence its client outcomes, explain its service proposition, demonstrate fair value, support vulnerable clients, communicate clearly and deliver a structured retirement income process has a strong story to tell.
That story matters.
It matters to clients.
It matters to introducers.
It matters to potential buyers.
It matters to future employees.
It matters to the regulator.
It matters to the long-term value of the business.
The Best Firms Will See the Opportunity
I do not think adviser firms need to love every FCA update.
Some will feel repetitive. Some will feel theoretical. Some will require careful interpretation. Some will create more work.
But frustration should not be the end point.
The better question is:
What is this update telling us about the type of business we should be building?
For me, the strongest financial planning firms of the future will not be those that simply react to regulation. They will be the firms that use regulatory change as a prompt to improve.
They will use data better.
They will listen to clients more carefully.
They will evidence outcomes properly.
They will build stronger retirement processes.
They will improve communication.
They will challenge their own assumptions.
They will see compliance, governance, marketing and client experience as connected.
That is where the opportunity sits.
Final Thoughts
It is easy to be frustrated by FCA updates.
But I think we should be careful not to miss what sits beneath them.
Consumer Duty, retirement income advice, client understanding and vulnerability are not just regulatory themes. They are reminders of what good financial planning should already be trying to achieve.
Better outcomes. Better conversations. Better evidence. Better businesses.
That is why I try to look at FCA updates differently.
Not as noise.
Not as another burden.
But as clues.
Clues about where the profession is going.
Clues about what clients need.
Clues about how better advice businesses are built.
And for firms willing to engage with that, there is a real opportunity.
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