What happened?
TCC and Recordsure launched an ‘AI for compliance’ webinar series with a session on suitability reviews. A live poll found that 42% of firms needed to rework between 10% and 20% of advice files after a suitability review, 29% reworked 20 to 30%, and 29% reworked fewer than 10%.
David Boyhan, TCC’s Technical Director, set out the FCA’s risk-based approach to sampling, referencing comments from Lucy Castledine, the FCA’s Director of Consumer Investments, at the PIMFA conference.
Why does it matter?
Even where checks and balances exist, many cases initially carry an unclear rating, pulling advisers away from client work and delaying evidence that advice was suitable.
The FCA expects firms to sample around 10% of files, with higher volumes for higher-risk areas such as new advisers or complex products like drawdown and VCTs, and for both new and ongoing advice to be reviewed.
Who is affected?
Compliance and paraplanning teams responsible for file review, and advisers whose files are rated unclear or unsuitable and need a route back to suitability.
Key risks
- Persistently high rework rates, with some firms historically seeing over 30% of cases need revisiting.
- Sampling models that focus only on new advice and overlook ongoing advice reviews.
- Feedback that is reported but not acted on, so it fails to change adviser behaviour.
Actions to take
- Apply a risk-based sampling model, reviewing around 10% of files with higher volumes for higher-risk areas.
- Review both new business and ongoing advice files for suitability, not just new recommendations.
- Give advisers a clear, actionable pathway back to suitability for every file rated unclear or unsuitable.
- Use case clinics, workshops and training to turn review findings into behavioural change.
Wider implications
Firms working with TCC on this approach have seen their right-first-time rates improve from the low 60s to nearly 90% over ten months, showing that structured feedback can drive lasting change when advisers act on it.
Recommendations
Combine risk-based sampling with a collaborative review process: case clinics, best-practice workshops and commentary on Consumer Duty outcomes give advisers and paraplanners the context they need to improve, not just a rating.
Supporting sources
Frequently asked questions
How many advice files typically need rework after a suitability review?
In TCC and Recordsure’s poll, 42% of firms reworked between 10% and 20% of files, 29% reworked 20 to 30%, and 29% reworked fewer than 10%.
What does the FCA expect on risk-based sampling?
The FCA expects firms to focus monitoring on higher-risk interactions, with a general benchmark of around 10% of files sampled and higher volumes for higher-risk areas such as new advisers or complex products.
What results has TCC's review process delivered?
Firms working with TCC over the past ten months have seen their right-first-time rates improve from the low 60s to nearly 90%.
- FCA remuneration reform explained: what CP26/27 could mean for firmsAnalysis & Perspectives · September 2, 2026
- IBS Intelligence: Why financial services firms face growing AI governance scrutinyAnalysis & Perspectives · September 2, 2026
- FCA CP26/28: What the AIFM regime reforms mean for wealth managers and firmsRegulatory Horizon · September 2, 2026
- Will Value for Money assessments change how advisers compare pension providers?Regulatory Horizon · September 2, 2026