Q&A: The important insights from the FCA’s ongoing advice review findings

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.