Compliance Matters: Week ending 20th March 2026

Here is a digest of issues that have come across my desk this week.  Just two topics this week. 

• Annual Client Reviews (or are they)

• Creating a redress system that works better for consumers and firms

Annual Client Reviews (or are they)

Why not begin this week’s digest with controversy. 

“There is an argument that we need to rethink annual client reviews to ensure that more clients receive the advice they need.”  These are the words of Phil Billingham at Perceptive Planning writing in Citywire.

Firstly, consider the word ‘review.’  The Oxford Languages Dictionary defines a review as “a formal assessment of something with the intention of instituting change if necessary.”  So far, so good, that is the reason for arranging the review meeting with our client.  Are we really carrying out a review, or are we conducting a forward planning meeting?

This is what the FCA requires from suitability reviews.

1. Annual requirement: the suitability of the client’s portfolio must be reviewed at least every 12 months, or more frequently based on client risk.

2. Documented evidence: reviews must be clearly documented, with a copy sent to the client.

3. Components of a review: must include up-to-date information on

   1. the client’s objectives,

   2. their financial situation,, and

   3. risk profile/capacity for loss. 

4. Ongoing fees: charging fees for ongoing advice without delivering a genuine, evidenced review is non-compliant.  We are required to confirm the fees a client has been charged for both our advice and the products we manage for them.

Consider point three.  It is the same criteria as that required for the initial advice.  And advice is always about the future, hence it is a future planning meeting.  Instead of simply asking, ‘Have your circumstances changed?’ a better opening question would be, ‘Are your plans, objectives and circumstances likely to change over the next 12 months or so?’  There is an argument that the only thing in a client’s circumstances that is guaranteed not to change in clients’ lives is their date of birth.

Clients should be getting new, fresh, and relevant advice every year, with their adviser making sure they are on track to meet their objectives and allowing for action to be taken if life changes mean objectives and circumstances alter. 

That has to be good for those who are already clients.  But for planners, this is potentially a constraint on capacity.

If the majority of a firm’s income is ongoing fees, and almost 100% of its value is based on ongoing fees, then annual reviews or planning meetings are what we do.  Future planning meetings will provide opportunities for the investment of further monies by maximising pension or ISA contributions and tax planning products when there is no further capacity to invest in pensions or ISAs

To deliver reviews or forward planning meetings effectively, all members of the team must have a role to play, not just the adviser.  Paraplanning and administration are key to delivering a quality service to our clients.  Additionally, can we engage clients with the process by, say, the use of the portal within IO to allow them to update their circumstances in advance of the meeting.  This will give vital information to paraplanning and administration when preparing review packs.

Our challenge is to create a process of client engagement where all clients seek and value our ongoing planning meetings, and cheerfully pay the fees required to make that happen.  Positive engagement with the back-office will assist.  Clients who are used to communicating with administrators and paraplanners will appreciate the infrastructure that sits behind their adviser, and this includes telephone calls.  This creates capacity for advisers to spend more time with clients discussing their financial plans.

I prefaced this with a warning of controversy, but more importantly, food for thought.

Creating a redress system that works better for consumers and firms

The FCA has published an update on the joint work it has carried out with the Financial Ombudsman Service and the Government to  modernise the redress system.  

The FCA’s aim has been to improve alignment, predictability, and early engagement across the system – while maintaining strong and effective consumer protection. 

For our clients, this means a smoother and more effective journey when problems arise, with complaints handled promptly by their financial services firm, and fair and fast compensation where it is due. 

For firms, greater alignment between the FCA and the Financial Ombudsman, alongside clearer routes for early engagement when issues arise, should provide more confidence and predictability.