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Insights and analysis

Practical thinking on outsourced reviews, regulatory change, and IFA operations.

CP26/10 has closed. Waiting for Q4 is the most expensive option

The CP26/10 consultation closed on 22 May 2026. The policy statement is not due until Q4, and nothing in the rulebook has changed. Firms reading the consultation as permission to ease off the long tail face a board report on 31 July, six live fair-value investigations, and an evidence gap that compounds every month.

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We filed our CP26/10 response. Here is what it says.

Pillar Client Services has filed its CP26/10 consultation response, ten days before the FCA deadline. Three arguments, two exhibits, one operational data point. Download the full PDF.

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Targeted Support is live. Your sub-threshold clients are now somebody else's market

Targeted Support went live on 6 April 2026. Banks, platforms and asset managers can now make ready-made recommendations to consumers without giving regulated advice. For IFA firms carrying hundreds of sub-threshold clients on ongoing fees, this is a commercial threat that has not been priced in yet.

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CP26/10 and periodic reviews: what IFA firms need to know now

The FCA wants to replace annual reviews with periodic reviews. Most firms think that means less work. It means the opposite. Here's what the consultation actually proposes and what firms should do now.

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Your annual review file wouldn't survive a Section 165 request

The FCA isn't checking whether you have a process. They're checking whether your files contain actual evidence. A file note that says "annual review conducted, no changes" tells the FCA nothing.

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Launch client results: what structured reviews actually produce

Structured reviews running live at our launch client, an FCA-authorised IFA firm: 200 reviews completed, a 5% escalation rate, 90% QA pass, and £55,000 of new revenue handed to the firm.

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Consumer Duty and annual reviews: what firms need to evidence in 2026

The FCA found 17% of firms are not delivering annual reviews to clients paying ongoing fees. Section 165 data requests are already landing. If your files cannot evidence what was discussed, what changed, and what action was taken, your firm is exposed.

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The true cost of annual reviews in UK advice firms

A 200-client firm spends up to six figures a year on adviser-led annual reviews that generate zero additional revenue. There is a structural fix that cuts that cost significantly without compromising compliance.

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CP26/10 updates, Consumer Duty guidance, and practical advice for IFA firms. No spam.