Financial Services Compliance Blog - Thistle Initiatives

FCA Consolidator Review: Why Post-Acquisition Integration Now Determines M&A Success

Written by Sam Coe | Nov 20, 2025 10:49:09 AM
As consolidation continues across the wealth management and advice sector, the FCA’s recent Consolidator review has highlighted avoidable risks that are emerging after an acquisition.
 
Following our recent summary of the FCA’s Consolidator Review, one message is becoming increasingly difficult to ignore: the real risks in consolidation are emerging after the acquisition, not before it.
 
While acquisitions can deliver scale and growth, weaknesses in governance, integration planning and debt structures are creating avoidable risks. These include poor client outcomes, weakened financial resilience and gaps in oversight.  
 
As consolidation continues across the advice and wealth management sector, the regulator is now paying close attention to what happens after the contracts are signed.
 
Post-Integration is Now the Critical Phase
 
The FCA highlighted several areas where post-deal execution is falling short, including:
 
  • Regulatory oversight is not keeping pace with rapid growth.
  • Weak integration of systems, processes and clients/staff leads to poor outcomes and an underestimation of the challenges surrounding this.
  • Insufficient MI and outcomes monitoring across group structures.
  • Cultural misalignment between acquired firms and parent groups.
  • Conflicts of interest are not being properly identified or mitigated.
  • Weak governance structures across acquired entities.
  • Insufficient oversight of advisers and advice processes post-acquisition.
  • Financial arrangements (e.g. debt and guarantees) that increase stress on the group.
In practice, this means that even well-structured acquisitions can fail to deliver value if integration is rushed, inconsistent or poorly governed. Those taking a structured approach are more likely to deliver positive customer and commercial outcomes. Those who treat consolidation as a pipeline of deals to aid growth rather than a strategic operating model struggled.
 
Firms must be able to evidence how post-deal decisions protect clients, support long-term resilience, and align with Consumer Duty Expectations.
 
Managing Sustainable Integration
 
As consolidators grow, the challenge is no longer just about executing a transaction, it is achieving a level of operational, cultural and regulatory alignment that stands up to regulatory scrutiny and enables good customer outcomes.  
 
Successful integration requires:
 
  • Clear Day-1 planning
  • Strong MI and governance across all entities
  • Cultural and operating model consolidation
  • Effective client communication and service continuity
  • Robust oversight of risk, incentives and conflicts
This is the standard the FCA expects, and it is where many organisations continue to fall behind.
The firms that will succeed over the next 2-5 years will be those that can integrate consistently, govern effectively and maintain adviser and staff engagement, ultimately driving consistent or better customer outcomes than before.  
 
Firms that demonstrate value and safeguard outcomes as opposed to ‘completing integration’ as a tick box exercise will thrive. This is where structured integration becomes a differentiator.
How Thistle Initiatives Can Help
 
Thistle Initiatives has developed a specialist M&A and Integration capability supporting all our FS clients. We support firms through:
 
  • Acquisition strategy and sell-side readiness
  • Regulatory Due Diligence
  • Commercial & Operational Due Diligence
  • Operating model and cultural integration
  • Day-1 planning and post-merger integration and delivery
  • Risk, governance and client outcome oversight
  • Regulatory alignment between firms
  • Assurance & Readiness
  • Governance and Value Realisation
Our objective is simple: help firms grow through acquisition in a way that is sustainable, compliant and genuinely value-accretive.
If your firm is preparing for an acquisition, working through integration, or seeking assurance on your group controls, we’d welcome a conversation about how we can support your next steps.

Meet the Expert

Sam Coe, Partner 

Sam has 14 years’ experience leading large scale change and transformation programmes in the Financial Services industry, working with several Tier 1 institutions across Banking, Insurance and Wealth and Asset Management (e.g. HSBC, Barclays, Aviva). Sam started his career at KPMG before moving to Capco in 2017, where he was part of the Banking and Payments Leadership Team. He has since spent time at Elixirr helping to grow the UK Financial Services vertical before joining Thistle.

He has led numerous Regulatory Change programmes including remedial responses to S166, Consumer Duty and Operational Resilience. As well as this he also has vast experience delivering pre and post deal transformation programmes related to M&A activity such as new target operating model design and implementation and post-merger integration. Other experience includes Digital Transformation and Operational Efficiency where Sam has led programmes saving millions in cost for the organisation.

 

 
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