How to stay ahead of FCA demands and unlock AI’s potential for wealth management compliance

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.