What risks remain for firms following the FCA’s ongoing advice review findings?

What happened?

On 19 March 2025, TCC’s Chief Commercial Officer and Chief Product Officer, Garry Evans, was joined by regulatory experts Gary Maude and David Boyhan for a webinar on the Financial Conduct Authority’s ongoing advice review findings.

The session covered how firms can deliver ongoing advice services with the appropriate evidence, the quality of ongoing advice reviews, the clarity of client chronology, and the importance of a backward-looking review alongside preparation for the future. Disengagement strategies and the wider ripple effect of poor ongoing servicing were also discussed.

The webinar was split into three parts covering the scope of the FCA’s review, next steps for wealth managers, and the long-term compliance implications for the sector.

Why does it matter?

Firms that cannot evidence the ongoing advice service a client has actually received are exposed when the FCA asks for proof, not assurance. The topics raised in the webinar point to specific gaps regulators are likely to probe, from unclear client chronology to weak disengagement processes.

A poorly evidenced ongoing advice proposition can affect more than one client file: issues identified in a backward-looking review often point to systemic weaknesses with a wider ripple effect across a firm’s client bank.

Who is affected?

Wealth managers and financial advice firms that charge for ongoing advice services, along with the compliance and advice quality teams responsible for reviewing and evidencing that service.

Key risks

• Ongoing advice reviews that lack clear, contemporaneous evidence of the service delivered.
• An unclear chronology of client contact and reviews over time.
• Disengagement processes that are not documented or consistently applied.

Actions to take

1. Review how ongoing advice service delivery is currently evidenced against FCA expectations.
2. Check that client chronology and review history are clear and complete.
3. Confirm that disengagement processes are documented and applied consistently.

Recommendations

Firms unsure whether their ongoing advice evidencing would satisfy FCA scrutiny should treat this as a priority review area, drawing on independent regulatory expertise where in-house resource or experience is limited.