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Firms Asked For Details About Ongoing Consumer Duty Services


The FCA is writing to a number of financial adviser firms requesting information about their delivery of ongoing services for which their clients continue to be charged after advice has been given.

An FCA survey asks whether firms have assessed their ongoing services in response to the introduction of the Consumer Duty, and whether they have made any changes as a result. It also asks for data on the numbers of clients due a review of the ongoing suitability of the advice as part of the service, how many have received that review, and how many have paid for ongoing advice but had their fee refunded as the suitability review did not take place.

The FCA is collecting this information to assess what, if any, further regulatory work it may need to undertake in this area. The FCA anticipates providing a further update once it has considered the firms’ responses.

Around 20 of the largest advice firms have received the survey in an attempt to gain the widest possible understanding of market practice. The FCA has stressed that their selection is not based on any particular concerns over those firms.

In a letter sent in December 2022, the regulator had indicated that it would undertake cross-firm work in this area. At that time, the FCA set out its concern that advice firms were not adequately considering the relevance, nature and costs of ongoing services for all their clients.

Another letter sent in January 2023 explained how advice firms should approach the Consumer Duty, reminding firms that it requires them to act in good faith towards customers, avoid causing them foreseeable harm, and support them in pursuing their financial objectives.

In a Consumer Duty webinar with firms in December 2023, the FCA flagged concerns that some consumers might be paying for a service, such as an annual review, but not receiving it.

The new survey forms part of the FCA’s efforts to raise standards so that people can invest with confidence. Central to that strategy is ensuring that people can access advice if they want it and have trust in the services on offer.