The FCA’s recently published findings of a multi-firm review of the fair price and value assessment process across CFD providers have revealed systematic gaps in how providers carry out essential processes.
The FCA has published the findings of a multi-firm review into the fair price and value assessment process across CFD providers. The findings reveal systemic gaps in how providers carry out this essential process and set expectations for firms operating in this high-risk space.
The FCA’s multi-firm review assessed how CFD providers deliver fair value to retail clients. While some firms demonstrated good practice in this area, the overall picture was mixed:
- Some firms made few or no adjustments to their products or services after the Consumer Duty came into force, raising concerns about their compliance culture. Notably missing was regular appropriateness testing, especially for vulnerable clients.
- Fair Value Assessments often focused on a few financial value metrics but failed to take into account wider financial metrics such as counterparty hedge pricing and overnight funding charges. Non-financial value metrics, such as complaints and satisfaction metrics, were not adequately considered.
- Board reports often restated Consumer Duty requirements without providing a meaningful analysis of whether the firm met them.
The regulator is increasingly tightening its expectations on firms’ compliance with the Consumer Duty. CFDs are an area of particular regulatory concerns due to their high-risk nature and accessibility to retail clients, however, all FCA authorised firms should aim for all their business processes to reach, at a minimum, the standards suggested by the FCA’s examples of good practice.
This means that firms must be able to demonstrate an ongoing commitment to delivering good outcomes for clients. Where firms fail to meet this, they should expect enhanced regulatory scrutiny in the short term.
How Thistle can help
- We can help your firm to prepare for board meetings to ensure the correct level of Consumer Duty analysis is provided to the board for discussion.
- We can help you enhance your firm’s vulnerable clients' policies and procedures.
- We can assist your firm in documenting and justifying its fair value assessments to ensure they incorporate a full range of financial and non-financial metrics.
Meet the Expert
Melissa Buckingham, Compliance Consultant 
Melissa joined Thistle Initiatives in 2025, bringing with her a strong background in managing conflicts of interest and cross-border regulatory activity from her time at a Tier 1 bank.
With a deep understanding of both the regulatory landscape and operational pressures facing firms, Melissa adopts a thorough and detail-oriented approach to helping clients achieve and maintain compliance.
She supports clients across a range of sectors, but primarily in the investments and wealth management space.