Evolving landscape of FCA Consumer Duty compliance regulations: a comprehensive guide for financial advisers

May 31st '24

In the rapidly shifting terrain of financial services, the Financial Conduct authority (FCA) continues to underscore its commitment to fostering trust and robust competition within the retail financial services markets. This commitment manifests in its recent focused assessments on the financial advice and wealth management sectors, highlighting key areas such as Consumer Duty, vulnerable customer identification, and retirement income advice. The aim is clear: to elevate industry standards and ensure firms prioritise excellent customer outcomes.


The imperative of the annual board report

July 2024 marks a significant milestone for firms under the FCA’s purview, with the inaugural Consumer Duty annual board report due. This requirement isn’t merely a procedural formality but a crucial document reflecting a firm’s dedication to achieving and enhancing customer outcomes across four defined duty outcome areas. Unlike traditional compliance exercises, this report demands a demonstrative action plan detailing both current successes and targeted improvements, thus avoiding the pitfalls of a compliance-led or superficial engagement.


Constructive challenges and executive accountability

For a board to effectively oversee and influence firm conduct, it is essential that the Consumer Duty champion and other board members actively challenge the executive’s strategies. This process ensures that the pursuit of compliance is integrated with genuine customer-centric initiatives, rather than being a mere tick-box exercise. Boards should focus on setting actionable goals that are measurable and directly tied to customer benefits, fostering a culture of continuous improvement.


Enhancing support for vulnerable customers

  • Identifying and addressing needs

The FCA has expressed concerns regarding the industry’s attention to vulnerable customers—a demographic that is surprisingly large yet frequently overlooked. Recent surveys indicate that a significant portion of the uk adult population exhibits characteristics of vulnerability, yet many do not self-identify as vulnerable, complicating compliance efforts. Financial institutions must develop more sophisticated methods for identifying and supporting these individuals, ensuring that their products and services are accessible and appropriate.


  • Operationalising empathy: staff training and product design

Effective support for vulnerable customers extends beyond identification; it requires a transformation in staff training, product design, and customer interactions. Firms should invest in comprehensive training programs that enhance staff understanding and responsiveness to the nuanced needs of vulnerable clients. Moreover, product and service offerings should be designed with the flexibility to accommodate diverse circumstances, ensuring that all customers receive tailored and effective financial solutions.


Retirement income advice: ensuring suitability and sustainability

  • Addressing poor advice practices

The transition to retirement is a critical financial phase for consumers, yet the FCA has identified widespread deficiencies in retirement planning advice. Firms are urged to reevaluate their advisory processes and employ tools, such as the newly introduced income requirement calculators, to better tailor their recommendations to individual financial situations. This approach helps ensure that advice provided is both suitable and sustainable, aligning with the clients’ long-term retirement goals.


Ongoing monitoring and annual client reviews

  • The criticality of timeliness and relevance

Advisers are mandated to conduct annual reviews, ensuring that clients’ investment strategies remain aligned with their evolving needs. However, the FCA has flagged concerns about the timeliness and completeness of these reviews. Firms must prioritize regular client engagements and recalibrate their focus to include all clients—not just the new or more vocal ones. This ensures a uniformly high standard of advisory service across the board.


Addressing the challenge of high-charging investment funds

  • Balancing cost and value

The scrutiny over high-charging investment funds is intensifying, with the FCA questioning the suitability of such expenses for customers who may benefit from simpler investment strategies. Firms must critically assess their investment portfolios and fee structures to ensure that they are justified by the value delivered and aligned with the clients’ best interests.



The landscape of FCA regulation is both complex and dynamic, requiring a proactive and informed response from financial advisers and wealth management firms. By embracing these guidelines and transforming them into strategic actions, firms can not only comply with regulatory expectations but also lead the way in setting high industry standards, ultimately securing both client satisfaction and operational success.


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LS Consultancy is a Affiliate Member of the Consumer Duty Alliance, which is an independent, ‘not-for-profit’ professional body. It aims to support the personal finance sector in the adoption and implementation of the FCA’s Consumer Duty requirements through the alliance of like-minded individuals and firms.


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