Seven key topics to ensure the success of your ongoing advisory reviews

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

  1. Seven key topics to ensure the success of your ongoing advisory reviews

Frequently asked questions

What are the seven topics in TCC's ongoing advice guide?

They cover the customer journey, proactive delivery of ongoing advice, timing, meeting the requirements of advice, customer information needs, fair value and refund policy.

Why does TCC compare this to PPI and pension review cases?

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.

Who can help firms address these topics?

TCC, working with its sister company Recordsure, offers advisory, managed services and AI-based tools to review, manage and evidence ongoing advice.

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